FSMA Fridays: The Top 5 FSMA Challenges And What You Should Be Doing To Prepare (Part Four Of Four)

Check out Part 1, Part 2, and Part 3 of this series

In the third portion of FSMA Fridays: The Top 5 FSMA Challenges And What You Should Be Doing To Prepare, Levin and the Acheson Group panel discussed the requirements of recordkeeping within FSMA and what companies should be doing now to prepare. The panel also began answering questions from the webcast’s live audience. Here, in the fourth and final part of the series, the panel will continue handling questions from the webcast’s live audience.

Barbara: David, a question from Noah. “In terms of HARPC, is this going to be very different from the pre-requisite programs as defined in ISO2200?”

David: Great question. Fundamentally, no, it’s not that different. What’s different about it in our view is about recognizing that some parts of your prerequisite programs will need to be, in my words, elevated, to more of a thorough preventive control-type approach to be put into your food-safety plan. There’ll be things in your prerequisite programs that you’re doing now, which will just need to move into your food -safety plan, some things in your prerequisites won’t.

If you move them up into the food-safety plan, because they are controlling a significant hazard, you’ll need to document in your food-safety plan what you’re monitoring procedures are, what your corrective actions will be for those “old prerequisite programs” that need elevated to HARPC. I think the burden around these for monitoring, for corrective actions, documentation, for verification to validations, etc… will just get elevated. Things that were important, but they were always just going on in the background; there’ll be more focus on them. So it’s not fundamentally different from prerequisites, it’s just elevating some prerequisites, in my belief, to a higher level of visibility, documentation, monitoring, etc…

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