HACCP alone won’t cover you for key rules under the Food Safety Modernization Act.
It’s unsurprising that modern food safety regulations would bear a resemblance to Hazard Analysis Critical Control Point (HACCP). Even though it first showed up in food manufacturing in the 1960s, HACCP is still our basic food safety model.
Hazard Analysis Risk-Based Preventative Controls (HARPC) looks a lot like HACCP on the surface. But having a HACCP plan does not mean you’ll comply with HARPC requirements under the Food Safety Modernization Act (FSMA).
Section 103 of the FSMA Preventative Controls, includes:
- Preventative Controls for Human Food
- Preventative Controls for Animal Food
- Mitigation Strategies to Protect Food from Intentional Adulteration
To comply with rule #1 and 2 you need HARPC. HARPC covers products that fall under the FDA’s jurisdiction (with the exception of seafood and juice, which are already covered by HACCP standards).
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