The HACCP Conundrum

The Food Safety Modernization Act is in full implementation mode and food manufacturers are, in some cases, franticly preparing for the FDA to walk through the door with clipboard in hand and inspection glasses hanging down their noses. To prepare for these regulatory visits, many food manufacturers are building Preventive Controls Plans and ensuring that the hazards they have identified in their hazard analysis are controls by one or more of the preventive controls.

So where does that leave HACCP? Does HACCP just go away? Should we continue to work within our HACCP Plan or just toss it out as old news? Do I still need to get HACCP Certified? These are some of the questions that our clients are posing to us and they want answers.

First, and perhaps the easiest of questions, yes, you must still comply with your HACCP Plan. The Preventive Controls Food Safety plan is basically an extension of your HACCP Plan. Your critical control points will still need to be monitored just as they are today but with the new Preventive Controls plans, we take that a step further by including sanitation, allergens and supply-chain. Your HACCP critical control points simply convert to what is now known as a “Process Control”. You will still do your identification of critical limits, monitoring, verification and record keeping.

Second, we know that certain industries will still fall under regulatory HACCP Regulations, this does not change. Here is a brief list of some of those regulations:

• Meat, Poultry and Siluriformes
• Seafood
• Juice
• Low Acid Canned Foods
• Dairy HACCP

Prior to the passing of the Food Safety Modernization Act, the food industry was and still in the process of implementing customer required Global Food Safety Standards. These include SQF, BRC and FSSC22000. Each of these standards were developed outside of the United States, therefore, they require that you have a HACCP Plan in place. Hence, the conundrum.
There are two options:

1. Keep your HACCP Plan as it was written and write an additional Preventive Controls Food Safety Plan.
2. Combine your HACCP and Preventive Controls Food Safety Plans.

Now, we have seen success with both options, so it really depends on your organization, the products you are producing and the regulations you must follow. Obviously if you are working in a facility where you are required to have HACCP and Preventive Controls due to the nature of the products you produce, naturally option 1 will work best for you.

However, if you are working in a facility who need only meet FSMA Preventive Control Regulations and a Global Standard, it might make more sense for you to go with option number 2. In this case, just be sure to express your process controls as CCP’s in the plan.

We know and we ask ourselves, wouldn’t it be easier if every food manufacturer just followed the same system? Of course it would and we hope that that will be the case one day but for right now, we have to meet what is required!

Since HACCP is a requirement for your Global Standard, you must also have folks that are HACCP Certified on your food safety team. Safe Food Resources offers International HACCP Alliance certified courses with seals issued a few times a year in our professional training center and we encourage you and your HACCP team members to take our course. It is fun, informative and has small class sizes for maximum learning.

It’s not just additional training, it is that stepping stone to the Preventive Controls, after all, in a two-day course with loads of information, how much do you really retain. Wouldn’t it be nice to have a starter course like HACCP to begin your teams journey to a more confident, educated workforce? Let’s take this journey together. After all:

We Create Food Safety Heroes!™

Contact us at 262-289-9526 and say “I’m a Food Safety Hero”. You just might find yourself with a discount!


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