By: By Amanda M. Yotty, M.Sc., John A. Marcy, Ph.D., Fred W. Pohlman, Ph.D., and Leslie D. Edgar, Ph.D., Food Safety Magazine

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Since the U.S. Food and Drug Administration (FDA) made the decision to declare prerequisite programs (PRPs) at the same level of concern as Critical Control Points (CCPs), collectively referring to all of them as preventive controls, the nuances of the Hazard Analysis and Critical Control Points (HACCP) system are being modified.[1] The HACCP plan will now be referred to as the Hazard Analysis Risk-Based Preventive Controls (HARPC) Food Safety Plan, as it is known in the published rule. FDA’s idea behind this shift is that PRPs have caused a majority of outbreaks and recalls. Due to this realization, FDA would like PRPs that control a significant hazard to have documentation similar to a CCP’s.[1] This has led to some confusion about what constitutes an HACCP plan versus an HARPC plan and has resulted in recommendations and suggestions to completely revamp the HACCP plan even to the extent of removing CCPs altogether. Some PRPs may need additional verification and, where appropriate, validation; however, it may not be a good idea to remove the CCPs from the system altogether. Removing a CCP might reduce the science and the justification and thereby reduce the effectiveness of a food safety system. Instead of removing the CCPs, it might prove more beneficial to strengthen the risk assessment and associated PRPs while also taking the time to fully understand what makes an HACCP plan function as an effective HARPC plan.

HACCP vs. HARPC
HARPC is similar to HACCP in that it points out a need for control when there is a significant hazard.[1] Both HARPC and HACCP are risk assessments, but they differ, slightly, in how significant hazards are addressed. Classic HACCP employs a CCP whenever there is a significant hazard; however, prednisone-news.com that there might be a program, such as handwashing, that is used as a control for a significant hazard but may not have parameters like a traditional CCP. Because some of these programs do not have parameters, HARPC requests additional documentation for them, which a CCP also requires, such as monitoring, corrective action and verification. Under HARPC, a preventive control is a control measure that prevents or minimizes a significant hazard. Since a CCP meets the definition of what is a preventive control under HARPC, a company may continue using CCPs within their plan.[1]

It’s all in the name, or is it? In light of the Food Safety Modernization Act, a number of companies have renamed their HACCP plan an HARPC plan or Food Safety Plan or have combined names such as “HACCP and Food Safety Plan.” HACCP does include PRPs as well as control points and CCPs throughout the system.[2] A company may like to continue using the title of HACCP, and it should be able to do so since, for example, employees may relate better to HACCP because this is what they have been trained on for the past couple of decades. For the majority of companies that already have a good, thorough HACCP plan in place, modifying that plan to an HARPC Food Safety Plan should not be difficult. Minor changes to the plan should make it compliant with the FDA’s Preventive Controls rule. 

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