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WHEN TO HACCP
AND WHEN TO HARPC
Hazard Analysis and Critical Control Points (HACCP) and Hazard Analysis and
Risk-Based Preventive Controls (HARPC) share more than just four letters.
They’re both food safety standards based on
prevention, but they do differ on execution.
Their differences and similarities aren’t as
important as the way they fit together for most food
processors. A HARPC plan shouldn’t be considered
as a replacement, but as a necessary upgrade to the
conventional HACCP plan. Understanding how the
systems fit together is the first step toward implementing
both.
HARPC as an Upgrade to HACCP
HACCP is already widely used due to requirements
from retailers, auditing standards and inspectors,
although the US Department of Agriculture (USDA)
and the US Food and Drug Administration (FDA) only
mandate it for meat, seafood and juice products.
HACCP has been continually developed and updated.
It requires a multi-disciplinary team for implementation
and follows prescriptive steps.
HARPC covers food safety concerns beyond CCPs
and is mandated by FDA for most facilities, with
some exemptions. Instead of only looking at process
steps where controls can be applied, HARPC relies
on the applicable FDA regulations, standards and
guidance documents to develop a preventive control
plan.
How HACCP Works
HACCP is a globally recognised, risk-based preventative
approach recommended by the Codex Alimentarius
Commission (Food Code) and the National
Advisory Committee on Microbiological Criteria for
Foods. The primary goals are to prevent occurrences
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of the hazard, or eliminate or reduce the food safety
hazard to acceptable or safe levels. HACCP plans
are developed, implemented and maintained by a
multi-disciplinary team. Even though HACCP programmes
for food establishments may be voluntary
(unless specified by regulations, industrial standards
or customers), it does not absolve a facility from
implementing Current Good Manufacturing Practices
and other relevant prerequisite programme requirements
necessary to maintain the safety and legality
of the food products. Auditors, inspectors, customers
and other stakeholders may inspect the HACCP or
food safety plan.
How HARPC Works
In brief, this preventive control system mandated
by FDA’s Food Safety Modernisation Act (FSMA)
is to be implemented by all food establishments
unless specifically exempted. Thus, it applies to food
facilities in the US that manufacture, process, pack,
distribute, receive, hold or import food, and to those
firms exporting foodstuffs to the US. Preventive
controls are science-based and adequate to significantly
minimise or prevent identified hazards ‘known
or reasonably likely to occur’ for each type of food
subject to the relevant FDA regulation. The HARPC
plan is developed, implemented and maintained by
a team of ‘preventive controls-qualified individuals’
as defined in FSMA, who have been trained or are
sufficiently conversant with the FSMA Preventive
Controls for Human Food rule and any other relevant
FSMA regulations.
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Recap of Key Differences
between the Hazard Analysis
Methods
The three conventional types of hazards that are
addressed in HACCP plans—physical, chemical and
biological—are accompanied by many more concerns
in HARPC plans. Radiation, natural toxins, pesticides,
drug residues, decomposition, parasites, allergens,
unapproved food or colour additives, naturally occurring
hazards, and intentionally and unintentionally
introduced hazards round out the list of HARPC-related
hazards.
CCPs versus Preventive Controls
CCPs during process steps are central to HACCP.
Each control point must include measurable critical
limits—the temperature and length of time a sauce
must be held at, for example, to be considered a kill
step. The objective of each control step is to prevent,
eliminate or reduce food safety hazards to a safe and
acceptable level. Food safety measures that aren’t
specific to the process, such as personnel hygiene,
are covered under Standard Operating Procedures.
HARPC focuses on preventive controls that are
science- or risk-based, and should be adequate to
‘significantly minimise or prevent’ known or foreseeable
hazards for each type of food subject to the
federal regulations.
By Remco Products
F A C T O R Y
To learn more about HACCP and HARPC,
contact Remco at cs@remcoproducts.
com or www.remcoproducts.com
/www.foodtechnology.co.nz
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