Hazard analysis and risk-based preventive controls: Difference between revisions

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*HARPC plans rely on Prerequisite Programs such as GMPs, allergen controls, [[Integrated Pest Management]] and vetting suppliers far more than HACCP plans, since these programs tend to be preventive.<ref>{{cite news |last1=Yotty |first1=Amanda M. |last2=Marcy |first2=John A. |last3=Pohlman |first3=Fred W. |last4=Edgar |first4=Leslie D. |issue=December 2015/January 2016 |title=How Food Companies Can Modify Their Existing HACCP Plans into an All-Encompassing Food Safety Plan |url=http://www.foodsafetymagazine.com/magazine-archive1/december-2015january-2016/how-food-companies-can-modify-their-existing-haccp-plans-into-an-all-encompassing-food-safety-plan/ |newspaper=Food Safety Magazine |___location= |access-date= 4 May 2016}}</ref><ref>{{cite news |last=Surak |first=John G. |issue= August/September 2014 |title=PROCESS CONTROL: A New Paradigm for Validation, Verification and Monitoring |url=http://www.foodsafetymagazine.com/magazine-archive1/augustseptember-2014/a-new-paradigm-for-validation-verification-and-monitoring |newspaper=Food Safety Magazine |___location= |access-date=6 May 2016 }}</ref>
*HARPC covers radiological hazards in addition to the chemical, biological and physical hazards covered by HACCP systems.<ref>{{cite news |last=Lindstrom |first=Eric |date=13 March 2013 |title=Do you know your HACCP from your HARPC? |url=http://www.foodprocessing.com/articles/2013/fda-haccp-harpc |newspaper=Food Processing |___location= |access-date=2 May 2016}}</ref>
*HARPC explicitly requires a [[Food Defense]] component, with both [[terrorism]] and [[Economically Motivated Adulteration]] addressed. Businesses with less than $10,000,000 a year in sales are exempt.
*HARPC de-emphasizes Critical Control Points in favor of Preventative Controls. Preventive Controls do not require specific Critical Limits.<ref>{{cite web |url=http://retailfoodalliance.com/html/HACCP%20vs%20HARPC.pdf |title=The FDA’s Food Safety Modernization Act (FSMA): Its requirements for Hazard Analysis and Risk-based Preventive Controls (HARPC) in the Proposed Preventive Controls Rule for Human Food |last1=Davis |first1=Steve |date=April 2014 |website=retailfoodalliance.com |publisher=Wholesale & Retail Food Alliance |access-date=2 May 2016 |quote=Although this proposed rule aligns well with HACCP, it differs in part in that preventive controls may be required at points other than at critical control points and critical limits would not be required for all preventive controls.}}</ref>
*HARPC allows Corrections in place of Corrective Actions when the public health is not threatened.<ref>{{cite news |last1=King |first1=Hal |last2=Ades |first2=Gary |issue=October/November 2015 |title=Hazard Analysis and Risk-Based Preventive Controls (HARPC): The New GMP for Food Manufacturing |url=http://www.foodsafetymagazine.com/magazine-archive1/octobernovember-2015/hazard-analysis-and-risk-based-preventive-controls-harpc-the-new-gmp-for-food-manufacturing |newspaper=Food Safety Magazine |___location= |access-date=2 May 2016}}</ref> Corrections are not as strict regarding paperwork as Corrective Actions. The FDA believes that companies might have been avoiding making minor improvements because they felt that the paper trail of a Corrective Action would open them to legal risk due to [[Discovery (law)|discovery]] during investigations or lawsuits.