Do you know the difference between a HACCP Plan and a Food Safety Plan? Do you know if your facility requires a designated Preventive Controls Qualified Individual or HACCP Trained Individual? Jeff Chilton, VP of Professional Services at Alchemy Systems answers frequently asked questions and more.
1. Which food sectors are mandated by regulatory agencies to comply with HACCP regulations and which ones are mandated to comply with Preventive Control for Human Food regulations?
Under the USDA inspection, all meat and poultry companies are mandated to comply with the HACCP regulations.
Under FDA jurisdiction, juice products and seafood products are mandated to comply with the HACCP regulations.
All other food sectors that are required to register with the FDA, other than exempt sectors such as alcoholic beverages and dietary supplements, are mandated by regulatory agencies to comply with Preventive Control for Human Food regulations. This includes facilities located within and outside of USA.
2. What if my industry is not mandated to comply with a HACCP regulation such as alcoholic beverages or dietary supplements?Exempt food sectors are recommended to have a food safety system based on HACCP principles. This may be a requirement for the company if they are audited by a third party.
3. Who should take PCQI training for the Preventive Controls for Human Food Course?All facilities that must comply with the FSMA Preventive Controls for Human or Animal Food should have at least 1 designated PCQI. It is recommended that the facility have more than one individual receive PCQI training to ensure adequate coverage in the absence of key personnel, and also to ensure competency of food safety team members.
4. Who should take Basic HACCP training?
In USDA facilities, it is required that the person who writes or reassesses the HACCP Plan receive HACCP Training. For SQF facilities, the SQF Practitioner is required to have HACCP Training. Otherwise, HACCP training is recommended for all food safety professionals.
5. Who should take Advanced HACCP Training?Individuals who have had prerequisite HACCP training and QA Management personnel responsible for food safety should take Advanced HACCP training. It is also recommended for individuals who haven’t had basic HACCP Training in many years. The Advanced HACCP Training focuses more on Verification and Validation, as well as auditing and continuously improving your HACCP System. The Basic HACCP Training focuses on the 5 Preliminary Steps & 7 Principles of HACCP, and includes a mock HACCP Plan to promote understanding.
6. Does the training expire or how often should it be refreshed?The training doesn’t expire, however, based on some audit requirements this training should be refreshed at least every five years.
7. What are the differences between a HACCP Plan and a Food Safety Plan?
There are quite a few differences between a HACCP plan and a food safety plan. It starts with the difference in the type of hazards that you have to analyze. Under the basic HACCP systems, you have to consider physical, biological, and chemical hazards. Under the preventive control approach for your food safety plan, there are three additional types of hazards that you have to consider, and these include radiological hazards as a type of chemical hazard. It also includes economically-motivated adulterants, which are associated with food fraud and the potential for environmental contamination in those facilities that produce ready-to-eat food products.
Another difference in HACCP versus the food safety plan is that FSMA regulations require a risk-based approach that also includes assessing likelihood of occurrence as well as the severity of consumer impact, as part of the hazard assessment. One of the major difference between food safety plans and HACCP plans is the HACCP plan primarily focuses on the identification of critical control points as part of that process. Under a food safety plan, the focus is not only on CCPs, a type of process preventive controls, but also on identifying other applicable preventive controls for allergens, sanitation, and the supply chain.