The Food Safety Modernization Act will soon have a dramatic impact on the food safety and regulatory landscape for facilities producing products regulated by the FDA. The Preventive Controls for Human Foods proposed rule, which is expected to be published as a final rule this month, will significantly change the way food manufacturing companies document their food safety systems.
HACCP Plan reassessments are required to be performed at least once a year. It is not only mandated by USDA and FDA regulations, but also by the Global Food Safety Initiative (GFSI) for companies certified under SQF, BRC, FSSC 22000 or IFS. In short, your HACCP plan should be a living document that continually and accurately reflects current operations. It assures your food safety system is kept up-to-date throughout the year.
Reassessments are necessary whenever any changes occur that could affect your hazard analysis or alter any current HACCP plans.
Example circumstances for HACCP reassessment include:
- Changes to or addition of new ingredients
- Revised formulations
- New equipment
- New packaging
- New production processes
- Changes to the intended consumer population
*Editor's note: this post is the first in an ongoing HACCP series.
The concept of HACCP validation has long been a mysterious and confusing topic for many people. Since it is included as a part of HACCP principle number 6 for verification, the validation requirement is often misunderstood.
There are many advocates, myself included, that feel like the National Advisory Committee for Microbiological Criteria for Foods should revise the standards to clarify the topic and give it the attention it deserves. Until then, I hope to help you learn the elements of validation and how you can prepare for the new Food Safety Inspection Service (FSIS) requirements before enforcement begins in 2016.