HACCP vs. HARPC

What are the differences between HACCP and HARPC?

There are a number of rules and proposed rules within the FSMA. I’ll try and clarify the differences between HACCP and HARPC.

I’m fresh into it so I am citing and paraphrasing as I go…the proposed rule of HARPC or Current Good Manufacturing Practice and Hazard Analysis and Risk-Based Preventive Controls For Human Food, within the FSMA (food Safety Modernization Act) differs from HACCP in that:

1. Every food manufacturing / processing facility is required to have someone able “to prepare the food safety plan, develop the hazard analysis, validate the preventive controls, review records and conduct a reanalysis of the food safety plan (or oversee these activities).”

2. This individual would be required to successfully complete training in accordance with a standardized curriculum or be otherwise qualified through job experience to develop and apply a food safety system.” HACCP practitioner training, I imagine, would be acceptable. Again refer to the online course  as it meets with the CODEX guidelines outlined in the WHO (1996).”Training aspects of the hazard analysis critical control point system (HACCP). Report of a Workshop on Training in HACCP with the participation of FAO, Geneva, 1–2 June 1995. Geneva, World Health Organization”.  And this training is:

1. HACCP training course used extensively in a country.

2. Administered and delivered by an institution recognized as a food safety training centre of excellence and issues a certificate of attendance to attendees.

3. Should be a minimum of three days (24 hrs) in duration.

4. Should be examinable.

3. The HARPC rule would affect all food processing companies, unlike HACCP which is only required in juice and sea food processors and manufacturers by the FDA and required by in meat processing by the USDA / FSIS. Keep in mind that if you are required to be HACCP compliant you are not required to be HARPC compliant.

4. Authoring bodies. i.e. HACCP was created by NASA while HARPC was created by a federal legislative processes so it’s not unconstitutional. Either way HACCP or HARPC systems are basic requirements in today’s food manufacturing industries.  

In my opinion, the rule looks much like traditional HACCP but with a large emphasis on preventative control, a deeper understanding of the hazards (microbiology, chemistry, etc.). documentation control and systems validation.

I’ll share more as I learn.

If people want to have a look at it here are some links…

http://www.regulations.gov/#!docketDetail;D=FDA-2011-N-0920

http://www.fda.gov/Food/guidanceregulation/FSMA/ucm334115.htm

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