The Devil is in the Details: The Important Distinctions Between HARPC and HACCP
GENEVA, OH, January 4, 2017
In 1989, the National Advisory Committee on Microbiological Criteria for Foods (NACMCF) published the first official HACCP document, standardizing the practice and presenting the seven principles of HACCP.
At first glance, HARPC requirements may look quite similar to HACCP. According to the FDA Federal Regulations for implementing FSMA, the core of HARPC starts with a Food Safety Plan. Even though HACCP and HARPC appear to have similarities, let’s summarize the important differences.
- HARPC shifts the regulatory emphasis from reactive to a protective and preventive mode. In the past under HACCP, regulators did not spring into action until outbreaks of foodborne illness occurred.
- HARPC is mandated by U.S. law, while HACCP is a global non-mandatory standard adopted as a rule by both the USDA, administered by FSIS, and the FDA.
- HARPC applies mandatory science-based preventive controls across the food supply chain. Food processors must also establish science-centered Risk-Based Preventive Controls. This extends beyond Critical Control Points defined by HACCP. Section 117.135 of the FSMA regulations specifically mentions Process Controls, Food Allergen Controls, Sanitation Controls, Supply-Chain Controls, a Recall Plan, and Other Controls. This differs from HACCP because HARPC enforces preventive controls to identify potential risks or threats to the food supply. It also requires food processors to implement appropriate corrective actions proactively.
- HARPC does not require the science of critical limits as does HACCP (Principle 3). According to Cornell University, a critical limit is defined as “a maximum and/or minimum value to which a biological, chemical or physical parameter must be controlled at a CCP to prevent, eliminate or reduce to an acceptable level the occurrence of a food-safety hazard.” However, for the hazard of foodborne pathogens, the risk-based preventive controls in HARPC will still equate to critical limits. You might ask, “Why?” Under FSMA, the FDA has a legislative mandate to require comprehensive, science-based preventive controls across the food supply. Therefore, the same science-based critical limits of maximum and minimum temperatures during processing steps in HACCP still apply under HARPC.
- Perhaps the most significant difference: HARPC extends risk-based preventive controls beyond in-plant processes to a food processor’s entire supply chain.
This last point raises a secondary question: Does your facility sell commercial products that are used as ingredients in your customers’ products? If so, then your facility is also regulated by the FDA under FSMA because the act specifically covers compliance by upstream supply chain vendors, including foreign suppliers. Examples of FSMA regulated products include raw products used as ingredients in pizza toppings, soups, and ready-to-eat packaged foods.
In either regulatory environment, temperature measurement of the foods being processed is crucial to preventing the growth of foodborne pathogens. One of the best solutions is an easy-to-handle, ruggedly designed automated temperature measurement solution. This eliminates the potential for recording and transcription errors of pen-and-pencil methods. Designed with built-in wireless connectivity to a vendor-neutral cloud environment, this solution creates a data repository readily accessed within minutes, well within the 24 hours required by FSMA. In conclusion, if there’s any question, meet both requirements. Although it may seem cumbersome, a written HACCP plan takes you a long way to meeting HARPC requirements. Take the few extra steps and let us help you along the way.
To learn more about how the HACCP and HARPC affect your food processing facility download “HACCP vs. HARPC: The Role of Temperature, Hazard, and Risk in Food Processing.”