Food safety as a discipline is highly complex, and it can become especially complicated for manufacturers as they struggle to address evolving regulations and shifting industry realities. In the midst of this confusion and the wake of FSMA rollout, many food safety-related terms are tossed around. Unfortunately, not all of them are clearly understood or correctly represented by the people using them. Today we’re going to dissect two of these particular concepts – HACCP and a Food Safety Plan – and explain exactly what makes them different.
What is HACCP?
Each entity along the food chain shares responsibility for food safety and quality. At the manufacturing level, this responsibility involves establishing and maintaining proactive and effective food safety management systems. The Hazard Analysis Critical Control Points (HACCP) system is based on the approach of controlling critical points in food handling to prevent food safety problems. This system was conceived in the 1960s by the Pillsbury Corporation and the U.S. National Aeronautics and Space Administration (NASA). It began as a tool to guarantee the safety of food for astronauts in the first space missions and was later incorporated into the Codex Alimentations of the World Health Organization (WHO). HACCP has been universally accepted by government agencies, trade associations, and the food industry internationally as the system for controlling and auditing safe food production practices.
There are seven principles that make up HACCP:
- Conduct a hazard analysis
- Identify critical control points
- Establish critical limits
- Establish monitoring procedures
- Establish corrective actions
- Establish verification procedures
- Establish record-keeping procedures
These principles can be applied to all functions of the food and beverage industry, including:
- Preparing for consumption
Implementing HACCP plans effectively in food processing plants, retail food stores, and food service operations involves building a foundation of prerequisite programs like current Good Manufacturing Practices (cGMPs), as well as executing the following preliminary steps:
- Assembling a HACCP team
- Describing the food and its distribution
- Describing the intended use and consumers of the food
- Developing a flow diagram describing the process
- Verifying the flow diagram
HACCP systems have been mandated by U.S. Federal regulations issued by the Food and Drug Administration (FDA) for seafood and juice, and by the Food Safety and Inspection Service (FSIS) for meat and poultry. Some organizations require a separate HACCP plan for each food product, processing method and facility for which there are unique risks involved.
What is a Food Safety Plan?
As you can see from the previous section, HACCP has not been mandated for all food groups. But with the recent rollout of the Food Safety Modernization Act (FSMA), any food processing entity that was not previously subject to HACCP is now required to develop and implement a Food Safety Plan (FSP).
The FDA defines a Food Safety Plan (FSP) as “the primary documents in a preventive controls food safety system that provides a systematic approach to the identification of food safety hazards that must be controlled to prevent or minimize the likelihood of foodborne illness or injury. It contains a collection of written documents that describes activities that ensure the safety of food during manufacturing, processing, packing, and holding.”
These documents include:
- Hazard analysis to identify whether there are hazards requiring preventive control
- Preventive controls, as appropriate to the facility and the food, to ensure safe food is produced (e.g., controls for process, food allergens, sanitation, supply chain and recall plan)
- Procedures for monitoring the implementation of preventive controls, as appropriate to the nature of each preventive control and its role in the facility’s food safety system
- Corrective action procedures, as appropriate to the nature of each hazard and preventive control
- Verification procedures, as appropriate to the nature of each preventive control and its role in the facility’s food safety system
Pursuant to this written record, the FDA mandates the following requirements:
- You must maintain records documenting that the FSP is being implemented.
- The FSP must be developed or overseen by a preventive controls qualified individual (PCQI), a person with specialized education, training or experience to develop and apply a food safety system.
- It must be signed and dated by the owner, operator or agent in charge of the facility when it is first completed and whenever it is modified.
- The FSP as a whole must be reanalyzed at least every three years.
- There is no standardized format for an FSP. You can use whatever form works best for your facility, provided that it includes all of the required information.
What are the differences between HACCP plans and FSPs?
There are a number of distinctions that differentiate HACCP plans from Food Safety Plans, including the following nuances described by the FDA:
- For the purposes of HACCP, this refers to biological, chemical and physical hazards.
- In the context of an FSP, this also includes radiological hazards and hazards due to economically motivated adulteration.
- For the purposes of HACCP, these apply to process-related critical control points (CCPs).
- In the context of an FSP, they can apply to controls at other points that are not CCPs.
Parameters and Values
- For the purposes of HACCP, there must be critical limits at CCPs.
- In the context of an FSP, there are defined parameters with minimum and maximum values, but they may not be practical or needed for non-process-related preventive controls.
- For the purposes of HACCP, monitoring is always required for CCPs.
- In the context of an FSP, monitoring is required only as appropriate for preventive controls, and it may not be needed for some preventive controls that are not applied at CCPs.
Corrective Actions and Corrections
- For the purposes of HACCP, corrective actions are required whenever there are deviations from a CCP’s critical limit.
- In the context of an FSP, immediate corrections may be more appropriate than a specific corrective action (involving product risk evaluations of product safety) for some preventive controls.
- For the purposes of HACCP, verification activities are required for process controls.
- In the context of an FSP, there is flexibility to conduct verification activities as appropriate to the food, the facility and the nature of the preventive control.
- Some HACCP systems (e.g., for juice, meat and poultry products) require validation of the plan as a whole.
- In the context of an FSP, validation means obtaining and evaluating scientific and technical evidence that a control measure, combination of measures or the FSP as a whole is capable of effectively controlling the identified hazards. The extent of validation activities may be less rigorous for some preventive controls than others, or may not be required (e.g., sanitation controls).
- For the purposes of HACCP, records are required for process controls.
- In the context of an FSP, records are required as appropriate for all preventive controls.
- For the purposes of HACCP, a recall plan is not required.
- In the context of an FSP, a recall plan must be prepared for each product for which a hazard requiring a preventive control has been identified.
It is important to note that in many cases, HACCP plans are a critical component of the overall FSP. So while these two concepts are not interchangeable, they are certainly interrelated.
Now that you have a clearer understanding of these two vital food safety elements, take action to ensure that you are managing your plans in accordance with your industry’s compliance regulations and food safety standards. The most effective way to automate, organize and control these efforts is by adopting smart food safety software with the capabilities to:
- Minimize wasted time and resources that result from sluggish, manual documentation efforts and human error
- Maintain document control and security, as well as streamline the process of consistently updating your plans
- Color-code test points on your plant floor plan in order to assess the state of your plant with one glance, as well as improve communication and compliance throughout your organization
- Easily generate schedules that support your company’s testing plans, including robust randomization that ensures good coverage
- Aggregate all of your testing data in one spot, as well as filter and print answers for any audit in minutes
- Set up workflows and automatically notify stakeholders according to your internal policies, with each step being recorded and time-stamped as a corrective action moves toward completion
- Get an instant snapshot of the health and performance of your sites via powerful visualization and reporting dashboards
- Garner visibility into trends and hotspots across all your plants in order to inform how to optimize your food safety program
To get a closer look at the cloud-based, comprehensive food safety solution that significantly minimizes recall and compliance risk, download your free CONTROL-PRO guide now.