Oftentimes, the terms “food safety plan” (FSP) and “HACCP plan” are used interchangeably. Yet, there are critical differences among these two concepts. Although both can support a robust approach to food safety in food and beverage companies, understanding the nuances of each program is essential to ensuring compliance. Here, we offer a close look into each type of plan and what they entail, along with key differences between the two.
What Is HACCP?
Hazard Analysis and Critical Control Points (HACCP) is a preventive management system used to identify and assess the risks and hazards associated with specific foods or production processes. The system also is used to control the identified hazards that are “reasonably likely to occur,” according to the FDA. HACCP plans are mandated by the FDA for the seafood and juice industries.
How Did HACCP Plans Start?
According to the Canadian Institute of Food Safety, HACCP plans have origins that are quite literally out of this world. When astronauts first took to the moon in the 1960s, NASA needed a way to ensure their safety against foodborne illnesses. Being that they were in cramped quarters – just 73 cubic feet – and there were no bathrooms aboard their spacecraft, cleanliness was critical. So, NASA collaborated with food safety specialists from Pillsbury to establish parameters which are now known as HACCP. Today, HACCP plans lay the foundations for safe production, preparation, packaging, and distribution of food all across the globe and at all levels of the supply chain.
Why Are HACCP Plans So Important?
HACCP plans are essential to food and beverage companies as they prioritize the control of potential hazards. These hazards include contaminants such as:
By addressing these risks, food and beverage companies can better promote public health and safety.
Which Major Food Hazards Does HACCP Protect Against?
While consumers remain concerned about chemical residue from contaminants such as pesticides and antibiotics, the HACCP Alliance notes that the real concerns are microbiological hazards. Some of the most common include:
- E. coli
- Clostridium botulinum
What Are the Principles of HACCP?
According to the FDA, there are seven core principles of HACCP.
1. Conduct a Hazard Analysis
To satisfy this requirement, companies must list the detailed steps involved in their processes and identify those in which significant hazards are likely to occur. From there, the focus should be on the hazards which can be prevented, eliminated, or controlled through an effective HACCP plan. The decision to include or exclude specific hazards from the plan should be detailed within the plan as well, with justification.
2. Determine Critical Control Points (CCPs)
Critical control points (CCPs) are points, steps, or procedures at which measures can be implemented to control a food safety hazard. Examples of CCPs in food processing include:
- Testing for chemical residue
- Thermal processing
- Testing for metal contaminants
HACCP teams should use a CCP decision tree to identify CCPs.
3. Establish Critical Limits
Critical limits (CLs) are the minimum and/or maximum values to which chemical, biological, or physical measures must be controlled to eliminate or reduce a hazard. CLs are often metrics such as temperature, time, weight, or other parameters controlled by regulatory standards.
4. Establish Monitoring Procedures
HACCP teams should establish and adopt monitoring procedures to measure CLs at each CCP in their process. When compiling a HACCP plan, be sure to describe how the measurement will be taken, as well as when and by whom.
5. Establish Corrective Actions
When a deviation in CLs occurs, corrective actions are used to correct and prevent hazards. This should include the identification of the problem itself as well as steps that will be taken to prevent it in the future.
6. Establish Verification Procedures
Verification activities determine the validity of the HACCP plan and ensure operations are running according to the plan. HACCP teams may use verification activities such as reviewing records, auditing CCPs, calibrating instruments, and testing products.
7. Establish Record-Keeping & Documentation Procedures
Recordkeeping is a key pillar of any sound HACCP plan. Not only do records detail all the information about the plan for personnel to reference, but they can also serve as proof that food was made safely. Documentation should include the plant’s hazard analysis, CCPs, CLs, monitoring system, corrective actions, recordkeeping procedures, and verification activities.
As one might imagine, managing such a significant volume of records for HACCP – in addition to other programs – can become overwhelming for facilities. For this reason, many organizations leverage automated HACCP plan software to organize and manage compliance requirements in one convenient system.
What Is a Food Safety Plan?
HACCP plans are not required by the FDA for all food groups. Yet, companies that fall under the Food Safety Modernization Act (FSMA) must now have a written FSP to satisfy the Human Food Rule. FSPs take a preventive controls approach to controlling hazards, and encompass HACCP principles.
According to the FDA, a FSP “consists of 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 describe activities that ensure the safety of food during manufacturing, processing, packing, and holding.”
What Does a Food Safety Plan Entail?
The documents to be included in an FSP are:
- A thorough hazard analysis to identify which risks require controlling
- Preventive controls to promote food safety; for instance, plans for processes, allergens, recalls, sanitation, and the supply chain
- Monitoring procedures for implementing preventive controls
- Corrective actions
- Verification procedures
The FDA also has the following requirements in place for FSPs:
- Documented records must show that the plant is actively implementing the FSP.
- A preventive controls qualified individual (PCQI) must establish or oversee the FSP.
- The FSP must be signed and dated when first completed or modified by the individual in charge of the facility.
- The FSP must be reassessed every three years at a minimum.
Why Are Food Safety Plans Important?
Like HACCP plans, FSPs play an important role in controlling risks in food and beverage manufacturing. Food safety plans are critical for:
- Reducing the risk of foodborne illnesses
- Controlling cross-contamination from
o Other foods
- Ensuring compliance
When established and implemented correctly, FSPs can help facilities control microbiological, chemical, and physical hazards, as well as risks associated with allergens.
To aid companies in the creation of FSPs, the FDA offers a Food Safety Plan Builder online. The use of this tool is optional and does not guarantee compliance with FDA requirements. Nonetheless, it may be a useful guide for creating or refining FSPs, as it takes users through the following key principles:
- Basic facility information
- Preliminary steps
- Good Manufacturing Practices (GMPs) and Prerequisite Programs
- HACCP determinations
- Preventive controls for:
o Food allergens
o Supply chain
- Recall plans
- FSP reanalysis
- FSP reporting
- Recordkeeping best practices
As you can see, there is a significant overlap between food safety plans and HACCP plans. Nonetheless, there are also several key differences.
What Are the Differences Between a HACCP Plan & a Food Safety Plan?
Here are a few key ways HACCP plans and FSPs differ:
With HACCP plans, biological, chemical, and physical hazards must be identified; for FSPs, radiological hazards and economically motivated adulteration must also be considered.
While HACCP plans only identify CCPs for processes, FSPs call for process CCPs as well as controls at points other than those determined critical.
Records must be maintained for process controls in HACCP plans, but with FSPs, records should be kept for all preventive controls.
CCPs & Parameters
While critical limits are required for CCPs in HACCP plans, with FSPs, the defined parameters may not be required for preventive controls not related to processes.
HACCP plans do not require monitoring, but FSPs do. Specifically, monitoring must be done after any hazard requiring a preventive control has been identified.
Any time there is a deviation from a CCP’s CL, the HACCP plan calls for corrective actions. With FSPs, immediate resolutions may be more practical than official corrective actions in some cases.
Whereas HACCP plans require verification activities, FSPs offer more leeway in terms of conducting verification activities based on the nature of the preventive control.
HACCP systems for juice, meat, and poultry require validation of the entire plan, whereas FSPs call for validation activities such as collecting evidence that specific controls effectively mitigate the hazards.
While HACCP does not mandate a recall plan, FSPs require a recall plan for each product that carries a hazard requiring a preventive control.
While the differences between food safety plans and HACCP plans may appear subtle, these nuances do exist and are important to identify and plan for. Understanding the distinguishing factors among the two plans will allow you to ensure your company is complying with all applicable requirements.
Whether your company must adopt an FSP, HACCP plan, or both, compliance with these programs calls for extensive preparation and ongoing due diligence. For more in-depth guidance on establishing and maintaining robust food safety protocols, download our free guide, Balancing Compliance, Risk, and Performance: How to Optimize Your Food Safety and Quality Systems.
About SafetyChain Software
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