From the Editor—HARPC: R.I.P.

Food Quality & Safety magazine would like to belatedly report the demise of HARPC. HARPC, or Hazard Analysis Risk Based Preventive Controls, was conceived in the halls of Congress in response to national concerns regarding the safety of U.S. food supply and a perceived need to improve management of food safety. How long HARPC remained in the womb until his/her birth in December 2010 is unknown, but it apparently was a long gestation period. HARPC was officially acknowledged by President Obama in January 2011 when the he signed FSMA into law; one of the rare recent examples of our Congress working together on something.

The coming of HARPC into the world was met with great jubilation by some proclaiming that the child was “HACCP on steroids” and was a vast improvement over traditional HACCP in that they felt HACCP was not a proactive means of ensuring food safety. The latter was sort of an odd take because the FDA as far back as 1990 was praising HACCP as being proactive. Former FDA Commissioner David Kessler referred to HACCP when he made the statement, “Our safety systems should be preventing problems rather than chasing the horses after they are out of the barn. HACCP is a system that will make that possible.”

Fred Shank of the FDA had similar thoughts in 1990 when he stated that “instead of relying on traditional inspections, our role in HACCP will be to review system parameters and operating procedures, to provide selective auditing of the system’s records, including verification by laboratory analysis, and provide for appropriate enforcement.”

The coming of HARPC created great angst as it was presented as a brand-new food safety management system that would mandate the industry completely disassemble its current programs to implement the new systems. The angst was magnified since as soon as the law was passed, “experts” came out of the woodwork offering expensive workshops on how to comply with HARPC. The route that the food industry should have taken as simpler: look at the law, re-evaluate existing food safety management systems, and await passage of the regulations that the FDA was charged with developing to ensure enforcement of FSMA. When the draft regulations appeared, they did not include much that was new but did mandate the food safety management systems be more robust; something which all processors did not do, especially when it came to validation issues.

But we are here to note the passing of HARPC. As the draft regulations were issued and the mandated programs to train Preventive Controls Qualified Individuals (PCQI) were developed, HARPC disappeared. In fact, he/she is not even mentioned in the PCQI course. So, HARPC is dead and buried and is really not being mourned. In fact, most food processors probably would say, “Good riddance.”

Rick Stier
From The Editors