How to Combine Your HACCP and HARPC Plans

This method can be used to assess each process step individually and detail the pertinent hazards at that step.

For example, from where a product is chilled, the hazard of Listeria monocytogenes during preparation, packing, and storage may be extracted. Similarly, from where a product is packed with a modified atmosphere, the hazard of incorrect gas content at packing or the use of porous film at the development stage may be extracted. In addition, from where knives are being used to fillet meat or fish, the hazard of contamination from the knife tip during butchery may be extracted.

Hierarchy of Controls

Figure 1. Three levels of control.

Image credit: Kassy Marsh

Once the pertinent hazards have been extracted and risk assessed, without taking the current controls into account, a number of significant hazards will have been produced. Each significant hazard will require a preventive control. Those that have been deemed not too significant should be managed through pre-requisite programs (PRPs) or GMPs.

But where do CCPs fit in when a combined HACCP and HARPC system is required? To understand when to apply a CCP, the hierarchy of the controls needs to be understood.

Currently, there are three levels of control that are ordered as seen in Figure 1.

A PRP is a facility-wide generic control, which is applied to more than one step in the process. A preventive control (PC) manages a significant food safety hazard, as defined through the risk assessment.

It is essential to understand the difference between a PC and a CCP. Answering this question was one of the key aspects in the research and development of my book, Combine Your HACCP & HARCP Plan Step-by-Step. The following excerpts from the book are summaries of definitions.

•  The FDA define a PC as: “risk-based, reasonably appropriate procedures, practices, and processes that a person knowledgeable about the safe manufacturing, processing, packing, or holding of food would employ to significantly minimize or prevent the hazards identified under the hazard analysis that are consistent with the current scientific understanding of safe food manufacturing, processing, packing, or holding at the time of the analysis.”
• The agency also defines a CCP as: “a point, step, or procedure in a food process at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce such hazard to an acceptable level.”

Extracting pertinent information from each summary, definitions of PC and a CCP can be devised:

PC: Procedures, practices, and processes to significantly minimize or prevent the hazard; and

CCP: Procedures, practices, and processes at which control can be applied and is essential to eliminate a food safety hazard or reduce such hazard to an acceptable level.

In summation, a PC recognizes when contamination has occurred and either corrects the error or stops the product from being released. A CCP is a control applied to a known contamination issue (such as cooking), which reduces that known contamination to a safe level.

Applying this theory to all the significant hazards generated from the risk assessment can help establish whether a PC or a CCP should be applied.

The Future of HACCP and HARPC

The principles of HACCP were originally published in the 1950s. Despite subtle changes and improvements along the way, its fundamental elements have stayed the same. This type of system has improved food safety over time, but today food safety recalls and withdrawals tend to be related to ineffective PRPs or GMPs.

HARPC is likely to turn HACCP on its head. However, the effects of this change can only be positive. The introduction of PCs as an additional tier of control will no doubt be an advantage. Perhaps in the future, requirements will be combined to produce one robust methodology for food safety risk assessment and control that can be used worldwide.