harpc what you need to know - ifsqn.com what you need to know.pdf · harpc: what you need to know...
TRANSCRIPT
Food Safety Management Solutions
Agenda
• Introduction
• What Are the New Rules?
• HACCP vs HARPC
• HARPC• Qualified Individual• Food Safety Plan
• More FSMA!
• Q & A
Food Safety Management Solutions
Food Safety Plan (PCP/HARPC)
Food Defense Plan
Foreign Supplier Verification Programs
FSMA RULES INCLUDE:
Food Safety Management Solutions
• There is no easy silver bullet!
• Compliance with the Preventive Controls rules requires significant time and internal resources
• Far reaching legislation which covers food manufacturers and suppliers from the farmer’s market on up to the large ‘big box’ retailer
• “All facilities engaged in manufacturing, processing, packaging, or holding food for consumption in the United States” are required to conduct Hazard Analysis and Risk-Based Preventive Control reviews and implementations to establish science-based measures to reduce the risk of food contamination
Food Safety Management Solutions
• In general, facilities required to register with FDA under
Sec. 415 of the FD&C Act must comply
• Applies to domestic and imported foods(some exemptions and modifications apply)
• The PCP (PCHF) intention: to modernize the
longstanding current Good Manufacturing Practices
(cGMP) requirements
Food Safety Management Solutions
What is the
biggest
challenge your
company faces
in regards to
FSMA
compliance?
Food Safety Management Solutions
HACCP –vs- HARPC
HARPC is very similar to HACCP in many waysException: HAZARD EVALUATION
• HACCP: Risk is determined with Preventive Controls in mind-Results in a lower risk
• HARPC: Risk is determined in the absence of Preventive Controls-Will result in a (sometimes significantly) higher risk
• Basic mitigation controls may be promoted to CCP or oPRP status
Food Safety Management Solutions
Identify Qualified Individual
Identify the Food
Follow a Flow
Diagram
Identify the Hazards
Evaluate Hazards
Identify Preventive Controls
Validate Preventive Controls
and Establish
Parameters
MonitorImplement Corrective
Actions
Verify Activities
HARPC Steps
Food Safety Management Solutions
• A qualified individual who has successfully completed training in the development and application of risk-based preventive controls at least equivalent to that received under a standardized curriculum recognized as adequate by FDA or is otherwise qualified through job experience to develop and apply a food safey system
• The QI may be, but is not required to be an employee of the establishment
Qualified Individual
Food Safety Management Solutions
Qualified Individual
• Must do or oversee the following: • Preparation of the Food Safety Plan• Validation of Preventive Controls• Review of Records• Reanalysis
Food Safety Management Solutions
Have you
conducted a gap
analysis to
determine
current
compliance /
deficiencies?
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
•Hazard identification must consider known or reasonably foreseeable biological, chemical and physical hazards• These could occor naturally, be unintentionally
introduced, or be intentionally introduced for economic gain
•Hazard evaluation must consider severity of illness/injury and probability of occurence in absence
of preventive controls
Food Safety Plan: Hazard Analysis
Food Safety Management Solutions
Hazards
Biological Chemical Physical
Process MaterialsOperational Environment
HACCP
Food Safety Management Solutions
Hazards
Biological Chemical Physical
Process MaterialsOperational Environment
Food FraudEconomically
Motivated Adulteration
Terrorism
HARPC / PCP
Food Safety Management Solutions
Unintentional
Intentional
Naturally Occuring
Scope ofHazard Analysis
Food Safety Management Solutions
HACCP
PRP CCP
Monitoring Verification CAPA Review
PCP/HARPC
Preventive Control
Monitoring Verification CAPA Review
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
•Measures required to ensure that hazards are significantly minimized or prevented• Process controls• Food Allergen controls• Sanitation controls• Supply Chain controls• Recall plan
Food Safety Plan: Preventive Controls
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
•Manufacturing/processing facilities must have a risk-based supply-chain program to ensure control of hazards in raw materials and other ingredients when the control is applied before receipt (”supply-chain applied control”)
Food Safety Plan: Supply Chain Program
Food Safety Management Solutions
Food Safety Plan: Supply Chain Program
Use Approved
Suppliers
Determine
Supplier
Verification
Activities
Conduct
Supplier
Verification
Activities
Document
Supplier
Verification
Activities
When applicable, verify a
supply-chain-applied
control applied by an
entity other than your
supplier
Food Safety Management Solutions
•Onsite audits
•Sampling and testing
•Review of relevant food safety records
•Other as appropriate
Activity and frequency based on nature of hazard, where it is controlled and supplier performance
Food Safety Plan: Supply Chain Verification Activities
Food Safety Management Solutions
• For serious hazards requiring a supply-chain-applied control:• Documented onsite audit before using the raw material
• At least annually after the initial audit
• Exception:• You document that other verification activities or less frequent
auditing provides adequate assurance
Food Safety Plan: Supply Chain -Onsite Audits
Food Safety Management Solutions
• Must be performed by a qualified auditor• Governement employee
• 3rd Part (CB)
• Employee of receiving facility
• Inspection may substitute for audit in certain cases
Food Safety Plan: Supply Chain -Onsite Audits
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
• Facility must have written procedures, including the frequency they are to be performed, for monitoring the preventive controls (as appropriate to the nature of the preventive control)
• Monitoring must be documented in records subject to verification
Food Safety Plan: Monitoring
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
• Facility must have written procedures for steps to be taken when preventive controls are not properly implemented• Identify and correct problem
• Reduce the likelihood of occurence
• Evaluate food for safety
• Prevent adulterated food from entering commerce
Food Safety Plan: Corrective Actions and Corrections
Food Safety Management Solutions
• Hazard Analysis
• Preventive Controls
• Supply Chain Program
• Procedures for Monitoring
• Corrective Action Procedures
• Verification Procedures
Food Safety Plan
Food Safety Management Solutions
• Included as appropriate to the facility, food, and nature of the preventive control• Validation of preventive controls (Process Controls)
• Verification of monitoring and corrective action
• Calibration of process monitoring and verification instruments
• Product testing, environmental monitoring
• Records review
Food Safety Plan: Verification
Food Safety Management Solutions
• Review at least every 3 years
• Whenever there is a significant change that creates the potential for a new hazard
• When there is new information about potential hazards associated with a food
• When a preventive control is ineffective
Food Safety Plan: Review
Food Safety Management Solutions
ConductVulnerability
Assessment (VA) and Food Defense
Audit
Identify gapsIdentify mitigation
strategiesrequired
Food DefensePlan
Food Defense Plan
Food Safety Management Solutions
FSVP
Initial Hazard
Analysis of
Product
Full Risk
Assessment
of Product
Supplier
Evaluation
Verification of
Program
Determination
Verification of
Program
Implementation
Approval of
Supplier
Corrective
ActionsRe-Evaluation
Food Safety Management Solutions
Food Safety Plan (HARPC)
Food Defense Plan
Foreign Supplier Verification Programs
Food Safety Management Solutions
Are you
considering
using software to
assist you with
building FSMA
compliant
programs?
Food Safety Management Solutions
Safefood 360° is thesoftware for FSMA
Visit us at: www.safefood360.com