HARPC – What To Include?
Still struggling to make the connection between your HACCP plan and the FDA mandated HARPC?
While some of the expectations are still a bit gray, and will be until we start to see enforcement from FDA, it is possible to take some active steps to bring your overall plan into compliance. The stressed difference is HACCP can be considered reactionary versus HARPC as preventative – i.e. what do you need to do in advance to prevent an issue?
HARPC should be applied to the following programs:
- Biological, chemical, physical and radiological hazards
- Natural toxins, pesticides, drug residues, allergens, and unapproved food and color additives
- Naturally occurring hazards or unintentionally introduced hazards.
- Intentionally introduced hazards (including acts of terrorism)
- Sanitation procedures at food surface contact points
- Sanitation of utensils and equipment
- Staff hygiene training
- Environmental monitoring program
- Food allergen control program
- Recall plan
- Current Good Manufacturing Practices (cGMPs)
- Supplier verification activities
Dusting off these programs and appraising them from a different angle can help get you started and we’d be happy to help. Feel free to contact us at firstname.lastname@example.org to discuss your organizational needs.