The main compliance date of September 2017 for the Preventive Controls Rule for Human Food is fast approaching. Facilities now have the daunting task of trying to amend their current food safety systems to meet the new requirements, which are becoming well known as HARPC (Hazard Analysis and Risk-Based Preventive Controls).
Need for a Combined System
Many facilities already have well-established Hazard Analysis and Critical Control Point (HACCP) or National Advisory Committee on Microbiological Criteria for Foods (NACMCF) based food safety systems. These sites will continue to be asked to comply with HACCP or NACMCF requirements by their customers, accreditation standards, and also by local legislation in the countries to which they export product.
At first glance, the requirements in HACCP or NACMCF and HARPC may look aligned, but facilities must be careful, as there are a number of fundamental differences, which need to be considered before making any alterations to their current food safety systems.
New HARPC requirements demand a new mindset, which many HACCP specialists are finding difficult to embody.