We’ve been contacted by many potential clients and workshop attendees who are under the impression HACCP is going away with the advent of the Preventive Controls for Human Food Regulation (21 CFR 117, commonly known as the PC rule). While this may seem like a logical conclusion, it is not true for several reasons. HACCP (Hazard Analysis and Critical Control Points) is the foundation of all preventive food safety management systems that have followed, including the Hazard Analysis and Risk-based Preventive Controls system introduced by the regulation (see what they did there?)
Industries currently subject to regulatory HACCP requirements, such as seafood, juice, meat, poultry, and egg production, are exempted from compliance with the PC rule. Regulatory HACCP may have been developed as a reactive approach to illness and injury in the public, but this does not mean that mature regulatory systems that were developed carefully over many years should suddenly be scrapped because a new regulation is introduced. Also, the FDA (U.S. Food & Drug Administration) likely has no desire to take on the regulation of meat, poultry, catfish, and/or certain types of eggs since the USDA (U.S. Department of Agriculture) has overseen managing these sectors of the food industry for many years. This division of labor was established due to the USDA’s regulation of the agricultural sector. Leave the aces in their places!
HACCP is an international standard, while the PC rule is a U.S. piece of legislation. HACCP plans are required by many GFSI (global food safety initiative)-approved CPOs (certified program owners), such as FSSC (Food Safety System Certification) 22000 and SQF (Safe Quality Food). Local regulatory compliance is required for all GFSI-approved food safety management systems, which would include compliance with the PC rule for companies manufacturing food intended for consumption in the U.S. However, PC rule compliance will never be the focus of these CPOs because they are international standards. A company that never intends for its product to be used in the U.S. might still need to be compliant to SQF or FSSC 22000. The U.S. is only one country in a global food supply chain.
HACCP is foundational to all preventive food safety management systems, including the PC rule. In the FDA-recognized FSPCA (Food Safety Preventive Controls Alliance) curriculum for 21 CFR 117, it is said that Preventive Controls address more than HACCP. This may be debated from a purely academic perspective, as most mature HACCP plans long ago addressed critical hazards in the areas of allergen management, sanitation, and their supply chains, but it is true that a supplier-applied control could not be managed as a Critical Control Point in traditional HACCP as it is outside the control of the facility. It’s purely an academic argument, as you can call the control Mickey Mouse if you want to – as long as you eliminate or reduce the hazard to a level that is not a public health concern.
Any way you slice it, HACCP is not going away. HACCP is even being taught to middle schoolers in the Florida public school system, which is fantastic – kids need to learn practical skills they can use in the real world as early as possible. Never forget the five pre-steps and seven principles, as you can apply them to situations as diverse as personal relationships if they are truly understood and applied as a system!