Is HACCP Dead? FSMA Compliance and the FSPCA
Since the new FSMA rules regarding Preventive Controls (PC) were introduced last year, food companies are facing some confusion around how to comply to these requirements. An alternate format of a food safety plan that includes PCs was put forward by the FSPCA but has muddied the waters further. So what’s really going on?
What is the FSPCA?
The Food Safety Preventive Controls Alliance (FSPCA) is a group of industry members seeking to support safe food production by developing training and outreach programs. Their aim is to assist food production companies with the compliance of the preventive control regulations that make up FSMA. The FSPCA has developed a course made up of a “standardized curriculum”: successful completion of this course allows a member of the food production industry to become a “preventive controls qualified individual.”
How Does FSPCA Relate to HACCP and FSMA?
In speaking with our users, we noticed that there is confusion with regards to FSMA and HACCP compliance and the way in which HACCP relates to the FSPCA’s PC-based system. While this group of industry members may be charged with the training of new health inspectors, HACCP is still by far the most accepted standard. The FDA endorses HACCP under the Preventive Controls for Human Food Regulation and will continue to do so in the foreseeable future.
The FSPCA’s food safety plan format, while innovative, is not a replacement to HACCP. In fact, there are a number of problems with the current proposed format. While the PC-based system aims to simplify HACCP, we are concerned that it may ultimately guide food production companies in the wrong direction.
Narrative vs. Analytic Approach
The FSPCA format encourages a narrative approach to developing a food safety plan. This has the potential to be problematic because a narrative format is missing the clarity of HACCP’s analytics-based methodology that allows one to arrive at a verifiable conclusion. Qualitative narratives are helpful and may make the plan easier to understand but the way the FSPCA format mixes analytic data with narrative descriptions makes the information more difficult to review and monitor on the floor.
While the narrative approach is inherently problematic, adopting a more qualitative format offers advantages. Narratives can be very useful in describing processes and providing information within the context of the process flow. For this reason, they form the basis of Standard Operating Procedures (or, SOPs). The type of information required in a food safety plan, however, includes process steps, ingredients, materials, packaging, and more. To attach narratives to each of these can be time-consuming, with descriptions of processes that must be written out repeatedly. For a small facility this may be manageable, but any larger operation would soon find itself bogged down in lengthy descriptions. Keep in mind that many facilities are dealing with thousands or even tens of thousands of products and ingredients! With HACCP-based food safety program, on the other hand, information is neatly contained within (and separated by) SOP documents for easy reference, application, and update.
Integrating SOPs within a food safety plan is an interesting idea, but the FSPCA’s current narrative format is not ready for prime-time because it doesn’t adequately address everything that makes an SOP useful on its own. The FSPCA’s preventive controls are fundamentally similar to SOPs in that the monitoring section identifies the who, what, when, and how. Here’s the catch: a truly comprehensive SOP will also ask the questions “where” and “why”. Those six questions are not only important for monitoring, but also for corrective actions and verifications.
One legitimate criticism of HACCP is that it is too process driven. With HACCP, hazards are usually assigned and controlled against process steps, making it difficult to control hazards beyond process steps. To solve this issue, we at Icicle saw that it was relatively easy to modify the analysis decision tree to accommodate hazards introduced with ingredients, materials, packaging, cross-contamination points, and even quality hazards as required by SQF Level 2, threat hazards under TACCP, and vulnerability hazards under VACCP.
The FSPCA format expands beyond processes to include ingredients, but does not account for materials, packaging, or other items listed above. Even accounting for this improvement, the structure remains process-centric, which means that certain questions asked in the program are more relevant for processes compared to other means by which hazards enter the food supply. In addition, when it comes to the preventive controls themselves, the FSPCA format doesn’t account for the possibility that a process can only partially control a hazard.
On the Plus Side: Accounting for Allergens
An element that has been poorly dealt with under HACCP is allergen prevention, something the FSPCA has aptly addressed. The FSPCA’s PC plan format is a step in the right direction in terms of allergen prevention. After all: allergens account for a huge percentage of all recalls.
Choosing HACCP as the Higher Bar for Compliance
For food companies, HACCP remains the most important standard of compliance, including FSMA compliance. In other words, alternative formats – such as the one put forth by the FSPCA – should not negate existing HACCP implementations. Our food production management software, Icicle, continues to prioritize HACCP while taking a different approach to addressing its weaknesses. Specifically, the addition of new HARPC requirements (such as PCs, radiological hazards, and intentional adulteration for example) speaks to the need for HACCP to be extended in both it’s method and reach to become proactively preventative.
The development of HACCP principles and their adoption by the food industry has been a remarkable consensus achievement that took over five decades to attain. We like to think of our incremental approach as HACCP Plus, rather than any sort of replacement. There are also many ways to build upon and adapt the HACCP structure to allow for more robust allergen management (including certifications), third-party certifications (such as organic, kosher, halal, gluten-free, and others), and more.
Request a free demo of Icicle’s food production management program today to learn more!