Most food processing companies currently operate their food safety programs based on Hazard Analysis and Critical Control Points (HACCP). But, for full compliance with the new Food Safety Modernization Act (FSMA), HACCP may not be enough.
Hazard Analysis and Risk-Based Preventive Controls (HARPC) is in many ways an extension of HACCP, but with a slightly different approach. This article reviews a key component of HARPC: the difference between critical control points (CCPs), prerequisite programs (PRPs), and operational prerequisite programs (OPRPs).
According to the FDA, a CCP is “a step at which control can be applied and is essential to prevent or eliminate a food safety hazard or reduce it to an acceptable level.”
CCPs are based on the idea of critical limits, which are thresholds used to determine safe and unsafe conditions. They are considered to have “absolute” control over the hazard.
For example, an HACCP team may decide that, for safety, a meat product needs to be heated to a minimum internal temperature of 165° and held there for 15 seconds. As long as these thresholds are met, the product is considered safe. If these thresholds are not met, the product is not considered safe.
PRPs are “procedures, including Good Manufacturing Practices, that address operational conditions providing the foundation for the HACCP system.” These are general control measures applicable across all areas of food processing and aimed at maintaining a safe and hygienic environment. They do not control specific hazards or steps in the process.
OPRPs are special types of PRPs. They are also control measures aimed at maintaining a safe and hygienic environment. But, unlike regular PRPs, they do control specific hazards and steps in the process. The main differences between OPRPs and CCPs is that OPRPs aren’t based on critical limits and they don’t have “absolute” control over the hazard. This means that while OPRPs are essential, their failure doesn’t automatically mean a product is unsafe.
The main impact of FSMA for CCPs and PRPs is that now, rather than being considered two distinct things, they are lumped together under the category of preventive controls (PCs). PRPs are now treated as equivalent to CCPs, which means they are subject to the same standards for implementation, monitoring, and documentation. As most food processing companies already follow strict food safety plans, the major shift will be adhering to the new record-keeping requirement.
As FSMA compliance deadlines approach, the more you know the better off you are. Here are three great resources where you can learn more about CCPs, PRPs, and OPRPs, and what they mean for you: