Food Safety Plans vs. HACCP—What Does Your Establishment Really Need?

Article By Nimisha Suraj M.Sc.
Article Source: Food Safety Plans vs. HACCP—What Does Your Establishment Really Need? (food-safety.com)

Food Safety Management Systems (FSMSs) have been in effect worldwide for the better part of the 20th century, and they continue to be an imperative part of the food and beverage ecosystem. Adherence to an FSMS helps food businesses prove to inspectors and auditors that they are operating safely and according to regulations or code. In a census conducted by the U.S. Department of Agriculture's Food Safety Inspection and Service (USDA-FSIS), it was estimated that 7.6 million food safety inspections were conducted in the U.S. in 2022 alone.1 

Among the most common FSMS systems is HACCP, or Hazard Analysis and Critical Control Points, which is considered one of the cornerstones of food safety science.2 Created in the 1960s by the National Aeronautics and Space Administration (NASA) and the Pillsbury Company, HACCP plans have been implemented by millions of food establishments across the globe, with countries like Australia, Canada, and Japan considering HACCP implementation a mandatory legal requirement for food businesses.3 

Food Safety Plans share a similar standing in the food safety world. They are considered an integral part of any food establishment, and are defined by the U.S. Food and Drug Administration (FDA) as "the primary documents in a preventive controls food safety system that provides a systematic approach to the identification of food safety hazards that must be controlled to prevent or minimize the likelihood of foodborne illness or injury." Unsurprisingly, Food Safety Plans are a mandatory requirement in the U.S. and several other countries.

Quite a bit of overlap exists between the concepts of a complete HACCP plan and a Food Safety Plan. HACCP can even be considered a vital component of a larger-scale Food Safety Plan. However, there are subtle differences between the two:

1. Hazard analysis: In HACCP plans, biological, chemical, and physical hazards need to be outlined. In comparison, for Food Safety Plans, radiological hazards and economically motivated hazards need to be considered, as well.

2. Monitoring: CCPs, or Critical Control Points, are a requirement for an effective HACCP plan, and their monitoring procedures need to be documented; however, for an FSP, monitoring of preventative controls are only applicable as required.

3. Parameters and values: HACCP plans are well known for critical limits. As FSPs deal with preventative controls, there are no mandatory limits; however, they lean more toward minimum and maximum levels and/or ranges.

4. Recall plans: All Food Safety Plans require that a documented recall plan be included, whereas this is not a requirement for a HACCP plan.

A question that often arises is, "Does a food production establishment require both a HACCP plan and a Food Safety Plan?" The answer to this question depends on country- or region-specific legal requirements, among other factors. For example, in the U.S., according to FDA regulations, all small businesses are required by law to have a documented Food Safety Plan, although there is no set template for this plan. In contrast, there are no legal requirements for the implementation of a HACCP system or a Food Safety Plan in India.

In addition to the above, it is important to note that, according to FDA, HACCP plans can be extremely specific depending on the industry sector. For example, separate protocols need to be followed for HACCP plans created for the juice sector, the meat sector, and the seafood sector, owing to the different food safety risks of these respective food groups and the operations of their sectors. Concerns such as these can be a contributing factor to whether an establishment decides to create and implement a Food Safety Plan, a HACCP plan, or both.

Different schools of thought exist regarding whether an establishment needs to have both a HACCP plan and a Food Safety Plan, and when the two systems should be required. Due to the generally broader scope of Food Safety Plans, which are capable of covering various aspects such as sanitation, allergen controls, and other preventive controls, many food establishments look at creating a Food Safety Plan first, and then use their Food Safety Plan as a springboard for creating an airtight HACCP plan. Of course, this could differ depending on the requirements of the food establishment itself. Other factors such as marketing, client retention, and complaint handling could also play key roles in determining what kind of FSMS an establishment requires.

References

1. USDA-FSIS. "Food Safety Stats: Inspection by the Numbers 2022." Current as of February 1, 2023. https://www.fsis.usda.gov/food-safety/food-safety-stats.

2. FDA. Center for Food Safety and Applied Nutrition (CFSAN). Draft Guidance for Industry: Hazard Analysis and Risk-Based Preventive Controls for Human Food. September 26, 2023. https://www.fda.gov/regulatory-information/search-fda-guidance-documents/draft-guidance-industry-hazard-analysis-and-risk-based-preventive-controls-human-food.

3. Food and Agriculture Organization of the United Nations. "How Official Services Foster and Enforce the Implementation of HACCP by Industry and Trade." Second FAO/WHO Global Forum for Food Safety Regulators. October 2004. https://www.fao.org/3/j3207e/j3207e.htm.