Facilities must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. A written food safety plan is required and must cover: (a) hazard analysis, (b) risk based preventive controls, (c) oversight and management of preventive controls including monitoring, corrective actions and completed steps, and (d) verification that the preventive controls are working. The written food safety plan must address a Hazard Analysis and Risk Based Preventive Controls (HARPC) approach, rather than the Hazard Analysis and Critical Control Points (HACCP) approach that many facilities have used for years. At first glance, HARPC may seem no different from HACCP, but HARPC leads facilities to more carefully analyze hazards and threats by requiring that preventive controls be in place before any identified hazard arises.
