HACCP (Hazard Analysis and Critical Control Point) is the FDA’s regulatory predecessor to HARPC under FSMA. HACCP is a very similar hazard control system, but only applies to seafood and juice processors. HARPC applies to all food facilities subject to FDA registration except those covered by and in compliance with HACCP (and a few other significant exemptions discussed below). Another significant difference is that seafood and juice HACCP were created by FDA regulation – not by federal statute. HARPC was created by an amendment to the Food Drug and Cosmetic Act, specifically, the Food Safety Modernization Act (FSMA). Although arguments could be made that seafood and juice HACCP are unconstitutional, in that they laws (legislation) created by a federal regulatory agency and not by Congress, signed by the President, those arguments do not exist for HARPC. Functionally, HACCP and HARPC are very similar, thought supplier verification procedures (including the Foreign Supplier Verification Program requirements (FSVP) are much more rigorous under FSMA.
