What is the Difference Between HACCP and a Food Safety Plan?

Although a Food Safety Plan (FSP) and a HACCP plan are similar, they are not identical. However, they both can support a robust approach to food safety in food and beverage companies, and understanding the difference between each program is essential to ensuring compliance.

There are quite a few differences between a HACCP plan and a Food Safety Plan. Just to mention a few points: For FSP, chemical hazards include radiological and economic threats, a Recall Plan is required, and also FSP can apply to controls at other issues that are not CCPs. In the following, we briefly discuss each of the differences, since it is essential to know the definitions of each system.

What is HACCP?

Hazard Analysis and Critical Control Points (HACCP) is a preventive management system used to identify and assess the risks and hazards associated with specific foods or production processes. According to the Food and Drug Administration (FDA), the system controls the identified threats “reasonably likely to occur.”

What is a Food Safety Plan?

A Food Safety Plan consists of the primary documents in a preventive controls food safety system that provides a systematic approach to identifying food safety hazards to prevent or minimize the likelihood of foodborne illness or injury. It contains written documents that describe activities that ensure food safety during manufacturing, processing, packing, and holding. See 21 CFR 117.126.

Both HACCP and FSP share responsibility for food safety and quality. This responsibility involves establishing and maintaining proactive and effective food safety management systems at the manufacturing level.

The U.S. Federal regulations issued by the FDA have mandated HACCP systems for seafood (21 CFR part 123) and juice (21 CFR part 120). and by the Food Safety and Inspection Service (FSIS) for meat and poultry (9 CFR part 417). In addition, some organizations require a separate HACCP plan for each food product, processing method, and facility for which there are unique risks involved.

All other food sectors required to register with the FDA, other than exempt sectors such as alcoholic beverages and dietary supplements, are mandated by regulatory agencies to comply with Preventive Control for Human Food regulations. In addition, any food processing entity that was not previously subject to HACCP must develop and implement a Food Safety Plan.

It is essential to know the differences between these two management systems to understand how to take action to ensure that you are managing your plans per your industry’s compliance regulations and food safety standards. In the following paragraphs, we discuss each of these elements.

Difference:

1.-Type of hazards

• Under the basic HACCP systems, this refers to biological, chemical, and physical hazards.
• Under the preventive control approach for your food safety plan, you have to consider three additional types of hazards, including radiological hazards as a type of chemical hazard. It also includes economically-motivated adulteration associated with food fraud and the potential for environmental contamination in facilities that produce ready-to-eat food products.

2.-Preventive Controls

• For HACCP, the hazard analysis leads to identifying critical control points (CCPs) where essential process controls are needed to prevent a foodborne hazard from causing illness or injury.
• In the context of an FSP, preventive controls may be applied at CCPs and points other than at CCPs. Therefore, the focus is on CCPs, a type of preventive process control, and on identifying other applicable preventive controls for allergens, sanitation, and the supply chain.
  

3.-CCPs & Parameters

• For HACCP, there must be critical limits at CCPs. Once CCPs are identified, critical limits to define the operating conditions in the process must be effectively managed and monitored to control the hazard.
• Under the FSP approach, there are defined parameters with minimum and maximum values. However, they may not be practical for non-process-related preventive controls, such as hygienic zoning controls to prevent cross-contact and cross-contamination or ensuring that suppliers have adequately controlled hazards in the foods they provide to a manufacturer/processor.
  

4.-Monitoring

• For HACCP, the CCPs are constantly being monitored.
• In an FSP, monitoring is required only as appropriate for preventive controls, and it may not be necessary for some preventive controls not applied at CCPs.
  

5.-Corrective Actions and Corrections

• For HACCP, corrective actions are taken for deviations from a critical limit at a CCP.
• An FSP also provides for facilities to take corrective actions. However, immediate corrections (e.g., re-cleaning and sanitizing a line before start-up of production when food residue remains after cleaning) may be more appropriate for some preventive controls than a specific corrective action involving product risk evaluations of product safety for some preventive controls.
  

6.-Verification

• For HACCP, verification activities are required for process controls to ensure the process can control the hazards, and the HACCP plan is followed.
• In the context of an FSP, because preventive controls do not just process controls, there is flexibility to conduct verification activities as appropriate to the food, the facility, and the nature of the preventive control and its role in the food safety system.
  

7.-Validation

• As previously mentioned, some HACCP systems (e.g., for juice, meat, and poultry products) require validation of the plan as a whole.
• In the context of an FSP, validation means obtaining and evaluating scientific and technical evidence that a control measure, combination of steps, or the FSP as a whole can effectively control the identified hazards. The extent of validation activities may be less rigorous for some preventive controls than others or may not be required (e.g., sanitation controls).
  

8.-Records

• For HACCP, records are required for process controls.
• In an FSP, records are required as appropriate for all preventive controls.
  

9.-Recall Plan

• For HACCP, a recall plan is not required.
• In an FSP, a Recall Plan must be prepared for each product for which a hazard requiring preventive control has been identified.
  

HACCP and Food Safety Plans are processes that food businesses can follow to minimize the risk of unsafe food. It has evolved into the fundamental principle for assessing the risk associated with food processing and handling. Despite the differences, compliance with these programs calls for extensive preparation and ongoing due diligence. Therefore, understanding the differences between these two systems is essential to ensuring compliance.

References:

21 C.F.R. § 117.126 2016. Link: https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-117/subpart-C/section-117.126
21 C.F.R. § 123. Link: https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-123
21 C.F.R. § 120. Link: https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-120
9 C.F.R. § 417. Link: https://www.ecfr.gov/current/title-9/chapter-III/subchapter-E/part-417

Nahomy Garcia, B.Sc.

“I currently work as a food safety expert in the HACCP department of the company. I am in charge, together with my team, of developing food safety plans such as HACCP and PC plans under FDA, CFIA, or USDA/FSIS regulations, to achieve food certification projects for our clients.”