HACCP in the Food Safety Modernization Act of 2011

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All food and beverage manufacturing companies, except for the very small, are required to have a written HACCP plan available for review should you be called upon. Have you examined your HACCP plan recently?

The language that is presented in the new law is worded as Hazard Analysis and Risk-Based Preventive Controls which may differ from HACCP but has yet to be fully defined by the FDA.

Hazard Analysis and Risk-Based Preventive Controls
This part of the law will take effect in July, 2012, when all registered facilities will be required to conduct a hazard analysis, implement preventive controls, and develop a food safety plan to document the monitoring, correction, and verification of preventive controls. The food safety plan and all related documents must be made available to FDA during inspections. As part of its food safety plan, a facility may be required to document sanitation procedures, a recall plan, a food allergen control program, supplier verification activities, and environmental sampling testing. The American Bakers Association (ABA) and AIB International have stated that the HACCP plan will likely be closer to that required by seafood and juice manufacturers.

The preventive controls requirements only apply to registered facilities. Under the current definition, farms, restaurants, and retail facilities are exempt from the registration requirement. Currently, farms are defined as a facility devoted to the growing and harvesting of crops for food and/or the raising of animals for food (including seafood). The current definition includes farms that pack, hold, process, or manufacture food, if all of the food is consumed on that farm or another farm under the same ownership. Under the new legislation, FDA must develop regulations defining what constitutes on-farm packing, holding, manufacturing, and processing. Some facilities that are only engaged in specific types of on-farm manufacturing, processing, packing or holding activities that are determined to be low-risk may be exempt or subject to modified preventive controls requirements. Additional exemptions apply for qualified facilities that sell under $500,000 of food annually and sell either directly to consumers or to a restaurant or retail establishments that are located in the same state or not more than 275 miles from the facility.

These HACCP Plans are required to be updated every 3 years. You will be required maintain records and make them available for review for a period of 2 years.

We have attached a brief overview of HACCP regulations for seafood and juice manufacturers for your review. We work every day to assure that the bcFood ERP solution meets all compliance regulations and these new regulations are no exception. We also encourage you to visit the FDA website to learn more about HACCP Plans.

As always, we would appreciate the opportunity to stay in touch with you and if we can be of assistance in any way, please feel free to contact Beck Consulting, a Southern California Dynamics NAV Partner, to learn more about bcFood.

 by Bruno Johansson, Beck Consulting

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