How Does HARPC system differ from HACCP ?

“What is the difference between the Hazard Analysis and Critical Control Points (HACCP) and the Hazards Analysis and Risk-Based Preventive Controls (HARPC)?” is a question we often hear from professionals working in the food industry and expected to be raised more often having been involved in managing the food safety systems based on the HACCP concept which is universally accepted by government agencies, trade associations and the food industry around the world ( NACMCF, 1997). HACCP is based on the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution and consumption of the finished product in order to reduce the risks of safety hazards in food. It is based on 7 principles:

Principle 1: Conduct a hazard analysis.

Principle 2: Determine the critical control points (CCPs).

Principle 3: Establish critical limits.

Principle 4: Establish monitoring procedures.

Principle 5: Establish corrective actions.

Principle 6: Establish verification procedures.

Principle 7: Establish record-keeping and documentation procedures

The HARPC is based on these same basic food safety principles; more specifically, it recognizes the importance of hazards analysis and setting critical limits to monitor the control points; it emphasizes the corrections/corrective actions, verification activities and the recall plan. The preventive approach is not recent, it dates back to the 60’s when the HACCP was pioneered by the Pillsbury corporation to ensure food safety for the first manned National Aeronautics and Space Administration space missions. NASA’s main concerns were to ensure safe food for astronauts. The WHO Europe recommended the system in 1983 and the Codex released the first HACCP Guidelines which was revised in 2001 and adopted by the FAO/WHO Codex Alimentarius Commission. The U.S.National Advisory Committee on Microbiological Criteria for Foods (Committee) reconvened a Hazard Analysis and Critical Control Point (HACCP) Working Group in 1995. The primary goal was to review the Committee’s November 1992 HACCP document, comparing it to current HACCP guidance prepared by the Codex Committee on Food Hygiene. The Committee again endorses HACCP as an effective and rational means of assuring food safety from harvest to consumption. NACMCF issues the third revision document in 1997.

Basically, the HACCP was integrated into the official regulations in the European Union and the United States. For instance, the U.S. Food and Drug Administration adopted HACCP in low acid canned foods, then the FDA mandated HACCP for seafood products and in 2001 for juice processors. The Council Directive no. 91/493/EEC places the responsibility of product safety on the industry as it introduced the concept of ‘own checks’ and Critical Control Points during processing and the Commission Decision 94/356/EEC details the rules for the application of the HACCP system.

The term HARPC goes back to 2011, when the Food Safety Modernization Act (FSMA) was signed into law by President Barack Obama. FSMA directs FDA to establish standards for adoption of modern food safety prevention practices by those who grow, process, transport, and store food. In 2015, FDA has finalized seven major rules to implement FSMA; the Hazards Analysis Risk-Based Preventive Controls for Human food is one of those 7 rules which is also referred to as The Preventive Controls for Human Food (PCHF). The Hazards Analysis Risk-Based Preventive Controls for Human food (HARPC) requirements specify that a facility must prepare, or have prepared, and implement a written food safety plan (FSP) (21 CFR 117.126).

The elements of the FSP are (21 CFR 117.126(b)):

  • Hazard analysis
  • Preventive controls (see 21 CFR 117.135), as appropriate to the facility and the food, to ensure safe food is produced,
  • Procedures for monitoring the implementation of the preventive controls, as appropriate to the nature of the preventive control and its role in the facility’s food safety system
  • Corrective action procedures, as appropriate to the nature of the hazard and the nature of the preventive control
  • Verification procedures, as appropriate to the nature of the preventive control

The preventive controls approach to controlling hazards used in an FSP is developed based on the risk-based HACCP principles as described by the National Advisory Committee on Microbiological Criteria for Foods

It is important to note that the preventive controls approach to controlling hazards used in an FSP is developed based on the risk-based HACCP principles as described by the National Advisory Committee on Microbiological Criteria for Foods. Therefore, there are similarities between the FSP and a HACCP plan and the similarities are in the essence of both systems; both adopt the preventive approach , yet there are few differences. Table 1 shows the different elements required in each of the plan and how they differ:

من يعالج الأمراض الناجمة عن تلوث الليطاني والمزروعات؟

موضوع تلوث مياه نهر الليطاني ليس بالجديد. لطالما تردّد أن الأسباب الرئيسية لتلوّث مياه نهر الليطاني هي غياب النظم الفعّالة لمعالجة مياه الصرف الصحي والنفايات الصناعية السائلة غير المعالجة التي تصبّ كلّها في التربة والمياه وقطع طريق النهر بسد القرعون. وقد تكثّفت الاجتماعات التي كان آخرها أمس للمعالجة، ولكن ما هي المخاطر التي تشكلها تلك…

UAE ban on import of fruits and vegetables: the national standards is a priority

Translated version (brief) of my column in the arabic Al-Akhbar newspaper الحظر الإماراتي لاستيراد الفواكه والخضار: سلامة المعايير الوطنية أولوية

Recently, the UAE banned the importation of vegetables and fruits from Lebanon and other countries because they contain high levels of pesticide residues that exceed the permitted levels according to their own standards. According to Al Bayan newspaper published in Dubai on 25 April 2017, the ban includes all types of apples from Lebanon.

The Microbiological Safety of Fresh Produce in Lebanon-A holistic “farm -to-fork chain” assessment approach

The consumption of unsafe fresh vegetables has been linked to an increasing number of outbreaks of human infections. In Lebanon, although raw vegetables are major constituents of the national cuisine, studies on the safety of fresh produce are scant. This research employed a holistic approach to identify the different stages of the food chain that contribute to the microbiological risks on fresh produce and the spreading of hazards. A thorough analysis of the institutional and regulatory framework and the socio-political environment showed that the safety of local fresh produce in Lebanon is at risk due to largely unregulated practices and shortfalls in supporting the agricultural environment as influenced by the lack of a political commitment.

The transfer rate of Salmonella Typhimurium from one contaminated parsley to other consecutively chopped batches- Modeling “Tabbouleh” preparation

It is becoming more evident that Salmonella-associated outbreaks are not limited to contaminated foods of animal origin; they are periodically linked to consumption of fresh produce, including parsley and lettuce and S. Enteritidis and S. Typhimurium have been commonly isolated from fresh vegetables. Salmonella spp. can be transferred to the food chain directly from human or animal faecal sources, run-off of nearby farms, untreated manure, or from contaminated irrigation water. Additionally, there are various routes for cross-contamination in the kitchen and processing environments. Of food contact surfaces, cutting boards were shown to represent critical risk factors of cross-contamination and recontamination events. In many Mediterranean and Middle Eastern countries, leafy green parsley is typically eaten raw and prepared by fine chopping several batches.

Microbiological quality of ready-to-eat fresh vegetables and their link to food safety environment and handling practices in restaurants in Lebanon

The increased consumption of ready-to-eat (RTE) salads outside homes as a result of a fast paced lifestyle, awareness on their nutritional attributes and enhanced processing technology is well documented. Outbreak investigations often indicate that food service establishments greatly contribute to food-borne illnesses involving fresh produce.

Fifty small and medium sized (SME) restaurants in Beirut were surveyed for their food safety climates. A total of 118 samples fresh-cut RTE salads vegetables and 49 swabs of knives and cutting boards were collected for microbiological analysis.

A number of food safety practices concerns were identified in this study. The general lack of cleaning and sanitization procedures combined with a clear evidence of cross-contamination opportunities were generally reflected in the overall unsatisfactory quality of RTE vegetables.

Prevalence of antimicrobial – resistant Escherichia coli from raw vegetables in Lebanon

Fresh produce has been implicated in a number of documented outbreaks of foodborne illness caused by bacteria, viruses, and parasites. Shiga toxin-producing Escherichia coli (STEC) have been detected on vegetables, raising concerns about the prevalence of E. coli contamination in produce, which can take place at various points from farm to fork. The prevalence of antimicrobial-resistant E. coli and potential transmission from soils and in the animal production environment to fresh produce at harvest has been documented, as has the further flow of resistance from fresh produce bacteria via gene transfer to enterobacterial strains in humans.The most common route for fresh produce contamination is at the pre-harvest stage, when microorganisms from animal feces, contaminated irrigation water, and wild and domestic animals can be deposited in crops. Even though foodborne disease outbreaks due to contamination of fruit and leafy green vegetables with pathogens have been rarely documented in Lebanon or the whole Middle East Region, they undoubtedly occur based on surveillance data from other regions. Therefore, the study aimed to detect the presence of STEC and multidrug-resistant (MDR) E. coli on fresh vegetables and water from different sources along the fresh produce supply chain in Lebanon.