What is the difference between HACCP and PCQI? 

Is the food safety plan different than HACCP? I had HACCP training, is that good enough? 

Your facilities may already have a HACCP plan in place. Typically, HACCP plans focus on process controls. The food safety plan goes one step further and includes preventive controls. 

Supply chain, allergen, and sanitation activities have typically been included in the GMPs or prerequisite programs. In the preventive controls regulation, these may be elevated into the food safety plan as preventive controls.  

Sometimes a hazard analysis identifies a specific hazard. For example, recontamination of product after a kill step. Then these activities become more important. In that example, a sanitation control is needed to control the hazard of recontamination. Sanitation is being used to control a hazard identified during the hazard analysis. We need to elevate that to a preventive control. 

The sanitation circle overlaps in both GMPs and the food safety plan, showing that sometimes sanitation activities are GMPs, but some may be elevated into the food safety plan. They may become preventive controls. In this example, sanitation to prevent the recontamination of product will become a preventive control, but general sanitation will remain a GMP. 

The same thing can happen with allergen controls or supply chain controls. When you see a specific hazard during hazard analysis, we will need to address those with the preventive control. So those activities now become part of the food safety plan. The requirement for becoming qualified to be the PCQI is that you have “successfully completed training in the development and application of risk-based preventive controls, at least equivalent to that received under a standardized curriculum recognized as adequate by the FDA”. HACCP courses do not meet this definition. 

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