The Difference Between HACCP And HARPC: A Case Of The Emperor's New Clothes?

By George Howlett, Safefood 360°

What does a child’s tale by Hans Christian Andersen have to do with a piece of American legislation issued regarding food safety? In my efforts over recent weeks to get to grips with the new FSMA Rules, I believe quite a lot. But, before I get in to all that, I would like to talk more generally about FSMA and what I perceive to be its impacts.

FSMA — Changing The Rules Of The Game
Recent issuing of a number of final rules under FSMA has now placed these specific compliance requirements for food businesses firmly in the spotlight. As with any new or changed piece of legislation or food safety standard, it is important to undertake a review of the requirements to see how they impact food safety management software platforms and the needs of food manufacturers and processors. Normally, this is a straight-forward process given food safety and its management is core to food safety software providers. Identifying and making any necessary changes to the software is a matter of routine. Not so however, for FSMA.

FSMA is an interesting animal to observe. Unlike other pieces of food safety legislation, e.g. EU Food Regulations, reading the requirements of FSMA rules is nothing short of a new vocation for those brave enough to undertake it. It certainly isn’t light bedtime reading. It is legal in its language, circular in nature, and more effective at making your head spin than a NASA human centrifuge. You need to be made of the right stuff!

However, FSMA is interesting for none of the above reasons. It is compelling for one reason alone. It’s actually a good piece of legislation. Once you cut through the layers of legal jargon surrounding the requirements contained therein, what we find is something very clear, very prescriptive, and which leaves little to the imagination. And, as strange as it may sound, this is actually a very good thing.

Most food safety legislation globally tends to be general, stating what needs to be done rather than how it should be done. On the face of it, this might appear as a smart approach. However, it can leave the door wide open to interpretation by companies, auditors, and regulators.