What are the differences between traditional HACCP based food safety plans and the new Preventive Controls required by the Food Safety Modernization Act (FSMA)?


Applies to low-acid, canned food, juice, and seafood processors, HARPC applies to almost all food-processing facilities.  Its mandatory application is for juice, seafood, retail, and foodservice.  Primarily concerned with raw materials, products, and processes, and often are mandated by large brands to their suppliers, and suppliers’ suppliers.

  • Requires a team.
  • Plan covers chemical, biological and physical hazards.
  • Identifies CCPs, doesn’t recognize Preventive Controls.
  • Conduct a hazard analysis
  • Determine the Critical Control Points (CCPs)
  • Establish critical limit(s)
  • Establish a system to monitor control of the CCP
  • Establish the corrective action to be taken when monitoring indicates that a particular CCP is not under control
  • Establish procedures for verification to confirm that the HACCP system is working effectively
  • Establish documentation concerning all procedures and records appropriate to these principles and their application


Requires that companies have written plans that identify hazards, list the steps needed to minimize or prevent those hazards, identify monitoring procedures and record the results, and specify what actions will be taken to correct should problems arise. These plans will be evaluated by FDA, and checked for proper implementation and adherence.

  • Requires a qualified individual with training and experience.
  • Plan covers chemical, biological and physical hazards as well as radiological hazards.
  • Requires technical or scientific information that backs up the plan. Specifically, information that demonstrates the plan will be effective at controlling hazards.
  • Conduct a thorough hazard analysis for all food-processing procedures.
  • Develop and implement preventive controls, and then monitor the controls’ effectiveness.
  • Provide a detailed plan in writing, describing how the hazards will be controlled, and the preventive controls put in place, and a schedule and methodology for monitoring the efficiency of the controls.
  • Verify the effectiveness of the controls, also maintaining written records of the verification processes.


Covered facilities must establish and implement a food safety system that includes an analysis of hazards and risk-based preventive controls. The rule sets requirements for a written food safety plan that includes:

Hazard analysis: The first step is hazard identification, which must consider known or reasonably foreseeable biological, chemical, and physical hazards. These hazards could be present because they occur naturally, are unintentionally introduced, or are intentionally introduced for economic gain (if they affect the safety of the food).

Preventive controls: These measures are required to ensure that hazards requiring a preventive control will be minimized or prevented. They include process, food allergen, and sanitation controls, as well as supply-chain controls and a recall plan.

Monitoring: These procedures are designed to provide assurance that preventive controls are consistently performed. Monitoring is conducted as appropriate to the preventive control. For example, monitoring of a heat process to kill pathogens would include actual temperature values and be more frequent than monitoring preventive maintenance activities used to minimize metal hazards, which could be a simple record of the date on which the activity took place.

Corrective actions and corrections: Corrections are steps taken to timely identify and correct a minor, isolated problem that occurs during food production. Corrective actions include actions to identify a problem with preventive control implementation, to reduce the likelihood the problem will recur, evaluate affected food for safety, and prevent it from entering commerce. Corrective actions must be documented with records.

Verification: These activities are required to ensure that preventive controls are consistently implemented and effective. They include validating with scientific evidence that a preventive control is capable of effectively controlling an identified hazard; calibration (or accuracy checks) of process monitoring and verification instruments such as thermometers, and reviewing records to verify that monitoring and corrective actions (if necessary) are being conducted.

Product testing and environmental monitoring are possible verification activities but are only required as appropriate to the food, facility, nature of the preventive control, and the role of that control in the facility’s food safety system. Environmental monitoring generally would be required if contamination of a ready-to-eat food with an environmental pathogen is a hazard requiring a preventive control.

Advantages of the Iron Apple Food Safety Solution for Carriers

Iron Apple InternationalWe have developed a food safety program that meets requirements from both US and CA new and future regulations, that has been tailored and developed specifically for the trucking / logistics industry, ready to be installed today!  Here are several benefits of the Food Safety Solution for Carriers:

  • Our Food Safety Solution for Carriers meets all of the new food safety regulations from the CFIA and US-FDA, valid in Canada and the United States.
  • When you receive an Iron Apple PCP certificate of compliance, you will also be compliant with the following food safety plans:
    • Preventive Controls Plan (PCP) Compliance; valid for 1 year.
    • HACCP Requirements and Compliance; valid for 1 year.
    • FSEP Requirements and Compliance; valid for 1 year.
    • HARPC Compliance; valid for 1 year.
    • Sanitary Transportation of Human and Animal Food Regulation; valid for 1 year.
  • Iron Apple provides a full range of food safety training, ongoing customer care and support, one-on-one consultation with food safety experts, digital solution and data management.
  • Compliance audits will be completed by Iron Apple’s exclusive third party audit partner, SAI Global, throughout North America. Iron Apple will share industries best practices from all transporters to continuously improve upon existing systems and procedures.
  • As a digital system we offer many benefits over paper version food safety systems
    • Always-up-to-date Regulatory References – direct links to regulation requirements.
    • Digital document management with redundant off-site backups.
    • Ease of access from anywhere through supported internet browsers (no software required to install program).
    • Light-weight framework designed for speed and mobile connections.

Iron Apple International has ensured that the content of our program meets all government requirements for both United States and Canada.  We’ve built a digital platform to offer the best possible delivery of our program.

For over 3 years, we’ve worked with leaders in the trucking industry to tailor a solution specifically for trucking companies.  We’ve simplified all aspects of the food safety regulations, becoming compliant and staying compliant.

With our program, there are only 4 steps to a successful compliance audit:

  1. Review and understand the Prerequisite Components for Certification.
  2. Implement Prerequisites Requirements and Required Record Keeping.
  3. Implement Preventive Controls and Collect Accurate Data for a 90 Day Period.
  4. Completion of a Successful Compliance Audit.

Get Started Today!