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Food Safety Command Center 15 items

HARPC Food Safety Plan Reanalysis Checklist

Guide the periodic reanalysis of a HARPC food safety plan, verifying triggers, hazard re-evaluation, and required updates under the Preventive Controls for Human Food rule.

21 CFR 117FSMA Preventive Controls

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Reanalysis Triggers

  • Has the food safety plan been reanalyzed at least once every three years? *
  • Was a reanalysis performed whenever a significant change in activities created a reasonable potential for a new hazard or increased a previously identified hazard? *
  • Was the plan reanalyzed after new information about potential hazards associated with the food became available? *
  • Was reanalysis triggered when a preventive control or the food safety plan was found to be ineffective? *
  • Date reanalysis initiated

Hazard Re-Evaluation

  • Was the hazard analysis reviewed for new biological, chemical, and physical hazards, including radiological and economically motivated hazards? *
  • Were changes in raw materials, suppliers, and ingredients evaluated for new hazards? *
  • Were process, equipment, and facility changes assessed for their impact on identified hazards? *
  • Were consumer complaints, recalls, or illness data considered as inputs to the reanalysis?

Preventive Control Adequacy

  • Were existing preventive controls confirmed to remain adequate for controlling identified hazards? *
  • Were critical limits, monitoring, corrective actions, and verification procedures reviewed for continued suitability? *
  • Were any new or revised preventive controls implemented as a result of the reanalysis?

Completion and Documentation

  • Was the reanalysis completed within 90 days of production of the applicable food, or was a written justification for a longer timeframe prepared? *
  • Was the reanalysis conducted or overseen by a preventive controls qualified individual (PCQI)? *
  • Were plan revisions and the reanalysis outcome documented as records? *

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