After reading the draft regulations of the Food Safety Modernization Act and some of the comments that have come out, I found the February 14, 2013 comments by David Acheson from Leavitt Partners quite interesting, especially his comment alluding that the new regulations were “HACCP on steroids.” I can’t quite agree with that, especially as one who has been involved with teaching Hazard Analysis and Critical Control Points (HACCP) for 20 years and as a member of the United States delegation to the ISO committee that developed the ISO 22000 standard, “Food safety Management systems — Requirements for any organization in the food chain.” Looking at the ISO 22000 standard and the draft regulation, one could almost call the preventive controls draft “ISO 22000 lite.” In fact, when looking over the preamble in the section entitled “HACCP in the international food safety community,” ISO 22000 is not even mentioned and the Global Food Safety Initiative (GFSI) gets one sentence. The ISO 22000 standard addresses all of the documentation issues cited in the draft standard plus utilizes the operational prerequisite program (oPRP) to address hazards that have been identified and are not specifically controlled using critical control points. In other words, two types of preventive controls.
It is surprising that these elements were not addressed in the preamble, especially since ISO 22000 is an international standard that has received excellent acceptance globally since it was issued in 2005. We must also remember that this draft regulation will have an impact on other nations, so it might be a good idea to utilize language and programs that have been accepted around the world.