Preventive controls or HACCP: which framework actually governs your facility
One of the most expensive early mistakes in food compliance is building the wrong framework. Preventive controls, seafood HACCP and juice HACCP are not interchangeable, and a customer requirement is not the same thing as a regulatory requirement.
Key points
- Part 117 preventive controls, Part 123 seafood HACCP and Part 120 juice HACCP are largely allocated by product category, not layered.
- Retail food establishments are generally regulated under a locally adopted food code rather than by the preventive controls rule.
- Exemptions and modified requirements are extensive; applicability depends on your activities and sales figures.
- A customer or certification requirement for HACCP is separate from, and additional to, whatever FDA rule governs you.
