Service area
HACCP Development, Review & Training
Plans that survive validation, verification and the inspector's questions.
- Service lines
- 8 listed
- Delivery
- Onsite and remote
- Coverage
- United States
Overview
What this covers
The most common HACCP problem we encounter is not a missing plan. It is a plan that was written once, adopted from a template, and never reconciled with the equipment, product mix or process the plant runs today. Critical limits with no scientific basis, monitoring frequencies nobody follows, and corrective action records that stop at 'product held' are all findings waiting to happen.
We build plans from the process, not from a template library: flow diagram verification on the floor, hazard analysis with documented reasoning, critical control point determination, critical limits tied to a citable basis, and verification and validation activity that a third party can follow. Where a specialized process needs a variance or a HACCP plan under a state's adopted food code, we prepare that package.
Who this is for
- Seafood processors and importers subject to 21 CFR Part 123
- Juice processors subject to 21 CFR Part 120
- Retail food establishments running specialized processes such as reduced oxygen packaging, curing, smoking, sushi rice acidification, sprouting or fermentation
- Manufacturers whose customers or certification scheme require a HACCP plan alongside a preventive controls food safety plan
- Operators who need an independent second read of an existing plan before an audit or regulatory review
HACCP services
- HACCP development
- HACCP review
- Seafood HACCP – 21 CFR Part 123
- Juice HACCP
- Retail HACCP
- Specialized process HACCP
- Variance assistance
- HACCP training
Engagements are scoped to what applies to your operation. Where a listed service is not relevant to your products, processes or jurisdiction, we will say so.
How an engagement runs
Sequenced so each step earns the next.
Nothing gets written before the operation is verified, and nothing is declared complete before it has been tested against the standard it will be judged by.
Process verification on the floor
We walk the line and confirm the flow diagram against reality — every step, every ingredient addition, every rework and hold point. A plan built from a drawing that does not match the plant fails at the first serious question.
Hazard analysis and CCP determination
Documented reasoning for each hazard considered, the decision on whether it is reasonably likely to occur, and whether it is controlled at a CCP, by a prerequisite program, or downstream. The written justification matters as much as the conclusion.
Critical limits and validation
Critical limits tied to a defensible basis — regulatory guidance such as the FDA Fish and Fishery Products Hazards and Controls Guidance, published process authority letters, or study data — with monitoring and verification frequencies your team can realistically sustain.
Variance and regulatory submission support
Where a jurisdiction requires a variance for a specialized process, we assemble the submission: process description, hazard analysis, supporting science, HACCP plan and monitoring records. Approval rests with the regulatory authority.
Training and handover
HACCP training for the team who will run the plan, plus reassessment discipline so the plan is revisited when the process, equipment, supplier or product changes — not only when an auditor asks.
Regulatory basis
The requirements behind the work.
Applicability depends on your products, processes, size and jurisdiction. Exemptions and modified requirements exist throughout these rules, and part of the engagement is establishing which apply to you.
Summaries below are educational and simplified. They are not legal advice and do not replace the text of the regulation or guidance from your regulatory authority or counsel.
- 21 CFR Part 123
- Fish and Fishery Products. Requires a HACCP plan for each kind of fish and fishery product processed, plus sanitation control records and, for importers, verification that imported product was processed under HACCP-equivalent conditions.
- 21 CFR Part 120
- Hazard Analysis and Critical Control Point systems for juice processing, including the pathogen reduction performance standard applicable to juice.
- FDA Food Code (as adopted by each jurisdiction)
- Retail specialized processes generally require a HACCP plan and often a variance. Adoption, edition, and variance procedure vary by state, county and city, so the requirement must be confirmed with your regulatory authority.
- 21 CFR Part 113 / Part 114
- Thermally processed low-acid foods in hermetically sealed containers and acidified foods. These carry their own scheduled process and process authority requirements distinct from HACCP, and may apply depending on your product.
Applied by industry
How this looks in practice.
The same regulatory framework produces very different programs depending on the operation it lands in.
- Sushi / SeafoodSeafood carries species-specific hazards and its own federal HACCP rule. Sushi programs add acidified rice and raw consumption on top. Both draw regulatory attention.
- Food ManufacturersFDA inspection, customer audits and GFSI certification all test the same underlying system. We build it once, properly, so each of those reviews draws on the same evidence.
- RestaurantsPublic inspection results, high turnover and thin margins make retail food safety unforgiving. We inspect against your jurisdiction's adopted code and close findings before the health department returns.
- Grocery RetailA supermarket is a dozen different food businesses under one roof, each with its own hazards. We assess department by department and build controls that fit how each one actually runs.
- Foodservice OperationsContract foodservice, healthcare, education and catering combine high volume, off-site transport and often highly susceptible populations. Consequences scale with the number of covers.
Questions we get asked
HACCP — common questions
Do we need HACCP if we already have a FSMA food safety plan?
Sometimes both, sometimes one. Seafood and juice operations are regulated under Part 123 and Part 120 respectively and are generally exempt from the Part 117 preventive controls requirements for those products, though CGMPs still apply. Many manufacturers outside those categories need a Part 117 food safety plan, and separately need a HACCP plan because a GFSI scheme or a retail customer requires it. We determine which framework governs before writing anything.
Our sushi program was told it needs a variance. Is that normal?
Yes, in many jurisdictions. Acidifying sushi rice to hold it at room temperature is a specialized process under most adopted food codes, and the regulatory authority typically requires a HACCP plan and often a variance before you can operate without time or temperature control. Requirements differ meaningfully between jurisdictions, so the first step is confirming what your specific health department requires.
Can you review a plan we already have rather than rewrite it?
Often that is the better value. An independent HACCP review compares your plan against the applicable regulation and against your actual process, flags unsupported critical limits and record gaps, and gives you a prioritised correction list. If the underlying hazard analysis is sound, rewriting from scratch wastes your money.
Related
Other practice areas
FDA & FSMA Compliance
The FDA Food Safety Modernization Act moved the regulatory burden from reacting to contamination to proving you prevented it. We build the hazard analysis, preventive controls, supplier verification and records systems that carry that burden — and we prepare your team for the inspection that tests them.
Read moreDietary Supplements
Part 111 is a specification-driven rule. Most observations we see trace back to a specification that was never established, an identity test that was never performed, or a batch record that a quality unit signed without the supporting data attached.
Read moreManufacturing
Preventive controls only work when the programs beneath them do. We build and audit the prerequisite layer — sanitation, environmental monitoring, allergen segregation, food defense, supplier approval — and the CAPA discipline that keeps findings from repeating.
Read more
HACCP
Tell us what you need to be ready for.
Send the operation, the products and the deadline. We will tell you which parts of haccp apply to you and what it takes to be ready — in writing, before you commit.
Direct contact
- info@surucompliance.com
- 651-329-4787
- Serving food businesses nationwide, onsite and remotely.
SURU Compliance is a regulatory consulting practice. We are not a government agency, a certification body, or a law firm, and we do not provide legal advice or guarantee regulatory outcomes.