CFR 117.135(a)(2) of the Preventive Controls for Human Food rule states that preventive controls include: “(i) Controls at Critical Control Points (CCPs), if there are any CCPs”; and “(ii) Controls, other than those at CCPs, that are also appropriate for food safety." There is considerable interest and some confusion among food safety professionals as we debate and attempt to decide the appropriate preventive controls for a manufacturing facility. Decisions on how to choose, verify, and validate “controls other than CCPs” can be difficult, especially for smaller companies. This symposium will serve as an interactive session for industry to share practices and lessons learned for decisions on CCPs, Operational Prerequisite Programs (OPrPs), and Prerequisite Programs (PrPs); how to identify them, how to implement them, and how to verify and validate them where applicable. Speakers will discuss the various decision trees that can be used to determine different types of preventive controls based on hazard analysis, practical examples and considerations for their choices, verification and validation options for these types of controls, and a discussion on regulatory implications of preventive control choices.  Attendees should feel free to start discussions about these examples, to collectively benchmark current practices among participants.

Presentations