I am super confused on how preventive controls compares to HACCP control points. I work at a small candy company and am trying to use the FSP Builder from the FDA to convert our HACCP plans into FSMA compliant Food Safety Plans.
We make a very low risk product. Our candy HACCP plan has no CCP and just a few control points. Almost all of the control points in the process except for the cook step are contained within the pre-requisite programs of Allergen Program, Sanitation Program, Pest Program, etc.
1. For each step where a hazard is known or foreseeably known, how do I determine if it rises to the level where a preventive control is REQUIRED?
2. Also, if the preventive control is NOT REQUIRED, then do I still have to write out a complete hazard analysis in the software as if a preventive control is required to show verification, validation, and monitoring/limits that the control is effective? Which in my case is the verification/validations I do of the Allergen and Sanitation Program on a regular basis.
3. Anyone willing to take a look at the HACCP plan to see what needs to be updated for FSMA compliance?