For those of us in Canada - The HARPC program is a new twist that needs to be adressed. HARPC is an American FDA program and is the acronym for Hazard Analysis and Risk-based Preventive Controls. It is part of the FDA food modernization act and is meant for all US based non-regulated food companies. Any US based company that is "regulated" with a HACCP plan is exempt from the HARPC program.
All food companies, exporting food to the USA, need to have a HARPC plan registered with the US FDA. Below are only a few websites that have good info on this program. It seams to me that if you are certified with a GFSI program, you should be good for HARPC. You will still need to send your HARPC plan to the FDA.
I do like the idea of HARPC being "risk" based. Also, HARPC does look at all hazards - not just bio terrorism. One fault, in my opinion is, this program does not seam to mention food FRAUD. If fraud were to be addressed in HARPC - it would take the US program to a new, higher level.
http://www.harpc.com/what-is-harpc/
http://www.foodsafetytech.com/FoodSafetyTech/Features1/Moving-from-HACCP-to-HARPC-1591.aspx
http://www.foodprocessing.com/articles/2013/fda-haccp-harpc/
https://www.aibonline.org/newsletter/Magazine/.../8AreYouQualified.pdf
http://www.fdaimports.com/industries/food_beverages/food_safety_mod_act_2011/harpc_risk_prevention.php
