Who needs a HACCP plan, and how is it different from an FDA food safety plan?

HACCP (Hazard Analysis and Critical Control Point) is a written plan that identifies the hazards in a process and controls them at specific points. U.S. law requires it for three groups: juice processors (21 CFR 120), fish and seafood processors (21 CFR 123) and USDA-inspected meat and poultry establishments (9 CFR 417).

In all three, you start with a hazard analysis, and a written HACCP plan is required when that analysis finds hazards that are reasonably likely to occur. For the juice rule, "juice" includes liquid extracted from fruits or vegetables, purees and concentrates, whether sold as juice or used as a beverage ingredient. Most other FDA-regulated plants do not write a HACCP plan; they write a food safety plan under the Preventive Controls rule (21 CFR 117). A plant that complies with the juice or seafood HACCP rule is exempt from the hazard analysis and preventive controls parts of Part 117 for those activities.