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If the foreign processor does not have a formal HACCP plan but takes all steps necessary to assure safety of products, is this sufficient?

April 26, 2017foreign formal HACCP necessary Plan processor safety steps takes

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If the foreign processor does not have a formal HACCP plan but takes all steps necessary to assure safety of products, is this sufficient?

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No, the regulations, section 123.6(b), require every processor (domestic and foreign) to have and implement a written HACCP plan whenever a hazard analysis identifies one or more food safety hazards that are reasonably likely to occur in the product.