HARA vs HACCP: What BRCGS Consumer Product Manufacturers Can Borrow From Food Safety

By Robert Low, Lead Management System Specialist and BRCGS Approved Trainer

Anyone who has worked in food manufacturing will look at the HARA methodology in the BRCGS Consumer Products Issue 5 draft and feel immediate recognition. Team, prerequisites, product description, flow diagram, hazard analysis, controls, limits, monitoring, corrective action, verification. That is the Codex HACCP architecture, adapted for non-food products. And that is good news, because it means consumer product manufacturers get to borrow thirty years of hard-won food safety practice instead of inventing their own.

Where They Are the Same

Both methodologies are systematic, step-based hazard studies of a manufacturing process. Both depend on prerequisite programmes as the foundation, both require a multi-disciplinary team with a trained leader, both demand validated controls with measurable limits, and both live or die on verification, the routine confirmation that the plan on paper matches reality on the floor.

Where They Differ

The hazards themselves. Food safety is dominated by microbiological growth, allergens and temperature control. Consumer products deal in a broader, flatter risk landscape: physical contamination, chemical migration, product integrity and function, sensitising materials, and microbiological risk only for specific product types such as cosmetics and personal care. One notable difference in the Issue 5 draft, and something I raised in my own consultation feedback, is terminology around critical control points. Food practitioners are anchored to the CCP concept, and the draft as consulted on does not use the phrase, which in my personal opinion risks confusion. Whether that changes in the final text, we will see in October 2026.

What to Borrow From the Food Side

Walk the flow diagram. Food auditors have spent decades catching flow diagrams that miss rework loops, waste streams and seasonal variations. Verify yours on the floor.

Challenge your controls. Validation means evidence the control works at the limits you have set, not a sentence saying it does. Food sites learned this the hard way.

Make monitoring records honest. A monitoring record signed at the end of the shift for checks supposedly done hourly is one of the oldest findings in food auditing. Build monitoring people can actually do.

Treat corrective action as pre-planned. Decide before the failure what happens to product made while a control was out of limits. Deciding afterwards, under commercial pressure, produces worse decisions.

If you are starting from zero, my explainer on what HARA involves walks the methodology step by step, and my piece on traceability testing covers the discipline that connects your HARA to your recall readiness.