FDA 483 OBSERVATION · #35 OF 1,923 MOST-CITED

No HACCP plan

FDA cited this observation 624 times across 576 firms in recent inspections. Below: how it breaks down by program area and fiscal year, and real examples of how FDA worded it on Form FDA 483.

What this grouping is not

An observation-type page groups FDA’s published citation records. The grouping, the compliance steps and the root causes are SPEQ synthesis, not an FDA classification of any citation, and a count measures what FDA published rather than risk.

BY PROGRAM AREA
Foods624
BY FISCAL YEAR
FY202653
FY202541
FY202435
FY202341
FY202236
FY202133
FY202033
FY201984
FY201870
FY201789
FY2016109

What this observation means, and how to comply

SPEQ's practitioner reading of this finding. The regulatory basis is a cited fact; the interpretation, compliance steps, and root causes are SPEQ synthesis — not an FDA classification of the citation.

Seafood 21 CFR 123.6 · Juice 21 CFR 120.8

A processor required to have a HACCP plan did not have one for a product/hazard where the hazard analysis identified a food-safety hazard reasonably likely to occur — the plan simply did not exist.

Why FDA writes it — For seafood and juice, HACCP is the mandatory food-safety framework. When a required HACCP plan is absent, the identified hazards are, by definition, not being systematically controlled — so FDA cites the missing plan as a fundamental failure, not a paperwork gap.

HOW TO COMPLY
  • Conduct a hazard analysis and, where it identifies a hazard reasonably likely to occur, develop and implement a written HACCP plan.
  • Ensure the plan covers each such hazard with critical control points, critical limits, monitoring, corrective actions, verification, and recordkeeping.
  • Have the plan signed and dated by the responsible individual, and reassess it as required.
  • Where the analysis identifies no hazards reasonably likely to occur, document that determination.
WHY FIRMS GET CITED
  • A hazard analysis was never performed, so the need for a plan was never recognised.
  • A hazard reasonably likely to occur was judged away without a documented, defensible rationale.
PROFESSIONAL · REMEDIATION PLAYBOOK · SPEQ SYNTHESIS

How to close this finding — and stop it recurring

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What this observation is associated with

Firms cited for this observation also appear in FDA compliance actions — warning letters, injunctions, or seizures — at 1.5× the rate of the average FDA-cited firm (11.6% vs 7.8%), across 576 FEI-matched firms.

This is an association, not causation, and reflects co-occurrence in FDA's records — not a claim that the observation caused or preceded the action.

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How FDA worded it — real examples

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

Food Bucks Co., Ltd. · Gwangju · Foods · 2026-08-14

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

La Bakerie Inc · Hollywood, Florida · Foods · 2026-08-11

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

Terra Cotta Pasta Co., Inc · Dover, New Hampshire · Foods · 2026-07-22

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

A Farms Trading Inc. · South El Monte, California · Foods · 2026-07-22

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

NAGASAKI TAKARA SYOKUHIN Co., Ltd. KYOUDOMARI FACTORY · Nagasaki · Foods · 2026-07-22

You do not have a written HACCP plan that outlines controls for a food safety hazard that is reasonably likely to occur.

HOY LUNG SEAFOOD CORP. · Brooklyn, New York · Foods · 2026-07-20

Related SPEQ references

Where to read the requirements behind this observation area on SPEQ. These are SPEQ's topic and audience pages — not an FDA classification of the citation.

HACCP →Food industry →

Examples are a representative sample of FDA's published inspection observations. Open the 483 observation explorer →