The Hazard Analysis and Critical Control Points (HACCP) process control system is an important element in food safety assurance. However, equally important are the prerequisite programs that go into HACCP, including Good Manufacturing Practices (GMPs) as described in the Code of Federal Regulations (21CFR110). A factory with an inadequate HACCP plan that fails to adequately address a microbial hazard may produce a product resulting in foodborne illness. The same can be said for a factory with an excellent HACCP plan but inadequate GMPs reflecting poor microbial control of the factory environment.