I'm going to side with Liz on this issue for the following reasons. 1) With
the exception of cooked ready-to-eat products there is little evidence to
suggest that plant equipment age is deleterious to food safety. What Jon
Pall describes in his example of conveyor belts is a potential problem with
Good Manufacturing Practices or Standard Sanitary Operating Procedures but
may not be an issue in a HACCP plan for raw products. 2) Most prudent
processors will make the extra effort to properly clean and sanitize such
problem areas as needed to ensure safety. 3) A company's HACCP plan is not
an "approved" program. FDA merely makes a judgment on whether it works or
not. Equipment or facility design/age is a factor in this judgment but the
bottom line is -- does the company CONTROL food safety hazards or not. If
they do, then their HACCP plan is in compliance. 4) There is no evidence of
a US government conspiracy to impede foreign imports of seafoods. In fact,
the US is arguably one of the worlds largest exporter and importer of
seafoods. It seems counterintuitive that such a conspiracy argument is
meritorious.
I will concede to Jon Pall on one issue, namely the poor compliance by US
processors with the HACCP regulation. We still have too many processors
operating without a full understanding of HACCP and without adequate control
of hazards. This problem is independent of equipment/facility design or
age. I'm not surprised if the Europeans are ahead of the US in terms of
compliance. Too bad they had to pay so much for new equipment and
facilities to get there.
Doug
********************************************
Douglas L. Marshall, Ph.D.
Professor, Mississippi State University
Department of Food Science & Technology
Room 110 Herzer, Stone Blvd (FedEx)
Box 9805 (USPS)
Mississippi State, MS 39762-9805
Ph 662-325-8722
Fax 662-325-8728
http://www.msstate.edu/dept/fst/Homepage
********************************************
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On
Behalf Of Liz Best
Sent: Tuesday, December 05, 2000 12:42 PM
To: 'jonpall@3x.is'
Cc: 'seafood@ucdavis.edu'
Subject: RE: The HACCP situation in US
Yes, I understand what you are saying but you seem to be missing my point.
I only meant to clarify what HACCP is and what it is not! I become
concerned when you separate plants into "HACCP plants" and "other plants".
I strongly urge you to change your verbiage when discussing new equipment
for processing plants. New equipment will not make a facility HACCP
compliant and making such claims could damage the intention of HACCP by
giving a facility the false assumption that if the equipment is new they
will be HACCP compliant and not have food safety problems. That would be
bad for us all! And for your information, I know of facilities that are
probably older than you and I combined that have been producing safe seafood
products for a long time. Sure, they may pay a little more to keep the
facility "up to snuff", but I know their products are safe to eat, that is
what matters!
From the desk of Elizabeth Best
email liz@akgen.com
-----Original Message-----
From: Jon Pall Hreinsson [mailto:jonpall@3x.is]
Sent: Tuesday, December 05, 2000 10:08 AM
To: 'Liz Best'
Cc: seafood@ucdavis.edu
Subject: RE: The HACCP situation in US
Thank you for your clarification.
I am however a little confused. My company, where I am the marketing
manager, have been involved in building equipment and designing layout
chances for both fish processing plant and shrimp processing plants that
where taking up the HACCP regulation. I know very well what it takes to have
good plant, good enough to get HAACP improved. Of course there can exists
such a situation where the infrastructure was sufficient and the only thing
was to clean up and stay clean, but that is rare. In most cases you need to
change out some of the old equipment for new hygienically friendly equipment
(actually I never suggested below that to implement HACCP you need to buy
new equipment! I mearly pointed out that this has been tha case in Northern
Europe). In some processing industries, where you cook the product in the
processing (shrimp) the change to HACCP needs massive
reorganisation/renavation of the plant housing. that alone requires serious
captal investments.
Take conveyors for one example. Up until 3-5 years ago (in some places
still today) conveyors where not built for cleaning. They where almost
impossible to clean and it was virtually impossible to get the free of
bacteria’s. With more advanced designed in term of accessibility for
cleaning, the risk of bacteria’s in conveyors where decreased dramatically.
Furthermore implementation and sustaining the HACCAP system is not
effortless and the transformation was difficult for some producers to grasp
and to capture at the essence of the system and learning how to implement it
efficiently. All this cost money!
The final point. Every one that have seen the difference to a modern
fish/shrimp/seafood processing plant and the old run down plant that i was
referring to in my first mail understand that to chance those plants it
takes effort and in the end capital. It is a completely different issue to
run a HACCP plant or the other type plants. However more and more plant
owners and manager are realizing that despite the increased cost of capital
and higher operating cost the end result is positive. From HACCP comes a
better product that can give better price (if I was the aggressive type I
would now start to talk how my new equipment would increase the capacity
ect, ect..... but notice that I have not even revealed the name of my
company - if you want to know contact my directly).
Thanks for the comments Liz Best; it was an interesting point of view.
re,
Jon Pall Hreinsson
-----Original Message-----
From: Liz Best [mailto:liz@akgen.com]
Sent: 5. desember 2000 16:57
To: 'jonpall@3x.is'
Cc: 'seafood@ucdavis.edu'
Subject: RE: The HACCP situation in US
I do not know what your exact complaints regarding these US manufactures
is, but HACCP does not immediately quantify into a need to purchase
additional equipment nor modernize a processing facility. HACCP is a
program designed to assure product safety. Yes, I agree that newer
technology is a good addition to any processing facility, but new equipment
is worthless if one does not understand the basic premise of food safety.
If one has good maintenance programs in place, assures that the plant is
cleaned properly and educates its work force it does not matter the age of
the facilty or the equipment. Remember HACCP is a food safety program
designed to "highlight" those areas within a process determined as needing a
higher level of control in order to maintain the safety of the food being
produced. I hope I have clarified this for you.
From the desk of Elizabeth Best
email liz@akgen.com
-----Original Message-----
From: Jon Pall Hreinsson [mailto:jonpall@3x.is]
Sent: Tuesday, December 05, 2000 12:12 AM
To: seafood@ucdavis.edu
Subject: The HACCP situation in US
hi,
As manufacturer of equipment in various seafood processing industries, I
have seen many plants over the world. What has been interested for me is to
see how plants exporting to the US and EU have modernized and improved their
processing facilities and equipment to undertake the HACCP regulations.
However it has equally interesting to see how many processing plants in the
US have failed to do the same. I have seen frequently plants in the US that
are more the 10 years behind plants in northern Europe and far away from
being able to comply with the HACCP regulation. This made me think if the
HACCP was, or was initially set up a technical import restriction to the US.
I can’t think of any other reason why the US are so strict on enforcing the
HACCP rule for imported fish, while at the same time US produced seafood, at
least in some cases, have failed to enforced the same regulations.
I hope I am not offending anybody. I am sure that many seafood
processors in US have a good plant that have the HACCP regulation in order.
My colleagues and I have however personally visited number of plants that
are not even close of getting HACCP.
You must not for get that with HACCP you get a better and more secure
product, but it comes at a price (more cost of capital and higher operating
costs). Thus, the tendency will always be that some will slack in producer’s
effort to enforce such a regulation.
re,
jonpall
3X-Stal http://www.3x.is/
--------------------------------------------------------------
Jon Pall Hreinsson Tel. +354 456 5079
Marketing Manager Fax. +354 456 5479
--------------------------------------------------------------
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