Dear All,
Can I add my two cents worth, as a HACCP consultant working in Australia ?
HACCP is a risk management system designed to minimise the food safety risk
within a food production system. In Australia and NZ HACCP is usually
implemented with a Quality Management system, stress on MANAGEMENT SYSTEM.
In Australia it is extremely rare to find a food processor, especially a
seafood processor, that will spend any money at all on capital expenses. The
buildings are often 60 years old and literally falling down. It takes a
lateral thinking, practical consultant/QA Manager to implement HACCP within
such a context, but it can be done. To go out and spend hundreds of
thousands of dollars is wonderful if you have that luxery, but on the whole
we down under (AUD is running at 54 US cents today and the NZD about 39 US
cents) cannot do that and must work smarter.
I have worked in plants with old conveyor belts fraying at the edges, there
is nothing that Chlorine and a bit of "elbow grease" can't fix. Sure over
time the extra chemical and labor costs could be offset by new equipment,
but if you don't have cash.......
I have also worked in brand new shiny plants, with very bad processing
practices and no staff training and so the money spent was completely
wasted.
If you want a good summary of HACCP implementation worldwide read this
paper" Evaluation of worldwide approaches to the use of HACCP to control
food safety" Karl Ropkins and Angus. J. Beck. Trends in Food Science &
Technology 11 (2000) 10-21
It must be remembered that different parts of the world are implementing
HACCP to meet differing legslative requirements ie EU directives, FDA, USDA
and in Aust, differing market requirements (not Government requirements). So
the implementation and intrepretation of HACCP across the world is very
different. So first you need to understand whether you are implementing a
requirement for your Government or an actual CODEX based HACCP system ?
Clare Winkel
Food Consultant
Centre for Food Technology
Hamilton, Brisbane
Qld Australia
> -----Original Message-----
> From: Douglas L. Marshall [SMTP:microman@ra.msstate.edu]
> Sent: Wednesday, 6 December 2000 5:35
> To: liz@akgen.com; jonpall@3x.is
> Cc: seafood@ucdavis.edu
> Subject: RE: The HACCP situation in US
>
> 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
>
> --------------------------------------------------------------
> Processing Solutions Made Easy!
>
>
>
>
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