Dear All,
This issue is very surprising coming from Australia. All our export
vessels that "process" (ie freeze or cook) need FPA- a HACCP based Food
Production Accredatation system adminstered by AQIS (Aust Quarantine
Inspection Service= FDA). Yes they go on boats in the sea to inspect. And
they mainly do this to meet the requirements of overseas importing countries
(ie USA & EU).
So yes, there is onboard HACCP plans. Some vessels here also have ISO 9000
(the international Quality Managment Standard). I have been running Seafood
Risk Assessment courses across our state, and have vessel owners and
operators on every course this year.
In Australia we have HACCP implemented (or being implemented) in all sectors
from Paddock/Ocean to Plate. It has not been required by Govt regulation on
the whole- but by the market forces. The 3 largest supermarket chains here
demanded the implementation of full HACCP based QA programs by all
suppliers- yes farmers, processors, pre-prepared
meals ect. So have the Airlines, large institutional caterers(Hospitals,
Army, Schools.....)
So yes there is HACCP in retailers. Have a look at what Sainsburys and
Tescos expect of their suppliers in the UK.
It stuns me that people even need to ask this question, let alone that other
people answer NO.
Below is an extract from an article that I wrote for Joe Slavin's newsletter
in Jan this year. It may go some way to explaining how other parts of the
world approach HACCP implementation.
Both the European Union and the United States have implemented HACCP to meet
their respective Government's legislation. The legislation in both
continents is significantly different in their approaches. This legislation
also includes prescriptive "Standard Operating Procedures" or good
manufacturing practices, suggestions for Quality Assurance systems and even
risk analysis methods. The similarity between the two approaches is that all
importing countries have to meet the same standard as the domestic
producers.
Other areas in the world like Australia, New Zealand and parts of Asia have
taken different approaches; some Governments passing partial HACCP
legislation (Aust and NZ), some relying on market demands (Aust and most of
Asia) or using a 3rd countries standards as their defacto standards (Japan).
Usually this approach means that the domestic producers are usually meeting
very different standards to the exporting producers. The exporting
producers are usually trying to meet both the EU and USA requirements, which
may directly, conflict with the implementation methods used in their
domestic market. In Australia it is quite common for an exporting processor
to have at least 8 different types of audits a year, some processors having
up to 26 different types of audits.
In the USA there is HACCP legislation to cover the meat (USDA) and seafood
(FDA) processing industry and proposed legislation for the fruit juicing
industry, but there is no federal legislation covering HACCP for the rest of
the food industry ie food service where most of the poisoning's occurs.
This is left up to the state and local governments.
In the EU the Directive 93/43/EEC covers "all stages after primary
production (the latter including, for example, harvesting, slaughter and
milking) during preparation, processing, manufacturing, packaging, storing,
transportation........for sale or supply to the consumer". The dairy and
meat industry have further legislation relating to hygienic production (DIR
92/5 & DIR92/46). It is left up to each individual member country to
implement the directives intent and that has led to differing
interpretations within Europe. If you want a good summary of HACCP
implementation worldwide, with particular regard to different member states
of the EU, 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
In an export focussed country like New Zealand, all areas of the food
industry have implemented HACCP to meet their trading partner's
requirements, but many have been using HACCP based Quality assurances
schemes for at least fifteen years to enable their industry to keep an edge
on their trading competitors.
In Australia there is legislated "HACCP" requirements for the meat
processing and dairy industries, all exported food products. Certainly in
Australia whatever domestic regulations are set, have no connection to the
requirements for imports. There was proposed federal legislation covering
all other aspects of the domestic food industry, but this approach seems to
have been abandoned in favour of each of the seven states and territories
implementing their own (different) food safety legislation. Some of these
legislation's requiring "food safety plans" some not requiring much more
than documented good manufacturing practices (GMP). Parallel developments
by the three major supermarket chains have meant that most food producers
and processors have implemented at least one of the 161 different HACCP
based Quality Assurance systems, to remain in business. So the HACCP push in
Australia has come from the domestic supermarkets and in certain exporting
industries (meat), trading partners, not the Government.
Clare Winkel
Food Consultant
CENTRE FOR FOOD TECHNOLOGY
Department of Primary Industries
19 Hercules Street Hamilton Q 4007
Telephone 07 3406 8691
Facsimile 07 3406 8662
winkelc@dpi.qld.gov.au
http://www.dpi.qld.gov.au/cft/
> -----Original Message-----
> From: Ronald Hoelzer [SMTP:rsardine@acadia.net]
> Sent: Sunday, 20 May 2001 4:22
> To: SeafoodGS@aol.com
> Cc: seafood@ucdavis.edu
> Subject: Re: Should Vessels or Retailers be included in HACCP
>
> I need to add my 2 cents to this question.
>
> In an ideal world, the vessels should be included under the Seafood
> Rule. As it is now, the processor or buyer becomes the regulator for the
> vessels as it is the processor/buyer that must demand proper
> documentation from the vessel.
>
> Unfortunately, if the vessels were included in the seafood rule, it
> would simply become one more unenforceable law. There simply aren't
> enough regulators to inspect the thousands of fishing vessels.
>
> Ron Hoelzer
> Maine Food Technology Associates
>
> SeafoodGS@aol.com wrote:
>
> >
> > > Hi,
> > >
> > > Should vessels or retailers be included in HACCP?
> > >
> > > In the following article from the May Issue of U.S. Seafood News on
> > FDA
> > Warning Letters you can see that often reports are required by
> > inspectors as
> > to how Scombroid fish were handled on the vessel so as to guard
> > against the
> > Hazard of Histamine poisioning.
> > >
> > > The basic emphasis of HACCP is now placed on the processor. The
> > retailers or
> > > vessel operators are not included. But when we look at Histamine and
> > similar
> > > cases investigators say that vessels should have records to show
> > that fish
> > > were handled properly and the processor receiving this fish should
> > have
> > these records or acess to them.
> > >
> > > What do you think? Should vessels landing higher risk products ie
> > scombroid fish be required to have a HACCP plan.
> >
> > Should vessels be given a higher priority for HACCP than retailers.
> >
> > We would appreciate your views.
> >
> > Please visit our web site at www.seafoodglobalservices or request a
> > complementary issue of the May Issue of U.S. Seafood News for
> > additional
> > information.
> >
> > Article Follows
> >
> > FDA Warning Letters Increase The U.S.Food and Drug
> > Administration
> > (FDA) issued 23 warnings letters to industry firms in March 2001 for
> > not
> > complying with the HACCP seafood processing regulation âEUR"bringing the
> > total
> > number of warning letters issued for the first three monthsof 2001 to
> > 47.
> > See U.S. Seafood News,vol. 9, issues 2 and 3 for information on
> > warning
> > letters issued in January and February. The Seattle FDA
> > office was
> > the leader issuing nine warning letters in March, followed by Atlanta
> > and
> > Florida who issued four each. The FDA offices in San Francisco,
> > Dallas,
> > Chicago, Baltimore, NewOrleans and New England issued one warning
> > letter each
> > in March. Following are some observations by U.S. Seafood
> > News
> > concerning the warning letters issued in March.
> >
> > -Many of the letters were issued to firms that had failed to correct
> > deficiencies previously brought to theirattention by FDA. -About 25
> > percent
> > of the firms were cited for having sanitation deficiencies, such as no
> >
> > sanitation control records and insanitary handling conditions..
> > -Smoked fish received a high priority. Firms were cited for nothaving
> > at
> > lease 3.5% water phase salt content, lack of sufficient
> > time-temperature
> > controls, high storage temperatures and lack of controls for
> > histamine..
> > -Sandwich manufacturers received warning letters for not
> > including
> > allergens in their HACCP plan and for not storing tuna salad
> > sandwiches at
> > low enough temperatures to minimize pathogengrowth.
> > -Histamine
> > controls continued to receive a priority in the FDA inspections. Firms
> > were
> > cited for not taking and/or recording the internal temperature of fish
> > at
> > receiving, for not using low enough storage temperatures, for not
> > taking into
> > account transportation of the product prior to receiving and for not
> > requiring vessel handling records as part of the HACCPplan.
> > -Lack
> > of specifications and/or affirmative action steps for imported
> > products were
> > noted in about 20 percentof the warning letters. In one case, an
> > importer
> > was cited for not having sufficient controls to guard against
> > ciguatoxin in
> > grouper and snapper imported from Mexico. In others the importer did
> > not
> > issue specifications for canned tuna, grouper, herring and raw shrimp.
> >
> > -Other warning letters include citations for lack of controls for
> > sulfite
> > in raw shrimp, pathogens in storageof cooked stone crabs and fried
> > fish cakes
> > and thawing vacuum packed imitationcrabmeat.
> > >
> > > Looking forward to your views.
> > >
> > > Best regards,
> > >
> > > Joe Slavin, Publisher
>
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