HACCP plan audits and European regs

From: CHARLES DAXBOECK (biodax@mail.pf)
Date: Fri Sep 10 2004 - 19:19:46 PDT

  • Next message: Lupin, Hector (FIIU): "RE: HACCP plan audits and European regs"

    GlacierDear Group :

    As we all are aware, for USFDA Seafood HACCP compliance (and for that matter nearly all other countries' HACCP requirements), there is need for at a minimum, an annual audit of each operational plan (with written report to that effect), under the plan verification practices, Section 123.8 of Title 21 CFR Part 123. In the older versions of the European Union's "self-checks" seafood HACCP regulations 91/493/CE of July 22, 1991 and 94/356/CE of May 20, 1994 (with or without their subsequent modifications), I don't seem to able to explicitly find any direct mention of requirements for at a minimum an annual review of the effectiveness of the HACCP plan. If this is true then, once you have your plan for the EU, you don't need to do anything anymore - except the occasional critical limit "verification", and of course keep the ever-present veterinary inspectors happy with test after test after test of your end product ? If not please could someone clarify the real situation. I do realize that as of January 2006, the new, better, revised EU "Food Hygiene Package - 2004/C 48 E/ 01 through 04" will come into effect. Therein are provisions for "official audits" of HACCP plans by an official vet, approved vet or official auxiliary designated by the "competent authority", at what frequency is not specified. One could interpret that to mean only for initial approval of not only the facility but also of the HACCP plan, then if ever a "question" about a real or imagined public food safety issue. Now under the EU "own-checks Haccp", unlike the USFDA which is clear, there again is absolutely no mention or provision (unless I completely missed it) for any review or audit of the plan at any minimum frequency whatsoever. I do understand that, after initial approval (provisional or permanent) EU sanitary inspection approvals for operating permits (EU agreement #'s) are up for renewal every 4 years. At that time of competent authority inspection, a valid HACCP plan must also be presented. It would therefore seem all too logical that in order to prove that your plan has been effective over the last 4 years, that you have all records available and that at a logical minimum also, you have your plan audited and verified annually by a competent team (either internal or external of your seafood operation) that does not have to be a priori approved by the competent authority. If those who put into place and costruct the HACCP plan then one should assume that they are competent enough to underastand the underlying principles of HACCP and therefore will insist in their plan that a reasonable frequency of internal review, validation and audit is a mandatory part of THEIR plan, even if not specified under EU regs. Is this correct or am I missing something ????? Please, could someone help me understand ?

    Thanks all in advance.

    Dr. Charles Daxboeck
    Tahiti, French Polynesia


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