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GlacierDear Group :
I have a follow-up question to the one I posed the other day regarding HACCP "audits" or reevaluations. It goes as follows :
Here in Tahiti, French Polynesia, we have our veterinary inspection service which will not sign any "health-sanitary" certificate for fish being exported to the USA if the HACCP plan for the exporting company has not been "audited" under the verification section of the plan, on a yearly basis and is not current on the date of export. Such due diligence for USFDA could be applauded, but neither USFDA, NMFS, nor the US importer needs an EU-style "health" certificate for fish imports under present regulations. What everyone does want (and it is of course mandatory !) is a valid HACCP plan for the particular seafood product being exported, and that's also a matter of due diligence between the importer to have on record and the exporter to furnish (or at least relevant monitoring records) such plans. On the other hand, the same inspection service within our "competent authority", which has the responsibility of actually assigning EU seafood export agreement numbers, based on inspection of the facility AND upon inspection and approval of the adequacy of the individual HACCP plans does not have the same criterion for reevaluation for the EU. Be reminded here that within these seafood export plans (for Europe and the USA), under the HACCP principle 6 section (Verifications) the inspection service has approved the fact that these plans are "audited" or reassessed at least on an annual basis. Many individual exporters no longer respect the minimum yearly reassessment of their plan and therefore are not current, for the most part in their annual "audits". This seems to me to create an administrative and HACCP implementation problem because on the one hand, the reassessment in needed for export to the USA (since the inspector won't sign the health certificate and without this certificate according to our laws and statutes, you cannot export any seafood product) but for export to the EU, under the SAME PLAN, and where a health certificate is in fact needed, the same inspection service now simply states that no annual "audit" is needed, so the certificates are signed without any qualms. BUT, the HACCP plans that has been APPROVED by the "competent authority " to export to the EU AND USA are the same (French and English versions). Is this not a bit confusing for seafood products exported to the EU from a LIST 1 Third Country such as French Polynesia ?? Could this in fact jeopardize our export market simply for a procedural error on the part of our inspection service ?? My understanding, and correct me if wrong, but HACCP is the same thing in Europe, the USA, Japan etc. and is still based ONLY on the standard 12 steps or stages and the 7 principles, with prerequisite sanitation programs, and GMPs.
I thank you in advance for your insight.
Sincerely,
Charles
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