HACCP plans

From: CHARLES DAXBOECK (biodax@mail.pf)
Date: Fri Nov 12 2004 - 13:28:58 PST

  • Next message: oscar.doporto: "Re: HACCP plans"

    Glacier

    Dear Group :

    Thanks to those who responded to my last set of queries.

    I now have another more "legal" sort of question. Under the USFDA seafood HACCP regulation, the agency does not "validate" plans. FDA must nonetheless have access to existing plans for inspections and can make comments and recommendations as their appropriateness for controlling identified CCPs. FDA may also recommend additional control measures should there be missing food safety hazards for the particular commodity, that may not not been identified or considered in the particular plan. As far as I know, FDA does not keep individual plans on file, since again as far as I know these plans remain in the domain of private, individual property which may contain trade secrets/proprietary information. The situation is a bit different in other countries, and especially in the EU, where plans MUST BE submitted for validation and verification before an "export permit" can be issued. In addition, at least for EU, the facility in which the export commodity is produced must also pass inspection. Only when BOTH PLAN and FACILITY pass muster can the company export. Now the question remains, under the latter situation, would it then be "legal" for the "competent authority" to keep a photocopy of each "validated" plan despite the fact that the plans have been elaborated by the private sector, at private sector expense (or sometimes subsidised by public funds/assistance) ? Don't these plans still remain private property, but as such must still be available for official review and inspection upon request in the facility of commodity production ? The potential for unauthorized "sharing" of plans among persons outside of the "official circle" to me seems to be a fairly serious issue. The obvious way around this is the USFDA system whereby the plans stay in place and are available for consultation in place upon request and therefore there is less of an "unauthorized sharing" problem. Would anyone on the list care to enlighten me on this issue, either in group or off-line ?

    Thanks again all in advance.

    Dr. Charles Daxboeck
    Tahiti, French Polynesia
    biodax@mail.pf


    Glacier_Bkgrd.jpg

    This archive was generated by hypermail 2b29 : Fri Nov 12 2004 - 13:46:04 PST