Re: HACCP plans

From: oscar.doporto (oscar.doporto@wanadoo.fr)
Date: Fri Nov 12 2004 - 15:03:23 PST

  • Next message: Francisco Blaha: "Re: HACCP plans"

    GlacierDear Charles,
    Working as a consultant in the area of consideration, in many countries and frequently in connetion with EU requierements and modalities, I have to say that the situation in the mayority of those countries is worst than that. In fact, when the matter is managed by Veterinarians with a clasic sanitary police point of view, (what happens in most cases in Europe), you have not the right to any secret and some times either to any technical opinion even correctly founded in science and legislation. One think is what the HACCP or "self-control" supose to be (including if you take the EU legislation as the only refference) and a different one is how most "competent authorities" understund for that.
    I observed for exemple, the "competent authority" imposing to the companies to accept a person (to not say a Vet), -In fact in Uruguay that is written in the law- from a list of people trained by them, as their employee to be in-charge of quality assurance and Hygiene, to satisfy their views.
    That way the plans not only are not private but are frequently not corresponding wth the company view, copied and "corrected" by the inspectors convinced that they are doing their job.
    I understand your point and I agree with you in the sence that the manners observed are not correct at all.
    Cheers,
    Oscar do Porto

     ----- Original Message -----
      From: CHARLES DAXBOECK
      To: seafood@ucdavis.edu
      Sent: Friday, November 12, 2004 10:28 PM
      Subject: HACCP plans

       
      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


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