Hector,
I think your explanation of the difference between HACCP and regulatory
actions based on HACCP is excellent, and more important, is that it is
too often overlooked.
Larry Wyatt
FoodHorizon Inc.
www.foodhorizon.com
Lupin, Hector (FIIU) wrote:
>
> Dear colleagues:
>
> This is a very interesting discussion, that pops up very frequently. I
> think that there are some general considerations:
>
> (i) Regulatory HACCP is not HACCP (e.g. in the sense of HACCP
> according the Codex Alimentarius) */but a regulation based on HACCP/*.
> Therefore, in principle, you have to comply with a regulation and not
> just with the dry HACCP principles and/ or steps.
> (ii) Regulations, as any other piece of knowledge, is open to
> interpretations. "Interpretations" are usually a problem. Inspection
> agencies in general make every possible effort to make
> interpretations, of their own officers, uniform. But not always succeed.
> (iii) One of the aspects of HACCP-based regulations is that they
> determine directly or indirectly "regulatory hazards"; this means
> hazards that you *shall *be taken into account in your HACCP plan,
> regardless which could be your own technical opinion. In the case of
> the US FDA HACCP-based regulations theoretically you may eventual
> appeal (if you are in the US), based on scientific grounds. However,
> for most "regulatory hazards" the possibility somebody could
> demonstrate they are not hazards (e.g. histamine in pelagic fish) is
> usually very remote.
>
> Regarding the EU directives there are a couple of things to clarify
> (translate from EU English to USA English):
> (a) HACCP for fish and fish products is called "own-checks".
> (b) CCP is called "Critical Point"
> (c) "Hazard is a potential to cause harm to health */and is anything
> covered by the hygiene objectives of Directive 91/493/EEC/*" (bold and
> Italics mine)
> (from Commission Decision 94/356/EC of 20 May 1994)
>
> Going to Council Directive 91/493/EEC we found the following:
>
> (1) "- frozen fishery products, with the exception of frozen fish in
> brine intended for the manufacture of canned foods, *must *be kept at
> an even temperature of -18 º C or less in all parts of the product,
> allowing for the possibility of brief upward fluctuations of not more
> than 3 º C, during transport;" (Council Directive 91/493/EEC, Annex,
> Chapter VIII, Storage and Transport, Point 1) (bold mine)
>
> (2) "3. Storage rooms *must* have a temperature recording device in
> place where it can easily be read. The temperature sensor of the
> recorder *must *be located in the area furthest away from the cold
> source, i.e. where the temperature in the storage room is the highest.
> Temperature charts *must *be available for inspection by the
> supervisory authorities at least during the period in which the
> products are stored." (Council Directive 91/493/EEC, Annex, Chapter
> IV, Special Conditions for Handling Fishery Products on Shore, II
> Conditions fro frozen products, Point 3) (bold mine)
>
> And finally, and perhaps the most important for this discussion:
>
> (3) "*Critical limits* may be derived from a variety of sources. When
> not taken from regulatory standards (*e.g. frozen storage
> temperature*) or from existing and validated guides of good
> manufacturing practices, the team should ascertain their validity
> relative to the control of identified hazard and critical points"
> (Commission Decision 94/356/EC, Chapter II, Point 1). (bold mine)
>
> In this case the regulation is not saying that the cold storage
> temperature is a CP (a CCP); but is given all the indications in that
> sense (critical limit, tolerance, measurement and record keeping and
> use it as regulatory example). The need for corrective actions, in the
> case of deviations, is obviously a result; and the need for
> verifications of measurement and record equipment fall into the
> general principle of verification and calibration and re-calibration
> of measurement equipment. Therefore we have our regulatory hazard and
> CP (or CCP).
>
> *Again, the possibility that in this situation a fish inspector from
> the EU do not consider the temperature in a cold storage room a CP (a
> CCP) is remote. He/ she may eventually accept that continuous records
> could be replaced by recorded lectures, say every 3-5 hours (taking
> into account the thermal inertia of cold storage rooms); but hardly
> that it is not a CP (CCP). *
>
> The discussion about the rationality or not of frozen storage
> temperature as a CP (or CCP) is interesting; I am tempted to go on
> that, but not time now. *In any case **we should keep in mind that
> HACCP based regulations (or by the case all Risk Analysis) are based
> on Science, they are not Science.*
>
> I have worked with people in developing countries that want to export
> their fish. People normally ask you to provide an advice that put them
> into the safe side. Which advise would you provide in this case?
>
> *(Warning: from 1 January 2006 there will be a new set of EU
> regulations dealing with HACCP, and a new careful reading of
> regulations is necessary for all trading fish with the EU)*
>
> Kind regards.
>
>
> *Hector M. Lupin*
>
> *Senior Fishery Industry Officer (Quality Assurance)*
>
> *Fish Utilization and Marketing Service (FIIU)*
>
> *Fishery Industries Division (FI)*
>
> *Fisheries Department, FAO, Room F 606*
>
> *Viale delle Terme di Caracalla*
>
> *00100 Rome, Italy*
>
> *Tel + 39 06 570 56459*
>
> *Fax + 39 06 570 55188*
>
> *E-mail: hector.lupin@fao.org*
>
>
>
>
>
>
>
> -----Original Message-----
> *From:* owner-seafood@ucdavis.edu
> [mailto:owner-seafood@ucdavis.edu] *On Behalf Of *Richard Chivers
> *Sent:* 07 October 2005 16:36
> *To:* alma tina; seafood@ucdavis.edu
> *Subject:* RE: inquiry about cold storage being considered as CCP
>
> Hi Alma,
>
>
>
> These are my views:
>
>
>
> 1. There are no EU directives that set CCPs, these are up to
> the processor to determine.
> 2. I assume you refer to the Competent Authority. I would not
> consider cold (frozen) storage a CCP simply because a
> product that is intended to be kept in be frozen condition
> would be in breach of specifications and GMP, drawing in
> quality and safety issues. I would set the temperature
> control as a prerequisite programme; a given if you like.
> I.e. if the product temperature were outside the limits,
> that would be the end of it for its primary purpose and
> disposal or alternative use should be considered.
> 3. Pathogen growth is unlikely to present a food safety hazard
> due to the reasonable expectation that the product would be
> cooked. That is unless there were an issue with spore
> formers or with heat resistant toxins then there would be a
> problem. These matters would be highlighted in the analysis
> part of the HACCP. Unfortunately it is not an argument that
> sways opinion in international trade which will set
> stringent micro counts.
> 4. It is not illegal but may mean that your analysis was
> invalid if a CCP were missed. In the UK this alone would
> not lead to prosecution but could become evidence to support
> a prosecution if there were more serious matters arising
> from temperature abuse i.e. food poisoning.
>
>
>
> I hope this helps
>
>
>
> Richard Chivers
>
>
>
> -----Original Message-----
> *From:* owner-seafood@ucdavis.edu
> [mailto:owner-seafood@ucdavis.edu]*On Behalf Of *alma tina
> *Sent:* 07 October 2005 06:34
> *To:* seafood@ucdavis.edu
> *Subject:* inquiry about cold storage being considered as CCP
>
>
>
> Dear List,
>
>
>
> Please give me some insight or enlightening regarding the issue of
> considering cold storage as CCP.
>
>
>
> These are my questions:
>
>
>
> 1.Is there an EU directives that considers storing at cold storage
> as CCP.
>
> 2.Can the competitive authority insist on us to consider storing
> at cold storage as CCP.
>
> 3. Is my thinking correct, that since our product is to be fully
> cooked before consumption, then pathogen growth is not a hazard?
> By the way our products are frozen octopus and shrimps.
>
> 4. Is it illegal not to have CCP for a particular item?
>
>
>
>
>
> Plese provide some information on this issue, we badly needed the
> info.
>
>
>
> Thanks,
>
>
>
> Alma O. Tina
>
> almaorodiotina@yahoo.com
>
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This archive was generated by hypermail 2b29 : Tue Oct 11 2005 - 09:36:13 PDT