Dear all,
HACCP has been (and is) the top of an iceberg of a way in producing safe
foods. HACCP has been defined as a change of paradigm in the way to produce
safe foods (change of technological paradigm in the terms of Thomas Kuhn);
and from that point of view we are still in the transitory period between the
old and the new paradigm; between the "classic" food and fish inspection,
generic food hygiene and the new paradigm.
However, at the same time HACCP is just a risk management tool within what is
the Risk Management chapter of Risk Analysis. Risk Analysis is the real new
paradigm (*).
In Marguerite Yourcenar's book, Memoirs of Hadrian, she wrote that emperor
Hadrian's time was a very particular time because the old gods were moribund
and the new god was still a baby. We could have a similar image for HACCP
(and Risk Analysis) that are the new "gods" (that in some way engulf the
"old" ones) but at the same time a large portion of the "old" practices
remain including regulatory aspects.
HACCP in all the regulations is the responsibility of the producer and/ or
the people responsible of the different stages till the food arrive to the
consumer. There are some noticeable differences between regulations because
some include primary producers (e.g. fish boats and ponds) and other not; or
may not include some of the responsible along the food chain (covered by some
ad-hoc regulations). But the important thing is that regulatory HACCP is the
whole responsibility of producer (or according to regulations of who owns,
handle or process the food at a given time). In my opinion a point not well
communicated is that the responsibility (and in most cases the liability) of
the safety of the fish or food, under regulatory HACCP, is with that
operators (identified in the specific regulations); and not any longer with
inspection services (or "competent authorities").
Of course fish and food inspection services continue to have a number of
responsibilities and role, among others that of monitoring and verify (audit)
that HACCP be implemented according with regulatory requirements (this
obviously depends on the specific HACCP regulation). Perhaps here we could
repeat that that one of the big problems (world over) and that sometimes
affect even big companies, is the lack of implementation of HACCP Principle
No 6; that according to the Codex version reads:
"Establish procedures for verification to confirm that the HACCP system is
working effectively"
This "verification" is not the same "verification" (and audit) of the fish
inspection service. The "verification" mentioned in Principle 6 is for the
operators to do; is internal verification and audit. This is the weakest part
of HACCP implementation and very often analysing food outbreaks it is easy to
find out that the problem has born from the lack of verification of who
should do that. For instance a number of HACCP plans rely on the declaration
or analysis reports provided by suppliers on the absence/ control of some
hazards; that is fine as normal procedure, but verification should be
performed, by who is purchasing, from time to time. Not with every batch, but
from time to time to see if reality checks with documents. Just that. It is
not possible or economic to check, for instance each ice load for
microbiological standards or to see if each bag of chilli powder is free from
Sudan 1; but if the hazard could be there, we should have a plan to verify
from time to time that what our supplier is telling us is true. A word of
caution, not necessarily he/ she wants to cheat us on purpose; quite often
they have the same problem, they accept certificates from their suppliers
without to verify them. Papers (or electronic records) are one thing reality
may be different; papers (or computers) never say NO!!! when somebody want to
write (record) some non-sense.
Food and fish inspection services (or competent authorities), or wherever you
want to call them, have very little possibility to control situations like
those described in the previous paragraph. They can look (monitor), from time
to time, your HACCP plans to see if you have proper verification (and
internal HACCP audit) schemes; sometimes they could have also access to your
records and can ask for corrective actions logbook. Look at the face of a
(experienced) HACCP fish inspector when you tell him/ her that you do not
have any record of corrective actions during the last year because there was
not need! Certainly you had, and most probably you did the right thing at the
time; but most probably you did not record it; and the main problem is that
you acted when the problem was notorious (e.g. because of the complaint of a
customer) and not because of a systematic and planned action from your side.
The concept of the systematic and planned verification is that you could
discover problems before they leave your plant.
It is placed there in case something serious could escape the CCPs (and
eventually the SSOPs).
All that are things to do, in the plant, to do seriously, with conviction,
with the best of our technological knowledge. No "certification",
"authorization" from fish inspection service, private institutions or even
ISO, or wherever, could replace that. Some of that things could certainly
help by providing guidelines or a procedure (or even a standard) to do that,
but people should do it (and that requirement it is already in the HACCP
guidelines).
Yes, fish is not only fish; but what we call "fish" is actually "fish +
technology + quality & safety + service"; and the last three terms continue
to increase.
Kind regards.
Hector M. Lupin
(*) I wrote this paragraph to express that we are part of a culture, of a
society, of a time in History. Some authors talk of post-modern societies as
the "Risk Societies" (see for instance Ulrich Beck, Risk Society, Towards a
New Modernity. London: Sage Publications, 1992 [originally publ. 1986]. 260
pp.) and most likely developed countries behave very much in the way Beck
theorises. Without this understanding of the role of "risk" in contemporary
developed societies it is difficult to understand changes like the
introduction of HACCP and the development of Risk Analysis. They are not here
because of some illuminated food (or fish) inspector created them, but
because society is pressing for schemes like that (to self protect
themselves) and politicians have very little or not chance to follow.
Industries that understand that, both in developed and developing countries,
will have certainly a competitive advantage in the years to come. HACCP
regulations are not a regulation in the terms of an imposition, and it is
misleading to see them like that. It is an answer to something that Society
are asking for. HACCP regulations have been a help to the fish industry all
around the world.
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
Behalf Of Daniel Brooks
Sent: 11 April 2006 11:58
To: seafood@ucdavis.edu
Subject: HACCP Question
Dear All:
In most cases, things have improved in the correlation between a
written HACCP document with the implemented HACCP practices. But there is
still a way's to go meaning there still can be a big discrepancy between the
written HACCP document in the importer's office vs. what's actually going on
in a supplier's plant. And one should be careful not to be automatically
lulled into a sense of security by the word 'competent' in the term competent
authority - especially in the area of HACCP!
Thank you.
Daniel E. Brooks
Managing Director
Food Audits International, Ltd. &
International Food Technology, Ltd.
5th Floor Charn Issara Tower 1
942/137 Unit 6, Rama 4 Road
Bangkok 10500, Thailand
phone: (662) 267-3740
fax: (662) 267-3743
email: info@foodaudits.com
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