The main issue actually is that everyone presents the HACCP as a
miracle solution to prevent food safety issues.
However, HACCP is nothing without the Pre-Requisites Program e.g.
GMP, SSOP, Facilities conditions and Workers' Skills and Awareness.
If you do not meet the requirements for the PRP, well, no need to
claim "I am a HACCP company".
That is right, you can have all the documentation the customers need,
you can prepare your audit but, at the end, if you do not have your
PRP, if you do not have correctly designed, implemented and made your
HACCP leaving (that is to say verified, validated and reviewed), it
is so useless... such as getting milk powder in the middle of the
desert without water.
HACCP is a tool, powerful, but if you look at the Codex standard : if
you cannot monitor the CCP, it is not a CCP... What the hell is that???
The gap is filed with the ISO 22000 and I really believe that this
standard is a little revolution for the food businesses and all the
actors within the food chain.
kind regards,
Remi Michalowski
Indonesia
On Apr 11, 2006, at 6:53 PM, Lupin, Hector (FIIU) wrote:
>
> 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
>
Dipl. Ing. Remi Michalowski
Senior Manager IQA Food Processing
PT. Centralpertiwi Bahari - Lampung, Indonesia
HP + 62 815 4040 484
Charoen Pokphand Group - "A Tradition of Quality"
This archive was generated by hypermail 2b29 : Wed Apr 12 2006 - 00:51:07 PDT