Hi Food safe list,
The prequisite programs are important especially GMP and SSOP to support
your HACCP plan and I agree with this comment. However, I'm still
having difficulty in defferenciating GMP from SSOP. Can anybody explain
what is GMP and SSOP? Thanks.
Tim.
-----Original Message-----
From: owner-seafood@ucdavis.edu
[mailto:owner-seafood@ucdavis.edu] On Behalf Of Remi Michalowski
Sent: Wednesday, 12 April 2006 5:50 PM
To: Lupin, Hector (FIIU)
Cc: Daniel Brooks; seafood@ucdavis.edu
Subject: Re: HACCP Question
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"
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