Hi Tim,
actually in US regulation, cGMP or Current Good Manufacturing
Practices is a whole thing e.g. SSOP or Sanitation Standard
Operational Procedures (hygiene, sanitation, prevention of
adulteration and cross-contamination, safety of water and ice,
etc.,), production and process controls (via HACCP and Defect Actions
Levels), and facilities conditions.
In Europe, we use more PRP or Pre-requisites program (SSOP or Good
Hygienic Practices (GHP), facilities and workers basic knowledge).
And you need a GMP to make your process works. The HACCP is another
thing: a tool to complete the whole food safety package by supporting
your control on key steps.
Kind regards,
RM
On Apr 12, 2006, at 3:11 PM, Timothy Numilengi wrote:
> 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"
>
>
>
>
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 - 02:09:29 PDT