Dear Tim,
With acronyms (e.g. GMP and/ or SSOP) the first problem is that they may
appear in different reference documents (e.g. regulations and guidelines)
sometimes with slightly or large differences between them. If we want to have
a sharp definition of each of them, that will be within the context of a
given regulation or guideline (e.g. the FDA Title 21 Part 123). In addition
there are other acronyms like GHP (Good Hygiene Practices), GAP (Good
Aquaculture Practices) and as already mentioned Pre-Requisites (PR) of
Pre-Requisites Programme (PRP). In Europe you can find also HP (Hygiene
Plans). However is is necessary to take into account that when we add "plan"
or "programme" we are talking about a systematic procedure (that could be or
not in written, but if it is in written better, and some regulations ask
that). "Plans" and "programmes" are (under HACCP regulations) a sole
responsibility of the operator. Regulations do not necessarily tell you much
how to perform them (you know your process better than anybody else).
However, if we have to do a practical classification (from the point of view
of safety), we could say that the order of hierarchy (starting from the
lowest) could be the following:
Pre-requisites : Things that physically should be all right from the hygiene
point of view in your plant, even before the fish enter there (walls, floors,
windows, filleting tables, water supply, drainage, bathrooms, air curtains,
hand-washing stations, boot-washing stations, etc.).
Good Manufacturing Practices: Are the standard procedures you are going to
follow to process your fish. Manufacturing refers to production. However, you
have to produce in a safe way and as a matter of fact some people mix good
manufacturing practices (how you are going to fillet your fish) with hygiene
considerations (e.g. Good Hygiene Practices). However, from the point of view
of safety the important thing would be to be sure that manufacturing
practices do not interfere with safety systems or create (or enhance)
hazards. GMP practices are normally related to time, concentrations,
temperatures, Aw, pH, weight, yields, traceability (e.g. FIFO), etc.
Good Hygiene Practices: They are general (non-specific) practices aimed to
achieve a general hygiene state in the plant. They tend to be general advice
like "personnel shall not move from dirty to clean areas" or "everybody in
the plant shall wear rubber boots and clean them before to enter the plant"
or "knives shall be cleaned, disinfected and rinsed after each shift"; "do
not spit in the floor"; etc.. Good Hygiene Practices could be more or less
complex depending of the type of product, plant, etc. For instance everybody
cooking food for a family should follow some Good Hygiene Practices. No
plans, no records, but in complex plants could be necessary to write them
down and to tell personnel what do you expect from them.
SSOPs and Hygienic Plans: Good Hygiene Practices are necessary but not enough
to provide food safety. There are in the plants some recurrent hygiene/
safety problems that it is better to focus in more detail. For instance water
and ice safety or pest control. In this case we prefer to have a systematic
scheme to monitor them and to provide corrective action. There is some
discussion about this, but is preferable to have a written plan (or
programme) to monitor and control SSOPs and similar.
How we decide on what should be "promoted" from a generic indication of GHP
to a SSOP? The first answer (and the practice) is those specified in
regulations (like the 8 SSOPs included in the FDA Title 21 Part 123). The
ones included in regulations are those already identified as common problems
in that sector or type of industry. Different type of food industries could
require different type of SSOPs. We know in the fish industry that we have
(or could have) problems with water (or ice) and pests. If we research for
the most common and recurrent problems, guess who are the first eight that
will pop up.
But your plant could be different and you may need some additional SSOP from
those in regulations. To analyse that you have to look into the
"epidemiology" of your plant. Two of my favourites "non-regulatory" SSOPs
are: (i) SSOP for indoor facilities repair and (ii) SSOP for plant equipment
repair and adjustment. They are not mentioned very often, but a common source
of foreign objects in fish (and food products) came from non food safety
criteria of people performing repairs and adjustments, both when the plant is
in operation or even when is idle.
CCP and HACCP Plans: In this case we go into the epidemiology of the product.
We look into specific hazards (e.g. Salmonella spp) and the control is
specific on the risk of that hazard. All the previous procedures help to
reduce risk in general, but focusing on the main relevant (and known) hazards
of a given product we reduce the specific risk.
As it has been said HACCP Plans per se can not solve the problems left by the
lack of proper facilities, or absence of SSOPs plan. The highest hierarchy
(till here) are HACCP plans but each hierarchy is building up on the
precedent. Each level reduce the risk further.
The important thing is not to become entangled with acronyms, but to look
first into the regulations you should be in compliance with and then look
into your plant and see for things your plant or your product may be
different. Do not wait somebody else find the difference.
Hector M. Lupin
-----Original Message-----
From: Timothy Numilengi [mailto:tnumilengi@fisheries.gov.pg]
Sent: 12 April 2006 10:11
To: Remi Michalowski; Lupin, Hector (FIIU)
Cc: Daniel Brooks; seafood@ucdavis.edu
Subject: RE: HACCP Question
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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