Thanks Dr. Lupin and others for clearing this issue. Now I understand
the difference between SSOPand GMP issues.
Tim
-----Original Message-----
From: Lupin, Hector (FIIU) [mailto:Hector.Lupin@fao.org]
Sent: Thursday, 13 April 2006 3:20 AM
To: Timothy Numilengi
Cc: Daniel Brooks; seafood@ucdavis.edu; Remi Michalowski
Subject: RE: HACCP Question
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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