I am an extension specialist and native of a South American country. What you
have said is already public and whether you wanted or not the FDA already knows
what you wrote and probably who you are.
I do not doubt your assertion as to the violations by some South American
companies. However, by publishing this vague document you have placed a burden on
the good and the bad companies. You need to first sign your document and
secondly, if you have proof, go ahead and send a list to the authorities so that
they can take action. I do not understand why you would be worried of retaliation
if you are following the rules and the law.
I aplaud you for adhering to the law and improving the products you bring to the
public. I hope that you come forth and provide evidence to stop fraudulent
shipments of seafood that may cause harm to our consumers.
Juan L. Silva
PROFOODS14@aol.com wrote:
> We are a seafood importer and domestic fish processor fully in compliance with
> the FDA HACCP regulation. As with most domestic seafood processors (and the
> majority of foreign processors), we have spent countless hours and made a
> significant monetary investment in educating ourselves in HACCP, writing a
> HACCP program, implementing the HACCP system, verifying our system and record
> keeping practices and training our employees. It was a significant challenge
> but ultimately, we have become a better company and seafood supplier because
> of it. For us, the investment has been worthwhile.
>
> In addition to developing our own domestic HACCP program, as an importer, we
> have been active in assisting our foreign suppliers and travelling to their
> locations to verify their HACCP systems and be sure that they are implementing
> the systems correctly. Again, this has been a signicant investment of both
> time and dollars, but for the most part, a worthwhile investment.
>
> Having been through this process and having made the financial investment, I
> find it particularly offensive to have knowledge of a select few members of
> this industry (principally foreign processors and their domestic
> importers/brokers) who knowingly violate the system by submitting a generic
> HACCP document (typically written by a third party) to "qualify" their
> products for import into the United States, but do not implement the system in
> their manufacturing operations. In South America particularly, there are
> generic HACCP documents for sale that these foreign processors purchase and
> submit to their importers/brokers here in the United States. These foreign
> processors do not implement the HACCP plans and in many cases could not
> possibly comply with HACCP as they do not have the process, instrumentation or
> qualified personnel in place. They understand too well, that the FDA is too
> stretched to ever check these foreign processors plants and that in
> colaboration with their importers/brokers here in the United States they can
> slip through the regulation by submitting these types of "false" documents and
> having these "less than honest" US importers/brokers simply say that they are
> following the HACCP plan. We have had first hand experience with this on
> several of our visits to South America. These processors boldly ask us to
> assist them with their imports to the United States by "verifying a HACCP
> plan" that we can clearly see does not exist. Often, financial incentives are
> offerred.
>
> We have dismissed all such offers and have dropped several suppliers because
> of this fraudulent submission of documents to the FDA.
>
> The dilema: We know of these companies and their US importers/brokers. We
> know that several of these companies are sending products into the United
> States that are not only not processed under HACCP but have microbial loads
> which exceed the FDA limits. Some of these companies are importing
> potentially dangerous products. We would like to report these companies to
> the FDA but fear that doing so may bring undue scrutiny onto our own company.
> We may be the subject of automatic import detensions and examination that will
> raise our import costs and delay release of our products. Currently the FDA
> examines about one out of every six of our import shipments. This is
> acceptable and maintains our import costs at a reasonable level. We have
> never had any problems with our imports or the FDA, primarily because we
> scrutinize our export partners and their operations.
>
> Should we report these companies to the FDA? Can we do it annonimously? Does
> the FDA even want to know this information or does this fall into the category
> of things the they can't change and therefore prefer not to know about?
>
> I realize that the current HACCP regulations is not perfect and that the FDA
> has a limited human resources, but it simply rubs me the wrong way to see a
> select few violators capitalize on the FDA's limited resources and in effect
> thumb their noses at the rest of us in this industry that have taken this
> HACCP regulation seriously and worked diligently to implement it into our
> organizations.
>
> Any comments are appreciated.
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