I just visited, with some of my co-workers with long time experience in
Iceland, some seafood factories in a China coast city. To believe by
to see, we give highest marks for their performance in HACCP and so =
on.
Therefore I will suggest everybody should have same CP apply to his own
work first then to his HACCP. There are some factories did some no
good job, but this happened allover the world, not only in developing
countries. Please local one case by one case objectively. If we apply
the rule of one dot for all, then we need shut down all the food
companies in the world.
Best Regards
Johann Youyi Xiang
=20
> -----Original Message-----
> From: Juan L. Silva [SMTP:jls@ra.msstate.edu]
> Sent: 14. febr=FAar 1999 22:54
> To: PROFOODS14@aol.com
> Cc: seafood@ucdavis.edu
> Subject: Re: HACCP Viloations by Foreign Processors
>=20
> 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.
>=20
> Juan L. Silva
>=20
> PROFOODS14@aol.com wrote:
>=20
> > 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.
>=20
> << File: Card for Silva Juan L. >>=20