Andrew Strak (abstrak@accesswave.ca)
Tue, 1 Jun 1999 09:53:31 -0300
Yes Ben, but the consumer is much more aware this days about eating some
products raw that ever before and that fact itself may lead to a significant
shift in preferences and consumption in general. It almost brings a
preventive driving style analogy when we do not comply only with driving
regulations but proactively assess any situation from the point what may go
wrong and adjust our actions accordingly. Besides, she has every right to
know the risks and the producer should be compelled to exercise due
diligence in minimizing those risks not through HACCP only but making the
consumer aware if those risks are inherent in the product. And the potential
allergent presence situation in the product can be used as a good example.
Any potential procurement from artisanal fishery is a tricky and risky one
since usually so little is known about the origin of the product and its
handling and any evaluation based on chemical or micro analysis without a
solid risk preventing system in place is simply impractical and
overwhelming. The situation must be particularly bad in the areas where
resource management practices are poor or ineffective not too mention
inability to implement any HACCP program by the suppliers and the proximity
of fishing ground to the shore and human settlements multiplies the risk
factor due to agricultural, industrial and human waste situation. And that
issue has to be address beforehand prior to engaging in any product or
process specific CCP situation in the plant and sometimes the only
reasonable and right way is to walk away from the business or delay till
the situation is becoming managable. Therefore a solid awareness and
knowledge about risk factors in particular those invisible ones or outside
the wall of the organization is essential and therefore the best internal
process cannot help if there is a shortage of critical expertise. Too much
reliance on a team approch to the HACCP situation may be sometimes
blindsiding since it brings the comfort of dissolving in the crowd and
diluted responsibility therefore a team composition is always critical since
0+0=0 regardless and any team without a right mix of knowledge, experience
and ability is nothing more than empowered ignorance. On the other hand a
sole reliance on a single CCP point and its effectiveness can be ilusory as
well and depending on the particular company environment and culture or
reliability of the system sometimes it would be wiser and more practical
to have a hurdle type of technology instead. And if one hurdle fails there
is always another to pick-up the slack and very often it's simply a
probability issue according to the formula that if the probability of two
independent events occuring independently is 1/100 each or 1% chance
therefore a probability of occuring them simultaneously is only 100x100=
1/10000 or 0.01%, therefore not two-fold but a hundredfold difference.
Andrew Strak
-----Original Message-----
From: Ben J. Elder <benelder@home.com>
To: Andrew Strak <abstrak@accesswave.ca>; phowgate@rsc.co.uk
<phowgate@rsc.co.uk>; Dipak.Chaudhari@unilever.com
<Dipak.Chaudhari@unilever.com>; seafood@ucdavis.edu <seafood@ucdavis.edu>
Date: Monday, May 31, 1999 11:14 PM
Subject: Re: CCP - microbial contamination
>Andrew,
>You are correct relative to washing the surface of the fish followed by
>skinning. However; monitoring the aquatic conditions of the origin of the
>seafood has pretty much put the Louisiana oyster business under. It has
>required the restaurants in New Orleans to put disclaimers on their menus
>informing people to eat the oysters at their own risk. How would you like
>that sticker on your product?
>Any product eaten raw today is in jeapordy. Especially in the U.S. That
>includes oysters to hot dogs to baloney.
>Ben Elder
>-----Original Message-----
>From: Andrew Strak <abstrak@accesswave.ca>
>To: benelder@home.com <benelder@home.com>; phowgate@rsc.co.uk
><phowgate@rsc.co.uk>; Dipak.Chaudhari@unilever.com
><Dipak.Chaudhari@unilever.com>; seafood@ucdavis.edu <seafood@ucdavis.edu>
>Date: Monday, May 31, 1999 6:27 PM
>Subject: Re: CCP - microbial contamination
>
>
>>Ben,
>>
>>Your are largely right but we do not even know the extent of the proplem
in
>>terms of the nature of contamination. If it is on the surface of the skin
>of
>>round fish it is still possible to wash the fish thoroughly and
>subsequently
>>skin it, depending on the required attributes of the product. It should
not
>>be in lieu of much stringent SOP for fish handling and icing, however. The
>>quality of ice may be a culprit as well as quality of any process water.
>>Moreover, nothing is known about the aquatic environment of the fish
>itself.
>>There are lots of other variables therefore no HACCP out of shelf ever
>>works.
>>
>>Andrew
>>
>>
>>
>>
>>-----Original Message-----
>>From: Ben J. Elder <benelder@home.com>
>>To: phowgate@rsc.co.uk <phowgate@rsc.co.uk>; Dipak.Chaudhari@unilever.com
>><Dipak.Chaudhari@unilever.com>; seafood@ucdavis.edu <seafood@ucdavis.edu>
>>Date: Monday, May 31, 1999 5:25 PM
>>Subject: Re: CCP - microbial contamination
>>
>>
>>>Peter,
>>>You are correct. But the dilema here is if Dipak cannot control the
>safety
>>>of the product, and even sometimes if he can, using it in an uncooked
>>>product places him in enormous jeapordy and only one recall or law suit
>>from
>>>being out of business or worse.
>>>A good example is Hudson Foods who received certified good product from
>>IBP,
>>>ground it into hamburger meat under sanitary conditions which were
>>certified
>>>by the USDA, sold it as patties, and within one year this S1.6 billion
>was
>>>out of business, and its top managers indicted by a Federal grand jury.
>>>There are differences between USDA and FDA but the consumers and the
>courts
>>>will not care.
>>>If I were in his position, I would establish a CCP at the receiving dock,
>>>with stringent SOP's, backed up by inspections of the suppliers
>>>establishments and periodic swab tests of the product and document
>>>everything so that if the occasion should ever arise, I would have
>>something
>>>on which to base a defense.
>>>I think is best in today's marketplace, to plan on "when" rather than
>"if".
>>>Ben Elder
>>>-----Original Message-----
>>>From: howgate <phowgate@rsc.co.uk>
>>>To: benelder@home.com <benelder@home.com>; Dipak.Chaudhari@unilever.com
>>><Dipak.Chaudhari@unilever.com>; seafood@ucdavis.edu <seafood@ucdavis.edu>
>>>Date: Monday, May 31, 1999 1:56 PM
>>>Subject: Re: CCP - microbial contamination
>>>
>>>
>>>>Ben Elder wrote on 31 May:
>>>>
>>>>> Dipak,
>>>>> I have to disagree with Peter Howgate on the importance of the
>receiving
>>>>of
>>>>> raw fish for control of microorganisms.
>>>>> It has been my experience that if you have a further process that
>>>>controls
>>>>> the problem, such as a cooking cycle, it would not be a CCP. However;
>>if
>>>>> you do not, how will you control the potential problem if not at the
>>>>loading
>>>>> dock?
>>>>> It would seem to me, if you have a receiving SOP that examines the
>>>>product
>>>>> relative to temp., color, smell, etc., and a procedure for rejecting
>the
>>>>> substandard product, that rejection is a corrective action and that
>>>>implies
>>>>> the process is a CCP.
>>>>> Regards,
>>>>> Ben Elder
>>>>
>>>>Dipak was not very specific in his original message about the hazards in
>>>>his fish. He referred to the 'CCP for control of microbiological
>>>>contamination...'. I assumed he was referring to a CCP in a HACCP plan
>and
>>>>that he was concerned with contamination with human health pathogens,
and
>>I
>>>>based my comments on these assumptions. If either of these assumptions
do
>>>>not describe the situation, then we are not discussing CCP's, but just
>>>>quality assurance procedures. In that case, Ben's second paragraph above
>>is
>>>>not relevant, but the third is. However, let me assume my assumptions
are
>>>>correct.
>>>>
>>>>There are several texts and summaries of the HACCP system around, but
the
>>>>two I use as authoritative reference texts are the Codex Alimentarius
>>>>guidelines published in its Food Hygiene Basic Texts, FAO/WHO, Rome,
>1997,
>>>>and the NACMCF HACCP Principles and Application Guidelines, J. Food
>Prot.,
>>>>1998, 61, 762-775. These are clear descriptions of the system drawn up
by
>>>>experts and I see no reason why one would want to deviate from them. It
>is
>>>>quite clear in both of these texts, and in others, that HACCP addresses
>>>>safety issues and not matters of quality outside of safety. The
>definition
>>>>of a hazard in the Codex text, (it is similar in the NACMCF text), is:
'A
>>>>biological, chemical or physical agent in, or condition of, food with
the
>>>>potential to cause an adverse health effect.'. None of the actions
listed
>>>>in Ben's third paragraph will detect a hazard, apart perhaps the hazard
>of
>>>>the presence of scombrotoxin in spoiled fish of the species liable to
>>>>produce the toxin. Dipak referred to microbial contamination and not to
>>>>scombrotoxin. Very fresh fish could be heavily contaminated with
>>pathogenic
>>>>bacteria, but would be accepted on Ben's criteria. Spoiled fish which
>>would
>>>>be rejected on Ben's criteria would most likely be safe, though
>>unpleasant,
>>>>to eat because pathogenic bacteria would die in competition with the
>>>>spoilage flora.
>>>>
>>>>A CCP is defined as: 'A step at which control can be applied and is
>>>>essential to prevent or eliminate a food safety hazard or reduce it to
an
>>>>acceptable level.'. I take reception to be the step in which fish is
>>>>brought into the processing plant and procedures such as removal from
>any
>>>>containers, sorting, grading, perhaps washing, sending on to the next
>>step,
>>>>perhaps repacking in ice, and storage in a chill are applied. None of
>>these
>>>>procedures prevent or eliminate microbiological hazards, or reduce them
>to
>>>>acceptable levels. The presence of pathogenic hazards can not be
>>monitored,
>>>>and it is not possible to apply control measures or corrective actions
if
>>>>the result of monitoring show a deviation from control. If Dipak goes
>>>>through the decision trees included in the texts I have referred to he
>>will
>>>>find that reception fails as a CCP at Question 1 or Question 2.
>>>>
>>>>Ben asks the question: '...how will you control the potential problem if
>>>>not at the loading dock?'. Would Ben care to describe how he would
>control
>>>>the problem at the loading dock? Let me pass on this quotation from
>>Chapter
>>>>6 of the Compendium of Fish and Fishery Product Processing Methods,
>>Hazards
>>>>and Controls:
>>>>
>>>>'FDA Guidelines
>>>>
>>>>1. Raw fish and fishery products to be cooked before consumption
>>>>
>>>>FDA is not aware of any HACCP controls that may exist internationally
for
>>>>the control of pathogens in fish and fishery products that are intended
>to
>>>>be fully cooked by the consumer or end user before consumption, other
>than
>>>>a rigorous sanitation regime as part of either a prerequisite program or
>>as
>>>>part of HACCP itself. The Seafood HACCP Regulation requires such a
>regime.
>>>>The proper application of sanitation controls is essential because of
the
>>>>likelihood that any pathogens that may be present in seafood products
are
>>>>introduced through poor handling practices (e.g., by the aquacultural
>>>>producer, the fisherman, or the processor) (FDA, 1998i).' Quite.
>>>>
>>>>Dipak refers to use of the fish in sashimi, that is in a product
intended
>>>>for consumption without prior cooking. Here he has a much more severe
>>>>problem. In HACCP plans where reception is a CCP, the recipient requires
>>>>the supplier to assure the former that the hazard is within the control
>>>>limits and control at reception is verification of records, for example
>>>>mercury in tuna delivered to a cannery, bacterial contaminants in
bivalve
>>>>shellfish. In the case of raw fish, it is not possible for a supplier to
>>>>assure a recipient that the fish is free of pathogens, or is even within
>>>>control limits as very few regulatory authorities have laid down limits
>>for
>>>>pathogens in raw fish. If Dipak knows from surveys and analysis that the
>>>>fish he receives contains biological hazards - parasites, pathogenic
>>>>bacteria like V. parahaemolyticus and L. monocytogenes, all widely
>>>>distributed in the aquatic environment - should he contemplate using it
>>for
>>>>preparation of sashimi?
>>>>
>>>>Peter Howgate
>>>>
>>>
>>>
>>
>
>
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