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I think that it is important to realize that HACCP, just like Organic, can be a double edged sword. Buyers and consumers want to know that the food they are buying is of a certain quality. The problem is in defining:
1. What is quality?
2. What can and can't producers do and use in order to achieve this quality?
3. Who decides on all of the definitions and standards?
Even though you may create and implement a HACCP program to ensure the quality and safety of raw dairy products, you will have a difficult time selling these products (in the US). The crux of the matter is that I would trust a knowledgeable and ethical farmer to set his/her own standards and methods of operation. But what about the not so enlightened farmer or the unscrupulous farmer? This is where third party standards may be required.
One side note on whether food producers are allowed to convert poor quality product into a "safe" product. HACCP is primarily focused on product safety and not necessarily product quality. As long as you have an adequate kill step that results in the mandated log reductions in pathogens, you are considered to be producing a suitable product. Douglas, I respect your view that safety and quality go hand in hand, but I think that you will find that the majority of the food production system has separated these attributes. The government imposed HACCP standards in response to food safety concerns. Your suggestion to create a new acronym if HACCP does not address quality and safety could face the same problems encountered in setting the "new organic" standards.. In the end. consumers will need to get closer to the producers of their food and place their trust in the individual and not the piece of paper or the certification.
Alan Ismond, P.Eng.