[Date Prev][Date Next][Thread Prev][Thread Next][Date Index][Thread Index]
Re: HACCP "Rules"
Hello Alan & other saneters following this thread,
In relation to the post Alan sent Saturday, November 16, 2002 about
AAC> I think that it is important to realize that HACCP, just like Organic, can be
AAC> a double edged sword. Buyers and consumers want to know that the food they
AAC> are buying is of a certain quality. The problem is in defining:
AAC> 1. What is quality?
AAC> 2. What can and can't producers do and use in order to achieve this quality?
AAC> 3. Who decides on all of the definitions and standards?
AAC> Even though you may create and implement a HACCP program to
AAC> ensure the quality and safety of raw dairy products, you will
AAC> have a difficult time selling these products (in the US).
It depends on the state. Some states permit the sale of Certified
Raw Milk for human consumption, some don't. While a state inspector
may drop by every week or two to inspect a milking operation that
pasteurizes their milk, in a Certified Raw Milk operation, a state
inspector will be there EVERY DAY. That's because the certification
means that the milk came from cows that have NO contagious disease
that's transmissible via milk and that the milking and milk was
handled in a hygienic way.
AAC> The crux of the matter is that I would trust a knowledgeable
AAC> and ethical farmer to set his/her own standards and methods of
AAC> operation. But what about the not so enlightened farmer or the
AAC> unscrupulous farmer? This is where third party standards may be
Some of us are making our own decisions in relation to our own
production, while others of us are responsible for making rules that
others will follow.
AAC> One side note on whether food producers are allowed to convert
AAC> poor quality product into a "safe" product. HACCP is primarily
AAC> focused on product safety and not necessarily product quality.
AAC> As long as you have an adequate kill step that results in the
AAC> mandated log reductions in pathogens, you are considered to be
AAC> producing a suitable product.
Rather than suitable, a product that will not transmit infectious
disease. That is the responsibility of those responsible for public
AAC> Douglas, I respect your view that safety and quality go hand in
It will in our system.
AAC> but I think that you will find that the majority of the
AAC> food production system has separated these attributes.
And that is precisely why we are here. That is the reason sanet
AAC> The government imposed HACCP standards in response to food
AAC> safety concerns. Your suggestion to create a new acronym if
AAC> HACCP does not address quality and safety could face the same
AAC> problems encountered in setting the "new organic" standards.
I suggest implementing HACCP or HACCP-like principles, without
letting ourselves be boxed into a system that fails to recognize our
own fundamental concerns, such as the example Wytze gave. I am in no
way convinced that all HACCP or HACCP-like systems necessarily fall
victim to the the failings of a less then enlightened design team. I
am not worried about the failings that somebody else's poorly
designed HACCP system foisted on those concerned with toxic
chemicals in their food,because we will not make that mistake -
Also, I seriously doubt that we'll need to use a different acronym.
In any case, other systems (with other names) based on HACCP-like
principles have already been put in place: GAP (Good Agricultural
Practices) and MPE (the Model Plan of Excellence) are just two of
the HACCP-like systems put in place to insure food safety
As far as I'm concerned, the main issue here is the fact that we
need to to be thinking about these issues. We are not stuck with
ANYBODIES ready-made system for the simple reason that TIME HASN'T
AAC> In the end. consumers will need to get closer to the producers
AAC> of their food and place their trust in the individual and not
AAC> the piece of paper or the certification.
You are confusing two separate issues: It's not the label, it's the
process and the intelligence that went into designing it.
Just to get this back on track, I refer you to my answer to Wytze
(and remember that my suggestion was made in response to the
concerns raised by Chuck Benbrook). This what HACCP means to me:
Let's just look at what HACCP stands for: Hazard (in this case,
pathological microorganisms), Analysis (testing for them &/or
taking steps designed to insure their absence) via Critical
Control Points. I interpret that to mean that the entire operation
is analyzed in order to determine:
1).- At which points are the Hazards (the presence of pathological
microorganisms [or toxic chemicals] in food), likely to
present themselves and infiltrate the operation,;
2).- What can be done to minimize that risk (the concept of hazard
implies a risk - in this case the risk that a product will
become contaminated by pathological microorganisms);
3).- At what point and in what way can that risk be observed; and
4).- At what point and in what way can that risk be minimized?
I think the concept is valid and should be extended to other
possible sources of contamination, even for organic food
HACCP methodology represents an option I intend to look into
I'll second the point you made about the need to begin at the
beginning and end at the end. By why split hairs in the middle?