Subject: HACCP "Rules"

From: [email-masked]
Date: Sat, 16 Nov 2002 10:55:43 EST

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.
Aqua-Terra Consultants

---

From: sals <[email-masked]>
Date: Sat, 16 Nov 2002 12:23:59 -0800

IMHO as a grower and eater of organic food.  If in doubt I leave it out.
that goes for anything they say don't pick for 90 to 120 days or it
might kill u or make u sick.  why would I want to spray something on the
food I grow and eat that if u pick it before the 90 days u get real
sick.  come-on now this is getting to sound more like conventional
growing every day.  when I started growing organic and eating organic I
did it because I was looking for safer food.  The USDA better keep
organic safe if nothing else.  I don't use any shit any more and I don't
use anything that says you have to wait so long before the food is safe
to eat.  what about the grower spraying the stuff can he get sick if he
is spraying something that takes 80 days to be safe.  if one USDA
organic grower grows food that makes folks sick all organic growers will
suffer ..  If folks can say organic is not safer than conventional food
because the USDA lets organic growers use stuff that will make u sick
then all organic growers will suffer.  .  now I use no shit still folks
say organic food is not safer because the organic stuff they use on the
plants is not safe.  well I don't use that stuff but still I have to
suffer because someone is bum raping all organic growers because the
USDA is letting organic growers use unsafe stuff.  If one grower made
folks sick with a USDA organic materials list approve product forget
about it it.     maybe to u folks that want to grow organic just for the
big bucks its ok but if u want to grow safer food for all that eat it
why take the chance with HACCP or whatever.  if in doubt leave it out.
how can u sleep because the USDA says leave it 120 days and it will be
safe.  they  say that about a lot of stuff. If the USDA lets stuff be
used in the USDA organic movement that is not safe I will run from the
word organic.  RUN  and so will all those that buy organic.  Keep
organic safe plus keep organic organic .  that is what the USDA should
be doing.  Most folks that buy organic feel it is safer no matter what
the USDA says so let us not betray their trust in organic food.
-----Original Message-----
From: Sustainable Agriculture Network Discussion Group
[mailto:[email-masked]] On Behalf Of [email-masked]
Sent: Saturday, November 16, 2002 7:56 AM
To: [email-masked]
Subject: HACCP "Rules"

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.
Aqua-Terra Consultants

---

From: Douglas Hinds <[email-masked]>
Date: Sat, 16 Nov 2002 15:31:47 -0600

Hello Alan & other saneters following this thread,

In relation to the post Alan sent Saturday, November 16, 2002 about
HACCP "Rules":

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
AAC> required.

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
health.

AAC> Douglas, I respect your view that safety and quality go hand in
AAC> hand,

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
exists.

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 -
period.

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
(innocuity).

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
STOPPED.

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
  production...

  HACCP methodology represents an option I intend to look into
  further ...

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?
(Habit)?

Douglas

.