Subject: Re: SANET-MG Digest - 15 Nov 2002 to 16 Nov 2002 - Special issue (#2002-60)

From: [email-masked]
Date: Sat, 16 Nov 2002 20:14:22 EST

In a message dated 11/16/2002 4:12:45 PM Pacific Standard Time,
[email-masked] writes:

> 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?

Douglas, I don't mean to split hairs. However, I am concerned that HACCP has
sometimes been used to perpetuate poor quality food. I know that you intend
to use the concept wisely, but from a consumer point of view, it is difficult
to differentiate "good" HACCP from "bad" HACCP. One bone of contention in the
food industry is whether HACCP should be extended beyond the walls of the
plant. One interpretation of HACCP would involve minimizing the levels of
pathogens in the incoming raw materials. Another interpretation would be
based on having a kill step that can accommodate any level of pathogens in
the incoming raw materials. Theoretically, the pathogen levels in the
finished product could be the same. My question is: should consumers prefer
to eat food that was made from materials that were grown pathogen free, or
should they prefer food rendered "safe" through the use of pathogen reducing
technologies such as irradiation? Unless I am wrong, both plants would have
legitimate HACCP plans in place and produce pathogen levels acceptable for
commerce. I also believe that both plants would meet the criteria set forth
in your list of HACCP principles. Finally, the reason I am so picky about the
HACCP concept is that many food plants have legitimized their processing
methods by having a HACCP plan. While the concepts of HACCP are straight
forward, the implementation leaves room for error. The quality of the HACCP
plan is limited by the company's understanding of their process and their
ability to implement the plan. Again, I am not directing this at you and your
intentions. I am concerned that implementing HACCP in the organic food
industry will the same very positive and negative results as in the
mainstream food industry.

Alan Ismond, P.Eng.
Aqua-Terra Consultants

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From: Douglas Hinds <[email-masked]>
Date: Sat, 16 Nov 2002 20:33:38 -0600

Hello Alan other saneters following this thread,

You said:

AAC> ... I am concerned that HACCP has sometimes been used to
AAC> perpetuate poor quality food. I know that you intend to use the
AAC> concept wisely, but from a consumer point of view, it is
AAC> difficult to differentiate "good" HACCP from "bad" HACCP.

I wasn't planning on promoting the use of whatever HACCP-like system
is put in place and I doubt that many consumers know what it is. We
just want to be sure that our food isn't contaminated and need to
analyze and act methodically in order to take care of that.

AAC> One bone of contention in the food industry is whether HACCP
AAC> should be extended beyond the walls of the plant.

>From beginning to end.

AAC> One interpretation of HACCP would involve minimizing the levels of
AAC> pathogens in the incoming raw materials.

It should.

AAC> Another interpretation would be based on having a kill step
AAC> that can accommodate any level of pathogens in the incoming raw
AAC> materials.

Not adequate.

AAC> Theoretically, the pathogen levels in the finished product
AAC> could be the same.

Pathogen levels is only part of the story.

AAC> My question is: should consumers prefer to eat food that was
AAC> made from materials that were grown pathogen free, or should
AAC> they prefer food rendered "safe" through the use of pathogen
AAC> reducing technologies such as irradiation?

A rhetorical question. Part of the problem is the fact that not all
consumers are aware of these issues.

AAC> Unless I am wrong, both plants would have legitimate HACCP
AAC> plans in place and produce pathogen levels acceptable for
AAC> commerce.

But not directed to the same consumers.

AAC> I also believe that both plants would meet the criteria set forth
AAC> in your list of HACCP principles.

No, because first you need to know how and where the pathogens are
getting into the system.

AAC> Finally, the reason I am so picky about the HACCP concept is
AAC> that many food plants have legitimized their processing methods
AAC> by having a HACCP plan.

An unconscious, incomplete HACCP plan.

AAC> While the concepts of HACCP are straight forward, the
AAC> implementation leaves room for error.

To error is human. A good HACCP implementation would help minimize
that.

AAC> The quality of the HACCP plan is limited by the company's
AAC> understanding of their process and their ability to implement
AAC> the plan.

That's true of anything.

AAC> Again, I am not directing this at you and your
AAC> intentions. I am concerned that implementing HACCP in the
AAC> organic food industry will the same very positive and negative
AAC> results as in the mainstream food industry.

The organic food industry is not going to do this and OFPA doesn't
require it. However, it represents a valid way to resolve the issue
raised in relation to compost tea and the organic food industry's
Achilles heel.

Douglas

.