Because HACCP is a growing continuum, when problems arise in verification or enforcement, adjustments can be made, such as the use of CFR 500, Rules of Practice, in order to pursue the documentation, notification and actions necessary for proper enforcement and ensuring food safety.
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In the past few years, new enforcement training has come about in food safety regulation enforcement. The Consumer Safety Inspectors and Veterinarians group within FSIS are trained such that HACCP enforcement is more clearly defined and so that the nation is uniform in its HACCP decision-making.
This uniformity is important to further ensure food safety and at the same time to provide equitability in carrying out HACCP’s main function, that is, to afford the plants to demonstrate that they can control their system even when deviations occur. This involves understanding and application of the principles of HACCP by the establishment and verification of establishment’s performance by regulators. These have resulted in reassessments of HACCP plans in terms of E. coli in livestock operations; an update of FSIS Directive 10010.1, Microbiological Testing Program for E. coli 0157:H7 in Raw Ground Beef and an update on the Reassessment of HACCP plans dealing with E. coli 0157:H7; updates to the sampling programs for detection of Listeria monocytogenes; and modifications and updates to enforcement procedures in establishments, listed and discussed in FSIS Directive 5000.1.
In this directive, sanitation SOPs and performance standards and HACCP are presented together and enforcement discussed, as well as the rules of practice which are also found in CFR 500. In 2003, Garry McKee–then administrator of USDA–affirmed that those in the field must continue to enforce HACCP using a science-based approach and to remember the goal of pathogen reduction. He then charged both regulators and industry with the responsibility for food safety.
ISO is a little more complicated than HACCP, in that each establishment uses international standards and customizes its programs accordingly. It designs its own steps to assure quality and meeting the standard. As such, ISO gives the establishment flexibility. From the quality standpoint, ISO provides for development and implementation of a program that is able to audited, accredited and measured. Now with ISO 22000, HACCP, along with supporting measures is being incorporated into companies around the world. The standards are auditable and useful for building confidence. The British Retail Consortium (BRC) has a Web page devoted to the use of ISO 22000. In ISO 22000, all points of the food chain are considered, as well as the regulations regarding food safety. (9 CFR 417) It is the purest incorporation of HACCP into ISO and the combination of both sets of standards.
But can both be used successfully, at least theoretically? One way to determine both the drawbacks and benefits of just such an arrangement is by risk management, assessment and communication which ultimately formulate risk analysis.
- Futures. Michigan Agricultural Experimental Station. Is Michigan Food Supply Safe? PP. 18 -21. Robin Usbourne Milsap. Winter, 2003.
- http://www.foodlaw.org/fortin_HACCP.pdf The Hang-up with HACCP: The Resistance to Translating Science into Food Safety Law. Food and Drug Law Journal. Vol 58:4 (2003) pp 565 – 594
- www.ers.usda.gov/ Meat and Poultry Food Safety Investments: Survey Findings/ TB-1911.
- FSIS Notice 54-03 Review of Establishment’s Data by Inspection Program Personnel. 12/6/04.
- www.foodqualitymagazine.com “HACCP Technology and Services” Jeff Chilton Feb/Mar 2004
- “Tweaking HACCP”, Chapter VIII, Lydia M. Guillot, DVM, MS, presented as the final project paper for Master’s Degree in Food Safety from Michigan State University, May 2004 7. FSIS Directive 5000.1 Revision 1. Verifying an Establishment’s Food Safety System. 5/21/2003.
- www.safefood.nsw.gov/ Practical application of risk.
- FSIS Directive 10240.3 Microbial Samples of Ready-to-Eat (RTE) products for the FSIS Verification Testing Program. 12/9/2002
- FSIS Directive 10240.4 Verification Procedures for the Listeria monocytogenes Regulation and Microbial Sampling of Ready-to-Eat (RTE) Products for the FSIS Verification Testing Program. 10/2/2003
- www.fsis.usda.gov/OPPDE/ Draft FSIS Listeria Risk Assessment. May 26, 2003.
- www.fsis.usda.gov Draft Risk Assessment of the Public Health Impact of Escherichia coli 0157:H7 in Ground Beef. September 7, 2001.
- www.meatscience.org/pubs/ Prevalence of E. coli during processing
- FSIS Notice 11-03. An update of FSIS Directive 10010. Microbiological Testing Program for Escherichia coli 0157: H7 in Raw Ground Beef (4/18/2003).
- FSIS Notice 44-02. Instructions for Verifying E. coli 0157:H7 Reassessment. 11/4/02.
- www.fsis.usda.gov CFR 500. Rules of Practice
- www.fsis.usda.gov Field Operations: Heart and Soul of FSIS. Dr. Garry McKee, Administrator. Office of Field Operations Supervisory Committee. 10/27/03.
- www.saferpak.com/brc.htm. Development of ISO and the BRC.
Lydia Guillot is a veterinary medical officer/public health veterinarian for USDA. Reach her at LGuil42909@aol.com.