A Perfect Blend of ISO and HACCP, Part 3

Having done the risk assessment, risk management then becomes easier. Risk management incorporates information derived from risk assessment and uses educated judgment to make a decision whether or not to proceed with the program. The Agricultural Outlook published by the ERS (Economic Research Service) in May 1997 described how risk management was useful to farmers with limited resources. In this instance, risk management uses crop losses, price declines, and other economic issues to provide farmers with a strategy for recovery.

According to the Risk Management Decision Criteria, there are five aspects to consider in any risk management decision: 1) economic gain or burden, 2) health issues, 3) environmental issues, 4) social issues, 5) geo-political issues.

In this case of applying risk management criteria to combining HACCP and ISO in a poultry establishment, these apply readily. The economics in a poultry establishment are very real, especially smaller operations. While HACCP may only take $25,000 to operate and ISO only $31,000 to operate, smaller plants do not have the luxury of that liquid assets that larger plants do.

On the other hand, it takes more to implement ISO in a larger establishment, and the gains may not be as significant as in the smaller establishments. And while HACCP is already mandatory in all meat and poultry establishments, many are still recovering from having to bring themselves into compliance with the new regulations.

Will the implementation of ISO improve health issues? That may not be seen for many years, but ISO reduces rework potential, reduces dressing defects, and adds to food safety and quality improvement, according to Jeff Chilton of Chilton Consulting Services.

Sadao Komemushi of the School of Agriculture in Nakamchi, Japan, states that where HACCP has weak points, ISO would be able to strengthen those particular points. In this case, ISO would address dressing defects that the vendors, openers, and eviscerators fail to remove from a chicken carcass prior to reaching the line inspectors, such as failing to remove the bursa of fabricious from the tail area, removal of lung tissue, removal of oil glands, feathers, etc. Each of these is not at present considered food safety issues. Yet each one does contribute to food safety issues because of fecal material (in the case of intestines) or inedible material (in the case of lung tissue). For instance, the presence of the bursa of fabricious may indicate that feces may be leaking which means that pathogenic bacteria may also present.

While bacteria are undetectable at a microscopic level, and while the pressure washers used on a poultry line may be eliminate visible fecal material, the fact remains is that there is a high degree of probability that pathogenic bacteria are still present and contaminating the carcass. This is due to the structure of pathogenic bacteria and the fact that not all the washers in the word will remove all fecal material. ISO would increase accountability for the upkeep of machinery and facilities, as logs and records are important in the implementation of ISO, as they are in HACCP. Also, foreign countries themselves will be looking to import from countries that have implemented ISO in poultry and red meat plants, because the ISO standards are global standards. Foreign countries use ISO. It would be the job of the federal agencies to sell ISO to industry domestically, because at the present time, companies believe that it is enough to have HACCP, and that the finished product standards sufficiently provide tools for maintaining dressing and trimming.

Environmental issues are also important in poultry establishments, as many of the facilities have been in operation for at least 20 years in the same building. For that reason, the facilities are fairly old. When additions are made, they are done so onto the older facilities. In many instances, the roofs have not be upgraded and there are leaks which are only repaired when pointed out and documented by the USDA inspector, although those leaks are quite visible to anyone walking through.