Transparency Needed When Combining HACCP with ISO

In 1998, the Final Rule was passed concerning HACCP implementation in the meat and poultry industries in order to ensure the nation’s meat and poultry products were produced in a safe manner and that these products were not produced in conditions that would cause adulteration or contamination.

Some organizations that work with food safety, using HACCP in combination with food quality issues, using ISO 9000 and higher, are Stoller’s honey 1, Sealord 2 and Chilton Consulting 3. Theoretically, because of the accountability that is present due to monitoring, verification, corrective actions and recordkeeping of all of the steps required by both HACCP and ISO, food safety and food quality are maintained in a more efficient and effective fashion. But the combination is not likely to occur in American food industry in general. The food industry in particular will offer much resistance as the food industry has just come through HACCP implementation that proved rather expensive 4.

According to Christine Bedillion of NSF, many companies in the U.S. don’t wish to incorporate ISO into their food safety/quality system because they feel that their own quality systems are sufficient to provide good quality. 5 In fact, many industrial and governmental workers, while being well aware of HACCP and the HACCP regulations found in 9 CFR 417, were not aware of ISO, or knew of it but did not use the system 6.

Any combination would mean the expense of retraining. Many poultry and red meat plants, particularly smaller plants, are still recovering from having to comply with HACCP regulations 7. The consensus is, “If it ain’t broke, don’t fix it,” which gives a false sense of security, especially in regards to existing regulations on finished products.

FPS and Accountability

FPS deals with dressing defects, that indicate problems with the mechanization in the establishment, as well as trimming defects, that are related to how well the establishment is preparing its product for further processing or for shipping to various consumers.

FPS has accountability problems in many establishments. Once a particular lot of poultry has passed testing after having initially failed, the testing of that lot is completed although subsequent lots may be in violation. While testing can be done again, the time constraints usually dictate that further testing is not done. When the test is deemed complete by markers exiting the chiller defining the lot of birds that is questionable, the establishment is allowed to return to its usual testing pattern in accordance to FSIS regulations and directives.

Since this is not considered food safety, emphasis is not placed on finished product standards. On the other hand, FPS does indicate a problem that could lead to food safety and/or sanitation issues. The accountability that is lacking can be amended with the use of ISO, particularly from the standpoint of recordkeeping, much as HACCP has done with food safety.

This will call for a more consistent application of transparency that must be present in HACCP and SSOP in order to be effective. Regulators will have to be consistent in their observations and establishments will have to be more transparent in demonstrating the effectiveness and efficiency of their process. This will further call for the consistent application of transparency between the various segments involved with the production and processes of the poultry and red meat industries, i.e., production itself, the maintenance department, quality assurance and any other department that has an involvement in the production of food, including governmental regulators 8. So state the HACCP regulations 9.

From the governmental standpoint, the important directive to keep in mind with HACCP, SSOP and Sanitation Performance Standards is Directive 5000.1, Verifying an Establishment’s Food Safety System.