Transparency Needed When Combining HACCP with ISO

Also of considerable importance regarding transparency are tests results showing the presence and quantity of E. coli, Salmonella and Listeria in the establishment, from testing that is done by the government and by the establishment. Levels obtained from regular testing by governmental officials are available to field governmental officials through LEARN 10 and correlations can then be made between the results of performance standards and zero tolerance testing and what is seen on various in-plant testing in order to improve food safety, sanitation and quality.

Establishments are often reluctant, if not unwilling, to share their data obtained by their own labs with inspection personnel. This was never more apparent than in the recall of poultry products in Franconia, Pa. 11 For transparency to be effective, these test results should be available and both regulators and establishment should be open so that compliance with regulations regarding pathogen levels can be determined.

Establishments need more consistency in their application of HACCP regulations in the performance of various tasks, as there is more emphasis on those tasks that are strictly for food safety issues, i.e., 03J01 tasks, than those that are commonly known as OCP (other consumer protection) tasks, even though those tasks may point to sanitation and/or food safety issues. A revamping of the task system would put some tasks under the 03 tasks, some under pathogen reduction performance testing (the 05 tasks), some under sanitation task codes 01 and 06 and the rest could be categorized under ISO.

While there are things that are company business, when it comes to food safety and sanitary handling issues, because government officials are public servants and because records are part and parcel of food safety, performance standards, sanitation and other tasks, establishments must comply with the oversight of pertinent records.

The Need for Transparency

The necessity of transparency cannot and is not subject to debate, particularly from the standpoint of producing a safe, wholesome product. From a regulatory standpoint, transparency of both the regulatory agencies with regard to expectations from and establishments of their processes and the safety of their products is of utmost importance.

From the standpoint of international trade, transparency is necessary to comply with the standards set by the sanitary and phytosanitary standards and technical barriers to trade. Transparency is also necessary in discussions in the World Trade Organization and in the formation of trade agreements. Barriers often arise because of lack of transparency and lack of accurate use of science 12. Trade agreements seek not to have barriers, and ISO will reduce these barriers even more so, since ISO standards provide an accounting for the quality of products that enter the country from other countries, much as HACCP provides that products entering other countries are safe food products 13.

Many barriers have arisen due to confusion about how far USDA’s authority in the field extends. In terms of ensuring the safety of the national food supply, authority of the USDA has come into question in both the Supreme Beef case and the Nebraska Beef case 14-16 in which inspectors were charged with harassment for their part in trying to enforce regulations governing sanitation, as found in 9 CFR 416, as well as food safety regulations, as found in 9 CFR 417.

In both of these landmark cases, it appeared that even with the rules of practice, industry was nevertheless convinced that USDA had overstepped its bounds in not allowing the establishment to work its HACCP plan. How far regulators go in working with the establishment has a lot to do with trust and transparency between all parties. On the other hand, how far should inspectors allow an establishment to produce a product that is suspect as long as the establishment is trying to bring their process under control and some point in their system? That is a question that is still under considerable debate, even within the USDA.