Transparency, Part Deux

While records show compliance with product during time points throughout a shift, HACCP, SSOP and ISO records demonstrate overall compliance during both time points in the process of production. This is a much more accurate record, and one in which transparency is much more necessary in order to have a consistent and effective production.

At present, transparency is inconsistently applied, while due diligence is demanded. Recordkeeping in particular is inconsistent at best. Can the inherent problems with observing records and enforcement based on poor recordkeeping be solved combining HACCP and ISO? The answer to that is no. Just because sophisticated methods of monitoring, verification and recordkeeping have been added to the existing system, this does in no way correct the inherent problems with transparency. If any thing, before ISO is added to a HACCP system in meat and poultry industries, transparency must be insisted upon. In addition, regulators should insist on consistent application of the regulations, including enforcement, from establishment to establishment.

References:

1. Tweaking HACCP. Lydia M. Guillot, DVM. presented in completion of Special Projects class, VM 815, Appendix: Team Building.
2. www.uasep.org, Due Diligence in AEP. Due Diligence in Banking.
3. http://esf.uvm.edu/ Slides on Due Diligence
4. http://anr-ifl.vu.msu.edu/web/mod3.htm Module 3 International Food Law in the United Kingdom, Fall 2002.
5. FSIS Directive 5000.1, Enforcement of Regulatory Requirements in Establishments Subject to HACCP System Regulations. 1998, Attachment 1. (2) and (3) (i), (ii), (iii)
6. FSIS Directive 5400.5 Inspection System Activities (11/27/97).
7. 9 CFR 500.2. What circumstances call for regulatory control action; 9 CFR 500.3, When prior notification may not be necessary, even though written notification must be accomplished promptly; 9 CFR 500.4. When is prior notification necessary before taking a withholding action; Rules of Practice.
8. FSIS News and Notes and www.usda.gov/OA/news/2003/McKee012703.htm , Congressional and Public Affairs Office. Nebraska Beef, Inc. Sues USDA, 9 inspector,. Pg. 2. May 16, 2003.
9. www.cep.unep.org/pubs/ The precautionary principle.
10. www.biotech-info.net/ The precautionary principle.
11. HACCP Regulatory Process For HACCP-Based Inspection, Reference Guide, Published by USDA/FSIS Human Resource Development Staff,. January 1998.

Lydia Guillot is a veterinary medical officer/public health veterinarian with the USDA. Reach her at [email protected].