GMO - and risk assessment
I'm currently reviewing our HACCP, and we want to as a site say that we are GM free (which we are, I have all the documented evidence from ingredient suppliers to say as such).
How would I address it in our decision tree...my heart tells me its Micro, but is it?
Caz x
Dear Cazyncymru -
Are you considering this based on thinking that GM products pose a health hazard or for customer and/or regulatory compliance? If not based on a health risk, I would have a separate program outside HACCP.
When processing meat in the US, we tend to try to keep the HACCP plan very clean - only discussing health-risk issues. This is because the regulatory agency (USDA FSIS) conducts periodic reviews of all regulatory-related programs and want them focused and not delving into non-regulated areas...
cazyncymru,
IMO, genetically modified organism is not necessarily chemical or microbial hazard in food. Whole food itself is a potencial concern based also in technology used...
Perhaps you could find extra info in the following file,
Codex - Food Derived From Modern Biotechnology.pdf 360.7KB 109 downloads
Rgds.
Hi Caz,
It could potentially touch upon BCA / regulatory IMHO ?. But a validated (hazard) example is obviously needed.
There is an overview here which illustrates the safety ambiguities involved –
http://en.wikipedia....ified_organisms
Seemingly specific (ie GM induced) negative BCA data does not (so far) exist.
i got totally lost after ploughing through 10-15 pages or so of the Codex document (thks Ruim) in previous post but it does seem to be totally devoid of negative data ?
I enclose a (passionately) detailed viewpoint within the (draconian?) context of USFDA regulations from 15 years back plus a current policy document from NASDA (National Association of State Departments of Agriculture).
GMO and Food safety, ca.2000.ppt 1.75MB 129 downloads
NASDA PolicyStatements_05022013.pdf 1.08MB 84 downloads
Seems the original fears have become "smoothened".
Other current official handling seems to be more of a side-step ? eg
http://www.foodsafet...nched-by-haccp/
http://www.gmoid.com.au/index.php
a few, critical, assessments of current US controls are here -
http://www.ipsnews.n...modified-foods/
http://www.examiner....t-gmos-are-safe
http://www.huffingto..._b_1551732.html
Nonetheless, Innocent until proven Guilty ?
If so, as per previous posts, I guess that leaves regulatory (GM) labelling as the only (potential) hazard. Unless you have some more in UK. Looks like a good case for a Prerequisite.
Rgds / Charles
Thank You Charles for all the information. It's good reference material
Just to give you a bit more background, we've been asked by one of our customers, how we ensure that the product we supply them is GM free. I have statements from all of our suppliers saying everything is GM free, but I need to add this to my HACCP, or my other thinking is to add it to my pre-requisite risk assessment??
My brain is pickled!
Caz x
Hi Caz,
Never been faced with this request myself. Some organisations appear to have decided that any "free" declaration is an unrealistic expectation, eg -
Unfortunately, “GMO free” and similar claims are not legally or scientifically defensible due to limitations of testing methodology.
http://www.nongmopro...nding-our-seal/
http://newhope360.co...ow-can-hurt-you
(any sampling limitation is obviously analogous to Salmonella where it tends to be ignored for most haccp purposes, accuracy is a different matter, no idea on that one)
For UK I noticed -
http://food.gov.uk/science/novel/gm/
http://www.food.gov....g/#.UmqRiHJ9gsY
I deduce UK has as yet no labelling option such as "GM-free" which is probably fortuitous.
I assume the (presumably somehow justifiable) tolerance of 0.9% is designed to avoid the zero-detection quagmire and maybe also incorporate sampling / detection capabilities. Analysis presumably at a significant cost (and maybe impossible to use in a routine way?). I suppose this would satisfy yr customers if available / affordable. An example of one procedure here -
Analysis of food sample for GMOs.pdf 342.62KB 100 downloads
The above situation would logically imply the justification in postulating a (regulatory) hazard due to unlabelled GMO material (albeit avoiding the definition of the actual hazard).
If analysis not feasible, it may appear necessary to reach an "understanding" of the interpretation of"GM-free" supplier certificates (validated how?) between you / yr customer and for any (postulated) HACCP prerequisite. Bit like allergens i suppose.
My guess is that most people opt for a prerequisite (as per allergens) and the preceding paragraph. It might be different if there are some validated GMO, UK prevalence statistics similar to the levels claimed in the upper links of this post.
I agree it's not very satisfactory from a haccp POV. On the other hand, there are some other questionable regulatory haccp CCPs in routine use already.
Rgds / Charles.C
Under SQF, GMO is considered an identity preserved food. If you are not SQF certified, you can still look up the code on the SQF website, it'll give you a basic idea of what to do to create a GMO control program and treat it as one of your pre-requisite programs. Write up procedures on how you ensure your foods are GMO free, include supplier approval, shipping requirements, how they are stored at your facility, etc. If you want your GMO PRP to be really beefy you can include a hazard analysis or risk assessment of each of your raw materials and assess them for risk level of containing GMOs. Maybe your risk is based on supplier or how often you have to do spot purchases or whatever you feel may vary in the process.
Once you have a plan in place you can add a comment in your HACCP plan that pre-requisite programs are included in the annual HACCP review.
Bottom line, treat it as it's own program.
Thank You Charles for all the information. It's good reference material
Just to give you a bit more background, we've been asked by one of our customers, how we ensure that the product we supply them is GM free. I have statements from all of our suppliers saying everything is GM free, but I need to add this to my HACCP, or my other thinking is to add it to my pre-requisite risk assessment??
My brain is pickled!
Caz x
Sounds like someone insisting GMO is in the HACCP plan is a bit too much for me & I can sympathise. Isn't a risk assessment more appropriate?
Regards,
Tony
Hi Caz,
for me GMO is not a hazard, i.e. is not part of my HACCP. Why? All GMOs are registrated and recognized as safe by authorities after a long period of examination. Food is safe. Otherwise authorities can't allow to apply GMO in food.
Of course - and this is really true in Germany - customers and consumers (> 75%) don't want to have GMO in their food. And the most people believe that GMO is a hazard.
But what is GMO-free for you by definition? In Germany we have a label "ohne Gentechnik (without genetic engineering)". What's about enzymes from bioengineered mircos? Still GMO-free?
Does anybody can provide "worldwide" labelling requirements for "GMO-free" declaration?
Rgds
moskito