Dear All,
Came across a recent article presenting a personal appraisal of the origins of HACCP writtten by one of the people closely involved.
Doesn’t give prescriptive answers but it does address a lot of practical questions.
The formatting makes the reading a bit laborious but still highly recommended IMO .
http://foodsafetymag...?...13&sub=sub1
Hv extracted two small chunks as examples -
We needed communications between those skilled in interfacing with state and federal agencies and staff performing hazard analyses such that mutually agreed upon conclusions could be achieved, frequently involving R&D scientists, engineering, legal, and quality assurance staff. What does “safe” mean? Is it an absolute or statistical outcome? How should we interpret the Delaney Clause that required zero tolerance of a carcinogen? Many ingredients are acceptable within tolerances established by regulatory agencies. Is there a difference between saying something is safe versus “safe for all practical purposes.” Can we control infestation of spices with radiation? How do we ensure that the assurance of a package supplier was adequate to protect against PCBs? What tests do we need to do on incoming ingredients and packaging materials? But there was agreement on our general objective: safe products.
The major operating change was that if anybody came across a safety incident, potential or in progress, they had the authority and absolute requirement to stop everything. The line or plant would shut down and the problem would be fixed. It became known as the “bell ringing” requirement. Now, when safety information was encountered the action occurred at the site immediately, and the process of deciding what to do next could be evaluated by relevant managers according to the degree of risk while the product was being held. The process of communication took minutes, not days. But what would make a person make the correct judgment? Could line workers be trusted? If the criteria for a safety incident remained simply a legal and regulatory requirement and responses were based on statistical probabilities with traditional cost/benefit analyses, the system would fail. It would be okay for lines of thought such as: “It was only one piece of metal, what is the likelihood that a consumer will eat it? It was small, if they didn’t bite into it they’ll simply pass it through in their feces.” Or, “Anyway, the government has allowable levels of microbes, rodent pellets and hair, why not allowable levels of glass and metal? If we avoid the recall, the dollar risk is low.” This kind of discussion becomes an analytical and regulatory one that, as in all legal matters, becomes a matter of due process. It would not inspire the line operator, nor convince him that his bell-ringing action was truly endorsed by management. It had to become an ethical issue. Each employee simply had to believe and commit to the absolute requirements that our products will be safe, and that no consumer would be injured by the use of our products when used in accordance with our preparation instructions. Everybody in the company had to believe it, say it, and do it—from the CEO to the plant sweeper. The ethics of caring and commitment had to be translated into specific action if anything occurred that triggered it. And it worked.
Regards / Charles.C
