Problems with the HACCP verification processes in the United States
2004
Oe, T. (Norinchukin Research Inst., Tokyo (Japan))
Hazard Analysis and Critical Control Point, which considers hazards in processes as occurring in "Critical Control Points" and sets "Critical Limit" on them, is essentially risk management with close watch over production processes and quick response to emergency. HACCP was invented in the United States and was widely applied in plants as risk management after the law obligated establishments to introduce HACCP was enacted in 1996. Although HACCP is the most advanced mechanism of risk management, it still has some problems. Regarding verification, FSIS cannot react to non-compliance of a plant because of obscure rules regarding both correction itself and when corrective actions can be taken after inspector discovery. Nothing but sending a Non-compliance Record (NR) to the establishment can be done and implementing corrective actions could be delayed. Therefore, it is difficult to take urgent actions against non-compliance under the present verification system. Sometimes an inspector prefers discussing non-compliance with plant management rather than sending NRs. The FSIS verification system has another serious problem in its shortage of inspectors with adequate knowledge and experience. With inappropriate rules and light punishments, verification dose not work as properly designed. In the case of product recall, plants do not have incentives to implement recall thoroughly and recalled products are, in fact, very few because FSIS has no authority to order recall.
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