RE: HACCP (Hazard Analysis and Critical Control Points)

Roberto Verzola (rverzola@phil.gn.apc.org)
12 Nov 99 11:05:23

Roberto:
>> From the descriptions, it sounds to me as if HACCP, like the
>> California organic law, is really about small organic farm
>> elimination, wrapped in technical mumbo-jumbo...
Dale:
>It sounds to me like HACCP is mainly commonsense sanitation. This is
>important for human health and safety. Farmers who can't or won't do this,
>should produce something other than fruits and vegetables.

That was exactly my point: small farmers like single-family operations
who can't do the extremely detailed documentation or afford the
bureaucratic procedures required will be driven out of farming. I am
suggesting this could be the real purpose of that law.

Consider the process:

Analyse your entire operation from beginning to end
analyse each element in detail
establish procedures for contamination control.
Critical procedures must be precisely defined and measurable.
Implement systems of *documented* monitoring at each critical point
Develop mandatory procedures

With proper guidance, farmers would probably observe the necessary
hygienic procedures automatically. But to meet all the documentary
requirements, if you're a husband-and-wife team, you'd need
consultants, and documentors, and all kinds of bottom-feeders (as Sal
puts it).

But even when the full documentation is done, which big corporate
farms can easily afford, you're no nearer to actual hygienic
conditions. (An exploited worker, after going to the toilet, can fill
up the checklist and sign whatever has to be signed, but you are no
nearer to ensuring that he actually washed his hands, especially if he
hates the boss.) Perhaps something like a certifier will again be
needed to certify that every worker washed his hands after going to
the toilet. And a supercertifier to ensure that all the certifiers are
doing their jobs.

In a big corporate farm where workers have to be locked in (remember
that fire?), you can establish all the procedures you need to keep
certifiers busy and rich, but your product will probably be not as
healthful and hygienic as an uncertified farm run by a family which
has stuck to farming because they love the work.

Roberto

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