RE: HACCP

Rebecca Kneen (rkneen@ramshorn.bc.ca)
Fri, 12 Nov 1999 18:28:06 -0800

Hi everyone -

We are in the final stages of putting together the *world's only* (so
far as we know) on-farm, certified organic microbrewery. As a "food"
producer, we come under the Canadian Food Inspection Agency - the
same people who inspect processing plants, slaughterhouses etc. HACCP
is not part of the regulations yet, but will be, and we had to draw
up a plan to answer HACCP issues. While the process was useful
(reminders about how to keep things clean), I have grave concerns
about its purpose.

Once upon a time in Canada, back when we still had Ag Reps from the
Ministry of Agriculture, we also had food inspectors. _They_ visited
farms, processing plants etc., and ensured that we were producing
safely. They understood microbiology and production processes (as
well as human limitations), and they helped us create safe and
useable workplaces. They gave us standards to meet, helped us create
safer systems, and gave the public some assurance that their food was
safe. With HACCP, all we have are pieces of paper, which say "Yeah,
we thought about it, here's what we thought, and isn't it nice."
There's no guarantee that what we put on the paper is real. With the
advent of HACCP, federal inspectors are being phased out, in favour
of a self-regulating system.

I have been calling my federal inspector, telling them how useful
they are, and that I personally don't believe that the best plans in
the world are any substitute for on-the-ground inspection. We need to
be telling the Ministry of Health and the Ministry of Agriculture, as
well as our local gov't reps, to save the food inspection system. The
last thing Canada needs is to impose the dangerous American model of
self-inspection and regulation.

On top of that, HACCP is no substitute for "touch and sniff"
inspections: all the Critical Control Points in the world won't help
if what's coming in is already contaminated - by pesticides,
herbicides or disease. HACCP does nothing to ensure that cows with
tumors are rejected by the slaughterhouse. All it does is create
mountains of paperwork and no way to verify any of it.

I am thoroughly in favour of inspectors - food and certification.
They keep us honest, keep us in touch with others in similar
situations, and alert us to places we might be getting sloppy. They
keep track of the whole system, and at their best, are an aid to
farmers and a reassurance to consumers. At their worst, they are a
hindrance and an annoyance - but not as much as having the whole
industry disappear (see Britain's beef... a friend tells me that
calves go for £1 over there now).

rebecca Kneen
===============================================
"Growing food for others is a sacred trust. The exchange of
nourishing food from the grower to the consumer should be a
sacrament, not a commodity exchange. Herein lies the
spirituality of farming." Alex McGregor, farmer
===============================================
Brian MacIsaac & Rebecca Kneen
Crannog Ales - the first farm-integrated organic brewery in the world!
S6, C38, RR#1 Sorrento BC V0E 2W0
Phone: 250-675-4122
Fax: 250-675-4866
email <rkneen@ramshorn.bc.ca>
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