Sunday, March 6, 2011

You can lead a horse to water, but you can't make her drink

Another saying from my childhood, translated from the original Yorkshire dialect into English!

What triggered this?  Well, HACCP (Hazard Analysis and Critical Control Points) has been around since 1959, when NASA attempted to ensure that food fed to astronauts would not make them ill, or cause injury.  The possibility of early astronauts, trapped in orbit and vomiting into their helmets, could not be contemplated.  Originally developed as a microbiological safety programme by the US Natick laboratory and later by The Pillsbury Company, the Modes of Failure programme eventually covered all aspects of astronaut food, not just microbiological hazards.  By 1971, the HACCP system was published and documented in the USA and by 1985, the National Academy of Science recommended the use of the system. Incidentally, I began teaching HACCP to food technology undergraduates in New Zealand in 1978.

Recently, Roy Costa posted an article on Food Safety and Environmental Health Blog:
in which he pointed out that retailers demand food safety management systems from suppliers.  The end of the supply chain - institutions and food service organisations - are also required to have HACCP-based food safety plans in place, but schools seem to have dropped beneath the regulatory radar: few have implemented the requirements and they are not being pursued by the local health departments.  Costa suggests that this is because the schools and health departments are both part of the counties, which claim that this is an unfunded Federal Government mandate. 

Politics aside, this problem of lack of implementation of HACCP-based food safety plans is not restricted to schools and food service outlets.

Some years ago, I wrote an HACCP-based food safety programme for a local food manufacturer.  This is not something I will do again; as a consultant, I was an outsider and though I had a close familiarity with the factory, I don't think that the production manager wanted to do more than "tick the box" that they had a programme.

About a year after I wrote the programme, one of my students got a job at the factory.  "What do you think of the HACCP programme?" I asked.  "What programme?" he replied, "I never saw it".  The next time I visited the factory, I mentioned this to the manager.  He said "Oh, I'm sure it's around somewhere, probably on the shelf in my office".

So, after that roundabout story, we come back to the title of this posting.  The factory complied with the regulations - it had an HACCP-based food safety programme, so any auditor could be shown the document.  But just having a nicely bound document on the shelf is only the beginning.  The plan must actually be implemented in the factory and reviewed on a regular basis.  This manager wasn't even sure where it was, his staff didn't know of its existence and there is no doubt in my mind that he never reviewed it.

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