Prior to the development of HACCP, food manufacturers used quality control protocols relying on end-product testing. But these methods were proving inadequate to the task: testing small amounts of product simply cannot provide a high level of assurance that the entire product batch is free from contamination. To obtain a high assurance level that a large batch of product was safe, an enormous amount of end-product would have to be tested, a costly, wasteful and not necessarily useful tactic, as low level of contamination can escape detection. A better way was needed.
A real HACCP system does away with testing and instead builds food safety into the production process itself. In other words, food safety is assured by employing certain production methods that serve to kill certain identified pathogens that may be present during the production of the food.
Sperber, currently serving as Cargill's Global Ambassador for Food Protection, writes in "HACCP and Transparency, published in Food Control, that the policies implemented by Taylor, who he does not identify by name, are more legislation-based than science-based. The policies, according to Sperber, do not resemble a real HACCP approach and have been counterproductive to achieving food safety goals.[18]
Sperber writes critically of the meat and poultry rules implemented by Taylor and considered the constant reference to them as "science-based to be, simply, a false claim. Sperber observes that "the promulgation of opaque HACCP rules in the US was accompanied by another very counterproductive and troubling development " the use of the term "science-based by the rule-making regulators and by their supporting legislators and activists. Any discussion of deficiencies in this HACCP rule was deflected by claims that the rule was science-based. More broadly today, appeals to "science are commonly used to discredit even the most constructive criticism of a food safety rule or policy. Any pathogen performance standard used in the context of the Pathogen Reduction/HACCP rule is not ˜science-based.' At best it is a very poor and inappropriate use of statistics. [19]
Farm to Table HACCP " NOT
As Sperber explain in another Food Control article entitled "HACCP does not work from Farm to Table : "It is no accident that HACCP evolved at the food processing step of the Farm to Table supply chain. It is at this step that effective controls, such as cooking, drying, acidification, or refining are available to eliminate significant hazards".Safety is assured by process control, not by finished product testing. [20]
According to Sperber, the idea that HACCP can be applied from farm to table " which is all the rage among those pushing for this legislation -- is mistaken at best and deceitful at worst. He writes that "attempts to control these pathogens at the "Farm or the "Table ends of the supply chain have been disappointing because of the lack of effective control measures at these steps that are available at the food processing step. [21]
The Misbranded HACCP a Repeated Failure
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