In order to make this education happen, industries now coming under HARPC are going to have to work with university extension programs and government agencies to develop a training support system that’s accessible to all processors, says Otwell, who is the national coordinator for the Seafood HACCP Alliance.“[Cost] should not be a hurdle. Education should be available for everybody to help this thing happen and cost should not be an impediment,” Otwell says. “If people have not accounted for educational delivery, that imposes a pretty heavy cost.”
“The Seafood HACCP Alliance is a model that everybody else is trying to follow, but we came up with it at a time when the universities were funded to do these sorts of educational things. Now things have gotten tougher. Budgets across the United States are tighter, so the delivery’s going to be a little more difficult.”
That’s why Otwell says that it’s crucial for government, universities and the industry come together to figure out an education plan for the new preventive controls.
An ever-evolving process
Despite the fact that seafood has been making friends with HACCP since FDA issued its final rule in 1995 (two years before it was implemented), the industry still faces difficulties associated with these standards.
“It continues to be a challenge for small processors as well as new processors coming into the business,” Lum says. “Sometimes it just becomes overwhelming and they just decide maybe they’ll do something else. Maybe manufacturing toys or something,” he jokes. But for those willing to get serious about HACCP, the tools are there to help them.
One key to ensuring that HACCP stays effective — and not prohibitively expensive — is flexibility in the rules, he says. While FDA’s HACCP rule says seafood processors can adjust regulations to fit their businesses if they can prove that what they’re doing is just as effective, he says many processors, especially smaller ones, lack the resources and knowledge to put together the data needed to make these changes.
For example, while HACCP requires processors to record storage temperatures every 30 minutes, for some firms, such as those in very cold climates, this might be unnecessary since years of records will show that temperatures never fluctuate that quickly. Processors need to know how to present this type of data to FDA in order to get a change in process approved, Lum explains.
Adapting the HACCP rule is something Otwell says FDA could work on, both for the benefit of inspectors and processors.
“Inspectors get put into situations where they have to make judgment calls but don’t have information,” Otwell notes. “There needs to be some way of constructive exchange so that it can be shared across the wider community.”
This is something he suggests FDA work on with other industries as it moves forward with the preventive controls rule.
Looking toward the future
Although the seafood industry will not be subject to the new HARPC rule, it continues to evolve its HACCP plan. One aspect that will be important going forward is translating HACCP into other languages so that foreign processors are on the same page, Otwell says.
New estimates have found that 90 percent of seafood consumed in the U.S is imported. Because of this, a big part of HACCP compliance now is making sure that foreign suppliers understand and incorporate these preventive controls into their food safety culture, he says.
“So if you’re going to get the training across, not only does the language have to be there, but you’ve got to be mindful of how they learn and their cultures,” Otwell points out. “And it’s different in different locations. So looking back over the past 15 years, that’s one of the lessons there from the seafood alliance that the other groups could pay attention to.”
Lum says he hopes pathogen interventions for ready-to-eat foods such as tuna and oysters will get more attention. While processes such as irradiation for oysters have been approved, they are not currently required under seafood HACCP.
“That’s really one of our focuses is this very category of minimally processed ready-to-eat foods because we believe we can build risk assessment models and put in the interventions,” Lum says.
What do other industries have to look forward to? Otwell says mandatory preventive controls help everyone get on the same page.
“One thing that was dramatic [about HACCP for seafood] – it changed the whole knowledge base and the whole language of communication. Before HACCP came along, people didn’t talk about sanitation control procedures. Now everybody can communicate and compare things. [HACCP] definitely raised attention and awareness, and if you’re aware and you get into a more preventive mode, obviously you’re going to have some impact.”
