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HACCP — Its Application By John B. Adams The development of a national dairy preharvest food safety plan, utilizing the principles of HACCP, is a worthwhile goal for our industry to pursue. Some basic tenants need to be addressed if such an effort is to meet success. First, we must build on our current quality assurance programs. Our first efforts addressed the need to control animal drug residues. A second program has been designed to address dairy animal care. Other quality assurance initiatives are contemplated. Certainly, residue avoidance and pathogen reduction are tied to the safety as well as quality of both milk and dairy beef. Therefore, since our present quality assurance efforts have emphasized HACCP and preventative risk avoidance, wisdom dictates that we utilize existing programs to extend HACCP based controls to the area of pathogen reduction. Second, there must be established a real public health benefit that can sustain a major initiative of pathogen reduction at the preharvest level. Lack of control over animals once they leave the ownership of the producer remains a major mitigating factor in the success of any preharvest food safety strategy. Third, it goes without saying that we need more research to identify successful intervention strategies at the preharvest level if pathogen reduction can be achievable. Without further research which will identify the ecology and epidemiology of human pathogens, as they exist in the farm environment and as carried by normal healthy animals, there can be no sustainable basis for education, training or quality control directed at this issue. Fourth, assuming we are successful in developing appropriate intervention strategies, there must be some economic incentive to encourage producers to adopt new preharvest HACCP based strategies. The almighty dollar drives the universe—so how can we expect producers to be overly concerned if they are in fact marketing otherwise normal healthy animals? Can we not expect producers to believe the real critical control points lie further down the line toward the consumer, if indeed not at the consumer level!? Finally, the dairy industry can have only one program at the farm level. If we are going to develop and promote a preharvest strategy to address both human pathogens and other potential chemical adulterants, we must go to the producer level with one all-inclusive program. We will not be successful in promoting a voluntary or regulatory program if it is too complicated, overly burdensome or confusing. We must follow the "KISS" principle! We must be able to combine a preharvest food safety initiative which addresses the quality and safety of dairy beef with a similar program which addresses milk safety and quality. This particular issue can be addressed by observing the following overhead (CHART 3). Explanation How do we get started to address pathogen reduction as well as other important issues which impact the overall safety and quality of milk and dairy beef? We believe the first step will be to agree, as an industry, that we need to form a National Dairy Preharvest Food Safety Task Group (Refer to overhead—CHART 2). Let me conclude by saying that we must all realize the tremendous challenge which we face if we are to realistically address pathogen reduction at the preharvest level. It will take some very practical common sense medicine to treat the patient, if indeed we determine the patient is really sick!!!! |
