by Bryan Salvage
Shortly after the mailing of the March issue of Meat Marketing & Technology, a small packer from Pennsylvania called me distraught with emotion.
"I just got your March issue," he said. "Do you know what this [estimated cost to implement HACCP] means? It's going to put me and a lot of my competitors out of business. What can I do?"
He was referring to the information contained within the March cover story on USDA's proposed inspection reform initiative, "Pathogen Reduction: Hazard Analysis and Critical Control Point System."
USDA estimates the cost for small processors (which it considers $2.5 million or less in annual sales) to implement HACCP over a three-year period is $157.6 million. The total estimated cost to implement the near-term initiatives is about $173 million.
Many packers and processors (particularly the smaller ones) are concerned about what affect this proposed rule will have on their businesses.
After encouraging the distraught packer to respond to USDA directly on its proposal by the June 5 comment period deadline, I suggested that he also touch base with similar-sized packers so they could address this proposed rule as one group.
Smaller companies will make more of an impact addressing this proposal by speaking through one, unified voice. Next, I suggested he contact his state meat industry association and the American Association of Meat Processors to see what they could suggest or do.
Billy on HACCP
Thomas Billy, FSIS associate administrator, recently met with me while in Chicago. I mentioned to him that in addition to affording the costs involved in creating and maintaining a HACCP-based program, developing a formal HACCP plan could be overwhelming for some smaller processors.
What advice did he have?
"Begin by doing some reading," Billy suggested. "There's a myriad of articles available written in laymen's terms. Develop a basic understanding of what [HACCP] means, the philosophy behind it, and how it can be applied to food.
"Then I would take some training," he added. "There are short courses under development for executives, as well as more intensive courses that are two to four days in duration.
"Finally, get your feet wet; get started," he noted. "Voluntarily get started in HACCP and apply it to one part of your operation to develop an experience base on how it works. There is no reason to wait for the time when the federal government says you must have it in place."
Billy said the proposal acknowledges that implementing HACCP will be a bigger challenge for small firms.
"We've provided them with the longest time frame before they have to have HACCP in place-three years after the final rule is published."
Billy said he hopes the final rule is published by the end of 1995. Model plans for each sector of the meat industry will be included in the proposal.
"These plans will be a guide for [smaller companies] to get a basic understanding of HACCP so they can lay out HACCP programs for their particular operations," Billy pointed out.
During the stage when companies are identifying critical control points, FSIS will be available to review this important step for packers and processors to make sure they're on the right track.
"If they get on the right track at that point, much of the rest of laying out this HACCP plan falls into place," Billy said. "This direct assistance of small firms will be of great help to them."
The bottom line? Study and respond to this proposal. If possible, attend the public hearing on the proposal set for May 30 and 31 at Georgetown University Conference Center, 3800 Reservoir Road, NW, Washington, DC 20007, 202/687-3200.