112. The Delegation of the Netherlands introduced the document and pointed out that the discussion of the paper during the 3lst Session of the Committee indicated substantial interest in its content, but some fundamental issues were not solved. Therefore WHO in cooperation with the Government of the Netherlands had convened a Consultation on Strategies for Implementing HACCP in Small and/or Less Developed Businesses in June 1999 to:
113. The Delegation indicated that SLDBs were defined as “businesses that because of their size, lack of technical expertise, economic resources, or the nature of their work, encountered difficulties in implementing HACCP in their food businesses” and that the term “less developed business” referred to the status of the food safety management system and not to the number of staff or volume of the production. The Consultation addressed the implementation of HACCP in SLDBs in developed and developing countries. The Delegation also noted that the revised document was mainly based on the recommendations of that Consultation, however the guidance of the Committee was sought regarding the type of document being developed, the need for sector specific guides, the application of sector specific templates, and generic HACCP plans.
114. Many delegations complimented the Delegation of the Netherlands for the revision of the discussion paper and indicated that it contained valuable and practical information on the implementation of HACCP, which would certainly assist governments and businesses in their work with HACCP. Some delegations stressed the need to continue working on the document but noted that before putting it into the Step Procedure it should be more clearly focused on providing practical guidance. Some delegations were of the opinion that it was preferable to elaborate additional guidance for SLDBs as an Annex to the existing Codex Guidelines on HACCP while others pointed out that the original intention was to develop a separate document. The Delegation of Germany drew the attention of the Committee to the title of the document which should refer to “application” as the content was mainly oriented to that aspect, rather than to “implementation”.
115. The Observer from IDF indicated that some small dairies could not fully apply the HACCP system and opposed generic HACCP plans that could lead to misuse of the guidelines.
116. Some delegations supported the view that prerequisite programmes were necessary for the successful application of HACCP and this should be stated in the Guidelines. The Delegation of the United States opposed this proposal and the revision of the HACCP Guidelines since it would alter the Concept of HACCP. The Delegation expressed concern about the use of generic HACCP plans and the use of third parties for international recognition and further noted that there should be no fundamental difference in HACCP, whether applied to small, medium, or large businesses.
117. The Committee agreed that the Delegation of the Netherlands with the assistance of their drafting partners should prepare a discussion paper to identify issues involved in elaborating appropriate guidance on the application of HACCP principles by SLDBs for consideration by the next Session of the Committee. The document therefore should be maintained at the stage of Discussion Paper.
