106 Handbook of herbs and spices
Traceability
Traceability is driven by many factors; some of the key ones are consumer confidence
in the product, product credibility and market access, protection from brand fraud
and adulterants, supply chain management, quality factors and the insurance system.
Full traceability requires that producers are responsible for their product one level
down from their operation and one level up, or one-step preceeding and one-step
after. They need to know what they are buying or collecting, what goes into the
production of it or the history of the land where the product is grown and where the
product goes. Good record keeping is imperative to ensure this. Canadian Herb,
Spice and Natural Health Product Coalition HACCP based GAPs were developed
incorporating the CanTrace Standards for Traceability.
Auditing
The HACCP system developed for on-farm use is an auditable system. An audited
system ensures traceability to the buyers. Producers must provide validation, either
by third party or self-attestation ensuring that they can trace backwards at any stage
and ensuring that all questions are able to be answered and documentation is in place
to back this up. In a recall situation producers need to be able to isolate the problem
if they are to prove it was not their product. If it is the producer’s problem this system
should be able to address the issue and enable them to fix the problem in a fast,
effective and safe manner. A paper trail must be developed for an auditor, with farm
maps, field history, input records, harvest and post-harvest records, storage data and
sales information to confirm all processes and due diligence. Auditing is also a tool
to ensure that producers are up to date and aware of regulations or changes to
regulations that affect their operation. Auditing confirms that all processes are under
control and that the producer/collector is providing a food or medicinal product that
is safe and free from biological, chemical or physical contaminants.
Levels of GAPs
A GAP level relates to the significance of its impact in any given operation. The
GAPs developed for this program fall into one of two levels; either ‘must-do’ GAPs
or ‘recommended practices’. A ‘must-do’ practice is relevant to all operations and has
to be addressed. Any deviation from a ‘must-do’ practice must be recorded, explained
and witnessed. ‘Recommended practices’ may be relevant to one operation and not to
another. A risk assessment of the operation is vital to determine which practices
should be implemented on a must-do basis and which are recommended to enhance
the operation in ensuring quality, safety and traceability.
Critical limits and acceptable levels
A HACCP model identifies two things.
- Points in the operation that have a critical impact on food safety (a critical
control point) that can only be addressed through avoidance.
- Points in the operation that recognize levels of food safety and that can be
addressed through compliance with a designated procedure. These levels can be
‘critical’ or ‘acceptable’.In the CHSNC model they have not identified a critical control point but they have
identified critical limits and acceptable levels.
Critical limits are defined as criteria that separate acceptable from unacceptable
risks in relation to food safety. Critical limits are benchmarks for performance of the