> Whilst some good stuff has been written, some has also come from people
> who you can almost visualise 'foaming at the mouth' as they have written
> it.
 
And here I thought I had a good imagination.  Try and try as I might, I
cannot visualize even a tiny bit of slobber on the chins of my BEE-L
friends.  I did notice more than a little earnestness and anxiety in
their words, but foam?  Come now!   Once again we remember that this is an
international list and that different cultures and social groups have
different ways and different fears.  Anyone who forgets that gets a giggle
or two from the crowd. FWIW I vote you two giggles (minimum). <G> And me
(shame) one--for responding to your troll.
 
When I sat down to write this I expected to be addressing some
substantive points, given the length and tone of your original post.
However, other than showing you are comfortable with the current level of
regulation in your jurisdiction, detailing a voluntary HACCP compliance
situation and discussing batch sizes, I can't see how you are addressing
the issues that concern the 'foamers'.
 
Many are less sanguine about governments and their agendas and demand
something of real value for each and every expenditure of legislative
power and taxpayer money.  They seem to believe that there should actually
be a good and valid reason for each and every law and that the law or
regulation should be reasonable and legislators ought to consider all the
circumstances in which such rules might be applied.  Moreover they are
aware that the presence of any regulation *implies* certain things and
leads to assumptions and possible further action, and they are thus biased
towards minimum government regulation and taxation.
 
Not surprisingly, it turns out that most of the people writing on the
topic have quite a bit of exposure to government regulation both in
writing and enforcing rules--as well as being on the receiving end of
regulation and enforcement.   Some are or have been government people and
others are or have been directors of state or national bee associations
-- and it is not surprising that there is a high level of apprehension
shown when new legislation is contemplated. (If we have to show our
credentials here, FWIW, I have served at some time in each of the above
roles over the last quarter century).
 
Unofficially, in my own daily life, I personally I just say, "Thank
heavens we don't get *half* the government we pay for" and hope if I shut
up and keep my head down that the shadow will pass me by and find another
more interesting project.  Thankfully though there are those who take up
the cause and challenge every new encroachment by governments on personal
liberty.  If not for them we would still be serfs (most of us anyhow).
 
When a large and powerful forces like coalitions of international
governments start to focus on one's livelihood and beaureaucrats begin to
think they know more about one's business than the proprietor,  and one
has read even a little history, one would be nuts not to get a bit edgy.
That is of course unless one is very young and naive--or one believes we
are in a whole new age and that the experiences of the past no longer
obtain.  Santayana had some good thoughts on that several "whole new
eras" ago.
 
> Take your beekeepers hat off for a moment and put on your consumers hat.
> You will want the foods you buy to have been produced in correct
> conditions, and that the claims on the label are accurate and true.
> Anything which assists in ensuring this is normally helpful to you, the
> consumer, although it may, at least superficially, be unhelpful to you,
> the producer.
 
What is the point of ignoring the position of other writers then arguing
at length with yourself?  Who is wearing a beekeepers hat?  Maybe a
straw man?  Just to set the record straight *no one* said that standards
are bad or that food should not be produced under correct conditions and
labelled correctly.  No one said HACCP is a bad thing.  No one but you.
 
However, quite a few thought that having ridiculous and unattainable
definitions enshined in US government law or regulations was likely to
haunt beekeepers worldwide in the long run.  Moreover, some of us are
concerned that governmental actions could escalate our costs or make our
normal practices impossible by sweeping us in with other larger groups of
producers that run more standardized and easily understood operations.
 
I personally expressed some concern that the HACCP program as it
may come to be applied or interpreted in Canada and other countries
*under force of law* may have some abuses--given the unusual nature of
beekeeping and honey.  Our inspectors here would love to handle all
packing houses the same and apply meat and milk rules to honey--just for
one example. In this particular government assualt,  I personally had
the dubious pleasure of being the Little Dutch Boy with his finger in the
dyke (the coffer dam variety).
 
> Which neatly brings us round to food safety.
 
I thought that this was what the whole matter was about--mistaking
government edict with food safety.
 
> One way of doing this is by ensuring that the producer has in place a
> correct and auditable system of ensuring product safety. Such a system,
> and there are much worse which could have been imposed, is HACCP
> (Hazard Analysis Critical Control Points)...
 
There is no question that HACCP is a good idea.  Most of us know what it
is and most of us have been following the principles behind it all along.
We care about our customers and we care about ourselves.  The whole
question here is how it will eventually be enforced and to what extent
government will be involved.
 
> It is wise to break you batch size down to as low as is reasonably
> achievable... The batch in question may need to be condemned, so the
> smaller it is the better protected you are.
 
Now this is an interesting argument.  But it may be exactly and
diametrically wrong--if we are talking *food safety* which was mentioned a
few lines up as being the topic.  If we are considering only lawsuits,
then perhaps your argument has merit.  FWIW, It has often been argued that
one reason for the improvement in public nutrition and health in this era
is the fact that our diet comes from *a very large sample* of the foods
and sources available, diluting any possible buildup of poisons and
nutritional deficiencies that might be found in any subsample.
 
Anyhow, let's consider:
 
Case one:  A contaminant is introduced at *one* of many hive locations in
modest levels. If you have small batches, this will appear as a relatively
high level contamination in the one small batch -- assuming anyone can
afford to run exhaustive tests on every small batch.   Likely not, so
unless the small batch is combined with others in packing, any consumer
gets a concentrated hit of the unsuspected contaminant.  If large batches
are used, the contaminant is diluted and overall level and with some
probability may even be below detection and harmful levels...  *but* then
again there is also more incentive to carefully test a larger batch...
 
Case two: A contaminant is introduced at one hive location in *high*
levels. If you have small batches, this will appear as a *very* high level
contamination in one batch and be caught there -- again assuming anyone
can afford to run exhaustive tests on every small batch.  Any consumer
eating from only such a small batch is vulnerable.  If large batches are
used, the level may or may not be detectable and thus the whole large
batch condemned if it is. ...  *but* then again there is also more
incentive to test a larger batch...
 
Case Three:  Contamination occurs over the whole range of the bee
operation.  It will not matter how big batches are.
 
What, interestingly enough, comes out of this is that unless foods are
all tested comprehensively, you are at highest immediate risk
when consuming untested honey from a small sample such as the honey from a
single beehive.
 
> What a tragedy it would be to be lazy about batching and just call your
> whole years production one batch to find that there was something wrong
> with some of it. It is almost an insurance policy and can result in
> lower product liability insurance premiums.
 
This is precisely the advantage, the escaping of responsibility, not food
safety.  No matter if a little batch of your product destroys a huge batch
at the packer's,  your insurance company is on the hook and (hopefully)
the rest of your crop is clear once tested.  Cynical, but wise.  I
certainly practice this batching myself.  And without HACCP.
 
> Someone also mentioned restrictions imposed by the EU causing a lack of
> flexibility on behalf of honey packers.
 
Hmmm.  That must have been me, but I wasn't alking about honey at all.  I
was talking about paint sprayer parts even though I did not say so.  My
friend referred, I think to CIS as being the culprit, atho' I did not say
so since I was only half listening and wasn't sure.  The part I was sure
about was his being sad at having to drop a good supplier who was bound
up in governmental red tape.
 
Allen