In article <[log in to unmask]>, Allen Dick
<[log in to unmask]> writes
>> 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!
 
OK then, what about this quotation from an earlier posting. Referring to
a site as 'a urinal' is not very constructive language as far as I am
concerned. (We could also have something of a culture clash here on the
use of the 'foaming at the mouth' saying.)
 
>>
You can check it out in detail and download the whole mess searching the
government sites using "nop" or start by going to this government urinal
and work back from there.' The term 'crock of organic stuff' appered
somewhere her as well.
 
>
As regards the organic issue, no-one from the mainstream organic issue
has come on line to put their point of view, and possibly none are
subscribers. This is their game, not mine. They are a minority grouping
with strong and rigid ideals, to which they are perfectly entitled, as
are you and I. I am not an organic fan and probably never will be, but
they have rights, and one of them is to specify the type and nature of
the food they want to eat, just like Jews, Moslems or anyone else. In
the UK and other countries they have been enticed to buy products
bearing 'organic' labels which were, according to their beliefs, not
organic at all. They may have been just as pure as any organic item but
that is just not the point. They are seeking a production regime which
is, for honey, unattainable in most developed countries. The goals are
not, however, unattainable globally and unless you are going to ban
imports they will be able to obtain honey meeting their requirements
from overseas.
 
You question my addressing the issues in the following quote. I only put
forward some input into a very one sided debate. I have, however no
right to expect to influence debate in your countries.
 
>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'.
>
Only the organic issue was the subject of the injudicious language.
HACCP is a seperate issue raised in a much more measured tone. I did not
say it was a bad thing, merely extracted from discussions I had
previously had with others who resented being required to implement it.
As you can gather, from an initial negative reaction I am now a convert.
Also no-one was taking the consumers part in this and it is essential to
consider balanced evidence to reach a balanced view. I also did not say
standards are bad, indeed in North America they will be among the best,
but we will all be aware that there are rogue operators in every market
from whom all good operators deserve protection.
 
I quote from your message:-
 
>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.
 
Please now read this little bit from an earlier posting of your own.
 
'If this keeps you up nights, think about this: The coming of HACCP
regulations are going to be a real problem.'
 
Possibly a fact for some, but not really a statement likely to give
anyone a 'feelgood factor' about HACCP, and could be interpreted as
contradicting your later position.
 
The arguments for and against regulation in some form or other, globally
as well as nationally, either industry or state led, are many and
require airing. Both sides need to air their views. A point was made in
one posting that I am not in the USA. Absolutely true and thus in many
ways this is not my argument and any input I make should righly be
discounted for any strictly USA affair. But as the thread emerged it was
apparent that some very polarised opinion was being voiced, and having
been through it all before here, I thought our experience could possibly
be helpful. I did not intend to offend anyone but obviously have,
although in one case I think merely to disagree is to offend.
'
>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.
 
With this I wholeheartedly agree, but to avoid it they have first to put
their own house in order. On the organic issue it will involved sitting
down with that group and reaching some kind of agreement, which is then
enforced by both parties.
>
>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).
 
If you have genuine grounds to fear this then you are quite right to
seek effective input. But don't throw out the system automatically. It
can bring benefits if sensibly applied.
 
>> 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.
 
I would have thought lawsuits would be a pretty potent fear in North
America. It certainly is for any insurer we have approached for our
North America product liability cover. I disagree with you on the safety
issue, WE must balance the two issues, which in any case I do not
consider diametrically opposed to each other. I regard them as alike
because we do not sell to large packers, we are the packer, and the
producer, and we have a trade reputation to guard and by doing properly
so we will keep our customers.
>
>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.
>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.
Escaping responsibility is merely a by product of good practice and in
no way forms any part of our primary considerations.
 
Batching practice is, as I said, entirely at the producers discretion,
and for a variety of reasons we also started it long before HACCP even
entered my vocabulary. This may be modified, and particularly with
single floral source honey which is our main business, by edicts issued
by the larger clients. HACCP will merely effectively document the good
practices being carried on in a well run business, and only require
serious changes to be made in the less well operated concern. But could
you prove your methods were good in court when confronted by a zealous
regulator and an eager lawyer? A good quality HACCP set of records can
defend you very effectively. Fortunately we both know that we are
talking about rare and highly unlikely situations here, that with luck
and good practice we will never encounter in our lifetimes.
>
>> 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.
>
Accepted
 
>Allen
 
Debate like this can be quite constructive, at least so long as it is
carried on in a civilised manner. As you can gather I have no fear of
good argument properly constructed, indeed I quite enjoy it.
 
The subject of age and experience came up.
Just for your information we operate around 1700 hives, all migratory.
We have 21 employees, of whom 12 are year round.
We pack over 75 tonnes of speciality honeys, of about 25 varieties, some
of which are only a single drum, plus a wide variety of other foods,
over 70 lines in all.
We import from 12 countries.
We export to around 20 countries, USA included.
We do all our own export procedures and documentation.
We do NOT handle organic honey.
I am 42 years old and both own and run this business.
I am 2nd generation in the business.
 
I look forward to your next posting on this with interest.
 
Kind regards
 
murray
 
 
Murray McGregor