I find that this is'nt necessary taking into account that industry has been following HACCP for many years now and if they don't have a program that's working they are no longer in business. In addition to this fact in order to really prove that you are reducing pathoghens to levels acceptable you would nave to introduce pathogens to your product and run the risk of contaminating your facility in so doing.
Comment from Gerald Boullion
This is comment on Proposed Rule
Hazard Analysis Critical Control Point Systems Validation
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