I think the people here talked about the new system and CVS, and there's an audit function in CVS, as you know. That goes back to reviewing the programs.
One thing I should take you back to is when HACCP first came in, during the late nineties. It came in because there was a requirement. If plants shipped to the U.S., they had to have a HACCP program in their plant. For that reason, a lot of emphasis was put on...and they tended to be the major players because that's who was doing a lot of the shipping. The bigger plants tended to be shipping to the U.S. There was a lot of emphasis. Big teams of people were sent to those plants by the agency to go through it. By the time it became mandatory in 2005 for the other plants...and I've always had this concern. A lot of those were the small plants, because the smaller plants didn't necessarily ship out of the country. By the time it became mandatory for them, there was more of a hands-off approach by the agency, which was saying they really didn't have the resources to spend the same amount of time with those people, that it was really up to them to write their own plan, and what have you. It was quite a different dynamic.
The base in all of this is the auditing of the written program. If there's a flaw in the written part, and I say that because the concept is that you say what you do, you do what you say, and you prove it. So your first step is to say what you do. So if there's a failure in saying what you do to indicate any of those that could be critical areas, if there's a failure, for instance, to look at the design and construction of equipment coming in and you find out there's a place inside that equipment that harbours contamination and that the juices run out of to other areas of the equipment from your clean-down, then that's a critical part. So the reviews have to be part of your HACCP plan. That's where the audit function or now the audit and the CVS functions should come in.