Dear Judith,
The National Shellfish Sanitation Program (NSSP) requires that each
individual package of fresh
or fresh frozen shucked molluscan bivalve shellfish must have permanently
recorded on the
principal display panel all information required by 21 CFR 101 and 21 CFR
161.130-161.140
(36) and the certification number of the dealer.
The Federal Food, Drug and Cosmetic Act requires that food labels provide an
accurate
statement which includes the name and address of either the manufacturer,
packer, or
distributor; the net amount of food in the package; the common or usual name
of the food; and
the ingredients, unless the product conforms to standard of identity
requirements. Foods shipped
in interstate commerce having labels that do not meet these requirements are
deemed
misbranded and in violation of Section 405 of the Food, Drug and Cosmetic
Act.
Additionally the NSSP requires that , each individual package of fresh or
fresh frozen shucked shellfish with a capacity of less than 1873 ml
(one-half gallon - 64 ounces) must have a SELL BY date; each individual
package with a capacity of 1873 ml (one-half gallon - 64 ounces) or more
must have the DATE SHUCKED. Packages of shucked shellfish containing 1873
ml (one-half gallon - 64 ounces) or more must have the certification number
and name of the packer on the side wall of the package and the date marking
on both the lid and the side wall or bottom. For packages of shucked
shellfish containing 1873 ml (one-half gallon - 64 ounces) or more, the side
wall is considered the principal display panel since the cover may not
remain an integral part of the package. The requirement for placing the
certificate number and date marking on the side wall or bottom of durable
containers holding 1873 ml (64 fluid ounces) or more is to discourage re-use
of these containers for illegal purposes.
In the example you present boxes of oysters containing 20 and 10 dozen box
of shucked oysters in 1 and 1/2 doz. tray. I assume that each 1 or ½ a
dozen trays is a consumer package with individual label to be displayed at
the refrigerated section of a supermarket. I suggest that each master
carton and individual package tray of fresh or fresh frozen shucked
shellfish have the certification number, names of the packer, a packer
address, SELL BY date, country of origin.
It is strongly recommended that complete and accurate, legible transaction
records be maintained by each certified dealer which provides all
information necessary to trace all purchases and sales of shellfish back to
their source. Receiving records must contain information that identifies
were the shellfish species, quantities received, harvest area, harvest date,
Receiving date and harvester identification number. Your shipping or sales
record should contain lot number, process dates, quantity, shipping dates,
sold to. This information assists in tracing the product back through the
distribution system to the harvest area in the event the shellfish is
associated with a disease outbreak.
In case of an outbreak of disease attributable to shellfish, it is necessary
that health departments
and other appropriate state and federal agencies are able to determine the
source of
contamination, and thereby to prevent any further outbreaks from this
source. This can be done
most effectively by following the course of a shipment, through all the
various dealers who have
handled it, back to the point of origin by means of records kept by the
shellfish dealers.
Lack of good record keeping has resulted in stymied follow-up investigations
of disease outbreaks have been, identification of the cause of the outbreak
has been delayed, and outbreaks have continued.
An example where the failure to maintain adequate records that contributed
to a series of
continuing disease outbreaks was in 1981 and 1982. The outbreaks continued
for several
months and affected thousands of people. FDA found during its inspections
that approximately
one-third or the certified dealers failed to maintain adequate records.
However, it is recognized
that no single source identity and record keeping system will be applicable
to all situations in
each state. Therefore, specific requirements should be developed by each
state and industry
member to achieve the NSSP and HACCP requirements.
As a friendly advise please be aware that there is no active Memorandum of
Understanding between Australia and the United States for the exportation of
fresh or frozen molluscan shellfish. If you ship fresh or frozen molluscan
shellfish your product may be subjected to detention or embargo and
destruction by the receiving state.
Sincerely,
Angel M. Suarez, R.S.
ruelloinc@wr.com.au wrote:
> Many thanks to the many helpful answers from the oyster experts out
> there! I was most impressed that there are so many still active in this
> dangerous industry!
>
> I now have another request. I am looking for ideas for the
> identification and traceability of bags and boxes of oysters from the
> farm to the processor through to the 20 and 10 doz box of opened oysters
> and then on to the retailer of 1 and 1/2 doz trays. I am looking for
> soemthing that is an advance on paper and pen, but does not cost the
> earth in mdoern technology.
>
> Ideally I want ot id a tray of 1/2 or 1 daz opened oysters back to the
> original farm.
>
> I look forward to your assistance, again.
>
> Regards to all oyster lovers
>
> Judith Woods
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