Dear S.Balamurugan:
In the USA the FDA's (Food and Drug Administration) regulations "Procedures
for Safe and Sanitary Processing and Importing of Fish and Fishery Products"
can be found at:
http://vm.cfsan.fda.gov/~dms/haccp-2.html
The regulation requires that each seafood firm conduct (1) a Hazard Analysis
for each product it produces, (2) obtain training equivalent to the FDA
approved 3 day course, and (3) monitor and keep records of sanitation. It
has special requirements for importers of seafood into the USA.
The Hazard Analysis procedure is detailed in the FISH AND FISHERY PRODUCTS
HAZARDS AND CONTROLS GUIDE which can be found at:
http://vm.cfsan.fda.gov/~dms/haccp-2.html
If a Hazard Analysis does not identify any hazards "which are reasonably
likely to occur" then no CCPs (Critical Control Points) are established and
no HACCP plan is needed. However, at least once each year the seafood firm
should review their Hazard Analysis - so a plan which details how that would
be done might be considered by some to be a "HACCP plan" although the US FDA
would not define it as one. Most seafood processing firms will identify at
least one hazard in their production. A possible example of product which
might not need a HACCP plan would be the heading, gutting, and freezing of
whole fish which have no hazards identified in FDA's Hazards Guide. Many
species of sharks would fall into that group of fish.
In addition, even though a HACCP plan may not be needed, the requirements of
training and sanitation monitoring must still be met.
It is the responsibility of each seafood processing firm to train themselves
in the requirements of the "Safe and Sanitary" regulations or employ the
services of someone who is trained. Certain HACCP functions must be
implemented by a HACCP trained person.
Kenneth S. Hilderbrand Jr.
Seafood Processing Specialist
Sea Grant Extension Program
Oregon State Univ. Marine Science Center
2030 Sth Marine Science Drive
Newport, Oregon 97365-5296 USA
phone: 541 867-0242
fax: 541 867-0138
email: <ken.hilderbrand@hmsc.orst.edu>
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On
Behalf Of Balamurugan
Sent: Monday, February 05, 2001 3:56 AM
To: seafood@ucdavis.edu
Subject: HACCP without CCP
dear sir
Dear Sir,
If your are excusing me I would like to ask some basic questions.
What is CCP (critical control point) during fish processing? How to
identify it and Control that. (Ex. Whole clean Cuttlefish processing or
lobster or shrimp). Some are telling without CCP can prepare product flow
diagram because all the CCP will be controled by SSOP and GMP.
Is it possible to create a product processing flow diagram without any
critical control point during HACCP manual preparation?.please explain it.
with Regards
S.Balamurugan
Balasm@rediffmail.com
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