RE: HACCP without CCP

From: Ken Hilderbrand (ken.hilderbrand@hmsc.orst.edu)
Date: Mon Feb 05 2001 - 09:41:47 PST

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    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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