Should Vessels or Retailers be included in HACCP

From: SeafoodGS@aol.com
Date: Fri May 18 2001 - 07:44:16 PDT

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    > Hi,
    >
    > Should vessels or retailers be included in HACCP?
    >
    > In the following article from the May Issue of U.S. Seafood News on FDA
    Warning Letters you can see that often reports are required by inspectors as
    to how Scombroid fish were handled on the vessel so as to guard against the
    Hazard of Histamine poisioning.
    >
    > The basic emphasis of HACCP is now placed on the processor. The retailers or
    > vessel operators are not included. But when we look at Histamine and similar
    > cases investigators say that vessels should have records to show that fish
    > were handled properly and the processor receiving this fish should have
    these records or acess to them.
    >
    > What do you think? Should vessels landing higher risk products ie
    scombroid fish be required to have a HACCP plan.

    Should vessels be given a higher priority for HACCP than retailers.

    We would appreciate your views.

    Please visit our web site at www.seafoodglobalservices or request a
    complementary issue of the May Issue of U.S. Seafood News for additional
    information.

    Article Follows

    FDA Warning Letters Increase The U.S.Food and Drug Administration
    (FDA) issued 23 warnings letters to industry firms in March 2001 for not
    complying with the HACCP seafood processing regulation –bringing the total
    number of warning letters issued for the first three monthsof 2001 to 47.
    See U.S. Seafood News,vol. 9, issues 2 and 3 for information on warning
    letters issued in January and February. The Seattle FDA office was
    the leader issuing nine warning letters in March, followed by Atlanta and
    Florida who issued four each. The FDA offices in San Francisco, Dallas,
    Chicago, Baltimore, NewOrleans and New England issued one warning letter each
    in March. Following are some observations by U.S. Seafood News
    concerning the warning letters issued in March.

    -Many of the letters were issued to firms that had failed to correct
    deficiencies previously brought to theirattention by FDA. -About 25 percent
    of the firms were cited for having sanitation deficiencies, such as no
    sanitation control records and insanitary handling conditions..
    -Smoked fish received a high priority. Firms were cited for nothaving at
    lease 3.5% water phase salt content, lack of sufficient time-temperature
    controls, high storage temperatures and lack of controls for histamine..
         -Sandwich manufacturers received warning letters for not including
    allergens in their HACCP plan and for not storing tuna salad sandwiches at
    low enough temperatures to minimize pathogengrowth. -Histamine
    controls continued to receive a priority in the FDA inspections. Firms were
    cited for not taking and/or recording the internal temperature of fish at
    receiving, for not using low enough storage temperatures, for not taking into
    account transportation of the product prior to receiving and for not
    requiring vessel handling records as part of the HACCPplan. -Lack
    of specifications and/or affirmative action steps for imported products were
    noted in about 20 percentof the warning letters. In one case, an importer
    was cited for not having sufficient controls to guard against ciguatoxin in
    grouper and snapper imported from Mexico. In others the importer did not
    issue specifications for canned tuna, grouper, herring and raw shrimp.
        -Other warning letters include citations for lack of controls for sulfite
    in raw shrimp, pathogens in storageof cooked stone crabs and fried fish cakes
    and thawing vacuum packed imitationcrabmeat.
    >
    > Looking forward to your views.
    >
    > Best regards,
    >
    > Joe Slavin, Publisher



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