To: Joe Slavin
Should vessels or retailers be included in HACCP?
Joe, very briefly and in my opinion, I think they already are (included),
albeit not directly in the FDA regulation "Procedures for the Safe and
Sanitary Processing and Importing of Fish and Fishery Products". I like to
call it the SASS (Safe and Sanitary Seafood) regulation because it involves
more than HACCP. Remember, there are also training, and sanitation
monitoring and record keeping requirements.
Including vessels under the FDA regulation directly would be a nightmare!
Hundreds of thousands of domestic and foreign vessels which do not harvest
hazardous species would need training, consultants, records, and inspections
even though they might not need a HACCP plan . Neither the FDA nor the
industry has the resources to do it. And it would not produce safer seafood.
In fact, the accuracy of vessel records is best determined by the on-site
receiver who knows both the boat and the product.
Retail and food service establishments are generally following the 1999 FDA
Food Code administered by the states. While many states have not yet
formally adopted the voluntary Food Code, they are following it (1999) to
some extent or at least previous versions. The 1999 Food Code
(http://vm.cfsan.fda.gov/~dms/fc99-a5.html) addresses the HACCP issue as
follows:
"Food Code 1999, Annex 5 - HACCP Guidelines, 3.0 Summary
"Food processing operations at retail food establishments such as reduced
oxygen packaging and curing and smoking under the Food Code are required to
develop and implement a HACCP plan for that part of the operation.
Additionally, any establishment seeking a variance from the requirements of
the Code must submit a HACCP plan. The HACCP Annex can serve to guide these
establishments in this process."
As with fishing vessels, the FDA does not have the resources to enforce
mandatory HACCP at the retail level. And even if they did, it would have
minimal value and too many unintended consequences. As an example, prior to
publishing the current FDA SASS regulation, the FDA had apparently not
thought about the allergen issue. The tuna fish sandwich makers who get
warning letters about allergens are not getting them because the canned tuna
they use is hazardous. They get them because the bread and mayonnaise have
allergens and the FDA labeling regulations require that all the ingredients
of the bread and mayonnaise be listed - a good idea. But because they are
selling a SEAFOOD sandwich, the labeling issue is raised to the SASS HACCP
level with all the costs of training, consultants, records, and inspections
that go with it. Most of these sandwich makers are very small businesses and
can not afford training and consultants. Food Code inspections by the states
is completely adequate in most cases.
The mandatory SASS regulation was supposed to address significant safety
issues. But the unintended consequence of applying it to bread and
mayonnaise in a tuna sandwich is a waste of time and money. A more
significant hazardous situation would be the sandwich maker who mistakenly
puts a tuna label on a peanut butter and jelly sandwich. The consumer may
not be able to tell the difference and peanuts are a well known allergen
hazard!
In the preamble to the SASS regulation the FDA did a good job analyzing
whether or not to include fishing vessels, transportation firms, and retail
establishments in their mandatory rules. FDA's means of covering the hazards
associated with these industry sectors was adequate then and I believe it
remains adequate today.
For sandwich makers who may be interested, there is a generic tuna sandwich
HACCP plan at:
http://seagrant.orst.edu/sgpubs/onlinepubs/haccptunasandwich.html
Ken Hilderbrand
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: 541 867-0369
email: <ken.hilderbrand@hmsc.orst.edu>
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