I need to add my 2 cents to this question.
In an ideal world, the vessels should be included under the Seafood
Rule. As it is now, the processor or buyer becomes the regulator for the
vessels as it is the processor/buyer that must demand proper
documentation from the vessel.
Unfortunately, if the vessels were included in the seafood rule, it
would simply become one more unenforceable law. There simply aren't
enough regulators to inspect the thousands of fishing vessels.
Ron Hoelzer
Maine Food Technology Associates
SeafoodGS@aol.com wrote:
>
> > 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
This archive was generated by hypermail 2b29 : Sat May 19 2001 - 11:29:12 PDT