On Fri, 24 Jan 2003, Ray Swanson wrote:
> 1/24/03 Hi Pam ; I am considering importing fresh whole fish from Mexico
> , like re snapper . Do you if it need to come from a HACCP plant or
> could you direct me to a source that can help me . Thanks , Ray
Ray, the short answer to your inquiry is that whoever receives the
shipment first ("first receiver"), i.e., the processor, needs to conduct a
hazards analysis on both the product and the process. So, if the product
is coming in fresh whole with no processing, a hazard analysis still needs
to be conducted on the product. And if the product has hazards
identified, a HACCP plan is required.
Reminder: The Seafood HACCP Regulation is species and process specific
for each product in your operation.
If you are the "second receiver" (importers fall into this category), you
fall under the Seafood HACCP regulation and you have to verify that the
"first receiver" complied with the Seafood HACCP Regulation. The
Regulation provides 6 importer verification (affirmative steps) options.
Further details on the above are on the Internet:
http://www.cfsan.fda.gov/~lrd/searule3.html (HACCP Regulation)
Sec. 123.3 Definitions.(g)
Sec. 123.6 Hazard Analysis and Hazard Analysis Critical Control Point
(HACCP) Plan. (a)
Sec. 123.12 Special requirements for imported products. (a)(2)(ii)
http://vm.cfsan.fda.gov/~dms/qa2haccp.html (HACCP REGULATION FOR FISH AND
FISHERY PRODUCTSQUESTIONS AND ANSWERS for guidance to facilitate the
implementation of a HACCP system in seafood processing.)
To help you identify species and process related hazards, refer to the
FDA's "Hazards Guide:"
http://www.cfsan.fda.gov/~comm/haccp4c1.html (Potential Species-Related &
Process-Related Hazards, Table 3-1, Potential Vertebrate Species Related
Hazards. Note: there are some Snapper species with identified hazards in
the Guide.)
Pamela Tom, California Sea Grant Extension Program
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