Dear Mr Porto and respected list members,
The plant I am Speaking of in Hodeidah, Yemen. We have recently
purchased it ( may 2003 ), I am not quite sure where the Committee Came from
but what I am Sure of is that it came by influence of the government in 1997
as the E.U approved Yemen for export to Europe, all the information I have
is from our quality manager who was there when they approved the plant.
Please correct me if I am wrong, But from all your valuable input my
deduction about HACCP and export to the USA is this: All that is required on
my part is to actually implement HACCP, It is the importers responsibility
to “make sure” that we are implementing it in front of the USA authorities
if requested. As for shipping documents, Each shipment is sampled and tested
( Microbology, not sure if it’s the correct word ) before being granted the
health certificate by the Ministry of fisheries. That includes every
shipment and not random shipments, new rules as of July 2003.
If I am missing something please advise,
Regards,
Hamad Al-Kulaib
VP Marketing
Al-Kulaib Fisheries Co.
Email:- Kuwait@alkulaibfisheries.com <mailto:Kuwait@alkulaibfisheries.com>
http://www.alkulaibfisheries.com/
Tel: 965 2405551/2
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
Of Oscar do Porto
Sent: Wednesday, January 21, 2004 2:10 AM
To: Brendan McHugh (CBL); 'Hamad Al-Kulaib'; seafood@ucdavis.edu
Subject: Re: HACCP Confusion
Hello all
On my view, Brendan and Hamad are adding more confussion to the matter.
In connection with Brendan commentary: In fact, formaly the US FDA and the
law are not recognising any valid third party intervention or certification.
The matter of making a bussiness related to certification promote many
confussions. The one responsible for the application of HACCP at the level
of production any where is the broker / importer in USA. If the Importer use
the service of a third party to verify the situation it's under his
responsibility.
Hamad :
a) You are not metionning who represented the "committee approving your
factory and giving you a EU code. That supose to be done by a National
Competent Authority, previously agreed by the FVO from Brussels and not
anybody else...
What's next? If you follow your plan and pass the audits regularly done by
your National C.A. you will mantain your name in the list of approved
establishments and yours products will benefit of national health
certification saying that the product was obtained under the conditions of
the regulation and will be accepted to enter the EU border. Then Next is
doing all the time what you declared and keeping records to prove it.
b) You are not metionning in which country are you or the plant to refer to,
to provide us some framework.
Regards,
Oscar do Porto
----- Original Message -----
From: Brendan McHugh (CBL) <mailto:Brendan.McHugh@connors.ca>
To: 'Hamad Al-Kulaib' <mailto:Hamad@alkulaibfisheries.com> ;
seafood@ucdavis.edu <mailto:seafood@ucdavis.edu>
Sent: Tuesday, January 20, 2004 2:29 PM
Subject: RE: HACCP Confusion
Apart from all the registration, specifications etc. documents, the HACCP
requirement is for the US based broker or customer to have one of the
importer's affirmative steps one of which is having a copy of a document
from a third party saying that your HACCP plan has been inspected and meets
the requirements of the US regulations.
(21 CFR 123.12 (ii) B or F )
It would be an interesting exercise to determine if any certification that
you get from the EU inspection could be used to satisfy the US FDA.
Can anyone advise?
Brendan McHugh
-----Original Message-----
From: Hamad Al-Kulaib [mailto:Hamad@alkulaibfisheries.com]
Sent: Saturday, January 17, 2004 11:58 AM
To: seafood@ucdavis.edu
Subject: HACCP Confusion
Dear List,
I am starting to get very confused on the requirements of
exporting Seafood to the USA. In order to export to the E.U, a committee
came to our factory, inspected and approved giving us an E.E.C code. Simple
enough, I know the steps of HACCP and that a person has to be HACCP trained
on site, HACCP team, Critical point analysis, Product flow diagrams but what
I want to know is after all this has been implemented what next? Who is the
authority figure that is connected to the fda that grants exports from a
specific factory outside the USA? Please someone explain to me the method of
exporting to USA in lamens terms. Any light on this subject would be greatly
appreciated.
Best regards,
Hamad Al-Kulaib
VP Marketing
Al-Kulaib Fisheries Co.
Email:- Kuwait@alkulaibfisheries.com <mailto:Kuwait@alkulaibfisheries.com>
http://www.alkulaibfisheries.com/
Tel: 965 2405551/2
This archive was generated by hypermail 2b29 : Tue Jan 20 2004 - 23:28:08 PST