On October 10, 2003, U.S. FDA issued two regulations: 1) an interim
final rule requiring that domestic and foreign facilities that
manufacture, process, pack, or hold food for human or animal consumption
in the United States must register with FDA by December 12, 2003, and 2)
an interim final rule requiring submission to FDA of prior notice of
food, including food for animals, that is imported or offered for import
into the United States after December 12, 2003.
Information on the new U.S. FDA requirements for food exporters to the
U.S. can be found at:
http://www.cfsan.fda.gov/~furls/helpf.html
This includes information on:
1. Required food facility registration,
2. Required prior notice before shipping food to the U.S., and
3. A requirement that exporters have a U.S. agent.
Bob
Robert J. Price, Ph.D.
Emeritus Extension Specialist
University of California, Davis
616 Buchanan Street
Davis, CA 95616
Phone: 530-753-4762
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
Behalf Of Hamad Al-Kulaib
Sent: Tuesday, January 20, 2004 11:17 PM
To: Oscar do Porto; seafood@ucdavis.edu
Subject: RE: HACCP Confusion
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:- <mailto:Kuwait@alkulaibfisheries.com>
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 <mailto:Brendan.McHugh@connors.ca> McHugh (CBL)
To: 'Hamad <mailto:Hamad@alkulaibfisheries.com> Al-Kulaib' ;
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:- <mailto:Kuwait@alkulaibfisheries.com>
Kuwait@alkulaibfisheries.com
http://www.alkulaibfisheries.com/
Tel: 965 2405551/2
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