Dear Mr. Hamad Al-Kulaib:
Related to your question about HACCP & seafood´s export to the USA and the Plant manager duties, I wish to make the following comments:
1. You should have in place proper GMP related to building, equipment and personnel hygiene practices.
2. You should perform the SSOP in a daily basis and the sanitation controls may be included in the HACCP Plan (US FDA Final Rule, Sec.123(b)). The daily SSOP records are mandatory.
3. You should implement the HACCP Plan in according to the US FDA Final Rule requirements.
4. Allways the HACCP Plan is under your Company´s responsibility.
5. The US importer should have your HACCP Plan on file for the eventual requirement from the FDA personnel; if your seafoods have a Recall situation, the HACCP & SSOP mandatory records should be claimed by your US importer.
6. The US importer is the link between your Factory and the US FDA.
7. Your seafoods sampling, microbiological & chemical testing and results could be a part of your HACCP Plan Verification procedures (Sec.123.8) .
8. The Health Certificate issued by your Ministry of Fisheries is a local requirement to export.
9. Your Fishery Plant (country) could be visit by the US FDA personnel.
Sapced out you may consider the voluntary Fishery Plant Biosecurity Rules and more information is available at: www.fsis.usda.gov/OA/topics/security guide_sp.htm
Finally, I compete agree with Bob Price´s opinion about the new FDA requirements for food exporters to the US.
Best Regards,
Enrique Bertullo
Estate University of Uruguay
www.pes.fvet.edu.uy
----- Original Message -----
From: Hamad Al-Kulaib
To: Oscar do Porto ; seafood@ucdavis.edu
Sent: Tuesday, January 20, 2004 11:16 PM
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:- 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)
To: 'Hamad 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:- Kuwait@alkulaibfisheries.com
http://www.alkulaibfisheries.com/
Tel: 965 2405551/2
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