Re: difference between C.A. and NUOCA records.

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Mon Sep 05 2005 - 11:27:51 PDT

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    On Mon, 5 Sep 2005, Amol Bhingarde wrote:

    > Hello Everyone!
    >
    > We are into Seafood processing. I would like to know the difference between
    > Corrective Action Records and Notice of Unusual Occurrence and Corrective
    > action Record. How exactly this records are to be maintained?
    >
    > Thank you very much in anticipation. Have a nice day!
    >
    > Regards,
    > Amol Bhingarde.

    Hi Amol and Seafood Community,

    The "Preliminary Regulatory Impact Analysis of the Proposed Regulations to
    Establish Procedures for the Safe Processing and Importing of Fish and
    Fishery Products, December 15, 1993" (pre-HACCP regulation days) mentions
    NUCOA:

    "...the proposed rule requires more extensive recordkeeping than does the
    MSSP. The proposed rule requires positive records, that is, records that
    are regularly kept at specified intervals regardless of the condition
    being observed and noted. For the most part, the MSSP requires notations
    of unusual occurrences and corrective actions (NUOCA records). These are
    negative records; that is, records are made only when there is an observed
    deviation from prescribed procedures."

    Source: http://www.cfsan.fda.gov/~djz/cfudpria.txt

    The US FDA HACCP regulation refers to corrective action records. The
    procedures on how to maintain the records are taught in the HACCP Alliance
    and USDC/NOAA-Seafood Inspection Program HACCP training courses.

    Chapter 9 of "HACCP: Hazard Analysis and Critical Control Point Training
    Curriculum" (Developed by the Seafood HACCP Alliance for Training and
    Education, 4th Edition, November 2001) goes into detail on corrective
    actions.

    Here's what the NMFS HACCP Manual says about NUOCA: "NOTE: Documenting an
    unusual occurrence and the corrective action may also be called a NUOCA
    (Notice of Unusual Occurrence and Corrective Action), a commonly used
    acronym within industry and government."

    Both the "HACCP Training Manual - Seafood HACCP Alliance" and the "NMFS
    HACCP Manual - NMFS" are on the internet and can be accessed (along with
    other HACCP resources including the Alliance's HACCP Training Manual in
    Spanish, 2nd ed.) from the Seafood Network Information Center (SeafoodNIC)
    web site at: http://seafood.ucdavis.edu/haccp/othersources.htm

    Perhaps someone who is involved with the USDC Seafood Inspection Program
    can provide further comment on NUCOA and record maintenance?

    Regards,

    Pamela Tom, Seafood HACCP List Owner
    University of California
    Sea Grant Extension Program



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