Re: Status of FDA's Memorandum of Understanding - importers take note

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Tue Feb 21 2006 - 21:56:40 PST

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    To: Seafood HACCP Mailing List

    After posting my February 15 comments
    (http://listproc.ucdavis.edu/archives/seafood/log0602/0014.html), I
    received a subscriber and FDA comments.

    I've compiled the information and am sharing it with you below.

    QUESTION:
    Related to MOU for shellfish, you know there is a monthly
    update ICSSL listed all the local and international companies under MOU
    for shellfish. Do you know that under what condition, companies and/or
    countries not listed can import and trade frozen shellfish in US? Is
    importing frozen scallop under that restriction?

    ANSWER:
    Yes, there is a monthly Interstate Certified Shellfish Shippers List
    There is also a listserv for the ICSSL. Information is on the US FDA web
    site at: http://www.cfsan.fda.gov/~ear/shellfis.html

    Shucked, frozen scallops do not fall under shellfish MOU's. The MOU's
    cover all other raw or live bivalve molluscan shellfish without
    distinction as to species or product form.

    There has to be HACCP controls where a hazard exists. Companies and/or
    countries not listed on the shellfish MOU will have to follow the
    verification procedures outlined in the HACCP regulation. This would fall
    under Sec. 123.12 (a)(2) - (d) of the "Special requirements for imported
    products." The regulation is at:
    http://www.cfsan.fda.gov/~lrd/searule3.html

    The US FDA has links from its web site, "Fish and Fishery Product Imports:
    Affirmative Steps, Lists of Foreign Processors Approved by their
    Governments" (http://www.cfsan.fda.gov/~frf/sfimport.html) to locations of
    lists provided by foreign government inspection authorities of processors
    of fish and fishery products that, according to those authorities, are in
    good standing and are meeting the requirements of the FDA seafood Hazard
    Analysis Critical Control Point (HACCP) regulations. The lists include:

    - Canada: Canadian Food Inspection Agency
    - Japan: Ministry of Health, Labour and Welfare, Department of Food
      Safety, Inspection and Safety Division
    - New Zealand: Ministry of Agriculture and Forestry, New Zealand
    - Thailand: Fish Inspection and Quality Control Division (FIQD)

    Information is featured on the above web site for foreign inspection
    authorities who want to submit a request to have their site (listing
    processors) linked by the US FDA.

    Pamela Tom
    University of California
    Sea Grant Extension Program

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