6 replies to this topic

[CaliforniaFS]

Hello,

I'm looking into expanding our cold storage capabilities to include fish.

Frozen fish boxed.

Only for storage.

No repacking, processing. IN and OUT. A storage service.

 

Right now I have a Food Safety Certificate for Produce. I am looking for guidance for what I need for Fish. 

 

The research I've done includes Best Aquatic Practices certificates, however these are more involved for processing.

 

Thanks in advance.

[AdeSea]

You don't need anything special that I'm aware of for Frozen Fish. Fish is an allergen so storing in a segregated space is recommended. If the product is received and stored frozen then there is little concern. You should have a temperature monitoring program for the freezer. Make sure the temps are monitored daily and/or use a chart recorder. You may not need a HACCP plan either for this since the product is received, stored and shipped frozen. 

[Hilltop]

FDA regulates all sorts of fish.  Even though you only provide storage, you are still a processor according to the FDA.  They have guidance material on the website that you can help fulfill the requirements.  The good news is HACCP plans for frozen fish is not difficult to put together.

 

cheers. 

[astro]

Hi 

 

Do you have a HACCP plan for frozen fish as I would be interested to see as I have just moved jobs into storage and distribution for frozen fish etc. to Wholesale and restaurants and the more help I can get the better I will get along. The site is not BRC accredited at all...... has anybody got any ideas what standards I should follow!

 

UK by the way

 

Regards

[Charles.C]

Dear Astro,

 

i assume you mean whole raw fish.

 

Any haccp plan will require yr doing a risk assessment on the specific fish type (ie raw material species) and what happened to it prior to the arrival in cold store.

 

In frozen state (ie maintained -18degc or colder) there is usually no significant change in any existing safety hazards although non-safety quality will slowly degrade.

 

Fish standards depend on the fish/presentation/etc. Yr customer will often only too happily provide.

 

Or did you mean FS standards?, eg BRC, SQF, etc I think the first has a near monopoly in UK ?

 

Rgds / Charles.C

[Snookie]

Seafood-Fish requires a separate HACCP certification.  UC Davis and NOAA are the most common places to get it, but believe they are others. 

[bacon]

Hello,

I'm looking into expanding our cold storage capabilities to include fish.

Frozen fish boxed.

Only for storage.

No repacking, processing. IN and OUT. A storage service.

 

Right now I have a Food Safety Certificate for Produce. I am looking for guidance for what I need for Fish. 

 

The research I've done includes Best Aquatic Practices certificates, however these are more involved for processing.

 

Thanks in advance.

 

Hello CaliforniaFS,

 

Are you doing S&D (Storage & Distribution) for your enterprise (do you own the product) or are you S&D'ing it for clients?  In the latter, your potential clients will give you the lead on what type of cert you must have in order to S&D for them. In the former... same thing, the clients that you sell to will some type of cert.

 

Now, depending on your (potential) clients, the big boys are going to have greater expectations... but will be more of a payoff I am sure.

 

That aside: I haven't dealt strictly with Seafood S&D, however I do know a local Seafood frozen S&D company that has come under client pressures to get a GFSI benchmarked certification; in this case they chose BRC S&D.

 

What does this mean?  Depending on to whom you distribute for/sell to will define the type of "assurances" (i.e. - certifications) you'll be needing to provide to them.

 

As Hilltop stated, per FDA "Storage meets the definition of "processing" in the regulation. The fact that the firm handles imported product indicates than they are engaged in interstate commerce. If the firm is also the importer of the product, as defined by the regulation, it would also be responsible for meeting the importer verification requirements of the regulation... They are defined as "processors" for purposes of the regulation. See 21 CFR 123.3(l)."

 

Just because it is frozen does not preclude the product from not creating a quality issue or hazard: safety, legal or otherwise.

 

So, adhere to the FDA regs and ask your clients what commercial standards they would expect you to be certified under.

 

Chances are that they are scrambling a wee bit and may not know or even care (at this exact point in time) for S&D as the perceived "risk" is pretty low... for now... until some jacka** does not have proper Time/Temp control on their pasteurized crab, creates botulism toxin, kills an end-user and gets into the media.

 

With seafood being the largest commodity traded on the planet, and over 70% of it imported into the US, one would only expect more government (FDA) and public scrutiny in the future.

 

Hope that gives you some guidance.

 

 

Note: FSMA actually excludes “Seafood HACCP”, however, it does not protect seafood processors from FDA oversight. Some new powers the FDA has recently displayed:

• inspect any and all records where FDA believes that there is a reasonable probability of a food safety concern.
• suspended food manufacturers registrations making it illegal sell or transport food.
• invoked Administrative Detention of Foods.
• issued Mandatory Recalls.

Many food handlers are now discovering that GFSI benchmark audit requirements also cover FSMA compliance concerns (on top of legal concerns like fraud, labeling, etc).

 

So, very recently (with concerted effort), the ENTIRE supply chain is coming under scrutiny and where things break down in the complexities of global supply chain traceability. At one time it was only on the Processing level, now Storage & Distribution, Agents & Brokers, Pre-farmgate and Retail are all coming under the gun (as a proximate cause, per FSMA and the GFSI benchmarks).