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USDA inspection - is a seafood HACCP certificate required?


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#1 sarah2014

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Posted 10 April 2017 - 12:09 PM

Hi all,

 

I work as a  Food Safety /HACCP coordinator for a seafood company, we had  USDA inspection last week, the inspector told me that I need to have a seafood Haccp certificate not only a HACCP certificate  , she told me is a FDA requirement is that true ??. I been in the business for 2 years we are BRC Certified I never had any issue in the past.  

 

Please advise

Thank you


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#2 Scampi

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Posted 10 April 2017 - 01:28 PM

Perhaps this is helpful---it would appear the inspector is partly correct------who is supposed to issue the certificate?

 

 

 

/www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfCFR/CFRSearch.cfm?fr=123.6


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#3 FurFarmandFork

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Posted 10 April 2017 - 01:44 PM

The CFR States:

 

PART 123 -- FISH AND FISHERY PRODUCTS

Subpart A--General Provisions

Sec. 123.10 Training.

At a minimum, the following functions shall be performed by an individual who has successfully completed training in the application of HACCP principles to fish and fishery product processing at least equivalent to that received under standardized curriculum recognized as adequate by the U.S. Food and Drug Administration or who is otherwise qualified through job experience to perform these functions. Job experience will qualify an individual to perform these functions if it has provided knowledge at least equivalent to that provided through the standardized curriculum.

(a) Developing a HACCP plan, which could include adapting a model or generic-type HACCP plan, that is appropriate for a specific processor, in order to meet the requirements of 123.6(b);

(b) Reassessing and modifying the HACCP plan in accordance with the corrective action procedures specified in 123.7©(5), the HACCP plan in accordance with the verification activities specified in 123.8(a)(1), and the hazard analysis in accordance with the verification activities specified in 123.8©; and

© Performing the record review required by 123.8(a)(3); The trained individual need not be an employee of the processor.

 

 

So yes, your USDA inspector was correct, your HACCP training needs to include curriculum specific to the seafood haccp regulation. Guidance available here: https://www.fda.gov/...176892.htm#viii


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#4 Charles.C

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Posted 11 April 2017 - 01:10 AM

Hi,

 

As a non-USA person I'm confused. I thought seafood production was under sole jurisdiction of USFDA ?

 

3 x USDA are typos ?


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Charles.C


#5 sarah2014

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Posted 11 April 2017 - 07:37 PM

Florida department of agriculture and consumer services


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#6 sarah2014

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Posted 11 April 2017 - 07:38 PM

thank you. I am going to look for an online seafood HACCP training  


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#7 Charles.C

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Posted 11 April 2017 - 09:42 PM

Florida department of agriculture and consumer services

 

Hi Sarah,

 

Thanks but TBH I'm not sure what that means. I assume it's a State level jurisdiction. I believe USDA/USFDA are Federal level. But (fully) open to correction.

I believe agriculture at Federal level = USDA jurisdiction

I had believed seafood at Federal Level = USFDA jurisdiction

:uhm:


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#8 FurFarmandFork

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Posted 11 April 2017 - 10:15 PM

Hi Sarah,

 

Thanks but TBH I'm not sure what that means. I assume it's a State level jurisdiction. I believe USDA/USFDA are Federal level. But (fully) open to correction.

I believe agriculture at Federal level = USDA jurisdiction

I had believed seafood at Federal Level = USFDA jurisdiction

:uhm:

Charles, you're correct. USDA/FSIS only inspects federal facilities for meat/poultry items, egg products, and catfish. I assumed this operation had a catfish line and therefore got inspected by USDA.

 

It gets extra confusing because for certain inspection tasks. FDA contracts out the majority of their inspections to state departments of agriculture (who oftentimes end up citing state regulations because they don't know any better >_<), and for facilities with USDA inspected products but only performing business within the state, you may also have USDA representation from your state department.

 

FURTHER *breathes in*, the Agricultural Marketing Service (AMS) who is underneath USDA and therefore represents themselves that way, do inspections for various dairy products that are FDA products but receive AMS sanitary inspections (like spray dried cheeses  and milks) and therefore get "usda" into your plant even without amenable products.

 

It sounds like in this case sarah2014 or their inspector may have misspoke, as it doesn't seem like USDA had any reason to be there (unless in an AMS capacity or an Agricultural capacity). Was the state level department of agriculture.

 

...


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#9 Charles.C

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Posted 12 April 2017 - 03:10 AM

Hi 3F,

 

Thanks for the info. Quite a spider's web of entwined activities

.

Actually, based on a parallel thread, the seafood involved was probably shrimp, just to insert another twist.

 

I guess the Florida Dept of Agriculture & Consumer Services might be doing a little "moonlighting". :smile:

 

A few USFDA classics here -

 

https://www.fda.gov/.../ucm2006764.htm
 


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Charles.C





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