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Shrimp Salvage Procedure for Dropped Product on Line


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#51 Charles.C

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Posted 19 April 2017 - 06:51 PM

hi Sarah,

 

As I understand, you have 3 requirements –

 

(1) a floor “sanitizer” whose residues (if any) are permitted to be in direct contact with shrimp.

(2) a fcs “sanitiser” which is approved for no rinse or approved with a rinse.

(3) a dropped shrimp rinse ‘sanitizer” which is approved for direct food contact.:

 

All of (1-3) may be associated with some kind of limit, ie X ppm

 

The complications seem to primarily arise over which Official organisation is approving what. :smile:


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#52 Seafood Safety 2008

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Posted 13 June 2017 - 08:46 PM

Hi All:
 
As far as I know shrimp processing plant is usually under FDA jurisdiction, not USDA. I found this recent FDA memo in which they did not recommend reconditioning fish and fishery products that fell on the processing floor etc..
 
Quote: "Fish and fishery products that have come in direct contact with processing floors or walkways are considered adulterated, the insanitary condition cannot be overcome through reconditioning, and the product should be diverted for a purpose other than human food".

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#53 FurFarmandFork

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Posted 13 June 2017 - 10:23 PM

Hi All:
 
As far as I know shrimp processing plant is usually under FDA jurisdiction, not USDA. I found this recent FDA memo in which they did not recommend reconditioning fish and fishery products that fell on the processing floor etc..
 
Quote: "Fish and fishery products that have come in direct contact with processing floors or walkways are considered adulterated, the insanitary condition cannot be overcome through reconditioning, and the product should be diverted for a purpose other than human food".

BUMP, thanks Seafood Safety 2008! Excellent find, I'm actually curious if this was in any way related to the OP.

 

Straight from FDA then, keep the shrimp from hitting the floor, maybe get better conveying system or "catch bins" at areas that tend to spill.


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For discussions related to food safety, production, and agriculture. Check out my blog at http://furfarmandfork.com/.

 


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#54 Charles.C

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Posted 14 June 2017 - 08:56 AM

Hi All:
 
As far as I know shrimp processing plant is usually under FDA jurisdiction, not USDA. I found this recent FDA memo in which they did not recommend reconditioning fish and fishery products that fell on the processing floor etc..
 
Quote: "Fish and fishery products that have come in direct contact with processing floors or walkways are considered adulterated, the insanitary condition cannot be overcome through reconditioning, and the product should be diverted for a purpose other than human food".

 

Hi Seafood Safety,

 

Thks for the interesting memorandum.
 

I also thought that all  USA shrimp is FDA-regulated but according to OP apparently not. Maybe a typo.

 

Product reconditioning is the reworking, relabeling, segregation, or other manipulation that brings a product into compliance with the law, whether or not for its original intended use.  Any reworking of product for this purpose must ensure the facilities and equipment to be used are sanitary and effective for the proposed process.

 

Fish and fishery products that have come in direct contact with processing floors or walkways are considered adulterated, the insanitary condition cannot be overcome through reconditioning, and the product should be diverted for a purpose other than human food.

 

It seems to me that the validity of the (FDA) 2nd quote would appear to be based on what specific criteria are required by "law" in the (CFR) 1st quote. (Also see posts 6,7, et al)

 

As above quoted, "should" surely must be "must" ?

 

Do FDA also have juridiction of floors/walkways at  Vessels, Ports, Auctions, "Suppliers"  etc. If so - Wow !!!

 

It looks like FDA may be textually supporting a change in what may (?) previously have been a more flexible approach (eg see Post 19).

 

I anticipate rumblings.

 
 


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#55 FurFarmandFork

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Posted 14 June 2017 - 02:56 PM

Charles, there's a Q&A here discussing what does and doesn't fall under FDA seafood HACCP regs, which is a pretty good line for when FDA can start taking issue with your facility or vessel: https://www.fda.gov/...d/ucm176892.htm


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#56 Charles.C

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Posted 15 June 2017 - 07:33 PM

Charles, there's a Q&A here discussing what does and doesn't fall under FDA seafood HACCP regs, which is a pretty good line for when FDA can start taking issue with your facility or vessel: https://www.fda.gov/...d/ucm176892.htm

 

Hi 3F,

 

Thanks / good searching although, despite the "updated 2016" at end of article, I fear a lot of the content is pure 1999. (the 1995 "final rule" itself is nonetheless still nominally viable afaik).

 

I did notice this -

 

A fishing vessel that catches the fish and then processes the fish in any manner (e.g., cuts steaks and/or fillets or cooks), and then sells the product at retail (i.e., to the consumer or end user) is exempt from the regulation.

 

 

Looks pretty much the same as the currently described shrimp scenario to me ?

 

Maybe there was a Nostradamus working with FDA in 1999.


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Charles.C


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