5 replies to this topic

[ajrfrank]

We have a client who asked us to literally follow the FDA HACCP guidance but we think it is an illustrative guide and not mandatory and that HACCP team must asses the risks in our plant to determine if it is or not a CCP. we want to compare the FDA guidance with European requirements on HACCP.
Does anyone know of a guide for seafood haccp in Europe?
Does the FDA take any action if do not follow a CCP that they suggest, even if you have it covered without being a CCP?

[Charles.C]

We have a client who asked us to literally follow the FDA HACCP guidance but we think it is an illustrative guide and not mandatory and that HACCP team must asses the risks in our plant to determine if it is or not a CCP. we want to compare the FDA guidance with European requirements on HACCP.
Does anyone know of a guide for seafood haccp in Europe?
Does the FDA take any action if do not follow a CCP that they suggest, even if you have it covered without being a CCP?

Dear ajrfrank,

Sorry but i don't fully understand yr post/query.

Are you trying to compare the typical HACCP requirements if exporting seafood from El Salvador to USA and Europe respectively ?

I presume by "FDA HACCP Guidance" you mean the the US publication - "Fish and Fishery Products Hazards and Controls Guidance"? There is also a FDA official document which spells out the detailed reguirements for seafood HACCP Plans (approx 50-100pgs, from memory).

This is slightly old knowledge but AFAIK (assuming no country-to-country special agreement exists), your importer in USA is typically required to have on file (for possible vetting by FDA if required) a copy of yr HACCP plan. It makes sense if yr HACCP plan does conform to the basic US HACCP requirements (mostly similar to Codex) of the US documents quoted above but this might not always be 100% possible due, for example, yr own local regulatory requirements. Certain types of seafood also IMEX may face specific restrictions for export to USA, eg clams, scallops, etc.

For EC, I am not aware of any standard reference text as in the case of USA. There is an EC directive(s) containing a generic set of HACCP requirements for seafood imports from 3rd World countries which I guess may be yr case ?. Additionally the EC operates a system of approved suppliers based on hygiene / process / HACCP inspection by a so-called "competent authority" in each exporting country.

Rgds / Charles.C

[ajrfrank]

Yes Charles

You got my question, I meant the "Fish and Fishery Products Hazards and Controls Guidance"

By "FDA official document which spells out the detailed reguirements for seafood HACCP Plans (approx 50-100pgs, from memory)." you mean the FDA Food Safety Modernization Act (P.L. 111-353)? or which document would it be?

For EC, I knew it, there is no reference text as for the FDA, things would be a bit easier if so.
But, we already export to Europe wo problem, we r just adding the US in our export market.

[Charles.C]

By "FDA official document which spells out the detailed reguirements for seafood HACCP Plans (approx 50-100pgs, from memory)." you mean the FDA Food Safety Modernization Act (P.L. 111-353)? or which document would it be?

Dear ajrfrank,

This is the document i meant, it's quite old (1995) but AFAIK, still legally operational (haven't checked recently).

http://www.fda.gov/f...p/ucm111304.htm

A related document is of occasional help also -

http://www.fda.gov/F...P/ucm194434.htm

Rgds / Charles.C

PS - Haven't studied the FSMA document you mention yet.

[KTD]

Dear ajrfrank -

FDA is quite proud of their seafood HACCP guide. Unlike other guidances (USDA FSIS and FDA), where the idea is you can do what you can technical and/or scientifically support, FDA does appear to treat the seafood guidance as pretty accurate. To avoid import/export issues with the US, I would follow the guidance closely, unless you have substantial support to the contrary...

[ajrfrank]

Do you think it would be a valid option to avoid import/export issues with the US to have a HACCP Plan for US products and another HACCP Plan for Central American and European Products?