I had an FDA inspection and they said because we distribute RTE tuna and seafood sandwiches and we store them for more than 24 hours in our warehouse we are considered a secondary processor and need to fall under Seafood HACCP. Im fine with that but they did not direct me to were they found this information. All I could find is this under the seafood HACCP book.
(1) Processing means, with respect to fish or fishery products: Handling, storing, preparing, heading, eviscerating, shucking, freezing,
changing into different market forms, manufacturing, preserving, packing, labeling, dockside unloading, or holding.
Whats FDA's definition for storing and holding? My company only receives prepackaged final form product and then we store the product in our warehouse and deliver to convenience stores. If we held the RTE seafood sandwiches for less then 24 hours would we still need to follow seafood HACCP?