What’s FDA's definition for storing and holding of seafood?

Hello,

 

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.

 

k.
(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?

This is a simple HACCP plan with CCP's for receiving, storage and shipment of product. Your plan would have monitoring and verification of temperature and of course corrective actions on what to do if product is out of temperature. Check with the state requirements as well, some have temperature requirements below the FDA requirement.

This is a simple HACCP plan with CCP's for receiving, storage and shipment of product. Your plan would have monitoring and verification of temperature and of course corrective actions on what to do if product is out of temperature. Check with the state requirements as well, some have temperature requirements below the FDA requirement.

Hi ndoiken,

Thks for the input.
Do you know the answer to the specific queries in the OP ?

Hi biddlecom,

 

I myself is working in a fish processing company producing RTE LA canned tuna. I have attached the US DOHHS,PHS, and FDA's Fish and Fishery Products Hazards and Controls Guidance 4th ed. April 2011 book in pdf file (UCM251970 04242012.pdf   4.74MB   25 downloads). This book has been very useful to us in establishing our HACCP.  They have here requirements and controls here in detail per hazard. Hope this will help.

 

Thanks and Best Regards,

 

Joven 

Hi biddlecom,

 

The FDA logic looks to be summarised and referenced in attachment below.

 

I didn't delve into the minutiae but offhand it looks like any time criterion such as you refer is a lot less than 24 hours.

 

The type of control aspects involved are possibly (partially) illustrated in the example on Pg 229 of the famous reference attached in previous post.

 

retail product warehousing - transit controls.pdf   765.71KB   48 downloads

Thank you everyone for your input.

 

Charles that PDF document is perfect.  Thank you.