Are we exempt from FSMA because we have a Seafood HACCP Plan?
Good Morning,
This is my first post however I've been reading the forums and watching the webinars here for a little while now.
My company produces products under the USDA and FDA. We several seafood products which we have a Seafood HACCP plan for but we make other products as well under the FDA that are not under Seafood HACCP.
My question that I have been struggling with for a long time is are we exempt from FSMA because we have a Seafood HACCP plan or just exempt for the seafood products but still need to meet the FSMA requirements for the other products we make under the FDA?
Thank you very much in advance for all of your time and help in this matter!
I appreciate it!
Yes, if you produce multiple products under multiple jurisdictions you need to meet the requirements for each one. So your seafood items are exempt from the preventative controls rule, however your inspectors will expect your other products to comply with the rule.
No different than having export product in your facility and needing to apply the destination nation regulations to those products and not your domestic ones, or applying FSIS regulations to meats and poultry and FDA to others.
Thank you very much Earth20. I appreciate it! That make sense to me but not everyone at the company agrees so hopefully we can all get on the same page soon!
Yes, but only the product lines/items under your Seafood HACCP Plan. With other items not under that plan you will not be exempt and you will have to comply with FSMA preventive controls rule.
In essence you will need at least two food safety plans; one for Seafood HACCP and one for FSMA. Fun stuff...
Our facility will need three food safety plans. Dairy (PMO), FSMA, Juice HACCP. Oy vey....
Thank you very much Ryan! I appreciate your response!
So, seafood is not under FSMA scope? An meat? Would it be under FSMA regulation?
Thank you both by this piece of information.. We are trying to get more information about FSMA, but FDA is having a hard (and slow) time transmitting the information and from Europe, it is even more complicated to correctly understand these important regulations.
Dear Mr Ryan!
Our company only produce seafood product. We have HACCP plan and our HACCP under FDA guide. We have FDA number. We exempt from HARPC?
Waiting information from you
Thanks and best regard
Ms Chau
So, seafood is not under FSMA scope? An meat? Would it be under FSMA regulation?
Thank you both by this piece of information.. We are trying to get more information about FSMA, but FDA is having a hard (and slow) time transmitting the information and from Europe, it is even more complicated to correctly understand these important regulations.
That's right, Maltus, Seafood, raw meat and juices are under FDA HACCP regs, not FSMA.