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Are Tuna Salad Wraps under FDA or USDA Jurisdiction?


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#1 jcieslowski


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Posted 09 February 2018 - 06:50 PM

One of our customers wants us to make a Tuna Salad Wrap.  We make Tuna Salad now (under FDA jurisdiction) and wraps (under USDA jurisdiction) and have HACCP plans for both.


My questions are: who gets jurisdiction over a Tuna Salad Wrap and, if it's both, does it require a separate HACCP plan or can I use either my seafood HACCP or USDA HACCP?

#2 FurFarmandFork


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Posted 09 February 2018 - 08:30 PM

You're under USDA inspection. The best resource will be simply asking the inspector on-site.


Generally the sandwich question depends on the % meat of the finished product. But since tuna is not an amenable product, I think that one solidly lands in FDA territory.

QA Manager and food safety blogger in Oregon, USA.


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#3 SQFconsultant



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Posted 11 February 2018 - 05:31 AM


Warm regards,



Glenn Oster

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#4 Fishlady


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Posted 15 February 2018 - 08:54 PM

For any product in which seafood is a characterizing ingredient, you are required to comply with the US FDA Seafood HACCP Regulation (21 CFR 123).

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