Are Tuna Salad Wraps under FDA or USDA Jurisdiction?

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?

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.

FDA

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).