11 replies to this topic

[llove]

Hello All,

I am working with a distribution center that receives, stores, stages, and transport frozen /Fishseafood. Does anyone have a sample HACCP plan for such a distributor? Also, is it necessary to perform a Hazard Analysis for each type of fish product that they are bringing into the facility?

Thank you,

 

Lindsay

[FSQA]

Hello All,

I am working with a distribution center that receives, stores, stages, and transport frozen /Fishseafood. Does anyone have a sample HACCP plan for such a distributor? 

Hi Lindsay,

 

FDA has established seafood guidelines for Seafood, please look in the following link, which can help you understand the regulations:

https://www.fda.gov/.../ucm2018426.htm

 

Also, please look into the following post by one of our follow IFSQN member that defines it further:

https://www.ifsqn.co...rated/?p=100812

 

These are general Seafood guidance, however, if you are just receiving, storing and distributing seafood, your control will be only limited to Temperature control. 

I would recommend to get yourself or someone in your facility, train and certified for a Seafood HACCP certification (http://www.afdo.org/seafoodhaccp). 

 

 

Also, is it necessary to perform a Hazard Analysis for each type of fish product that they are bringing into the facility?

Yes.

[Charles.C]

Hello All,

I am working with a distribution center that receives, stores, stages, and transport frozen /Fishseafood. Does anyone have a sample HACCP plan for such a distributor? Also, is it necessary to perform a Hazard Analysis for each type of fish product that they are bringing into the facility?

Thank you,

 

Lindsay

 

Hi Lindsay,

 

The specifics may depend on whether an audit is envisaged and if so, by whom ? eg FDA, BRC, SQF etc

 

Regardless, these 2 older threads may give you some general ideas regarding haccp plans for yr kind of situation  -

 

https://www.ifsqn.co...any/#entry82622

 

https://www.ifsqn.co...age/#entry77986

[Fishlady]

Hi, Lindsay,

 

If you are going to do any re-boxing or re-labeling of the seafood, you will also need to have a Critical Control Point to make sure that the label properly declares the type of seafood by its "market name."  This is to ensure that you have correctly identified the allergen of fish or crustacean shellfish, in accordance with the Food Allergen Labeling and Consumer Protection Act (FALCPA).  It may not be obvious from reading the FDA's Hazards and Controls Guidance, but it is how the FDA interprets things.

 

I strongly suggest that you go through formal seafood HACCP training.  Cornell University offers an online course that gets you 2/3 of the way there; you will still need to do one day in person in order to get a formal certificate of training. http://seafoodhaccp....ntro/index.html  The National Oceanic and Atmospheric Administration (NOAA) Seafood Inspection Program also offers 3-day training classes https://www.fisherie...ing-&-education, or there may be training offered by local universities.

[Charles.C]

Hi, Lindsay,

 

If you are going to do any re-boxing or re-labeling of the seafood, you will also need to have a Critical Control Point to make sure that the label properly declares the type of seafood by its "market name."  This is to ensure that you have correctly identified the allergen of fish or crustacean shellfish, in accordance with the Food Allergen Labeling and Consumer Protection Act (FALCPA).  It may not be obvious from reading the FDA's Hazards and Controls Guidance, but it is how the FDA interprets things.

 

I strongly suggest that you go through formal seafood HACCP training.  Cornell University offers an online course that gets you 2/3 of the way there; you will still need to do one day in person in order to get a formal certificate of training. http://seafoodhaccp....ntro/index.html  The National Oceanic and Atmospheric Administration (NOAA) Seafood Inspection Program also offers 3-day training classes https://www.fisherie...ing-&-education, or there may be training offered by local universities.

 

Hi Fishlady,

 

I take yr points however based on previous threads, these operations seem to often be equivalent to an "in-transit"/distribution  process of frozen cartoned produce. The CCPs then IMO would tend to have a somewhat simple result as developed for what should be a haccp (fairly) low risk chain.

 

As usual, more "process" information is necessary for a detailed analysis.

[Fishlady]

Charles C,

 

You are correct that this would be a simple process.  I wanted to point out, though about relabeling because it does happen sometimes in these types of operations and FDA in that case does expect there to be a CCP to check the allergen labeling.

[dpalu]

Hi All,

 

We also have a frozen food distribution centre we wish to get HACCP certified, under Codex.

 

Our frozen and chilled foods arrive in reefers and we offload and store in temperature controlled coolrooms, freezers.

 

We've identified 2x CCPs,

 

1. Temperature upon receipt to be 4 degrees C or below for chilled, and -18 degrees C or below for frozen, 

2. Storage temperature to be the same as the above.

 

Question: Why do some distribution centre members in this forum say they have no CCPs for the same processes, stating that it's just all part of maintaining the Cold Chain?

 

Thanks for the clarification.

[Fishlady]

Hi, dpalu

For US seafood HACCP it is not likely that most frozen seafood receiving must be a CCP, as usually there is not a food safety hazard there. There certainly are quality considerations, but HACCP is limited to food safety. THere will be a control point here, but not a critical control point. For fresh fish that has potential for scombrotoxin (histamine) formation, C. Botulinum, or other potential for pathogen growth, receiving temperature is a CCP; otherwise, it may also be only a control point.

Hi All,
 
We also have a frozen food distribution centre we wish to get HACCP certified, under Codex.
 
Our frozen and chilled foods arrive in reefers and we offload and store in temperature controlled coolrooms, freezers.
 
We've identified 2x CCPs,
 
1. Temperature upon receipt to be 4 degrees C or below for chilled, and -18 degrees C or below for frozen, 
2. Storage temperature to be the same as the above.
 
Question: Why do some distribution centre members in this forum say they have no CCPs for the same processes, stating that it's just all part of maintaining the Cold Chain?
 
Thanks for the clarification.

[Charles.C]

Hi All,

 

We also have a frozen food distribution centre we wish to get HACCP certified, under Codex.

 

Our frozen and chilled foods arrive in reefers and we offload and store in temperature controlled coolrooms, freezers.

 

We've identified 2x CCPs,

 

1. Temperature upon receipt to be 4 degrees C or below for chilled, and -18 degrees C or below for frozen, 

2. Storage temperature to be the same as the above.

 

Question: Why do some distribution centre members in this forum say they have no CCPs for the same processes, stating that it's just all part of maintaining the Cold Chain?

 

Thanks for the clarification.

 

hi dpalu,

 

So many suggestions for such a seemingly simple "Process" !

 

A comprehensive  answer seems to depend on what you internally do with the received products before "outputting", if anything ?

[Agie_19]

Hi All,

 

We also have a frozen food distribution centre we wish to get HACCP certified, under Codex.

 

Our frozen and chilled foods arrive in reefers and we offload and store in temperature controlled coolrooms, freezers.

 

We've identified 2x CCPs,

 

1. Temperature upon receipt to be 4 degrees C or below for chilled, and -18 degrees C or below for frozen, 

2. Storage temperature to be the same as the above.

 

Question: Why do some distribution centre members in this forum say they have no CCPs for the same processes, stating that it's just all part of maintaining the Cold Chain?

 

Thanks for the clarification.

Hi dpalu,

 

I agree with charles, it will depend on what you internally do. Depending on the process and your current controls.

 

We are also in the same business of cold storage and base on our current process and environment, we came up of 4 CCPs which includes receiving. I suggest that you go through your hazards analysis and check the likelihood and severity of your identified hazard which is bases on your current controls. Then if it is significant, assess if it is a CCP through decision tree.

[dpalu]

Thanks Agie,

 

It is interesting to see how the FDA in the US - Florida, assessed over 100 HACCP Plans and found that about 30% of CCPs identified by frozen food distribution centres were not necessarily CCPs. These included receipt and storage.

 

Refer to link https://www.foodsafe...ood-haccp-plans.

 

It depends on your specific risks which are different from facility to facility I believe.

 

We've now cut down our CCPs to just one from three.

[Charles.C]

Thanks Agie,

 

It is interesting to see how the FDA in the US - Florida, assessed over 100 HACCP Plans and found that about 30% of CCPs identified by frozen food distribution centres were not necessarily CCPs. These included receipt and storage.

 

Refer to link https://www.foodsafe...ood-haccp-plans.

 

It depends on your specific risks which are different from facility to facility I believe.

 

We've now cut down our CCPs to just one from three.

 

Hi dpalu,

 

Thks for the interesting link.

 

Offhand, I predict various Regulatory bodies will have distinct reservations concerning some of the "hazards" categorized as "negligible elements". Possibly including USFDA.

 

Regardless, I do have partial agreement with this general comment -

 

In other words, the probability of significant food hazards occurring while in an unchanged frozen state is not reasonably foreseeable, and thus, any CCP is a negligible element.