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CCPs for receiving refrigerated fish

HACCP CCPs Fish Seafood Critical Control Points

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swarren

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Posted 17 September 2021 - 02:17 PM

Hi everyone,

 

I work at a distribution center for a variety of food products. Most of the seafood products we receive are frozen. However, we may receive some refrigerated smoked fish, marinated anchovies, and anchovies in olive oil. If we receive and store these refrigerated, do the receiving and storage temperatures need to be considered CCPs in our HACCP Plan?

 

Thanks in advance for your help.



Scampi

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Posted 17 September 2021 - 02:58 PM

you're implying you believe this products could be stored out of control without a CCP?

 

Do you have the proper facilities to store products requiring refrigeration?


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TimG

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Posted 17 September 2021 - 03:27 PM

Good morning Swarren,

In my brief year in a grocer distributor, maintaining the cold chain was king. Temperature was recorded and documented prior to unloading (most of these were digital readouts that we then verified with a gun) and from that point on temperature was monitored in facility and until it left our control.

 

If you have a HACCP plan, I assume you are repackaging or the product is exposed to the environment? If so, I would find it hard to justify not including the cold chain and establishing CCP's at critical points under my biological hazards. As a distributor, while you can set a FSplan to cover all hazards, you must be sure each hazard and each product is covered. If any of the products you receive requires constant refrigeration to be considered safe to eat (i.e. not adulterated by FDA standards) then I would suggest you keep it refrigerated (obviously) and document that refrigeration is maintained, which could be done with a proper CCP.



swarren

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Posted 17 September 2021 - 04:02 PM

you're implying you believe this products could be stored out of control without a CCP?

 

Do you have the proper facilities to store products requiring refrigeration?

 

Hi Scampi,

 

They wouldn't be stored "out of control." We are wondering whether the receiving step should be considered a CCP or whether considering it as a prerequisite program is sufficient.



Charles.C

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Posted 18 September 2021 - 01:36 AM

Hi everyone,

 

I work at a distribution center for a variety of food products. Most of the seafood products we receive are frozen. However, we may receive some refrigerated smoked fish, marinated anchovies, and anchovies in olive oil. If we receive and store these refrigerated, do the receiving and storage temperatures need to be considered CCPs in our HACCP Plan?

 

Thanks in advance for your help.

 

Hi swarren,

 

You can find a variety of opinions in previous theads here as to whether PRPs or CCPs are involved (or even OPRPs).

 

It may relate to whether a particular FS Standard is involved, eg BRC, SQF etc ?

 

Just as 2 (oldish) examples can have a look at these -

 

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

 

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


Kind Regards,

 

Charles.C


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Posted 18 September 2021 - 03:44 PM

Hi everyone,

 

I work at a distribution center for a variety of food products. Most of the seafood products we receive are frozen. However, we may receive some refrigerated smoked fish, marinated anchovies, and anchovies in olive oil. If we receive and store these refrigerated, do the receiving and storage temperatures need to be considered CCPs in our HACCP Plan?

 

Thanks in advance for your help.

 

With the exception of frozen (mostly) both receiving and refrigerated storage are CCPs for seafood under 21 CFR part 123 with the product you have mentioned. Pushing these into a PRP method is not going to fly with the FDA. Actual control strategies will depend on numerous factors to include packaging, end use, species, etc.  

 

Common hazards are pathogen growth/formation (smoked fish is notorious for L. mono), C. bot toxin formation (e.g. Vacuum, CAP, MAP, oil fill), histamine, allergen/additive controls in receiving.

 

Attached is the Seafood Hazards Guidance. Since you haven't stated so, I assume you have no formal training or experience with this so I have provided a link to online training with Cornell University Sea Grant Extension Program.

 

Attached File  Hazards and Controls Guidance.pdf   4.53MB   8 downloads


Food Safety News  Marine Stewardship Council

 

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Charles.C

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Posted 19 September 2021 - 12:14 AM

With the exception of frozen (mostly) both receiving and refrigerated storage are CCPs for seafood under 21 CFR part 123 with the product you have mentioned. Pushing these into a PRP method is not going to fly with the FDA. Actual control strategies will depend on numerous factors to include packaging, end use, species, etc.  

 

Common hazards are pathogen growth/formation (smoked fish is notorious for L. mono), C. bot toxin formation (e.g. Vacuum, CAP, MAP, oil fill), histamine, allergen/additive controls in receiving.

 

Attached is the Seafood Hazards Guidance. Since you haven't stated so, I assume you have no formal training or experience with this so I have provided a link to online training with Cornell University Sea Grant Extension Program.

 

attachicon.gif Hazards and Controls Guidance.pdf

 

Hi Slab,

 

Well remembered. Thks.

 

I deduce that in American, "Refrigerated Storage" = "cooled" but not frozen. Too much attention to James Bond perhaps.

 

I speculate that USFDA are one of the last official FS Organisations to mandate this  CCP, How about USDA ?


Kind Regards,

 

Charles.C


Slab

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Posted 20 September 2021 - 08:53 PM

 

 

I speculate that USFDA are one of the last official FS Organisations to mandate this  CCP, How about USDA ?

 

I'm not sure about USDA, however their HACCP guidance usually lists temperature monitoring as a "control"


Food Safety News  Marine Stewardship Council

 

"Some people freak out when they see small vertebra in their pasta" ~ Chef John


BigLou21972

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Posted 22 September 2021 - 07:38 PM

Hello Swarren,

 

   If I didn't know any better I would swear that you work in the same facility as I. That being said, we are also a storage and distribution facility that receive, store and ship those exact products along with caviar and and some other seafood products and most are in our HACCP plan as CCP's. What do the specifications say from the manufacturer and how are they packaged? If it is reduced oxygen packaged, (ROP, vac sealed), then you have the potential for clostridium botulinum. Anchovies have a scombrotoxin, (histamine) hazard. Shelf stable anchovies in tins are not CCP's because there is no temperature requirement besides "Keep Cool".

  These are temperature abuse CCP's and we require TTI's from our suppliers while in transit to our facility. My QA tech's will also be the ones to inspect and receive said seafood products with 10% of the product requiring manual surface temp checks as part of the controls. While the products are in storage at our facility, we monitor our "CCP Coolers & Freezers" 24/7 digitally and twice a day, (am/pm), manually.

  I think you first need to start with the product information from your suppliers. We have a robust supplier approval program that require 3rd party audits from our seafood suppliers along with the reports, (not just the certs). I want to be sure that their HACCP plans were covered in detail by the auditor, regarding seafood and if not, I will ask to see their HACCP flow charts and even the plans if I still have concerns.  Our seafood suppliers are required to send us updated spec sheets of all product and any new products require new spec sheets. 

  By the way, our seafood HACCP plans and facility is inspected 4 times a year by NOAA/USDC as part of an "Approved Facility" under the NOAA/USDC voluntary seafood inspection program.

 

I hope this helps.  :smile:



swarren

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Posted 22 September 2021 - 08:00 PM

Hello Swarren,

 

   If I didn't know any better I would swear that you work in the same facility as I. That being said, we are also a storage and distribution facility that receive, store and ship those exact products along with caviar and and some other seafood products and most are in our HACCP plan as CCP's. What do the specifications say from the manufacturer and how are they packaged? If it is reduced oxygen packaged, (ROP, vac sealed), then you have the potential for clostridium botulinum. Anchovies have a scombrotoxin, (histamine) hazard. Shelf stable anchovies in tins are not CCP's because there is no temperature requirement besides "Keep Cool".

  These are temperature abuse CCP's and we require TTI's from our suppliers while in transit to our facility. My QA tech's will also be the ones to inspect and receive said seafood products with 10% of the product requiring manual surface temp checks as part of the controls. While the products are in storage at our facility, we monitor our "CCP Coolers & Freezers" 24/7 digitally and twice a day, (am/pm), manually.

  I think you first need to start with the product information from your suppliers. We have a robust supplier approval program that require 3rd party audits from our seafood suppliers along with the reports, (not just the certs). I want to be sure that their HACCP plans were covered in detail by the auditor, regarding seafood and if not, I will ask to see their HACCP flow charts and even the plans if I still have concerns.  Our seafood suppliers are required to send us updated spec sheets of all product and any new products require new spec sheets. 

  By the way, our seafood HACCP plans and facility is inspected 4 times a year by NOAA/USDC as part of an "Approved Facility" under the NOAA/USDC voluntary seafood inspection program.

 

I hope this helps.  :smile:

 

Thanks so much for your detailed response! I have reached out to our suppliers for more detailed product specs. According to the FDA Fisheries Guidance, it looks like if the product has a pH less than 4.6 (acidic), water activity less than 0.85, or water phase salt of at least 20% a refrigeration CCP is not required. Do you have any insight on that?

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Charles.C

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Posted 24 September 2021 - 04:34 AM

Thanks so much for your detailed response! I have reached out to our suppliers for more detailed product specs. According to the FDA Fisheries Guidance, it looks like if the product has a pH less than 4.6 (acidic), water activity less than 0.85, or water phase salt of at least 20% a refrigeration CCP is not required. Do you have any insight on that?

 

So are yr products vac. (or MAP) packed ?


Kind Regards,

 

Charles.C


swarren

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Posted 24 September 2021 - 12:28 PM

So are yr products vac. (or MAP) packed ?

Some are marinated and and vacuum sealed, others are in a glass jar with olive oil.



Charles.C

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Posted 26 September 2021 - 09:05 AM

Thanks so much for your detailed response! I have reached out to our suppliers for more detailed product specs. According to the FDA Fisheries Guidance, it looks like if the product has a pH less than 4.6 (acidic), water activity less than 0.85, or water phase salt of at least 20% a refrigeration CCP is not required. Do you have any insight on that?

Hi swarren,

 

^^^^ Depending on which specific product you are referring to and its Process, note that there may be caveats associated with yr refrigeration assumption, just for example pg. 256 in attachment Post 10.

 

Detailed knowledge of the specific Product and it's Process/Control/Storage Justification aspects is required.

.


Kind Regards,

 

Charles.C






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