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Product with fish: HACCP or HARPC

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SilkeFood

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Posted 04 May 2022 - 11:29 AM

Hi!

 

A company is manufactuting fish spread. They buy fish as a cooked ingredient and then mix it with others ingredients to do the final product; being the final fish percentage under 40% of the total.

Shall they follow the Fish and fishery products HACCP (acording to 21 CFR 123) or follow an HARPC??

 

Thank you very much!!

 

 

 

 



SQFconsultant

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Posted 04 May 2022 - 01:12 PM

HARPC.


All the Best,

 

All Rights Reserved,

Without Prejudice,

Glenn Oster.

Glenn Oster Consulting, LLC -

SQF System Development, Implementation & Certification | eConsultant | Internal Auditor Training

http://www.GCEMVI.XYZ

https://glennoster.website3.me/

 


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SilkeFood

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Posted 06 May 2022 - 06:22 AM

Thank you very much, Mr. Oster!!!

Greetings,

Celia



Fishlady

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Posted 08 May 2022 - 05:21 PM

If fish is a characterizing ingredient, then you must comply with 21 CFR 123, the seafood HACCP regulation. If it is called a fish spread, I would say it is a characterizing ingredient.

The exception given in FDA’s examples where the fish is not characterizing is Worcestershire sauce, which has a tiny bit of anchovies.



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SilkeFood

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Posted 11 May 2022 - 08:06 AM

Thanks Fishlady!

 

But now I have doubts due to Mr. Oster and you replied in a diferent way.

 

In this product in particular, although the main ingredient is fish there's only 35% of it. Also, this ingredient is not process in the firm, is already bought cooked, and the only process activity happening in the firm is the mixing step with the rest of ingredients.

 

Waiting for your reply. Thank you very much in advance!!!



Fishlady

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Posted 11 May 2022 - 04:25 PM

Hi, Celia
I have worked in seafood for over 30 years and have been seafood HACCP certified since 1996. In the definition section of 21CFR 123 it defines “fishery product” as “any human food product in which fish is a characterizing ingredient.” Section 123.6 states that each kind of fish and fishery product must have a hazard analysis. There is nothing that specifies percent fish content or state of processing, but I would emphasize that your product appears to have fish as a characterizing ingredient.



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kfromNE

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Posted 11 May 2022 - 04:54 PM

I agree with Fishlady. It falls under seafood HACCP. For our seafood items, we structured the hazard analysis in the HARPC format. This was before my time so not 100% sure why this was done.



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SilkeFood

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Posted 25 May 2022 - 09:31 AM

Thank you very much Fishlady, kfromNE and SQFconsultant !!!

 

I'm very grateful for your replies and interest in the subject. Yep, the product falls under 21 CFR 123.

 

I wish you all a nice day!!! :sleazy:





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