13 replies to this topic

[wbourg]

Hello,

I manage the food safety program in a bakery/distribution center for a small C store chain. We have a coman produce sandwiches for us, but we just receiving a cold tuna salad sandwich. I am under the impression that I should have been involved because we need a seafood HACCP on top of our normal RTE sandwich HACCP. Am I wrong or missing something? Can someone point my in the right direction code wise? I'm upset with our marketing VP who decided this without involving me so I need to tread carefully.

Thanks.

[Charles.C]

Hello,

I manage the food safety program in a bakery/distribution center for a small C store chain. We have a coman produce sandwiches for us, but we just receiving a cold tuna salad sandwich. I am under the impression that I should have been involved because we need a seafood HACCP on top of our normal RTE sandwich HACCP. Am I wrong or missing something? Can someone point my in the right direction code wise? I'm upset with our marketing VP who decided this without involving me so I need to tread carefully.

Thanks.

Hi wbourg,

 

Not sure exactly what you mean by "Code wise" ?

 

Do you have an Organisation Flowchart delineating Responsibilities/Reporting Chain ?

[SoupsNStuff]

Are the risks for the tuna sandwich different than the risks for your other RTE sandwiches? If not, they can use the same HACCP plan. 

 

Separate issue, you definitely should have been informed of any new products so you could do this risk assessment and add the product to your Food Safety Plan....

[kfromNE]

Are the risks for the tuna sandwich different than the risks for your other RTE sandwiches? If not, they can use the same HACCP plan. 

 

Separate issue, you definitely should have been informed of any new products so you could do this risk assessment and add the product to your Food Safety Plan....

The seafood part becomes the tricky situation. I'm not familiar with sandwiches. However for soups. Soup with seafood in it falls under FDA Seafood HACCP. We have to have separate plans for seafood soups and FDA soups. Different rules too.

[SoupsNStuff]

The seafood part becomes the tricky situation. I'm not familiar with sandwiches. However for soups. Soup with seafood in it falls under FDA Seafood HACCP. We have to have separate plans for seafood soups and FDA soups. Different rules too.

Despite my name, its been a few years since I was in the soup industry and the 'nstuff' part is more relevant now...so it is entirely possible I'm forgetting all of that lol. 

 

But for a FSMA Food Safety Plan, would there need to be a different plan entirely for seafood even if the product is similar in type, process steps, and hazards? What rules are different that would necessitate an entirely different plan?

 

I'm trying to remember our set up back in the soup days (since we did meat, seafood, and veg thus had all the regulatory fun), but I can't recall anything special we had to do... traceability of seafood ingredients sure but now that needs to be done for everything anyway... 

[G M]

...

But for a FSMA Food Safety Plan, would there need to be a different plan entirely for seafood even if the product is similar in type, process steps, and hazards? What rules are different that would necessitate an entirely different plan?

...

 

Possible, I'm sure.  It would just require lots of terminology clarifications because the FDA tried to reinvent the wheel.  The USDA inspectors would also get more process limits and programs to call you out on because its in the plan they're looking at every day.

[kfromNE]

Despite my name, its been a few years since I was in the soup industry and the 'nstuff' part is more relevant now...so it is entirely possible I'm forgetting all of that lol. 

 

But for a FSMA Food Safety Plan, would there need to be a different plan entirely for seafood even if the product is similar in type, process steps, and hazards? What rules are different that would necessitate an entirely different plan?

 

I'm trying to remember our set up back in the soup days (since we did meat, seafood, and veg thus had all the regulatory fun), but I can't recall anything special we had to do... traceability of seafood ingredients sure but now that needs to be done for everything anyway... 

For soups - yes two separate HACCP plans are required even with similar processes. I actually have 3 separate plans for the same process because one for FDA, FDA Seafood and USDA soups. The only difference - one calls out receiving meat, one calls out receiving seafood and the other FDA ingredients. I believe it's a agency control thing and each has their own rules. Our procedures and processes are pretty similar for all three. Though the regulations are a little different for all three in little ways. (It's a fun time) 

[Charles.C]

JFI there is a highly detailed haccp plan/hazard  analysis for Tuna sandwiches somewhere on this Forum (intended to enable the prediction of shelf life).

 

It is unclear to me if the OP is in US ? Based on above fascinatingly complicated posts I hope not.

[wbourg]

Separate issue, you definitely should have been informed of any new products so you could do this risk assessment and add the product to your Food Safety Plan....

 

I raised hell over this incident. They were aware they need to inform me of any and all new items used, they just ignored it because I would have rejected the item. I raised the issue with the CEO and President of the company and he took it from there. Not sure why, but my notifications weren't on. 

 

 

Hi wbourg,

 

Not sure exactly what you mean by "Code wise" ?

 

I was looking for the FDA code that specifically said that we were seafood processors. It is found here: FDA 21 CFR 123.3(k). 

 

This should answer your second question, which is yes, I am in the US. These coman sandwiches are only in our facility for about 15 minutes so I don't see them like I do other products. 

 

Thank you for everyone's insight. I am taking Seafood HACCP classes on the Marketing departments dime, completed a seafood HACCP plan, and we have suspended distributing the sandwich. 

[Charles.C]

Hi wbourg,

 

So is there any Policy regarding commercialisation of new (any?) Products (eg Positive Hold re-QS Specification) ?

 

Based on yr info, the Management System seems sort of Cowboy style. (A disaster waiting to happen).

[Sayed M Naim Khalid]

If you already have a HACCP plan for other RTE, I will just see if fish was part of hazard analysis. Fish is a high risk for heavy metals, toxins and parasites. If not included in the RTE HACCP. I would do one of the following: 

1. conduct a new HACCP study for the new product

2. Update the current HACCP plan and include the new product 

[kfromNE]

If you already have a HACCP plan for other RTE, I will just see if fish was part of hazard analysis. Fish is a high risk for heavy metals, toxins and parasites. If not included in the RTE HACCP. I would do one of the following: 

1. conduct a new HACCP study for the new product

2. Update the current HACCP plan and include the new product 

Regulations are different for fish items vs other FDA items. It needs a separate HACCP plan from the other items.

 

I wish it was that easy to add it to a Food Safety Plan with similar process steps. Coming off a recent FDA inspection - not allowed/recommended. We make a clam chowder and a lobster bisque soup along with FDA soups and USDA soups. I have 4 separate plans even though they follow the same process. One USDA plan, one FDA plan and two separate plans for the two seafood soups. The reason being - clams and lobster have different hazards we have to account for. The two separate seafood HACCP plans - the recommendation by the FDA inspector.

[AltonBrownFanClub]

wbourg,

 

Here is the seafood-specific HACCP text.

It has HACCP requirements, examples, risk analysis, etc.

 

It's easy to follow and will have evrything you're looking for.

It's used for seafood HACCP training courses.

 

Free download if you search "Fish & Fishery Products: Hazards and Controls or follow this link:

https://www.fda.gov/...ds-and-controls

[wbourg]

Hi wbourg,

So is there any Policy regarding commercialisation of new (any?) Products (eg Positive Hold re-QS Specification) ?

Based on yr info, the Management System seems sort of Cowboy style. (A disaster waiting to happen).

Yes, like I said. They chose to ignore this and I raised the issue with the president and CEO of the company. If it happens again they will get reprimanded.