Critical limits in seafood

Hello,

Working  to SQF level 2 certification module 9. We are a seafood wholesaler. I am establishing limits in product descriptions, and it's reasonable that people would consume our yellowfin tuna raw. I have histamine and mercury levels established, but is there anything additional I should be testing and establishing limits of? There's a lot on the FDA side, and it's unreasonable to test every batch for clostridium, botulinum,  etc. when raw consumption isn't the intended product use. 

Any help would be appreciated!  

You can't test your way into food safety.  If you want to offer your tuna as edible raw, I'd assume (with no seafood experience) that you'd need to have a flash freeze type kill step established as a CCP or a temp control CCP if you're getting the fish from a vessel that does the freezing themselves.  Your process would need to be validated to prove it controls the pathogens and parasites that wild tuna has contracted.  Different risks apparently for farm raised, but it's up to you to establish a process that kills the pathogens of concern.

Or slap warnings on the labels that this fish isn't intended to be consumed raw, "Must cook to XXXF for food safety".

You can't test your way into food safety.  If you want to offer your tuna as edible raw, I'd assume (with no seafood experience) that you'd need to have a flash freeze type kill step established as a CCP or a temp control CCP if you're getting the fish from a vessel that does the freezing themselves.  Your process would need to be validated to prove it controls the pathogens and parasites that wild tuna has contracted.  Different risks apparently for farm raised, but it's up to you to establish a process that kills the pathogens of concern.

 

Or slap warnings on the labels that this fish isn't intended to be consumed raw, "Must cook to XXXF for food safety".

We don't want to offer the product raw. We have warnings on every invoice that all product is intended to be cooked. 

Yellowfin tuna and farm raised salmon fed with pelletized feed are exempt parasite destruction, so it's reasonable that people may consume the product raw. Just trying to do my due diligence here in providing safe food and wondering what extra pathogens should be of note in my documentation. 

I would look at the FDA seafood guidance document if you haven't yet. The document calls out specific species and risks. 

Here is a link to FDA's Fish & Fishery Products Hazards & Controls Guidance.

It is free to download and very helpful.

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

Table 3-2 shows potential vertebrate species-related hazards

"Tuna, aquacultured" has the following potential hazards:

• Parasite Hazards
• Scombrotoxin (Histamine) Hazards
• Environmental Chemical Hazards
• Aquaculture Drug Hazards