Seafood HACCP Plan Guidelines

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Seafood HACCP Plan
Guidelines - Introduction

Processors of fish and fishery products currently fall under the regulatory rules of local State Health Departments and the United States Food & Drug Administration’s Seafood Hazards Analysis and Critical Control Point (HACCP) program. This plan guidance page will walk through the basics of developing a HACCP plan in order to achieve compliance with both State and Federal entities to facilitate safe and sanitary processing.

Types of companies that would use this plan would be:

Types of food products that would use a version of this guidance would be:

Crab – Fresh
Crab – Frozen
Fish – General
Lobster – Cooked
Shucked Oysters
Sushi

Mussels – Live
Salmon – Hot Smoked
Seafood – General HACCP
Scallops – Shucked Chilled
Squid – Raw, Frozen
Tuna – Canned

Why HACCP /
Food Safety Plan?

The Food Safety Plan (HACCP or Preventive Controls) is not a stand alone program, but rather part of a larger food safety system. The foundational programs that are part of the food safety system are frequently termed prerequisite programs. The term was coined to indicate that they should be in place before HACCP based systems are implemented in order to effectively manage risk from foodborne hazards. The Current Good Manufacturing Practice (GMP) regulations address requirements for many prerequisite programs. The regulation (117 Subpart B) that outlines the conditions and practices the regulated food industry must follow for processing safe food under sanitary conditions, including personnel, plant and grounds, sanitary operations, sanitary facilities and controls, equipment and utensils, processes and controls, warehousing and distribution, and defect action levels considerations. Elements of GMPs that are not covered in the Food Safety Plan are still required by regulations.

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Process Flow

The process flow of a food safety plan (HACCP or Preventive Controls) is the center of a food product’s food safety story. It tells how a company makes it’s products and also what hazards and controls are associated with each step. Here’s an example process flow for lobster:

Suggested
Logs and Records

Monitoring records and logs must include the actual values or observation that document the actual implementation of a Food Safety Plan . For example, if a temperature is being measured, the actual temperature must be recorded rather than a check mark indicating that the temperature complied with the critical limit. To comply with regulations, information must be recorded at the time it is observed.

Here are suggested record and log types to use:

Customer Complaints
Corrective Action Forms
Employee Training
Food Safety Quarterly Audit
Food Safety Checklist
Raw Materials/Receiving Log
Worker Illness
Refrigerator Log
Assembly Log
Shipping Temperature Log

Potential Hazards

Canned Salmon

Spore formers — Clostridium botulinum

&nbsp Salmon

Psychotrophs — Listeria monocytogenes

Oysters/Mussels

Psychotrophs — Listeria monocytogenes
Proteobacteria — Campylobacter jejuni
Enterobacteriacae — Salmonella
Marine biotoxins
Virus — Norovirus
Environmental chemical contaminants
Proteobacteria — Vibrio spp.
Allergens

Fin Fish

Parasites — Anisakis
Environmental chemical contaminants
Allergens
Enterobacteriacae — Salmonella
Psychotrophs — Listeria monocytogenes

Suggested Standard
Operating Procedures (SOP)

SOPs are related to both GMPs and Controls of Hazards in the Food Safety Plan. SOPs define the specific steps of how GMPs and Controls of Hazards mitigate food safety hazards and define a repeatable process.

Using and Calibrating Thermometers
Transporting Food to Remote Sites
Cooling Potentially Hazardous Foods
Cleaning and Sanitizing Food Contact Surfaces
Storing and Using Poisonous or Toxic Chemicals
Preventing Cross-Contamination During Storage and Preparation
Receiving Deliveries
Cleaning of Buildings and Facilities
Allergen Control Program
Washing Hands – To prevent foodborne illness by contaminated hands
Employee Illness Program
Using Suitable Utensils When Handling Ready-to-Eat Foods

Additional Components for
Compliance (Recommended)

The following associated food safety components are recommended to achieve compliance with State and Federal rules and regulations.

Recall Plan

According to the Food Safety Modernization Act, Preventive Controls for Human Food regulation requires the development of a written Recall Plan when a hazard analysis identifies a hazard requiring a control. Recalls are actions taken by an establishment to remove an adulterated, misbranded or violative product from the market. In other words, a product for which FDA or a state could take legal action against the company would be subject to recall.

Verification

Verification is an important component of supply chain, sanitation, allergen and critical controls. It confirms that the Food Safety Plan is operating as intended. Validation confirms the effectiveness of the Food Safety Plan in controlling food safety hazards. The purpose of verification is to provide a level of confidence that the Food Safety Plan is: 1) based on solid scientific principles that are adequate to control the hazards associated with the product and process, and 2) that the plan is being followed correctly every day of operation.

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Seafood HACCP Plan Guidelines