By: Michael Jahncke*
The United States Department of Agriculture (USDA) has regulatory HACCP authority over meat and poultry, and processed egg products (i.e., liquid, frozen, dried egg products). The USDA/Food Safety Inspection Service (FSIS) also has oversight authority for food products containing more than 2-3% meat or poultry. The Food and Drug Administration (FDA) has regulatory authority on seafood, fruits and vegetables, grain products, dairy products, and shell eggs, and juice. Mandatory HACCP for seafood was implemented by the FDA in 1997.
In most cases, the warehouse is defined as a secondary processor if it only receives stores and ships refrigerated or frozen seafood products, and does not repack or reprocess the products. Its customer, the primary processor, must have a HACCP Plan to control significant biological (e.g., pathogens), chemical (e.g., control of food allergens through labeling; control of histamine formation through temperature control in scombroid species, etc.) and physical hazards (e.g., potential metal fragments, glass, etc.) in the food product. The warehouse must also implement Sanitation Standard Operating Procedures (SSOPs) to prevent recontamination with biological, chemical and physical hazards. In addition, even though the biological hazards (e.g., pathogen growth, toxin formation) and chemical hazards (histamine formation) are initially controlled in the primary processor’s HACCP Plan, unlike other chemical and physical hazards (which are still controlled by the primary processor’s HACCP Plan), pathogen growth, toxin formation, and/or histamine formation can still occur due to temperature abuse during transport and storage. Thus, these significant hazards must be controlled by appropriate refrigerated product temperatures in the warehouse’s HACCP Plan.
Therefore, a Seafood HACCP plan is required at the warehouse for high risk refrigerated seafood products (i.e., Time Temperature Control for Safety Foods [TCS]), if the warehouse is: 1). A first-processor, that receives refrigerated fish or shellfish directly from the vessel; or 2). If it stores live or fresh shellfish, or refrigerated scombroid species (tuna, mahi-mahi, bluefish), or refrigerated vacuum packaged smoked fish, refrigerated pasteurized crab meat, or other products where time/temperature abuse can cause a food-safety hazard. A Warehouse HACCP Plan, however, may not be required for frozen seafood products, since pathogen growth, toxin formation, and/or histamine formation are not reasonably likely to occur in frozen products.
Regardless, whether or not seafood products are frozen or refrigerated, a Hazard Analysis (HA) must be conducted. The FDA requires that every processor conduct an HA for each step in the flow diagram (i.e., the step in the production cycle in which one would expect to find the potential hazard). The HA is conducted to identify all potential food safety hazards, identify which of these hazards are significant and identify measures to control the significant hazards. In the case of a warehouse that only receives, stores and ships product, the HACCP Plan for high risk refrigerated seafood products (i.e., TCS foods) may include temperature control (depending on the product) to prevent pathogen growth, toxin formation, and/or histamine formation.
Solution: The first step in HACCP is to 1). Assemble the HACCP Team. This team should be comprised at a minimum of a supervisor, individuals that understand HACCP concept, individuals that are knowledgeable about the receiving, storage and shipment process, and individuals that are responsible for the specified activities. 2). Draw a flow chart of the flow of food products through the facility.
3). Verify the accuracy of the flow diagram by asking questions and walking through the facility. For a warehouse that receives refrigerated or frozen seafood the processing steps are as follows:
Step 1. Assess the Hazards: Determine whether or not there is the potential for pathogen growth and/or histamine formation at the receiving, storage and shipping steps at the warehouse. (i.e., identify the appropriate refrigerated temperatures needed to prevent pathogen growth, toxin formation, and/or histamine formation).
Step 2. Establish Critical Control Points: The step in the process where control must be in place to prevent, eliminate or reduce to an acceptable level the identified hazard(s). (i.e., receiving, refrigerated storage and shipping).
NOTE: If there is one or more identified CCPs then the company must write a HACCP Plan that includes each identified significant hazard at each CCP.
Step 3: Establish Critical Limits (CLs): For a refrigerated warehouse this is the maximum not to exceed temperature to ensure the safety of the refrigerated high risk seafood product(s) at receipt, storage and shipment.
Step 4: Establish Monitoring Procedures: Procedures to ensure that a CL is met and to provide documentation that the CLs have been met, and lastly to identify when there is a loss of control at a CCP. (Note: All temperature monitoring equipment should be calibrated at least annually and have daily accuracy checks conducted prior to each use).
Step 5: Establish Corrective Action: Procedures to be taken whenever the monitoring step finds that a deviation has occurred (e.g., exceeded maximum internal product temperatures that ensure safe food at receipt, storage or shipping).
Step 6: Verification Procedures: Activities other than monitoring that determines the accuracy and reliability of the HACCP Plan and verifies that the HACCP Plan is operating according to the plan. (e.g., the thermometer, continuous temperature recorder device, infrared gun, etc., used to determine product temperatures must be calibrated at least yearly and checked for accuracy prior to each use).
Step 7: Recordkeeping: Records including, the HACCP Plan, pre-requisite programs such as Sanitation Standard Operating Procedures (SSOPs), monitoring and corrective action records, temperature calibration and thermometer accuracy records, etc.
Whether or not the HA indicates that a HACCP Plan is required, each warehouse must monitor and keep sanitation monitoring records. There are 8 Key Sanitation Conditions and Practices which must be monitored in a warehouse’s SSOPs.
1).Safety of water – source and in-plant (includes ice);
2).Condition and cleanliness of food-contact surfaces (includes gloves, garments etc.);
3).Prevention of cross-contamination reflects employee practices/handling (e.g., separation of raw and “cooked” product), plant design – movement of product and people);
4).Maintenance of hand-washing, hand- sanitizing and toilet facilities;
5).Protection from adulterants;
6).Labeling, storage and proper use of toxic compounds;
7).Employee health conditions; and
8).Exclusion of pests.
In addition to monitoring the 8 Key SSOPs, the warehouse should have written Standard Operating Procedures (SOPs) at each processing step. (i.e., Incoming goods inspection program, proper storage procedures, and an outgoing goods inspection program).
*Dr. Michael Jahncke is a Professor at Virginia Tech and the Director of the Virginia Seafood Agricultural Research and Extension Center. He earned his Ph.D. in Food Science at Cornell University. His research interests include safety and quality of wild catch and aquaculture species, sensory evaluation of seafood products, handling and processing of fish and fishery products, public, environmental, and animal health issues associated with aquaculture systems.