HOW Safe Gulf Seafood · 2015. 11. 24. · HOW to assure Safe Gulf Seafood ADDITIONAL PROGRAMS (provided by Sea Grant): •Train seafood processors to screen shrimp harvests from

HOW to assure

Safe Gulf Seafood

HOW = HARVEST OPEN WATERS

PURPOSE: Sea Grant personnel from Gulf states provided training to assist primary seafood processors in providing additional evidence for buyer confidence in Gulf seafood following DWH.

APPROACH: Use existing food safety programs plus additional proven methods for verifications explained by training offered through the Sea Grant Extension Services around the Gulf of Mexico

HOW to assure Safe Gulf Seafood(Mandated & Voluntary Parts)

HOW to assure Safe Gulf Seafood(Mandated Programs)

• Federal (NMFS) and State approved harvestsfrom open waters based on expert sensoryscreening and analytical confirmations

• Federal (FDA) mandated HACCP • (Hazard Analysis Critical Control Point) programsfor primary processors to prevent anypotential environmental chemical hazards

EXISTING PROGRAMS:

HOW to assure Safe Gulf Seafood

ADDITIONAL PROGRAMS (provided by Sea Grant):

• Train seafood processors to screen shrimp harvests from open waters by smell to verify absence of obviouscontaminants due to petroleum taint. Processors added this screening to their existing HACCP (food safety) plans to further assure consumers of the safety of Gulf seafood.

• Periodic analytical verification of productsharvested from open waters – voluntary part of the HACCP plan

Based on HARVEST from OPEN WATERS


http://sero.nmfs.noaa.gov/deepwater_horizon_oil_spill.htm

http://www.myfwc.com/OilSpill/

http://www.fda.gov/Food/FoodSafety/Product-SpecificInformation/Seafood/ucm210970.htm#background_testing


PROTOCOL FOR RE-OPENING OIL-IMPACTED WATERS CLOSED TO SEAFOOD HARVEST


Sensory Analysis:Examined by team of trained and qualified “sensory experts”

If no sensory ‘taint’ detected, then …..

Chemical Analysis:Calculated limited based on a designated ‘group’ of chemicals of concern that are unique for the particular oil spill in the Gulf of Mexico

HACCP for Seafood Processors – Background:

• Food safety program mandated by FDA and respective Stateagencies since 1996 for all seafood processing operations

• Processor is defined as “any person engaged in commercial,custom, or institutional processing of fish or fishery products

• Processing is defined as … handling, storing, preparing, heading, eviscerating, shucking, freezing, changing into different market forms, manufacturing , preserving, packing,labeling, dockside unloading, or holding

Based on HACCP for Seafood SafetyHazard Analysis Critical Control Point

http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/Seafood/FishandFisheriesProductsHazardsandControlsGuide/default.htm

Chapter 9

Based on HACCP for Seafood Safety

Although the ‘Guide’ does not specifically list hazards associated with oil spills, HACCP requires a processor be responsible for any potential hazard Chapter 9 does addresses chemical hazards in general and suggestsmonitoring of open waters as a method to control a hazard. However, there are currently no specified tolerances or action levels for fish products relative to specific contaminants from an oil spill

The ‘Guide’ recognizes use of third party evidence and rapid analyticalmethods to assess chemical contamination

Starts with the Primary Processors

Primary processor is the first person or firm that obtains the fish products from harvest

Secondary or latter processor the person or firm that obtains the fish or fishery products after primary processing

Applies to all primary processing in domestic or international settings

Process Flow Diagram (Processing Steps)

RECEIVING

PROCESSING STEP 1

PROCESSING STEP 2

PROCESSING STEPS etc…

STORAGE

Washing, Thawing, Grading, Sorting, Shucking, Cooking, Picking, Packaging,Labeling, etc…

Harvest Open Waters

HACCP PROGRAM for Safe Gulf Seafood

Revised Hazard Analysis for the DWH situation in the Gulf of Mexico should include the environmental chemical contaminant “petroleum taint “ based on reference to FDA’s “Fish and FisheryProducts Hazards and Controls Guide” (2001 edition) as reminded by the FDA directive issued June 14, 2010. This directive involves all fishery products (shrimp, crabs, fish, oysters) from the Gulf… and suggests including :

RECEIVING as a first Critical Control Pointto prevent any potential hazards from environmental chemical contaminants, specifically oil from the DWH



Critical Control Point (CCP)

Food Safety Hazard

Critical Limits

MonitoringCorrective

ActionsRecords Verifications

What How When Who

7 Required Principles“Fish” includes all Gulf products



Food Safety Hazard

Critical Limits



What How When Who

Product Receiving (fromharvest)

1. Product Received(from harvest)



Food Safety Hazard

Critical Limits



What How When Who


EnvironmentalChemicalContaminants

(Oil Spill related )

2. Environmental Chemical Contaminants(Oil Spill related)

[ based on Chapter 9 FDA Fish’ Hazards Guide ]



Food Safety Hazard

Critical Limits



What How When Who


EnvironmentChemicalContaminants

(Oil Spill related)

No fish may be harvested from an area that is covered by a Local, State or Federal closure or for which there is additional information that indicates potential hazards related to an oil spill

3. *No fish may be harvested from an areathat is covered by a Local, State or Federal closure or for which there isadditional information that indicatespotential hazards related to an oil spill

* Open water status issued by Federal and State authoritieshttp://sero.nmfs.noaa.gov/deppwater_horizon_oil_spill.htm



Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)

*No fish may be harvested from an area that is covered by a Local, State or Federal closure or for which there is additional information that indicates potential hazards related to an oil spill

Identify harvest area for product received 4. Identify harvest area

for product received



Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)


Identify harvest area for product received

Document for harvest location (tags, trip tickets, site coordinates, confirming letters, etc)

4. Document harvest location(tags, trip tickets, site coordinates,confirming letters, etc.)



Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)




Every lot received

4. Every lot received



Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)




Every lot received

Receiving employee

4. Receiving employee



Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)




Every lot received

Receiving employee

Reject lot

Discontinue use of supplier until evidence is obtained that harvesting practices have changed

5. Reject lot




Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)




Every lot received

Receiving employee

Reject lot


Receiving Record

Corrective Action Records

6. Receiving Record




Food Safety Hazard

Critical Limits



What How When Who



(Oil Spill related)




Every lot received

Receiving employee

Reject lot


Receiving Record

Corrective Action Record

Review monitoring and corrective action records within one week of preparation

1Sensory screening for every lot

1Periodic analytical screening of samples3

7. Review monitoring and correction action records within one week of preparation

1Sensory screening for every lot21Periodic analytical screening of samples3



Food Safety Hazard

Critical Limits



What How When Who


Environment ChemicalContaminants

(Oil Spill related)




Every lot received

Receiving employee

Reject lot


Receiving Record


Review monitoring and corrective action records within one week of preparation

1Sensory screening for every lot2

1Periodic analytical screening of samples3

Add Footnotes

HACCP PROGRAM for Safe Gulf SeafoodAdd Footnotes

1 Sensory and analytical screening are temporary measures that can beused in addition to the recommendations and guidance provided in FDA’s 2001 Fish & Fisheries Products Hazards and Control Guide, Chapter 9-Environmental Contaminants & Pesticides.

2 If sensory screening detects hydrocarbon taint it does not immediately indicate oil spill contamination, it may be caused by contamination during handling on the harvest vessel. In either case, the product should be rejected and the problem corrected.

3 Frequency for analytical screening can vary according to seasons, nature and volume of product, and other factors involving a particular fishery.

Carried out “nose‐on” training for processing plant personnel to detect ‘obvious oil taint’ in incoming seafood – assuming harvest came from open watersParticipants were asked to identify by smell

-Gulf harvested shrimp that had been exposed to various concentrations of DWH crude oil, diesel fuel, as well as slightly spoiled shrimp and non-treated controls.-Participants were instructed how to include “receiving shrimp” as a Critical Control Point (CCP) in their HACCP plans.-Participants were provided HOW labels to include on their product packages-indicating a further level of scrutiny

Sea Grant sponsored ‘HOW’ Certification Training

Further:Directions were provided for sampling, packing and identifying fish products for subsequent analytical verifications

• Wrap fish, oysters and crabs individually, and shrimpas a whole sample

• Wrap in double layers of heavy aluminum foil (dull side touching sample). Avoid any contact or packingin plastic

• Label firm, sample date, sample type (oyster, crab,etc.), harvest location and file number to link withHACCP records

• Store frozen (> 0F) in odor-free area

So long as State/Federal closures exist to prevent oil‐tainted seafood from entering the food supply, you must modify your HACCP plan so that:

Receiving is a Critical Control Point and Harvest location records are required demonstrating that every lot you receive was harvested from open waters.

Screen every lot for obvious oil‐taint,

So long as State/Federal closures exist to prevent oil‐tainted seafood from entering the food supply, you may also:

Periodically collect and store samples, and Periodically have samples analytically screened.

‘HOW’ Certification ‐ Summary