By Laurel Maloy, contributing writer, Food Online
Proper labeling should be part of your HACCP process. The FDA is making sure the means by which to ensure compliance are readily available.
The seafood industry is faced with far different challenges than many others in the food-processing industry, though one primary goal remains the same across the board — food safety. The FDA’s recent release of its Seafood Labeling Learning Module targets those involved in the processing, distribution, or sale of seafood. However, state and federal regulators, as well as consumers, will benefit from the information provided.
Leading up to this latest release, the FDA has published ongoing guidance representing the agency’s current thinking on the appropriate controls by which to regulate the hazards associated with fish and fishery products. In April, 2011, the FDA made public its Fish and Fishery Products Hazards and Controls Guidance document. A correction worth repeating was made on Aug 3, 2011, to Chapter 11: Aquaculture Drugs. The corrected sentence now reads, “Sodium sulfite used in a 1.5 percent solution for five to eight minutes to treat eggs in order to improve their hatchability.” The previous version incorrectly allowed for a 15 percent solution. Such inadvertent errors and industry shop talk can lead to misinformation becoming fact. It can also lead to serious violations with the FDA and the Food Safety Inspection Service (FSIS).
A recent FDA update to recall information highlighted the fact that FSIS is now actively documenting the lack of Hazard Analysis and Critical Control Point (HACCP) procedures, as well as the associated paperwork. FSMA has been in the works for just about four years now and is nearing full implementation, though some processors seem to have been living under a rock. No one should be surprised by what is expected of them. The FDA has been communicative and forthcoming, even going so far as to include those affected the most in the discussions regarding the new rules. The gist is: If you are required to comply, do it!
As a safeguard, it is wise to regularly provide refresher training to all levels of management and personnel involved in getting seafood from the river, lake, ocean, or farm to the plate. Now is also the ideal time to reassess your current HACCP plan, being sure to integrate Critical Control Points (CPP) to ensure proper labeling. This includes knowing your supplier and being confident that the product they are is the product for. The issue of Seafood Species Substitution and Economic Fraud has become so pervasive; the FDA is conducting DNA sampling. Be aware that this is not just an import/export issue. The FDA recently collected samples from 14 states, 15 percent of which were incorrectly labeled. Incorrect labeling considered false or misleading may result in a misbranding recall under section 403(a) of the Federal Food, Drug, and Cosmetic (FD&C) Act. In response to this growing problem, the FDA has also provided the Seafood List, the agency’s guide to acceptable market names for seafood sold within the U.S.
You have the tools at your disposal; it is just a matter of implementation. The FDA’s online support even enables you to download its guidance document chapter by chapter and a Spanish translation is available on the Florida Sea Grant website. Even if your facility is considered a “small” or “very small” business by FDA guidelines, you are required to have a program in place by which to identify potential hazards. You are also required to monitor the program with your first line of defense being the paperwork. Everything you do to ensure a safe product should be documented, to include the methods by which you verify safe labeling and vet your supplier(s). There is really no good excuse for non-compliance and it appears the FSIS is seriously kicking butt and taking names. Is this the kind of attention you want?