Fish and Fishery Products HACCP

Fish and Fishery Products Hazards and Controls Guidance
Fourth Edition APRIL 2011
DEPARTMENT OF HEALTH AND HUMAN SERVICES PUBLIC HEALTH SERVICE FOOD AND DRUG ADMINISTRATION CENTER FOR FOOD SAFETY AND APPLIED NUTRITION OFFICE OF FOOD SAFETY
Fish and Fishery Products Hazards and Controls Guidance

Fourth Edition April 2011 Additional copies may be purchased from: Florida Sea Grant IFAS - Extension Bookstore University of Florida P.O. Box 110011 Gainesville, FL 32611-0011 (800) 226-1764 Or www.ifasbooks.com Or you may download a copy from: http://www.fda.gov/FoodGuidances You may submit electronic or written comments regarding this guidance at any time. Submit electronic comments to http://www.regulations. gov. Submit written comments to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Rm. 1061, Rockville, MD 20852. All comments should be identified with the docket number listed in the notice of availability that publishes in the Federal Register. U.S. Department of Health and Human Services Food and Drug Administration Center for Food Safety and Applied Nutrition (240) 402-2300
April 2011
Table of Contents: Fish and Fishery Products Hazards and Controls Guidance
Guidance for the Industry: Fish and Fishery Products Hazards and Controls Guidance................................ 1
CHAPTER 1: General Information.......................................................................................................19
CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan ..........................................21
CHAPTER 3: Potential Species-Related and Process-Related Hazards..................................................... 29
CHAPTER 4: Pathogens From the Harvest Area ...................................................................................75
CHAPTER 5: Parasites ......................................................................................................................91
CHAPTER 6: Natural Toxins ............................................................................................................ 99
CHAPTER 7: Scombrotoxin (Histamine) Formation ............................................................................. 113
CHAPTER 8: Other Decomposition-Related Hazards .........................................................................153
CHAPTER 9: Environmental Chemical Contaminants and Pesticides......................................................155
CHAPTER 10: Methylmercury .......................................................................................................... 181
CHAPTER 11: Aquaculture Drugs .....................................................................................................183
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum)
as a Result of Time and Temperature Abuse ................................................................. 209
CHAPTER 13: Clostridium botulinum Toxin Formation......................................................................... 245
CHAPTER 14: Pathogenic Bacteria Growth and Toxin Formation as a Result of Inadequate Drying .........293
CHAPTER 15: Staphylococcus aureus Toxin Formation in Hydrated Batter Mixes .................................. 309
CHAPTER 16: Pathogenic Bacteria Survival Through Cooking or Pasteurization ..................................... 315
CHAPTER 17: Pathogenic Bacteria Survival Through Processes Designed to Retain
Raw Product Characteristics .......................................................................................331
CHAPTER 18: Introduction of Pathogenic Bacteria After Pasteurization and
Specialized Cooking Processes ................................................................................. 345
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances
and Prohibited Food and Color Additives ....................................................................355
CHAPTER 20: Metal Inclusion..........................................................................................................385
CHAPTER 21: Glass Inclusion ..........................................................................................................395
APPENDIX 1: Forms....................................................................................................................... 405
APPENDIX 2: Sample Product Flow Diagram ..................................................................................... 411
APPENDIX 3: Critical Control Point Decision Tree ............................................................................... 413
APPENDIX 4: Bacterial Pathogen Growth and Inactivation .................................................................. 417
APPENDIX 5: FDA and EPA Safety Levels in Regulations and Guidance ................................................439
APPENDIX 6: Japanese and Hawaiian Vernacular Names for Fish Eaten Raw ...................................... 443
APPENDIX 7: Bacterial and Viral Pathogens of Greatest Concern in Seafood Processing Public Health Impacts..................................................................................................451
APPENDIX 8: Procedures for Safe and Sanitary Processing and Importing of Fish and Fishery Products ... 455
NOTES:
Guidance for the Industry: Fish and Fishery Products Hazards and Controls Guidance
Fourth Edition This guidance represents the Food and Drug Administrations (FDAs) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call the telephone number listed on the title page of this guidance.
I. INTRODUCTION
This guidance is intended to assist processors of fish and fishery products in the development of their Hazard Analysis Critical Control Point (HACCP) plans. Processors of fish and fishery products will find information in this guidance that will help them identify hazards that are associated with their products, and help them formulate control strategies. The guidance will help consumers and the public generally to understand commercial seafood safety in terms of hazards and their controls. The guidance does not specifically address safe handling practices by consumers or by retail establishments, although many of the concepts contained in this guidance are applicable to both. This guidance is also intended to serve as a tool to be used by federal and state regulatory officials in the evaluation of HACCP plans for fish and fishery products. FDAs guidance documents, including this guidance, do not establish legally enforceable responsibilities. Instead, guidance describe the Agencys current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in Agency guidance means that something is suggested or recommended, but not required.
II. DISCUSSION A. Scope and Limitations

The control strategies and practices provided in this guidance are recommendations to the fish and fishery products industry unless they are required by regulation or statute. This guidance provides information that would likely result in a HACCP plan that is acceptable to FDA. Processors may choose to use other control strategies, as long as they comply with the requirements of the applicable food safety laws and regulations. However, processors that chose to use other control strategies (e.g., critical limits) should scientifically establish their adequacy. The information contained in the tables in Chapter 3 and in Chapters 4 through 21 provide guidance for determining which hazards are reasonably likely to occur in particular fish and fishery products under ordinary circumstances. However, the tables should not be used separately for this purpose. The tables list potential hazards for specific species and finished product types. This information should be combined with the information in the subsequent chapters to determine the likelihood of occurrence. The guidance is not a substitute for the performance of a hazard analysis by a processor of fish and fishery products, as required by FDAs regulations. Hazards not covered by this guidance may be relevant to certain products under certain circumstances. In particular, processors should be alert to new or emerging problems (e.g., the occurrence of natural toxins in fish not previously associated with that toxin).
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Guidance for the Industry: Fish and Fishery Products Hazards and Controls Guidance Fourth Edition
FDA announced its adoption of final regulations to ensure the safe and sanitary processing of fish and fishery products in the Federal Register of December 18, 1995 (60 FR 65096) (hereinafter referred to as the Seafood HACCP Regulation). This guidance, the Seafood HACCP Regulation (21 CFR 123),and the Control of Communicable Diseases regulation (21 CFR 1240) apply to all aquatic animal life, other than birds and mammals, used as food for human consumption. For example, in addition to fresh and saltwater finfish and crustaceans, this guidance applies to echinoderms such as sea cucumbers and sea urchins; reptiles such as alligators and turtles; amphibians such as frogs; and to all mollusks, including land snails (escargot). It also applies to extracts and derivatives of fish, such as eggs (roe), oil, cartilage, and fish protein concentrate. In addition, this guidance applies to products that are mixtures of fish and non-fish ingredients, such as tuna sandwiches and soups. Appendix 8, 123.3, lists the definitions for fish and fishery product used in the Seafood HACCP Regulation. This guidance covers safety hazards associated with fish and fishery products only. It does not cover most hazards associated with nonfishery ingredients (e.g., Salmonella enteritidis in raw eggs). However, where such hazards are presented by a fishery product that contains nonfishery ingredients, control must be included in the HACCP plan ( 123.6). Processors may use the principles included in this guidance for assistance in developing appropriate controls for these hazards. This guidance does not cover the hazard associated with the formation of Clostridium botulinum (C. botulinum) toxin in low-acid canned foods (LACFs) or shelf-stable acidified foods. Mandatory controls for this hazard are contained in the Thermally Processed LowAcid Foods Packaged in Hermetically Sealed Containers regulation (hereinafter referred to as the LACF Regulation, 21 CFR 113) and the Acidified Foods regulation (21 CFR 114). Such controls may be, but are not required to be, included in HACCP plans for these products.
This guidance does not cover the sanitation controls required by the Seafood HACCP Regulation. However, the maintenance of a sanitation monitoring program is an essential prerequisite to the development of a HACCP program. When sanitation controls are necessary for food safety, but are not included in a sanitation monitoring program, they must be included in the HACCP plan (21 CFR 123.6). This guidance does not describe corrective action or verification records, because these records are not required to be listed in the HACCP plan. Nonetheless, such records must be maintained, where applicable, as required in 123.7 and 123.8. Additionally, this guidance does not restate the general requirements for records that are set out in 123.9(a). This guidance does not cover reassessment of the HACCP plan and/or the hazard analysis or review of consumer complaints, as mandated by 123.8. This guidance also does not provide specific guidance to importers of fish and fishery products for the development of required importer verification procedures. However, the information contained in the text, and, in particular, in Appendix 5 (FDA and EPA Safety Levels in Regulations and Guidance), should prove useful for this purpose.
B. Changes in This Edition

Following is a summary of the most significant changes in this edition of the guidance document. In addition to using this summary list, you should carefully review the chapters that are applicable to your product and process. The information contained throughout this guidance document is changed as follows: The elements of a control strategy (i.e., critical limits, monitoring procedures, corrective action procedures, recordkeeping system, and verification procedures) are now consolidated for each control strategy. In most cases, an example of a HACCP plan follows the discussion of each control strategy; A bibliography is now located at the end of most chapters. References have been added and deleted for many of the chapters; Information on the mechanics of completing a HACCP plan, previously repeated in Chapters 4 through 21, is now contained in Chapter 2; Information on the potential public health consequences (i.e., illness or injury) of seafood safety hazards is now provided; Recommendations for specific job positions are no longer listed for Who should perform the monitoring? in Chapters 4 through 21; Additional information is now provided on the performance of accuracy checks and calibration of temperature-indicating devices (e.g., thermometers) and temperaturerecording devices (e.g., recording thermometers); and Reference is no longer made to the intended issuance by FDA of guidance on the development of Sanitation Standard Operating Procedures (SSOPs) and sanitation monitoring or guidance on the development of importer verification procedures. The recommendations in Chapter 2 for conducting a hazard analysis and developing a HACCP plan are changed as follows:
Additional information that is broadly applicable to these tasks, also contained in the companion document to this guidance, HACCP: Hazard Analysis Critical Control Point Training Curriculum, developed by the Seafood HACCP Alliance for Training and Education, is now included. The information in Chapter 3 for identifying potential species-related and process-related hazards is changed as follows: Information is now provided on how illicit species substitution can impact on the identification of potential species-related hazards. The information contained in Table 3-2 (Potential Vertebrate Species-Related Hazards) is changed as follows: There are several scientific name changes to reflect changes in taxonomic conventions; Aholehole (Kuhlia spp.) is no longer listed as having a potential ciguatera fish poisoning (CFP) hazard; Amberjack or Yellowtail, Aquacultured (Seriola lalandi), is no longer listed as having a potential CFP hazard; Barramundi (Lates calcarifer) is now listed as a species that is aquacultured; Basa or Bocourti (Pangasius bocourti) is now listed as a species in U.S. commerce; Bass, Sea (Dicentrarchus labrax) is now listed as a species that is aquacultured; Bata (Labeo bata) is now listed as a species in U.S. commerce; Bream (Abramis brama) is now listed as a species that is aquacultured; Caparari (Pseudoplatystoma tigrinum) is now listed as a market name for a species previously referred to as catfish; Carp (Barbonymus spp., Hypophthalmichthys nobilis, and Carassius carassius) is now listed as a species in U.S. commerce; Carp (Hypophthalmichthys nobilis and
Carassius carassius) is now listed as a species that is aquacultured; Cascarudo (Callichthys callichthys) is now listed as a market name for a species previously referred to as catfish; Characin (Leporinus obtusidens) is now listed as a species in U.S. commerce; Charal (Chirostoma jordani) is now listed as a species in U.S. commerce; Chiring (Apocryptes bato) is now listed as a species in U.S. commerce; Clarias Fish, or Walking Clarias Fish (Clarias anguillaris and Clarias gariepinus), is now listed as a market name for a species previously referred to as catfish, and is now listed as a species that is aquacultured; Cobia (Rachycentron canadum) is now listed as a species that is aquacultured; Coroata (Platynematichthys notatus) is now listed as a market name for a species previously referred to as catfish; Curimbata or Guramata (Prochilodus lineatus) is now listed as a species in U.S. commerce; Cusk-eel (Brotula clarkae) is now listed as a species in U.S. commerce; Dace (Rhinichthys spp.) is now listed as a species that is aquacultured; Eel, Moray (Muraena retifera), is no longer listed as having a potential CFP hazard; Featherback (Notopterus notopterus) is now listed as a species in U.S. commerce; Flathead (Platycephalus conatus) is now listed as a species in U.S. commerce; Flatwhiskered Fish (Pinirampus pirinampu) is now listed as a market name for a species previously referred to as catfish; Frog (Rana spp.) is now listed as having a parasite hazard; Gillbacker, or Gilleybaka (Aspistor parkeri), is now listed as a market name for a species previously referred to as catfish; Goatfish (Mulloidichthys vanicolenis) is now listed as a species in U.S. commerce;
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Goatfish (Mulloidichthys spp., Pseudupeneus spp., and Upeneichthys lineatus) is no longer listed as having a potential CFP hazard; Goby (Neogobius melanostomus) is now listed as a species in U.S. commerce; Grouper (Anyperodon spp., Caprodon schlegelii, and Diplectrum formosum) is no longer listed as having a potential CFP hazard; Grouper, or Coral Grouper (Plectropomus spp.), is now listed as a species in U.S. commerce; Grouper, or Jewfish (Epinephelus itajara), is no longer listed as a having a potential CFP hazard; Herring, or Sea Herring, or Sild (Clupea spp.), is no longer listed as having a potential scombrotoxin (histamine) hazard associated with its roe; Hind (Epinephelus drummondhayi) is no longer listed as having a potential CFP hazard; Jack (Carangoides bartholomaei) is now listed as having a potential CFP hazard; Jack (Selene spp., Urapsis secunda, and Oligoplites saurus) is no longer listed as having a potential CFP hazard; Jack or Crevalle (Alectis indicus) is no longer listed as having a potential CFP hazard; Jack or Roosterfish (Nematistius pectoralis) is no longer listed as having a potential CFP hazard; Jobfish (Aprion spp.) is now listed, and Aprion virescens is deleted because it is included in Aprion spp.; Jobfish (Aphareus spp., Aprion spp., and Pristipomoides spp.) is no longer listed as having a potential scombrotoxin (histamine) hazard; Kahawai (Arripis spp.) is no longer listed as having a potential CFP hazard; Loach (Somileptus gongota) is now listed as a species in U.S. commerce;
Mackerel, narrow-barred Spanish (Scomberomorus commerson), is now listed as having a potential CFP hazard; Menhaden (Brevoortia spp. and Ethmidium maculatum) is now listed as having a potential scombrotoxin (histamine) hazard for products intended for direct human consumption of the muscle and for aqueous components, such as fish protein concentrates, that are to be used as food additives. It is also listed as having a potential environmental chemical contaminant and pesticide hazard when the food products are intended for human consumption, such as oil extracts used as dietary ingredients; Oreo Dory (Neocyttus spp.)is now listed as a species in U.S. commerce; Oreo Dory (Pseudocyttus spp.) is now listed, and Pseudocyttus maculates is deleted because it is included in Pseudocyttus spp; Pangasius or Shortbarbel (Pangasius micronemus) is now listed as a market name for a species previously referred to as catfish; Parrotfish (Bolbometopon spp.) is now listed as a species in U.S. commerce; Piramutaba or Laulao Fish (Brachyplatystoma vaillanti) is now listed as a market name for a species previously referred to as catfish; Puffer (Fugu spp., now Takifugu spp.) is now listed as an aquacultured species; Puffer (Sphoeroides annulatus, Sphoeroides nephelus, Sphoeroides spengleri, and Sphoeroides testudineus, Tetraodon spp.) is now listed as a species in U.S. commerce; Puffer (Fugu spp., now Takifugu spp.) is now listed as having a potential Paralytic Shellfish Poisoning (PSP) hazard; Rita (Rita rita) is now listed as a species in U.S. commerce; Rohu (Labeo rohita) is now listed as a species in U.S. commerce; Sailfish (Istiophorus platypterus) is now listed as a species in U.S. commerce;
Salmon and roe (wild) (freshwater) (Oncorhynchus spp. and Salmo salar) is now listed as having a potential parasite hazard; Scad (Trachurus spp.) is now listed as having a potential scombrotoxin (histamine) hazard; Scad or Horse Mackerel (Trachurus trachurus) is now listed as a market name for a species previously referred to as only scad; Shad (Alosa spp.) is no longer listed as having a potential scombrotoxin (histamine) hazard associated with its roe; Shad, Hilsa (Tenualosa ilisha), is now listed as a species in U.S. commerce; Snapper (Etelis spp. and Pristipomoides spp.) is no longer listed as having a potential CFP hazard; Snapper (Pristipomoides spp.) is no longer listed as having a potential scombrotoxin (histamine) hazard; Snapper (Symphorus nematophorus) is now listed as having a potential CFP hazard; Sorubim, or Surubi (Pseudoplatystoma corruscans), is now listed as a market name for a species previously referred to as catfish; Spearfish (Tetrapturus spp.) is now listed as having a potential scombrotoxin (histamine) hazard; Squirrelfish (Holocentrus spp.) is no longer listed as having a potential CFP hazard; Sutchi or Swai (Pangasius hypophthalmus) are now listed as market names for a species previously referred to as catfish and are now listed as species that are aquacultured; Tang (Naso spp.) is now listed as a species in U.S. commerce; Tang (Tenthis spp.) is no longer listed. Tang (Zebrasoma spp.) is no longer listed as a having a potential CFP hazard; Tigerfish (Datnioides microlepis and Datnioides polota) is now listed as a species in U.S. commerce; Tinfoil (Barbonymus altus) is now listed as a species in U.S. commerce;
Trahira (Hoplias malabaricus) is now listed as a species in U.S. commerce; Triggerfish (Canthidermis sufflamen and Melichthys niger) is no longer listed as having a potential CFP hazard; Tuna (Thunnus spp.) is now listed as a genus that is aquacultured; Turbot (Scophthalmus maximus, now Psetta maxima) is now listed as a species that is aquacultured; Turtle (Malaclemys spp., Chelydra spp., Apalone spp., and Trachemys spp.) is now listed as a species in U.S. commerce; Turtle, Aquacultured (Malaclemys spp., Chelydra spp., Apalone spp., and Trachemys spp.), is now listed as a species in U.S. commerce; Unicornfish (Naso unicornis) is now listed as a species in U.S. commerce; Weakfish (Cynoscion spp.) is now listed as having a potential environmental chemical contaminant and pesticide hazard; Weakfish, or Bangamary (Macrodon ancylodon), is now listed as a market name for a species previously referred to as only weakfish; Whiskered Fish (Arius spp.) is now listed as a market name for a species previously referred to as sea catfish; Whiskered Fish, or Gafftopsail Fish (Bagre marinus), is now listed as a market name for a species previously referred to as sea catfish; Whiskered Fish, or Hardhead Whiskered Fish (Ariopsis felis), is now listed as a market name for a species previously referred to as sea catfish; Wrasse (Cheilinus undulatus) is now listed as a species in U.S. commerce; Yellowtail Amberjack (Seriola lalandi) is now listed as a species that is aquacultured and is no longer listed as having a potential CFP hazard; Zander (Sander lucioperca) is now listed as a species that is aquacultured.
The information contained in Table 3-3 (Potential Invertebrate Species-Related Hazards) is changed as follows: There are several scientific name changes to reflect changes in taxonomic conventions; Abalone (Haliotis spp.) is now listed as having a natural toxin hazard; Conch (Lambis lambis) is now listed as a species in U.S. commerce; Crab, all species are now listed as having a potential environmental chemical contaminant and pesticide hazard; Crab, Blue (Callinectes sapidus), is now listed as a species that is aquacultured; Crab, Japanese Freshwater (Geothelphusa dehaani), is now listed as a species in U.S. commerce; Crab, Sheep (Loxorhynchus grandis), is now listed as a species in U.S. commerce; Crab, Swamp (Scylla serrata), is now listed as a species in U.S. commerce; Murex, or Merex (Murex brandaris), is now listed as a species in U.S. commerce; Oyster (Spondylus spp.) is now listed as a species in U.S. commerce; Sea Squirt (Styela spp.) is now listed as a species in U.S. commerce; Shrimp (Pleoticus muelleri) is now listed as a species in U.S. commerce; Snail, Moon (Polinices spp.), is now listed as a species in U.S. commerce; Whelk (Busycon spp.) is now listed as having a potential natural toxin hazard. The information contained in Table 3-4 (Potential Process-Related Hazards) is changed as follows: Fish oil is now listed as a food category; Changes have been made to be consistent with changes in Chapters 13, 16, and 17.
The recommendations in Chapter 4 for the control of pathogens from the harvest area are changed as follows: Hydrostatic pressure, individual quick freezing (IQF) with extended storage, and irradiation are now identified as processes that are designed to retain raw product characteristics and that can be used to reduce Vibrio vulnificus (V. vulnificus) and Vibrio parahaemolyticus (V. parahaemolyticus) to non-detectable levels; It is now recognized that a tag on a container of shellstock (in-shell molluscan shellfish) received from another dealer need not identify the harvester; Critical limits relating to control of pathogen growth prior to receipt of raw molluscan shellfish by the primary processor are now linked to monitoring the time that the shellfish are exposed to air (i.e., by harvest or receding tide) rather than to the time that the shellfish are harvested; Reference is now made to the role of the Federal, state, tribal, territorial and foreign government shellfish control authorities in determining whether the hazard of V. parahaemolyticus is reasonably likely to occur in raw molluscan shellfish and in the development of a V. parahaemolyticus control plan that will dictate, at least to some extent, the nature of the controls for this pathogen in HACCP plans; The control strategy examples are restructured for improved clarity: one for source controls (e.g., tagging, labeling, source waters, harvester licensure, and raw consumption advisory) and a second for time from harvest to refrigeration controls. The recommendations in Chapter 5 for the control of parasites are changed as follows: It is now recognized that the parasite hazard may be reasonably likely to occur in fish raised in freshwater containing larvae of pathogenic liver, lung and intestinal flukes because these parasites enter the fish through the skin rather than in the food.
The recommendations in Chapter 6 for the control of natural toxins are changed as follows: Azaspiracid Poisoning (AZP) is now described, and an action level of 0.16 mg/kg is now provided; Information regarding potential molluscan shellfish toxins, pectenotoxins (PTXs) and yessotoxins (YTXs), is now provided, although FDA has no specific expectations for control of YTXs; An example of a HACCP plan is now provided for control of natural toxins in molluscan shellfish; The action level for Diarrhetic Shellfish Poisoning (DSP) is now listed as 0.16 ppm total okadaic acid equivalents; Action levels for CFP are now listed as 0.01 ppb for Pacific ciguatoxin and 0.1 ppb for Caribbean ciguatoxin; It is now noted that in 2008, FDA advised against the consumption of lobster tomalley because unusually high levels of PSP toxins were detected in that organ in lobsters caught in the waters of New England during a red tide event; CFP is now described as being associated with consumption of toxin-contaminated fish found in tropical or subtropical areas around the world between 35 north latitude and 35 south latitude, particularly the Caribbean Sea, Pacific Ocean, and Indian Ocean and in the Flower Garden Banks area in the northern Gulf of Mexico; Gempylotoxin is now described as being associated with orange roughy (Hoplostethus atlanticus) and oreo dory (Allocyttus spp., Pseudocyttus spp. and Neocyttus spp.) although in lesser amounts than escolar. The recommendations in Chapter 7 for the control of scombrotoxin (histamine) formation are changed as follows: Information is now provided about the potential for scombrotoxin (histamine)
formation in products like tuna salad that have been allowed to become recontaminated and then subjected to time and temperature abuse; The recommendations regarding on-board chilling of scombrotoxin-forming species of fish are now listed as follows: Fish exposed to air or water temperatures above 83F (28.3C) should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible during harvest, but not more than 6 hours from the time of death, or
The lower anterior portion of the loin is now identified as the best place to collect a sample from large fish for histamine analysis; Fermenting, pickling, smoking, and drying are now identified as likely critical control points (CCPs) for this hazard; When fish are checked for internal temperature at off-loading, it is now recommended that:
Fish exposed to air and water temperatures of 83F (28.3C) or less should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible during harvest, but not more than 9 hours from the time of death, or Fish that are gilled and gutted before chilling should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible during harvest, but not more than 12 hours from the time of death, or Fish that are harvested under conditions that expose dead fish to harvest waters of 65F (18.3C) or less for 24 hours or less should be placed in ice, refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than the time limits listed above, with the time period starting when the fish leave the 65F (18.3C) or less environment;
For fish held iced or refrigerated (not frozen) onboard the vessel and offloaded from the vessel by the processor 24 or more hours after death, the internal temperature should be 40F (4.4C) or below, OR For fish held iced or refrigerated (not frozen) onboard the vessel and offloaded from the vessel by the processor from 15 to less than 24 hours after death, the internal temperature should be 50F (10C) or below, OR For fish held iced or refrigerated (not frozen) onboard the vessel and offloaded from the vessel by the processor from 12 to less than 15 hours after death, the internal temperature should be 60F (15.6C) or below;
The recommended level at which a lot should be rejected based on sensory examination when 118 fish are examined is now corrected to be no more than 2 fish to coincide with the goal of less than 2.5% decomposition in the lot; It is now recommended that the number of fish subjected to sensory examination be increased if there is likely to be greater than normal variability in the lot, and that only one species constitute a lot for sampling purposes; When histamine analysis is performed as a corrective action, it is now recommended that any fish found to exceed the internal
Cautions are now provided that handling practices and processing controls that are recommended as suitable for preventing the formation of scombrotoxin may not be sufficient to prevent fish from suffering quality or shelf-life degradation (i.e., decomposition) in a way that may otherwise render it adulterated under the Federal Food, Drug, and Cosmetic Act;
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temperature at receiving critical limit be included in the sample; When the sensory critical limit has not been met, it is now recommended that the processor perform histamine analysis of a minimum of 60 fish, collected representatively from throughout the lot, including all fish in the lot that show evidence of decomposition, and reject the lot if any fish are found with a histamine level greater than or equal to 50 ppm; Subdividing and retesting for histamine is no longer recommended after an initial failed histamine test; It is now recommended that employees who conduct sensory screening receive adequate training; It is now recommended that for shipments of scombrotoxin-forming species received under ice on open-bed trucks be checked for both sufficiency of ice and internal product temperature; It is now recommended that shipments of scombrotoxin-forming species received under gel packs be checked for both adequacy of gel packs and internal product temperature; It is now recommended that if only the internal temperature of fish is checked at receipt by a secondary processor because the transit time is no more than 4 hours, calculation of transit time should include all time outside a controlled temperature environment; It is now recommended that if only the internal temperature of fish is checked at receipt by a secondary processor because the transit time is no more than 4 hours, a temperature-indicating device (e.g., a thermometer) should be used to determine internal product temperatures in a minimum of 12 fish, unless there are fewer than 12 fish in a lot, in which case all of the fish should be measured; When checks of the sufficiency of ice or chemical cooling media, such as gel packs,
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or internal product temperatures are used at receipt of fish from another processor, it is now recommended that the number of containers examined and the number of containers in the lot be recorded; Control of scombrotoxin (histamine) formation during processing and storage are now provided as separate control strategy examples, and examples of HACCP plans are now provided for both strategies; The extended exposure times during processing (more than 12 hours, cumulatively, if any portion of that time is at temperatures above 70F (21.1C); or more than 24 hours, cumulatively, as long as no portion of that time is at temperatures above 70F (21.1C)) previously recommended for fish that have been previously frozen are now also recommended for fish that have been previously heat treated sufficiently to destroy scombrotoxin-forming bacteria and are subsequently handled in a manner where there is an opportunity for recontamination with scombrotoxin-forming bacteria; It is now acknowledged that it may be possible to control scombrotoxin formation during unrefrigerated processing using a critical limit that is time of exposure only (i.e., no temperature component), if it is developed with an assumption that worstcase temperatures (e.g., in excess of 70F (21.1C)) may occur; Chemical coolants (e.g., gel packs) are no longer recommended for control of temperature during in-plant storage; For control of time and temperature during refrigerated storage, it is now noted that critical limits that specify a cumulative time and temperature of exposure to temperatures above 40F (4.4C) are not ordinarily suitable because of the difficulty in determining when specific products have entered and left the cooler and the time and temperature exposures to which they were subjected. However, there may be circumstances where
this approach is suitable. It is also noted that minor variations in cooler temperature measurements can be avoided by submerging the sensor for the temperaturerecording device in a liquid that mimics the characteristics of the product; High-temperature alarms are no longer recommended for monitoring temperatures in coolers or processing areas; When the adequacy of ice is established as the critical limit for refrigerated storage, it is now recommended that monitoring be performed with sufficient frequency to ensure control rather than at least twice per day. The recommendations in Chapter 8 related to other decomposition-related hazards are changed as follows: It is now noted that FDA has received consumer complaints concerning illnesses associated with the consumption of decomposed salmon, attributable to the production in the fish of toxins other than histamine (e.g., biogenic amines, such as putrescine and cadaverine); It is now noted that there are also some indications that chemicals formed when fats and oils in foods oxidize may contribute to long-term detrimental health effects. The recommendations in Chapter 9 for the control of environmental chemical contaminants and pesticides are changed as follows: Toxic element guidance levels for arsenic, cadmium, lead, and nickel are no longer listed; Tolerance levels for endothall and its monomethyl ester in fish and carbaryl in oysters are now listed; The collection of soil samples from aquaculture production sites is no longer listed as a preventive measure; An example of a HACCP plan is now provided for control of environmental chemical contaminants in molluscan shellfish;
When testing for environmental chemical contaminants and pesticides is used as the control measure, it is now recommended that the adequacy of the testing methods and equipment be verified periodically (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent method, or by analyzing proficiency samples). Chapter 10, which covers the control of methylmercury, has been rewritten to acknowledge that FDA is receiving comments on a draft quantitative risk assessment for methylmercury, which may result in a reassessment of its risk management strategies. The recommendations in Chapter 11 for the control of aquaculture drugs are changed as follows: The potential for this hazard to occur during transportation of live fish is now recognized, and recommended controls are provided; An explanation of extra-label use of drugs is now provided, and a list of drugs prohibited for extra-label use is now listed; FDA high enforcement priority aquaculture drugs are now listed; Aquaflor Type A Medicated Article (florfenicol) is now listed as an approved drug for catfish and salmonids; Aquaflor CA1 is now listed as an approved drug for catfish or in fingerling to food fish as the sole ration for 10 consecutive days. 35% PEROX-AID (hydrogen peroxide) is now listed as an approved drug for freshwater-reared salmonids and freshwaterreared cool water finfish and channel catfish; Terramycin 200 for Fish (oxytetracycline dihydrate) Type C, is now listed as an approved drug for catfish, salmonids; and lobster; OxyMarine, Oxytetracycline HCl Soluble Powder-343, Terramycin-343, TETROXY Aquatic is now listed as an approved drug for all finfish fry and fingerlings as an aid in identification;
10
Quarterly raw material, in-process, or finished product testing is now recommended as a verification step for control strategies involving review of suppliers certificates at receipt of raw materials, review of records of drug use at receipt of raw materials, and on-farm visits; When testing for aquaculture drugs is used as the control measure, it is now recommended that the adequacy of the testing methods and equipment be verified periodically (e.g., by comparing results with those obtained using an AOAC or equivalent method, or by analyzing proficiency samples). The recommendations in Chapter 12 for the control of pathogenic bacteria growth and toxin formation (other than C. botulinum) as a result of time and temperature abuse are changed as follows: It is now recognized that V. vulnificus, V. parahaemolyticus, and Vibrio cholarae non-O1 and non-0139 are generally associated with marine and estuarine species of fish and may not be reasonably likely to occur in freshwater species or non-fishery ingredients, unless they have been crosscontaminated; It is now clarified that products that are partially cooked to set the batter or breading or stabilize the product shape (e.g., fish balls, shrimp egg rolls, and breaded fish portions) are not considered to be ready to eat; Information is now provided on the determination of CCPs for products that are a combination of raw, ready-to-eat and cooked, ready-to-eat fishery ingredients; Control of time and temperature abuse at receipt, during cooling after cooking, during unrefrigerated processing, and during refrigerated storage and processing are now provided as four separate control strategy examples. Examples of HACCP plans are now provided for all four strategies;
For control of transit conditions at receipt of ready-to-eat fish or fishery products delivered refrigerated (not frozen), it is now recommended that all lots be accompanied by transportation records that show that the fish were held at or below an ambient or internal temperature of 40F (4.4C) throughout transit or, for transit times of 4 hours or less, that the internal temperature of the fish at time of receipt was at or below 40F (4.4C); For control of time and temperature during refrigerated storage and refrigerated processing, it is now noted that critical limits that specify a cumulative time and temperature of exposure to temperatures above 40F (4.4C) are not ordinarily suitable because of the difficulty in determining when specific products have entered and left the cooler and the time and temperature exposures to which they were subjected. However, there may be circumstances where this approach is suitable. It is also noted that minor variations in cooler temperature measurements can be avoided by submerging the sensor for the temperaturerecording device in a liquid that mimics the characteristics of the product; It is now recommended that if only the internal temperature of the fishery product is checked at receipt, because the transit time is no more than 4 hours, calculation of transit time should include all time outside a controlled temperature environment; It is now recommended that if only the internal temperature of product is checked at receipt by a secondary processor because the transit time is no more than 4 hours, a temperature-indicating device (e.g., a thermometer) should be used to determine internal product temperatures in a minimum of 12 containers (e.g., cartons and totes), unless there are fewer than 12 containers in a lot, in which case all of the containers should be measured;
11
When checks of the sufficiency of ice or chemical cooling media, such as gel packs, or internal product temperatures are used at receipt of fish from another processor, it is now recommended that the number of containers examined and the number of containers in the lot be recorded; Chemical coolants (e.g., gel packs) are no longer recommended for control of temperature during in-plant storage; Recommended cumulative exposure times and temperatures (i.e., critical limits) are now listed as follows:
For raw, ready-to-eat products:
Alternatively, the product is held at ambient air temperatures below 50F (10C) throughout processing;
For cooked, ready-to-eat products:
If at any time the product is held at internal temperatures above 80F (27.2C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 1 hour (3 hours if S. aureus is the only pathogen of concern), OR Alternatively, if at any time the product is held at internal temperatures above 80F (26.7C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 1 of those hours is above 70F (21.1C),
If at any time the product is held at internal temperatures above 70F (21.1C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 2 hours (3 hours if Staphylococcus aureus (S. aureus) is the only pathogen of concern), OR Alternatively, exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 2 of those hours are between 70F (21.1C) and 135F (57.2C),
OR
If at any time the product is held at internal temperatures above 70F (21.1C), but never above 80F (26.7C), exposure time at internal temperatures above 50F (10C) should be limited to 2 hours (3 hours if S. aureus is the only pathogen of concern), OR Alternatively, if the product is never held at internal temperatures above 80F (26.7C), exposure times at internal temperatures above 50F (10C) should be limited to 4 hours, as long as no more than 2 of those hours are above 70F (21.1C),
OR
If the product is held at internal

temperatures above 50F (10C), but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern), The product is held at internal
temperatures below 50F (10C), OR
OR
OR
If the product is held at internal temperatures above 50F (10C), but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern),
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OR
The product is held at internal

temperatures below 50F (10C), OR Alternatively, the product is held at ambient air temperatures below 50F (10C) throughout processing;
spoilage organisms have been eliminated or significantly reduced by such processes as high pressure processing and (2) refrigeration is the sole barrier to toxin formation. The generally recommended 10,000 cc/m2/24 hours at 24C oxygen transmission rates may not be suitable in this case; High-temperature alarms are no longer recommended for monitoring temperatures in coolers or processing areas; Chemical coolants (e.g., gel packs) are no longer recommended for control of temperature during in-plant storage; When the adequacy of ice is established as the critical limit for refrigerated storage, it is now recommended that monitoring be performed with sufficient frequency to ensure control rather than at least twice per day; It is now recommended that a water phase salt level of 20% be achieved in shelf-stable, reduced oxygen packaged products in which salt is the only barrier to pathogenic bacteria growth and toxin formation; It is now recommended that monitoring shipments received under gel packs include both adequacy of gel packs and internal product temperature; It is now recommended that if only the internal temperature of the fishery product is checked at receipt, because the transit time is no more than 4 hours, calculation of transit time should include all time outside a controlled temperature environment; It is now recommended that if only the internal temperature of product is checked at receipt by a secondary processor because the transit time is no more than 4 hours, a temperature-indicating device (e.g., a thermometer) should be used to determine internal product temperatures in a minimum of 12 containers (e.g., cartons and totes), unless there are fewer than 12 containers in a lot, in which case all of the containers should be measured;
High-temperature alarms are no longer recommended for monitoring temperatures in coolers or processing areas; When the adequacy of ice is established as the critical limit for refrigerated storage, it is now recommended that monitoring be performed with sufficient frequency to ensure control rather than at least twice per day; It is now recommended that monitoring shipments received under gel packs include both adequacy of gel packs and internal product temperature. The recommendations in Chapter 13 for the control of C. botulinum toxin formation are changed as follows: Information is now provided on TimeTemperature Indicator (TTI) performance and suitability; A control strategy is now provided for application of TTIs on each of the smallest package units (i.e., the unit of packaging that will not be distributed any further, usually consumer or end-user package), where refrigeration is the sole barrier to prevent toxin formation; It is no longer recommended that consideration be given to whether the finished product will be stored and distributed frozen when determining whether the hazard is significant. A control strategy is now provided to ensure that frozen products are properly labeled when freezing is the sole barrier to prevent toxin formation; Processors are now advised to take particular care in determining the safety of a packaging material for a product in which (1) the
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A control strategy example is now provided for receipt by a secondary processor of refrigerated reduced oxygen packaged products that may be stored and further distributed or used as an ingredient for further processing; It is now clarified that brining time should be monitored during the processing of smoked fish; It is now recommended that brine be treated to minimize microbial contamination or be periodically replaced as a good manufacturing practice control. The recommendations in Chapter 14 for the control of pathogenic bacteria growth and toxin formation as a result of inadequate drying are changed as follows: It is no longer recommended that consideration be given to whether the finished product will be stored and distributed frozen (in the case of reduced oxygen packaged products) or refrigerated (in the case of aerobically packaged products) when determining whether the hazard is significant. A control strategy to ensure that refrigerated dried products are properly labeled when refrigeration is the sole barrier to toxin formation is now provided. A control strategy to ensure that frozen products are properly labeled when freezing is the sole barrier to toxin formation is now provided in Chapter 13. The recommendations in Chapter 15 for the control of S. aureus toxin formation in hydrated batter mixes are changed as follows: The number of S. aureus organisms normally needed to produce toxin is now listed as 500,000 to 1,000,000 per gram; High-temperature alarms are no longer recommended for monitoring temperatures in processing areas. The recommendations in Chapter 16 for the control of pathogenic bacteria survival through cooking are changed as follows:
The separate chapters that previously covered pathogen survival through cooking and pathogen survival through pasteurization are now combined; Pasteurization is now defined as a heat treatment applied to eliminate the most resistant pathogen of public health concern that is reasonably likely to be present in food; Information is now provided for an option to monitor End-Point Internal Product Temperature, instead of continuous time and temperature monitoring during cooking or pasteurization, when a scientific study has been conducted to validate that it will provide a 6D process for the target pathogen; For surimi-based products, soups, or sauces, the following pasteurization process is now recommended: a minimum cumulative, total lethality of F194F (F90C) = 10 minutes, where z = 12.6F (7C) for temperatures less than 194F (90C), and z = 18F (10C) for temperatures above 194F (90C); For dungeness crabmeat, the following pasteurization process is now recommended: a minimum cumulative total lethality of F194F (F90C) = 57 minutes, where z = 15.5F (8.6C); Information concerning levels of Listeria monocytogenes (L. monocytogenes) in foods is now updated based on the final FDA/U.S. Department of Agriculture L. monocytogenes risk assessment. Chapter 17 is a new chapter that contains guidance for the control of pathogen survival through processes designed to retain raw product characteristics, including high hydrostatic pressure processing, mild heat processing, IQF with extended frozen storage, and irradiation. At present, the chapter applies exclusively to the processing of molluscan shellfish products for which there is a desire to retain raw product characteristics. However, these technologies may have other applications as well.
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The recommendations in Chapter 18 for the control of the introduction of pathogenic bacteria after pasteurization and specialized cooking processes are changed as follows: It is no longer recommended that consideration be given to whether the finished product will be stored and distributed frozen when determining whether the hazard is significant. A control strategy to ensure that frozen products are properly labeled when freezing is the sole barrier to prevent C. botulinum toxin formation is now provided in Chapter 13. The recommendations in Chapter 19 for the control of undeclared food allergens and intolerance substances and prohibited food and color additives are changed as follows: Additional explanatory material on food allergens is now included, with information on the Food Allergen Labeling and Consumer Protection Act of 2004 and its impact on preventive controls for allergens; Additional information is now provided on the factors to be considered in judging when the presence of certain food intolerance substances and prohibited food and color additives is or is not reasonably likely to occur, such as the historical use of the substance and the expected level of sulfiting agent in the formulated finished food; Additional information is now provided on regulatory requirements for food additives. Corrective actions are now expanded to include steps that should be taken to regain control over the operation after a critical limit deviation, for consistency with guidance in the other chapters; It is now recommended that finished product labels be checked at time of labeling rather than at time of label receiving; It is now recommended that finished product testing be included as a verification step when review of suppliers labeling is used as a monitoring procedure for the presence of sulfiting agents;
The use of sulfiting agents in conch meat is now identified as a reasonably likely hazard. The recommendations in Chapter 20 for the control of metal inclusion are changed as follows: Foreign objects less than 0.3 inch (7 mm) are now identified as having a potential for causing trauma or serious injury to persons in special risk groups, such as infants, surgery patients, and the elderly; Additional information on calibration and validation of electronic metal detectors is now provided; Wire mesh baskets are no longer used as an example of an unlikely source of metal fragments; The recommended critical limit for the metal detection or separation control strategy has been expanded to read, All product passes through an operating metal detection or separation device, and No detectable metal fragments in a product passing through the metal detection or separation device. As a result, the recommended monitoring procedures are also expanded so that they now are designed to also ensure that the processes are in place and operating; It is now recommended that when metal fragments are found in a product by a metal detector or separated from the product stream by magnets, screens, or other devices, the source of the fragment is located and corrected. The recommendations in Chapter 21 for the control of glass inclusion are changed as follows: This chapter is no longer identified as a draft; The use of x-ray detection devices is no longer recommended as a reliable method for controlling glass inclusion; The recommended critical limit for the glass container cleaning and visual inspection control strategy has been expanded to read, All container pass through an operating glass container inspection or cleaning
15
process, and No detectable glass fragments in glass containers passing the CCP. As a result, the recommended monitoring procedures are also expanded so that they now are designed to also ensure that the processes are in place and operating; The monitoring procedures for the glass container cleaning and visual inspection control strategy now include a recommendation that a representative sample of the cleaned or inspected containers be examined at the start of processing, every 4 hours during processing, at the end of processing, and after any breakdowns; It is now recommended that monitoring for the presence of glass be performed at the start of each production day and after each shift change. It is now recommended that a representative sample of cleaned or inspected glass containers be examined daily, at the start of processing, every 4 hours during processing, at the end of processing, and after any breakdowns. The Hazard Analysis Worksheet in Appendix 1 has been changed for consistency with the worksheet in the HACCP: Hazard Analysis Critical Control Point Training Curriculum, developed by the Seafood HACCP Alliance for Training and Education. The recommendations in Appendix 4 for bacterial pathogen growth and inactivation are changed as follows: Recommended summary cumulative exposure times and temperatures are now listed as described above for Chapter 12; The maximum water phase salt level for growth of Campylobacter jejuni is now listed as 1.7%; The maximum level of acidity (pH) for growth of pathogenic strains of Escherichia coli (E. coli) is now listed as 10; The maximum recommended cumulative
exposure times for Bacillus cereus are now listed as follows: 5 days at temperatures of 39.2 to 43F (4 to 6C); 1 day at temperatures of 44 to 59F (7 to 15C); 6 hours at temperatures of 60 to 70F (16 to 21C); and 3 hours at temperatures above 70F (21C); The maximum cumulative exposure times for E. coli, Salmonella, and Shigella spp. are now listed as follows: 2 days for temperatures from their minimum growth temperature 41.4 to 50F (10C); 5 hours for temperatures of 51 to 70F (11 to 21C); and 2 hours for temperatures above 70F (21C); The maximum cumulative exposure times for Listeria monocytogenes are now listed as follows: 7 days for temperatures of 31.3 to 41F (-0.4 to 5C); 1 day for temperatures of 42 to 50F (6 to 10C); 7 hours for temperatures of 51 to 70F (11 to 21C); 3 hours for temperatures of 71 to 86F (22 to 30C); and 1 hour for temperatures above 86F (30C); The maximum cumulative exposure times for Vibrio cholerae, V. vulnificus, and V. parahaemolyticus are now listed as follows: 21 days for temperatures from their minimum growth temperature to 50F (10C); 6 hours for temperatures of 51 to 70F (11 to 21C); 2 hours at temperatures of 71 to 80F (22 to 26.7C); and 1 hour at temperatures above 80F (26.7C), with the last temperature range applying only to cooked, ready-to-eat products. The safety levels listed in Appendix 5, Table A-5, FDA and EPA Safety Levels in Regulations and Guidance, are changed as follows: Toxic element guidance levels for arsenic, cadmium, lead, and nickel are no longer listed; Tolerance levels for endothall and its monomethyl ester in fish and carbaryl in oysters are now listed; A tolerance level for Florfenicol in channel catfish and freshwater-reared salmonids is now listed;
16
The tolerance for oxytetracycline is now corrected to apply to all finfish and lobster; The tolerance for sulfamerazine is now corrected to apply to trout; A list of drugs prohibited for extra-label use is now provided; V. parahaemolyticus and V. vulnificus levels are now listed for post-harvest processed molluscan shellfish. Appendix 6 no longer lists food allergens. It now contains a table of Japanese and Hawaiian vernacular names and their corresponding U.S. market names. Appendix 7 no longer lists the bibliography. It now contains information regarding the public health impacts of bacterial and viral pathogens of greatest concern in seafood processing.
17
NOTES:
18
CHAPTER 1: General Information

This guidance represents the Food and Drug Administrations (FDAs) current thinking on this topic. It does not create or confer any rights for or on any person and does not operate to bind FDA or the public. You can use an alternative approach if the approach satisfies the requirements of the applicable statutes and regulations. If you want to discuss an alternative approach, contact the FDA staff responsible for implementing this guidance. If you cannot identify the appropriate FDA staff, call the telephone number listed on the title page of this guidance.
THE GUIDANCE
This is the fourth edition of the Food and Drug Administrations (FDAs) Fish and Fishery Products Hazards and Controls Guidance. This guidance relates to FDAs Fish and Fishery Products regulation (called the Seafood HACCP Regulation, 21 CFR 123, in this guidance document) and the Control of Communicable Diseases regulation, 21 CFR 1240, that require processors of fish and fishery products to develop and implement HACCP systems for their operations. Those final regulations were published in the Federal Register on December 18, 1995, and became effective on December 18, 1997. The codified portion of the regulations is included in Appendix 8. This guidance is being issued as a companion document to HACCP: Hazard Analysis Critical Control Point Training Curriculum, which was developed by the Seafood HACCP Alliance for Training and Education. The Alliance is an organization of federal and state regulators, including FDA, academia, and the seafood industry. FDA recommends that processors of fish and fishery products use the two documents together in the development of a HACCP system. This guidance document will be maintained on the FDA.GOV website, which should be consulted for subsequent updates. Copies of the training document may be purchased from: Florida Sea Grant IFAS - Extension Bookstore University of Florida P.O. Box 110011 Gainesville, FL 32611-0011 (800) 226-1764 Or www.ifasbooks.com Or you may download a copy from: http://www.fda.gov/FoodGuidances
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NOTES:
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CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

THE HACCP PLAN FORM

This guidance document is designed to walk you through a series of 18 steps that will yield a completed Hazard Analysis Critical Control Point (HACCP) plan. A blank HACCP Plan Form is contained in Appendix 1. Note that this is a twopage form, with the second page to be used if your process has more critical control points than can be listed on one page. The Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products regulation, 21 CFR 123 (hereinafter, the Seafood HACCP Regulation), requires that you prepare a HACCP plan for fish and fishery products that you process if there are significant food safety hazards associated with the products. The regulation does not require that you use the form included in Appendix 1. However, using this standardized form may help you develop an acceptable plan and will expedite regulatory review. A separate HACCP plan should be developed for each location where fish and fishery products are processed and for each kind of fish and fishery product processed at that location. You may group products together in a single HACCP plan if the food safety hazards and controls are the same for all products in the group.
THE HAZARD ANALYSIS WORKSHEET

In order to complete the HACCP Plan Form, you will need to perform a process called hazard analysis. The Seafood HACCP Regulation requires that all seafood processors conduct, or have conducted for them, a hazard analysis to determine whether there are food safety hazards that are reasonably likely to occur in their product and to the preventive measures that a processor can apply to control those hazards (21 CFR 123.6(a)). FDA has found that the use of a standardized Hazard Analysis Worksheet assists with this process. A blank Hazard Analysis Worksheet is contained in Appendix 1. Note that this is also a two-page form, with the second page to be used if your process has more processing steps than can be listed on one page. The Seafood HACCP Regulation does not require that the hazard analysis be kept in writing. However, FDA expects that a written hazard analysis will be useful when you perform mandatory HACCP plan reassessments and when you are asked by regulators to justify why certain hazards were or were not included in your HACCP plan.
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THE STEPS
Following is a list of the steps that this guidance uses in HACCP plan development: Preliminary Steps Provide general information;
PRELIMINARY STEPS
STEP 1: Provide general information.
Record the name and address of your processing facility in the spaces provided on the first page of both the Hazard Analysis Worksheet and the HACCP Plan Form (Appendix 1).
Describe the food;
Describe the method of distribution and storage;

Identify the intended use and consumer;
Develop a flow diagram.
STEP 2: Describe the food.

Identify the market name or Latin name (species) of the fishery component(s) of the product. Examples: Tuna (Thunnus albacares); Shrimp (Pandals spp.); Jack mackerel (Trachurus spp.). Fully describe the finished product food. Examples: Individually quick frozen, cooked, peeled
shrimp;
Hazard Analysis Worksheet Set up the Hazard Analysis Worksheet;
Identify potential species-related hazards; Identify potential process-related hazards; Understand the potential hazard; Determine whether the potential hazard is significant;
Identify critical control points.
HACCP Plan Form Set up the HACCP Plan Form; Set critical limits; What,
How,
Frequency,
Who;
Establish monitoring procedures:
Fresh tuna steaks; Frozen, surimi-based, imitation king crab

legs;
Fresh, raw drum, in-the-round; Raw shrimp, in-shell; Raw, shucked clams; Fresh seafood salad, with shrimp and blue crabmeat;
Establish corrective action procedures;

Establish a recordkeeping system; Establish verification procedures.
Frozen, breaded pollock sticks; Frozen crab cakes. Describe the packaging type. Examples:
Vacuum-packaged plastic bag; Aluminum can; Bulk, in wax-coated paperboard box; Plastic container with snap lid.
Record this information in the space provided on the first page of both the Hazard Analysis Worksheet and the HACCP Plan Form.
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STEP 3: Describe the method of distribution and storage.

Identify how the product is distributed and stored after distribution. Examples: Stored and distributed frozen; Distributed on ice and then stored under
refrigeration or on ice.
STEP 5: Develop a flow diagram.

The purpose of the diagram is to provide a clear, simple description of the steps involved in the processing of your fishery product and its associated ingredients as they flow from receipt to distribution. The flow diagram should cover all steps in the process that your firm performs. Receiving and storage steps for each of the ingredients, including non-fishery ingredients, should be included. The flow diagram should be verified on-site for accuracy. Figure A-1 (Appendix 2) is an example of a flow diagram.
Record this information in the space provided on the first page of both the Hazard Analysis Worksheet and the HACCP Plan Form.
STEP 4: Identify the intended use and consumer.

Identify how the product will be used by the end user or consumer. Examples: To be heated (but not fully cooked) and
served;
HAZARD ANALYSIS WORKSHEET

STEP 6: Set up the Hazard Analysis Worksheet.
Record each of the processing steps (from the flow diagram) in Column 1 of the Hazard Analysis Worksheet.
To be eaten with or without further cooking; To be eaten raw or lightly cooked; To be fully cooked before consumption; To be further processed into a heat and serve product.
STEP 7: Identify the potential species-related hazards.

Biological, chemical, and physical hazards can affect the safety of fishery products. Some food safety hazards are associated with the product (e.g., the species of fish, the way in which the fish is raised or caught, and the region of the world from which the fish originates). These hazards are introduced outside the processing plant environment before, during, or after harvest. This guidance refers to these as species related hazards. Other food safety hazards are associated with the way in which the product is processed (e.g., the type of packaging, the manufacturing steps, and the kind of storage). These hazards are introduced within the processing plant environment. This guidance refers to these as process-related hazards. They are covered in Step 8. Find in Table 3-2 (Chapter 3) or Table 3-3 (Chapter 3) the market name (Column 1) or
Identify the intended consumer or user of the product. The intended consumer may be the general public or a particular segment of the population, such as infants or the elderly. The intended user may also be another processor that will further process the product. Examples: By the general public; By the general public, including some
distribution to hospitals and nursing homes;
By another processing facility. Record this information in the space provided on the first page of both the Hazard Analysis Worksheet and the HACCP Plan Form.
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Latin name (Column 2) of the product that you identified in Step 2. Use Table 3-2 for vertebrates (animals with backbones) such as finfish. Use Table 3-3 for invertebrates (animals without backbones) such as shrimp, oysters, crabs, and lobsters. Determine whether the species has a potential species-related hazard by looking for a mark (or one- or three-letter codes for a natural toxin) in the right-hand columns of the table. If it does, record the potential speciesrelated hazard(s) in Column 2 of the Hazard Analysis Worksheet, at every processing step. Tables 3-2 and 3-3 include the best information currently available to FDA concerning hazards that are specific to each species of fish. You should use your own expertise, or that of outside experts, as necessary, to identify any hazards that may not be included in the table (e.g., those that may be new or unique to your region). You may already have effective controls in place for a number of these hazards as part of your routine or traditional handling practices. The presence of such controls does not mean that the hazard is not significant. The likelihood of a hazard occurring should be judged in the absence of controls. For example, the fact that scombrotoxin (histamine) development in a particular species of fish has not been noted may be the result of (1) the inability of the fish to produce histamine or (2) the existence of controls that are already in place to prevent its development (e.g., harvest vessel time and temperature controls). In the first case, the hazard is not reasonably likely to occur. In the second case, the hazard is reasonably likely to occur, and the controls should be included in the HACCP plan.
You may need to include potential hazards for more than one finished product food category from Table 3-4, which will happen when your product fits more than one description. For example, if you cook shrimp and use it to prepare a finished product salad, you should look at both the cooked shrimp and the salads prepared from ready-to-eat fishery products categories in Table 3-4, Column 1. Potential hazards from both finished product food categories apply to your product and should be listed in Column 2 of the Hazard Analysis Worksheet. Table 3-4 includes the best information currently available to FDA concerning hazards that are related to specific processing techniques. You should use your own expertise, or that of outside experts as necessary, to identify any hazards that may not be included in the table (e.g., those that are new or unique to your physical plant, equipment, or process).
STEP 9: Understand the potential hazard.

Consult the hazards and controls chapters of this guidance document (Chapters 4 through 7, 9, and 11 through 21) for each of the potential hazards that you entered in Column 2 of the Hazard Analysis Worksheet. These chapters offer guidance for completing your hazard analysis and developing your HACCP plan. Each chapter contains a section, Understand the Potential Hazard, that provides information about the significance of the hazard, the conditions under which it may develop in a fishery product, and methods available to control the hazard.
STEP 8: Identify potential process-related hazards.

Find in Table 3-4 (Chapter 3) the finished product food (Column 1) and package type (Column 2) that most closely match the information that you developed in Steps 2 and 3. Record the potential hazard(s) listed in the table for that product in Column 2 of the Hazard Analysis Worksheet, at every processing step.
STEP 10: Determine whether the potential hazard is significant.

Narrow the list of potential hazards that you entered in Column 2 of the Hazard Analysis Worksheet to those that are significant or, in other words, reasonably likely to occur. The Seafood HACCP Regulation defines a food safety hazard that is reasonably likely to occur as one for which a prudent processor would establish controls because experience, illness data,
24
scientific reports, or other information provide a basis to conclude that there is a reasonable possibility that it will occur in the particular type of fish or fishery product being processed in the absence of those controls. The hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Determine Whether this Potential Hazard Is Significant, that provides information about how to assess the significance of potential hazards. You should evaluate the significance of a potential hazard independently at each processing step. It may be significant at one step but not at another. A potential hazard is significant at the processing or handling step if (1) it is reasonably likely that the hazard can be introduced at an unsafe level at that processing step; or (2) it is reasonably likely that the hazard can increase to an unsafe level at that processing step; or (3) it is significant at another processing or handling step and it can be prevented, eliminated, or reduced to an acceptable level at the current processing or handling step. When evaluating the significance of a hazard at a processing step, you should consider the method of distribution and storage and the intended use and consumer of the product, which you developed in Steps 3 and 4. If you determine that a potential hazard is significant at a processing step, you should answer Yes in Column 3 of the Hazard Analysis Worksheet. If you determine that a potential hazard is not significant at a processing step, you should answer No in that column. You should record the reason for your Yes or No answer in Column 4. You need not complete Steps 11 through 18 for a hazard for those processing steps where you have recorded a No. It is important to note that identifying a hazard as significant at a processing step does not mean that it must be controlled at that processing step. Step 11 will help you determine where in the process the critical control point is located.
STEP 11: Identify critical control points.

For each processing step where a significant hazard is identified in Column 3 of the Hazard Analysis Worksheet, determine whether it is necessary to exercise control at that step in order to control the hazard. Figure A-2 (Appendix 3) is a critical control point (CCP) decision tree that can be used to aid you in your determination. The hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Identify Critical Control Points (CCPs), which provides information about where control should be exercised. Each chapter discusses one or more control strategy example(s) for how the hazard can be controlled, because there are often more ways than one to control a hazard. CCP(s) for one control strategy example often differ from those of another example for the same hazard. The control strategies contain preventive measure information. Record the preventive measure(s) in Column 5 of the Hazard Analysis Worksheet for each Yes answer in Column 3. For every significant hazard, there must be at least one CCP where the hazard is controlled (21 CFR 123.6(c)(2)). In some cases, control may be necessary at more than one CCP for a single hazard. In other cases, a processing step may be a CCP for more than one hazard. CCPs are points in the process (i.e., processing steps) where the HACCP control activities will occur. Control activities at a CCP can effectively prevent, eliminate, or reduce the hazard to an acceptable level (21 CFR 123.3(b)). If you determine that a processing step is a CCP for a significant hazard, you should enter Yes in Column 6 of the Hazard Analysis Worksheet. If you determine that a processing step is not a CCP for a significant hazard, you should enter No in that column. You need not complete Steps 12 through 18 for a hazard for those processing steps where you have recorded a No.
25
HACCP PLAN FORM

STEP 12: Set up the HACCP Plan Form.
Find the processing steps that you have identified as CCPs in Column 6 of the Hazard Analysis Worksheet. Record the names of these processing steps in Column 1 of the HACCP Plan Form. Enter the hazard(s) for which these processing steps were identified as CCPs in Column 2 of the HACCP Plan Form. This information can be found in Column 2 of the Hazard Analysis Worksheet. Complete Steps 13 through 18 for each of the significant hazards. These steps involve setting critical limits, establishing monitoring procedures, establishing corrective action procedures, establishing a recordkeeping system, and establishing verification procedures.
met, but before a critical limit deviation would require you to take corrective action. You should set operating limits based on your experience with the variability of your operation and with the closeness of typical operating values to the critical limit. Consider that the critical limit should directly relate to the parameter that you will be monitoring. For example, if you intend to monitor the temperature of the water in the cooker and the speed of the belt that carries the product through the cooker (because you have determined that these factors result in the desired internal product temperature for the desired time), you should specify water temperature and belt speed as critical limits, not the internal temperature of the product. Enter the critical limit(s) in Column 3 of the HACCP Plan Form.
STEP 13: Set critical limits.

For each processing step where a significant hazard is identified on the HACCP Plan Form, identify the maximum or minimum value to which a parameter of the process must be controlled in order to control the hazard. Each control strategy example provided in the hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Set Critical Limits, that provides information about appropriate critical limits for each of the control strategy example(s) discussed. You should set a critical limit at such a value that if it is not met, the safety of the product may be questionable. If you set a more restrictive critical limit, you could, as a result, be required to take corrective action when no safety concern actually exists. On the other hand, if you set a critical limit that is too loose, you could, as a result, allow an unsafe product to reach the consumer. As a practical matter, it may also be advisable to set an operating limit that is more restrictive than the critical limit. In this way, you can adjust the process when the operating limit is not
STEP 14: Establish monitoring procedures.

For each processing step where a significant hazard is identified on the HACCP Plan Form, describe monitoring procedures that will ensure that critical limits are consistently met (21 CFR 123.6(c)(4)). The hazards and controls chapters of this guidance document (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Establish Monitoring Procedures, that provides information about appropriate monitoring procedures for each of the control strategy example(s) discussed. To fully describe your monitoring program, you should answer four questions: (1) What will be monitored? (2) How will monitoring be done? (3) How often will monitoring be done (frequency)? and (4) Who will do the monitoring? It is important for you to keep in mind that the monitoring process should directly measure the parameter for which you have established a critical limit. The necessary frequency of monitoring is dependent upon the circumstances. Continuous monitoring is always desirable, and in some cases necessary. In other cases, it may not be necessary or practical. You should monitor
26
often enough that the normal variability in the values you are measuring will be detected. This is especially true if these values are typically close to the critical limit. Additionally, the greater the time span between measurements, the more products you are putting at risk should a measurement show a deviation from a critical limit has occurred, because you should assume that the critical limit had not been met since the last good value. Even with continuous monitoring, the paper or electronic record of the continuous monitoring should be periodically checked in order to determine whether deviations from the critical limit have occurred. The frequency of that check should be at least daily, and more frequent if required in order to implement an appropriate corrective action. Enter the What, How, Frequency, and Who monitoring information in Columns 4, 5, 6, and 7, respectively, of the HACCP Plan Form.
through 21) each contain a section, Establish Corrective Action Procedures, that provides information about appropriate corrective action procedures for each of the control strategy example(s) discussed. An appropriate corrective action procedure must accomplish two goals: (1) ensure that an unsafe product does not reach the consumer and (2) correct the problem that caused the critical limit deviation (21 CFR 123.7). If the corrective action involves testing the finished product, the limitations of the sampling plan should be understood. Because of these limitations, microbiological testing is often not a suitable corrective action. The Seafood HACCP Regulation requires that corrective actions be fully documented in records (21 CFR 123.7(d)). Note that if a critical limit deviation occurs repeatedly, the adequacy of that CCP for controlling the hazard should be reassessed. Remember that deviations from operating limits do not need to result in formal corrective actions. Enter the corrective action procedures in Column 8 of the HACCP Plan Form.
STEP 15: Establish corrective action procedures.

A corrective action must be taken whenever there is a deviation from a critical limit at a CCP (21 CFR 123.7((a)). For each processing step where a significant hazard is identified on the HACCP Plan Form, describe the procedures that you will use when your monitoring indicates that the critical limit has not been met. Note that the Seafood HACCP Regulation does not require that you predetermine your corrective actions. You may instead elect to follow the prescribed corrective action procedures listed at 21 CFR 123.7(c). However, a predetermined corrective action has the following advantages: (1) It provides detailed instructions to the processing employee that can be followed in the event of a critical limit deviation; (2) it can be prepared at a time when an emergency situation is not calling for an immediate decision; and (3) it removes the obligation to reassess the HACCP plan in response to a critical limit deviation. The hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11
STEP 16: Establish a recordkeeping system.

For each processing step where a significant hazard is identified on the HACCP Plan Form, list the records that will be used to document the accomplishment of the monitoring procedures discussed in Step 14 (21 CFR 123.9(a)(2)). The hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Establish a Recordkeeping System, that provides information about appropriate records for each of the control strategy example(s) discussed. Records must document monitoring of the CCP and shall contain the actual values and observations obtained during monitoring (21 CFR 123.6(b)(7)) The Seafood HACCP Regulation lists specific requirements about the content of the records (21 CFR 123.9(a)). Enter the names of the HACCP monitoring records in Column 9 of the HACCP Plan Form.
27
STEP 17: Establish verification procedures.

For each processing step where a significant hazard is identified on the HACCP Plan Form, describe the verification procedures that will ensure that the HACCP plan is (1) adequate to address the hazard and (2) consistently being followed (21 CFR 123.6(c)(6)). The hazards and controls chapters of this guidance (Chapters 4 through 7, 9, and 11 through 21) each contain a section, Establish Verification Procedures, that provides information about appropriate verification activities for each of the control strategy example(s) discussed. The information covers validation of the adequacy of critical limits (e.g., process establishment); calibration (including accuracy checks) of CCP monitoring equipment; performance of periodic end-product and in-process testing; and review of monitoring, corrective action, and verification records. Note that the Seafood HACCP Regulation does not require product testing (21 CFR 123.8(a)(2)(iii)). However, it can be a useful tool, especially when coupled with a relatively weak monitoring procedure, such as reliance upon suppliers certificates. When calibration or an accuracy check of a CCP monitoring instrument shows that the instrument is not accurate, you should evaluate the monitoring records since the last instrument calibration to determine whether the inaccuracy would have contributed to a critical limit deviation. For this reason, HACCP plans with infrequent calibration or accuracy checks can place more products at risk than those with more frequent checks should a problem with instrument accuracy occur. Enter the verification procedures in Column 10 of the HACCP Plan Form.
that of the most responsible individual on-site at your processing facility or a higher level official (21 CFR 123.6(d)(1)). It signifies that the HACCP plan has been accepted for implementation by your firm.
STEP 18: Complete the HACCP Plan Form.

When you have finished these steps for all significant hazards that relate to your product, you will have completed the HACCP Plan Form. You should then sign and date the first page of the HACCP Plan Form. The signature must be
28
CHAPTER 3: Potential Species-Related and Process-Related Hazards

INTRODUCTION
Purpose The purpose of this chapter is to identify potential food safety hazards that are species related and process related. It also provides information on how the illicit substitution of one species for another can impact on the identification of species-related hazards. To assist in identifying species-related and process-related hazards, this chapter contains three tables: Table 3-2, Potential Vertebrate Species-Related Hazards, contains a list of potential hazards that are associated with specific species of vertebrates (species with backbones). These hazards are referred to as species-related hazards; Table 3-3, Potential Invertebrate Species-Related Hazards, contains a list of potential hazards that are associated with specific species of invertebrates (species without backbones). These hazards are also referred to as speciesrelated hazards; Table 3-4, Potential Process-Related Hazards, contains a list of potential hazards that are associated with specific finished fishery products, as a result of the finished product form, the package type, and the method of distribution and storage. These hazards are referred to as process-related hazards.
It is important to note that the tables provide lists of potential hazards. You should use the tables, together with the information provided in Chapters 4 through 21, and your own expertise or that of outside experts, to determine whether the hazard is significant for your particular product and, if so, how it should be controlled. Species substitution Illicit substitution of one species for another may constitute economic fraud and/or misbranding violations of the Federal Food, Drug, and Cosmetic Act. Furthermore, species substitution may cause potential food safety hazards to be overlooked or misidentified by processors or end users, as shown in Table 3-1, The Effect of Misbranding Through Species Substitution on the Identification of Potential Species-Related Hazards. These examples are based on actual incidents of species substitution or misbranding.
29
TABLE 3-1
THE EFFECT OF MISBRANDING THROUGH SPECIES SUBSTITUTION ON THE IDENTIFICATION OF POTENTIAL SPECIES-RELATED HAZARDS
POTENTIAL SPECIES- RELATED HAZARDS ASSOCIATED WITH THE ACTUAL PRODUCT (FROM TABLE 3-2)
ACTUAL MARKET NAME OF PRODUCT
PRODUCT INAPPROPRIATELY LABELED AS
POTENTIAL SPECIES-RELATED HAZARDS THAT WOULD BE IDENTIFIED BASED ON INAPPROPRIATE SPECIES LABELING (FROM TABLE 3-2)
Escolar Puffer fish
Gempylotoxin Histamine Tetrodotoxin Paralytic Shellfish Poisoning Parasites Histamine Ciguatera Fish Poisoning Environmental chemical contaminants and pesticides Parasites Ciguatera Fish Poisoning
Sea bass Monkfish
Parasites Parasites
Spanish mackerel
Kingfish
None
Basa
Grouper
Parasites Ciguatera Fish Poisoning
Grouper
Cod
Parasites
30
TABLE 3-2
POTENTIAL VERTEBRATE SPECIES-RELATED HAZARDS

Note: You should identify pathogens from the harvest area as a potential species-related hazard if you know or have reason to know that the fish will be consumed without a process sufficient to kill pathogens, or if you represent, label, or intend for the product to be so consumed. (See Chapter 4 for guidance on controlling pathogens from the harvest area.)
HAZARDS MARKET NAMES LATIN NAMES PARASITES CHP 5 NATURAL TOXINS CHP 6 SCOMBROTOXIN (HISTAMINE) CHP 7 ENVIRONMENTAL CHEMICALS CHP 9 AQUACULTURE DRUGS CHP 11
AHOLEHOLE ALEWIFE OR RIVER HERRING ALFONSINO
Kuhlia spp. Alosa pseudoharengus
Beryx spp. Centroberyx spp. Alligator mississipiensis Alligator sinensis CFP
ALLIGATOR
ALLIGATOR, AQUACULTURED AMBERJACK AMBERJACK OR YELLOWTAIL AMBERJACK OR YELLOWTAIL, AQUACULTURED
Alligator mississipiensis Alligator sinensis Seriola spp. Seriola lalandi
Seriola lalandi
Anchoa spp. Anchoviella spp. ANCHOVY Cetengraulis mysticetus Engraulis spp. Stolephorus spp. ANGELFISH ARGENTINE QUEENFISH Holacanthus spp. Pomacanthus spp. Argentina elongata
ASP5 ASP ASP

5 5
ASP5 ASP5
Sphyraena spp. BARRACUDA S. barracuda S. jello BARRAMUNDI Lates calcarifer
CFP CFP CFP
31
TABLE 3-2

BARRAMUNDI AQUACULTURED BASA OR BOCOURTI8 BASA OR BOCOURTI8, AQUACULTURED
Lates calcarifer
Pangasius bocourti
Pangasius bocourti
Ambloplites spp. Micropterus spp. BASS Morone spp. Stereolepis gigas Synagrops bellus BASS, AQUACULTURED Morone spp. Centropristis spp. Acanthistius brasilianus Centropristis spp. Dicentrarchus labrax Lateolabrax japonicus BASS, SEA Paralabrax spp. Paranthias furcifer Polyprion americanus Polyprion oxygeneios Polyprion yanezi BASS, SEA, AQUACULTURED BATA BIGEYE BLUEFISH BLUEGILL Dicentrarchus labrax 3 3 3 3 3 3 3 3 3 3
Labeo bata Priacanthus arenatus Pristigenys alta Pomatomus saltatrix Lepomis macrochirus
32
TABLE 3-2

BLUENOSE BOMBAY DUCK
Hyperoglyphe antarctica Harpadon nehereus Cybiosarda elegans
BONITO
Gymnosarda unicolor Orcynopsis unicolor Sarda spp.
BOWFIN AND ROE
Amia calva Abramis brama Acanthopagrus spp.7 Argyrops spp.
BREAM
Gymnocranius grandoculis7 Monotaxis spp. Sparus aurata Wattsia spp.
BREAM, AQUACULTURED BREAM OR BOGUE BREAM, THREADFIN BUFFALOFISH BULLHEAD BURBOT
Abramis brama
Boops boops Nemipterus japonicus Ictiobus spp. Ameiurus spp. Lota lota Odax pullus 3
BUTTERFISH8
Peprilus spp. Pampus cinereus
CAPARARI8 CAPELIN AND ROE
Pseudoplatystoma tigrinum Mallotus villosus
33
TABLE 3-2

Barbonymus spp. Cyprinus carpio CARP Hypophthalmichthys molitrix Hypophthalmichthys nobilis Carassius carassius Cyprinus carpio CARP, AQUACULTURED Hypophthalmichthys molitrix Hypophthalmichthys nobilis. Carassius carassius CASCARUDO8 Callichthys callichthys
Ameiurus catus CATFISH Ictalurus spp. Pylodictis oliveris CATFISH, AQUACULTURED CHAR CHAR, AQUACULTURED CHARACIN CHARAL CHIMAERA CHIRING Ictalurus spp.
Salvelinus alpinus Salvelinus alpinus
Leporinus obtusidens Chirostoma jordani Harriota raleighana Hydrolagus spp. Apocryptes bato Coregonus kiyi
CHUB
Kyphosus spp. Semotilus atromaculatus
34
TABLE 3-2

Coregonus alpenae CISCO OR CHUB Coregonus reighardi Coregonus zenithicus CISCO OR TULLIBEE CLARIAS FISH OR WALKING CLARIAS FISH8 Coregonus artedi7 Clarias spp.
Clarias anguillaris CLARIAS FISH OR WALKING CLARIAS FISH, AQUACULTURED8 Clarias gariepinus
COBIA COBIA, AQUACULTURED
Rachycentron canadum Rachycentron canadum Arctogadus spp.
3 3
3 3 3 3 3
COD
Boreogadus saida Eleginus gracilis Gadus spp.
COD OR ALASKA COD
Gadus macrocephalus
Lotella rhacina COD, MORID Mora moro Psendophycis barbata7 Pseudophycis spp. COROATA8 Platynematichthys notatus Cilus gilberti7 CORVINA Micropogonias undulates7 Pomoxis spp.
3 3 3 3 3 3 3
CRAPPIE
35
TABLE 3-2

Argyrosomus spp. Bairdiella spp. Cheilotrema saturnum Genyonemus lineatus Micropogonias spp. Nebris microps Nibea spp. CROAKER Pachypops spp. Pachyurus spp. Paralonchurus spp. Plagioscion spp. Pseudotolithus spp. Pterotolithus spp. Roncador stearnsii
7
Umbrina roncador Odontoscion dentex CROAKER OR CORVINA CROAKER OR SHADEFISH CROAKER OR YELLOWFISH CURIMBATA OR GURAMATA CUSK Cynoscion spp.
Argyrosomus regius
Larimichthys polyactis7
Prochilodus lineatus
Brosme brosme Lepophidium spp.
CUSK-EEL Brotula clarkae Aphanopus carbo CUTLASSFISH Lepidopus caudatus Trichiurus spp. DACE Rhinichthys ssp.
36
TABLE 3-2

DACE, AQUACULTURED
Rhinichthys ssp.
Cyttus novaezealandiae DORY Zenopsis spp. Zeus spp. DRIFTFISH Hyperoglyphe spp. Equetus punctatus Larimus spp. DRUM Pogonias cromis Stellifer spp. Totoaba macdonaldi Umbrina coroides DRUM OR CUBBYU DRUM, FRESHWATER DRUM OR LION FISH DRUM OR MEAGRE DRUM OR QUEENFISH DRUM OR REDFISH DRUM OR REDFISH, AQUACULTURED EEL Pareques umbrosus7 Aplodinotus grunniens Collichthys spp. Argyrosomus regius7 Seriphus politus
Sciaenops ocellatus Sciaenops ocellatus
Anguilla spp. Anguilla Anguilla
EEL, AQUACULTURED
Anguilla australis Anguilla dieffenbachii Anguilla japonica7
37
TABLE 3-2

Ariosoma balearicum Conger spp. EEL, CONGER Gnathophis cinctus Rhynchoconger spp. Paraconger caudilimbatus EEL, FRESHWATER EEL, FRESHWATER, AQUACULTURED Anguilla rostrata Anguilla rostrata
Gymnothorax funebris EEL, MORAY Lycodontis javanicus Muraena retifera EEL, SPINY EELPOUT ELEPHANT FISH EMPEROR ESCOLAR OR OILFISH FEATHERBACK FLATHEAD FLATWHISKERED FISH8 Notacanthus chemnitzii Zoarces americanus Zoarces viviparus Callorhynchus millii Lethrinus spp. Lepidocybium flavobrunneum Ruvettus pretiosus Notopterus notopterus Platycephalus conatus Pinirampus pirinampu 3 3
CFP CFP
G G
38
TABLE 3-2

Ancylopsetta dilecta Arnoglossus scapha Reinhardtius evermanni Bothus spp. Chascanopsetta crumenalis Cleisthenes pinetorum Colistium spp. Cyclopsetta chittendeni Hippoglossoides robustus Limanda ferruginea Liopsetta glacialis Microstomus achne FLOUNDER Paralichthys albigutta Hippoglossina oblonga Paralichthys olivaceus Paralichthys patagonicus Paralichthys squamilentus Pelotretis flavilatus Peltorhampus novaezeelandiae Platichthys spp. Pseudorhombus spp. Rhombosolea spp. Samariscus triocellatus Scophthalmus spp.
3
3
1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1
3 3 3 3
3
3 3 3
3
3 3
3
3 3 3 3
3
3
3
3
3
39
TABLE 3-2

Ancylopsetta dilecta Arnoglossus scapha Reinhardtius evermanni Bothus spp. Chascanopsetta crumenalis Cleisthenes pinetorum Colistium spp. Cyclopsetta chittendeni FLOUNDER, AQUACULTURED Hippoglossoides robustus Limanda ferruginea Liopsetta glacialis Microstomus achne Paralichthys spp. Pelotretis flavilatus Peltorhampus novaezeelandiae Pseudorhombus spp. Rhombosolea spp. Samariscus triocellatus Scophthalmus spp. Limanda limanda FLOUNDER OR DAB
7
3,4
3,4 3,4
3,4 3,4 3,4

3,4 3,4
3,4 3,4
3,4 3,4
3,4
3,4 3,4
3,4 3,4
3,4
3,4
3
Limanda proboscidea7 Limanda punctatissima7 Paralichthys dentatus
3
3
1 1 1 1 1 1
3 3 3 3 3
FLOUNDER OR FLUKE
Paralichthys lethostigma Paralichthys microps Platichthys flesus7
FLOUNDER, ARROWTOOTH
Reinhardtius hippoglossoides
40
TABLE 3-2

Cypselurus spp. Exocoetus spp. Fodiator acutus Hirundichthys spp. FLYINGFISH AND ROE Oxyporhamphus micropterus Parexocoetus brachypterus Prognichthys gibbifrons FROG GAR Rana spp. Lepisosteus spp. Epinnula magistralis GEMFISH Nesiarchus nasutus Lepidocybium flavobrunneum GEMFISH OR BARRACOUTA GEMFISH OR CABALLA GILLBACKER OR GILLEYBAKA8 Rexea solandri Thyrsites atun Thyrsites lepidopoides G 3
Aspistor parkeri
Mulloidichthys spp. Mulloidichthys vanicolenis Mullus auratus GOATFISH Parupeneus spp. Pseudupeneus spp. Upeneichthys lineatus Upeneus spp. GOBY GRAYLING Neogobius melanostomus Thymallus arcticus
41
TABLE 3-2

GREENBONE GREENLING
Odax pullus7 Hexagrammos spp. Coryphaenoides spp. Lepidorhynchus denticulatus
GRENADIER
Macruronus spp7 Nezumia bairdii7 Trachyrhynchus spp.7 Anyperodon spp. Caprodon schlegelii Cephalopholis spp. C. argus C. miniata Diplectrum formosum Epinephelus spp. 3 3 3 3
3 3
CFP CFP CFP
3
3 3
CFP CFP CFP CFP CFP CFP CFP CFP CFP CFP
GROUPER
E. fuscoguttatus E. lanceolatus E. morio Mycteroperca spp. M. venenosa M. bonaci Variola spp. Variola louti
3
3 3
3
3
3 3
GROUPER OR CORAL GROUPER GROUPER OR GAG GROUPER OR HIND GROUPER OR JEWFISH GRUNION
Plectropomus spp.
Mycteroperca microlepis Epinephelus guttatus Epinephelus itajara
3 3 3
CFP CFP
Leuresthes tenuis
42
TABLE 3-2

Anisotremus interruptus Conodon nobilis GRUNT Haemulon spp. Orthopristis chrysoptera Pomadasys crocro GRUNT OR CATALINA GRUNT OR MARGATE GRUNT OR SWEETLIPS HADDOCK HAKE HALIBUT HALIBUT, AQUACULTURED HALIBUT OR CALIFORNIA HALIBUT HAMLET, MUTTON Anisotremus taeniatus
Haemulon album Anisotremus surinamensis7 Plectorhinchus spp.
Melanogrammus aeglefinus Urophycis spp. Hippoglossus spp. Hippoglossus spp. 3 3,4
Paralichthys californicus
Alphestes afer 7 Etrumeus teres Harengula thrissina 3

3 3
HERRING
Ilisha spp. Opisthopterus tardoore Pellona ditchela Alosa spp.
3
3
HERRING OR SEA HERRING OR SILD
Clupea spp.
43
TABLE 3-2

HERRING OR SEA HERRING OR SILD ROE HERRING, THREAD
Clupea spp.
Opisthonema spp. Epinephelus guttatus 3

3
CFP CFP
HIND
Epinephelus adscensionis Epinephelus drummondhayi
3 3 3 CFP
HOGFISH HORSE MACKEREL OR SCAD
Lachnolaimus maximus Trachurus trachurus
Caranx spp. C. ignobilis C.melampygus C.latus C. lugubris JACK C. ruber Carangoides bartholomaei Oligoplites saurus Selene spp. Seriola rivoliana Urapsis secunda JACK OR BLUE RUNNER JACK OR CREVALLE JACK OR RAINBOW RUNNER JACK OR ROOSTERFISH Caranx crysos
3
3
CFP CFP CFP CFP CFP CFP CFP
3
3 3
3
3
3
3
3 3
3
CFP
CFP
Alectis indicus7 Elagatis bipinnulata
3 3 CFP
Nematistius pectoralis
44
TABLE 3-2

Aphareus spp. JOBFISH Aprion spp. Pristipomoides spp. KAHAWAI KINGFISH6 KINGKLIP LADYFISH LING LING, MEDITERRANEAN LINGCOD LIZARDFISH LOACH LUMPFISH ROE Arripis spp. Menticirrhus spp. Genypterus spp. Elops spp. Molva spp. Molva macrophthalma7 Ophiodon elongatus Synodus spp. Somileptus gongota Cyclopterus lumpus Gasterochisma melampus MACKEREL Grammatorcynus spp. Rastrelliger kanagurta Scomber scombrus MACKEREL, ATKA MACKEREL, CHUB MACKEREL, JACK Pleurogrammus monopterygius Scomber spp. Trachurus spp. Scomberomorus spp. MACKEREL, SPANISH
3
3 3
CFP CFP CFP
3 3
3 3
3 3 3 3
45
TABLE 3-2

MACKEREL, NARROW-BARRED SPANISH MACKEREL, SPANISH OR KING MAHI-MAHI MAHI-MAHI, AQUACULTURED MARLIN
Scomberomorus commerson
CFP
Scomberomorus cavalla Coryphaena spp. Coryphaena spp.
CFP
Makaira spp. Tetrapturus spp. Brevoortia spp.
9 9 10 10
MENHADEN
Ethmidium maculatum Chanos chanos Chanos chanos
MILKFISH MILKFISH, AQUACULTURED MONKFISH
Lophius spp. Aplodactylus arctidens7
MORWONG
Cheilodactylus spp. Goniistius spp. Nemadactylus spp. Agonostomus monticola Aldrichetta forsteri Crenimugil crenilabis 3 3
3 3
MULLET
Mugil spp. Mullus spp. Mugil cephalus

7
3
3 3
Mugil thoburni MUSKELLUNGE Esox masquinongy
46
TABLE 3-2

OPAH OPALEYE
Lampris guttatus Girella nigricans Allocyttus niger
OREO DORY
Neocyttus spp. Pseudocyttus spp.
OSCAR OSCAR, AQUACULTURED PACU PADDLEFISH AND ROE PADDLEFISH AND ROE, AQUACULTURED PANGASIUS, GIANT8 PANGASIUS SHORTBARBEL8 PARROTFISH PATAGONIAN TOOTHFISH OR CHILEAN SEA BASS PERCH PERCH, LAKE OR YELLOW PERCH, NILE PERCH, NILE, AQUACULTURED
Astronotus ocellatus Astronotus ocellatus
Myleus pacu Polyodon spp.
Polyodon spp.
Pangasius gigas Pangasius micronemus Scarus spp. Bolbometopon spp. Dissostichus eleginoides7 3 CFP2
Hermosilla azurea Perca fluviatilis Perca flavescens
Lates niloticus Lates niloticus
47
TABLE 3-2

PERCH, OCEAN PERCH, PILE PERCH, SILVER PERCH, WHITE PICAREL PICKEREL PIKE PILCHARD OR SARDINE PIRAMUTABA OR LAULAO FISH8
Sebastes spp. Rhacochilus vacca Bairdiella chrysoura Morone americana Spicara maena Esox spp. Esox lucius Sardina pilchardus Sardinops spp. Brachyplatystoma vaillantii Hippoglossoides platessoides
3 3 3 3 3 3
PLAICE
Pleuronectes platessa Pleuronectes quadrituberculatus
POLLOCK POLLOCK OR ALASKA POLLOCK
Pollachius pollachius Pollachius virens Theragra chalcogramma Brama spp.
POMFRET
Parastromateus spp. Taractes rubescens Alectis ciliaris CFP
POMPANO
Parastromateus niger Trachinotus spp.
POMPANO OR PERMIT
Trachinotus kennedyi Trachinotus falcatus
48
TABLE 3-2

POMPANO OR POMPANITO
Trachinotus rhodopus
Calamus spp. Chrysophrys auratus Dentex spp. PORGY Diplodus spp. Lagodon rhomboides Pagrus spp. Pterogymnus laniarus Stenotomus caprinus PORGY OR SCUP Stenotomus chrysops Arothron spp. Lagocephalus spp. Sphoeroides annulatus Sphoeroides nephelus PUFFER Sphoeroides maculatus Sphoeroides spengleri Sphoeroides testudineus Takifugu spp.7 Tetraodon spp. PUFFER, AQUACULTURED RACEHORSE RITA Takifugu spp.
7
T, PSP T, PSP T, PSP T, PSP T, PSP T, PSP T, PSP T, PSP T, PSP T, PSP
Congiopodus leucopaecilus Rita rita Scorpaena papillosus 3 3 3
ROCKFISH
Scorpaena cardinalis Sebastes spp.
ROCKLING ROHU
Ciliata spp. Enchelyopus cimbrius Labeo rohita
49
TABLE 3-2

ROSEFISH ROUGHY ROUGHY, ORANGE ROUGHY, SILVER SABLEFISH SAILFISH SALMON AND ROE, AQUACULTURED SALMON AND ROE (WILD)(FRESHWATER) SALMON AND ROE, (WILD) (OCEAN) SANDDAB SANDPERCH SARDINE SAUGER SAURY
Helicolenus dactylopterus Paratrachichthys trailli Hoplostethus atlanticus Hoplostethus mediterraneus mediterraneus7 Anoplopoma fimbria Istiophorus platypterus Oncorhynchus spp. Salmo salar Oncorhynchus spp. Salmo salar Oncorhynchus spp. Salmo salar Citharichthys sordidus Mugiloides chilensis Parapercis spp. Harengula spp. Sardinella spp. Atule mate
7
3 3,4 3,4 3
3
3 3
Cololabis saira Scomberesox saurus Atule mate7 Decapterus spp. 3 3 3 3 3
SCAD
Selar crumenophthalmus Trachurus spp.
SCAD OR HORSE MACKEREL
Trachurus trachurus
50
TABLE 3-2

Hemitripterus americanus SCULPIN Myoxocephalus polyacanthocephalus Scorpaenichthys marmoratus Archosargus rhomboidalis SEA BREAM Chrysophrys auratus7 Pagellus spp. Chelidonichthys spp. SEAROBIN Peristedion miniatum Prionotus carolinus Pterygotrigla picta SEATROUT SHAD SHAD ROE SHAD, GIZZARD SHAD, HILSA Cynoscion spp. Alosa spp. Alosa spp. Dorosoma spp. Nematalosa vlaminghi Tenualosa ilisha Carcharhinus spp. Cetorhinus maximus Galeocerdo cuvier Galeorhinus spp. Hexanchus griseus Lamna ditropis SHARK Negaprion brevirostris Notorynchus cepedianus Prionace glauca Sphyrna spp. Triaenodon obesus Triakis semifasciata 3
51
TABLE 3-2

SHARK OR PORBEAGLE SHARK OR SMOOTHHOUND SHARK, ANGEL
Lamna nasus
Mustelus spp.
Squatina spp. Centrophorus spp.
SHARK, DOGFISH OR CAPE SHARK
Mustelus spp. Scyliorhinus spp. Squalus spp.
SHARK, MAKO SHARK, THRESHER
Isurus spp. Alopias spp. Semicossyphus pulcher
SHEEPHEAD
Archosargus probatocephalus Notropis spp. Atherinops spp.
SHINER
SILVERSIDE
Basilichthys australis Menidia menidia
SKATE SKILLFISH
Bathyraja spp. Raja spp. Erilepis zonifer Allosmerus elongatus Argentina spp. Hypomesus spp. Osmerus spp.
SMELT
Plecoglossus altivelis altivelis7 Retropinna retropinna Spirinchus spp. Thaleichthys pacificus
52
TABLE 3-2

SNAKEHEAD
Channa striata Parachanna obscura7 Apsilus dentatus Etelis spp. Lutjanus spp. L. bohar L. gibbus L. sebae L. buccanella L. cyanopterus CFP CFP CFP CFP CFP CFP CFP CFP
SNAPPER
L. jocu Symphorus nematophorus Macolor spp. Ocyurus chrysurus Pristipomoides spp. Rhomboplites aurorubens Symphorichthys spilurus 3
SNOOK
Centropomus spp.
53
TABLE 3-2

Aseraggodes spp. Austroglossus spp. Buglossidium luteum Clidoderma asperrimum Embassichthys bathybius Lyopsetta exilis7 Eopsetta jordani Glyptocephalus zachirus7 Glyptocephalus spp. Gymnachirus melas SOLE OR FLOUNDER Hippoglossina spp. Lepidopsetta bilineata Microchirus spp. Microstomus kitt Microstomus pacificus Pseudopleuronectes americanus7 Parophrys vetulus7 Psettichthys melanostictus Solea solea7 Brachirus orientalis7 Trinectes spp. Xystreurys liolepis
3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3 3
54
TABLE 3-2

Aseraggodes spp. Austroglossus spp. Buglossidium luteum Clidoderma asperrimum Embassichthys bathybius Lyopsetta exilis 7 Eopsetta jordani Glyptocephalus zachirus 7 Glyptocephalus spp. SOLE OR FLOUNDER, AQUACULTURED Gymnachirus melas Hippoglossina spp. Lepidopsetta bilineata Microchirus spp. Pseudopleuronectes americanus 7 Parophrys vetulus 7 Psettichthys melanostictus Solea solea 7 Brachirusorientalis Trinectes spp. Xystreurys liolepis SORUBIM OR SURUBI8 SPADEFISH SPEARFISH SPOT SPRAT OR BRISTLING Pseudoplatystoma corruscans Chaetodipterus spp. Tetrapturus spp. Leiostomus xanthurus Sprattus spp.
7
3,4
3,4 3,4
3,4 3,4 3,4

3,4 3,4
3,4 3,4
3,4 3,4
3,4
3,4
3,4 3,4 3,4

3,4 3,4
3,4
55
TABLE 3-2

Holocentrus spp. SQUIRRELFISH Myripristis spp. Sargocentron spp. Acipenser spp. STURGEON AND ROE Huso huso Pseudoscaphirhynchus spp. Scaphirhynchus spp. Acipenser spp. STURGEON AND ROE, AQUACULTURED Huso huso Pseudoscaphirhynchus spp. Scaphirhynchus spp. Carpiodes spp. SUCKER Catostomus commersonii Cycleptus elongatus SUCKER OR REDHORSE SUNFISH (NOT MOLA MOLA) Moxostoma macrolepidotum Archoplites interruptus Lepomis spp. Amphistichus spp. Cymatogaster aggregata SURFPERCH Embiotoca spp. Hyperprosopon argenteum Rhacochilus toxotes SUTCHI OR SWAI8 SUTCHI OR SWAI8, AQUACULTURED SWORDFISH Pangasius hypophthalmus Pangasius hypophthalmus Xiphias gladius
56
TABLE 3-2

Acanthurus spp. TANG Ctenochaetus spp Naso spp. Zebrasoma spp. TARPON TAUTOG THORNYHEAD Megalops atlanticus Tautoga onitis Sebastolobus spp. Eleutheronema tetradactylum THREADFIN Galeoides decadactylus Gnathanodon spp. Polydactylus spp. Polynemus spp. TIGERFISH Datnioides microlepis Datnioides polota Tilapia spp. TILAPIA Oreochromis spp. Sarotherodon spp Oreochromis spp. TILAPIA, AQUACULTURED Sarotherodon spp. Tilapia spp. Caulolatilus spp. TILEFISH Lopholatilus chamaeleonticeps Malacanthus plumieri Prolatilus jugularis TINFOIL TOMCOD TONGUESOLE TRAHIRA Barbonymus altus Microgadus spp. Cynoglossus spp. Hoplias malabaricus 3 3 3
CFP2 CFP2 CFP2
57
TABLE 3-2

TREVALLY
Caranx spp. Balistes spp.
CFP CFP
TRIGGERFISH
Canthidermis sufflamen Melichthys niger Navodon spp.
TRIPLETAIL
Datnioides quadrifasciatus Lobotes spp Oncorhynchus mykiss aguabonita Oncorhynchus clarkii Oncorhynchus gilae
3
TROUT, AQUACULTURED
Oncorhynchus mykiss Salmo trutta Salvelinus fontinalis Salvelinus malma Salvelinus namaycush Stenodus leucichthys
TROUT, RAINBOW OR STEELHEAD TRUMPETER
Oncorhynchus mykiss
Latridopis spp. Latris lineata Allothunnus fallai Auxis spp. 3 3

3
TUNA (SMALL)
Euthynnus spp. Katsuwonus pelamis Thunnus tonggol Thunnus alalunga Thunnus albacares
3
3
TUNA (LARGE)
Thunnus atlanticus Thunnus maccoyii Thunnus obesus Thunnus thynnus
58
TABLE 3-2

TUNA, AQUACULTURED
Thunnus spp.
3,4
Pleuronichthys guttulatus7 Pleuronichthys spp. TURBOT Psettodes spp. Reinhardtius hippoglossoides Psetta maxima7 TURBOT, AQUACULTURED Psetta maxima
3 3 3 3 3
TURTLE
Malaclemys spp. Chelydra spp. Apalone spp. Trachemys spp. Malaclemys spp. Chelydra spp. Apalone spp. Trachemys spp. Naso unicornis Acanthocybium solandri Sander spp.7 Seriolella spp. Cynoscion spp. Macrodon ancylodon
TURTLE, AQUACULTURED UNICORNFISH WAHOO WALLEYE WAREHOU WEAKFISH WEAKFISH OR BANGAMARY WHISKERED FISH8 WHISKERED FISH OR GAFFTOPSAIL FISH8 WHISKERED FISH OR HARDHEAD WHISKERED FISH8
Arius spp. Bagre marinus
Ariopsis felis
59
TABLE 3-2

Coregonus spp. WHITEFISH Prosopium cylindraceum Merluccius gayi WHITING Merluccius hubbsi Merluccius merluccius WHITING, BLUE WHITING OR PACIFIC WHITING WHITING, NEW ZEALAND WRASSE WOLFFISH YELLOW TAIL OR AMBERJACK YELLOWTAIL AMBERJACK, AQUACULTURED ZANDER ZANDER, AQUACULTURED Micromesistius spp. Merluccius productus
Macruronus novaezelandiae Cheilinus undulatus Anarhichas spp. Seriola lalandi 3 CFP
Seriola lalandi7
Sander lucioperca7 Sander lucioperca7
60
TABLE 3-2

ASP = Amnesic Shellfish Poisoning; CFP = Ciguatera Fish Poisoning; G = gempylotoxin; PSP = Paralytic Shellfish Poisoning; and T = tetrodotoxin. 1. This hazard does not apply to offshore catch (e.g., areas not subject to shore side contaminant discharges). 2. Indicates that the ciguatera hazard is associated with this species only in the tropical Pacific Ocean. 3. This hazard applies where the processor has knowledge or has reason to know that the parasite-containing fish or fishery product will be consumed without a process sufficient to kill the parasites, or where the processor represents, labels, or intends for the product to be so consumed. 4. This hazard, when caused by consuming infected feed, only applies if fish processing waste, fresh fish, or plankton is used as feed. 5. This hazard only applies if the product is marketed uneviscerated. 6. Amberjack, yellowtail, Spanish mackerel, king mackerel and other scombrotoxin-forming fish are sometimes marketed incorrectly as kingfish. 7. The scientific name for this species has changed since the previous edition of this guidance. 8. The market name for this species has been changed since the previous edition of this guidance. 9. This hazard does not apply to products intended for animal feed or fish oil products, but does apply to products intended for direct human consumption of the muscle and to aqueous components, such as fish protein concentrates that are to be used as food additives. 10. This hazard only applies to food products for human consumption, such as oil extracts used as dietary ingredients.
61
TABLE 3-3
POTENTIAL INVERTEBRATE SPECIES-RELATED HAZARDS

Note: You should identify pathogens from the harvest area as a potential species-related hazard if you know, or have reason to know, that the fish will be consumed without a process sufficient to kill pathogens or if you represent, label, or intend for the product to be so consumed. (See Chapter 4 for guidance on controlling pathogens from the harvest area.)
HAZARDS MARKET NAMES LATIN NAMES PATHOGENS CHP 4 PARASITES CHP 5 NATURAL TOXINS CHP 6 ENVIRONMENTAL CHEMICALS CHP 9 AQUACULTURE DRUGS CHP 11
Haliotis spp ABALONE Marinauris roei Haliotis ruber Haliotis laevigata ARKSHELL CLAM, BENTNOSE CLAM BUTTER CLAM, CALICO CLAM, GEODUCK Anadara subcrenata Arca spp. Macoma nasuta Saxidomus spp. Macrocallista maculata Panopea abrupta Panopea bitruncata Arctica islandica CLAM, HARD Meretrix spp. Venus mortoni CLAM, HARDSHELL OR QUAHOG Protothaca thaca Mercenaria spp. Protothaca staminea Protothaca tenerrima Tapes variegata CLAM, LITTLENECK Tapes virginea Venerupis aurea4 Venerupis decussata
4
Venerupis philippinarum CLAM, MARSH CLAM, PISMO Corbicula japonica Tivela stultorum Ensis spp. CLAM, RAZOR Siliqua spp. Solen spp. Tagelus spp. CLAM, SANGUIN Sanguinolaria spp.
62
TABLE 3-3

CLAM, SOFTSHELL
Mya arenaria Mactrellona alata Mactromeris spp. Mactra spp.
CLAM, SURF OR SURFCLAM
Mactrotomas spp. Simomactra spp. Spisula spp. Tresus spp.
CLAM, SURF AQUACULTURED
Mactra schalinensis
Chione spp. CLAM, VENUS Chionista spp.4 Macrocallista nimbosa CLAM, WEDGE Paphies spp. Cardium spp. COCKLE Clinocardium spp. Dinocardium robustum Serripes groenlandicus CONCH COQUINA COQUINA, FALSE Strombus spp. Lambis lambis Donax spp. Iphigenia brasiliana
CRAB, BLUE, AQUACULTURED CRAB, BLUE CRAB, BROWN CRAB, BROWN KING
Callinectes sapidus
Callinectes sapidus Chaceon fenneri4 Lithodes aequispinus4
63
TABLE 3-3

CRAB, CENTOLLA CRAB, DEEPSEA CRAB, DUNGENESS CRAB, JAPANESE FRESHWATER CRAB, JONAH CRAB, KING CRAB, KING OR HANASAKI CRAB, KOREAN OR KEGANI CRAB, LITHODES CRAB, RED CRAB, RED ROCK CRAB, ROCK CRAB, SHEEP
Lithodes antarcticus Lithodes murrayi Paralomis granulosa Cancer magister Geothelphusa dehaani 1 2
Cancer borealis Paralithodes camtschaticus Paralithodes platypus Paralithodes brevipes
Erimacrus isenbeckii
Neolithodes brodiei Chaceon quinquedens4 Cancer productus Cancer irroratus Cancer pagurus Loxorhynchus grandis Chionoecetes angulatus 2
CRAB, SNOW
Chionoecetes bairdi Chionoecetes opilio Chionoecetes tanneri
CRAB, SPIDER CRAB, STONE CRAB, SWAMP
Jacquinotia edwardsii Maja squinado Menippe spp.

4
Scylla serrata
64
TABLE 3-3

CRAB, SWAMP, AQUACULTURED
Scylla serrata
Callinectes arcuatus CRAB, SWIMMING Callinectes toxotes Portunus spp. Cambarus spp. Cherax spp. Euastacus armatus CRAWFISH OR CRAYFISH Pacifastacus spp. Paranephrops spp. Procambarus spp. Astacus spp. Cambarus spp. Cherax spp. CRAWFISH OR CRAYFISH, AQUACULTURED Euastacus armatus Pacifastacus spp. Paranephrops spp. Procambarus spp. Astacus spp. CUTTLEFISH JELLYFISH Sepia spp. Rhopilema spp. Euphausia spp. KRILL Meganyctiphanes norvegica Thysandoessa inermis Cervimunida johni LANGOSTINO Munida gregaria Pleuroncodes spp.
65
TABLE 3-3

Tectura testudinalis4 Cellana denticulata LIMPET Diodora aspera Fissurella maxima Lottia gigantea Patella caerulea LOBSTER LOBSTER, NORWAY LOBSTER, ROCK LOBSTER, ROCK OR SPINY Homarus spp. Nephrops norvegicus Jasus spp. Palinurus spp. Panulirus spp. Ibacus ciliatus LOBSTER, SLIPPER Scyllarides spp. Thenus orientalis LOBSTERETTE MUREX OR MEREX Metanephrops spp. Nephropsis aculeata Murex brandaris Modiolus spp. MUSSEL Mytilus spp. Perna canaliculus OCTOPUS Eledone spp. Octopus spp. Crassostrea spp. OYSTER Ostrea spp. Spondylus spp. Tiostrea spp. PEN SHELL PERIWINKLE Atrina pectinata Littorina littorea
1
66
TABLE 3-3

Aequipecten spp. Amusium spp. Argopecten nucleus SCALLOP Chlamys spp. Euvola spp.
4
2
2 2
2
2 2
2
2 2
2
2 2
Patinopecten yessoensis Pecten spp. Placopectin magellanicus Aequipecten spp. Amusium spp. Argopecten nucleus SCALLOP AQUACULTURED Chlamys spp. Euvola spp.
4
2
2 2
2
2 2
2
2
2
2
2
2 2
2
2 2
Patinopecten yessoensis Pecten spp. Placopectin magellanicus SCALLOP OR BAY SCALLOP SCALLOP, CALICO SCALLOP OR WEATHERVANE Argopecten irradians
2
2 2
2
2 2
Argopecten gibbus Patinopecten caurinus
2 2
2 2
Cucumaria spp. SEA CUCUMBER Holothuria spp. Parastichopus spp. Stichopus spp. Echinus esculentus Evechinus chloroticus Heliocidaris spp. SEA URCHIN ROE Loxechimus spp. Paracentrotus spp. Pseudocentrotus spp. Strongylocentrotus spp. SEABOB Xiphopenaeuskroyeri
67
TABLE 3-3

SEA SQUIRT
Styela spp. Crangon spp. Farfantepenaeus spp.4 Fenneropenaeus spp.4 Litopenaeus spp.4 Marsupenaeus spp.4 Melicertus spp.4
SHRIMP
Metapenaeus affinis Palaemon serratus Palaemonetes vulgaris Pandalopsis dispar Pandalus spp. Penaeus spp. Pleoticus muelleri Plesionika martia Crangon spp. Exopalaemon styliferus Farfantepenaeus spp. Fenneropenaeus spp. Litopenaeus spp.4
4
SHRIMP, AQUACULTURED
Marsupenaeus spp.
Macrobrachium spp. Melicertus spp.4 Metapenaeus spp. Palaemon serratus Palaemonetes vulgaris Pandalopsis dispar Pandalus spp. Penaeus spp. Plesionika martia Crangon spp.
SHRIMP, FRESHWATER
Macrobrachium spp.
68
TABLE 3-3

SHRIMP, FRESHWATER, AQUACULTURED SHRIMP, ROCK SHRIMP, ROYAL SHRIMP OR PINK SHRIMP SHRIMP OR PRAWN SNAIL OR ESCARGOT SNAIL, MOON
Macrobrachium spp.
Sicyonia brevirostris Pleoticus robustus Pandalus borealis Pandalus jordani Hymenopenaeus sibogae Otala spp. Helix pomatia Achatina fulica Polinices spp. Berryteuthis magister Dosidicus gigas Illex spp. Loligo spp. Loligo media
4
1 1 1 1 1 1 1 1 1 1 1 1
SQUID
Lolliguncula spp. Nototodarus spp. Ommastrephes spp. Rossia macrosoma Sepiola rondeleti Sepioteuthis spp. Todarodes sagittatus
TOP SHELL
Turbo cornutus Monodonta turbinata4 Buccinum spp.
WHELK OR SEA SNAIL
Busycon spp. Neptunea spp.
69
TABLE 3-3

1. This hazard applies where the processor has knowledge or has reason to know that the parasite-containing fish or fishery product will be consumed without a process sufficient to kill the parasites, or where the processor represents, labels, or intends for the product to be so consumed. 2. This hazard only applies if the product is marketed uneviscerated. 3. This hazard only applies if the lobsters are held in pounds. 4. The scientific name for this species has changed since the last edition of this guidance.
70
TABLE 3-4
POTENTIAL PROCESS-RELATED HAZARDS

HAZARDS PATHOGENIC BACTERIA SURVIVAL THROUGH PROCESSES DESIGNED TO RETAIN RAW PRODUCT CHARACTERISTICS PATHOGENIC BACTERIA CONTAMINATION AFTER PASTEURIZATION AND SPECIALIZED COOKING PROCESSES
PATHOGENIC BACTERIA SURVIVAL THROUGH COOKING OR PASTEURIZATION
PATHOGENIC BACTERIA GROWTH TEMPERATURE ABUSE
S. AUREUS TOXIN - DRYING
S. AUREUS TOXIN - BATTER
C. BOTULINUM TOXIN
FINISHED PRODUCT FOOD1
PACKAGE TYPE
CHP 12 Cooked shrimp, crab, lobster, and other fish, including cooked meat, sections, and whole fish, and surimi-based analog products Cooked shrimp, crab, lobster, and other fish, including cooked meat, sections, and whole fish, and surimi-based analog products Pasteurized crab, lobster, and other fish, including pasteurized surimi-based analog products Pasteurized crab, lobster, and other fish, including pasteurized surimi-based analog products Smoked fish Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil) Other than reduced oxygen packaged
CHP 13
CHP 14
CHP 15
CHP 16
CHP 17
CHP 18
CHP 19
CHP 20
CHP 21
Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP hermetically sealed, or packed in oil) Other than reduced oxygen packaged
Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil)
71
GLASS INCLUSION
METAL INCLUSION
ALLERGENS/ ADDITIVES
TABLE 3-4

C. BOTULINUM TOXIN
PACKAGE TYPE
CHP 12 Smoked fish Salads, sandwiches, dips, cocktails, and similar seafood products prepared from ready-to-eat fishery products Other than reduced oxygen packaged Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil)
CHP 13
CHP 14
CHP 15
CHP 16
CHP 17
CHP 18
CHP 19
CHP 20
CHP 21
Salads, sandwiches, dips, cocktails, and similar seafood products prepared from ready-to-eat fishery products Battered or breaded (including surface-browned) raw shrimp, finfish, oysters, clams, squid, and other fish Stuffed crab, shrimp, finfish, and other fish Dried fish
Other than reduced oxygen packaged
All
All
All
72
GLASS INCLUSION
METAL INCLUSION
TABLE 3-4

C. BOTULINUM TOXIN
PACKAGE TYPE
CHP 12 Raw oysters, clams, and mussels Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil) Other than reduced oxygen packaged Reduced oxygen packaged (e.g. mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil) Other than reduced oxygen packaged
CHP 13
CHP 14
CHP 15
CHP 16
CHP 17
CHP 18
CHP 19
CHP 20
CHP 21
Raw oysters, clams, and mussels Raw fish other than oysters, clams, and mussels (finfish and non-finfish)
Raw fish other than oysters, clams, and mussels (finfish and non-finfish) Partially cooked or uncooked prepared foods
Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil) Other than reduced oxygen packaged
Partially cooked or uncooked prepared foods
73
GLASS INCLUSION
METAL INCLUSION
TABLE 3-4

C. BOTULINUM TOXIN
PACKAGE TYPE
CHP 12 Fully cooked prepared foods Reduced oxygen packaged (e.g., mechanical vacuum, steam flush, hot fill, MAP, CAP, hermetically sealed, or packed in oil) Other than reduced oxygen All
CHP 13
CHP 14
CHP 15
CHP 16
CHP 17
CHP 18
CHP 19
CHP 20
CHP 21
Fully cooked prepared foods Fermented, acidified, pickled, salted, and LACFs Fish oil
All
C. botulinum = Clostridium botulinum; S. aureus = Staphylococcus aureus; MAP = modified atmosphere packaging; CAP = controlled atmosphere packaging; and LACF = low-acid canned food. 1. You should include potential hazards from more than one finished product food category if your product fits more than one description. 2. This hazard only applies if you have knowledge, or have reason to know, that the fish will be consumed without a process sufficient to kill pathogens or if you represent, label, or intend for the product to be so consumed. 3. Controls for this hazard need not be included in HACCP plans for shelf-stable acidified and LACFs. See Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation (21 CFR 113), called the LACF Regulation in this guidance document, and Acidified Foods regulation (21 CFR 114) for mandatory controls. 4. This hazard does not apply to highly refined fish oil.
74
GLASS INCLUSION
METAL INCLUSION
CHAPTER 4: Pathogens From the Harvest Area

UNDERSTAND THE POTENTIAL HAZARD

This chapter covers the control of pathogens from the harvest area for both molluscan shellfish and fish other than molluscan shellfish. Strategies for control of pathogens There are a number of strategies for the control of pathogens in fish and fishery products. They include: Controlling the source (i.e., harvest waters) of molluscan shellfish and the time from exposure to air (i.e., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in this chapter); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogenic bacterial growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of acidity (pH) in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable acidified products, and by Chapter 13, for refrigerated acidified products); Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18);
Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for Clostridium botulinum, in Chapter 13; and for Staphylococcus aureus in hydrated batter mixes, in Chapter 15); Killing pathogenic bacteria by cooking or pasteurization (covered in Chapter 16) or retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation (hereinafter, the Low-Acid Canned Foods (LACF) Regulation), 21 CFR 113); Killing pathogenic bacteria by processes that retain raw product characteristics (covered in Chapter 17). Molluscan shellfish Pathogens found in waters from which molluscan shellfish are harvested can cause disease in consumers. For the purposes of this guidance, molluscan shellfish include: (1) oysters; (2) clams; (3) mussels; and (4) scallops, except where the final product is the shucked adductor muscle only. The pathogens of concern include both bacteria (e.g., Vibrio spp., Salmonella spp., Shigella spp., and Campylobacter jejuni (C. jejuni)) and viruses (e.g., hepatitis A virus and norovirus). See Appendix 7 for a description of the public health impacts of these pathogens. Pathogens from the harvest area are of particular concern in molluscan shellfish because (1) environments in which molluscan shellfish grow are commonly subject to contamination from
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sewage, which may contain pathogens, and contamination from naturally occurring bacteria, which may also be pathogens; (2) molluscan shellfish filter and concentrate pathogens that may be present in surrounding waters; and (3) molluscan shellfish are often consumed whole, either raw or partially cooked. Certain pathogens generally originate from human or animal fecal sources (e.g., Vibrio cholerae (V. cholerae) O1 and O139, Salmonella spp., Shigella spp., C. jejuni, Yersinia enterocolitica (Y. enterocolitica), hepatitis A virus, and norovirus). Other pathogens are naturally occurring in certain waters (e.g., Vibrio vulnificus (V. vulnificus), Vibrio parahaemolyticus (V. parahaemolyticus), and V. cholerae non-O1 and non-O139), and their presence is not associated with human or animal fecal sources. See Appendix 7 for a description of the public health impacts of these pathogens.
Control of pathogens of human or animal origin
harvest location, and the date of harvest (21 CFR 123.28(c)); (2) molluscan shellfish harvesters be licensed (note that licensing may not be required in all jurisdictions); (3) processors that ship, reship, shuck, or repack molluscan shellfish be certified; and (4) containers of shucked molluscan shellfish bear a label with the processors name, address, and certification number. The controls listed above serve to minimize the risk of molluscan shellfish containing pathogens of human or animal origin, but do not fully eliminate the risk. As a result, consumption of raw or undercooked molluscan shellfish may not be safe for individuals with certain health conditions, such as liver disease; chronic alcohol abuse; diabetes; and stomach, blood, and immune disorders. For this reason, shellfish control authorities require that shellstock intended for raw consumption bear a tag that instructs retailers to inform their customers that consuming raw or undercooked shellfish may increase the risk of foodborne illness, especially for individuals with certain medical conditions. You can also eliminate the hazard of pathogens from the harvest area by properly cooking, pasteurizing, or retorting the product. Guidance on cooking and pasteurizing to control pathogenic bacteria is provided in Chapter 16. Mandatory retorting controls are described in the LACF Regulation (21 CFR 113). It should be noted that neither cooking, nor pasteurizing, nor retorting will eliminate the hazards of natural toxins or environmental chemical contaminants and pesticides that also may be associated with molluscan shellfish. Appropriate control strategies for these hazards are provided in Chapters 6 and 9. Additionally, the laws and regulations of states that participate in the National Shellfish Sanitation Program administered by FDA require that all molluscan shellfish be harvested from waters authorized for harvesting by the shellfish control authority, regardless of how it will be processed.
Control of naturally occurring pathogens
To minimize the risk of molluscan shellfish containing pathogens of human or animal fecal origin (e.g., V. cholerae O1 and O139, Salmonella spp., Shigella spp., C. jejuni, hepatitis A virus, and norovirus), Federal, state, tribal, territorial and foreign government agencies, called shellfish control authorities, classify waters in which molluscan shellfish are found, based, in part, on an assessment of water quality. As a result of these classifications, molluscan shellfish harvesting is allowed from some waters, not from others, and only at certain times or under certain conditions from others. Shellfish control authorities exercise control over the molluscan shellfish harvesters to ensure that harvesting takes place only when and where it has been determined to be safe. Other significant elements of shellfish control authorities efforts to control the safety of molluscan shellfish include requirements that (1) containers of in-shell molluscan shellfish (shellstock) bear a tag that identifies the type and quantity of shellfish, the harvester, the
To minimize the risk of illness from the consumption of molluscan shellfish containing
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naturally occurring pathogens such as V. vulnificus, V. parahaemolyticus, and V. cholerae non-O1 and non-O139, shellfish control authorities place certain controls on the harvest of molluscan shellfish. Naturally occurring pathogens may be present in relatively low numbers at the time that molluscan shellfish are harvested but may increase to more hazardous levels if they are exposed to time and temperature abuse. To minimize the risk of growth of Vibrio spp., shellfish control authorities place limits on the time from exposure to air (i.e., by harvest or receding tide) to refrigeration. The length of time is dependent upon the Average Monthly Maximum Air Temperature (AMMAT) or the Average Monthly Maximum Water Temperature (AMMWT) at the time of harvest, which is determined by the shellfish control authority. In addition to the above, control for V. parahaemolyticus in oysters involves (1) a risk evaluation by the shellfish control authority to determine whether the risk of V. parahaemolyticus illness from the consumption of oysters harvested from a growing area(s) in a state is reasonably likely to occur; and (2) a determination by shellfish control authorities about whether a growing area(s) in a state has average monthly daytime water temperatures that exceed 60F for waters bordering the Pacific Ocean or 81F for waters bordering the Gulf of Mexico and the Atlantic Ocean (New Jersey and south) at times during which harvesting occurs. If either of these conditions is met, the shellfish control authority develops and implements a V. parahaemolyticus control plan intended to reduce the incidence of V. parahaemolyticus illnesses. As part of the plan, shellfish control authorities may (1) temporarily close some waters to the harvesting of oysters; (2) limit the time from exposure to air (i.e., by harvest or receding tide) to refrigeration; (3) temporarily permit harvesting of oysters for products that will be labeled For Shucking Only from some waters; or (4) temporarily permit harvesting of oysters for processes that retain raw product characteristics (covered in Chapter 17) only from some waters.
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As with pathogens of sewage origin, the above controls for naturally occurring pathogens help minimize the risk from these pathogens in molluscan shellfish but do not fully eliminate the risk. For this same reason, shellfish control authorities require that shellstock intended for raw consumption bear a tag containing an advisory relative to raw and undercooked consumption (described above). The controls for Vibrio spp. discussed in this chapter apply only to molluscan shellfish if they are intended for raw consumption. For example, they would not be applied to oyster shellstock if tags on the containers of shellstock indicate that they must be shucked before consumption. Vibrio spp. can be eliminated or reduced to nondetectable levels by cooking, pasteurizing, and retorting. These control mechanisms are widely used in the processing of fishery products for the control of pathogens. Guidance for these control mechanisms can be found in Chapter 16 (cooking and pasteurization to control pathogenic bacteria) and the LACF Regulation, 21 CFR 113 (retorting). Other mechanisms for control of Vibrio spp. include processes that are designed to retain the raw characteristics of the food, including individual quick freezing (IQF) with extended storage, mild heat, high hydrostatic pressure, and irradiation. These control mechanisms are covered in Chapter 17. Appropriate controls to prevent further growth of these pathogenic bacteria during processing, storage, and transportation between processors are discussed in Chapter 12. Fish other than molluscan shellfish Pathogens from the harvest area may also be a potential hazard for fish other than molluscan shellfish. Pathogens may be found on raw fish as a result of near-shore harvest water contamination, poor sanitary practices on the harvest vessel, and poor aquacultural practices. The pathogens of concern include those described above for molluscan shellfish, but also include Listeria monocytogenes and Escherichia coli. See Appendix 7 for a description of the public health impacts of these pathogens.
Control of pathogens
The processor can control pathogens by proper cooking, pasteurizing, or retorting. Guidance for these control mechanisms can be found in Chapter 16 (cooking and pasteurizing to kill pathogenic bacteria) and the LACF Regulation, 21 CFR 113 (retorting). For many products (e.g., raw fish fillets), there is no cooking, pasteurizing, or retorting step performed by the processor. For most of these products, cooking is performed by the consumer or end user before consumption. FDA is not aware of any Hazard Analysis Critical Control Point (HACCP) controls that exist internationally for the control of pathogens in fish and fishery products that are customarily fully cooked by the consumer or end user before consumption other than a rigorous sanitation regime as part of a prerequisite program or as part of HACCP itself. The Fish and Fishery Products regulation (21 CFR 123.11, Sanitation control procedures) requires such a regime. The proper application of sanitation controls is essential because of the likelihood that pathogens in seafood products can be introduced through poor handling practices by the aquaculture producer, the harvester, or the processor. For some products (e.g., raw fish intended for sushi), there is no cooking performed by either the processor, or the consumer, or the end user. When the processor has knowledge or has reason to know that the product will be consumed without a process sufficient to kill pathogens of public health concern or where the processor represents, labels, or intends for the product to be so consumed, the processor should control time and temperature exposure of the product to prevent growth of bacterial pathogens and formation of toxins by any bacterial pathogens that may be present in the product. Guidance for these controls can be found in Chapter 12 and in Chapter 13 (for those products where the packaging technique creates a reduced oxygen environment).
Note: The guidance contained in the remainder of this chapter applies to receiving controls for molluscan shellfish only.
DETERMINE WHETHER THIS POTENTIAL HAZARD IS SIGNIFICANT.

The following guidance will assist you in determining whether pathogens from the harvest area are a significant hazard at a processing step:
1. Is it reasonably likely that an unsafe level of pathogens from the harvest area will be introduced at this processing step (e.g., are pathogens present in the raw material at an unsafe level)?
Under ordinary circumstances, it would be reasonably likely that pathogens of human or animal origin from the harvest area could enter the process at an unsafe level at the receiving step for the following types of fish: Raw oysters; Raw clams; Raw mussels; Raw scallops (see information
provided under Intended use).
In addition: Under ordinary circumstances, it would be reasonably likely that an unsafe level of V. vulnificus (a naturally occurring pathogen) could enter the process from oysters harvested from areas that have been confirmed as the original source of oysters associated with two or more V. vulnificus illnesses (e.g., states bordering the Gulf of Mexico); Under ordinary circumstances, it would be reasonably likely that an unsafe level of V. parahaemolyticus could enter the process from oysters harvested from an area that meets any one of the following conditions:
The shellfish control authority has conducted a risk evaluation and determined that the risk of V. parahaemolyticus illness from the consumption of oysters harvested
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from that growing area is reasonably likely to occur. Specific guidance for determining risk can be found in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision;
Making sure that incoming molluscan shellfish are supplied by a licensed harvester (where licensing is required by law) or by a certified dealer; Killing pathogenic bacteria by cooking or pasteurizing (covered in Chapter 16) or retorting (covered by the LACF Regulation, 21 CFR 113). It should be noted that neither cooking nor retorting will eliminate the hazards of natural toxins or chemical contamination that also may be associated with molluscan shellfish; Killing Vibrio spp. by IQF with extended storage, mild heat, irradiation, or high hydrostatic pressure (covered in Chapter 17); Minimizing the growth of V. cholerae, V. parahaemolyticus, and V. vulnificus by limiting the time from exposure to air (i.e., by harvesting or receding tide) to refrigeration; Including an advisory on tags on containers of molluscan shellstock intended for raw consumption or on containers of shucked molluscan shellfish that instructs retailers to inform their customers that consuming raw or undercooked shellfish may increase the risk of foodborne illness, especially for individuals with certain medical conditions. Intended use For most raw molluscan shellfish products, you should assume that the product will be consumed raw. You should, therefore, identify the hazard as significant if it meets the criteria in the previous section. Where the product consists of scallop adductor muscle only, it may be reasonable to assume that the product will be cooked before consumption. In this case, you would not need to identify pathogens from the harvest area as a significant hazard. However, if you have knowledge, or have
The shellfish control authority has determined that harvesting occurs in the growing area at a time when average monthly daytime water temperatures exceed 60F for waters bordering the Pacific Ocean and 81F for waters bordering the Gulf of Mexico and the Atlantic Ocean (New Jersey and south), except where a more rigorous risk evaluation has led the shellfish control authority to conclude that the risk of V. parahaemolyticus illness from the consumption of oysters harvested from that growing area is not reasonably likely to occur; The growing area has been confirmed as the original source of oysters associated with two or more V. parahaemolyticus illnesses in the past 3 years.
2. Can an unsafe level of pathogens from the harvest area that was introduced at the receiving step be eliminated or reduced to an acceptable level at this processing step?
Pathogens from the harvest area should also be considered a significant hazard at any processing step where a measure is or can be used to eliminate the pathogens that had been introduced at a previous step or is adequate to reduce the likelihood of occurrence of the hazard to an acceptable level. Measures to eliminate pathogens or to reduce the likelihood of occurrence of the hazard from the harvest area include: Checking incoming molluscan
shellfish to ensure that they are
properly tagged or labeled;
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reason to know, that the scallop adductor muscle will be consumed without a process sufficient to kill pathogens of public health concern or where the processor represents, labels, or intends for the product to be so consumed, you should control time and temperature exposure of the product to prevent growth of bacterial pathogens and formation of toxins by any bacterial pathogens that may be present in the product. Guidance for these controls can be found in Chapter 12 and in Chapter 13 (for those products where the packaging technique creates a reduced oxygen environment). The controls for V. vulnificus and V. parahaemolyticus that are discussed in this chapter do not need to be applied to molluscan shellfish that are not marketed for raw consumption. For example, they need not be applied to oyster shellstock from the Gulf of Mexico if tags on the containers of shellstock indicate that they must be shucked before consumption.
Additionally, the laws and regulations of states that participate in the National Shellfish Sanitation Program require that all molluscan shellfish be harvested from waters authorized for harvesting by the shellfish control authority, regardless of how it will be processed. Example: A canned clam chowder processor should set the CCP for pathogens from the harvest area at the retorting step, and would not identify the receiving step as a CCP for this hazard.
b. If the product will not be cooked,
IDENTIFY CRITICAL CONTROL POINTS.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for pathogens from the harvest area:
1. Will the product be cooked, pasteurized, or retorted sufficiently to kill all bacterial pathogens of public health concern during processing in your facility? a. If it will be, you should identify the cook
pasteurized, or retorted sufficiently to kill bacterial pathogens during processing in your facility, you should identify the receiving step as a CCP where you can exercise control over the source of the molluscan shellfish and the time from exposure to air (i.e., by harvest or receding tide) to refrigeration in order to control pathogens from the harvest area. If the finished product is shellstock intended for raw consumption, you should also identify the labeling step or the label (tag) receiving step as a CCP, because you can ensure that the raw consumption advisory is on the tag. Example: A processor that shucks raw oysters and ships a raw product should check the tags of incoming shellstock (in-shell oysters), the license of the harvesters that supply the shellstock, and the length of time between exposure to air (i.e., by harvest or receding tide) and refrigeration. The processor should identify the receiving step as the CCP for this hazard.
step, pasteurization step, or retorting step as the CCP. In this case, you would not need to identify the receiving step as a CCP for the hazard of pathogens from the harvest area. However, note that neither cooking, nor pasteurizing, nor retorting will eliminate the hazards of natural toxins or environmental chemical contaminants and pesticides that also may be associated with molluscan shellfish. Chapters 6 and 9 provide appropriate control strategies for these hazards.
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Example: A processor that ships oyster shellstock should check the tags of incoming shellstock, the license of the harvesters that supply the shellstock, the harvest location, and the length of time between exposure to air (i.e., by harvest or receding tide) and refrigeration. The processor should identify the receiving step as a CCP for this hazard. The processor should also identify the labeling step as a CCP for this hazard and would check for the presence of the raw consumption advisory on the label or tag. This control approach includes two control strategies referred to in this chapter as Control Strategy Example 1 - Source Control and Control Strategy Example 2 - Shellstock Temperature Control. Refer to Control Strategy Example 2 - Shellstock Temperature Control when controls for V. vulnificus or V. parahaemolyticus are needed. Conditions that warrant control for these pathogens are described below.
2. If the finished product is raw oyster shellstock intended for raw consumption and is harvested from a state that has been confirmed as the original source of oysters associated with two or more V. vulnificus illnesses (e.g., the Gulf of Mexico), will it be subjected in your plant to a process that is designed to retain raw product characteristics (e.g., mild heat processing, IQF with extended storage, high hydrostatic pressure processing, or irradiation) and is sufficient to kill V. vulnificus during processing in your facility (i.e., reduced to a non-detectable level of less than 30 Most Probable Number per gram (herein referred to as 30 MPN/gram), as defined in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision)? a. If the finished product will be subjected
characteristics as the CCP for control of V. vulnificus. In this case, you would not need to identify the receiving step as a CCP for the control of V. vulnificus. Example: A Gulf of Mexico oyster processor should set the CCP for V. vulnificus at the mild heat processing step and would not identify the receiving step as a CCP for that pathogen. If you choose to follow this approach, you should refer to Chapter 17 for further guidance.
b. If the finished product will not be
subjected to a process that is designed to retain raw product characteristics and is sufficient to kill V. vulnificus during processing in your facility, you should identify the receiving step as a CCP, because you can exercise control over the time from exposure to air (i.e., by harvest or receding tide) to refrigeration in order to control V. vulnificus. Example: A Gulf of Mexico oyster processor should set the CCP for V. vulnificus at the receiving step. This control strategy is referred to as Control Strategy Example 2 - Shellstock Temperature Control Refer to Control Strategy Example 2 - Shellstock Temperature Control when controls for V. vulnificus are needed. These controls should be considered in addition to the controls contained in Control Strategy Example 1 - Source Control. If your shellfish control authority has developed a V. vulnificus control plan, you should develop a HACCP plan that is based on the requirements of that plan. Elements of the control strategy example provided in this chapter and in Chapter 17 may be useful for development of such a plan.
to such a process in your facility, you should identify the processing step that is designed to retain raw product
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3. If the finished product is raw oyster shellstock intended for raw consumption and is harvested from an area where: (1) The shellfish control authority has conducted a risk evaluation and determined that the risk of V. parahaemolyticus illness from the consumption of oysters harvested from that growing area is reasonably likely to occur; (2) the shellfish control authority has determined that harvesting occurs in the growing area at a time when average monthly daytime water temperatures exceed 60F for waters bordering the Pacific Ocean and 81F for waters bordering the Gulf of Mexico and the Atlantic Ocean (New Jersey and south); or (3) the waters of the state have been confirmed as the original source of oysters associated with two or more V. parahaemolyticus illnesses in the past 3 years, will it be subjected in your facility to a process that is designed to retain raw product characteristics (e.g., mild heat processing, IQF with extended storage, high hydrostatic pressure processing, or irradiation) and is sufficient to kill V. parahaemolyticus (i.e., reduced to a nondetectable level of less than 30 MPN/gram, as defined in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision)? a. If the finished product will be subjected to
b. If the finished product will not be
subjected in your facility to a process that is designed to retain raw product characteristics and is sufficient to kill V. parahaemolyticus during processing, you should identify the receiving step as a CCP, because you can exercise control over the time from exposure to air (i.e., by harvest or receding tide) to refrigeration in order to control V. parahaemolyticus or exercise other controls as determined by your states V. parahaemolyticus control plan. Example: An oyster processor should set the CCP for V. parahaemolyticus at the receiving step. This control strategy is referred to as Control Strategy Example 2 - Shellstock Temperature Control. Refer to Control Strategy Example 2 - Shellstock Temperature Control when controls for V. parahaemolyticus are needed. These controls should be considered in addition to the controls contained in Control Strategy Example 1 - Source Control. If your shellfish control authority has developed a V. parahaemolyticus control plan, you should develop a HACCP plan that is based on the requirements of that plan. Elements of the control strategy examples provided in this chapter and in Chapter 17 may be useful for development of such a plan. Only the primary processor (the processor who takes possession of the molluscan shellfish from the harvester) should apply the time-to refrigeration controls for Vibrio spp. that are discussed in this chapter, because this processor is in the best position to control the time from exposure to air (i.e., by harvest or receding tide) to refrigeration.
such a process in your facility, you should identify the processing step designed to retain raw product characteristics as the CCP for the control of V. parahaemolyticus. In this case, you would not need to identify the receiving step as a CCP for the control of V. parahaemolyticus. Example: An oyster processor should set the CCP for V. parahaemolyticus at the mild heat processing step and would not identify the receiving step as a CCP for that pathogen. If you choose to follow this approach, you should refer to Chapter 17 for further guidance.
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DEVELOP A CONTROL STRATEGY.

The following guidance provides three examples of control strategies for pathogens from the harvest area. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations, except that some parts of Control Strategy Example 1 Source Control are specifically required by the Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products regulation, 21 CFR 123 (called the Seafood HACCP Regulation in this guidance document). The following are examples of control strategies included in this chapter:
MAY APPLY TO PRIMARY PROCESSOR MAY APPLY TO SECONDARY PROCESSOR
accompanied by a bill of lading or similar shipping document that contains the same information;
Note: The source controls listed in this critical limit are required under 21 CFR 123.28(c).
OR All containers of shellstock received from a processor must bear a tag that discloses the date and place they were harvested (by state and site), the type and quantity of shellfish, and the certification number of the processor; OR All containers of shucked molluscan shellfish must bear a label that identifies the name, address, and certification number of the packer or repacker of the product; AND All molluscan shellfish must have been harvested from waters authorized for harvesting by a shellfish control authority. For U.S. federal waters, no molluscan shellfish may be harvested from waters that are closed to harvesting by an agency of the federal government; AND All molluscan shellfish must be from a harvester that is licensed as required (note that licensing may not be required in all jurisdictions) or from a processor that is certified by a shellfish control authority; AND All finished product shellstock intended for raw consumption must bear a tag that instructs retailers to inform their customers that consuming raw or undercooked shellfish may increase the risk of foodborne illness, especially for individuals with certain medical conditions.
Note: Only the primary processor, the processor that takes possession of the molluscan shellfish from the harvester, needs to apply controls relative to the identification of the harvester, the harvesters license, or the approval status of the harvest waters.
CONTROL STRATEGY
Source control Shellstock temperature control
CONTROL STRATEGY EXAMPLE 1SOURCE CONTROL

Note: The following controls should be considered in addition to those in Control Strategy Example 2 - Shellstock Temperature Control.
Set Critical Limits.

All containers of shellstock (in-shell molluscan shellfish) received from a harvester must bear a tag that discloses the date and place they were harvested (by state and site), type and quantity of shellfish, and information on the harvester or the harvesters vessel (i.e., the identification number assigned to the harvester by the shellfish control authority, where applicable, or if such identification numbers are not assigned, the name of the harvester or the name or registration number of the harvesters vessel). For bulk shipments of shellstock where the shellstock is not containerized, the shellstock must be
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Establish Monitoring Procedures. What Will Be Monitored?

Information contained on tags on containers of incoming shellstock or on the bill of lading or similar shipping document accompanying bulk shipments of shellstock; AND Information on whether the harvest area is authorized for harvest by a shellfish control authority or information on whether federal harvest waters are closed to harvesting by an agency of the federal government; OR Information contained on labels on containers of incoming shucked molluscan shellfish; AND The harvesters license, where applicable; AND The raw consumption advisory on tags on containers of finished product shellstock intended for raw consumption or the raw consumption advisory on labels on containers of shucked molluscan shellfish.
For checking incoming labels:
At least three containers randomly selected from every lot;
AND
For checking licenses:
Every delivery;
AND For checking the raw consumption advisory on finished product tags or labels:
Each container of finished product shellstock intended for raw consumption or at least three containers randomly selected from every lot of shucked molluscan shellfish.
Who Will Do the Monitoring?

Any person who has an understanding of the nature of the controls.
Establish Corrective Action Procedures.

Take the following corrective action to a product involved in a critical limit deviation:
Reject the lot; OR Relabel finished product shellstock intended for raw consumption that does not bear a tag that contains the raw consumption advisory or relabel shucked molluscan shellfish that does not bear a label that contains the raw consumption advisory; OR Reject any incoming tags to be used on finished product shellstock intended for raw consumption that do not contain the raw consumption advisory or reject any incoming labels to be used on shucked molluscan shellfish that do not contain the raw consumption advisory. AND
How Will Monitoring Be Done?

Perform visual checks; AND Ask the shellfish control authority of the state in which your shellstock are harvested whether the harvest area is authorized for harvest.
How Often Will Monitoring Be Done (Frequency)?

For checking incoming tags:
OR
Every container;
For checking the bill of lading or similar shipping document:
OR
Every delivery;
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Take the following corrective action to regain control over the operation after a critical limit deviation:
Quantity and type of shellfish; AND Name and certification number of the packer or repacker; AND Presence of the raw consumption advisory.
Discontinue use of the supplier until evidence is obtained that harvesting, tagging, and/or label manufacturing practices have changed; OR Modify labeling practices.
Establish a Recordkeeping System.

For shellstock:
Establish Verification Procedures.

Review monitoring and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Receiving record that documents:
Date of harvest; AND

Location of harvest by state and site;
AND
Quantity and type of shellfish;
AND Name of the harvester, name or registration number of the harvesters vessel, or an identification number issued to the harvester by the shellfish control authority (for shellstock received directly from the harvester only); AND Number and date of expiration of the harvesters license, where applicable;
AND
Certification number of the shipper,
where applicable; AND For shellstock intended for raw consumption, the presence of the raw consumption advisory, when received from a certified dealer.
For shucked molluscan shellfish:
Date of receipt; AND

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TABLE 4-1
CONTROL STRATEGY EXAMPLE 1 - SOURCE CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Source Control. This example illustrates how a primary processor (processor that takes possession of the oysters from the harvester) of shellstock oysters, that is, the shellstock shipper, can control pathogens from the harvest area. It is provided for illustrative purposes only. This control strategy should be considered in addition to Control Strategy Example 2 - Shellstock Temperature Control.
Pathogens from the harvest area may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., natural toxins, environmental chemical contaminants and pesticides, and pathogens during processing).
Example Only See Text for Full Recommendations

(3) MONITORING WHAT HOW FREQUENCY WHO CORRECTIVE ACTION(S) RECORDS VERIFICATION CRITICAL LIMITS FOR EACH PREVENTIVE MEASURE (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
CRITICAL CONTROL POINT
SIGNIFICANT HAZARD(S)
Receiving shellstock
Pathogens from the harvest area
Information on incoming shellstock tags
Visual checks
Every sack
Receiving employee
All incoming shellstock must be tagged with the date and place of harvest, type and quantity of shellfish, and name or registration number of the harvesters vessel Harvest site on tags Ask the shellfish control authority of the state in which the shellstock are harvested whether the area is authorized for harvest Harvesters license Visual checks Every delivery Visual checks Every lot Receiving employee
Reject the lot Discontinue use of the supplier until evidence is obtained that tagging practices have changed
Receiving record
CHAPTER 4: Pathogens From the Harvest Area All shellstock must be from a licensed harvester Receiving employee
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Review monitoring and corrective action records within 1 week of preparation
All shellstock must be from waters approved by the state shellfish control authority
Reject lots from unapproved waters Discontinue use of the supplier until evidence is obtained that harvesting practices have changed Reject lots from unlicensed harvesters Discontinue use of the supplier until evidence is obtained that the harvester has secured a license
Receiving record
Receiving record
CONTROL STRATEGY EXAMPLE 2 - SHELLSTOCK

TEMPERATURE CONTROL
Note: The following controls should be considered in addition to those in Control Strategy Example 1 - Source Control.
12 hours; OR

When controls for neither V. vulnificus nor V. parahaemolyticus are needed:
For AMMAT of greater than 80F (greater than 27C): 10 hours.
Note: AMMAT is determined by the shellfish control authority. The shellfish control authority may implement time to temperature controls that are more stringent than those described here. Processors should consult with their shellfish control authority for current requirements. Note: Only the primary processor, the processor that takes possession of the molluscan shellfish from the harvester, should apply controls for the time from exposure to air (i.e., by harvest or receding tide) to refrigeration.

OR
For AMMAT of less than 66F (less than 19C): 36 hours;

OR
For AMMAT of 66 to 80F (19 to 27C):
24 hours; OR For AMMAT of greater than 80F (greater than 27C): 20 hours;

The time shellfish was exposed to air (i.e., by harvest or receding tide); AND The time shellstock was placed under refrigeration;
Note: AMMAT is determined by the shellfish control authority.
When controls for V. vulnificus are needed:
For AMMWT of less than 65F (less than 18C): 36 hours;

OR
For AMMWT of 65 to 74F (18 to 23C):
14 hours; OR For AMMWT of greater than 74 to 84F (greater than 23 to 29C): 12 hours; OR For AMMWT of greater than 84F (greater than 29C): 10 hours;

For the time from exposure to air (i.e., by harvest or receding tide) to refrigeration:
Obtain information from the shellfish control authority;

OR
Check the harvesters log or tags;
OR Note the time of departure from and return to dock;
OR
Ask the harvester.
Note: AMMWT is determined by the shellfish control authority. The shellfish control authority may implement time to temperature controls that are more stringent than those described here. Processors should consult with their shellfish control authority for current requirements.

Every delivery.
OR When controls for V. parahaemolyticus are needed:

Any person who has an understanding of the nature of the controls may perform the monitoring.
For AMMAT of less than 66F (less than 19C): 36 hours;

OR
For AMMAT of 66 to 80F (19 to 27C):
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Reject lots that do not meet the critical limit; OR Subject the shellstock to a cooking, pasteurization, retorting, or other process that reduces pathogens of public health concern to acceptable levels. See Chapters 16 and 17 and LACF Regulation (21 CFR 113) for further guidance; OR Destroy the product; OR Divert the product to a non-food use. AND
Discontinue use of the supplier until evidence is obtained that harvesting practices have changed.

Time shellstock is exposed to air (i.e., by harvest or receding tide); AND Time shellstock was placed under refrigeration;
AND
AMMWT.

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TABLE 4-2
CONTROL STRATEGY EXAMPLE 2 - SHELLSTOCK TEMPERATURE CONTROL (V. VULNIFICUS MODEL)
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Shellstock Temperature Control. This example illustrates how a primary processor (one that takes possession of the oysters from the harvester) of shellstock oysters, that is, the shellstock shipper, can control the pathogen from the harvest area, V. vulnificus. It is provided for illustrative purposes only. This control strategy should be considered in addition to Control Strategy Example 1 - Source Control.
Pathogens from the harvest area may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., natural toxins, environmental chemical contaminants and pesticides, and pathogens during processing).

(3) MONITORING WHAT HOW FREQUENCY WHO CORRECTIVE ACTION(S) RECORDS VERIFICATION (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
CRITICAL CONTROL POINT Maximum time from harvest to refrigeration: AMMWT < 65F: 36 hours AMMWT 65 to 74F: 14 hours AMMWT >74 to 84F: 12 hours; AMMWT >84F: 10 hours
CRITICAL LIMITS FOR EACH PREVENTIVE MEASURE
Pathogens from the harvest area
Time of harvest
Harvesters log
Every delivery
Receiving employee
Receiving record
CHAPTER 4: Pathogens From the Harvest Area Time placed in refrigeration Visual checks Every delivery Receiving employee
AMMWT = Average Monthly Maximum Water Temperature
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Reject lot Discontinue use of the supplier until evidence is obtained that harvesting practices have changed
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Cook, D. W., J. C. Bowers, and A. DePaola. 2002. Density of total and pathogenic (tdh+) Vibrio parahaemolyticus in Atlantic and Gulf Coast molluscan shellfish at harvest. J. Food Prot. 65:1873-1880. DePaola, A., L. H. Hopkins, J. T. Peeler, B. Wentz, and R. M. McPhearson. 1990. Incidence of Vibrio parahaemolyticus in U.S. coastal waters and oysters. Appl. Environ. Microbiol. 56:2299-2302. Frankhauser, R. L., S. S. Monroe, J. S. Noel, C. D. Humphrey, J. S. Bresee, U. D. Parashar, T. Ando, and R. I. Glass. 2002. Epidemiologic and molecular trends of Norwalk-like viruses associated with outbreaks of gastroenteritis in the United States. J. Infect. Dis. 186:1-7. Motes, M. L., A. DePaola, D. W. Cook, J. E. Veazey, J. C. Hunsucker, W. E. Garthright, R. J. Blodgett, and S. J. Chirtel. 1998. Influence of water temperature and salinity on Vibrio vulnificus in northern Gulf and Atlantic Coast oysters (Crassostrea virginica). Appl. Environ. Microbiol. 64:1459-1465. Nishibuchi, M., and A. DePaola. 2005. Vibrio species, p. 251-271. In P. M. Fratamico, A. K. Bhunia, and J. L. Smith (ed.), Foodborne pathogens: microbiology and molecular biology. Caister Academic Press, Norfolk, UK. Rippey, S. R. 1994. Infectious diseases associated with molluscan shellfish consumption. Clin. Microbiol. Rev. 7:419-425.
U.S. Centers for Disease Control and Prevention. 2001. Norwalk-like viruses: Public health consequences and outbreak management. Morb. Mortal. Wkly. Rep. 50:1-18. U.S. Centers for Disease Control and Prevention. February 2010 Norovirus: Technical Fact Sheet. Atlanta, GA. http://www. cdc.gov/ncidod/dvrd/revb/gastro/norovirus factsheet.htm. U.S. Food and Drug Administration. 2007. National Shellfish Sanitation Program Guide for the control of molluscan shellfish 2007 revision. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Division of Seafood Safety, College Park, MD. http://www.fda.gov/ Food/FoodSafety/Product-SpecificInformation/ Seafood/FederalStatePrograms/ NationalShellfishSanitationProgram/ ucm046353.htm.
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CHAPTER 5: Parasites
UNDERSTAND THE POTENTIAL HAZARD

Parasites (in the larval stage) consumed in uncooked or undercooked seafood can present a human health hazard. Among parasites, the nematodes or roundworms (Anisakis spp., Pseudoterranova spp., Eustrongylides spp., and Gnathostoma spp.), cestodes or tapeworms (Diphyllobothrium spp.), and trematodes or flukes (Chlonorchis sinensis (C. sinensis), Opisthorchis spp., Heterophyes spp., Metagonimus spp., Nanophyetes salmincola, and Paragonimus spp.) are of most concern in seafood. Most of these parasites cause mild-to-moderate illness, but severe symptoms can occur. Roundworms may embed in the intestinal wall and cause nausea, vomiting, diarrhea, and severe abdominal pain and sometimes may penetrate the intestine. Tapeworms can cause abdominal swelling and abdominal cramps and may lead to weight loss and anemia. Intestinal flukes (Heterophyes spp., Metagonimus spp., and Nanophyetes salmincola) may cause abdominal discomfort and diarrhea. Some intestinal flukes may also migrate to and damage the heart and central nervous system. Liver flukes (C. sinensis and Opisthorchis spp.) and lung flukes (Paragonimus spp.) may migrate to the liver and lung and sometimes cause serious problems in other vital organs. Some products that have been implicated in human parasite infection are the following: ceviche (fish and spices marinated in lime juice); lomi lomi (salmon marinated in lemon juice, onion, and tomato); poisson cru (fish marinated in citrus juice, onion, tomato, and coconut milk); herring roe; sashimi (slices of raw fish); sushi (pieces of raw fish with rice
and other ingredients); green herring (lightly brined herring); drunken crabs (crabs marinated in wine and pepper); cold-smoked fish; and, undercooked grilled fish. A survey of U.S. gastroenterologists confirmed that seafood-borne parasitic infections occur in the United States with sufficient frequency to recommend preventive controls during the processing of parasite-containing species of fish that are intended for raw consumption. Controlling parasites The process of heating raw fish sufficiently to kill bacterial pathogens is also sufficient to kill parasites. Guidance concerning cooking and pasteurizing to kill bacterial pathogens is provided in Chapters 13 (hot smoking) and 16 (cooking and pasteurization). Regulatory requirements for retorting (i.e., thermal processing of low acid canned foods) are contained in the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (hereinafter, the Low-Acid Canned Foods (LACF) Regulation). This guidance does not provide further information on retorting. The effectiveness of freezing to kill parasites depends on several factors, including the temperature of the freezing process, the length of time needed to freeze the fish tissue, the length of time the fish is held frozen, the species and source of the fish, and the type of parasite present. The temperature of the freezing process, the length of time the fish is held frozen, and the type of parasite appear to be the most important factors. For example, tapeworms are more susceptible to freezing than are roundworms. Flukes appear to be more resistant to freezing than roundworms.
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Freezing and storing at an ambient temperature of -4F (-20C) or below for 7 days (total time), or freezing at an ambient temperature of -31F (-35C) or below until solid and storing at an ambient temperature of -31F (-35C) or below for 15 hours, or freezing at an ambient temperature of -31F (-35C) or below until solid and storing at an ambient temperature of -4F (-20C) or below for 24 hours are sufficient to kill parasites. Note that these conditions may not be suitable for freezing particularly large fish (e.g., thicker than 6 inches). Brining and pickling may reduce the parasite hazard in a fish, but they do not eliminate it, nor do they minimize it to an acceptable level. Nematode larvae have been shown to survive 28 days in an 80 salinometer brine (21% salt by weight). Fish that contain parasites in their flesh may also contain parasites within their egg sacs (skeins), but generally not within the eggs themselves. For this reason, eggs that have been removed from the sac and rinsed are not likely to contain parasites. Trimming away the belly flaps of fish or candling and physically removing parasites are effective methods for reducing the numbers of parasites. However, they do not completely eliminate the hazard, nor do they minimize it to an acceptable level.
that the fish will be consumed without thorough cooking by the end user or if you represent, label, or intend for the product to be consumed in that manner. Species of fish not listed with a parasite hazard in Tables 3-2 and 3-3 may have a parasite hazard that has not been identified if these fish are not customarily consumed raw or undercooked, or if the hazard occurs in certain localized harvest areas that are not known commercial sources of fresh fish for the U.S. You should consider this possibility in your hazard analysis. Species that normally have a parasite hazard as a result of consuming infected prey apparently do not have the same parasite hazard when raised only on pelleted feed in an aquaculture operation. You need not consider such aquacultured fish as having a parasite hazard. On the other hand, aquacultured fish that are fed processing waste, fresh fish, or plankton may have a parasite hazard, even when wildcaught fish of that species do not normally have a parasite hazard. Pellet fed fish that sometimes depend on wild-caught prey to supplement their diet may have a parasite hazard. In addition, fish raised in freshwater may have a parasite hazard from trematodes because these parasites enter the fish through the skin rather than in the food. You should verify the culture methods used by your aquaculture producers before eliminating parasites as a significant hazard. If the finished product is fish eggs that have been removed from the sac (skein) and rinsed, the fish eggs are not reasonably likely to contain parasites and you need not consider such product as having a parasite hazard. However, unrinsed fish eggs or fish eggs that remain in the sac ordinarily will have a parasite hazard if the species is identified in Table 3-2 or 3-3 as having a parasite hazard. If you receive the fish frozen and have documented assurance from your supplier that the fish are frozen in a way that will
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DETERMINE WHETHER THE POTENTIAL HAZARD IS SIGNIFICANT.

The following guidance will assist you in determining whether parasites are a significant hazard at a processing step:
1. Is it reasonably likely that parasites will be introduced at the receiving step (e.g., do they come in with the raw material)?
Tables 3-2 and 3-3 (Chapter 3) list those species for which FDA has information that a potential parasite hazard exists. Ordinarily, you should identify the receiving step for these species as having a significant parasite hazard if you know or have reason to know
kill the parasites (e.g., consistent with the guidance in this chapter), you do not need to identify the hazard of parasites as reasonably likely to occur in your product. It is not reasonably likely that parasites will enter the process at other processing steps.
2. Can the parasite hazard that was introduced at an earlier step be eliminated or reduced to an acceptable level at this processing step?
primary processor would not need to identify parasites as a significant hazard.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for parasites:
1. Does the process contain a heating step, such as retorting, cooking, or pasteurizing that is designed to kill bacterial pathogens? a. If the process contains a heating step,
Parasites should be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard that was introduced at an earlier step or to reduce to an acceptable level the likelihood of occurrence of the hazard. Preventive measures for parasites can include: Retorting (covered in 21 CFR
113, the LACF Regulation);
Hot smoking (covered in Chapter 13); Cooking and pasteurization
(covered in Chapter 16);
Freezing (covered in this chapter). Intended use If the consumer intends to cook the fish thoroughly before consumption, then you do not need to consider the hazard significant, even if Table 3-2 or 3-3 lists the species as having a potential parasite hazard. In order to eliminate parasites as a significant hazard when you are unsure of the products intended use, you should obtain documented assurance from the subsequent processor, restaurateur, or institutional user (e.g., prison or nursing home) that the fish will be processed in a way that will kill the parasites. Example: A primary processor receives whole salmon from the harvest vessel and re-ices the fish for shipment to a second processor. The second processor butchers the fish for sale to the sushi market. The primary processor has documented assurance that the second processor freezes the fish before sale. The
you should identify the heating step as the CCP and would not need to identify receiving as a CCP for this hazard. See Chapters 13 (Clostridium botulinum toxin formation) and 16 (Pathogen bacteria survival through cooking or pasteurization), and the LACF Regulation (21 CFR 113) for further information on this control strategy. Example: A hot-smoked salmon processor should set the CCP for parasites at the hot-smoking step and would not need to identify the receiving step as a CCP for this hazard.
b. If the process does not contain a heating
step, you should identify a freezing step as the CCP, and would not need to identify receiving as a CCP for this hazard. Example: A salmon processor that sells the finished product for raw consumption should identify a freezing step as the CCP for parasites. The processor would not need to identify the receiving step as a CCP for this hazard. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Freezing.
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The following guidance provides an example of a control strategy for parasites. It is important to note that you may select a control strategy that is different from that which is suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following is an example of the control strategy included in this chapter:
For 7-day freezing critical limit: Starting time of freezing and ending time of the frozen storage period; OR
For 15-hour and 24-hour freezing critical limits: Time when all fish are solid frozen and ending time of the frozen storage period.

Use a continuous temperature-recording device (e.g., a recording thermometer); AND Perform a visual check of time and physical check of solid frozen condition, as appropriate.
CONTROL STRATEGY
Freezing
CONTROL STRATEGY EXAMPLE - FREEZING
Set the Critical Limits.

Freezing and storing at an ambient temperature of -4F (-20C) or below for 7 days (total time); OR Freezing at an ambient temperature of -31F (-35C) or below until solid and storing at an ambient temperature of -31F (-35C) or below for 15 hours; OR Freezing at an ambient temperature of -31F (-35C) or below until solid and storing at an ambient temperature of -4F (-20C) or below for 24 hours.
Note: These conditions may not be suitable for freezing particularly large fish (e.g., thicker than 6 inches). It may be necessary for you to conduct a study to determine effective control parameters specific to your freezing method, fish thickness, fish species, method of preparation, and target parasites.

For temperature:
Continuous monitoring, with a visual check of the recorded data at least once during each freezing or storage period, but no less than once per day;
AND For time:
Each batch, at the beginning and end of the freezing or storage period, as appropriate.

The device itself performs the monitoring. Any person who has an understanding of the nature of the controls may perform the visual check of the data generated by this device to ensure that the critical limits have been met consistently.

Freezer temperature; AND Length of time fish is held at freezer temperature or held solid frozen, as appropriate:

Refreeze and store the product at an ambient temperature of -4F (-20C) or below for 7 days (total time), or refreeze it at an ambient temperature of -31F (-35C) or below until solid
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and store at an ambient temperature of -31F (-35C) or below for 15 hours, or refreeze it at an ambient temperature of -31F (-35C) or below until solid and store at an ambient temperature of -4F (-20C) or below for 24 hours. Note that these conditions may not be suitable for freezing particularly large fish (e.g., thicker than 6 inches); OR Destroy or divert the product to a non-raw or non-food use. AND
known accurate reference device (e.g., a thermometer traceable to the National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used; AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Make repairs or adjustments to the freezer; OR Move some or all of the product in the freezer to another freezer.

Record of continuous temperature monitoring; AND Record of visual checks of recorded data. AND Record of notation of the start time and end time of the freezing periods; AND Record of notation of the time the fish is solid frozen (if appropriate).

Before a temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a
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TABLE 5-1
CONTROL STRATEGY EXAMPLE - FREEZING
This table is an example of a portion of a Hazard Analysis Critical Control Point plan using Control Strategy Example 1 - Freezing. This example illustrates how a proces sor can control parasites in frozen salmon fillets with pin bones removed, where the finished product will be distributed to other processors for the production of refrigerated lox. It is provided for illustrative purposes only.
Parasites may be only one of several significant hazards for this product. Refer to Tables 3-2, and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, aquaculture drugs, food and color additives, and metal fragments).

(3) MONITORING CORRECTIVE ACTION(S) RECORDS VERIFICATION (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
CRITICAL CONTROL POINT WHAT HOW FREQUENCY WHO
CHAPTER 5: Parasites Blast freeze at -31F or below until solid, and hold at -4F or below for 24 hours Temperature of blast freezer and storage freezer Recorder thermometers Continuous, with visual check of recorded data at end of each freezing process Freezer operator Time when all fish are visually solid frozen and time at end of storage period Visual and physical checks Each batch, at beginning and end of storage period
Freezing
Parasites
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Adjust or repair freezer Refreeze product
Recorder chart with notations for visual temperature check, time solid frozen, and time at end of storage period
Check the recorder thermometer for accuracy and damage and to ensure that it is operational before putting into service; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to Non-FDA Web site references after March 29, 2011. Adams, A. M., K. D. Murrell, and J. H. Cross. 1997. Parasites of fish and risks to public health. Rev. Sci. Tech. Off. Int. Epiz. 16(2):652-660. Adams, A. M., M. N. Ton,M.M. Wekell, A. P. MacKenzie, and F.M. Dong. 2005. Survival of Anisakis simplex in arrowtooth flounder (Atheresthes stomia) during frozen storage.J.Food Prot.68(7):1441-1446. American Gastroenterological Association. 2000. Determination of the incidence of gastrointestinal parasitic infections from the consumption of raw seafood in the U.S. [Report under FDA Contract 223-97-2328 with Life Sciences Research Office, American Society for Nutritional Sciences]. AGA, Bethesda, MD. Berland, B. 1961. Nematodes from some Norwegian marine fishes. Sarsia 2:1-50. Bier, J. W. 1988. Anisakiasis. In A. Balows, W. J. Hausler, Jr., M. Ohashi, and A. Turano (ed.), Laboratory diagnosis of infectious diseases, vol. I. Springler-Verlag, New York, NY. Bouree, P., A. Paugam, and J. C. Petithory. 1995. Review - Anisakidosis: report of 25 cases and review of the literature. Comp. Immunol. Microbiol. Infect. Dis. 18(2):75-84. Daniel, R. J. 1950. A guide to marketable fish. Proc. Lpool. Biol. Soc. 57:App1, 68 pp. Deardorff, T. L., and M. L. Kent. 1989.
Prevalence of larval Anisakis simplex in penreared and wild-caught salmon (Salmonidae) from Puget Sound, Washington. J. Wildl. Dis. 25:416-419. Deardorff, T. L., and R. M. Overstreet. 1990. Seafood-transmitted zoonoses in the United States: the fish, the dishes and the worms, p. 211-265. In D. Ward and C. R. Hackney (ed.). Microbiology of marine food products, Van Nostrand Reinhold, New York, NY. Deardorff, T. L., and R. Throm. 1988. Commercial blast-freezing of third-stage Anisakis simplex larvae encapsulated in salmon and rockfish. J. Parasitol. 74(4):600 603. Deardorff, T. L., M. J. Klicks, M. E. Rosenfeld, R. A. Rychlinski, and R. S. Desowitz. 1982. Larval ascaroid nematodes from fishes near the Hawaiian Islands, with comments on pathogenicity experiments. Pac. Sci. 36:187 201. Deardorff, T. L., R. B. Raybourne, and R. S. Desowitz. 1984. Behavior and viability of third-stage larvae of Terranova sp. (Type HA) and Anisakis simplex (type I) under coolant conditions. J. Food Prot. 47(1):49-52. Edgerton, B. F., L. H. Evans, F. J. Stephens, and R. M. Overstreet. 2002. Synopsis of freshwater crayfish diseases and commensal organisms. Aquaculture 206:57-135. Eslami, A., and B. Mokhayer. 1997. Nematode larvae of medical importance found in market fish in Iran. Pahlavi Med. J. 8:345-348. Freeman, R. S., P. F. Stuart, S. J. Cullen, A. C. Ritchie, A. Mildon, B. J. Fernandes, and R. Bonin. 1976. Fatal human infection with mesocercariae of the trematode Alaria americana, Am. J. Trop. Med. Hyg. 25(6):803 807. Gardner, M. A. 1990. Survival of Anisakis in cold-smoked salmon. Can. Inst. Food Sci. Technol. J. 23:143-144. Hauck, A. K. 1977. Occurrence and survival of the larval nematode Anisakis sp. in the
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flesh of fresh, frozen, brined, and smoked Pacific herring, Clupea harengus pallasi, J. Parasitol. 63:515-519. Jensen, T., K. Andersen, and S. des Clers. 1994. Sealworm (Pseudoterranova decipiens) infections in demersal fish from two areas in Norway. Can. J. Zool. 72:598-608. Karl, H., and M. Leinemann. 1989. Viability of nematode larvae (Anisakis sp.) in frozen herrings. Archiv fur Lebensmittelhygiene. 40(1):14-16 (in German). Lile, N. K., O. Halvorsen, and W. Hemmingsen. 1994. Zoogeographical classification of the macroparasite faunas of four flatfish species from the northeastern Atlantic. Polar Biol. 14(2):137-141. Margolis, L., and J. R. Arthur. 1979. Synopsis of the parasites of fishes of Canada. Fish. Res. Board Can. Bull. Canadian Department of Fisheries and Oceans. 199:1-269. McClelland, G., R. K. Misra, and D. J. Martell. 1990. Larval anisakine nematodes in various fish species from Sable Island Bank and vicinity, p. 83-118. In W. D. Bowen (ed.), Population biology of sealworm (Pseudoterranova decipiens) in relation to its intermediate and seal hosts. Can. Bull. Fish. Aquat. Sci., vol. 222:83-118. Ogawa, K. 1996. Marine parasitology with special reference to Japanese fisheries and mariculture. Vet. Parasitol. 64:95-105. Polyanskii, Y. 1966. The parasitology of fish of northern waters of the U.S.S.R. Parasites of the fish of the Barents Sea, p. 158. Transactions of the Zoological Institute of the Academy of Sciences of the U.S.S.R., vol. 19 (Translated from Russian by the Israel Program for Scientific Translations, Jerusalem). Punt, A. 1941. Recherches sur quelques nematodes parasites des poissons de la Mer du Nord. Mem. Mus. Hist. Nat. Belg. 98:1-110. Sakanari, J. A., and J. H. McKerrow. 1989. Anisakiasis. Clin. Microbiol. Rev. 2:278-284.
Templeman, W., H. J. Squires, and A. M. Fleming. 1957. Nematodes in the fillets of cod and other fishes in Newfoundland and neighbouring areas. J. Fish. Res. Bd. Can. 14:831-897. Verhamme, M. A. M., and C. H. R. Ramboer. 1988. Anisakiasis caused by herring in vinegar: a little known medical problem. Gut. 29:843-847. Williamson, H. C. 1910. Nematodes in the muscle of the cod (Gadus callarias). Rep. Fish. Bd. Scot. 28:61-62. Williamson, H. C. 1919. The distribution of parasite-infected fish. Ann. App. Biol. 6:48 52. World Health Organization. 1995. Control of foodborne trematode infections: report of a WHO study group. WHO, Geneva. WHO Technical Report Series No. 849.
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CHAPTER 6: Natural Toxins

UNDERSTAND THE POTENTIAL HAZARD.

Contamination of fish with natural toxins from the harvest area can cause consumer illness. Most of these toxins are produced by species of naturally occurring marine algae (phytoplankton). They accumulate in fish when they feed on the algae or on other fish that have fed on the algae. There are also a few natural toxins that are normal constituents of certain species of fish. For fish products in the United States (U.S.) commerce there are six recognized fish poisoning syndromes that can occur from the consumption of fish or fishery products contaminated with natural toxins: Paralytic shellfish poisoning (PSP), neurotoxic shellfish poisoning (NSP), diarrhetic shellfish poisoning (DSP), amnesic shellfish poisoning (ASP), ciguatera fish poisoning (CFP) and azaspiracid shellfish poisoning (AZP). Scombrotoxin (histamine) poisoning, that can occur as a result of scombrotoxin formation in time and temperature abused fish, is not considered a natural toxin, and is covered in Chapter 7. Species and geographic areas involved This section provides information about species of fish and geographic areas that have been linked to one of the five fish poisoning syndromes by historical occurrence of the syndrome. However, it is important to note that historical occurrence may be an inadequate guide to future occurrence in the case of natural toxins, because the distribution of the source algae may vary over time. You should be alert to the potential for emerging problems.
Paralytic Shellfish Poisoning (saxitoxin) in the U.S. is generally associated with the consumption of molluscan shellfish from its northeast and northwest coastal regions. PSP in other parts of the world has been associated with molluscan shellfish from environments ranging from tropical to temperate waters. Certain gastropods (e.g., conch, snails and whelk) are also known to accumulate PSP toxins. They may accumulate toxins by feeding on molluscs that are toxic. In particular, moon snails and whelk are commonly found to contain PSP toxins off the northeast coast of the U.S. Abalone from South Africa and Spain have been reported to contain PSP toxins, although there have been no reports of PSP toxins in abalone off the coast of the U.S. Similarly, PSP toxins have been reported in sea cucumbers, octopi and a variety of echinoderms, targeted for human consumption in sub-tropical regions of Australia, but to date no reports have been shown in these species in U.S. waters. In the U.S., PSP toxin has been reported from the viscera of lobster and crabs are often eaten whole, therefore it is important to include toxin loads contained in the viscera and flesh for these animals. The levels of PSP toxins found in lobster tomalley and crab viscera may pose a health hazard if eaten from a heavily contaminated area. In 2008, FDA advised against the consumption of American lobster tomalley because unusually high levels of PSP toxins were detected in that organ in lobsters caught in the waters of New England. In 2002, PSP from the consumption of the flesh of puffer fish was first reported in the U.S. All cases to date have been due to fish harvested from central east coast Florida. PSP toxins have been
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confirmed in southern (Sphoeroides nephelus), checkered (Sphoeroides testudineus), and bandtail (Sphoeroides spengleri) puffer fish. There is currently a ban on the harvesting of all puffer fish in the Florida counties of Volusia, Brevard, Indian River, St. Lucie, and Martin. The effects of PSP are primarily neurological and can include: tingling, burning, numbness, drowsiness, incoherent speech, and respiratory paralysis. Respiratory paralysis can result in death if respiratory support is not provided in a timely manner. PSP toxin is an extremely potent toxin with a high mortality rate. The symptoms develop from to 2 hours after consumption. Neurotoxic shellfish poisoning (from brevetoxin) in the U.S. is generally associated with the consumption of molluscan shellfish from the coast of the Gulf of Mexico, and, sporadically, along the southern Atlantic coast. NSP has also been linked to gastropods (whelk) harvested off the Florida Gulf Coast. In addition, there has been a significant occurrence of toxins similar to NSP in New Zealand and some suggestions of occurrence elsewhere. NSP is characterized by gastrointestinal and neurological symptoms, including: tingling and numbness of the lips, tongue, and throat; muscular aches; dizziness; reversal of sensations of hot and cold; diarrhea; and vomiting. Symptoms develop from a few minutes to a few hours after consumption. There are few, if any, after effects and there have been no reported fatalities. Diarrhetic shellfish poisoning (from okadaic acid and dinophysistoxins) is generally associated with the consumption of molluscan shellfish. There have been no documented occurrences of illness to date in the U.S. however reports of this illness can be misidentified as a bacterial or viral source and is expected to be highly underreported. Outbreaks have been documented in Japan, Southeast Asia, Scandinavia, Western Europe, Chile, New Zealand, and eastern Canada. However, in 2008, okadaic acid levels in excess of the 0.16 ppm guidance level were recorded for
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the first time in several locations along the Texas Gulf Coast during a large marine algae bloom. DSP is characterized by gastrointestinal symptoms, including: nausea, vomiting, diarrhea, abdominal pain, headache, and fever. Symptoms develop from 30 minutes to 3 hours after consumption and last for up to 4 days. DSP is generally not considered life threatening but complications could occur as a result of severe dehydration in some patients. Amnesic shellfish poisoning (from domoic acid) is generally associated with the consumption of molluscan shellfish from the northeast and northwest coasts of North America. In these regions, domoic acid has been identified in the viscera of Dungeness (Cancer magister), tanner, and red rock crab. Domoic acid has also been identified in several fish species including anchovies (Engraulis mordax), Pacific sanddab (Citharichthys sordidus), chub mackerel (Scomber japonicas), albacore tuna (Thunnas alalunga), jack smelt (Atherinopsis californiensis), and market squid (Loligo opalescens) along the west coast of the U.S. It has not yet been a problem in the Gulf of Mexico, although the planktonic algae that produce the toxin have been reported in coastal waters, and more recently detected in menhaden (Brevoortia partonus) collected from Louisiana. Although this planktivorous species is not currently commercially harvested for human food in the Gulf of Mexico, it is used in dietary supplements, feed products, and occasionally caught recreationally and eaten by locals. ASP is characterized by gastrointestinal symptoms, including: nausea, vomiting, abdominal cramps, and diarrhea. These symptoms develop within 24 hours of consumption. In severe cases, neurological symptoms also appear, including: dizziness, headache, seizures, disorientation, short-term memory loss, respiratory difficulty, and coma. These symptoms usually develop within 48 hours of consumption. These marine toxins described above are not ordinarily a problem in scallops if only the adductor muscle is consumed.
However, products such as roe-on scallops and whole scallops do present a potential hazard for natural toxins. Ciguatera fish poisoning (from ciguatoxin (CTX)) is associated with consumption of toxincontaminated subtropical and tropical reef fish. The toxin is introduced to the marine food chain by microscopic algae and moves up the food chain as small plant-eating reef fish eat the toxic algae and are then eaten by larger reef fish. The toxin accumulates in the flesh of certain predatory reef fish species. Although ciguatera hotspots are well recognized, there is not an even distribution of toxic fish within a given reef; fish caught side by side may have widely differing contamination levels. Ciguatoxic fish may be found in tropical or subtropical areas around the world between 35 north latitude and 35 south latitude and are common in several areas in the Caribbean Sea, Pacific Ocean, Indian Ocean, and in the Flower Garden Banks area in the northern Gulf of Mexico. Reef fish associated with CFP include: barracuda (Sphyraenidae), amberjack (Seriola), grouper (Family: Serranidae), snapper (Family: Lutjanidae), poou (Chelinus spp.), jack (Family: Carangidae), travelly (Caranx spp.), wrasse (Family: Labridae), surgeon fish (Family: Acanthuridae), moray eel (Family: Muraenidae), roi (Cephalopholis spp.), and parrot fish (Family: Scaridae). CFP is characterized by numbness and tingling of the lips and tongue, which may spread to the extremities; nausea; vomiting; diarrhea; joint pain; muscle pain; headache; reversal of sensation of hot and cold; acute sensitivity to temperature extremes; vertigo; muscular weakness; irregular heartbeat, and reduced blood pressure. Gastrointestinal symptoms may develop within 2 hours following consumption of toxic fish while neurological and cardiovascular symptoms will usually emerge within 6 hours post-ingestion. Azaspiracid shellfish poisoning (AZP) is caused by the consumption of molluscan shellfish contaminated with azaspiracids (AZA). AZP was first recognized following a 1995 outbreak in the
Netherlands, linked to consumption of mussels harvested in Ireland. Since then, several outbreaks of AZP have been reported in various regions in Europe. In 2008, two cases of AZP were reported in the US, and linked to consumption of an imported mussel product from Ireland confirmed to contain AZP toxins in excess of guidance levels. To date, AZP toxins have not been confirmed in any product harvested in the US. AZP is characterized by severe gastrointestinal disorders including abdominal pain, nausea, vomiting, and diarrhea. Symptoms develop within minutes to hours after consumption of the contaminated shellfish and last for several days. There have been no reported fatalities. A number of additional toxins that have been identified in molluscan shellfish have shown toxicity in mouse studies but have not been linked to human illness. Pectenotoxins (PTX) have been detected in phytoplankton and/ or molluscan shellfish in Australia, Italy, Japan, New Zealand, Norway, Portugal, and Spain. Yessotoxins (YTX) have been detected in phytoplankton and/or molluscan shellfish in Australia, Canada, Italy, Japan, New Zealand, Norway, the United Kingdom, and the U.S. Cyclic imines have been found in phytoplankton and/ or molluscan shellfish in Canada, Denmark, New Zealand, Norway, Scotland, Tunisia, and the U.S. PTX and YTX have been found to occur in shellfish along with the DSP toxins okadaic acid and dinophysistoxins. At this time, FDA makes no recommendations in this guidance and has no specific expectations with regard to controls for PTX, YTX and cyclic imines in processors Hazard Analysis Critical Control Point (HACCP) plans. Natural toxin detection The FDA has established action levels for natural toxins as follows: PSP - 0.8 ppm (80 ug/100 g) saxitoxin equivalents; NSP - 0.8 ppm (20 mouse units/100 g) brevetoxin-2 equivalents; DSP - 0.16 ppm total okadaic acid
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equivalents (i.e., combined free okadaic acid, dinophysistoxins, acyl-esters of okadaic acid and dinophysistoxins); ASP - 20 ppm domoic acid, except in the viscera of dungeness crab, where the action level is 30 ppm; CFP - 0.01 ppb P-CTX-1 equivalents for Pacific ciguatoxin and 0.1 ppb C-CTX-1 equivalent for Caribbean ciguatoxin; AZP - 0.16 ppm azaspiracid equivalents. There are currently no NSSP-accepted rapid test methods for NSP, ASP, DSP, CFP or AZP, and only one rapid test method has been validated (for PSP). Natural toxin control Natural toxins cannot be reliably eliminated by heat. However, severe heating processes, such as retorting, may be effective at reducing the levels of some natural toxins. To minimize the risk of molluscan shellfish containing natural toxins from the harvest area, state and foreign government agencies, called shellfish control authorities, classify waters in which molluscan shellfish are found, based, in part, on the presence of natural toxins in shellfish meats. Shellfish control authorities may also use cell counts of the toxin-forming algae in the harvest waters to classify shellfish harvest areas. As a result of these classifications, molluscan shellfish harvesting is allowed from some waters, not from others, and only at certain times, or under certain conditions, from others. Shellfish control authorities then exercise control over the molluscan shellfish harvesters to ensure that harvesting takes place only when and where it has been permitted. In this context, molluscan shellfish include oysters, clams, mussels, and scallops, except where the scallop product contains the shucked adductor muscle only. Other significant elements of shellfish control authorities efforts to control the harvesting of molluscan shellfish include requirements that (1) containers of in-shell molluscan shellfish (shellstock) bear a tag that identifies the type
and quantity of shellfish, the harvester, harvest location, and the date of harvest (21 CFR 123.28(c)); (2) molluscan shellfish harvesters be licensed (note that licensing may not be required in all jurisdictions); (3) processors that ship, reship, shuck, or repack molluscan shellfish be certified; and (4) containers of shucked molluscan shellfish bear a label with the processors name, address, and certification number. An established water classification system similar to that in use for the molluscan shellfish system is not in place for controlling CFP in finfish. However, some states issue advisories regarding reefs that are known to be toxic. In areas where there is no such advisory system, fishermen and processors must depend on their own knowledge of local reporting of illnesses associated with reefs from which they obtain fish. Where PSP or ASP has become a problem in finfish or crustaceans, states generally have closed or restricted the appropriate fisheries or have issued consumption advisories. In addition, removal and destruction of the viscera will eliminate the hazard, and this is at times required by state public health authorities. In 2008, FDA advised against the consumption of American lobster tomalley, but not the lobster meat itself, because unusually high levels of PSP toxins were detected in the lobster tomalley of lobsters caught in the waters of New England. Escolar, puffer fish, and whelk There are naturally occurring toxins in some species that do not involve marine algae. Escolar or oilfish (i.e., Lepidocybium flavobrunneum or Ruvettus pretiosus) contains a strong purgative oil (wax ester), called gempylotoxin, that may cause diarrhea, abdominal cramps, nausea, headache, and vomiting when consumed. FDA advises against importation and interstate marketing of these fish. Additional deep sea fish species, such as orange roughy (Hoplostethus atlanticus), and, oreo dory (Allocyttus spp., Pseudocyttus spp., Oreosoma spp., and Neocyttus spp.) are known to contain lesser amounts of the same indigestible wax esters. Sensitive individuals may
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also experience symptoms from the consumption of these fish. Improperly handled escolar and oilfish also have been associated with scombrotoxin (histamine) poisoning (Covered in Chapter 7). Puffer fish (also known as fugu, swellfish, bok, blowfish, globefish, balloonfish, or sea squab) may contain tetrodotoxin. Poisonings from tetrodotoxin have usually been associated with the consumption of puffer fish from waters of the Indo-Pacific Ocean regions. However, several reported cases of poisonings, including fatalities, involved puffer fish from the Atlantic Ocean, Gulf of Mexico, and Gulf of California. There have been no confirmed cases of poisonings from northern puffer fish (Sphoeroides maculatus), which was once harvested and marketed as sea squab on the U.S. east coast, but there is still reason for concern. There is a restriction on importation of all species of puffer fish and fishery products containing puffer fish. See Import Alert #16-20 at the internet location http://www. accessdata.fda.gov/cms_ia/importalert_37.html. Some puffer fish are also subject to contamination with PSP toxins, covered earlier in this chapter. Tetrodotoxin has been implicated in illnesses from the consumption of additional species besides puffer fish, for example, certain species of xanthid crabs, marine gastropods, and goby fish. Reports of these illnesses have been mainly limited to Asia, and involve species unlikely to be imported into the U.S. Tetrodotoxin poisoning is characterized by slight numbness of the lips and tongue, tingling sensation in the face and extremities, headache, abdominal pain, nausea, diarrhea, vomiting, difficulty in walking, paralysis, respiratory distress, difficulty in speech, shortness of breath, blue or purplish discoloration of the lips and skin, lowering of blood pressure, convulsions, mental impairment, irregular heartbeat, and death. Symptoms usually develop between 30 minutes and 3 hours after consumption and may last for 20 minutes to 8 hours. If respiratory aid is not provided, death may occur within 4 to 6 hours.
Tetramine is a toxin that is found in the salivary glands of Neptunia spp., a type of whelk. The hazard can be controlled by removing the glands. Symptoms of tetramine poisoning include: double vision, temporary blindness, difficulty in focusing, tingling of the fingers, prostration, nausea, vomiting, diarrhea, and loss of muscle control. Symptoms usually develop within 1 hour of consumption. FDA makes no recommendations in this guidance document and has no specific expectations with regard to controls for gempylotoxin in processors HACCP plans. Additionally, FDA makes no specific recommendation in this guidance for control of tetrodotoxin and tetramine.

The following guidance will assist you in determining whether natural toxins are a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of natural toxins will be introduced at this processing step (e.g., does the toxin come in on the raw material at an unsafe level)?
Tables 3-2 and 3-3 (Chapter 3) identify the species of fish for which natural toxins are known to be a potential hazard. Under ordinary circumstances, it would be reasonably likely to expect that, without proper controls, natural toxins from the harvest area could enter the process at unsafe levels at the receiving step for those species. There may be circumstances in your geographic area that would allow you to conclude that it is not reasonably likely for a particular natural toxin to occur at unsafe levels in fish from your area. You should be guided by the information provided above and the historical occurrence of the toxin in the fish, at levels above the established guidance levels, in your geographic area. However, you should remain alert to the potential for emerging problems. Examples
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of natural toxin hazards that had not until recently been known to exist are PSP in puffer fish and domoic acid in anchovies. If you are receiving fish, other than molluscan shellfish, from another processor, you would not need to identify natural toxins as a significant hazard. This hazard should have been fully controlled by the primary (first) processor.
2. Can natural toxins that were introduced at unsafe levels at an earlier step be eliminated or reduced to an acceptable level here?
Intended use In most cases, it is unlikely that the intended use of the product would determine whether the hazard is significant. One exception is with certain products for which only the muscle tissue will be consumed. For example, where the finished product is only the shucked adductor muscle of the scallop, it is reasonable to assume that the product as consumed will not contain natural toxins. In this case, you may not need to identify natural toxins as a significant hazard.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for natural toxins. Where preventive measures, such as those described above, are available to you the hazard of natural toxins can best be controlled at the receiving step. This control approach consists of two control strategies referred to in this chapter as Control Strategy Example 1 - Source Control for Molluscan Shellfish and Control Strategy Example 2 - Source Control for Fish Other Than Molluscan Shellfish (for primary (first) processors only).
Natural toxins should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the natural toxin hazard, which had been introduced at a previous step, or is adequate to reduce the likelihood of occurrence of the hazard to an acceptable level. Preventive measures for natural toxins can include: For molluscan shellfish: Checking incoming molluscan
shellfish to ensure that they are
properly tagged or labeled;
Making sure that incoming molluscan shellfish are supplied by a licensed harvester (where licensing is required by law) or by a certified dealer. For finfish other than molluscan shellfish: Making sure that incoming fish have not been caught in an area from which harvesting is prohibited or restricted because of a natural toxin problem; Making sure that incoming finfish have not been caught in an area for which there is a CFP advisory or for which you have knowledge there is a CFP problem. These preventive measures are ordinarily employed at the receiving step.

The following guidance provides two control strategies for natural toxins. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
CONTROL STRATEGY
Source control for molluscan shellfish Source control for fish other than molluscan shellfish
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CONTROL STRATEGY EXAMPLE 1 - SOURCE

CONTROL FOR MOLLUSCAN SHELLFISH

All containers of shellstock (in-shell molluscan shellfish) received from a harvester must bear a tag that discloses the date and place they were harvested (by state and site), type and quantity of shellfish, and information on the harvester or the harvesters vessel (i.e., the identification number assigned to the harvester by the shellfish control authority, where applicable, or if such identification numbers are not assigned, the name of the harvester or the name or registration number of the harvesters vessel). For bulk shipments of shellstock where the shellstock is not containerized, the shellstock must be accompanied by a bill of lading or similar shipping document that contains the same information;
that licensing may not be required in all jurisdictions) or from a processor that is certified by a shellfish control authority.
Note: Only the primary processor, the processor that takes possession of the molluscan shellfish from the harvester, should apply controls relative to the identification of the harvester, the harvesters license, or the approval status of the harvest waters.

Information contained on tags on containers of incoming shellstock or on the bill of lading or similar shipping document accompanying bulk shipments of shellstock; AND Information on whether the harvest area is authorized for harvest by a shellfish control authority or information on whether federal harvest waters are closed by an agency of the federal government. OR Information contained on labels on containers of incoming shucked molluscan shellfish; AND The harvesters license.
OR All containers of shellstock received from a processor must bear a tag that discloses the date and place they were harvested (by state and site), type and quantity of shellfish, and the certification number of the processor; OR All containers of shucked molluscan shellfish must bear a label that identifies the name, address, and certification number of the packer or repacker of the product; AND All molluscan shellfish must have been harvested from waters authorized for harvesting by a shellfish control authority. For U.S. federal waters, no molluscan shellfish may be harvested from waters that are closed to harvesting by an agency of the federal government; AND All molluscan shellfish must be from a harvester that is licensed as required (note

Perform visual checks; AND Ask the shellfish control authorities of the state or country in which your shellstock are harvested whether the harvest area is authorized for harvest.

For checking incoming tags:
OR
Every container;
For checking the bill of lading or similar shipping document:
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Every delivery;
OR For checking incoming labels:
Number and date of expiration of the harvesters license, where applicable; AND Certification number of the shipper, where applicable.
At least three containers randomly selected from every lot;
AND
For checking licenses:
Every delivery.

Date of receipt; AND

AND Name and certification number of the packer or repacker.

Reject the lot. AND

Take the following corrective action to regain control of the operation after a critical limit deviation:

Discontinue use of the supplier until evidence is obtained that harvesting and/or tagging practices have changed.

For shellstock:

AND
AND Name of the harvester, name or registration number of the harvesters vessel, or an identification number issued to the harvester by the shellfish control authority (for shellstock received directly from the harvester only); AND
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TABLE 6-1
CONTROL STRATEGY EXAMPLE 1 - SOURCE CONTROL FOR MOLLUSCAN SHELLFISH
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Source Control for Molluscan Shellfish. This example illustrates how a primary processor (processor that takes possession of the oysters from the harvester) of shellstock oysters, that is, the shellstock shipper, can control natural toxins from the harvest area in shellstock oysters received directly from a harvester. It is provided for illustrative purposes only.
Natural toxins may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., natural toxins, environmental chemical contaminants and pesticides, and pathogens during processing). Example Only
See Text for Full Recommendations
(1) MONITORING CORRECTIVE ACTION(S)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
RECORDS
VERIFICATION
Natural toxins
All incoming shellstock must be tagged with the date and place of harvest, type and quantity of shellfish, and name or registration number of the harvesters vessel All shellstock must be from waters approved by the state shellfish control authority Ask the shellfish control authority of the state in which the shellstock are harvested whether the area is authorized for harvest Harvesters license Visual checks Every delivery Receiving employee All shellstock must be from a licensed harvester Harvest site on tags Visual checks Every lot Receiving employee
Visual checks
Every sack
Receiving employee
Reject untagged sacks
Receiving record
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Discontinue use of the supplier until evidence is obtained that tagging practices have changed
Reject lots from unapproved waters Discontinue use of the supplier until evidence is obtained that harvesting practices have changed Reject lots from unlicensed harvesters Discontinue use of the supplier until evidence is obtained that the harvester has secured a license

CONTROL FOR FISH OTHER THAN MOLLUSCAN SHELLFISH

This guidance applies to primary (first) processors only.
Reject the lot. AND


No fish may be received that has been harvested from:
An area that is closed to fishing by foreign, federal, state, tribal, territorial or local authorities (e.g., certain counties in Florida for puffer fish); OR An area that is the subject of a CFP or ASP consumption advisory; OR An area for which you have knowledge that there is a CFP problem.

Receiving record that documents the location and status (e.g., prohibited, restricted, or unrestricted) of the harvest area.

Review monitoring and corrective action records within 1 week of preparation to ensure they are complete and any deviations that occurred were addressed appropriately.

The location and status (e.g., prohibited, restricted, or unrestricted) of the harvest area.

Ask the harvesters for the harvest site at the time of receipt, or obtain the information from the harvesters catch record, where applicable.

Every lot.

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TABLE 6-2
CONTROL STRATEGY EXAMPLE 2 - SOURCE CONTROL FOR FISH OTHER THAN MOLLUSCAN SHELLFISH
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Source Control for Fish Other Than Molluscan Shellfish. This example illustrates how a fish processor in Hawaii that receives locally harvested barracuda can control natural toxins. It is provided for illustrative purposes only.
Natural toxins may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides).

(1)
(2)
CHAPTER 6: Natural Toxins No fish may be harvested from an area that is covered by a state CFP advisory or for which there is information from a valid scientific source that there is a current CFP problem Location and status of the harvest area Every lot Ask the fisherman for the harvest location Receiving employee
Receiving fresh fish
Natural toxins - CFP
Reject lot Discontinue use of the supplier until evidence is obtained that harvesting practices have changed
Receiving record
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Dickey, R.W and S.M. Plakas. 2009. Ciguatera: A public health perspective. Toxicon In Press xxx:1-14. European Communities. 2002. Commission Decision of 15 March 2002. Laying down rules for the implementation of Council Directive 91/492/EEC as regards the maximum levels and the methods of analysis of certain marine biotoxins in bivalve molluscs, echinoderms, tunicates and marine gastropods. Off. J. Eur. Communities. (2002./225/EC) L 75:62-63. Food and Agriculture Organization. 2004. In, FAO (ed), FAO Food and Nutrition Paper 80. Risk Assessment of Toxins Associated with PSP, DSP, and ASP in Seafood, pp 56-95. 3. Diarrhoeic Shellfish Poisoning (DSP). Food and Agriculture Organization of the United Nations, Rome. Food and Agriculture Organization. 2004. Marine biotoxins FAO food and nutrition paper 80. Food and Agriculture Organization of the United Nations, Rome, Italy. Food Safety Authority of Ireland. August 2006. Risk assessment of azaspiracids (AZAs) in shellfish. Food Safety Authority of Ireland, Dublin, Ireland. Friedman, M. A., L. E. Fleming, M. Fernandez, P. Bienfang, K. Schrank, R. Dickey, M. Y. Bottein, L. Backer, R. Ayyar, R. Weisman, S. Watkins, R. Granade, and A. Reich. 2008. Ciguatera fish poisoning: treatment, prevention and management. Mar. Drugs 6:456-479. Hall, S., and G. Strichartz (ed.). 1990. Marine toxins: origin structure, and molecular pharmacology. ACS Symposium Series 418. American Chemical Society, Washington, DC. Halstead, B. W. 1967. Poisonous and venomous marine animals of the world, vol. 2 - invertebrates. U.S. Government Printing Office, Washington, DC. Halstead, B. W. 1988. Poisonous and venomous marine animals of the world, 2nd rev. ed. The Darwin Press, Inc., Princeton, NJ.
Hess, P., L. Nguyen, J. Aasen, M. Keogh, N. Keogh, J. Kilcoyne, P. McCarron, and T. Aune. 2005. Tissue distribution, effects on cooking and parameters affecting the extraction of azaspiracids from mussels, Mytilus edulis, prior to analysis by liquid chromatography coupled to mass spectrometry. Toxicon. 46:62-71. Hwang, D-F., and Y-H. Tsai. 1999. Toxins in toxic Taiwanese crabs. Food. Rev. 15(2):145-162. Hwang, D-F., Y-H. Tsai, T-J. Chai, and S-S Jeng. 1996. Occurrence of tetrodotoxin and paralytic shellfish poison in Taiwan crab Zosimus aeneus. Fish. Sci. 62(3):500-501. James, K. A. C., and B. P. Treloar. 1984. Comparative effects of orange roughy (Hoplostethus atlanticus) and snapper (Chrysophrys auratus) in the diets of growing rats. New Zealand J. Sci. 27:295-305. James, K. A. C., D. R. Body, and W. C. Smith. 1986. A nutritional evaluation of orange roughy (Hoplostethus atlanticus) using growing pigs. New Zealand J. Tech. 2:219-223. James, K. J., A. Furey, M. Lehane, H. Ramstad, T. Aune, P. Hovgaard, S. Morris, W. Higman, M. Satake, and T. Yasumoto. 2002. First evidence of an extensive northern European distribution of azaspiracid poisoning (AZP) toxins in shellfish. Toxicon. 40:909-915. Kawai, N., Y. Nakayama, S. Matsuoka, and T. Mori. 1985. Lipid composition of various tissues of Lepidocybium flavobrunneum. Yukagaku 34:25-31. Lawrence, J. F., M. Maher, and W. WatsonWright. 1994. Effect of cooking on the concentration of toxins associated with paralytic shellfish poison in lobster hepatopancreas. Toxicon. 33(12):1669-1673. Lehane, L. 2000. Paralytic shellfish poisoning: a review. National Office of Animal and Plant Health Agriculture, Fisheries and Forestry, Canberra, Australia.
Lehane, L., R. J. Lewis. 2000. Ciguatera: recent advances but the risk remains. Int. J. Food Microbiol. 61:91125. Ling, K. H., C. W. Cheung, S. W. Cheng, L. Cheng, S-L. Li, P. D. Nichols, R. D. Ward, A. Graham, and P. P-H. But. 2008. Rapid detection of oilfish and escolar in fish steaks: a tool to prevent keriorrhea episodes. Food Chem. 110:538-546. Martinez, A., J. M. Franco, I. Bravo, M. Mazoy, and E. Cacho. 1993. PSP toxicity in Haliotis tuberculata from NW Spain, p. 419 423. In T. J. Smayda and Y. Shimizu (ed.), Toxic phytoplankton blooms in the sea. Elsevier, Amsterdam, Netherlands. Nichols, P. D., B. D. Mooney, and N. G. Elliott. 2001. Unusually high levels of non-saponifiable lipids in the fishes escolar and rudderfish. Identification by gas chromatography and thin-layer chromatography. J. Chromatogr A 936:183-191. Noguchi, T., and Y. Hashimoto. 1973. Isolation of tetrodotoxin from a goby Gobius criniger. Toxicon. 11:305-307. Ochiai, Y., S. Watabe, K. Hashimoto, H. Narita, Y. Ukishima, and M. Nara. 1984. Biochemical identification of two gempylid fish causative of a food poisoning. Bull. Japan. Soc. Sci. Fish. 50:721-725. Perez-Zarza, M. C., V. Ruiz-Gutierrez, and L. Bravo. 1993. Lipid composition of two purgative fish: Ruvettus pretiosus and Lepidocybium flavobrunneum. Grasas y Aceites 44:47-52. Pitcher, G. C., M. Franco, G. J. Doucette, C. L. Powell, and A. Mouton. 2001. Paralytic shellfish poisoning in abalone Haliotis midae on the west coast of South Africa. J. Shellfish Res. 20(2):895-904. Poli, M., S. Musser, R. Dickey, P. Ellers, and S. Hall. 2000. Neurotoxic shellfish poisoning and brevitoxin metabolites: a case study from Florida. Toxicon. 38:981-993.
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Saito, T., T. Kohama, K. Ui, and S. Watabe. 2006. Distribution of tetrodotoxin in the xanthid crab (Atergatis floridus) collected in the coastal waters of Kanagawa and Wakayama prefectures. Comp. Biochem. Physiol. D: Genomics and Proteomics 1(1):158-162. Satake, M., K. Ofuji, H. Naoki, K. James, A. Furey, T. McMahon, J. Silke, and T. Yasumoto.1998.Azaspiracid, a new toxin having unique spiro ring assemblies, isolated from Irish mussels, Mytilus edulis. J. Am. Chem. Soc. 120: 9967-9968. Shui, L. M., K. Chen, K., J. Y. Wang, H. Z. Mei, A. Z. Wang, Y.-H. Lu, and D.-F. Hwang. 2003. Tetrodotoxin-associated snail poisoning in Zhoushan: a 25-year retrospective analysis. J. of Food Prot. 66(1):110-114. Sobel, J., and J. Painter. November 1, 2005. Illnesses caused by marine toxins. Food Safety Invited Article. Clin. Infect. Dis. 41:1290-1296. Spark, A. A., and A. A. deWit. 1980. Wax esters in edible fish. Identification of wax esters, p. 45-47. In Annual Report of the Fishing Industry Research Institute of South Africa, no. 34. Toyofuku, H. 2006. FAO/WHO/IOC activities to provide scientific advice on marine biotoxins (research report). Mar. Pollut. Bull. 52:1735-1745. Tsai, Y-H., D-F. Hwang, T-J. Chai, and S. S. Jeng. 1995. Occurrence of tetrodotoxin and paralytic shellfish poison in the Taiwanese crab Lophozozymus pictor. Toxicon. 33(12):1669-1673. Tsai, Y-H., D-F. Hwang, T-J. Chai, and S. S. Jeng. 1996. Occurrence of paralytic shellfish toxin in Taiwanese crab Atergatopsis germaini. Toxicon. 34(4):467-474. Twiner, M. J., N. Rehmann, P. Hess, G. J. Doucette. 2008. Azaspiracid shellfish poisoning: a review on the chemistry, ecology, and toxicology with an emphasis on human health impacts. 6:39-72.
Van Egmond, H. P., T. Aune, P. Lassus, G. Speijers, and M. Waldock. 1993. Paralytic and diarrhoeic shellfish poisons: occurrence in Europe, toxicity, analysis and regulation. J. Nat. Toxins 2:41-83. Withers, N. 1988. Marine toxins and venoms. In A. T. Tu (ed.), Handbook of natural toxins, vol. 3. Marcel Dekker, New York, NY. Yasumoto, T., and M. Murata. 1993. Marine toxins. Chem. Rev. 93:1897-1909.
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CHAPTER 7: Scombrotoxin (Histamine) Formation


Scombrotoxin (histamine) formation as a result of time and temperature abuse of certain species of fish can cause consumer illness. The illness is closely linked to the development of histamine in these fish. In most cases, histamine levels in illness-causing fish have been above 200 ppm, often above 500 ppm. However, there is some evidence that other chemicals (e.g., biogenic amines such as putrescine and cadaverine) may also play a role in the illness. The possible role of these chemicals in consumer illness is the subject of Chapter 8. Seafood-related scombrotoxin poisoning is primarily associated with the consumption of tuna, mahi-mahi, marlin, and bluefish. Table 3-2 (Chapter 3) identifies other species that are also capable of developing elevated levels of histamine when temperature abuse occurs. The illness caused by the consumption of fish in which scombrotoxin has formed is most appropriately referred to as scombrotoxin poisoning. The illness has historically been known by other names. Originally, the illness was termed scombroid poisoning because of its association with fish in the families Scombridae and Scomberesocidae. However, other species of fish are now known to cause the illness. The terms histamine poisoning and histamine fish poisoning have also been applied to the illness. However, because biogenic amines other than histamine have been associated with the illness, these terms also present difficulties. Nonetheless, this chapter refers to control measures to prevent the formation of histamine. It is expected
that the methods of control used to inhibit the bacteria that result in histamine formation will also inhibit the bacteria that produce other biogenic amines. Symptoms of scombrotoxin poisoning include tingling or burning in or around the mouth or throat; rash or hives on the upper body; drop in blood pressure; headache; dizziness; itching of the skin; nausea; vomiting; diarrhea; asthmatic-like constriction of the air passage; heart palpitation; and respiratory distress. Symptoms usually occur within a few minutes to a few hours of consumption and last from 12 hours to a few days. Scombrotoxin (histamine) formation Certain bacteria produce the enzyme histidine decarboxylase during growth. This enzyme reacts with histidine, a naturally occurring amino acid that is present in larger quantities in some fish than in others. The result is the formation of scombrotoxin (histamine). Histamine-forming bacteria are capable of growing and producing histamine over a wide temperature range. Growth of histamine is more rapid, however, at high-abuse temperatures (e.g., 70F (21.1C) or higher) than at moderate-abuse temperatures (e.g., 45F (7.2C)). Growth is particularly rapid at temperatures near 90F (32.2C). Histamine is more commonly the result of high temperature spoilage than of long-term, relatively lowtemperature spoilage, which is commonly associated with organoleptically detectable decomposition. Nonetheless, there are a number of opportunities for histamine to form under more moderate-abuse temperature conditions.
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Once the enzyme histidine decarboxylase is present in the fish, it can continue to produce histamine in the fish even if the bacteria are not active. The enzyme can be active at or near refrigeration temperatures. The enzyme remains stable while in the frozen state and may be reactivated very rapidly after thawing. Freezing may inactivate some of the enzymeforming bacteria. Both the enzyme and the bacteria can be inactivated by cooking. However, once histamine is produced, it cannot be eliminated by heat (including retorting) or freezing. After cooking, recontamination of the fish with the enzyme-producing bacteria is necessary for additional histamine to form. For these reasons, histamine development is more likely in raw, unfrozen fish but should not be discounted in other product forms of scombrotoxin-forming fish species. The kinds of bacteria that are associated with histamine development are commonly present in the saltwater environment. They naturally exist on the gills, on external surfaces, and in the gut of live, saltwater fish, with no harm to the fish. Upon death, the defense mechanisms of the fish no longer inhibit bacterial growth in the muscle tissue, and histamine-forming bacteria may start to grow, resulting in the production of histamine. Evisceration and removal of the gills may reduce, but not eliminate, the number of histamineforming bacteria. Packing of the visceral cavity with ice may aid in chilling large fish in which internal muscle temperatures are not easily reduced. However, when done improperly, these steps may accelerate the process of histamine development in the edible portions of the fish by spreading the bacteria from the visceral cavity to the flesh of the fish. With some harvesting practices, such as longlining and gillnetting, death may occur many hours before the fish is removed from the water. Under the worst conditions, histamine formation can already be underway before the fish is brought onboard the vessel. This condition can be further aggravated with certain tuna
species that generate heat, resulting in internal temperatures that may exceed environmental temperatures and increasing the likelihood of conditions favorable to growth of enzymeforming bacteria. The potential for histamine formation is increased when the scombrotoxin-forming fish muscle is in direct contact with the enzyme-forming bacteria. This direct contact occurs when the fish are processed (e.g., butchering or filleting) and can be particularly problematic when the surface-to volume ratio of the exposed fish muscle is large, such as minced tuna for salads. Even when such products are prepared from canned or pouch retorted fish, recontamination can occur during salad preparation, especially with the addition of raw ingredients. The mixing in of the bacteria throughout the product and the high surface-to volume ratio can result in substantial histamine formation if time and temperature abuse occurs. At least some of the histamine-forming bacteria are halotolerant (salt tolerant) or halophilic (salt loving). Some are more capable of producing histamine at elevated acidity (low pH). As a result, histamine formation is possible during processes such as brining, salting, smoking, drying, fermenting, and pickling until the product is fully shelf-stable. Refrigeration can be used to inhibit histamine formation during these processes. A number of the histamine-forming bacteria are facultative anaerobes that can grow in reduced oxygen environments. As a result, reduced oxygen packaging (e.g., vacuum packaging, modified atmosphere packaging, and controlled atmosphere packaging) should not be viewed as inhibitory to histamine formation. Histamine is water soluble (dissolves in water) and would not be expected in significant quantity in products such as fish oil that do not have a water component. However, histamine could be present in products such as fish protein concentrate that are prepared from the muscle or aqueous (water-based) components of fish tissue.
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Controlling scombrotoxin (histamine)

formation
Rapid chilling of scombrotoxin-forming fish immediately after death is the most important element in any strategy for preventing the formation of scombrotoxin (histamine), especially for fish that are exposed to warm waters or air, and for tunas which generate heat in their tissues. Some recommendations follow: Fish exposed to air or water temperatures above 83F (28.3C) should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than 6 hours from the time of death; or Fish exposed to air and water temperatures of 83F (28.3C) or less should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than 9 hours from the time of death; or Fish that are gilled and gutted before chilling should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than 12 hours from the time of death; or Fish that are harvested under conditions that expose dead fish to harvest waters of 65F (18.3C) or less for 24 hours or less should be placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than the time limits listed above, with the time period starting when the fish leave the 65F (18.3C) or less environment.
Note: If the actual time of death is not known, an estimated time of the first fish death in the set may be used (e.g., the time the deployment of a longline begins).
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TABLE 7-1
RECOMMENDED MAXIMUM TIME TO GET SCOMBROTOXIN-FORMING FISH INTO CHILLING MEDIUM ONBOARD HARVEST VESSELS TO PREVENT SCOMBROTOXIN FORMATION1
WHEN AND THE AIR TEMPERATURE (F) IS DEATH OF THE FISH OR EARLIEST ESTIMATED TIME OF DEATH IS
THEN, THE MAXIMUM TIME IN HOURS TO GET THE FISH INTO CHILLING MEDIUM ( 40F) FROM THE TIME OF ONBOARD LANDING IS
THE WATER TEMPERATURE (F) IS FOR UNEVISCERATED FISH:
> 65 Any 83 > 83 83

FOR FISH EVISCERATED ONBOARD BEFORE CHILLING:
> 83 6 9 - -
- - - 6 9
> 83
> 65, but 83
65
652
> 65 Any -
Any
12
- 12
116
652
1. This table is a summary of the preceding recommendations. For complete understanding of the recommendations, refer to the text above. 2. Provided exposure of the fish in the water at 65F or less is 24 hours.
The controls listed above for onboard chilling will prevent the rapid formation of the enzyme histidine decarboxylase. Once this enzyme is formed, control of the hazard is unlikely. It is important to recognize that the parameters listed above are intended to control scombrotoxin formation; these criteria may not effectively control the activity of other spoilage organisms, raising the possibility that fish may become adulterated because of decomposition (not a food safety hazard covered by the Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products regulation, 21 CFR 123, called the Seafood Hazard Analysis Critical Control Point (HACCP) Regulation in this guidance document) before scombrotoxin (histamine) is formed. Further chilling toward the freezing point is also desirable to safeguard against the less common, longer term, lower temperature development of histamine. Additionally, the shelf life and quality of the fish are significantly compromised when product temperature is not rapidly dropped to near freezing. Although it may be possible for a harvest vessel to completely avoid onboard chilling and still deliver fish to the processor within the time and temperature limitations recommended above for chilling the fish, this practice is discouraged. Failure to chill onboard may permit bacteria and enzymes, including those that form scombrotoxin (histamine), to increase unnecessarily. The time required to lower the internal temperature of fish after capture will be dependent upon a number of factors, including: The harvest method:
The size of the fish; The chilling method:
Ice alone takes longer to chill fish than does an ice slurry or recirculated refrigerated seawater or brine, a consequence of reduced contact area and heat transfer; The quantity of ice or ice slurry and the capacity of refrigerated seawater or brine systems, as well as the physical arrangement of the fish in the chilling media, should be suitable for the quantity of catch.
Once chilled, the scombrotoxin-forming fish should be maintained as close as possible to the freezing point (or held frozen) until it is consumed. Exposure to temperatures above 40F (4.4C) should be minimized. The amount of post-harvest time at elevated temperatures (after proper chilling onboard the harvest vessel) to which a fish can be exposed (e.g., during processing, storage, and distribution) without adverse effects is dependent primarily upon whether the fish was previously frozen (e.g., onboard the harvest vessel) or heat processed sufficiently to destroy scombrotoxin forming bacteria. Extended frozen storage (e.g., 24 weeks) or cooking minimizes the risk of additional histamine development by inactivating the enzyme-forming bacteria and, in the case of cooking, the enzyme itself. As previously mentioned, recontamination with enzymeforming bacteria and significant temperature abuse is necessary for histamine formation following cooking. Such recontamination may not be likely if the fish is processed under a conscientious sanitation program. However, addition of raw ingredients, employee contact, or poor sanitary conditions could reintroduce contamination. Further guidance is provided below: Scombrotoxin-forming fish that have not been previously frozen or heat processed sufficiently to destroy scombrotoxin forming bacteria should not be exposed to
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Delays in removing fish from the water after capture, such as those captured by a longline, may significantly limit the amount of time left for chilling and may allow some fish to heat up; Large quantities of fish captured in a single fishing set, such as those captured on a purse seiner, may exceed a vessels ability to rapidly chill the product;
temperatures above 40F (4.4C) for:
More than 4 hours, cumulatively, if any portion of that time is at temperatures above 70F (21.1C); or More than 8 hours, cumulatively, as long as no portion of that time is at temperatures above 70F (21.1C).
Scombrotoxin-forming fish that have been previously frozen, or heat processed sufficiently to destroy scombrotoxin-forming bacteria and are subsequently handled in a manner in which there is an opportunity for recontamination with scombrotoxin forming bacteria (e.g., contact with fresh fish, employees, or introduction of raw ingredients), should not be exposed to temperatures above 40F (4.4C) for:
More than 12 hours, cumulatively, if any portion of that time is at temperatures above 70F (21.1C); or More than 24 hours, cumulatively, as long as no portion of that time is at temperatures above 70F (21.1C);
Scombrotoxin-forming fish that have been heat processed sufficiently to destroy scombrotoxin-forming bacteria and enzymes and are not subsequently handled in a manner in which there is an opportunity for recontamination with scombrotoxin-forming bacteria (e.g., no contact with fresh fish, employees, or raw ingredients) are at low risk for further scombrotoxin (histamine) development.
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TABLE 7-2
RECOMMENDED MAXIMUM HOURS OF EXPOSURE OF SCOMBROTOXIN-FORMING FISH TO AMBIENT TEMPERATURES GREATER THAN 40F TO PREVENT SCOMBROTOXIN FORMATION AFTER PROPER ONBOARD HARVEST VESSEL CHILLING, FOR DIFFERING TEMPERATURE EXPOSURE AND PREVIOUS PROCESSING CONDITIONS1
THEN, THE MAXIMUM HOURS OF EXPOSURE TIME FOR
WHEN THE AMBIENT TEMPERATURE (F) OF EXPOSURE IS
Fresh fish (not heat processed or previously frozen) is 4 8 12 24
Previously frozen fish, or heat processed fish (that has been exposed to possible recontamination), is
> 70 AT ANY TIME
70 DURING ENTIRE EXPOSURE
1. This table is a summary of the preceding recommendations. For complete understanding of the recommendations, refer to the text above.
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Detection
Sensory evaluation
Sensory evaluation is generally used to screen fish for indicators of spoilage that develop when the fish is exposed to time and temperature abuse. Odor in particular is an effective means of detecting fish that have been subjected to a variety of abusive conditions. However, odors of decomposition that are typical of relatively low temperature spoilage may not be present if the fish has undergone high temperature spoilage. This condition makes sensory examination alone an ineffective control for preventing scombrotoxin (histamine) formation. It is important to recognize that the Federal Food, Drug, and Cosmetic Act (the FFD&C Act) prohibits interstate commerce of adulterated foods (21 U.S.C. 331). Under the FFD&C Act, a food that is decomposed is considered adulterated (21 U.S.C 342). Accordingly, a fish or fishery product that is decomposed in whole or in part is prohibited from entering interstate commerce even if the type of decomposition may not lead to scombrotoxin (histamine) formation. You should distinguish between recommendations in this chapter for sensory screening, as a component of a HACCP control strategy for scombrotoxin formation, and your obligation to avoid otherwise violating the FFD&C Act with regard to the distribution of decomposed food.
Chemical testing
histamine testing is dependent upon the design of the sampling plan. The amount of sampling required to accommodate such variability of distribution is necessarily quite large. The method of collection of the fish sample is also critical. In large scombrotoxin-forming fish, the lower, anterior (forward) portion of the fish loin (not the belly flap) is likely to provide the best information about the histamine content of the fish. The number of samples (i.e., scombrotoxin forming fish) necessary to make a judgment about a lot depends on the anticipated variability, but should not be fewer than 18 samples per lot, unless the lot contains less than 18 fish, in which case a sample should be collected from each fish. Where samples are composited to reduce the number of analyses needed on a lot, it should be done in a manner that ensures meaningful results. No more than three samples should be composited, in order to minimize masking of problematic fish. Furthermore, the analytical method and instrument used should be capable of reliably detecting histamine at the lower levels that are necessary for composited samples (e.g., 17 ppm histamine in a three-sample composite, rather than 50 ppm in an uncomposited sample ). Combining additional indicators of conditions that can lead to histamine formation, such as sensory examination and internal temperature measurement, with histamine testing can provide better assurance of product safety. Observation for the presence of honeycombing (voids in the fish flesh) in cooked tuna loins intended for canning is a valuable means of screening for fish that have been exposed to the kinds of temperature abuse that can lead to histamine development. Any scombrotoxin-forming fish that demonstrate the trait should be destroyed or diverted to a non-food use.
Chemical testing is an effective means of detecting the presence of histamine in fish flesh. However, the variability in histamine levels between fish and within an individual fish can be large, even in fish from the same harvest vessel. For this reason, a guidance level has been set of 50 ppm histamine in the edible portion of fish. If 50 ppm is found in one section of a fish or lot, there is the possibility that other sections may exceed 500 ppm. Because histamine is generally not uniformly distributed in a fish or a lot, the validity of
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The following guidance will assist you in determining whether scombrotoxin (histamine) formation is a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of histamine will be introduced at this processing step (do unsafe levels come in with the raw material)?
a refrigerated (not frozen) raw or cooked product from another processor (see Chapter 12). The in-transit controls for secondary processors recommended in Chapter 12 are similar to those recommended in this chapter.
2. Is it reasonably likely that unsafe levels of histamine will form at this processing step?
Table 3-2 (Chapter 3) lists those species of fish that are generally known to be capable of producing elevated levels of histamine if temperature abused. Such species of fish have this capability because they contain naturally high levels of histidine. They also have this capability because they are marine fish that are likely to harbor the kinds of bacteria that produce histidine decarboxylase. It is, therefore, reasonable to assume that without proper onboard vessel controls, these species of fish will contain unsafe levels of histamine upon receipt by the primary (first) processor. However, if the worst case environmental conditions (i.e., air and water temperatures) during the harvest season in a particular region would not permit the formation of histamine during the time necessary to harvest and transport the fish to the primary processor, onboard controls may not be necessary. For example, such conditions might exist if the fish are harvested when air and water temperatures do not exceed 40F (4.4C), as evidenced by supporting data. It is also reasonable to assume that without proper controls during refrigerated (not frozen) transportation between processors, scombrotoxin-forming species of fish will contain unsafe levels of histamine upon receipt by the secondary processor (including warehouses). In addition, you may need to exercise control to prevent pathogen growth or toxin formation when receiving
To answer this question, you should consider the potential for time and temperature abuse in the absence of controls. You may already have controls in your process that minimize the potential for time and temperature abuse that could result in unsafe levels of histamine. This guidance will help you determine whether those or other controls should be included in your HACCP plan. Time and temperature abuse that occurs at successive processing and storage steps may be sufficient to result in unsafe levels of histamine, even when abuse at one step alone would not result in such levels. For this reason, you should consider the cumulative effect of time and temperature abuse during the entire process. Information is provided above to help you assess the significance of time and temperature abuse that may occur in your process.
3. Can unsafe levels of histamine formation that are reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
Scombrotoxin (histamine) formation should also be considered a significant hazard at any processing or storage step where a preventive measure is or can be used to eliminate the hazard if it is reasonably likely to occur. Preventive measures for scombrotoxin (histamine) formation can include: Examining harvest vessel records
to ensure that incoming fish were
properly handled onboard the
harvest vessel, including:
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Rapidly chilling the fish immediately after death;
Controlling onboard refrigeration (other than frozen storage)

temperatures;
Performing proper onboard icing;

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for scombrotoxin (histamine) formation:
1. If scombrotoxin (histamine) formation is a significant hazard at the receiving step, you should identify receiving as a CCP for this hazard. a. If you are the primary processor of the
Testing incoming fish for

histamine levels;
Ensuring that incoming fish were handled properly during refrigerated transportation from the previous processor, including:
Controlling refrigeration temperatures during transit;

Performing proper icing during
transit;
Checking incoming fish to ensure

that they are not at an elevated
temperature at time of receipt;
Checking incoming fish to ensure
that they are properly iced or
refrigerated at time of receipt;
Performing sensory examination on incoming fish to ensure that they do not show signs of decomposition; Controlling refrigeration
temperatures in your plant;
Performing proper icing in your plant; Controlling the amount of time that the product is exposed to temperatures that would permit histamine formation during processing. These preventive measures are ordinarily employed at receiving, processing, and storage steps. Intended use Because of the heat stable nature of histamine, the intended use of the product is not likely to affect the significance of this hazard.
scombrotoxin-forming fish (i.e., if you receive the fish directly from the harvest vessel) and have a relationship with the operator of the harvest vessel(s) from which you purchase fish that enables you to obtain documentation of onboard practices, you should identify the following preventive measures for control of this hazard: Examining harvest vessel records to ensure that incoming fish were properly handled onboard the harvest vessel, including:
Rapidly chilling the fish immediately after death; Controlling onboard refrigeration (other than frozen storage)
temperatures;
Performing proper onboard icing;
Checking incoming fish to ensure that they are not at an elevated temperature at time of receipt; and, Performing sensory examination of incoming fish to ensure that they do not show signs of decomposition. Example: A mahi-mahi processor that regularly purchases from the same harvest vessels should require harvest vessel records as a condition of purchase.
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The processor should also check the internal temperatures of incoming fish and perform sensory examination of these fish. The processor should then set a CCP for histamine formation at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Harvest Vessel Control.
b. If you are the primary processor of the
you should identify the following preventive measures for control of this hazard: Ensuring that incoming fish were properly refrigerated during transportation from the previous processor, by controlling refrigeration temperatures during transit or, Checking incoming fish to ensure that they are properly iced at time of receipt. Example: A tuna processor that receives fish from another processor should require evidence of temperature control throughout transit as a condition of receipt. The processor should then set a CCP for histamine formation at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 3 - Transit Control. This control strategy, in addition to Control Strategy Example 1 - Harvest Vessel Control or Control Strategy Example 2 - Histamine Testing, may also be applicable if you are a primary processor and transport the fish by truck from your harvest vessel unloading site to your processing facility.
2. If scombrotoxin (histamine) formation is a significant hazard at one or more processing steps, you should identify the processing step(s) as a CCP for this hazard. a. The preventive measure for this type of
scombrotoxin-forming fish (i.e., if you receive the fish directly from the harvest vessel) and do not have a relationship with the operator of the harvest vessel(s) that enables you to obtain documentation of onboard practices, you should identify the following preventive measures for control of this hazard: Testing incoming fish for
histamine levels;
Checking incoming fish to ensure that they are not at an elevated temperature at time of receipt and, Performing sensory examination of incoming fish to ensure that they do not show signs of decomposition. Example: A canned tuna processor that purchases from a variety of harvest vessels should subject incoming fish from each harvest vessel to histamine testing, internal temperature checks, and sensory examination. The processor should then set a CCP for histamine formation at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 - Histamine Testing.
c. If you are a secondary processor of the
control is: Controlling the amount of time that the scombrotoxin-forming product is exposed to temperatures that would permit histamine formation during processing.
scombrotoxin-forming fish (i.e., if you receive the fish from another processor),
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Example: A mahi-mahi processor should control histamine formation by limiting exposure time and temperature of the product during processing. The processor should then set CCPs for histamine formation at the processing steps. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 - Processing Control. This control strategy is intended for processing at ambient and air-conditioned temperatures. Control Strategy Example 5 - Storage Control may be more appropriate for processing under refrigerated conditions.
3. If scombrotoxin (histamine) formation is a significant hazard at a storage step for raw material, in-process product, or finished product, you should identify the storage step(s) as a CCP for this hazard. a. The preventive measures for this type of
Receiving; Processing, such as:
Thawing; Brining and salting; Smoking; Heading and gutting; Manual filleting and steaking; Fermenting; Pickling; Drying; Stuffing; Mixing (e.g., salad preparation); Portioning;
Packaging; Final chilling after processing

and packaging;
Storing raw material, in-process product, and finished product under refrigeration.
Note: Rather than identify each processing step as an individual CCP when the controls are the same at those steps, it may be more convenient to combine into one CCP those processing steps that together contribute to a cumulative time and temperature exposure.
control are: Controlling refrigeration temperatures in your plant or, Performing proper icing in your plant. Example: A mahi-mahi processor should control histamine formation by icing the product during raw material, in-process product, and finished product storage. The processor should then set CCPs for histamine formation at the storage steps. This control approach is a control strategy referred to in this chapter as Control Strategy Example 5 - Storage Control. Likely CCPs Following is further guidance on processing steps that are likely to be identified as CCPs for this hazard:
Unlikely CCPs Time and temperature controls will usually not be needed at processing steps that meet the following conditions: Continuous, mechanical processing steps that are brief, such as:
Mechanical filleting;
Processing steps that are brief and unlikely to contribute significantly to the cumulative time and temperature exposure, such as:

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Date code stamping; Case packing;
Processing steps where the product is held in a frozen state, such as: Assembly of orders for distribution; Frozen product storage;
Retorting and post-retorting steps (if the product is covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (called the Low-Acid Canned Foods Regulation in this guidance document));
Sensory examination; Internal temperature measurements.

Harvest vessel records:
All scombrotoxin-forming fish lots received are accompanied by harvest vessel records that show:

The following guidance provides examples of five control strategies for scombrotoxin (histamine) formation. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
Fish exposed to air or water temperatures above 83F (28.3C) were placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not longer than 6 hours from the time of death; OR Fish exposed to air and water temperatures of 83F (28.3C) or less were placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not longer than 9 hours from the time of death; OR Fish that were gilled and gutted before chilling were placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not longer than 12 hours from the time of death; OR Fish that were harvested under conditions that expose dead fish to harvest waters of 65F (18.3C) or less for 24 hours or less were placed in ice, or in refrigerated seawater, ice slurry, or brine of 40F (4.4C) or less, as soon as possible after harvest, but not more than the time limits listed above, with the time period starting when the fish left the 65F (18.3) or less environment; OR Other critical limits for onboard handling (e.g., maximum refrigerated brine or seawater temperature, maximum fish size, maximum fish to brine/seawater/ ice ratio, maximum initial temperature of
CONTROL STRATEGY MAY APPLY TO PRIMARY PROCESSOR MAY APPLY TO SECONDARY PROCESSOR
Harvest vessel control Histamine testing Transit control Processing control Storage Control
CONTROL STRATEGY EXAMPLE 1 - HARVEST

VESSEL CONTROL
It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

The critical limits for this control strategy should include three components: Harvest vessel records;
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the fish) necessary to achieve a cooling rate that will prevent development of an unsafe level of histamine in the specific species, as established through a scientific study.
Note: If the actual time of death is not known, an estimated time of the first fish death in the set may be used (e.g., the time the deployment of a longline begins). Table 7-1 provides a summary of the preceding recommended critical limits.
(10C) or below;
OR
For fish held iced or refrigerated (not frozen) onboard the vessel from 12 to less than 15 hours after death:
The internal temperature should be 60F (15.6C) or below;
AND
OR
For fish held iced or refrigerated (not frozen) onboard the vessel less than 12 hours after death:
For fish held refrigerated (not frozen)

onboard the vessel: The fish were stored at or below 40F (4.4C) after cooling; OR The fish were stored completely and continuously surrounded by ice after cooling;
AND
Sensory examination:
Sensory examination of a representative sample of scombrotoxin-forming fish shows decomposition (persistent and readily perceptible) in less than 2.5% of the fish in the sample. For example, no more than 2 fish in a sample of 118 fish may show signs of decomposition. Note that the FFD&C Act prohibits interstate commerce of any decomposed fish whether or not the HACCP critical limit has been exceeded; AND
Internal temperature measurements:
The internal temperature should be sufficiently below water and air temperatures to indicate that appropriate chilling methods were implemented onboard the harvest vessel. Chilling of the fish should begin on the harvest vessel regardless of the time from death until off-loading from the vessel by the processor unless the environmental conditions (e.g., air and water temperatures) are below 40F (4.4C) from the time of death until off-loading from the vessel by the processor;
OR For fish held iced or refrigerated (not frozen) onboard the vessel:
For fish held iced or refrigerated (not frozen) onboard the vessel 24 or more hours after death:
Elapsed time from death and internal temperatures at the time of off-loading from the vessel by the processor should be consistent with cooling curves that will prevent development of an unsafe level of histamine in the specific species, as established through a scientific study.

Harvest vessel records containing the following information:
OR
Method of capture*; AND Where applicable to the critical limit, the
The internal temperature should be 50F

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date and time of landing the fish onboard the harvest vessel; AND Where applicable to the critical limit, the estimated earliest date and time of death for fish brought onboard in the fishing set (e.g., trawl, gillnet, longline, or purse seine); AND Where applicable to the critical limit, the air and water temperatures at the time of landing the fish onboard the harvest vessel*; AND Where applicable to the critical limit, the water temperature at the depth where dead fish may remain until harvest; AND Where applicable to the critical limit, the method of cooling* and temperature of the cooling medium; AND Where applicable to the critical limit, the date and time cooling began and/or the date and time when the last fish in a fishing set (e.g., trawl, gillnet, longline, or purse seine) was placed in the cooling medium; AND Where applicable to the critical limit, those factors of the cooling process that have been established through a scientific study as critical to achieving the cooling rate critical limits (e.g., refrigerated brine or seawater temperature, fish size, fish to brine/seawater/ice ratio, maximum initial temperature of the fish); AND For fish held iced or refrigerated (not frozen) onboard the vessel:
The presence of ice that completely and continuously surrounds the fish.
(*These items may be documented by the primary (first) processor, on the receiving records, rather than by the harvest vessel operator, on the harvest vessel records, provided the primary processor has direct knowledge about those aspects of the harvesting practices and has made first-hand observations for each lot received. The vessel operator should document other onboard handling information. The primary processor should maintain all relevant information.)
AND
Amount of decomposition in the lot; AND

Internal temperature measurement:
For fish held iced or refrigerated (not frozen) onboard the vessel:
The internal temperature of a

representative number of the largest
fish in the lot at the time of off-loading
from the harvest vessel, concentrating on
any fish that show signs of having been
mishandled (e.g., inadequately iced);
AND
Date and time of off-loading.
Example: A primary processor receives bluefish from several day-boats that catch the fish when the air and water temperatures are below 83F (28.3C). The day-boats take on ice at the processors facility immediately before setting out for the day and return within 9 hours to the processors facility with the iced catch. The processor monitors and records the date and time of departure of the vessels after they take on ice; the date and time of the return of the vessels; the ambient water and air temperatures of the fishing grounds; and the adequacy of icing of the catch at the time of off-loading. The processor also conducts sensory evaluations and checks the internal
The storage temperature, as evidenced by: The temperature of refrigerated seawater or brine in which the fish are stored; OR
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temperature of the catch upon arrival. The harvest vessel operators perform no monitoring or record keeping.

For harvest vessel records:
of the fish. Randomly select fish from throughout the lot. Lots that show a high level of temperature variability or lots of very small fish may require a larger sample size; AND
Review controls documented in the records;
AND
For sensory examination:
Visually determine the date and time of off-loading.

Every lot of scombrotoxin-forming fish received.
Examine at least 118 fish, collected representatively throughout each lot (or the entire lot, for lots smaller than 118 fish). Additional fish should be examined if variability in fish-to-fish histamine content is expected to be high. Lots should consist of only one species of fish; for vessels delivering multiple species, testing should generally be done separately on each species. All fish within a lot should have a similar history of harvest. If the fish are received frozen, this monitoring procedure may be performed by a sensory examination on the warmed flesh produced by drilling the frozen fish (drill method). It may also be performed after thawing, rather than at receipt;

Any person who is qualified by experience or training to perform the examination;
AND For other checks:

Take the following corrective actions to a product involved in a critical limit deviation:
AND For fish held iced or refrigerated (not frozen) onboard the vessel:
Use a temperature-indicating device (e.g., a thermometer) to measure the internal temperature of a representative number of the largest fish in each lot, concentrating on any that show signs of having been mishandled (e.g., inadequately iced). For example, when receiving 10 tons or more of fish, measure a minimum of one fish per ton, and when receiving less than 10 tons of fish, measure a minimum of one fish per 1,000 pounds. Measure a minimum of 12 fish, unless there are fewer than 12 fish in the lot, in which case measure all
In the absence of harvest vessel records or when one of the harvester-related critical limits has not been met, or when the internal temperature critical limit at receiving has not been met:
Chill and hold the affected lot (i.e., fish of common origin) until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the lot, including any fish measured to have temperatures that exceeded the critical limit (or the entire lot for lots smaller than 60 fish). Reject the lot if any fish are found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited for analysis if the action point is reduced accordingly. For
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example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit; OR

Harvest vessel records containing the information described above; AND Receiving records showing the date and time of off-loading; AND Results of sensory examination; AND For fish held iced or refrigerated (not frozen) onboard the vessel:
Reject the lot;
AND When the sensory examination critical limit has not been met:
Chill and hold the affected lot (i.e., fish of common origin) until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the lot, including all fish in the lot that show evidence of decomposition (persistent and readily perceptible odors) (or the entire lot for lots smaller than 60 fish), and reject the lot if any fish is found with histamine greater than or equal to 50 ppm; AND If any fish in the lot are to proceed into commerce for food use, perform a sensory examination of all fish in the lot to ensure that no decomposed fish proceed; AND Any individual fish found to be decomposed (persistent and readily perceptible) should be destroyed or diverted to a non-food use; OR
Reject the lot.
Internal temperatures of the fish.

Collect a representative sample of the raw material, in-process product, or finished product, and analyze it for histamine at least quarterly; AND Ensure that new sensory examiners receive training to calibrate their ability to identify decomposed fish and that all sensory examiners receive periodic refresher training; AND Where histamine testing is part of a corrective action plan, periodically verify the findings (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) method); AND Before a temperature-indicating device (e.g., a thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
AND
Discontinue use of the supplier until evidence is obtained that the identified harvesting and onboard practices and controls have been improved.
Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a
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known accurate reference device (e.g., a thermometer traceable to the National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used; OR
Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Following the manufacturers instructions;
AND Once in service, check the temperatureindicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND
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TABLE 7-3
CONTROL STRATEGY EXAMPLE 1 - HARVEST VESSEL CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Harvest Vessel Control. This example illustrates how a fresh mahi-mahi processor that receives the fish on ice directly from harvest vessels that use a hook and line technique (fish brought onboard alive) can control scombrotoxin formation. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.
Histamine formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., metal fragments).

(1)
(2)
Scombrotoxin formation
All lots received are accompanied by harvest vessel records that show
Harvest vessel records
Review of controls documented in the records
Every lot received
Receiving supervisor
Reject the lot
Harvester vessel records
Perform histamine analysis on 1 incoming lot every 3 months (18 fish per sample) Review monitoring, corrective action, and verification records within 1 week of preparation
Receiving fresh mahi mahi on ice from harvest vessels (1) placement of fish on ice within 9 hours of death if the maximum exposure temperature does not exceed 83F or within 6 hours if the maximum exposure temperature exceeds 83F; (2) The fish were stored completely and continuously surrounded by ice after capture Amount of decomposition in the incoming lot Sensory examination (118 fish per lot; or all fish in the lot if less than 118 fish) Digital thermometer (1 fish/1,000 pounds; minimum of 12 fish per lot) Date and time of off-loading Every lot received Quality control staff
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Internal temperature of the fish at time of off-loading from vessel; Every lot received
Less than 2.5% decomposition (persistent and readily perceptible) in the incoming lot
Discontinue use of the supplier until evidence is obtained that harvesting and onboard practices and controls have been improved
Receiving record
Provide sensory training for new fish examiners and annual training for all fish examiners
Internal temperatures of all fish are to meet the following criteria based on the time since the death of the fish: >24 hours g 40 15 to < 24 hours g 50 12 to < 15 hoursg 60 < 12 hours g below ambient air and water temperatures commensurate with size of fish and time since death
Receiving supervisor
Receiving record
Review monitoring, corrective action, and verification records within 1 week of preparation Check the digital thermometer for accuracy and damage and to ensure that it is operational before putting it into operation; perform these same checks daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 2 - HISTAMINE

TESTING
The internal temperature should be 50F (10C) or below;
OR

The critical limits for this control strategy should include three components: Histamine testing; Sensory examination; Internal temperature measurements.
Histamine testing:
OR
For fish held iced or refrigerated (not frozen) onboard the vessel less than 12 hours after death:
Analysis of a representative sample of scombrotoxin-forming fish shows less than 50 ppm histamine in all fish in the sample; AND
Sensory examination of a representative sample of scombrotoxin-forming fish shows decomposition (persistent and readily perceptible) in less than 2.5% of the fish in the sample. For example, no more than 2 fish in a sample of 118 fish may show signs of decomposition. Note that the FFD&C Act prohibits interstate commerce of any decomposed fish whether or not the HACCP critical limit has been exceeded; AND
Internal temperature measurements:
The internal temperature should be sufficiently below water and air temperatures to indicate that appropriate chilling methods were implemented onboard the harvest vessel. Chilling of the fish should begin on the harvest vessel regardless of the time from death until off-loading from the vessel by the processor, unless the environmental conditions (e.g. air and water temperatures) are below 40F (4.4C) from the time of death until off-loading from the vessel by the processor;
OR For fish held iced or refrigerated (not frozen) onboard the vessel:
For fish held iced or refrigerated (not frozen) onboard the vessel 24 or more hours after death:
Elapsed time from death and internal temperatures at the time of off-loading from the vessel by the processor should be consistent with cooling curves that will prevent development of an unsafe level of histamine in the specific species, as established through a scientific study.

Histamine testing:
OR
Histamine content in the scombrotoxin forming fish flesh; AND
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Amount of decomposition in the scombrotoxin-forming fish lot; AND

Internal temperature measurement:
For scombrotoxin-forming fish held iced or refrigerated (not frozen) onboard the vessel:
The internal temperature of a representative number of the largest

fish in the lot at the time of off-loading
from the harvest vessel by the processor,
concentrating on any fish that show
signs of having been mishandled (e.g.,
inadequately iced);
AND
Date and time of off-loading.
Examine at least 118 fish, collected representatively throughout each lot (or the entire lot, for lots smaller than 118 fish). Additional fish should be examined if variability in fish-to-fish histamine content is expected to be high. Lots should consist of only one species of fish; for vessels delivering multiple species, testing should generally be done separately on each species. If the fish are received frozen, this monitoring procedure may be performed by a sensory examination on the warmed flesh produced by drilling the frozen fish (drill method). It may also be performed after thawing, rather than at receipt;
AND For fish held iced or refrigerated (not frozen) onboard the vessel:

For histamine analysis: Test a minimum of 18 fish, collected representatively throughout each lot (or the entire lot when there are fewer than 18 fish in the lot). Additional fish should be examined if variability in fish-to-fish histamine content is expected to be high. Lots should consist of only one species of fish; for vessels delivering multiple species, testing should generally be done separately on each species. Reject the lot if any fish are found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited if the critical limit is reduced accordingly. For example, a sample of 18 fish may be composited into 6 units of 3 fish each, provided the critical limit is reduced from 50 ppm to 17 ppm for each unit;
Use a temperature-indicating device (e.g., a thermometer) to measure the internal temperature of a representative number of the largest fish in each lot, concentrating on any that show signs of having been mishandled (e.g., inadequately iced). For example, when receiving 10 tons or more of fish, measure a minimum of one fish per ton, and when receiving less than 10 tons of fish, measure a minimum of one fish per 1,000 pounds. Measure a minimum of 12 fish, unless there are fewer than 12 fish in the lot, in which case measure all of the fish. Randomly select fish from throughout the lot. Lots that show a high level of temperature variability or lots of very small fish may require a larger sample size; AND Visually determine the date and time of off-loading.
AND
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Every lot of scombrotoxin-forming fish received.
OR Reject the lot;

AND
When the sensory examination critical limit has not been met:

For sensory examination and histamine testing:
Any person who is qualified by

experience or training to perform the work;
If histamine did not exceed 50 ppm in the initial testing: Chill and hold the affected lot (i.e., fish of common origin) until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the lot, including all fish in the lot that show evidence of decomposition (persistent and readily perceptible odors) (or the entire lot for lots smaller than 60 fish). Reject the lot if any fish are found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited for analysis if the action point is reduced accordingly. For example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit; AND

Take the following corrective actions to a product involved in a critical limit deviation:
When the histamine-level critical limit at the receiving step has not been met, reject the lot; AND When the internal temperature critical limit has not been met:
If histamine did not exceed 50 ppm in the initial testing: Chill and hold the affected lot (i.e., fish of common origin) until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the lot, including any fish measured to have temperatures that exceeded the critical limit (or the entire lot for lots smaller than 60 fish). Reject the lot if any fish are found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited for analysis if the action point is reduced accordingly. For example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit;
If any fish in the lot are to proceed into commerce for food use, perform a sensory examination of all fish in the lot to ensure that no decomposed fish proceed; AND Any individual fish found to be decomposed (persistent and readily perceptible) should be destroyed or diverted to a non-food use; OR
Reject the lot.
AND
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Discontinue use of the supplier until evidence is obtained that the identified harvesting and onboard practices have been improved.
traceable thermometer) under conditions

that are similar to how it will be used (e.g.,
product internal temperature) within the
temperature range at which it will be used;
OR

Receiving records showing:
AND Once in service, check the temperatureindicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
135
Date and time of off-loading;
AND Results of histamine analysis; AND Results of sensory examination; AND For fish held iced or refrigerated (not frozen) onboard the vessel:
Internal temperatures of the fish.

Periodically verify histamine findings (e.g., by comparing results with those obtained using an AOAC method or by analyzing proficiency samples); AND Ensure that new sensory examiners receive training to calibrate their ability to identify decomposed fish and that all sensory examiners receive periodic refresher training; AND Before a temperature-indicating device (e.g., a thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NIST-
TABLE 7-4
CONTROL STRATEGY EXAMPLE 2 - HISTAMINE TESTING
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Histamine Testing. This example illustrates how a canned tuna processor that receives frozen tuna directly from the harvest vessel can control scombrotoxin formation. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.
Histamine formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., Clostridium botulinum growth and toxin formation).

(1)
(2)
Receiving frozen tuna from harvest vessels
Less than 50 ppm histamine in all fish in the sample
Fish flesh for histamine content
Every lot received
Quality assurance staff
Reject the lot; Discontinue use of the supplier until evidence is obtained that harvesting and onboard practices have been improved If the initial histamine sample was <50 ppm, perform histamine analysis on a min, of 60 fish, collected representatively from the lot and reject the lot if any fish contains 50 ppm histamine; and if all fish <50 ppm
Reports of histamine analysis
Do a quarterly comparison of histamine test results with AOAC method Review monitoring, corrective action, and verification records within 1 week of preparation
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Amount of decomposition in the incoming lot Sensory examination (118 fish per lot, or all fish if lot is less than 118 fish) Every lot received Quality assurance staff
Histamine testing using the AOAC 977.13 method on a minimum of 18 fish per lot (36 fish from vessels with high variability of histamine detected between fish or when 1 of the first 18 fish exceeds 30 ppm histamine)
Conduct sensory evaluation of all fish in the lot, removing and destroying all decomposed fish Discontinue use of the supplier until evidence is obtained that harvesting and onboard practices have been improved
Less than 3 decomposed fish (persistent and readily perceptible) in a 118-fish sample
Sensory examination record
Provide sensory training for new fish examiners and annual training for all fish examiners Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 3 - TRANSIT

CONTROL
a controlled temperature environment) of 4 hours or less (optional control strategy):
Time of transit does not exceed 4 hours; AND Internal temperature of the fish at the time of delivery does not exceed 40F (4.4C).

For fish delivered refrigerated (not frozen):
All lots received are accompanied by transportation records that show that the fish were held at or below an ambient or internal temperature of 40F (4.4C) throughout transit. Note that allowance for routine refrigeration defrost cycles may be necessary;
Note: Processors receiving fish with transit times of 4 hours or less may elect to use one of the controls described for longer transit times instead.

For scombrotoxin-forming fish delivered refrigerated (not frozen):
OR For fish delivered under ice:

OR
The internal temperature of the fish throughout transportation; OR The ambient temperature within the truck or other carrier throughout transportation;
Fish are completely surrounded by ice at the time of delivery;
OR
For fish delivered under ice on an open-bed truck:

OR
Fish are stored completely surrounded by ice; AND The internal temperature of the fish at the time of delivery is 40F (4.4C) or below;
For scombrotoxin-forming fish delivered under ice:
The adequacy of ice surrounding the product at the time of delivery;
OR
For scombrotoxin-forming fish delivered under ice on an open-bed truck:
For fish delivered under chemical cooling media such as gel packs:
The adequacy of ice surrounding the product at the time of delivery; AND The internal temperature of the fish at time of delivery;
There is an adequate quantity of

cooling media that remain frozen to have maintained product at an internal temperature of 40F (4.4C) or below throughout transit; AND The internal temperature of the fish at the time of delivery is 40F (4.4C) or below;
OR
For scombrotoxin-forming fish held under chemical cooling media such as gel packs:
OR

137
The quantity and frozen status of cooling media at the time of delivery; AND The internal temperature of the fish at the time of delivery;
For fish delivered refrigerated (not frozen) with a transit time (including all time outside
OR For scombrotoxin-forming fish delivered refrigerated (not frozen) with a transit time of 4 hours or less:
The date and time fish were removed from a controlled temperature environment before shipment and the date and time delivered; AND The internal temperature of a representative number of fish at the time of delivery.
Make visual observations of the adequacy and frozen state of the cooling
media in a representative number of
containers (e.g., cartons and totes) from
throughout the shipment;
AND
Use a temperature-indicating device (e.g.,
a thermometer) to determine internal product temperatures in a representative number of fish from throughout the shipment, at delivery;

For fish delivered refrigerated (not frozen):
OR For fish delivered refrigerated (not frozen) with a transit time of 4 hours or less:
Use a continuous temperature-recording device (e.g., a recording thermometer) for internal product temperature or ambient air temperature monitoring during transit;
Review carrier records to determine the date and time fish were removed from
a controlled temperature environment
before shipment and the date and time
delivered;
AND
a thermometer) to determine internal product temperatures in a representative number of fish randomly selected from throughout the shipment, at delivery. Measure a minimum of 12 fish, unless there are fewer than 12 fish in a lot, in which case measure all of the fish. Lots that show a high level of temperature variability or lots of very small fish may require a larger sample size.
OR For fish delivered under ice:
Make visual observations of the adequacy of ice in a representative number of containers (e.g., cartons and totes) from throughout the shipment, at delivery;
OR For fish delivered under ice on an open-bed truck:
Make visual observations of the

adequacy of ice surrounding the product
in a representative number of containers
(e.g., cartons and totes) from throughout
the shipment, at delivery;
AND
a thermometer) to determine internal product temperatures in a representative number of fish from throughout the shipment, at delivery;

Every scombrotoxin-forming fish lot received.

For continuous temperature-recording devices:
OR For fish delivered under chemical cooling media such as gel packs:
Monitoring is performed by the device itself. The visual check of the data generated by the device, to ensure that the critical limits have consistently been met, may be performed by any person who has an understanding of the nature of the controls;
138
OR For other checks:
The number of containers examined and the sufficiency of ice for each; AND The number of containers in the lot;
OR

For chemical cooling media checks:

The number of containers examined and the frozen status of the cooling media for each; AND The number of containers in the lot; AND
Chill and hold the affected lot until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the lot, including any with temperatures that exceeded a critical limit and any fish observed to have been exposed to inadequate cooling media (or the entire lot for lots smaller than 60 fish). Reject the lot if any fish is found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited if the action point is reduced accordingly. For example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit; OR Reject the lot. AND
Results of internal product temperature monitoring, where applicable, including: The number of containers examined and the internal temperatures observed for each; AND The number of containers in the lot; AND
Date and time fish were initially removed from a controlled temperature environment and the date and time fish were delivered, when applicable.

Before a temperature-indicating device (e.g., a thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Discontinue use of the supplier or carrier until evidence is obtained that the identified transportation-handling practices have been improved.

Receiving records showing: Printouts, charts, or readings from temperature-recording devices (e.g., temperature recorder); OR
Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used
For continuous temperature monitoring:
For ice checks:
139
(e.g., product internal temperature)

within the temperature range at which it
will be used;
OR
the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used; AND When visual checks of ice are used, periodically measure internal temperatures of fish to ensure that the ice are sufficient to maintain product temperatures at 40F (4.4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation are complete and any critical limit deviations that occurred were appropriately addressed.
AND Once in service, check the temperatureindicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Check the accuracy of temperature-recording devices that are used for monitoring transit conditions upon receipt of each lot. The accuracy of the device can be checked by comparing the temperature reading on
140
TABLE 7-5
CONTROL STRATEGY EXAMPLE 3 - TRANSIT CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Transit Control. This example illustrates how a fresh mahi-mahi secondary processor that receives the product by air under chemical coolant (gel packs) can control scombrotoxin formation. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(3) MONITORING (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
CORRECTIVE ACTION(S)
RECORDS
VERIFICATION
Receiving
Every lot received
Receiving clerk
Reject the lot Discontinue use of the supplier or carrier until evidence is obtained that transportation-handling practices have been improved
Receiving record
141
Internal temperatures of all fish at delivery are 40F or below Every lot received Receiving clerk Internal core Digital thermometer for internal temperature temperature of and a near-surface one fish in 25% of temperature shipping containers but not fewer than of each fish 12 containers (or all containers if lot has less than 12 containers)
Adequate quantity of frozen gel packs to maintain the product at 40F or less throughout transit; and
Quantity and frozen condition of gel packs
Visual observation of a minimum of 25% of shipping containers in the lot but not fewer than 12 containers (or all containers if lot has less than 12 containers)
Reject the lot Discontinue use of the supplier or carrier until evidence is obtained that transportation-handling practices have been improved
Receiving record
Check the thermometer for accuracy and damage, and to ensure that it is operational before putting into operation; perform these same checks daily at the beginning of operations, and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 4 - PROCESSING

CONTROL
The fish are not exposed to ambient temperatures above 40F (4.4C) for more than 12 hours, cumulatively, if any portion of that time is at temperatures above 70F (21.1C); OR The fish are not exposed to ambient temperatures above 40F (4.4C) for more than 24 hours, cumulatively, as long as no portion of that time is at temperatures above 70F (21.1C).

During processing (e.g., butchering, cleaning, brining, salting, smoking, drying, fermenting, pickling, mixing, fermenting, stuffing, packing, labeling, and staging) of scombrotoxin-forming fish that have not been previously frozen or heat processed sufficiently to destroy scombrotoxin-forming bacteria:
Note: Only one of the two limits above should be selected. They should not be added for a total exposure of 36 hours.

The length of time the scombrotoxin-forming fish are exposed to unrefrigerated conditions (i.e., above 40F (4.4C)); AND The ambient temperatures during the exposure periods.
Note: If the critical limit is based on an assumption that temperatures may exceed 70F (21.1C), then only the length of exposure may need to be monitored.
The fish are not exposed to ambient temperatures above 40F (4.4C) for more than 4 hours, cumulatively, if any portion of that time is at temperatures above 70F (21.1C); OR The fish are not exposed to ambient temperatures above 40F (4.4C) for more than 8 hours, cumulatively, as long as no portion of that time is at temperatures above 70F (21.1C).

Make visual observations of the length of time of product exposure to unrefrigerated conditions (i.e., above 40F (4.4C)); AND Measure ambient air temperature, using:
Note: Only one of the two limits above should be selected. They should not be added for a total exposure of 12 hours.
OR During processing (e.g., thawing, butchering, cleaning, brining, mixing, fermenting, stuffing, packing, labeling, and staging) of scombrotoxin-forming fish or fishery products that have been (1) previously frozen or (2) heat processed sufficiently to destroy scombrotoxin-forming bacteria and are processed in a manner where there is an opportunity for recontamination with scombrotoxin-forming bacteria (e.g., contact with fresh fish, employees, or introduction of raw ingredients), such as in a tuna salad made from canned tuna with added raw ingredients:
A continuous temperature-recording device (e.g., a recording thermometer)

located in the processing area;
OR
A temperature-indicating device (e.g., a
thermometer) located in the processing area.
Note: Where multiple processing locations are combined in a cumulative exposure control strategy, temperature monitoring may be needed in each of the processing locations.
142
Example: A fresh tuna processor using raw material that was not previously frozen has identified a series of processing steps (i.e., from raw material cooler to finished product cooler) as CCPs for scombrotoxin formation. The processor establishes a critical limit of no more than 4 cumulative hours of exposure to unrefrigerated temperatures in excess of 40F (4.4C) during these processing steps. The processor uses a marked product to monitor the progress of the product through the processing steps. The time that the marked product is removed from refrigeration to the time the last of the marked product is placed in the finished product cooler is monitored visually and recorded. It is not necessary for the processor to measure temperature because the critical limit is based on an assumption that the product temperature may exceed 70F (21.1C).

For a continuous temperature-recording device:


For exposure time:
At least every 2 hours;
AND For temperature measurements: For a continuous temperature-recording device: Continuous monitoring during processing operations is accomplished by the device itself, with a visual check of the device at least once per lot or batch, but no less often than once per day; OR
Chill and hold the affected product until histamine analysis is performed on a minimum of 60 fish representatively collected from throughout the affected lot. Destroy the lot or divert it to a non-food use if any fish is found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited if the action plan is reduced accordingly. For example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit; OR Destroy the product; OR Divert the product to a non-food use. AND
Take the following corrective actions to regain control over the operation after a critical limit deviation:
Add ice to the product; OR Return the affected product to the cooler; AND
For a temperature-indicating device:

At least every 2 hours.
143
Modify the process as needed to reduce the time and temperature exposure.

Processing records showing the results of time and temperature exposure measurements.

Before a temperature-indicating device (e.g., a thermometer) or a temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and has sufficient ink and paper, where applicable; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended
144
TABLE 7-6
CONTROL STRATEGY EXAMPLE 4 - PROCESSING CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Processing Control. This example illustrates how a fresh bluefish processor that butchers, cleans, packs, labels, and boxes the fish at ambient temperature can control scombrotoxin formation. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(1)
(2)
Quality control supervisor
Processing record Ice and hold the affected batch in raw material cooler Perform histamine analysis on a minimum of 60 fish in the affected batch Destroy the entire batch if any fish exceeds 50 ppm histamine Modify the process, if necessary, to reduce delays
145
Processing (butchering, cleaning, packaging, labeling, and boxing)
The product is not out of refrigeration for more than 4 hours cumulatively
Time of product exposure to unrefrigerated conditions during processing operations
Visual tracking of time for a marked batch of product to move from raw material cold storage to final product cold storage
Every batch of fish removed from raw material cold storage for processing
Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 5 - STORAGE

CONTROL

For refrigerated storage of scombrotoxin forming fish:
OR
The temperature of the cooler;

For refrigerated (not frozen) storage or processing of raw material, in-process product, or finished product:
For storage under ice of scombrotoxin forming fish:
The product is held at a cooler temperature of 40F (4.4C) or below. Note that allowance for routine refrigeration defrost cycles may be necessary. On the other hand, minor variations in cooler temperature measurements can be avoided by submerging the sensor for the temperature-recording device (e.g., temperature-recorder) in a liquid that mimics the characteristics of the product. Also note that critical limits during refrigerated storage that specify a cumulative time and temperature of exposure to temperatures above 40F (4.4C) are not ordinarily suitable because of the difficulty in tracking the specific products and the specific cumulative temperature exposures that those products experience. The cumulative exposure for each product would then need to be determined prior to shipping. If you chose this approach, the critical limit for cumulative exposure to temperatures above 40F (4.4C) should include time during transit, refrigerated storage, and refrigerated and unrefrigerated processing;
The adequacy of ice surrounding the product.

For refrigerated storage:
OR
Measure cooler temperature using a continuous temperature-recording device (e.g., a recording thermometer);
For storage under ice:
Make visual observations of the adequacy of ice in a representative number of containers (e.g., cartons and totes) from throughout the cooler.

Continuous monitoring during storage is accomplished by the device itself, with a visual check of the recorded data at least once per day;
OR For storage under ice:
Monitoring with sufficient frequency to ensure control.

OR For raw material, in-process product, or finished product stored under ice:
The product is completely and

continuously surrounded by ice throughout the storage time.
146
OR Any person who has an understanding of the nature of the controls.
Make adjustments to the ice application operations.


Chill and hold the product until it can be evaluated based on its total time and temperature exposure, including exposures during prior processing operations. OR Chill and hold the affected product until histamine analysis is performed on a minimum of 60 fish collected from throughout each affected lot. Destroy the lot or divert it to a non-food use if any fish is found with histamine greater than or equal to 50 ppm. The fish collected for analysis may be composited if the action point is reduced accordingly. For example, a sample of 60 fish may be composited into 20 units of 3 fish each, provided the action point is reduced from 50 ppm to 17 ppm for each unit; OR Destroy the product; OR Divert the product to a non-food use. AND
Printouts, charts, or readings from continuous temperature-recording

devices;
AND
Record of visual checks of recorded data;
OR
The number of containers examined and the sufficiency of ice for each; AND The approximate number of containers in the cooler.

Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
Prevent further deviation:
Add ice to the product; OR Move some or all of the product in the malfunctioning cooler to another cooler;
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the
AND Address the root cause:
Make repairs or adjustments to the malfunctioning cooler;

147
history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND When visual checks of ice are used, periodically measure internal temperatures of fish to ensure that the ice is sufficient to maintain product temperatures at 40F (4.4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
148
TABLE 7-7
CONTROL STRATEGY EXAMPLE 5 - STORAGE CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 5 - Storage Control. This example illustrates how a fresh fish processor can control scombrotoxin formation. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(1)
(2)
Raw material and finished product cold storage (shared cooler)
Maximum cooler temperature of 40F
Cooler temperature
Time and temperature data logger
Production supervisor
Continuous, with a visual check of recorded data once per day
Ice and hold the affected product inside the cooler Check sufficiency of ice on the product two times per day until cooler is functioning reliably Perform histamine analysis on a minimum of 60 fish representative of the affected product Destroy all affected product if any fish exceeds 50 ppm histamine Adjust and repair cooler as needed
Data logger printout
149
Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; perform these checks daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to Non-FDA Web site references after March 29, 2011. Arnold, S., and D. Brown. 1978. Histamine toxicity from fish products. Adv. Food Res. 24:113-154. Baranowski, J. D., H. A. Frank, P. A. Brust, M. Chongsiriwatana, and R. J. Premaratne. 1990. Decomposition and histamine content in mahimahi (Coryphaena hippurus). J. Food Prot. 53(3):217222. Behling, A. R., and S. L. Taylor. 1982. Bacterial histamine production as a function of temperature and time of incubation. J. Food Sci. 47:1311-1317. Bjeldanes, L. F., D. E. Schultz, and M. M. Morris. 1978. On the aetiology of scombroid poisoning: cadaverine potentiation of histamine toxicity in the guinea pig. Food Cosmet. Toxicol. 16:157-159. Brillantes, S., S. Paknol, and A. Totakien. 2002. Histamine formation in fish sauce production. J. Food Sci. 67:2090-2094. Concon, J. (ed.), 1988. Food toxicology, p. 511-605. Marcel Dekker, Inc., New York, NY. Eitenmiller, R., and S. DeSouza. 1984. Enzymatic mechanisms for amine formation in fish, p. 431-442. In E. Ragelis (ed.), Seafood toxins. American Chemical Society, Washington, DC. Farn, G., and C. Sims. 1987. Chemical indices of decomposition in tuna, p. 175-184. In D. Kramer and J. Liston (ed.), Seafood quality determination (Book 15 of Developments in
150
seafood science). Elsevier, New York, NY. Fletcher, G. C., G. Summers, and P. W. C. van Veghel. 1998. Levels of histamine and histamine-producing bacteria in smoked fish from New Zealand markets. J. Food Prot. 61(8):1064-1070. Frank, H. A., and D. H. Yoshinaga. 1984. Histamine formation in tuna, p. 443-451. In E. Ragelis (ed.), Seafood toxins. American Chemical Society, Washington, DC. Frank, H. A., D. H. Yoshinaga, and W. Nip. 1981. Histamine formation and honeycombing during decomposition of skipjack tuna. Katsuwonus pelamis, at elevated temperatures. Mar. Fisheries Rev. 43(10):9-14. Hernndez-Herrero, M. M., A. X. Roig-Sagus, J. J. Rodrguez-Jerez, and M. T. Mora-Ventura. 1999. Halotolerant and halophilic histamineforming bacteria isolated during the ripening of salted anchovies (Engraulis encrasicholus). J. Food Prot. 62(5):509-514. Inestia, C. 1973. Significance and detection of histamine in food, p. 327-347. In Microbiological safety of food. Academic Press, New York, NY. Lehane, L., and J. Olley. 2000. Review: histamine fish poisoning revisited. Int. J. Food Microbiol. 58:1-37. Predy, G., L. Honish, W. Hohn, and S. Jones. 2003. Was it something she ate? Case report and discussion of scombroid poisoning. Can. Med. Assoc. J. 168(5):587-588. Silva, C. C. G., J. B. Da Ponte, and M. L. N. Enes Dapkevicius. 1998. Storage temperature effect on histamine formation in big eye tuna and skipjack. J. Food Sci. 63(4):644-647. Staruszkiewicz, W. F. April 2007. Report on the 2005 Hawaii Bigeye Tuna Research Project. Effects of onboard fish handling on the formation of histamine. Staruszkiewicz, W. F., J. D. Barnett, P. L. Rogers, R. A. Benner, Jr., L. L. Wong, and J. Cook. 2004. Effects of on-board and
dockside handling on the formation of biogenic amines in mahimahi (Coryphaena hippurus), skipjack tuna (Katsuwonus pelamis), and yellowfin tuna (Thunnus albacares). J. Food Prot. 67(1):134-141. Stratton, J., and S. Taylor. 1991. Scombroid poisoning, p. 331-351. In D. Ward and C. Hackney (ed.), Microbiology of marine food products. Van Nostrand Reinhold, New York, NY. Taylor, S. 1985. Histamine poisoning associated with fish, cheese, and other foods, p. 1-47. World Health Organization, VPH/ FOS/85.1. Geneva, Switzerland. Taylor, S. 1988. Marine toxins of microbial origin. Food Technol. 42:94-98. Taylor, S., and S. Summer. 1987. Detection of histamine, cadaverine, and putrescine, p. 235-246. In D. Kramer and J. Liston (ed.), Seafood quality determination (Book 15 of Developments in seafood science). Elsevier, New York, NY. Taylor, S. L., J. Y. Hui, and D. E. Lyons. 1984. Toxicology of scombroid poisoning, p. 417-430. In E. Ragelis (ed.), Seafood toxins. American Chemical Society, Washington, DC. van Spreckens, K. 1987. Histamine production by psychrophilic flora, p. 309-318. In D. Kramer and J. Liston (ed.), Seafood quality determination (Book 15 of Developments in seafood science). Elsevier, New York, NY. Yongsawatdigul, J., Y. J. Choi, and S. Udomporn. 2004. Biogenic amines formation in fish sauce prepared from fresh and temperature-abused Indian anchovy (Stolephourus indicus). J. Food Sci. 69(4):312-319.
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NOTES:
152
CHAPTER 8: Other Decomposition-Related Hazards

Chapter 7 covers scombrotoxin poisoning in certain species of fish. This poisoning occurs as a result of the formation of high levels of histamine during decomposition of the fish at improper holding temperatures. There are indications that decomposition can result in the production of other toxins (e.g., biogenic amines, such as putrescine and cadaverine) that have the potential to cause illness, even in the absence of histamine formation. Such illnesses have been reported with consumption of a number of fish species. FDA also has received a number of consumer complaints concerning illnesses that are associated with the consumption of decomposed shrimp and salmon. There are also some indications that chemicals formed when fats and oils in foods oxidize may contribute to long-term detrimental health effects.
153
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to Non-FDA Web site references after March 29, 2011. Arnold, S. H., and D. W. Brown. 1978. Histamine toxicity from fish products. Adv. Food Res. 24:113-154. Bjeldanes, L. F., D. E. Schultz, and M. M. Morris. 1978. On the aetiology of scombroid poisoning: cadaverine potentiation of histamine toxicity in the guinea pig. Food Cosmet. Toxicol. 16:157-159. Concon, J. 1988. Food toxicology. Part A. Principles and concepts, p. 626-627. Marcel Dekker, Inc., New York, NY. Eitenmiller, R., and S. DeSouza. 1984. Enzymatic mechanisms for amine formation in fish, p. 431-442. In Ragelis, E. (ed.), Seafood toxins. American Chemical Society, Washington, DC. Farn, G., and C. Sims. 1987. Chemical indices of decomposition in tuna, p. 175-184. In D. Kramer and J. Liston (ed.), Seafood quality determination (Book 15 of Developments in food science). Elsevier, New York, NY. Guilln, M. D., and E. Goicoechea. 2008. Toxic oxygenated alpha, beta-unsaturated aldehydes and their study in foods: a review. Crit. Rev. Food Sci. Nutr. 48:119-136. Kubow, S. 1992. Routes of formation and toxic consequences of lipid oxidation products in foods. Free Radic. Biol. Med. 12:63-81. Lehane, L., and J. Olley. 2000. Review: histamine fish poisoning revisited. Int. J.
Food Microbiol. 58:1-37. Parrot, J., and G. Nicot. 1986. Absorption de lhistamine par lappareil digestif, p. 148-161. In Handbuch der Experimentellen Pharmakologie, Vol. 18. Springer-Verlag, New York, NY. Quakenbush, F. W. 1945. Toxicity of rancid fats. Oil & Soap. 22:336-338. Stratton, J., and S. Taylor. 1991. Scombroid poisoning, p. 331-351. In D. Ward and C. Hackney (ed.), Microbiology of marine food products. Van Nostrand Reinhold, New York, NY. Taylor, S. 1985. Histamine poisoning associated with fish, cheese, and other foods, p. 1-47. World Health Organization, VPH/ FOS/85.1. Geneva, Switzerland. Taylor, S. 1988. Marine toxins of microbial origin. Food Technol. 42:94-98. Taylor, S., and S. Summer. 1987. Determination of histamine, putrescine, and cadaverine, p. 235-246. In D. Kramer and J. Liston (ed.), Seafood quality determination (Book 15 of Developments in food science). Elsevier, New York, NY. Taylor, S. L., J. Y. Hui, and D. E. Lyons. 1984. Toxicology of scombroid poisoning, p. 417-430. In E. Ragelis (ed.), Seafood toxins. American Chemical Society, Washington, DC.
154
CHAPTER 9: Environmental Chemical Contaminants and Pesticides


Environmental chemical contaminants and pesticides in fish pose a potential human health hazard. Fish can be harvested from waters that are contaminated by varying amounts of industrial chemicals, including heavy metals and pesticides. These contaminants may accumulate in fish at levels that can cause human health problems (e.g., carcinogenic and mutagenic effects). The hazard is most commonly associated with exposure over a prolonged period of time (chronic exposure). Illnesses related to a single exposure (one meal) are very rare. Concern for these contaminants primarily focuses on fish harvested from aquaculture ponds, freshwater bodies, estuaries, and near-shore coastal waters (e.g., areas subject to shoreside contaminant discharges), rather than from the open ocean. Environmental chemicals and pesticides may also accumulate in aquacultured fish through contaminated feed ingredients (e.g., pesticides in oil-containing feed ingredients derived from near-shore bait fish). Although some pesticides have not been produced or used in the United States for many years (e.g., dichloro-diphenyl-trichloroethane (DDT) and polychlorinated biphenyls (PCBs)), many are very persistent and tend to accumulate in soil and sediments. Once pesticides are introduced into the environment, they may travel beyond their point of application or discharge. Certain pesticides are applied directly to the water in aquaculture ponds to control weeds and algae and to eliminate fish and invertebrates. These products can be used legally only if they are registered with the U.S. Environmental Protection Agency (US EPA)
and used according to conditions described on the label (40 CFR 180 and the Guide to Drug, Vaccine, and Pesticide Use in Aquaculture, the Federal Joint Subcommittee on Aquaculture (http://aquanic.org/ jsa/wgqaap/drugguide/drugguide.htm)). Many contaminants accumulate in the edible fatty tissues of fish. Concentrations of these contaminants can vary considerably in individual fish of the same species from the same location, depending on factors such as their fat content, size, age, and gender. In the case of components or extracts of whole fish (e.g., dietary supplements, dietary ingredients, and flavors), the component or extract may contain higher or lower concentrations of environmental chemical contaminants and pesticides than the whole fish from which it was derived. For example, organochlorine contaminants, such as PCBs, are oil soluble. When producing fish oil and fish meal, any PCBs present will become more concentrated in the oil fraction and less concentrated in the water fraction, as compared with the levels in the whole fish. Control of chemical contaminants Federal tolerances and action levels are established for some of the most toxic and persistent contaminants that can be found in fish. These levels are listed in Table 9-1. State, tribal, local, or foreign authorities may use the federal tolerances or action levels to decide whether to issue local advisories to consumers recommending limits on consumption of all or certain species of locally harvested fish (some of which may be commercially important) or to close waters for commercial harvesting of all or certain species of fish.
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In the case of molluscan shellfish, state, tribal, territorial and foreign government agencies, called shellfish control authorities, consider the degree of chemical contamination as part of their classification of harvesting waters. As a result of these classifications, molluscan shellfish harvesting is allowed from some waters and not from others. Shellfish control authorities then exercise control over the molluscan shellfish harvesters to ensure that harvesting takes place only when and where it has been permitted. In this context, molluscan shellfish include oysters, clams, mussels, and scallops. Other significant elements of shellfish control authorities efforts to control the harvesting of molluscan shellfish include requirements that (1) containers of in-shell molluscan shellfish (shellstock) bear a tag that identifies the type and quantity of shellfish, the harvester, harvest location, and the date of harvest (21 CFR 123.28(c)); (2) molluscan shellfish harvesters be licensed (note that licensing may not be required in all jurisdictions); (3) processors that ship, reship, shuck, or repack molluscan shellfish be certified; and (4) containers of shucked molluscan shellfish bear a label with the processors name, address, and certification number. Processors of seafood components and extracts may choose to control environmental chemical contaminants and pesticides at receipt (e.g., by screening raw materials). If contaminants in the raw material are present at unacceptable levels, processors may reject the product or choose to implement refining steps that reduce the contaminants to acceptable levels in the finished product. These steps may include distillation, absorption, and steam deodorization. You should validate the effectiveness of these refining steps at reducing environmental and chemical contaminants to an acceptable level and include appropriate controls in your Hazard Analysis Critical Control Point (HACCP) plan. No further information on these control measures is provided in this guidance document.
Tolerance and action levels Table 9-1, Environmental Chemical Contaminants and Pesticides Tolerance and Action Levels, lists the tolerance and action levels that have been established for environmental chemical contaminants and pesticides in the edible portion of fish (wet weight).
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TABLE 9-1
ENVIRONMENTAL CHEMICAL CONTAMINANTS AND PESTICIDES TOLERANCE AND ACTION LEVELS

Tolerance Levels
DELETERIOUS SUBSTANCE LEVEL IN EDIBLE TISSUE FOOD COMMODITY REFERENCE
PCBs Carbaryl Diquat Diquat Diuron and its metabolites Endothall and its monomethyl ester Fluridone Glyphosate Glyphosate 2,4-D 2,4-D
2 ppm 0.25 ppm 2 ppm 20 ppm 2 ppm 0.1 ppm 0.5 ppm 0.25 ppm 3 ppm 0.1 ppm 1 ppm
All fish Oysters Fish Shellfish Farm-raised, freshwater finfish All fish Finfish and crayfish Fish Shellfish Fish Shellfish
21 CFR 109.30 40 CFR 180.169 40 CFR 180.226 40 CFR 180.226 40 CFR 180.106 40 CFR 180.293 40 CFR 180.420 40 CFR 180.364 40 CFR 180.364 40 CFR 180.142 40 CFR 180.142
Action Levels
DELETERIOUS SUBSTANCE LEVEL IN EDIBLE TISSUE FOOD COMMODITY REFERENCE
Aldrin and dieldrin1 Benzene hexachloride Chlordane Chlordecone

2
0.3 ppm 0.3 ppm 0.3 ppm 0.3 ppm 0.4 ppm 5 ppm 1 ppm 0.3 ppm 0.1 ppm
All fish Frog legs All fish All fish Crabmeat All fish All fish All fish All fish
Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 540.600 Compliance Policy Guide, Sec. 575.100 Compliance Policy Guide, Sec. 575.100
Chlordecone2 DDT, TDE, and DDE3 Methylmercury4 Heptachlor and Heptachlorepoxide5 Mirex
1. The action level for aldrin and dieldrin is for residues of the pesticides individually or in combination. However, in calculating a total, amounts of aldrin or dieldrin found at below 0.1 ppm are not counted. 2. Previously listed as Kepone, the trade name of chlordecone. 3. The action level for DDT, TDE, and DDE is for residues of the pesticides individually or in combination. However, in calculating a total, amounts of DDT, TDE, and DDE found below 0.2 ppm are not counted. 4. See Chapter 10 for additional information. 5. The action level for heptachlor and heptachlor epoxide is for the pesticides individually or in combination. However, in calculating a total, amounts of heptachlor and heptachlor epoxide found below 0.1 ppm are not counted.
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The following guidance will assist you in determining whether environmental chemical contaminants and pesticides are a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of environmental chemical contaminants or pesticides will be introduced at this processing step (e.g., do such contaminants and pesticides come in on the raw material)?
2. Can unsafe levels of environmental chemical contaminants and pesticides that were introduced earlier be eliminated or reduced to an acceptable level at this processing step?
Tables 3-2 and 3-3 (Chapter 3) identify the species of fish for which environmental chemical contaminants and pesticides are a potential hazard. Under ordinary circumstances, it would be reasonably likely to expect that, without proper controls, unsafe levels of environmental chemical contaminants and pesticides could enter the process at the receiving step from those species. However, there may be circumstances that would allow you to conclude that it is not reasonably likely for unsafe levels of environmental chemical contaminants and pesticides to occur in fish harvested from your area. You should be guided by the historical occurrence of environmental contaminants and pesticides, at levels above established tolerance and action levels, in fish from the area in which your fish are caught. This information may be available from federal, state, tribal, territorial, local, or foreign health or environmental authorities in the area where your fish are caught. If you are receiving fish, other than molluscan shellfish, from another processor, you would not need to identify environmental chemical contaminants and pesticides as a significant hazard. This hazard should have been fully controlled by the primary (first) processor.
Environmental chemical contaminants and pesticides should be considered a significant hazard at any processing step where a preventive measure is or can be used to eliminate the hazard or to reduce the likelihood of its occurrence to an acceptable level. Preventive measures for environmental chemical contaminants and pesticides can include: For wild-caught fish other than molluscan shellfish: Making sure that incoming fish have not been harvested from waters that are closed to commercial harvest because of concentrations of environmental chemical contaminants or pesticides exceeding the federal tolerance or action levels; Making sure that incoming fish have not been harvested (for commercial purposes) from the same waters that are under a consumption advisory by a state, tribal, territorial, local, or foreign regulatory authority based on a determination by the authority that fish harvested from these waters are reasonably likely to contain contaminants above the federal tolerance or action levels. Note that many consumption advisories are not based on such a determination. For aquacultured fish other than molluscan shellfish: Reviewing, at time of receipt, the producers lot-by-lot certification that harvest is from uncontaminated waters, coupled with appropriate verification; Reviewing, at time of receipt, test results of fish tissue samples or production site water for those contaminants that
158
are reasonably likely to be present, and obtaining information on present land use practices in the area immediately surrounding the production area (tests and monitoring may be performed by the aquacultural producer, a state, tribal, territorial, local, or foreign authority, or a third-party organization); Conducting on-farm visits to the aquacultural producer to collect and analyze water or fish samples for those environmental chemical contaminants and pesticides that are reasonably likely to be present, and to review present land use practices in the area immediately surrounding the production area; Reviewing, at time of receipt, evidence (e.g., a third-party certificate) that the producer operates under a third party-audited Quality Assurance (QA) program for environmental chemical contaminants and pesticides (e.g., the National Aquaculture Associations Fish Producers Quality Assurance Program); Conducting, at time of receipt, environmental chemical contaminant and pesticide testing of fish tissue for those contaminants that are reasonably likely to be present. For molluscan shellfish, both aquacultured and wild caught: Checking incoming molluscan shellfish to ensure that containers are properly tagged or labeled; Screening incoming molluscan shellfish to ensure that they are supplied by a licensed harvester (where licensing is required by law) or by a certified dealer. These preventive measures are ordinarily employed either at the receiving step or at the pre-harvest step. In the case of an integrated operation, where fish cultivation and processing are performed by the same
firm, it may be possible and desirable to exercise preventive measures early in the process (ideally when the cultivation site is selected), rather than at receipt of the fish at the processing plant. Such preventive measures will not be covered in this guidance document. Intended use For environmental chemical contaminants and pesticides, it is unlikely that the intended use of the product will affect the significance of the hazard.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for the hazard of environmental chemical contaminants and pesticides:
Is the raw material an aquacultured product other than molluscan shellfish? 1. If the raw material is an aquacultured product other than molluscan shellfish, do you have a relationship with the producer that enables you to visit the farm before receipt of the fish? a. If you have such a relationship with
the producer, then you should identify the pre-harvest step as the CCP for environmental chemical contaminants and pesticides. The preventive measure for this type of control is: Conducting on-farm visits to the aquacultural producer to collect and analyze water or fish samples for those environmental chemical contaminants and pesticides that are reasonably likely to be present, and to review present land use practices in the area immediately surrounding the production area. Example: An aquacultured catfish processor that regularly purchases from the same
159
producers should visit the producers before the fish are harvested. The processor should collect and analyze water or fish samples for those environmental chemical contaminants and pesticides that are reasonably likely to be present and should review present land use at the pond site and in the adjacent areas. The processor should then set the CCP for environmental chemical contaminants and pesticides at the pre-harvest step. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - OnFarm Visits.
b. If no such relationship exists with the
verification and should set the CCP at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 Suppliers Certification. Reviewing, at time of receipt, test results of water or fish tissue samples for those contaminants that are reasonably likely to be present and obtaining information on the present land use practices in the area immediately surrounding the production area (the aquaculture producer, a state, tribal, territorial, local or foreign authority, or a third-party organization may perform tests and monitoring). Example: A farm-raised catfish processor purchases catfish from producers with which the processor has no long-term relationship. The processor requires all new suppliers to provide the test results of water samples or fish tissue for those contaminants that are reasonably likely to be present and reports on present agricultural and industrial land use at and near the pond site. The land use reports are updated annually and whenever information on the land use change warrants a more frequent update (the aquaculture producer, a state, tribal, territorial, local or foreign authority, or a thirdparty organization may perform tests and monitoring). The processor should set the CCP at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 3 Records of Testing and Monitoring.
producer, then you should identify the receiving step as the CCP for environmental chemical contaminants and pesticides. At the receiving step, you should exercise one of the following preventive measures: Reviewing, at time of receipt, the suppliers lot-by-lot certification of harvesting from uncontaminated waters, coupled with appropriate verification. Example: An aquacultured shrimp processor that purchases raw material through various brokers should receive lot by-lot certificates from the suppliers. The certificates would state that shrimp were not harvested from contaminated waters that would cause the levels in shrimp to exceed the established tolerance or action levels. The processor should combine this monitoring procedure with quarterly raw material testing for those environmental chemical contaminants and pesticides that are reasonably likely to be present for
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Conducting, at time of receipt, analysis of fish tissue for those environmental chemical contaminants and pesticides that are reasonably likely to be present. Example: An aquacultured shrimp processor that purchases raw material through various brokers should screen all incoming lots of shrimp for those environmental chemical contaminants and pesticides that are reasonably likely to be used in the production area. The processor should set the CCP at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 Chemical Contaminant Testing. Reviewing, at time of receipt, evidence (e.g., a continuing or lot-by-lot third- party certificate) that the producer operates under a third-party-audited QA program that covers environmental chemical contaminants and pesticides. The certificate should outline the audit steps and summarize the water and/or fish test results. Example: An aquacultured trout processor that regularly purchases raw trout from the same producer should obtain a thirdparty certificate, valid for 1 year (i.e., a continuing certificate), that attests that the producer operates under a QA program that controls environmental chemical contaminants and pesticides or should receive a lot-by-lot certificate issued by the third party. The processor should set the CCP at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 5 - QA Program.
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Is the raw material molluscan shellfish (aquacultured or wild caught) or wild caught fish other than molluscan shellfish? 1. If the raw material is molluscan shellfish or wildcaught fish other than molluscan shellfish, you should identify the receiving step as the CCP for environmental chemical contaminants and pesticides. At the receiving step, you should exercise the following preventive measures: a. For wild-caught fish other than
molluscan shellfish:
Making sure that incoming fish have not been harvested from waters that are closed to commercial harvest because of concentrations of environmental chemical contaminants or pesticides exceeding the federal tolerance or action levels; Making sure that incoming fish have not been harvested from waters that are under a consumption advisory by a state, tribal, territorial, local, or foreign regulatory authority based on a determination by the authority that fish harvested from the waters are reasonably likely to contain contaminants above the federal tolerance or action levels. Example: A processor purchases bluefish directly from the harvester. The processor asks the harvester where the fish were caught. The processor then compares the harvest area location with the areas that are closed to commercial fishing by state or local regulatory authorities or that are under consumption advisories that include bluefish and that are based on the reasonable likelihood that a contaminant level in fish tissue will exceed a federal tolerance or action level. The processor should set the CCP at receiving.
This control approach is a control strategy referred to in this chapter as Control Strategy Example 6 - Source Control for wild caught Fish Other Than Molluscan Shellfish.
b. For molluscan shellfish:
CONTROL STRATEGY
MAY APPLY TO PRIMARY PROCESSOR
MAY APPLY TO SECONDARY PROCESSOR
On-farm visit Suppliers certification Records of testing and monitoring Chemical contaminant testing QA program Source control for wild caught fish other than molluscan shellfish Source control for molluscan shellfish
Checking incoming molluscan shellfish to ensure that they are properly tagged or labeled; Checking incoming molluscan shellfish to ensure that they are supplied by a licensed harvester (where licensing is required by law) or by a certified dealer. Example: A processor purchases oysters directly from the harvesters. The processor should check the harvest location on the tags attached to the sacks of oysters. The processor should then compare the harvest area location with information on closed waters and check the harvesters state licenses. The processor should set the CCP at receiving. This control approach is a control strategy referred to in this chapter as Control Strategy Example 7 - Source Control for Molluscan Shellfish.
CONTROL STRATEGY EXAMPLE 1 - ON-FARM

VISIT

Environmental chemical contaminants and pesticides that are reasonably likely to be present in farm water may not be at levels so high that they are reasonably likely to result in concentrations in fish tissue above the established tolerance or action levels (refer to Table 9-1). Elevated concentrations of chemical contaminants in water can be an indication that they are reasonably likely to be present in the fish tissue. Note that US EPA has developed water quality guidance documents that may be suitable for evaluating water quality in local situations (U.S. EPA Water Quality Standards Handbook, Appendix I); OR The levels of environmental contaminants and pesticides in fish tissue samples that are reasonably likely to be present may not exceed the established tolerance or action levels (refer to Table 9-1); AND Agricultural and industrial practices in the area near the production site must not be reasonably likely to cause contamination

The following guidance provides seven control strategies for environmental chemical contaminants and pesticides. It is important to note that you may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
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of the fish tissue above the established tolerance or action levels (refer to Table 9-1).

The levels of environmental chemical contaminant and pesticide residues found in water or in fish tissue for those contaminants that are reasonably likely to occur; AND Agricultural and industrial practices in the area near the production site.

Do not have the product shipped from the production site for processing. AND

Collect and analyze water samples or fish tissue samples from each production site; AND Ask questions about and observe agricultural and industrial practices in the area near the production site, such as:
Discontinue use of the supplier until evidence is obtained that the cause of the chemical contamination has been eliminated.

Test results; AND On-site audit report.
Which types of crops, if any, are grown in the area near the production site? What pesticides, if any, are used on these crops, how are they applied, and at what time of year? What industrial and urban discharges, if any, enter the watershed surrounding the production site?


For testing water:
Before first delivery from each production site;
OR
For testing fish tissue:
Before each delivery;
AND For evaluating agricultural and industrial practices:
At least once per year for each

production site.
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TABLE 9-2
CONTROL STRATEGY EXAMPLE 1 - ON-FARM VISITS
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - On-Farm Visits. This example illustrates how an aquacultured catfish processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.
Environmental chemical contaminants and pesticides may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., aquaculture drugs, food and color additives, and metal fragments).

(1)
(2)
Pre-harvest
Environmental chemical contaminants and pesticides
Before each harvest
Levels of environmental chemical contaminants and pesticides in fish tissue may not exceed established tolerance and action levels for those contaminants that are reasonably likely to be present* Agricultural and industrial practices in the area near the pond must not be reasonably likely to cause contamination of the fish tissue above the established tolerances and action levels Agricultural and industrial practices near the pond Ask questions and observe agricultural and industrial practices Once per year Field agent
Environmental chemical contaminant and pesticide levels in fish tissue for those contaminants that are reasonably likely to be present*
Collect samples and analyze for environmental chemical contaminants and pesticides*
Field agent will submit samples to the contract laboratory
Test results
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Do not have the product shipped for processing Discontinue use of the supplier until evidence is obtained that the cause of the chemical contamination has been eliminated Do not have the product shipped for processing Discontinue use of the supplier until evidence is obtained that the cause of the chemical contamination has been eliminated
Review monitoring and correction action records within 1 week of preparation
Field agent report
* Note: This plan is for illustrative purposes only. An actual plan should specify (1) in the Critical Limits column: the environmental chemical contaminants and pesticides that are reasonably likely to be present and the critical limits to be applied to each contaminant; and (2) in the Monitoring columns: the contaminants for which analysis will be conducted, the protocol for sample collection, and the analytical method to be used for each contaminant.
CONTROL STRATEGY EXAMPLE 2 - SUPPLIERS

CERTIFICATION

Copy of the certificate; AND Receiving record showing lots received and the presence or absence of a certificate.

A certificate accompanying all lots received (lot by lot) that indicates that fish were not harvested from contaminated waters that could cause the levels in fish tissue to exceed the established federal tolerance and action levels (refer to Table 9-1).

Visit all new aquacultured fish producers within the year and all existing fish suppliers at a predetermined frequency (e.g., 25% per year) to collect and analyze water or fish tissue samples, as appropriate, for those environmental chemical contaminants and pesticides that are reasonably likely to be present, and review agricultural and industrial practices in the production area; OR Collect a representative sample of the raw material, in-process product, or finished product at least quarterly, and analyze it for those environmental chemical contaminants and pesticides that are reasonably likely to be present; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Presence of a certificate indicating harvesting from uncontaminated waters.

Visual check for the presence of a certificate.

Each lot received.


Reject the lot; OR Hold the lot until a certificate can be provided; OR Hold and analyze the lot for those environmental chemical contaminants and pesticides that are reasonably likely to be present. AND
Discontinue use of the supplier until evidence is obtained that the supplier will comply with the certification controls.
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TABLE 9-3
CONTROL STRATEGY EXAMPLE 2 - SUPPLIERS CERTIFICATION
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Suppliers Certification. This example illustrates how an aquacultured shrimp processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.

(1)
(2)
Receiving
CHAPTER 9: Environmental Chemical Contaminants and Pesticides Presence of a certificate Visual check Each lot received Receiving dock employee Reject lot Certificate accompanying all lots received indicates that fish were not harvested from contaminated waters that could cause the levels in fish tissue to exceed the established federal tolerance and action levels Discontinue use of the supplier until evidence is obtained that the supplier will comply with the certification controls
Copy of the certificate Receiving record
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Review monitoring, corrective action, and verification records within 1 week of preparation Visit all new aquacultured fish producers within the year and 25% of existing suppliers each year to collect and analyze water samples, and review agricultural and industrial practices in the area
CONTROL STRATEGY EXAMPLE 3 - RECORDS OF

TESTING AND MONITORING
pesticides that are reasonably likely to be present; AND Monitoring results for agricultural and industrial practices.

Reports of analyses of the water from all new suppliers that show that levels of those environmental chemical contaminants and pesticides that are reasonably likely to be present are not so high that they are reasonably likely to result in levels in the fish tissue that exceed the established federal tolerance and action levels (refer to Table 9-1). (The aquaculture producer, a state, tribal, territorial, local, or foreign authority, or a third-party organization may perform tests.) Note that US EPA has developed water quality documents that may be suitable for evaluating water quality in local situations (U.S. EPA Water Quality Standards Handbook, Appendix I); OR Reports of analyses of fish tissue for each delivery that show that levels of those environmental chemical contaminants and pesticides that are reasonably likely to be present are below the established federal tolerance and action levels (the aquaculture grower, a state, tribal, territorial, local, or foreign authority, or a third-party organization may perform tests); AND Reports from all suppliers that show that agricultural and industrial practices in the area near the aquaculture production site are not reasonably likely to cause contamination of fish tissue above the established federal tolerance or action levels (the aquaculture producer, a state, tribal, territorial, local, or foreign authority, or a third-party organization may perform monitoring).

Visual check of test results and monitoring reports.

For results of water testing:
OR
All new suppliers;
For results of fish tissue testing:
Each delivery;
AND For reports of evaluation of agricultural and industrial practices:
At least once every year.


Reject the lot. AND

Discontinue use of the supplier until evidence is obtained that the supplier will comply with the testing and evaluation controls.

Test results of water or fish tissue for those environmental chemical contaminants and

Test results; AND Reports of evaluation of agricultural and industrial practices.
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TABLE 9-4
CONTROL STRATEGY EXAMPLE 3 - RECORDS OF TESTING AND MONITORING
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Records of Testing and Monitoring. This example illustrates how a farm-raised catfish processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.

(1)
(2)
Receiving
Visual check
At first delivery
Quality control staff
Test results
CHAPTER 9: Environmental Chemical Contaminants and Pesticides Reports of analyses of the water from all new suppliers that show that levels of environmental chemical contaminants and pesticides that are reasonably likely to be present are not so high that they are likely to result in levels in fish tissue that exceed the established federal tolerance or action levels* Reports from all suppliers that show that agricultural and industrial practices in the area near the production site are not reasonably likely to cause contamination of fish tissue above the established tolerance or action levels Reports of agricultural and industrial practices in the area near the production site Visual check Once per year Reports of analyses showing levels of environmental chemical contaminants and pesticides in water samples for those contaminants that are reasonably likely to be present* Quality control staff
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Reject the lot Discontinue use of the supplier until evidence is obtained that the supplier will comply with the testing and evaluation controls.
Reject the lot Discontinue use of the supplier until evidence is obtained that the supplier will comply with the testing and evaluation controls
Reports of agricultural and industrial practices

Review monitoring and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed. CONTROL STRATEGY EXAMPLE 4 - CHEMICAL
CONTAMINANT TESTING
the chemical contamination has been eliminated.

Test results.

Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists, or equivalent method, or by analyzing proficiency samples); AND Review monitoring, corrective action and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

No lot may exceed the federal tolerance or action levels for those environmental chemical contaminants and pesticides that are reasonably likely to be present (refer to Table 9-1).

Fish tissue for those environmental chemical contaminants and pesticides that are reasonably likely to be present.

Obtain samples and analyze for environmental chemical contaminants and pesticides.

Each lot received.

Any person who is qualified by training or experience to perform the analyses.

Take the following corrective action to product involved in a critical limit deviation:
Reject the lot. AND

Discontinue use of the supplier until evidence is obtained that the cause of
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TABLE 9-5
CONTROL STRATEGY EXAMPLE 4 - CHEMICAL CONTAMINANT TESTING
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Chemical Contaminant Testing. This example illustrates how an aquacultured shrimp processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.

(1)
(2)
CRITICAL CON TROL POINT
Receiving
Each lot received
CHAPTER 9: Environmental Chemical Contaminants and Pesticides No lot of shrimp may exceed the established tolerance or action levels for environmental chemical contaminants and pesticides that are reasonably likely to be present* Chemical residue levels in shrimp tissue that are reasonably likely to be present* Obtain samples and analyze for environmental chemical contaminants and pesticides* Receiving employee will submit sample to quality control staff Reject the lot Discontinue use of the supplier until evidence is obtained that the cause of the chemical contamination has been eliminated
Test results
Annual methods comparison to AOAC methods Review monitoring and corrective action records within 1 week of preparation
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CONTROL STRATEGY EXAMPLE 5 - QA

PROGRAM
AND

A certificate indicating that the producer operates under a third-party-audited QA program that covers environmental chemical contaminants and pesticides. The certificate may accompany each lot of incoming aquacultured fish or may be issued for each producer of incoming aquacultured fish as a continuing certification.

Third-party certificates; AND Records showing lots received and the presence or absence of a certificate.

Certificate indicating operation under a third party-audited QA program.

Review the third-party-audited QA program and results of audits annually; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Visual check for the presence of a certificate.

Each lot received is checked for the presence of a certificate. Certificates may be issued on continuing (not less often than annually) or lot-by-lot basis.


Reject the lot; OR Hold the lot until a certificate can be provided; OR Hold and analyze the lot for those environmental chemical contaminants and pesticides that are reasonably likely to be present.
171
TABLE 9-6
CONTROL STRATEGY EXAMPLE 5 - QA PROGRAM
This table is an example of a portion of a HACCP plan using Control Strategy Example 5 - QA Program. This example illustrates how an aquacultured trout processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purpose only.

(1)
(2)
Receiving
Presence of a third-party certificate
Visual check for the presence of a certificate
Each lot
Receiving dock employee
Reject the lot
Certificate Receiving record
CHAPTER 9: Environmental Chemical Contaminants and Pesticides Certificate indicating that the producer operates under a third-party audited QA program that covers environmental chemical contaminants and pesticides Discontinue use of the supplier until evidence is obtained that the supplier will comply with the certification controls
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Review the third-partyaudited QA program and results of audits annually Review monitoring, corrective action, and verification records within 1 week of preparation

CONTROL FOR WILD CAUGHT FISH OTHER THAN MOLLUSCAN SHELLFISH


No fish may be harvested from an area that is closed to commercial harvesting by state, tribal, territorial, local, or foreign authorities because of concentrations of environmental chemical contaminants or pesticides exceeding the federal tolerance or action levels; AND No fish may be harvested from an area that is under a consumption advisory by a, state, tribal, territorial, local, or foreign regulatory authority based on a determination by the authority that fish harvested from the waters are reasonably likely to contain contaminants above the federal tolerance or action levels. Note that many consumption advisories are not based on such a determination.
Reject the lot; OR For fish harvested from an area under a consumption advisory based on federal tolerance or action levels:
Sample the lot and analyze it for the appropriate environmental chemical contaminant or pesticide. Reject the lot if the results exceed the federal tolerance or action level.
AND

Location of harvest and whether the harvest area is subject to closure or consumption advisory.

Receiving records that document the location and whether the harvest area is subject to closure or consumption advisory.

Ask the harvester for the harvest site at time of receipt, or obtain the information from the harvesters catch record, where applicable; AND Ask the state, tribal, territorial, local, or foreign authorities in which your fish are harvested whether there are closures or consumption advisories that apply to the areas from which your fish are harvested.


Every lot received.

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TABLE 9-7
CONTROL STRATEGY EXAMPLE 6 - SOURCE CONTROL FOR WILD CAUGHT FISH OTHER THAN MOLLUSCAN SHELLFISH
This table is an example of a portion of a HACCP plan using Control Strategy Example 6 - Source Control for Wild Caught Fish Other Than Molluscan Shellfish. This example illustrates how a wild caught bluefish processor can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.
Environmental contaminants and pesticides from the harvest area may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., scombrotoxin (histamine), metal fragments).

(1)
(2)
Receiving
CHAPTER 9: Environmental Chemical Contaminants and Pesticides Each lot received No fish may be harvested from an area that is closed to commercial harvesting by state, or local authorities because of concentrations of environmental chemical contaminants or pesticides exceeding the federal tolerance or action levels No fish may be commercially harvested from an area that is under a consumption advisory by a state, local, or local regulatory authority based on a determination by the authority that fish harvested from the waters are reasonably likely to contain contaminants above the federal tolerance or action levels Location of harvest and whether the harvest area is subject to closure or consumption advisory Ask the harvester for the harvest location, and ask state and local authorities the status of the area Receiving dock employee
Reject the lot Discontinue use of the supplier until evidence is obtained that harvesting practices have changed
Receiving record
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CONTROL FOR MOLLUSCAN SHELLFISH

All containers of shellstock (in-shell molluscan shellfish) received from a harvester must bear a tag that discloses the date and place they were harvested (by state and site), the type and quantity of shellfish, and the harvesters or harvesters vessel information (i.e., the identification number assigned to the harvester by the shellfish control authority, where applicable, or if such identification numbers are not assigned, the name of the harvester or the name or registration number of the harvesters vessel). For bulk shipments of shellstock, where the shellstock is not containerized, the shellstock must be accompanied by a bill of lading or other similar shipping document that contains the same information;
All molluscan shellfish must be from a harvester that is licensed as required (note that licensing may not be required in all jurisdictions) or from a processor that is certified by a shellfish control authority.
Note: Only the primary processor (the processor that receives molluscan shellfish directly from the harvester) needs to apply controls relative to the identification of the harvester, the harvesters license, or the approval status of the harvest waters.

The information contained on tags on containers of incoming shellstock or on the bill of lading or other similar shipping document accompanying bulk shipments of shellstock and whether the harvest area is authorized for harvest by a shellfish control authority; AND The license of the harvester; OR The information contained on labels on containers of incoming shucked molluscan shellfish.
OR All containers of shellstock received from a processor must bear a tag that discloses the date and place they were harvested (by state and site), the type and quantity of shellfish, and the certification number of the processor; OR All containers of shucked molluscan shellfish must bear a label that identifies the name, address, and certification number of the packer or repacker of the product; AND All molluscan shellfish must have been harvested from waters authorized for harvesting by a shellfish control authority. For U.S. federal waters, no molluscan shellfish may be harvested from waters that are closed to harvesting by an agency of the federal government; AND

Perform visual checks; AND Ask the relevant shellfish control authority whether the harvest area is authorized for harvest.

For checking tags:

OR
Every container;
AND For checking harvester licenses: Every delivery;
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For checking labels:
At least three containers randomly selected from throughout every lot.

Date of receipt; AND Quantity and type of shellfish; AND Name and certification number of the packer or repacker.


Reject the lot. AND

Discontinue use of the supplier until evidence is obtained that harvesting and/or tagging practices have changed.

For shellstock:

AND
AND Name of the harvester, name or registration number of the harvesters vessel, or an identification number issued to the harvester by the shellfish control authority (for shellstock received directly from the harvester only); AND Number and date of expiration of the harvesters license, where applicable;
AND
Certification number of the shipper,
where applicable.
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TABLE 9-8
CONTROL STRATEGY EXAMPLE 7 - SOURCE CONTROL FOR MOLLUSCAN SHELLFISH
This table is an example of a portion of a HACCP plan using Control Strategy Example 7 - Source Control for Molluscan Shellfish. The example illustrates how a processor of shellstock oysters received directly from a harvester can control environmental chemical contaminants and pesticides. It is provided for illustrative purposes only.
Environmental contaminants and pesticides from the harvest area may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., natural toxins and pathogens from the harvest area).

(1)
(2)
Receiving
Visual checks
Every sack
Receiving employee
Reject untagged sacks Discontinue use of the supplier until evidence is obtained that tagging practices have changed
Receiving record
CHAPTER 9: Environmental Chemical Contaminants and Pesticides All shellstock must be tagged with the date and place of harvest, type and quantity of shellfish, and name or registration number of the harvesters vessel All shellstock must be from waters approved by the state shellfish control authority Harvest site on tags Perform visual checks and ask the shellfish control authority whether the area is authorized for harvest Perform visual checks Every lot All shellstock must be from licensed harvesters License of harvester Every delivery
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Review monitoring and corrective action records within 1 week of preparation Reject lots from unapproved waters Discontinue use of the supplier until evidence is obtained that harvesting practices have changed Reject lots from unlicensed harvesters Discontinue use of the supplier until evidence is obtained that the harvester is properly licensed
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Catfish Farmers of America. 1993. Catfish quality assurance. Cooperative Extension Service Publication 1873. Mississippi State University, Mississippi State, MS. Federal Joint Subcommittee on Aquaculture. 2007. Guide to drug, vaccine, and pesticide use in aquaculture. http://aquanic.org/jsa/ wgqaap/drugguide/drugguide.htm. Gutenmann, W. H., J. G. Ebel, Jr., H. T. Kuntz, K. S. Yourstone, and D. J. Lisk. 1992. Residues of p,p-DDE and mercury in lake trout as a function of age. Arch. Environ. Contam. Toxicol. 22(4):452-455. Karl, H., I. Lehmann, and K. Oetjen. 1998. Levels of chlordane compounds in fish muscle, -meal, -oil and -feed. Chemosphere. 36(13):2819-2832. Ruus, A., K. I. Ugland, and J. U. Skaare. 2002. Influence of trophic position on organochlorine concentrations and compositional patterns in a marine food web. Environ. Toxicol. Chem. 21(11):2356-2364. Smith, A. G., and S. D. Grangolli. 2002. Organochlorine chemicals in seafood: occurrence and health concerns. Food Chem. Toxicol. 40:767-779. Striped Bass Growers Association. 1996. The hybrid striped bass industry from fish farmer to consumer. Striped Bass Growers Association, P.O. Box 11280, Columbia, SC.
U.S. Environmental Protection Agency. 1992. Water quality standards Establishment of numeric criteria for priority toxic pollutants; states compliance, p. 60848-60923. In Federal Register, vol. 57, no. 246. U.S. Government Printing Office, Washington, DC. U.S. Environmental Protection Agency. 1994. Appendix I: list of EPA water quality criteria documents. In Water quality standards handbook: second edition. http://www.epa. gov/waterscience/standards/handbook/. U.S. Environmental Protection Agency. 1995. Final water quality guidance for the Great Lakes System. In Federal Register, vol. 60, no. 56. U.S. Government Printing Office, Washington, DC. U.S. Environmental Protection Agency. Updated February 2011. Residue Analytical Methods (RAM). http://www.epa.gov/ pesticides/methods/ramindex.htm. U.S. Environmental Protection Agency. Revised July 2006. Tolerances and exemptions from tolerances for pesticide chemicals in or on raw agricultural products. In Code of Federal Regulations, 40 CFR 180. U.S. Government Printing Office, Washington, DC. http://www.access.gpo.gov/nara/cfr/ waisidx_05/40cfr180_05.html. U.S. Food and Drug Administration. Updated July 2009. Pesticide Analytical Manual (PAM). http://www.fda.gov/Food/ ScienceResearch/LaboratoryMethods/ PesticideAnalysisManualPAM/default.htm. U.S. Food and Drug Administration. Updated January 2008. Pesticide chemical residues in food - enforcement criteria. In Compliance policy guides, sect. 575.100. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, Washington, DC. http://www.fda. gov/downloads/ICECI/ComplianceManuals/ CompliancePolicyGuidanceManual/ UCM186872.pdf.
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U.S. Food and Drug Administration. Revised April 2009. Fish and fishery products. In Code of Federal Regulations, 21 CFR 123.3. U.S. Government Printing Office, Washington, DC. http://www.access.gpo.gov/ nara/cfr/waisidx_06/21cfr123_06.html. U.S. Food and Drug Administration. Revised April 2009. Unavoidable contaminants in food for human consumption and food-packaging material. In Code of Federal Regulations, 21 CFR 109. U.S. Government Printing Office, Washington, DC. http://www.access.gpo.gov/nara/cfr/ waisidx_06/21cfr109_06.html. U.S. Trout Farmers Association. 1994. Trout producers quality assurance program. USTFA, P.O. Box 220, Charles Town, WV.
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NOTES:
180
CHAPTER 10: Methylmercury

As with previous editions of the Fish and Fishery Products Hazards and Controls Guidance, this fourth edition does not contain advice on Hazard Analysis Critical Control Point (HACCP) controls for methylmercury, except where federal, state, local, or foreign authorities close certain waters to commercial harvesting as described in Chapter 9.
181
NOTES:
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CHAPTER 11: Aquaculture Drugs


Use of unapproved drugs or misuse of approved drugs in aquacultured fish poses a potential human health hazard. These substances may be toxic, allergenic, or carcinogenic, and/or may cause antibiotic resistance in pathogens that affect humans. To control this hazard, drugs for use in food animals, whether they are for direct medication or for addition to feed, generally must be approved, conditionally approved or index listed by FDA (Federal Food, Drug, and Cosmetic Act Section 512). Under certain conditions authorized by FDA, unapproved new animal drugs may be used in conformance with the terms of an Investigational New Animal Drug (INAD) application (21 CFR 511 and FDAs Center for Veterinary Medicine (CVM) Guide 1240.3025). Off label use in animals of approved human or animal drugs is permissible in certain circumstances. Drugs on the Index of Legally Marketed Unapproved New Animal Drugs for Minor Species (the Index) may not be used in food animals except in early nonfood life stages of food producing minor species in certain circumstances. Reasons for the use of drugs in aquaculture include the need to (1) treat and prevent disease, (2) control parasites, (3) affect reproduction and growth, and (4) provide tranquilization (e.g., for weighing). Relatively few drugs have been approved for aquaculture. This factor may lead to the inappropriate use of unapproved drugs,
general-purpose chemicals, or approved drugs in a manner that deviates from the labeled instructions. When a drug is approved by CVM, the conditions of the approval are listed on its label or in the labeling (21 CFR 514.1). These conditions specify the species for which the drug is approved for use; indications (disease or other circumstances) for use; dosage regimen; and other limitations, such as route of administration and withdrawal time. Labeled withdrawal times must be followed to ensure that no harmful drug residues are present in the edible tissue of the animal when harvested for human consumption and offered for sale. Tolerances for some drug residues in the edible tissue have been established (21 CFR 556). Only a licensed veterinarian may legally prescribe a drug under conditions that are not listed on the label (extra-label use). This includes: use in species not listed on the label; use for indications (disease or other conditions) not listed on the label; use at dosage levels, frequencies, or routes of administration other than those stated on the label; and deviation from the labeled withdrawal time. A veterinarian is a person licensed by a state, territory, or foreign government to practice veterinary medicine. The extra-label use restrictions are fully explained in 21 CFR 530. Information on the new animal drug approval process and for other information on the laws, regulations and policies pertaining to drugs can be found on FDAs internet website, http://www.fda.gov/ AnimalVeterinary/DevelopmentApprovalProcess/ Aquaculture/default.htm.
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Approved aquaculture drugs FDA-approved aquaculture drugs, with their approved sponsor, species for which they have been approved and required withdrawal times are listed below. Additional details on conditions of use (e.g., dosage levels) can be obtained from the Code of Federal Regulations (CFR) as cited below; the labeling for the drug; the FDA CVM Website, (http://www.fda.gov/AnimalVeterinary/ DevelopmentApprovalProcess/Aquaculture/ ucm132954.htm). FDAs determination that these substances are approved aquaculture drugs does not exempt facilities from complying with other federal, state, tribal, territorial and local environmental requirements. For example, in the United States, facilities using these substances would still be required to comply with the National Pollutant Discharge Elimination System requirements. Chorionic gonadotropin Chorulon Chorulon, supplied by Intervet, Inc., Roseland, NJ, is approved for use as an aid in improving spawning function in male and female brood finfish. The drug may be administered for up to three doses. The total dose should not exceed 25,000 I.U. chorionic gonadotropin in fish intended for human consumption. Federal law restricts this drug to use by or on the order of a licensed veterinarian (21 CFR 522.1081). Because residues are expected to be well below the safe concentration in the edible portion of fish, there is no tolerance level set for residues of gonadotropin in fish tissue 21 CFR 556.304). Formalin solution Paracide-F Paracide-F, supplied by Argent Laboratories, Redmond, WA, is approved for use as follows: in salmon, trout, catfish, largemouth bass, and bluegill for the control of external protozoa (Ichthyophthirius spp., Chilodonella
spp., Costia spp., Scyphidia spp., Epistylis spp., and Trichodina spp.) and monogenetic trematodes (Cleidodiscus spp., Gyrodactylus spp., and Dactylogyrus spp.); and on the eggs of salmon, trout, and esocids for the control of fungi of the family Saprolegniaceae (21 CFR 529.1030). There is no mandatory withdrawal time prior to harvest and no residue tolerance (formalin does not bioaccumulate in animals). This drug is approved as an over-the-counter (OTC) product, and a prescription is not required. Parasite-S , Formacide-B and Formalin-F Parasite-S is supplied by Western Chemical, Inc., Ferndale, WA. Formacide-B is supplied by B.L. Mitchell, Inc., Leland, MS. Formalin-F is supplied by Natchez Animal Supply Company, Natchez, MS. Each is approved for use to control external protozoan parasites (Chilodonella spp., Costia spp., Epistylis spp., Ichthyophthirius spp., Scyphidia spp., and Trichodina spp.) and monogenetic trematodes (Cleidodiscus spp., Dactylogyrus spp., and Gyrodactylus spp.) on all finfish species; external protozoan parasites (Bodo spp., Epistylis spp., and Zoothamnium spp.) on Penaeid shrimp; and fungi of the family Saprolegniaceae on the eggs of all finfish species (21 CFR 529.1030). There is no mandatory withdrawal time prior to food animal harvest and no residue tolerance (formalin does not bioaccumulate in animals). These drugs are approved as OTC products, and a prescription is not required. Florfenicol Aquaflor Type A Medicated Article Aquaflor Type A is supplied by Intervet, Inc., Millsboro DE/ Schering-Plough Animal Health Corporation, Roseland, NJ, and is approved for use in medicated feed for the control of mortality due to enteric septicemia of channel catfish (Ictalurus punctatus) associated with Edwardsiella ictaluri, control
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of mortality in freshwater-reared salmonids due to coldwater disease associated with Flavobacterium psychrophilum, and control of mortality in freshwater-reared salmonids due to furunculosis associated with Aeromonas salmonicida. The minimum withdrawal time before harvest is 12 days for catfish and 15 days for salmonids (21 CFR 558.261). The tolerance level for florfenicol amine (the marker residue) in muscle is 1 ppm (21 CFR 556.283). The product is restricted to use by or on the order of a licensed veterinarian (21 CFR 558.261). Extra-label use of medicated feed containing florfenicol is prohibited (21 CFR 558.6(a)(4) and (6)). Aquaflor CA1 Aquaflor CA1 is supplied by Intervet, Inc./ Schering-Plough Animal Health Corporation, Roseland, NJ, and is approved for use in medicated feed for the control of mortality in catfish due to columnaris disease associated with Flavobacterium columnare. The drug can be used at any stage of production, from fingerling to food fish, as the sole ration for 10 consecutive days. The minimum withdrawal time before harvest is 12 days. The product is restricted to use by or on the order of a licensed veterinarian (21 CFR 516.1215) . Extra-label use of medicated feed containing florfenicol is prohibited (21 CFR 558.6(a)(4) and (6)). Because Aquaflor CAI is a conditionally approved new animal drug, it extra-label use is also prohibited by 21 U.S.C. 360ccc(a)(1). Tricaine methanesulfonate (MS-222) Finquel and Tricaine-S Finquel is supplied by Argent Laboratories, Redmond, WA, and Tricaine-S is supplied by Western Chemical, Inc., Ferndale, WA, Tricaine-S. This drug is approved for use to temporary immobilization of fish, amphibians, and other aquatic cold-blooded animals. Tricaine methanesulfonate has
been recognized as a valuable tool for the proper handling of these animals during manual spawning (fish stripping), weighing, measuring, marking, surgical operations, and transport. Use in fish intended for human consumption is restricted to the following families: Ictaluridae (catfish), Salmonidae (salmon and trout), Esocidae (pike), and Percidae (perch). There is a mandatory 21 day withdrawal time before harvest. In other non-food, aquatic, cold-blooded animals, the drug should be limited to hatchery or laboratory use (21 CFR 529.2503). These drugs are approved as OTC products, and a prescription is not required. There is no tolerance level set for residues in fish tissue. Oxytetracycline Terramycin 200 for Fish (oxytetracycline dihydrate) Type A Medicated Article Terramycin 200 for Fish (oxytetracycline dihydrate) Type A Medicated Article is supplied by Phibro Animal Health, Ridgefield Park, NJ. Terramycin 200 for Fish is approved for use to treat bacterial hemorrhagic septicemia caused by Aeromonas liquefaciens and pseudomonas disease in catfish. For salmonids, Terramycin 200 for Fish is approved for use to control ulcer disease caused by Hemophilius piscium, furunculosis caused by Aeromonas salmonicida, bacterial hemorrhagic septicemia caused by Aeromonas liquefaciens, pseudomonas disease and for control of mortality due to coldwater disease associated with Flavobacterium psychrophilium. This drug is also approved for use to mark skeletal tissue. For lobster, Terramycin 200 for Fish is approved for use to control gaffkemia caused by Aerococcus viridians. Withdrawal times vary with indication as follows: for marking skeletal tissue in Pacific salmon, 7 days; for disease control in salmonids, 21 days; catfish, 21 days; lobster, 30 days (21 CFR 558.450).
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OxyMarine, Oxytetracycline
HCl Soluble Powder-343,
Terramycin-343, TETROXY Aquatic
OxyMarine is supplied by Alpharma, Inc., Fort Lee, NJ. Oxytetracycline HCl Soluble Powder-343 is supplied by Teva Animal Health, Inc., St. Joseph, MO. Terramycin-343 is supplied by Aquatic Health Resources. TETROXY Aquatic is supplied by Cross Vetpharm Group Ltd., Dublin, Ireland. Each of these drugs is administered by immersion, approved for use to mark skeletal tissue of all finfish fry and fingerlings as an aid in identification. These drugs are approved as OTC products, and a prescription is not required. A tolerance level of 2 ppm in muscle tissue (as the sum of tetracycline residues, including oxytetracycline, chlortetracycline, and tetracycline) has been established for all finfish and lobster (21 CFR 556.500). Hydrogen peroxide 35% PEROX-AID 35% PEROX-AID, supplied by Eka Chemicals, Inc., Marietta, GA, is approved for the control mortality in freshwater-reared finfish eggs due to saprolegniasis; freshwaterreared salmonids due to bacterial gill disease; and freshwater-reared coolwater finfish and channel catfish due to external columnaris disease. This drug is approved as an OTC product, and a prescription is not required. There are no limitations on acceptable daily intake; there is no required withdrawal time; and no tolerance has been set for residues in fish tissue. However, as with all new animal drugs, a licensed veterinarian is required to prescribe an extra-label use of 35% PEROX AID to treat diseases or species not listed on the product label (21 CFR 529.1150).
Sulfamerazine Sulfamerazine, supplied by Alpharma, Inc., Bridgewater, NJ, is approved for use only in trout (rainbow, brook, and brown) to control furunculosis. It may be used for treatment not more than 14 days. The withdrawal time is 21 days before harvest for marketing or stocking in stream open to fishing (21 CFR 558.582). A tolerance of zero is established for residues of sulfamerazine in the edible flesh (21 CFR 556.660). Sulfadimethoxine/ormetoprim combination Romet-30 Romet-30, supplied by Pharmaq AS, Overhalla, Norway, is approved for use only in medicated feed only for control of enteric septicemia of catfish caused by Edwardsiella ictaluri and furunculosis in salmonids (trout and salmon) caused by Aeromonas salmonicida. Required withdrawal times are as follows: salmonids, 42 days; catfish, 3 days (21 CFR 558.575). The withdrawal time for catfish is shorter because any residues that might be present in the skin are removed during processing. The tolerance for Sulfadimethoxine and ormetoprim in the flesh is 0.1 ppm for each drug (21 CFR 556.490 and 556.640). FDA low regulatory priority aquaculture
drugs
CVM has identified a number of unapproved aquaculture drugs that are of low regulatory priority when used in food fish. The following list identifies these compounds and provides their indicated use and usage levels (CVMs Policy and Procedures Manual Attachment: Enforcement Priorities for Drug use in Aquaculture (Guide 1240.4200) (http:// www.fda.gov/downloads/AnimalVeterinary/ GuidanceComplianceEnforcement/ PoliciesProceduresManual/UCM046931.pdf).
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The agency does not intend to take enforcement action against low regulatory priority substances if the following conditions are met: (1) the substances are used for the stated indications; (2) the substances are used at the stated levels; (3) the substances are used according to good management practices; (4) the product is of an appropriate grade for use in food animals; and (5) use of these products is not likely to result in an adverse effect on the environment. The agencys enforcement position on the use of these substances should not be considered an approval, or an affirmation of their safety and effectiveness. The agency reserves the right to take a different position on the use of any or all of these substances at some time in the future. FDAs determination that these substances are new animal drugs of low regulatory priority does not exempt facilities from complying with other federal, state, tribal, territorial and local environmental requirements. For example, in the United States, facilities using these substances would still be required to comply with the National Pollutant Discharge Elimination System requirements. Acetic acid Used in a 1,000 to 2,000 ppm dip for 1 to 10 minutes as a parasitide for fish. Calcium chloride Used to increase water calcium concentration to ensure proper egg hardening. Dosages used would be those necessary to raise calcium concentration to 10 to 20 ppm CaCO3. Used up to 150 ppm indefinitely to increase the hardness of water for holding and transporting fish in order to enable fish to maintain osmotic balance.
Calcium oxide Used as an external protozoacide for fingerlings to adult fish at a concentration of 2,000 mg/L for 5 seconds. Carbon dioxide gas Used for anesthetic purposes in fish. Fullers earth Used to reduce the adhesiveness of fish eggs to improve hatchability. Garlic (whole form) Used for control of helminth and sea lice infestations in marine salmonids at all life stages. Ice Used to reduce metabolic rate of fish during transport. Magnesium sulfate Used to treat external monogenic trematode infestations and external crustacean infestations in freshwater fish species at all life stages. Fish are immersed in a 30,000 mg MgSO4/L and 7,000 mg NaCl/L solution for 5 to 10 minutes. Onion (whole form) Used to treat external crustacean parasites and to deter sea lice from infesting the external surface of salmonids at all life stages. Papain Used in a 0.2% solution to remove the gelatinous matrix of fish egg masses in order to improve hatchability and decrease the incidence of disease.
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Potassium chloride Used as an aid in osmoregulation; relieves stress and prevents shock. Dosages used would be those necessary to increase chloride ion concentration to 10 to 2,000 mg/L. Povidone iodine Used in a 100 ppm solution for 10 minutes as an egg surface disinfectant during and after water hardening. Sodium bicarbonate Used at 142 to 642 ppm for 5 minutes as a means of introducing carbon dioxide into the water to anesthetize fish. Sodium chloride Used in a 0.5% to 1% solution for an indefinite period as an osmoregulatory aid for the relief of stress and prevention of shock; and in a 3% solution for 10 to 30 minutes as a parasitide. Sodium sulfite Used in a 15% solution for 5 to 8 minutes to treat eggs in order to improve their hatchability. Thiamine hydrochloride Used to prevent or treat thiamine deficiency in salmonids. Eggs are immersed in an aqueous solution of up to 100 ppm for up to 4 hours during water hardening. Sac fry are immersed in an aqueous solution of up to 1,000 ppm for up to 1 hour. Urea and tannic acid Used to denature the adhesive component of fish eggs at concentrations of 15g urea and 20g NaCl/5 liters of water for approximately 6 minutes, followed by a separate solution of 0.75 g tannic acid/5 liters of water for an additional 6 minutes. These amounts will treat approximately 400,000 eggs.
FDA high enforcement priority aquaculture

drugs
CVM has identified a number of drugs and families of drugs historically used in fish without FDA approval that are of high enforcement priority. They should not be used in fish that is to be consumed, unless a sponsor obtains an approval or index listing for them. The following list identifies these compounds (CVM Program Policy and Procedures Manual Attachment: Enforcement Priorities for Drug Use in Aquaculture (Guide 1240.4200) (http:// www.fda.gov/downloads/AnimalVeterinary/ GuidanceComplianceEnforcement/ PoliciesProceduresManual/UCM046931.pdf ): Chloramphenicol; Nitrofurans; Fluoroquinolones and Quinolones; Malachite Green; Steroid Hormones. Drugs prohibited for extra-label use The following drugs and families of drugs are prohibited for extra-label use in food-producing animals (21 CFR 530.41(a)): Chloramphenicol; Clenbuterol; Diethylstilbestrol (DES); Dimetridazole, Ipronidazole, and other Nitroimidazoles; Furazolidone, and Nitrofurazone; Fluoroquinolones; Glycopeptides. None of these drugs and families of drugs has been approved use in fish. Additional information on aquaculture-related topics can be obtained from FDA/CVM at: http://www.fda.gov/ cvm/aqualibtoc.htm.
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The following guidance will assist you in determining whether aquaculture drugs are a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of aquaculture drugs will be introduced at this processing step?
measure is or can be used to eliminate the hazard or to reduce the likelihood of its occurrence to an acceptable level. Preventive measures for the hazard of aquaculture drugs used in aquaculture operations and during live transportation can include: Conducting on-farm visits to review drug usage (other than INADs) before receipt of the product, coupled with a suppliers certificate that any INADs used were used in conformance with the application requirements and appropriate verification; Reviewing, at time of receipt, drug usage records (other than INADs), coupled with a suppliers certificate that any INADs used were used in conformance with the application requirements and appropriate verification; Reviewing, at time of receipt, the
producers lot-by-lot certification
of proper drug usage, including
INAD usage, coupled with
appropriate verification;
Conducting, at time of receipt,
drug residue testing;
Reviewing, at time of receipt, evidence (e.g., a third-party certificate) that the producer operates under a third party-audited Quality Assurance (QA) program for aquaculture drug use.
Note: INAD records are confidential unless an exception is made by the sponsor of the drug research. Thus, review of INAD drug usage records by the processor may not be practical in certain situations. Written certification, on a lot-by-lot basis, from the producer to the processor stating that INAD usage is in accordance with authorizations from FDA/CVM is a suitable alternative.
Under ordinary circumstances, if you are a primary (first) processor, it would be reasonably likely that unsafe levels of aquaculture drugs could enter the process at the receiving step of any type of aquacultured fish, including: Finfish; Crustaceans; Other aquatic food animals,
such as alligator.
Under ordinary circumstances it would also be reasonably likely that unsafe levels of aquaculture drugs could enter the process during aquatic holding (e.g., live lobster in pounds) or transport of live fish. Under ordinary circumstances, it would not be reasonably likely to expect that aquaculture drugs could enter the process during the receiving of wild-caught fish. Currently, FDA is not aware of drug use in the grow-out of molluscan shellfish. If you are receiving fish (other than live fish) from another processor, you would not need to identify aquaculture drugs as a significant hazard. The primary (first) processor should have fully controlled this hazard.
2. Can unsafe levels of aquaculture drugs that are reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
These preventive measures are ordinarily employed at either the receiving step or the pre-harvest step. Preventive measures for the control of aquaculture drugs used during aquatic holding (e.g. lobster pounds) can include
Aquaculture drugs should be considered a significant hazard at any processing step at a primary processor where a preventive
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controlled application of animal drugs in a manner consistent with: Established withdrawal times; Labeled instructions for use; Conditions for extra-label use of FDAapproved drugs, under a veterinarians supervision and in accordance with FDA regulations and guidelines; Conditions specified in the FDA list of low regulatory priority aquaculture drugs; Conditions of an INAD application. These preventive measures are ordinarily applied at the holding step. In the case of an integrated operation, where fish processing and farming, and perhaps feed manufacture, are performed by the same firm, it may be possible and desirable to exercise preventive measures early in the process (ideally, at feed manufacture), rather than at receipt of the fish at the processing plant. Such preventive measures will not be covered in this guidance document. Intended use For aquaculture drugs, it is unlikely that the intended use of the product will affect the significance of the hazard.
a. If you have such a relationship with the
grower, then you should identify a preharvest step as the CCP for aquaculture drugs. The preventive measure for this type of control is: Conducting on-farm visits to review drug usage, coupled with a suppliers certificate that any INAD used is used in accordance with food use authorization and appropriate verification. Example: A primary processor of aquacultured catfish that regularly purchases from the same grower should visit the grower before the fish are harvested and review drug usage practices and records. The processor should also receive a guarantee that any INAD used is used in conformance with the food use authorization requirements. The processor should combine this monitoring procedure with quarterly raw material testing for verification and should set the CCP at the preharvest step. This control approach is a control strategy referred to in this document as Control Strategy Example 1 - OnFarm Visits.
b. If you have no such relationship with

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for the hazard of aquaculture drugs.
Is the hazard the result of the use of aquaculture drugs during the raising of fish (i.e., aquaculture) or during aquatic holding (e.g., lobster pounds) or transport of live fish? 1. If the hazard is the result of aquaculture, do you have a relationship with the grower that enables you to visit the farm before receipt of the fish?
the grower, then you should identify the receiving step as the CCP for aquaculture drugs. At the receiving step, you should exercise one of the following preventive measures: Reviewing, at time of receipt, the producers lot-by-lot certification of proper drug usage, coupled with appropriate verification. Example: A primary processor of aquacultured shrimp that purchases raw material
190
shrimp through various brokers should receive lot-by-lot certificates from the producers. The certificates should state that all drugs were used in conformance with applicable FDA regulations and labeled instructions. The processor should combine this monitoring procedure with quarterly raw material testing for verification and should set the CCP at receiving. This control approach is a control strategy referred to in this document as Control Strategy Example 2 Suppliers Certification. Reviewing, at time of receipt, drug usage records (other than INADs), coupled with a suppliers lot-by lot certificate that any INAD used was used in conformance with the use authorization requirements and appropriate verification. Example: A primary processor of aquacultured shrimp that purchases raw material shrimp through various brokers should receive records of drug usage (other than INADs) from the producers when the product is delivered. Additionally, the processor should receive a lot-by-lot certificate stating that any INAD used was used in conformance with the food use authorization requirements. The processor should combine this monitoring procedure with quarterly raw material testing for verification and should set the CCP at receiving. This control approach is a control strategy referred to in this document as Control Strategy Example 3 Records of Drug Use. Conducting, at time of receipt, drug screening on all lots for the presence of approved or unapproved drugs.
This screening can be performed by rapid analytical methods that may indicate the presence of a family of drugs, rather than any specific drug. If the rapid screening test indicates that a family of drugs is present, further testing and/or follow-up with the supplier could be necessary.
Note: A limited number of drug screening tests for aquaculture drugs are available. Tests are not available to assay for all drugs that might be used in all aquacultured species. Processors should be cautioned that tests that have not been validated may be unreliable. These tests may fail to detect a residue or may give a false positive. Processors should ensure that the tests that they intend to use have been validated and are appropriate for the species and tissue to be tested.
Example: A primary processor of aquacultured shrimp that purchases raw material shrimp through various brokers should screen all incoming lots of shrimp with a series of validated rapid tests that target the families of drugs that are reasonably likely to be used during grow-out (e.g., chloramphenicol, nitrofurans, and fluoroquinolones). The processor should set the CCP at receiving. This control approach is a control strategy referred to in this document as Control Strategy Example 4 Drug Residue Testing. Reviewing, at time of receipt, evidence (e.g., continuing or lot by-lot third- party certificate) that the producer operates under a third-party-audited QA program that covers aquaculture drug use. Example: A primary processor of aquacultured trout that regularly purchases raw material trout from the same grower should obtain a third-party certificate, valid for 1 year (i.e., continuing certification), that attests
191
that the grower operates under a QA program that covers aquaculture drug use. The processor should set the CCP at receiving. This control approach is a control strategy referred to in this document as Control Strategy Example 5 Quality Assurance Program.
2. If the hazard is the result of aquatic holding (e.g., lobster pounds), then you should identify the holding step as the CCP for aquaculture drugs. The preventive measure for this type of control is:
3. If the hazard is the result of transportation of live fish, then you should identify the receiving step as the CCP for aquaculture drugs. In this case, you should refer to described in Control Strategy Examples 2 through 5 for guidance. However, if live transportation is on your own truck, you should identify the transportation step as the CCP, and refer to Control Strategy Example 6 for guidance.
Applying animal drugs in a manner consistent with:
Established withdrawal times; Labeled instructions for use; Conditions for extra-label use of FDA-approved drugs under a veterinarians supervision and in accordance with FDA regulations and guidances; Conditions specified in the FDA low regulatory priority aquaculture drug
list;
Conditions of an INAD food use
authorization.
Example: A primary processor that receives live basa from a broker on the brokers truck should receive lot by-lot certificates from the broker. The certificates should state that all drugs were used in conformance with applicable regulations and
labeled instructions. The processor should combine this monitoring procedure with quarterly raw material testing for verification and should set the CCP at receiving.
Example: A primary processor that receives live catfish from the growers on the processors own truck and uses drugs to control animal health during transportation (e.g., carbon dioxide as an anesthetizing agent at levels appropriate for the purpose) should control drug use during transportation and should set the CCP at transportation.
Example: A primary processor that uses oxytetracycline in the holding of live lobster in a lobster pound should use the drug as a medicated feed in accordance with labeled instructions and should document the withdrawal time of 30 days before selling. The processor should set the CCP at holding. This control approach is a control strategy referred to in this document as Control Strategy Example 6 Control During Holding.
192

The following guidance provides six control strategies for aquaculture drugs. You may select a control strategy that is different from those which are suggested provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
AND Verified by a certificate from the producer indicating that any investigational new drug used is subject to an investigational new animal drug exemption under 21 CFR Part 511, that fish intended for human consumption is subject to a food use authorization, and that the INAD is used in the fish according to the food use authorization requirements.

On-farm drug usage procedures; AND Certificate indicating proper INAD usage.
On-farm visit Suppliers certification Records of drug use Drug residue testing Quality assurance program Control during holding

Survey farm husbandry procedures, ask questions, and review drug usage records; AND Visual check for presence of INAD certificate of proper use.

Aquaculture drugs are used on food-producing fish only if they have been: Approved by FDA or granted a conditional approval by FDA and used in accordance with all labeled conditions; OR Approved by FDA and used in an extra-label manner under a veterinarians supervision in accordance with FDA regulations; OR Put on the FDA list of low regulatory priority aquaculture drugs and used according to the provisions in the list; OR Used in food fish as an INAD subjected to an investigational new animal drug exemption under 21 CFR Part 511 and used according to the requirements of the food use authorization;

At least once per year for each aquaculture site.


Do not have the product shipped from the production site for processing. AND
Discontinue use of the supplier until evidence is obtained that drug treatment
193
practices have changed.

On-site audit report; AND INAD certificate of proper use.

Collect a representative sample of the raw material, in-process product, or finished product at least quarterly, and analyze for those drug residues that are reasonably likely to be present; AND Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent method, or by analyzing proficiency samples); AND Review monitoring, verification, and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
194
TABLE 11-1
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example 1 - On-Farm Visits. This example illustrates how a primary processor of farm-raised catfish can control aquaculture drugs. It is provided for illustrative purposes only.
Aquaculture drugs may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides).

(1)
(2)
Preharvest
Aquaculture drugs
CHAPTER 11: Aquaculture Drugs On-farm drug usage procedures Field agent Aquaculture drugs are used on fish only if the drugs have been approved by FDA or granted conditional approval by FDA and used in accordance with all labeled conditions; approved by FDA and used in an extra-label manner under a veterinarians supervision in accordance with FDA regulations; put on the list of low regulatory priority aquaculture drugs and used in accordance with the provisions in the list; or use in food fish as an INAD subject to an investigational new animal drug exemption under 21 CFR Part 511 and used in accordance with the requirements of the food use authorization Certificate from the producer indicating that any investigational new drug used in fish intended for human consumption is subject to an investigational new animal drug exemption under 21 CFR Part 511 and that the INAD is used according to the requirements of the food use authorization Certificate indicating proper INAD usage Visual check Once per year for each aquaculture site Field agent Survey farm husbandry procedures, ask questions, and review drug records Once per year for each aquaculture site
Reject the product Do not have the product shipped from the production site for processing.
On-site audit report
195
Collect a representative sample of the raw material quarterly, and analyze for those drug residues that are reasonably likely to be present* Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) Discontinue use of the supplier until evidence is obtained that drug treatment practices have changed Certificate of INAD usage Review monitoring, verification, and corrective action records within 1 week of preparation
* Note: This plan is for illustrative purposes only. An actual plan should specify in the Verification column: the aquaculture drugs for which analysis will be conducted, the protocol for sample collection, and the analytical method to be used for each drug
CONTROL STRATEGY EXAMPLE 2 - SUPPLIERS

CERTIFICATION

Copy of certificates; AND Receiving record showing lots received and presence or absence of a certificate of proper use.

Certificate proper drug usage accompanying each lot of incoming aquacultured fish.

Presence of a certificate indicating proper drug usage.

Collect a representative sample of the raw material, in-process product, or finished product at least quarterly, and analyze for those drug residues that are reasonably likely to be present; AND Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent method, or by analyzing proficiency samples); AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Visual check for presence of certificate of proper use.

Each lot received.


Reject the lot; OR Hold the lot until a certificate can be provided; OR Hold and analyze the lot for those aquaculture drugs that are reasonably likely to be present. AND
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TABLE 11-2
CONTROL STRATEGY EXAMPLE 2 - SUPPLIERS CERTIFICATION
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Suppliers Certification. This example illustrates how a primary processor of pondraised shrimp can control aquaculture drugs. It is provided for illustrative purposes only.

(1)
(2)
Receiving
Aquaculture drugs
CHAPTER 11: Aquaculture Drugs Certificate indicating proper drug usage accompanying all lots of incoming pondraised shrimp Presence of a certificate indicating proper drug usage Visual check Each lot received Receiving dock employee
Reject the lot
Producers drug usage certificate Discontinue use of the supplier until evidence is obtained that the supplier will comply with the certification controls Receiving record
197
Collect a representative sample of the raw material quarterly, and analyze for those drug residues that are reasonably likely to be present* Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 3 - RECORDS OF

DRUG USE


Drug usage records for each delivery that show aquaculture drugs were used on foodproducing fish only if the drugs have been: Approved by FDA or granted conditional approval by FDA and used in accordance with all labeled conditions; OR Approved by FDA and used in an extra-label manner under a veterinarians supervision in accordance with FDA regulations; OR Put on the list of low regulatory priority aquaculture drugs and used according to the provisions in the list; AND Lot-by-lot certificate from the producer indicating that any investigational new drug used in fish intended for human consumption is subjected to an investigational new animal drug exemption under 21 CFR Part 511 and that the INAD is used according to the requirements of the food use authorization.
Reject the lot. AND

Discontinue use of the supplier until evidence is obtained that drug treatment practices have changed and/or the producer will comply with the certification controls.

Producers drug records; AND INAD certificate of proper use; AND Receiving record showing lots received and presence or absence of a certificate.

Collect a representative sample of the raw material, in-process product, or finished product at least quarterly, and analyze for those drug residues that are reasonably likely to be present; AND Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent method, or by analyzing proficiency samples); AND Review monitoring, verification, and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Records of on-farm drug use; AND Certificate indicating proper INAD usage.

Visual check of drug use records and INAD certificate of proper use.

Each lot received.

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TABLE 11-3
CONTROL STRATEGY EXAMPLE 3 - RECORDS OF DRUG USE
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Records of Drug Use. This example illustrates how a pond-raised shrimp processor can control aquaculture drugs. It is provided for illustrative purposes only.
Aquaculture drugs may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., chemical contaminants).

(1)
(2)
Receiving
Aquaculture drugs
Records of onfarm drug usage
Visual check
Each lot received
Reject the lot
Growers drug usage records Discontinue use of the supplier until evidence is obtained that drug treatment practices have changed Receiving record
CHAPTER 11: Aquaculture Drugs Certificate indicating proper INAD usage Visual check Each lot received Production supervisor
199
Drug usage records for each delivery that show that drugs were used on fish only if the drugs have been approved by FDA or granted a conditional approval by FDA and used in accordance with all labeled conditions; approved by FDA and used in an extra-label manner under a veterinarians supervision in accordance with FDA regulations; or put on the list of low regulatory priority aquaculture drugs and used according to the provisions on the list
Collect a representative sample of the raw material quarterly, and analyze for those drug residues that are reasonably likely to be present* Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) Reject the lot Certificate of INAD usage Discontinue use of the supplier until evidence is obtained that the supplier will comply with the certification requirements Receiving record Review monitoring, verification, and corrective action records within 1 week of preparation
Lot-by-lot certificate from the producer indicating that any investigational new drug used in fish intended for human consumption is subject to an investigational new animal drug exemption under 21 CFR Part 511 and that the INAD is used according to the requirements of the food use authorization
CONTROL STRATEGY EXAMPLE 4 - DRUG

RESIDUE TESTING

Test results.

No fish may contain a residue of an unapproved drug (other than for those drugs used as an INAD and according to the requirements of the food use authorization or used in accordance with the criteria specified in the list of low regulatory priority aquaculture drugs); AND No fish may contain a residue level of an approved drug that is above FDA tolerance for that drug.

Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent method, or by analyzing proficiency samples). AND Review monitoring, corrective action and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed;

Fish edible flesh for those drug residues that are reasonably likely to occur.

Obtain samples and test for drugs using rapid screening methods or other validated analytical methods.

Each lot received.

Any person who is qualified by training or experience to perform the analyses.

Reject the lot. AND

Discontinue use of the supplier until evidence is obtained that drug treatment practices have changed.
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TABLE 11-4
CONTROL STRATEGY EXAMPLE 4 - DRUG RESIDUE TESTING
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Drug Residue Testing. This example illustrates how a primary processor of farmraised catfish can control aquaculture drugs. It is provided for illustrative purposes only.

(1)
(2)
Receiving
Aquaculture drugs
Fish edible flesh for drug residues*
Each lot received
Quality assurance personnel
Reject the lot
Analytical results
CHAPTER 11: Aquaculture Drugs No fish may contain residues of unapproved drugs (other than those used as an INAD subject to an investigational new animal drug exemption under 21 CFR Part511 and according to requirements of the food use authorization or included on the list of low regulatory priority aquaculture drugs)* No fish may contain a residue level of an approved drug that is above FDA tolerance for that drug* Obtain samples and analyze for drugs using rapid screening methods or other analytical methods*
201
Discontinue use of the supplier until evidence is obtained that drug treatment practices have changed
Periodically verify the adequacy of the testing methods and equipment (e.g., by comparing results with those obtained using an Association of Official Analytical Chemists (AOAC) or equivalent Review monitoring, verification, and corrective action records within 1 week of preparation
* Note: This plan is for illustrative purposes only. An actual plan should specify: (1) in the Critical Limits column: the aquaculture drugs that are reasonably likely to be present and the critical limits to be applied to each drug; and (2) in the Verification column: the aquaculture drugs for which analysis will be conducted, the protocol for sample collection, and the analytical method to be used for each drug.
CONTROL STRATEGY EXAMPLE 5 - QUALITY

ASSURANCE PROGRAM

Certificate indicating that the producer operates under a third-party-audited quality assurance (QA) program that controls aquaculture drug use. The certificate may accompany each lot of incoming aquacultured fish or may be issued for each producer of incoming aquacultured fish as a continuing certification.

Third-party certificates; AND Receiving record showing lots received and presence or absence of a certificate.

Certificate indicating operation under third party-audited QA program.

Review the third-party QA program and results of audits annually; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Visual check for presence of a certificate.

Each lot received must be checked for the presence of certificates. Certificates may be issued on a lot-by-lot (no less than annually) or continuing basis.


Reject the lot; OR Hold the lot until a certificate can be provided; OR Hold and analyze the lot for those aquaculture drugs that are reasonably likely to be present. AND
202
TABLE 11-5
CONTROL STRATEGY EXAMPLE 5 - QUALITY ASSURANCE PROGRAM
This table is an example of a portion of a HACCP plan using Control Strategy Example 5 - Quality Assurance Program. This example illustrates how an aquacultured trout processor can control aquaculture drugs. It is provided for illustrative purposes only.
Aquaculture drugs may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants).

(1)
(2)
Receiving
Aquaculture drugs
Presence of a third-party certificate
Visual check
Each lot
Receiving dock employee
Reject the lot
Third- party certificate Receiving record
CHAPTER 11: Aquaculture Drugs Certificate indicating that the producer operates under a third party-audited QA program that covers aquaculture drug usage
Discontinue use until evidence is obtained that the supplier will comply with the certificate requirements
Review third-party QA program and results of audits annually Review monitoring, verification, and corrective action records within 1 week of preparation
203
CONTROL STRATEGY EXAMPLE 6 - CONTROL

DURING HOLDING
OR

Aquaculture drugs are used on fish only if the drugs have been: Approved by FDA or granted a conditional approval by FDA and used in accordance with all labeled conditions; OR Approved by FDA and used in an extra-label manner under a veterinarians supervision in accordance with FDA regulations; OR Put on the FDA list of low regulatory priority aquaculture drugs and used according to the provisions on the list; OR Used for use in food fish as an INAD subject to an investigational new animal drug exemption under 21 CFR Part 511 and used according to the requirements in the food use authorization.
Requirements of the INAD food use authorization;
AND
Date of distribution of the finished product.

Visually observe drug use and finished product distribution.

Every time aquaculture drugs are used during holding or transportation; AND Every time the finished product is distributed.



Type of aquaculture drug used; AND Date and quantity of drug use; AND Any other conditions of drug usage that are relevant to:
Destroy the product; OR Divert the product to non-food use; OR If the drug is approved for the species in which it was used, hold the product until the mandatory withdrawal period (if applicable) has been met and until the drug residue level is below the established tolerance. These corrective actions may be verified by collecting and analyzing a representative sample of the product, using an appropriate analytical method. AND
Established withdrawal times;

Labeled instructions; Extra-label use of an FDA-approved drug used under a veterinarians supervision in accordance with FDA regulations and guidances; Conditions specified in the FDA list of low regulatory priority aquaculture drugs;
Modify drug use practices.
204
TABLE 11-6
CONTROL STRATEGY EXAMPLE 6 - CONTROL DURING HOLDING
This table is an example of a portion of a HACCP plan using Control Strategy Example 6 - Control During Holding. This example illustrates how a processor that holds live lobster in a lobster pound can control aquaculture drugs. It is provided for illustrative purposes only.
Aquaculture drugs may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants, pesticides and natural toxins).

(1)
(2)
Holding
Aquaculture drug oxytetracycline
Type of aquaculture drug used
Visual observation of drug use
Every time aquaculture drugs are used
Production employee
Hold the product
Drug use record Collect a sample of the finished product and analyze for drug residues (oxytetracycline) Release the product if the drug residue level is below the tolerance (2 ppm)
CHAPTER 11: Aquaculture Drugs Lobster will be withheld from distribution for 30 days after treatment with oxytetracycline in accordance with the labeled directions for use No other aquaculture drugs will be used Date and quantity of drug use Visual observation of drug use Every time aquaculture drugs are used Production employee Date of finished product distribution Visual check of product distribution Every time finished product is shipped Shipping supervisor
205
Hold the product if the drug residue level exceeds the tolerance and retest Destroy the lot when unapproved drugs are used Modify drug use practices
Drug use record
Shipping record

Drug use records; AND Records indicating date of distribution of the finished product.

206
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Federal Joint Subcommittee on Aquaculture. April 2007. Guide to drug, vaccine, and pesticide use in aquaculture. http://aquanic. org/jsa/wgqaap/drugguide/drugguide.htm. Federal Register. November 21, 2005. Rules and regulations: new animal drugs: florfenicol, vol. 70, no 233. U.S. Government Printing Office, Washington, DC. Federal Register. February 6, 2007. Rules and regulations: new animal drugs: hydrogen peroxide, vol. 72, no. 24. U.S. Government Printing Office, Washington, DC. Federal Register. November 26, 2007. Rules and regulations: new animal drugs: florfenicol, vol. 72, no. 226. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. February 19, 2008. Extralabel use of approved drugs in aquaculture. In Program policy and procedures manual guide 1240.4210. Department of Health and Human Services, Food and Drug Administration, Center for Veterinary Medicine. http://www. fda.gov/downloads/AnimalVeterinary/ GuidanceComplianceEnforcement/ PoliciesProceduresManual/ucm046932.pdf. U.S. Food and Drug Administration. October 23, 2003. Evaluating the safety of antimicrobial new animal drugs with regard to their microbiological effects on bacteria of human health concern. In Guidance for industry, no. 152. Department
of Health and Human Services, Food

and Drug Administration, Center for
Veterinary Medicine. http://www.fda.
gov/downloads/AnimalVeterinary/
GuidanceComplianceEnforcement/
GuidanceforIndustry/ucm052519.pdf.
U.S. Food and Administration. April 2010. Certain other dosage form new animal drugs. In Code of Federal Regulations, 21 CFR 529. U.S. Government Printing Office, Washington, DC. U.S. Food and Administration. April 2010. Extra label drug use in animals. In Code of Federal Regulations, 21 CFR 530. U.S. Government Printing Office, Washington, DC. U.S. Food and Administration. April 2010. Implantation or injectable dosage form new animal drugs. In Code of Federal Regulations, 21 CFR 522. U.S. Government Printing Office, Washington, DC. U.S. Food and Administration. April 2010. New animal drug applications. In Code of Federal Regulations, 21 CFR 514. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. April 2010. New animal drugs for investigational use. In Code of Federal Regulations, 21 CFR 511. U.S. Government Printing Office, Washington, DC. U.S. Food and Administration. April 2010. Tolerances for residues of new animal drugs in food. In Code of Federal Regulations, 21 CFR 556. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. April 26, 2007. Enforcement priorities for drug use in aquaculture; part B and part C. In CVMs policy and procedures manual 1240.4200. Department of Health and Human Services, Food and Drug Administration, Center for Veterinary Medicine. http://www. fda.gov/downloads/AnimalVeterinary/ GuidanceComplianceEnforcement/ PoliciesProceduresManual/ucm046931.pdf.
207
NOTES:
208
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than
Clostridium botulinum) as a Result of Time and Temperature Abuse

Pathogenic bacteria growth and toxin formation as a result of time and temperature abuse of fish and fishery products can cause consumer illness. This hazard is limited to bacterial pathogens since viral pathogens (viruses) are not able to grow in food. Of particular concern in seafood are the pathogenic forms of Listeria monocytogenes (L. monocytogenes), Vibrio vulnificus (V. vulnificus), Vibrio parahaemolyticus (V. parahaemolyticus), Vibrio cholera (V. cholera), Escherichia coli (E. coli), Salmonella spp., Shigella spp., Staphylococcus aureus (S. aureus), Clostridium perfringens (C. perfringens), Bacillus cereus (B. cereus), Campylobacter jejuni (C. jejuni), and Yersinia enterocolitica (Y. enterocolitica). See Appendix 7 for a description of the public health impacts of these pathogens. Pathogenic bacteria can enter the process on raw materials. They can also be introduced into foods during processing from the air, unclean hands, insanitary utensils and equipment, contaminated water, or sewage and through cross-contamination between raw and cooked product. The primary method for control is to reduce levels through cooking or other treatments, when feasible, minimize the potential for recontamination and to maintain products at temperatures that do not support growth of pathogenic bacteria.
Time and temperature abuse occurs when a product is allowed to remain at temperatures favorable to pathogenic bacteria growth for sufficient time to result in unsafe levels of pathogenic bacteria or their toxins in the product. Therefore, management of time and temperature of product exposure is important to producing a safe product. Table A-1 (Appendix 4) provides guidance concerning the conditions under which certain pathogenic bacteria can grow. The bacteria listed are those of greatest concern in fish and fishery products.
Managing time and temperature of exposure
Time and temperature management relies on identification of time and temperature combinations that ensure the safety of your product. The following factors should be considered: The types of pathogenic bacteria that are reasonably likely to be present; Whether those pathogens can grow in the food; The infective dose of the pathogenic bacteria; The expected initial level of the pathogenic bacteria in the food.
Presence of pathogenic bacteria
It is reasonable to assume that pathogenic bacteria of various types that are not associated with specific food sources, including those listed in Table A-1 (Appendix 4), will be present on raw fish
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse
209
and fishery products and non-fishery ingredients. They might be present only at low levels or only sporadically, but even such occurrences warrant consideration because of the potential for growth and toxin production under temperature abuse conditions. However, certain pathogenic bacteria are associated with specific food sources, and it may not be necessary to assume that they will be present in other foods unless introduced from a contaminated source. For example, V. vulnificus, V. parahaemolyticus, and V. cholerae non-O1 and non-O139 are generally associated with marine and estuarine species of fish and not with freshwater species or non-fishery ingredients. Pathogenic bacteria can also be introduced during processing, even after cooking. Welldesigned sanitation programs will minimize their introduction. However, in most cases, it is not reasonable to assume that sanitation programs will fully prevent the introduction of pathogenic bacteria. For this reason, controls should be in place to minimize the risk of pathogenic bacteria growth.
Pathogenic bacteria growth
Table A-1 (Appendix 4) provides guidance on some conditions that limit the growth of those pathogenic bacteria that are most relevant to fish and fishery products. Table A-1 provides minimum and maximum values of pathogenic bacteria growth. This table can help you to decide whether particular pathogenic bacteria will grow in your food if it is time and temperature-abused. Certain pathogenic bacteria grow well in time and temperature-abused raw fish and fishery products (e.g., raw molluscan shellfish), and others do not. Those that grow well in time and temperature-abused raw fish include: V. vulnificus, V. parahaemolyticus, V. cholerae, and L. monocytogenes. Others may grow if the natural condition of the raw fish is changed, such as through salting or reduced oxygen packaging. Those that ordinarily do not grow well, because they compete poorly with the normal spoilage bacteria, include: C. jejuni, pathogenic strains of E. coli, Salmonella spp., Shigella spp., S. aureus, C. perfringens, B. cereus, and Y. enterocolitica. Most pathogenic bacteria will grow well in temperature-abused cooked fish if their growth is not controlled by means such as drying, salting, or acidification, because competing bacteria are destroyed by the cooking process.
Infective dose
Fish and fishery products generally provide sufficient nutrients for pathogenic bacteria growth. However, chemical and physical characteristics of the product and its packaging could limit or enhance pathogenic bacteria growth and toxin formation. Furthermore, these characteristics could restrict competing microorganism growth and provide conditions favorable to pathogenic bacteria growth. Consider: The moisture available to support pathogenic bacteria growth in the product (i.e., water activity); The amount of salt and preservatives in the product (e.g., water phase salt and nitrates); The acidity of the product (i.e., pH); The availability of oxygen in the product (i.e., aerobic or anaerobic conditions); The presence of competing spoilage organisms in the food.
210
The infective dose or toxic dose is the total number of a pathogen, or the total amount of a toxin, that is necessary to produce human illness. The dose often varies considerably for a single pathogen based on the health of the consumer and the virulence (infective capacity) of the particular strain of the pathogen. The typical infectious dose is known or suspected to be very low (i.e., one to several hundred organisms can cause illness) for many of the pathogenic bacteria listed in Table A-1 (Appendix 4). These include C. jejuni, E. coli, Salmonella spp., Shigella spp., and Y. enterocolitica. The typical infectious dose for other pathogenic bacteria is considered to be
somewhat higher (i.e., several thousand to less than 100,000). These include V. vulnificus and V. parahaemolyticus. In the case of both of these categories of pathogens, it is advisable to prevent any significant growth so that the typical infective dose is not exceeded. In other words, product temperatures should be maintained below the minimum growth temperature for the pathogen or should not be allowed to exceed that temperature for longer than the lag growth phase (i.e., the slow growth phase during which a pathogenic bacteria acclimates to its environment before proceeding to rapid growth) of the pathogenic bacteria at the exposure temperature. Still other pathogenic bacteria require large numbers in order to cause disease. The typical infectious dose of V. cholerae is suspected to be 1,000,000 cells. S. aureus and B. cereus toxin do not normally produce sufficient toxin to cause illness until numbers of the pathogen reach 100,000 to 1,000,000/gram. C. perfringens typically does not produce toxin in the human gut unless at least 100,000,000 bacteria are consumed. Limited growth of these pathogens might not compromise the safety of the product. However, time and temperature controls must be adequate to prevent growth before the infectious or toxic dose is reached.
Levels of pathogenic bacteria
pathogenic bacteria that have a relatively high infective dose, the initial number of pathogenic bacteria may be a significant consideration.
Practical considerations for unrefrigerated processing
Consider the above described factors to identify the pathogen(s) that presents the greatest challenge with respect to managing time and temperature exposure in your product. This then becomes the target pathogen(s) for time and temperature control. Table A-2 (Appendix 4) can then be used to establish safe exposure times for the target pathogen(s) at the temperatures at which you expect your product to be exposed. As an alternative, you can use predictive microbiology models, such as the U.S. Department of Agriculture Pathogen Modeling Program (http://ars.usda.gov/Services/docs. htm?docid=6786) or ComBase (http://www. combase.cc/default.html) for product-specific time and temperature exposure calculations. However, you should validate the reliability of predictions from such models for your food. Growth rates of pathogens are highly temperature dependent. Ordinarily, pathogenic bacteria growth is relatively slow at temperatures below 70F (21.1C). In most cases, growth is very slow below 50F (10C), and 40F (4.4C) is below the minimum growth temperature of most pathogenic bacteria, although there are some exceptions. On the other hand, pathogenic bacteria grow relatively fast at temperatures above 70F (21.1C). Product temperatures should be maintained below the minimum growth temperature for the pathogen or should not be allowed to exceed that temperature for longer than the lag growth phase of the pathogen growth cycle. Consider the following recommendations when developing a product monitoring program. Product surface temperature or ambient temperature generally should be monitored when the ambient temperature (e.g., air) is warmer than the product internal temperature. Internal temperature in the
The levels of a pathogen that are likely to be present in a fish or fishery product is dependent on factors such as the quality of the harvest water, how the raw material was handled before it was delivered to your plant, and the effectiveness of your sanitation control program. As a practical matter, the initial number of low to-moderate infectious dose pathogenic bacteria in a food is usually of limited importance when you develop a time and temperature management strategy because these pathogens should be controlled by a time and temperature strategy that does not permit their growth to pass the lag phase. On the other hand, when controlling
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center of the thickest part of the product should be monitored when the ambient temperature (e.g., air, ice, and brine) is cooler than the product internal temperature. Similarly, when selecting a product for temperature measurement, consider the location of the product selected in relation to the environment and select the likely worse case product. For example, a product in the center of a pile of products will take longer to cool than a product at the surface. Strategies for control of pathogenic bacteria There are a number of strategies for the control of pathogenic bacteria in fish and fishery products. They include: Managing the amount of time that food is exposed to temperatures that are favorable for pathogen growth and toxin production (covered generally in this chapter; for Clostridium botulinum (C. botulinum), in Chapter 13; and for S. aureus in hydrated batter mixes, in Chapter 15); Killing pathogenic bacteria by cooking or pasteurization (covered in Chapter 16) or by retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (hereinafter, the Low-Acid Canned Foods (LACF) Regulation); Killing pathogenic bacteria by processes that retain the raw product characteristics (covered in Chapter 17); Controlling the amount of moisture that is available for pathogen growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogen growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of acidity (pH) in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable
acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 4).

The following guidance will assist you in determining whether pathogenic bacteria growth and toxin formation as a result of time and temperature abuse is a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of pathogenic bacteria will be introduced at this processing step (do unsafe levels come in with the raw material or will the process introduce them)?
It is reasonable to assume that pathogenic bacteria of various types that are not associated with specific food sources, including those listed in Table A-1 (Appendix 4), will be present on raw fish and fishery products and non-fishery ingredients. However, certain pathogenic bacteria are associated with specific food sources, and it may not be necessary to assume that they will be present in other foods unless they have been cross-contaminated. For example, V. vulnificus, V. parahaemolyticus, and V. cholerae non-O1 and non-O139 are generally associated with marine and estuarine species of fish and not with freshwater species or non-fishery ingredients. Pathogenic bacteria also could be introduced during processing, even after cooking. Welldesigned sanitation programs (prerequisite programs) will minimize the introduction of pathogenic bacteria. However, in most cases
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it is not reasonable to assume that they will fully prevent the introduction of pathogenic bacteria. Additional information on this topic is presented in the previous section, Understand the Potential Hazard.
2. Is it reasonably likely that pathogenic bacteria will grow to unsafe levels and/or produce toxin at this processing step?
In summary, under ordinary circumstances (e.g., without data to the contrary), you should consider that it is reasonably likely that a pathogenic bacteria in Table A-1 (Appendix 4) will grow to an unsafe level or produce toxin in your product at a particular processing step if all of the following conditions are met: It is reasonably likely to be present; Its growth is not prevented by
a condition of the food;
It is reasonably likely that, in the absence of controls, cumulative time and temperature abuse conditions such as those described in Table A-2 (Appendix 4) could occur during processing of the product, and the processing step could contribute significantly to that cumulative abuse.
3. Can unsafe levels of pathogenic bacteria and/ or toxin production that are reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
In order to answer this question, you must first determine which of those pathogenic bacteria that are reasonably likely to be present in your product would be able to grow under time and temperature abuse conditions. Information on this topic is presented in the previous section, Understand the Potential Hazard. Time and temperature abuse at one step alone might not result in an unsafe product. However, time and temperature abuse that occurs at successive processing steps (including storage steps) might be sufficient to result in unsafe levels of pathogenic bacteria or toxins. For this reason, you should consider the cumulative effect of time and temperature abuse during the entire process. Table A-2 (Appendix 4) provides guidance about the kinds of time and temperature abuse that might cause a product to be unsafe. A study may need to be conducted to determine time and temperature exposure of your seafood to temperature abuse for each process step. Remember that you should consider the potential for time and temperature abuse in the absence of controls. You might already have controls in your process that minimize the potential for time and temperature abuse that could result in unsafe levels of pathogenic bacteria or toxins. This section and subsequent sections will help you determine whether those or other controls should be included in your Hazard Analysis Critical Control Point (HACCP) plan.
Pathogenic bacteria growth and toxin formation due to time and temperature abuse should be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measures that can be applied for pathogenic bacteria growth and toxin formation due to time and temperature abuse include: Refrigeration of the product and controlling refrigeration temperatures; Proper icing of the product; Controlling the amount of time that the product is exposed to temperatures that would permit pathogenic bacteria growth or toxin production; Rapid cooling of the product;
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Ensuring that incoming fish were handled properly during refrigerated transportation from the previous processor, including:
Controlling refrigeration temperatures during transit; Proper icing during transit.
Intended use Except as noted, it is unlikely that the intended use will affect the significance of the hazard. FDA is not aware of any HACCP controls that exist internationally for the control of pathogenic bacteria in fish and fishery products that are customarily fully cooked by the consumer or end user before consumption, other than a rigorous sanitation regime as part of a prerequisite program or as part of HACCP itself. The Fish and Fishery Products regulation, 21 CFR 123 (called the Seafood HACCP Regulation in this guidance document) requires such a regime. The proper application of sanitation controls is essential because of the likelihood that pathogenic bacteria can be introduced into fish and fishery products through poor handling practices by the aquaculture producer, the fisherman, or the processor. FDA is interested in information regarding any HACCP controls beyond sanitation that could be necessary and practical for the control of pathogenic bacteria in fish and fishery products that are customarily fully cooked by the consumer or end user. However, the agency makes no recommendations in this guidance document and has no specific expectations with regard to such controls in processors HACCP plans. The agency plans to develop Good Manufacturing Practice guidelines for harvest vessels and for aquaculture in an effort to minimize the likelihood that these operations will contribute pathogens to fish and fishery products. Some products are partially cooked by
the processor for culinary purposes (e.g., setting the batter or breading, or stabilizing the product shape), and are customarily fully cooked by the consumer or end user. Examples include: fish balls, shrimp egg rolls, shrimp and cheese stuffed ravioli, crab cakes, and breaded fish portions. Although the exterior of these products may appear cooked, the interior fish protein is not coagulated, and the products are not ready-to-eat. Other products contain a combination of raw or partially cooked, and fully cooked ingredients (e.g., seafood mixture of raw oysters, cooked shrimp, and raw or cooked octopus). Although the protein of some of the fishery ingredients is coagulated, some is not. As a result, many of these products are not ready-to-eat. However, these combination products should be considered ready-to-eat if the raw or partially cooked ingredients are customarily eaten without cooking by the consumer or end user. Note that the toxin produced by S. aureus is not destroyed by cooking or retorting. Its formation should, therefore, be prevented in all fish and fishery products. However, as previously mentioned, S. aureus does not grow well in raw fish, unless the growth of competing spoilage organisms is inhibited (e.g., by salting or vacuum packaging). B. cereus also produces a heat-stable toxin and forms heatresistant spores that can survive cooking.
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The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for pathogenic bacteria growth and toxin formation as a result of time and temperature abuse:
1. If there is a cook step, pasteurization step, or retorting step later in your manufacturing process, you should, in most cases, identify that step as the CCP. You would not usually need to identify processing steps prior to cooking, pasteurization, or retorting as CCPs for this hazard.
identify as a CCP each processing step at which you have identified this hazard as significant. You should control cumulative exposure of the product to time and temperatures that will permit growth or toxin formation at these steps.
Example: A cooked shrimp processor should set the critical control point for pathogenic bacteria growth and toxin formation as a result of time and temperature abuse at the cook step. The processor would not need to identify each of the processing steps prior to cooking as CCPs. Guidance for this pathogen control strategy is contained in Chapter 16 (for cooking and pasteurization) and the LACF Regulation, 21 CFR 113 (for retorting). However, there are two important limitations to this strategy: The cooking, pasteurizing, or retorting process must be sufficient to eliminate the most resistant pathogenic bacteria of public health concern that are reasonably likely to be present; Certain toxins (e.g., S. aureus and B. cereus toxins) are heat stable. Heat treatment, including retorting, might not eliminate the toxin once it is formed. In either case, time and temperature control would be necessary at the processing steps at which growth and toxin formation could occur.
2. If there is no cook step, pasteurization step, or retorting step later in the process, you should
Example: A crabmeat processor identifies a series of post-cook processing and storage steps (e.g., backing, picking, packing, and refrigerated storage) as presenting a reasonable likelihood of pathogenic bacteria growth and toxin formation. The processor does not subject the product to a final pasteurization process and recognizes that it might be consumed without further cooking. The processor controls the temperature during refrigerated storage and the time of exposure to unrefrigerated conditions during the processing steps. The processor should identify each of the post-cook processing and storage steps as CCPs for this hazard. This chapter provides the following four control approaches, or control strategies, each relating to a separate potential CCP or a set of CCPs: Control Strategy Example 1 - Transit Control. This control strategy should be applied to the control of transit at receipt of chilled (i.e., refrigerated, iced, or held under chemical cooling media, such as gel packs, and not frozen) ready-to-eat fishery products; Control Strategy Example 2 Refrigerated Storage and Refrigerated Processing Control. This control strategy should be applied to chilled (i.e., refrigerated, iced, and not frozen) storage and refrigerated (i.e., <40F (4.4C)) processing; Control Strategy Example 3 - Cooling After Cooking Control. This control strategy should be applied to a cooling
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step when there is no significant handling during the cooling and there is a need to control sporeforming pathogenic bacteria; Control Strategy Example 4 Unrefrigerated Processing Control. This control strategy should be applied to unrefrigerated (i.e., 40F (4.4C)) processing. Following is further guidance that may help you determine whether these processing steps should be identified as CCPs for this hazard. The guidance is divided into two types of finished products: cooked ready-to eat and raw ready-to-eat. Cooked, ready-to-eat products These products may be cooked by the processor, received by the processor already cooked, or assembled by the processor from ready-to-eat components. They may appear to the consumer or end user to be ready-to eat products and may, therefore, be eaten without further cooking. Examples include: cooked crabmeat, lobster meat, and crayfish meat; surimi-based analog products; seafood salads; and hot-smoked fish. Note that smoked fish is also covered in Chapter 13, and cooking and pasteurization are covered in Chapter 16. Cooked, ready-to-eat products, especially assembled products, might develop pathogen hazards as a result of cross-contamination and growth. Contributing factors to this risk are manual handling steps, multiple ingredients, unrefrigerated processing, and multiple cooling steps. Cumulative exposure to time and temperature abuse after the cook step should be taken into consideration when establishing CCPs based on time and temperature.
In some cases, refrigerated cooked, readyto-eat foods (e.g., lobster meat, pasteurized crabmeat, smoked fish, and surimi-based analog products) are received by a secondary processor and held for sale without further handling. In other cases, these products are received by a secondary processor and used as ingredients in a ready-to-eat product that will not be cooked or pasteurized by that processor (e.g., seafood salad). In these cases, the receiving and storage steps by the secondary processor should be designated as CCPs to control the hazard of pathogenic bacteria growth. On the other hand, if these ready-to-eat foods are received by the secondary processor to be used in a product that will be cooked or pasteurized by that processor, the receiving and storage steps before the cooking or pasteurization step might not need to be designated as CCPs, unless S. aureus or B. cereus toxin formation is a significant hazard. Remember that these toxins are not likely to be inactivated by heat. In still other cases, ready-to-eat foods are received by a secondary processor and used as ingredients in a non-ready-to-eat product (e.g., cooked octopus used by the processor as an ingredient in a seafood mix that is customarily eaten after cooking by the consumer or end user). Again, the receiving and storage steps might not need to be designated as CCPs, unless S. aureus or B. cereus toxin formation is a significant hazard. The need to establish a CCP at cooling after cooking or pasteurization depends on: The severity of the cooking (including hot smoking) or pasteurization step; The extent to which the product is handled between the end of the cooking or pasteurization step and the end of the cooling step. Spore-forming pathogenic bacteria may survive cooking or pasteurization processes that target vegetative pathogenic bacteria.
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For example, in foods that contain meat or rice, spores of C. perfringens and B. cereus could be present, could survive the cooking process, and could grow and produce toxin in the product during cooling and subsequent handling. In fact, the heat from the cooking process might initiate growth of the surviving spores. In this case, a CCP may be needed at product cooling. However, some cooking processes might be adequate to kill even the spores of C. perfringens and B. cereus. In this case, a CCP at product cooling may not be necessary. When significant handling occurs after cooking or pasteurization, there is a risk that the product might be recontaminated with pathogenic bacteria. Because many of the normally occurring spoilage organisms may have been eliminated by the cooking or pasteurization process and are no longer present to compete with the pathogenic bacteria, rapid growth and toxin formation by the pathogenic bacteria are possible. It is advisable to fully cool a product before it is further handled, in order to minimize pathogenic bacteria growth and toxin formation. When significant handling occurs after the heating process but before the completion of the cooling process or when the cooked product comes into contact with equipment that was not heated along with the product, time and temperature exposure controls may need to start at that point. In some processes, cooling is performed (1) before any significant handling of the cooked product; and (2) in the same container in which the product was cooked. Under these conditions, cooling after cooking may not need to be identified as a CCP for this hazard. However, such a determination is dependent upon strict adherence to good sanitation practices to further minimize the risk of recontamination with pathogenic bacteria.
Time and temperature controls may be needed at the following steps (CCPs): Receiving; Thawing; Cooling after cooking; Processing after cooking:
Slicing hot-smoked salmon; Mixing seafood salad; Picking crabmeat;
Packaging; In-process and finished product refrigerated (not frozen) storage. Time and temperature controls will usually not be needed at processing steps that meet the following conditions: Continuous, mechanical processing steps that are brief:
Mechanical size grading of cooked shrimp;

Mechanical forming of surimi-based
analog products; Individual quick freezing;
Processing steps that are brief and unlikely to contribute significantly to the cumulative time and temperature exposure to unrefrigerated conditions:
Processing steps where the product is held in a frozen state:

Glazing;
Assembly of orders for distribution; Frozen product storage;
Processing steps where the product is held at temperatures above 135F (57.2C):

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Initial stage of cooling; Hot holding.
Raw, ready-to-eat products These products are not heated during processing to a temperature that destroys pathogenic bacteria. They are often consumed without cooking. Examples include: cold-smoked fish, raw oysters, clams and mussels, and raw finfish (when the processor has knowledge or has reason to know that the product will be consumed without a process sufficient to kill pathogens of public health concern or where the processor represents, labels, or intends for the product to be so consumed). Like cooked, ready-to-eat products, raw ready-to-eat products may contain pathogenic bacteria as a result of near-shore harvest water contamination, poor aquaculture practices, or poor sanitary practices during harvesting, transportation, or processing. For example, oysters, especially those harvested during the warm weather months, might contain V. vulnificus or V. parahaemolyticus. Raw finfish might contain V. parahaemolyticus, Salmonella spp., or L. monocytogenes. Some of these pathogenic bacteria (e.g., V. vulnificus, V. parahaemolyticus, and L. monocytogenes) are capable of growth in raw fish. Time and temperature controls may be needed at the following processing steps (CCPs): Receiving; Processing:
Time and temperature controls will usually not be needed at processing steps that meet the following conditions: Continuous, mechanical processing steps that are brief:
Mechanical filleting;
Processing steps that are brief and unlikely to contribute significantly to the cumulative time and temperature exposure to unrefrigerated conditions:
Processing steps where the product is held in a frozen state: Assembly of orders for distribution; Frozen storage.
Time and temperature profile Preparing a diagram that depicts the maximum times and temperatures at which your product will be exposed at each processing step may help you determine cumulative product exposure, especially if your product is cooked, ready-to-eat. This diagram can help you identify CCPs, as well as critical limits, as will be discussed later. Figures 12-1 and 12-2 are examples of time and temperature profiles for two different crabmeat processes. Although the figures show similar time and temperature profiles, they demonstrate how differences in processing operations, especially with respect to when significant handling occurs, can have an impact on the location of CCPs and on the critical limits at those CCPs. Figure 12-1 shows a time and temperature profile for a cooked crabmeat processor that significantly handles product before it is cooled to 50F (10C). As a result, a CCP is likely to be needed at backing, picking, and packing.
Thawing;
Shucking; Portioning;
Packaging; Raw material, in-process product,

and finished product refrigerated
(not frozen) storage.
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Figure 12-2 shows a time and temperature profile for a cooked crabmeat processor that does not significantly handle product before it is cooled to 50F (10C). As a result, a CCP is not needed until the picking operation, which is the first point at which significant
handling occurs. A more restrictive set of critical limits is also likely for the product depicted by Figure 12-1 than for that depicted by Figure 12-2, because the former product is handled while still warm.
FIGURE 12-1: Internal Temperature Prole Blue Crabmeat Processing

Partial Cooling Only After Cook With Signicant Handling Before Full Cooling
135F (57.2C) Backing Begins Place in Cooler 80F (26.7C) 70F (21.1C) 50F (10C) 40F (4.4C) 1 HR. MAX. 1 HR. MAX. 2 HOURS MAX. Picking Begins Packing Ends
FIGURE 12-2: Internal Temperature Prole Blue Crabmeat Processing

Cooling After Cook in Original Container With No Signicant Handling During Cooling
135F (57.2C)
Cooling in Original Container No Signicant Handling Picking Begins
Packing Ends
80F (26.7C) 70F (21.1C) 50F (10C) 40F (4.4C) 5 HOURS MAX.
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The following guidance provides examples of four control strategies for pathogenic bacteria growth and toxin formation. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
OR For products delivered under ice:
Product is completely surrounded by ice at the time of delivery;
OR
For products delivered under chemical cooling media, such as gel packs:
There is an adequate quantity of cooling media that remain frozen to have maintained the product at an internal temperature of 40F (4.4C) or below throughout transit; AND The internal temperature of the product at the time of delivery is 40F (4.4C) or below;
CONTROL STRATEGY
OR
Transit control Refrigerated storage and refrigerated processing control Cooling after cooking control Unrefrigerated processing control
For products delivered refrigerated (not frozen) with a transit time (including all time outside a controlled temperature environment) of 4 hours or less (optional control strategy):
CONTROL STRATEGY EXAMPLE 1 - TRANSIT

CONTROL (FOR REFRIGERATED (NOT FROZEN) COOKED, READY-TO-EAT OR RAW, READY-TO EAT FISHERY PRODUCTS TO BE STORED OR PROCESSED WITHOUT FURTHER COOKING)
Time of transit does not exceed 4 hours; AND Internal temperature of the product at the time of delivery does not exceed 40F (4.4C).
Note: Processors receiving product with transit times of 4 hours or less may elect to use one of the controls described for longer transit times instead.

For products delivered refrigerated (not frozen):

For fish or fishery products delivered refrigerated (not frozen):
All lots received are accompanied by transportation records that show that the product was held at or below an ambient or internal temperature of 40F (4.4C) throughout transit. Note that allowance for routine refrigeration defrost cycles may be necessary;
The internal temperature of the product throughout transportation; OR The ambient temperature within the truck or other carrier throughout transportation;
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OR
OR
For products held under chemical cooling media, such as gel packs:

OR
The quantity and frozen status of cooling media at the time of delivery; AND The internal temperature of a representative number of product units at time of delivery;
Make visual observations of the

adequacy and frozen state of the cooling
media in a representative number of
containers (e.g., cartons and totes) from
throughout the shipment at delivery;
AND
a thermometer) to determine internal product temperatures in a representative number of product containers from throughout the shipment at delivery;
OR For products delivered refrigerated (not frozen) with a transit time of 4 hours or less:
For products delivered refrigerated (not frozen) with a transit time of 4 hours or less:
The date and time product was removed from a controlled temperature environment before shipment and the date and time delivered; AND The internal temperature of a representative number of product containers (e.g., cartons and totes) at the time of delivery.
Review carrier records to determine the date and time product was removed from
a controlled temperature environment
before shipment and the date and time
delivered;
AND
a thermometer) to determine internal product temperatures in a representative number of product containers (e.g., cartons and totes) randomly selected from throughout the shipment, at delivery. Measure a minimum of 12 product containers, unless there are fewer than 12 products in a lot, in which case measure all of the containers. Lots that show a high level of temperature variability may require a larger sample size.


Every lot received.
Make visual observations of the adequacy of ice in a representative number of containers (e.g., cartons and totes) from throughout the shipment at delivery;

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AND
Discontinue use of the supplier or carrier until evidence is obtained that the identified transportation- handling practices have been improved.


The results of continuous temperature monitoring, including: Printouts, charts, or readings from temperature-recording devices; AND Visual check of recorded data;
OR
Chill and hold the affected product until an evaluation of the total time and temperature exposure is performed (a product with cumulative exposures that exceed the critical limits recommended in Control Strategy Example 4 - Processing Controls should be cooked or diverted to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat, or destroyed or diverted to a non-food use); OR Cook the product, after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat; OR Reject the lot.
The results of ice checks, including:

The number of containers (e.g., cartons and totes) examined and the sufficiency of ice for each; AND The number of containers (e.g., cartons and totes) in the lot; OR
The results of chemical media checks,

including: The number of containers (e.g., cartons and totes) examined and the frozen status of the media for each; AND The number of units in the lot; AND/OR
The results of internal product temperature monitoring, including: The number of containers (e.g., cartons and totes) examined and the internal temperatures observed for each;
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AND The number of containers (e.g., cartons and totes) in the lot; AND Date and time product was initially removed from a controlled temperature environment and date and time product was delivered, when applicable.
kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Check the accuracy of temperature-recording devices that are used for monitoring transit conditions upon receipt of each lot. The accuracy of the device can be checked by comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used; AND When visual checks of ice or cooling media are used, periodically measure internal temperatures of fish to ensure that the ice or cooling media are sufficient to maintain product temperatures at 40F (4.4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device to the reading on a known accurate reference device (e.g., a thermometer traceable to standards of the National Institute of Standards and Technology (NIST)) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used;
AND Once in service, check the temperatureindicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and if the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or
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TABLE 12-1
CONTROL STRATEGY EXAMPLE 1 - TRANSIT CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Transit Control. This example illustrates how a processor receiving pasteurized crabmeat can control pathogenic bacteria growth and toxin formation as a result of time and temperature abuse during transit. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.
Pathogenic bacteria growth and toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, pathogen survival through cooking and pasteurization, and metal fragments).

(1)
(2)
Receiving pasteurized crabmeat
Pathogenic bacteria growth and toxin formation
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse All lots received are accompanied by truck records that show temperature was maintained at or below 40F Temperature of truck refrigerated compartment Digital time and temperature data logger Receiving employee Reject the shipment Discontinue use of the supplier or carrier until evidence is obtained that the identified transportationhandling practices have been improved Data logger printout Continuous, with visual review and evaluation of temperature monitoring records for each shipment Check accuracy of the temperature data logger upon receipt of each lot Review monitoring, corrective action, and verification records within 1 week of preparation
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CONTROL STRATEGY EXAMPLE 2 - REFRIGERATED

STORAGE AND REFRIGERATED PROCESSING CONTROL
For raw material, in-process product, or finished product stored under ice:
The product is completely and

continuously surrounded by ice throughout the storage time.

For refrigerated storage or processing:

For refrigerated (not frozen) storage or processing of the raw material, in-process product, or finished product:
OR
The ambient air temperature of the cooler or refrigerated processing room;
The product is held at a cooler ambient air temperature of 40F (4.4C) or below. Note that allowance for routine refrigeration defrost cycles may be necessary. On the other hand, minor variations in cooler temperature measurements can be avoided by submerging the sensor for the temperature-recording device (e.g., a recording thermometer) in a liquid that mimics the characteristics of the product. Also note that critical limits during refrigerated storage and refrigerated processing that specify a cumulative time and temperature of exposure to temperatures above 40F (4.4C) are not ordinarily suitable to control the hazard because of the difficulty in tracking the specific products and the specific cumulative temperature exposures that those products experience. The cumulative exposure for each product would need to be determined prior to shipping. If you chose this approach, the critical limit for cumulative exposure to temperatures above 40F (4.4C) should include time during transit, refrigerated storage, and refrigerated and unrefrigerated processing;

For refrigerated storage or processing:
OR
Use a continuous temperature-recording device (e.g., a recording thermometer);

For continuous temperature recording devices:
OR
Continuous monitoring by the device itself, with a visual check of the recorded data at least once per day;
Sufficient frequency to ensure the critical limit is met.
OR
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OR Destroy the product; OR Divert the product to a non-food use. AND

Prevent further deterioration of the product:
Add ice to the product; OR Move some or all of the product in the malfunctioning cooler to another cooler;
OR
Freeze the product;

AND Address the root cause: Make repairs or adjustments to the malfunctioning cooler; OR Make adjustments to the ice application operations.
Chill and hold the affected product until an evaluation of the total time and temperature exposure is performed. A product with cumulative exposures that exceed the critical limits recommended in Control Strategy Example 4 - Unrefrigerated Processing Controls, should be cooked or diverted to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat, or destroyed or diverted to a non-food use; OR Cook the product, after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat;


OR
Printouts, charts, or readings from continuous temperature-recording devices;

AND
The results of ice checks: The number of containers (e.g., cartons and totes) examined and the sufficiency of ice for each; AND The approximate number of containers (e.g., cartons and totes) in the cooler.
226

Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NIST-traceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND When visual checks of ice are used, periodically measure internal temperatures of fish to ensure that the ice is sufficient to maintain product temperatures at 40F (4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device.
227
TABLE 12-2
CONTROL STRATEGY EXAMPLE 2 - REFRIGERATED STORAGE AND REFRIGERATED PROCESSING CONTROL (ICING MODEL)
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Refrigerated Storage and Refrigerated Processing Control (Icing Model). This example illustrates how a blue crabmeat processor can control pathogenic bacteria growth and toxin formation as a result of time and temperature abuse during icing. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(1)
(2)
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse Finished product containers completely surrounded with ice Adequacy of ice Visual observation Each case immediately before shipping Production employee Re-ice the product Hold and evaluate based on total time and temperature exposure Ice storage record Check internal temperature of iced crabmeat weekly Review monitoring, corrective action, and verification records within 1 week of preparation
228
Finished product cooler
TABLE 12-3
CONTROL STRATEGY EXAMPLE 2 - REFRIGERATED STORAGE AND REFRIGERATED PROCESSING CONTROL (REFRIGERATION MODEL)
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Refrigerated Storage and Refrigerated Processing Control (Refrigeration Model). This example illustrates how a blue crabmeat processor can control pathogenic bacteria growth and toxin formation as a result of time and temperature abuse during refrigerated storage. It is provided for illustrative purposes only.

(1)
(2)
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse Cooler maintained at or below 40F Cooler temperature Digital time and temperature data logger Continuous, with visual check of recorded data once per day Production employee Move to alternate cooler and/or add ice Hold and evaluate based on total time and temperature exposure Data logger printout Record or visual checks Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
229
Finished product cooler
CONTROL STRATEGY EXAMPLE 3 - COOLING

AFTER COOKING CONTROL
OR Use appropriate instruments (e.g., a temperature-indicating device, such as a thermometer, a continuous temperaturerecording device, such as a time and temperature data logger, a scale) and/or visual observations as necessary to measure the critical factors of the process that affect the rate of cooling, as established by a cooling rate study. Example: A crayfish processor identifies cooling after the cook step as a CCP for pathogenic bacteria growth and toxin formation. The processor establishes a cooling critical limit of no more than 2 hours from 135F (57.2C) to 70F (21.1C) and no more than 4 more hours from 70F (21.1C) to 40F (4.4C). The processor uses marked batches of cooked product to monitor the cooling process. The time that the marked batch is removed from the cooker is monitored visually, and the internal temperature of the product in that batch 2 hours after cooking and 4 more hours after cooking is monitored with a dial thermometer. Example: Another crayfish processor has similarly identified cooling after cooking as a CCP and has established the same critical limit. The processor uses a digital time and temperature data logger to monitor the cooling rate of the cooked product. Example: Another crayfish processor has similarly identified cooling after cooking as a CCP. This processor has performed a cooling rate study that determined that a cooling rate of no more than 2 hours from 135F (57.2C) to 70F (21.1C) and no more than 4 more hours from 70F (21.1C) to 40F (4.4C) can be achieved as long as

The product is cooled from 135F (57.2C) to 70F (21.1C) within 2 hours; AND The product is further cooled from 135F (57.2C) to 40F (4.4C) within an additional 4 hours; OR The minimum or maximum values for the critical factors of the process that affect the rate of cooling, as established by a cooling rate study (e.g., product internal temperature at the start of cooling, cooler temperature, quantity of ice, quantity or size of the product being cooled, product formulation, configuration of the product in the cooler).

The length of the cooling cycle and the internal temperature of the product; OR The critical factors of the process that affect the rate of cooling, as established by a cooling rate study.

Clock; AND Use a temperature-indicating device (e.g., a thermometer) and visual check on time of cooling; OR Use a continuous temperature-recording device (e.g., time and temperature data logger);
230
certain conditions are met in the cooling process. The study determined that the following critical limits must be met: a cooler temperature of no more than 60F (15.6C) during the first 2 hours of cooling and no more than 40F (4.4C) during the remainder of cooling; and no more than 1,000 pounds of crayfish in the cooler. The processor monitors the cooler temperature with a recording thermometer and monitors the weight of the product at receiving with a scale.

Recook the product, after giving consideration to the fact that any S. aureus toxin that may be present may not be inactivated by heat; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any B. cereus toxin that may be present may not be inactivated by heat; OR Destroy the product; OR Divert the product to a non-food use. AND

For temperature-indicating devices:
OR
For temperature-recording devices:
At least every 2 hours a device is placed in the product. It provides continuous monitoring, which is visually checked at the end of the cooling period;
OR For critical aspects of the cooling process:
Prevent further deterioration of the product:
As often as necessary to ensure control of the process.
Add ice to the product;

AND Address the root cause: Make repairs or adjustments to the malfunctioning cooler;
OR
Make adjustments to the ice application operation.

For temperature-indicating devices:
Cooling records showing the internal temperature of the product, and the length of time between the end of the cooking (or the time that the product internal temperature falls below 135F (57.2C)), and the time that the measurement was made;
231
OR For temperature-recording devices:

OR
Record of continuous temperature monitoring; AND Record of visual checks of recorded data;
(e.g., product internal temperature) within the temperature range at which it will be used; AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Devices subjected to high temperatures for extended periods of time may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
232
For the critical factors of the process that affect the rate of cooling, as established by a cooling rate study:
Appropriate records (e.g., processing record showing the results of the time and temperature checks and/or volume of product in cooler).

Before a temperature-indicating device (e.g., a thermometer) or temperature- recording device (e.g., a time and temperature data logger) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used
TABLE 12-4
CONTROL STRATEGY EXAMPLE 3 - COOLING AFTER COOKING CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Cooling After Cooking Control. This example illustrates how a dungeness crabmeat processor can control pathogenic bacteria growth and toxin formation as a result of time and temperature abuse during cooling after cooking. In this case, the product is fully cooled, i.e., to 40F (4.4C), after cooking before significant handling. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(1)
(2)
Cooked crab cooler Approximately every 2 hours during cooking Cooked crab internal temperature Dial thermometer in marked batches of cooked crabs
Length of cooling cycle
Clock
Start marked batch
Destroy product Make adjustment or repairs to cooler
Production record
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse Crabs cooled from 135F to 70F in 2 hours and 70F to 40F in 4 more hours Check the dial thermometer for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
233
Note: Control during unrefrigerated processing is covered under Control Strategy Example 4 - Unrefrigerated Processing Control. Note: Control is necessary at this step because the processor has not established that the cook step is adequate to kill the spores of C. perfringens or B. cereus
CONTROL STRATEGY EXAMPLE 4 UNREFRIGERATED PROCESSING CONTROL
OR CRITICAL LIMIT 3: The product is held at internal temperatures below 50F (10C)
throughout processing,
OR

The following recommended critical limits are intended to keep the pathogenic bacteria of greatest concern in fish and fishery products from reaching the rapid growth phase (i.e., keep them in the lag phase) as a result of time and temperature exposure during processing. You may also wish to reference Table A-2 (Appendix 4), which provides cumulative time and temperature combinations for the pathogenic bacteria individually. For raw, ready-to-eat products: CRITICAL LIMIT 1: If at any time the product is held at internal temperatures above 70F (21.1C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 2 hours (3 hours if S. aureus is the only pathogen of concern), OR
Alternatively, the product is held at

ambient air temperatures below 50F (10C) throughout processing.
For cooked, ready-to-eat products:

Note: The critical limits for cooked, ready-to-eat products are intended to begin at the completion of cooling or at the time that the product is first significantly handled after cooking, whichever occurs first.
CRITICAL LIMIT 1: If at any time the product is held at internal temperatures above 80F (26.7C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 1 hour (3 hours if S. aureus is the only pathogen of concern), OR
Alternatively, exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 2 of those hours are between 70F (21.1C) and 135F (57.2C);
Alternatively, if at any time the product is held at internal temperatures above 80F (26.7C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 1 of those hours is above 70F (21.1C);
OR CRITICAL LIMIT 2: If at any time the product is held at internal temperatures above 70F (21.1C) but never above 80F (26.7C), exposure time at internal temperatures above 50F (10C) should be limited to 2 hours (3 hours if S. aureus is the only pathogen of concern),
OR CRITICAL LIMIT 2: If at any time the product is held at internal temperatures above 50F (10C) but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern);
234
OR
Alternatively, if the product is never held at internal temperatures above 80F (26.7C), exposure times at internal temperatures above 50F (10C) should be limited to 4 hours, as long as no more than 2 of those hours are above 70F (21.1C);
OR CRITICAL LIMIT 3: If at any time the product is held at internal temperatures above 50F (10C) but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern); OR CRITICAL LIMIT 4: The product is held at internal temperatures below 50F (10C)
throughout processing,
OR
Example: A crabmeat processor using a retort process identifies a series of post-cook processing steps (e.g., backing, picking, and packing) as CCPs for pathogenic bacteria growth and toxin formation. Initial cooling takes place in the cooking crates and then the product is first handled at temperatures of around 120F (48.9C). The processor sets a critical limit of maximum cumulative time of exposure of 4 hours at product internal temperatures above 50F (10C), no more than 1 of which is above 70F (21.1). This critical limit is selected because the crabs are handled while still warm (e.g., above 80F (26.7C)). Cooling that takes place after the product is handled is included in the limit. Example: Another crabmeat processor using a retort process also identifies a series of post-cook processing steps (e.g., backing, picking, and packing) as CCPs. However, this product is cooled fully before handling, and ice is used on the product during processing to control time and temperature abuse. The processor sets a critical limit of a maximum product internal temperature of 50F (10C) at all times. Specifying a time of exposure is not necessary in this case, because it is not reasonably likely that the product would be held long enough that significant pathogen growth could occur at this temperature (e.g., 2 to 21 days, depending upon the pathogen).
Alternatively, the product is held at

ambient air temperatures below 50F (10C) throughout processing.
Note: The preceding recommended critical limits do not address internal product temperatures between 40F (4.4C), the recommended maximum storage temperature for refrigerated fish and fishery products, and 50F (10C). The recommended critical limits do not address such temperatures because growth of foodborne pathogenic bacteria is very slow at these temperatures and the time necessary for significant growth is longer than would be reasonably likely to occur in most fish and fishery product processing steps. However, if you have processing steps that occur at these temperatures that approach the maximum cumulative exposure times listed in Table A-2 (Appendix 4) for the pathogenic bacteria of concern in your product, you should consider development of a critical limit for control at these temperatures. The cumulative time and temperature critical limits above (other than the last critical limit for raw, ready-to-eat and cooked, ready-to-eat fish and fishery products) are depicted in table format below:
235
TABLE 12-5
CUMULATIVE TIME AND TEMPERATURE CRITICAL LIMITS

WHEN THE PRODUCT INTERNAL TEMPERATURE RANGE IN F (C) IS THEN THE CUMULATIVE EXPOSURE TIME AT INTERNAL TEMPERATURES ABOVE 50F (10C) IN HOURS IS1 1 2 3 5 12
RAW, READY TO EAT
>50 (>10)
3
X2
Alternatively, >50 to 70 (>10 to 21.1) Plus >70 (>21.1) Alternatively, >50 to 70 (>10 to 21.1) Plus >70 (>21.1) >50 to 70 (>10 to 21.1)
COOKED, READY TO EAT
X X
X2
>50 (>10)
4
X2 X
Alternatively, >50 to 70 (>10 to 21.1) Plus >704 (>21.1) >50 to 80 (>10 to 26.7) Alternatively, >50 to 70 (>10 to 21.1) Plus >70 to <80 (>21.1 to <26.7) Alternatively, >50 to 70 (>10 to 21.1) Plus >70 to <80 (>21.1 to <26.7) >50 to 70 (>10 to 21.1)
1. 2. 3. 4.
X2 X
X2
Time at temperatures of 135F (57.2C) and above is not counted. Where S. aureus is the only pathogen of public health significance. Temperature may exceed 70F (21.1C). Temperature may exceed 80F (26.7C).
236

The length of time of product exposure to unrefrigerated conditions (i.e., above 40F (4.4C));
Make visual observations of length of exposure to unrefrigerated conditions (i.e.,

>40F (4.4C)) using a clock.
Example: A crabmeat processor identifies a series of processing steps (e.g., backing, picking, and packing) as CCPs for pathogenic bacteria growth. The processor establishes a critical limit of no more than 1 cumulative hour of exposure to unrefrigerated temperature during these processing steps (Critical Limit 1). The processor uses marked product containers to monitor the progress of the product through the three processing steps. The time that the marked container is removed from and returned to refrigeration is monitored using a clock. Example: Another crabmeat processor with identical CCPs establishes a more complex set of critical limits: no more than 4 cumulative hours with product internal temperatures above 50F (10C), with no more than 1 of those hours above 70F (21.1C) (Critical Limit 1 Alternative). This processor also uses marked containers to monitor the progress of the product through the process. However, in addition to monitoring time using a clock, the processor also monitors product internal temperature for the marked containers using a thermometer. This monitoring technique provides the processor more flexibility in processing but requires more monitoring effort. Example: A lobster meat processor identifies the meat removal process as a CCP for pathogenic bacteria growth. The operation is performed under near-refrigeration conditions (<50F (10C)) (Critical Limit 4 Alternative). The processor monitors ambient air temperature with a digital data logger.
The product internal temperature during the exposure period; OR The ambient temperature of the processing area;
OR
The length of time only of product exposure to unrefrigerated conditions (i.e., >40F (4.4C)), for critical limit 1 (raw, ready-to-eat and cooked, ready-to-eat); OR The internal temperature only of the product, when internal temperatures are held below 50F (10C) or above 135F (57.2C) throughout processing for critical limit 3 for raw, ready-to-eat or critical limit 4 for cooked, ready-to-eat; OR The ambient air temperature only, when ambient air temperature is held below 50F (10C) throughout processing for critical limit 3 for raw, ready-to-eat or critical limit 4 for cooked, ready-to-eat.

For product internal temperature or ambient air temperature:
Use a temperature-indicating device (e.g., a thermometer);
OR
For ambient air temperature:
AND/OR
237

Continuous monitoring during processing is accomplished by the device itself, with a visual check of the recorded data at least once per day;
Divert the product to a use in which the critical limit is not applicable (e.g., divert crabmeat to a stuffed flounder operation), after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat; OR Destroy the product; OR Divert the product to a non-food use. AND
OR For temperature-indicating devices and clocks:

OR
Every batch.

For continuous temperature recording devices:
Add ice to the product; OR Return the affected product to the cooler; AND Modify the process as needed to reduce the time and temperature exposure.

Processing records showing the results of time and/or temperature exposure measurements.
OR For temperature-indicating devices and clocks:

Before a temperature-indicating device (e.g., a thermometer) or temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:

Chill and hold the affected product until an evaluation of the total time and temperature exposure is performed; OR Cook the product, after giving consideration to the fact that any S. aureus or B. cereus toxin that may be present may not be inactivated by heat; OR
238
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary;
OR
Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature and product internal temperature) within the temperature range at which it will be used;
or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Where appropriate to the critical limit, by using a study that establishes the relationship between exposure time and product temperature; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration
239
TABLE 12-6
CONTROL STRATEGY EXAMPLE 4 - UNREFRIGERATED PROCESSING CONTROL
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Unrefrigerated Processing Control. This example illustrates how a blue crabmeat processor that handles the crabs at the beginning of backing while still hot can control pathogenic bacteria growth and toxin formation as a result of time and temperature abuse during unrefrigerated processing. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.

(3) MONITORING WHAT HOW FREQUENCY WHO (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
RECORDS
VERIFICATION
Backing, in-process cooler, picking, and packing
The length of time of product exposure to unrefrigerated conditions (i.e., above 40F) The product internal temperature during the exposure period Dial thermometer
Exposure time (i.e., time at internal temperatures above 50F but below 135F) during backing, inprocess cooler, picking, and packing should be limited to 4 hours, as long as no more than 1 of those hours is above 70F
Visual observation of marked containers using a clock
Start marked container approximately every 2 hours during backing, in-process cooler, picking, and packing
Immediately ice product or move to cooler Hold and evaluate based on total time and temperature exposure
Production record
CHAPTER 12: Pathogenic Bacteria Growth and Toxin Formation (Other Than Clostridium botulinum) as a Result of Time and Temperature Abuse Check the dial thermometer for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, verification, and corrective action records within 1 week of preparation
240
Note: Control during refrigerated storage is covered under Control Strategy Example 2 - Refrigerated Storage and Refrigerated Processing Control. Note: This critical limit is necessary because the crabs are handled at internal temperatures above 80F during backing
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Gecan, J. S., R. Bandler, and W. F. Staruskiewcz. 1994. Fresh and frozen shrimp: a profile of filth, microbiological contamination, and decomposition. J. Food Prot. 57:154158. Hood, M. A., G. E. Ness, G. E. Rodrick, and N. J. Blake. April 1983. Effects of storage on microbial loads of two commercially important shellfish species, Crassostrea virginica and Mercenaria campechiensis. Appl. Environ. Microbiol. 45:12211228. Huss, H. H., 1993. Assurance of seafood quality. FAO fisheries technical paper, no. 334. FAO, Rome, Italy. 169p. Huss, H. H. (ed.). 1993. Quality and quality changes in fresh fish. FAO fisheries technical paper, no. 346. FAO, Rome, Italy. Huss, H. H. 1997. Control of indigenous pathogenic bacteria in seafood. Food Control. 8:9198. Jemmi, T., and A. Keusch. 1992. Behavior of Listeria monocytogenes during processing and storage of experimentally contaminated hot-smoked trout. Int. J. Food Microbiol. 15:339346. Huss, H. H., A. Reilly, and P. K. Ben Embarek. 2000. Prevention and control of hazards in seafood. Food Control. 11:149156. Jrgensen, L. V., and H. H. Huss. 1998. Prevalence and growth of Listeria monocytogenes in naturally contaminated seafood. Int. J. Food Microbiol. 42:127131. Leung, C. K., Y. W. Huang, and M. A. Harrison. 1992. Fate of Listeria monocytogenes and Aeromonas hydrophila on packaged channel catfish fillets stored at 4 C. J. Food Prot. 55:728730. Morris, G. J., and R. E. Black. 1985. Cholera and other vibrioses in the United States. New Engl. J. Med. 12:343350. Nielsen, H.-J. S., and P. Zeuthen. 1984. Growth of pathogenic bacteria in sliced vacuum-packed bologna-type sausage
as influenced by temperature and gas permeability of packaging film. Food Microb. 1:229243. Palumbo, S. A. 1986. Is refrigeration enough to restrain foodbourne pathogens? J. Food Prot. 49: 10031009. Peixotto, S. S., G. Finne, M. O. Hanna, and C. Vanderzant. 1979. Presence, growth and survival of Yersinia entercolitica in oysters, shrimp and crab. J. Food Prot. 42:974981. Peterson, M. E., G. A. Pelroy, R. N. Paranjpye, F. T. Poysky, J. S. Almond, and M. W. Eklund. 1993. Parameters for control of Listeria monocytogenes in smoked fishery products: sodium chloride and packaging method. J Food Prot. 56:938943. Philips, F. A., and T. Peeler. December 1972. Bacteriological survey of the blue crab industry. Appl. Microbiol. 24(6):958966. Rahmati, T., and R. Labbe. 2007. Incidence and enterotoxigenicity of Clostridium perfringens and Bacillus cereus from retail seafood. IAFP Annual Meeting. P128. Refrigerated Foods and Microbiological Criteria Committee of the National Food Processors Association. 1988. Factors to be considered in establishing good manufacturing practices for the production of refrigerated foods. Dairy and Food Sanit. 8:288291. Rivituso, C. P. and Snyder, O. P. 1981. Bacterial growth at foodservice operating temperatures. J. Food Prot. 44:770775. Rodrguez, ., V. Losada, S. P. Aubourg, and J. Barros-Velzquez. 2004. Enhanced shelf-life of chilled European hake (Merluccius merluccius) stored in slurry ice as determined by sensory analysis and assessment of microbiological activity.Food Res. Intl. 37(8):749757. Rosso, L., J. R. Lobry, J. P. Flandrois. 1993 An unexpected correlation between cardinal temperature of microbial growth highlighted by a new mode. J. Theor. Biol. 162:447463.
Rosso, L., S. Bajard, J. P. Flandrois, C. Lahellec, J. Fournaud, and P. Veit. 1996. Differential growth of Listeria monocytogenes at 4 and 8C: consequences for the shelf life of chilled products. 59:944949. Satoshi, I., A. Nakama, Y. Arai, Y. Kokubo, T. Maruyama, A. Saito, T. Yoshida, M. Terao, S. Yamamoto, and S. Kumagai. 2000. Prevalence and contamination levels of Listeria monoocytogenes in retail foods in Japan. Int. J. Food Microb. 59:7377. Son, N. T., and G. H. Fleet. December 1980. Behavior of pathogenic bacteria in the oyster, Crassostrea commercialis, during depuration, relaying and storage. Appl. Environ. Microbiol. 40(6):9941002. U.S. Food and Drug Administration. Foodborne pathogenic microorganisms and natural toxins handbook. In The bad bug book. http://www.fda.gov/ Food/FoodSafety/FoodborneIllness/ rneIllnessFoodbornePathogensNaturalToxins/ BadBugBook/default.htm. U.S. Food and Drug Administration. 2009. Food code. Department of Health and Human Services, Public Health Service, FDA, Center for Food Safety and Applied Nutrition, College Park, MD. http://www.fda.gov/Food/ FoodSafety/RetailFoodProtection/FoodCode/ FoodCode2009/default.htm. U.S. Food and Drug Administration. 2005. Quantitative risk assessment on the public health impact of pathogenic Vibrio parahaemolyticus in raw oysters. Department of Health and Human Services, Public Health Service, FDA, Center for Food Safety and Applied Nutrition, College Park, MD. http://www.fda.gov/Food/ScienceResearch/ ResearchAreas/RiskAssessmentSafetyAssessment/ ucm050421.htm U.S. Food and Drug Administration and U.S. Department of Agriculture. 2003. Quantitative assessment of the relative risk to public health from foodborne Listeria monocytogenes among selected categories of ready-to-eat foods.
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http://www.fda.gov/Food/ScienceResearch/ ResearchAreas/RiskAssessmentSafetyAssessment/ ucm183966.htm. Wallace, B. J., J. J. Guzewich, M. Cambridge, and S. Altekruse. 1999. Seafood-associated disease outbreaks in New York, 1980-1994. Amer. J. Prev. Med. 17:4854. Ward, D. R, and C. R. Hackney (ed.). 1991. Microbiology of marine food products. Van Nostrand Reinhold, New York, NY. Wentz, B. A., A. P. Duran, A. Swartzentruber, A. H. Schwab, F. D. McClure, D. Archer, and R. B. Read, Jr. 1985. Microbiological quality of crabmeat during processing. J. Food Prot. 48:4449. Wong, H.-C., M.-C. Chen, S.-H. Liu, and D. P. Lin. 1999. Incidence of highly genetically diversified Vibrio parahaemolyticus in seafood imported from Asian countries. Int. J. Food Microbiol. 52:181188.
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NOTES:
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CHAPTER 13: Clostridium botulinum Toxin Formation


Clostridium botulinum (C. botulinum) toxin formation can result in consumer illness and death. It is the toxin responsible for botulism. About 10 outbreaks of foodborne botulism occur annually in the United States, from all sources. Symptoms include: weakness, vertigo, double vision, difficulty in speaking, swallowing and breathing, abdominal swelling, constipation, paralysis, and death. Symptoms start from 18 hours to 36 hours after consumption. Everyone is susceptible to intoxication by C. botulinum toxin; only a few micrograms of the toxin can cause illness in a healthy adult. Mortality is high; without the antitoxin and respiratory support, death is likely. This chapter covers the hazard of C. botulinum growth and toxin formation as a result of time and temperature abuse during processing, storage, and distribution. Strategies for controlling pathogen growth There are a number of strategies for the control of pathogens in fish and fishery products. They include: Controlling the level of acidity (pH) in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable acidified products, and by this chapter for refrigerated acidified products); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in this chapter);
Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in this chapter); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the introduction of pathogenic bacteria after the pasteurization process and after the cooking process performed immediately before reduced oxygen packaging (covered in Chapter 18); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 4); Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for C. botulinum, in this chapter; and for Staphylococcus aureus (S. aureus) in hydrated batter mixes, in Chapter 15); Killing pathogenic bacteria by cooking or pasteurization (covered in Chapter 16), or retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (hereinafter, the Low-Acid Canned Foods (LACF) Regulation)); Killing pathogenic bacteria by processes that retain the raw product characteristics (covered in Chapter 17).
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Formation of C. botulinum toxin When C. botulinum grows, it can produce a potent toxin, one of the most poisonous naturally occurring substances known. The toxin can be destroyed by heat (e.g., boiling for 10 minutes), but, because of its potency, you should not rely on this as a means of control. The strains of C. botulinum can be divided into two groups, the proteolytic group (i.e., those that break down proteins) and the non proteolytic group (i.e., those that do not break down proteins). The proteolytic group includes C. botulinum type A and some of types B and F. The non-proteolytic group includes C. botulinum type E and some of types B and F. The vegetative cells of all types of C. botulinum are easily killed by heat. However, C. botulinum is able to produce spores. In this state, the pathogen is very resistant to heat. The spores of the proteolytic group are much more resistant to heat than are those of the non-proteolytic group (i.e., they require a canning process to be destroyed). Table A-4 (Appendix 4) provides guidance about the conditions under which the spores of the most heat-resistant form of non-proteolytic C. botulinum, type B, are killed. However, there are some indications that substances that may be naturally present in some products (e.g., dungeness crabmeat), such as lysozyme, may enable non-proteolytic C. botulinum to more easily recover after heat damage, resulting in the need for a considerably more stringent process to ensure destruction. C. botulinum is able to produce toxin when a product in which it is present is exposed to temperatures favorable for growth for sufficient time. Table A-1 (Appendix 4) provides guidance about the conditions under which C. botulinum and other pathogenic bacteria are able to grow. Table A-2 (Appendix 4) provides guidance about the time necessary at various temperatures for toxin formation to occur. Packaging conditions that reduce the amount of oxygen present in the package (e.g., vacuum
packaging and modified atmosphere packaging) extend the shelf life of a product by inhibiting the growth of aerobic spoilage bacteria. There is a safety concern with these products because there is an increased potential for the formation of C. botulinum toxin before spoilage makes the product unacceptable to consumers. C. botulinum forms toxin more rapidly at higher temperatures than at lower temperatures. The minimum temperature for growth and toxin formation by C. botulinum type E and non proteolytic types B and F is 38F (3.3C). For type A and proteolytic types B and F, the minimum temperature for growth is 50F (10C). As the shelf life of refrigerated foods is increased, more time is available for C. botulinum growth and toxin formation. As storage temperatures increase, the time required for toxin formation is significantly shortened. You should expect that at some point during storage, distribution, display, or consumer handling of refrigerated foods, safe refrigeration temperatures will not be maintained (especially for the non-proteolytic group). Surveys of retail display cases indicate that temperatures of 45 to 50F (7 to 10C) are not uncommon. Surveys of home refrigerators indicate that temperatures can exceed 50F (10C). In reduced oxygen packaged products in which the spores of non-proteolytic C. botulinum are inhibited or destroyed (e.g., smoked fish, pasteurized crabmeat, and pasteurized surimi), a normal refrigeration temperature of 40F (4.4C) is appropriate because it will limit the growth of proteolytic C. botulinum and other pathogens that may be present. Even in pasteurized products where non-proteolytic C. botulinum is the target organism for the pasteurization process, and vegetative pathogens, such as Listeria monocytogenes, are not likely to be present (e.g., pasteurized crabmeat and pasteurized surimi), a storage temperature of 40F (4.4C) is still appropriate because of the potential for survival through the pasteurization process and recovery of spores of non-proteolytic C. botulinum, aided by naturally occurring
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substances, such as lysozyme. In this case, refrigeration serves as a prudent second barrier. However, in reduced oxygen packaged products in which refrigeration is the sole barrier to outgrowth of non-proteolytic C. botulinum and the spores have not been destroyed (e.g., vacuumpackaged refrigerated raw fish, vacuum-packaged refrigerated unpasteurized crayfish meat, and reduced oxygen packaged unpasteurized dungeness crabmeat), the temperature should be maintained below 38F (3.3C) from packing to consumption. Ordinarily you, as a processor, can ensure that temperatures are maintained below 38F (3.3C) while the product is in your control. However, the current U.S. food distribution system does not ensure the maintenance of these temperatures after the product leaves your control. The use of a Time-Temperature Indicator (TTI) on each consumer package may be an appropriate means of overcoming these problems in the distribution system for reduced oxygen packaged products in which refrigeration is the sole barrier to outgrowth of non-proteolytic C. botulinum and in which the spores have not been destroyed. A TTI is a device that monitors the time and temperature of exposure of the package and alerts the consumer or end user if a safe exposure limit has been exceeded. If a TTI is used, it should be validated to ensure that it is fit for its intended purpose and verified that it is functional at the time of use. It should be designed to alert the consumer (e.g., a color change) that an unsafe time and temperature exposure has occurred that may result in C. botulinum toxin formation. Additionally, the alert should remain perpetually visible after it has been triggered, regardless of environmental conditions that could reasonably be expected to occur thereafter. Skinner, G. E., and J. W. Larkin in Conservative prediction of time to Clostridium botulinum toxin formation for use with time-temperature indicators to ensure the safety of foods, Journal of Food Protection, 61:1154-1160 (1998), describe a safe time and temperature exposure curve (Skinner-Larkin curve) that may be useful in evaluating the suitability of a TTI for control of C. botulinum
toxin formation in reduced oxygen packaged fish and fishery products. Alternatively, products of this type may be safely marketed frozen, with appropriate labeling to ensure that it is held frozen throughout distribution. For some reduced oxygen packaged products, control of C. botulinum can be achieved by breaking the vacuum seal before the product leaves the processors control. The guidance in this chapter emphasizes preventive measures for the control of non proteolytic strains of C. botulinum in products that are contained in reduced oxygen packaging. As was previously described, this emphasis is because such an environment extends the shelf life of a refrigerated product in a way that, under moderate temperature abuse, favors C. botulinum growth and toxin formation over aerobic spoilage. It is also possible for both non-proteolytic and proteolytic C. botulinum to grow and produce toxin in a product that is not reduced oxygen packaged and is subjected to severe temperature abuse. This is the case because of the development within the product of microenvironments that support its growth. However, this type of severe temperature abuse of refrigerated products is not reasonably likely to occur in the processing environment of most fish or fishery products and the Current Good Manufacturing Practice in Manufacturing, Packing, or Holding Human Food regulation, 21 CFR 110, requires refrigeration of foods that support the growth of pathogenic microorganisms. Sources of C. botulinum C. botulinum can enter the process on raw materials. The spores of C. botulinum are very common. They have been found in the gills and viscera of finfish, crabs, and shellfish. C. botulinum type E is the most common form found in freshwater and marine environments. Types A and B are generally found on land but may also be occasionally found in water. It should be assumed that C. botulinum will be present in any raw fishery product, particularly in the viscera.
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Because spores are known to be present in the viscera, any product that will be preserved by salting, drying, pickling, or fermentation should be eviscerated prior to processing (see the Compliance Policy Guide, Sec. 540.650). Without evisceration, toxin formation is possible during the process, even with strict control of temperature. Evisceration of fish is the careful and complete removal of all internal organs in the body cavity without puncturing or cutting them, including gonads. If even a portion of the viscera or its contents is left behind, the risk of toxin formation by C. botulinum remains. Uneviscerated small fish, less than 5 inches in length (e.g., anchovies and herring sprats), for which processing eliminates preformed toxin, prevents toxin formation during processing and that reach a water phase salt content of 10% in refrigerated finished products, or a water activity of below 0.85 in shelf-stable finished products, or a pH of 4.6 or less in shelfstable finished products, are not subject to the evisceration recommendation.
Note: The water phase salt content of 10% is based on the control of C. botulinum type A and proteolytic types B and F. Note: The water activity value of below 0.85 is based on the minimum water activity for toxin production of S. aureus.
packaging) may be rapidly depleted by the activity of spoilage bacteria, resulting in the formation of a reduced oxygen environment. Packaging that provides an oxygen transmission rate (in the final package) of at least 10,000 cc/ m2/24 hours at 24C can be regarded as an oxygen-permeable packaging material for fishery products. The oxygen transmission rate of packaging material is listed in the packaging specifications that can be obtained from the packaging manufacturer. An oxygen-permeable package should provide sufficient exchange of oxygen to allow aerobic spoilage organisms to grow and spoil the product before toxin is produced under moderate abuse temperatures. Particular care should be taken in determining the safety of a packaging material for a product in which the spoilage organisms have been eliminated or significantly reduced by processes such as high pressure processing. The generally recommended 10,000 cc/m2/24 hours at 24C transmission rate may not be suitable in this case. Use of an oxygen-permeable package may not compensate for the restriction to oxygen exchange created by practices such as packing in oil or in deep containers from which the air is expressed or the use of oxygen scavengers in the packaging. Control of C. botulinum There are a number of strategies to prevent C. botulinum growth and toxin formation during processing, storage, and distribution of finished fish and fishery products. They include:
For products that do not require refrigeration (i.e., shelf-stable products):
Reduced oxygen packaging A number of conditions can result in the creation of a reduced oxygen environment in packaged fish and fishery products. They include: Vacuum, modified, or controlled atmosphere packaging. These packaging methods generally directly reduce the amount of oxygen in the package; Packaging in hermetically sealed containers (e.g., double-seamed cans, glass jars with sealed lids, and heat-sealed plastic containers), or packing in deep containers from which the air is expressed (e.g., caviar in large containers), or packing in oil. These and similar processing and packaging techniques prevent the entry of oxygen into the container. Any oxygen present at the time of packaging (including oxygen that may be added during modified atmosphere
Heating the finished product in its final container sufficiently by retorting to destroy the spores of C. botulinum types A B, E, and F (e.g., canned fish). This strategy is covered by the LACF Regulation, 21 CFR 113, and these controls are not required to be included in your Hazard Analysis Critical Control Point (HACCP) plan;
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Controlling the level of acidity (pH) in the finished product to 4.6 or below, to prevent growth and toxin formation by C. botulinum types A, B, E, and F (e.g., shelf-stable acidified products). This strategy is covered by the Acidified Foods regulation, 21 CFR 114, and these controls are not required to be included in your HACCP plan; Controlling the amount of moisture that is available in the product (water activity) to 0.85 or below by drying, to prevent growth and toxin formation by C. botulinum types A, B, E, and F and other pathogens that may be present in the product (e.g., shelf-stable dried products). This strategy is covered by Chapter 14;
Controlling the amount of salt in the product to 20% water phase salt (wps) or more, to prevent the growth of C. botulinum types A, B, E, and F and other pathogens that may be present in the product (e.g., shelf-stable salted products). This strategy is covered in this chapter. Water phase salt is the concentration of salt in the water-portion of the fish flesh and calculated as follows: (% NaCl X 100)/(% NaCl + % moisture) = % NaCl in water phase. The relationship between percent water phase salt and water activity in fish is described in the following graph.
Relationship of Water Activity to Water Phase Salt in NaCl/Water Solutions

1
1.00 0.98 0.96 0.94 0.92 0.90 0.88 0.86 0.84
Water ac tivity
6 8 10 12 14 16 Percent water phase salt
18 20
1. This relationship is generally valid for fish products when salt (sodium chloride) is the primary means of binding water. The specific food matrix and the use of other salts or water binding agents could affect the exact relationship. If you intend to use this relationship in your control strategy, you should determine the exact relationship in your product by conducting a study.
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For products that require refrigeration:
Heating the finished product in its final container sufficiently by pasteurization to destroy the spores of C. botulinum type E and non-proteolytic types B and F, and then minimizing the risk of recontamination by controlling seam closures and cooling water, and next controlling the growth of the surviving C. botulinum type A and proteolytic types B and F in the finished product with refrigerated storage (e.g.. pasteurized crabmeat and some pasteurized surimi-based products). Pasteurization is covered in Chapter 16, controlling recontamination after pasteurization is covered in Chapter 18, and controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter; Heating the product sufficiently to destroy the spores of C. botulinum type E and non-proteolytic types B and F, and then minimizing the risk of recontamination by hot filling the product into the final container in a sanitary, continuous, closed filling system and controlling seam closures and cooling water, and next controlling the growth of the surviving C. botulinum type A and proteolytic types B and F and other pathogens that may be present in the finished product with refrigerated storage (e.g., vacuum packed soups, chowders, and sauces). Specialized cooking processes are covered in Chapter 16, prevention of recontamination after specialized cooking processes is covered in Chapter 18, controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12; Controlling the amount of moisture that is available in the product (water activity) to 0.97 or below to inhibit the growth of C. botulinum type E and non-proteolytic types B and F by drying, and then controlling the growth of C. botulinum
type A and proteolytic types B and F and other pathogens that may be present in the finished product through refrigerated storage (e.g., refrigerated dried fish). Drying is covered in Chapter 14, controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12; Controlling the level of pH to 5 or below, salt to 5% wps or more, moisture (water activity) to 0.97 or below, or some combination of these barriers, in the finished product sufficiently to prevent the growth of C. botulinum type E and non-proteolytic types B and F by formulation, and then controlling the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present in the finished product with refrigerated storage (e.g., refrigerated acidified (pickled) products). Controlling the growth of nonproteolytic C. botulinum through formulation is covered in this chapter, controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12; Controlling the amount of salt and preservatives, such as sodium nitrite, in the finished product, in combination with other barriers, such as smoke, heat damage, and competitive bacteria, sufficiently to prevent the growth of C. botulinum type E and non-proteolytic types B and F, and then controlling the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present in the finished product with refrigerated storage (e.g., salted, smoked, or smoke-flavored fish). Controlling the growth of non-proteolytic C. botulinum through salting and smoking is covered in this chapter, controlling the growth of proteolytic C. botulinum through
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refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12; Controlling the amount of salt in the finished product, in combination with heat damage from pasteurization in the finished product container, sufficiently to prevent the growth of C. botulinum type E and nonproteolytic types B and F, and then controlling the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present in the finished product with refrigerated storage (e.g., some pasteurized surimi based products). Controlling the growth of non-proteolytic C. botulinum through a combination of salt and heat damage is covered in this chapter, controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12.
Examples of C. botulinum control in specific products:
In hot-smoked products, heat damage to the spores of C. botulinum type E and non proteolytic types B and F also helps prevent toxin formation. In these products, control of the heating process is critical to the safety of the finished product. It is important to note, however, that this same heating process also reduces the numbers of naturally occurring spoilage organisms. The spoilage organisms would otherwise have competed with, and inhibited the growth of, C. botulinum. In cold-smoked fish, it is important that the product does not receive so much heat that the numbers of spoilage organisms are significantly reduced. This is important because spoilage organisms must be present to inhibit the growth and toxin formation of C. botulinum type E and non-proteolytic types B and F. This inhibition is important in cold-smoked fish because the heat applied during this process is not adequate to weaken the C. botulinum spores. Control of the temperature during the cold-smoking process to ensure survival of the spoilage organisms is, therefore, critical to the safety of the finished product. The interplay of these inhibitory effects (i.e., salt, temperature, smoke, and nitrite) is complex. Control of the brining or dry salting process is clearly critical to ensure that there is sufficient salt in the finished product. However, preventing toxin formation by C. botulinum type E and non-proteolytic types B and F is made even more complex by the fact that adequate salt levels are not usually achieved during brining. Proper drying during smoking is also critical in order to achieve the finished product water phase salt level (i.e., the concentration of salt in the water portion of the fish flesh) needed to inhibit growth and toxin formation by C. botulinum. This chapter covers the control procedures described above.
Refrigerated (not frozen), reduced oxygen

packaged smoked and smoke-flavored fish
Achieving the proper concentration of salt and nitrite in the flesh of refrigerated, reduced oxygen packaged smoked and smoke-flavored fish is necessary to prevent the formation of toxin by C. botulinum type E and non-proteolytic types B and F during storage and distribution. Salt works along with smoke and any nitrites that are added to prevent growth and toxin formation by C. botulinum type E and non-proteolytic types B and F. Note that nitrites should be used only in salmon, sable, shad, chubs, and tuna, according to 21 CFR 172.175 and 21 CFR 172.177 , and should not exceed a level of 200 ppm in salmon, sable, shad, chubs and 10 ppm in tuna.
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You should ordinarily restrict brining, dry salting, and smoking loads to single species and to fish portions of approximately uniform size. This restriction minimizes the complexity of controlling the operation. You should treat brine to minimize microbial contamination or periodically replace it as a good manufacturing practice control. The combination of inhibitory effects that are present in smoked and smoke-flavored fish are not adequate to prevent toxin formation by C. botulinum type A and proteolytic types B and F. Strict refrigeration control (i.e., at or below 40F (4.4C)) during storage and distribution should be maintained to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F and other pathogens that may be present in these products. Controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the growth of other pathogenic bacteria through refrigeration is covered in Chapter 12. Refrigerated (not frozen), reduced oxygen
packaged, pasteurized fishery products
also serves as a prudent second barrier because of the potential survival through the pasteurization process and recovery of spores of non-proteolytic C. botulinum, aided by naturally occurring substances, such as lysozyme. Cooking and pasteurization are covered in Chapter 16, and controlling the growth of C. botulinum through refrigeration is covered in this chapter. In the second category of products, filling the product into the final container while it is still hot in a continuous, closed filling system (i.e., hot filling) is also critical to the safety of the finished product because it minimizes the risk of recontamination of the product with pathogens, including C. botulinum type E and non-proteolytic types B and F. This control strategy applies to products such as soups, chowders, and sauces that are filled directly from the cooking kettle, where the risk of recontamination is minimized. It may not apply to products such as crabmeat, lobster meat, or crayfish meat or to other products that are handled between cooking and filling. Control of hot filling is covered in Chapter 18. Chapter 18 also covers other controls that may be necessary to prevent recontamination, including controlling container sealing and controlling contamination of container cooling water. These controls may be critical to the safety of both categories of products. Examples of properly pasteurized products follow: fish and fishery products generally (e.g., surimi-based products, soups, or sauces) pasteurized to a minimum cumulative total lethality of F194F (F90C) = 10 minutes, where z = 12.6F (7C) for temperatures less than 194F (90C), and z = 18F (10C) for temperatures above 194F (90C); blue crabmeat pasteurized to a minimum cumulative total lethality of F185F (F85C) = 31 minutes, where z = 16F (9C); and dungeness crabmeat pasteurized to a minimum cumulative total lethality of F194F (F90C) = 57 minutes, where z = 15.5F
Refrigerated, reduced oxygen packaged, pasteurized fishery products fall into two categories: (1) those which are pasteurized in the final container; and (2) those which are cooked in a kettle and then hot filled into the final container in a continuous, closed filling system (e.g., heat-and-fill soups, chowders, and sauces). In both cases, ordinarily the heating process should be sufficient to destroy the spores of C. botulinum type E and non-proteolytic types B and F. In neither case is it likely that the heating process will be sufficient to destroy the spores of C. botulinum type A and proteolytic types B and F. Therefore, strict refrigeration control (i.e., at or below 40F (4.4C)) should be maintained during storage and distribution to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F. Refrigeration
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(8.6C). Equivalent processes at different temperatures can be calculated using the z values provided.
EXAMPLES OF PROPERLY PASTEURIZED PRODUCTS
PRODUCT MINIMUM CUMULATIVE TOTAL LETHALITY Z VALUE
Adding sufficient acid to reduce the acidity (pH) to 5.0 or below; Reducing the amount of moisture that is available for growth (water activity) to below 0.97 (e.g., by adding salt or other substances that bind the available water); or Making a combination of salt, pH, and/or water activity adjustments that, when combined, prevents the growth of C. botulinum type E and non-proteolytic types B and F (to be established by a scientific study). Much like smoked products, in some of these products the interplay of these inhibitory effects (i.e., salt, water activity, and pH) can be complex. Control of the brining, pickling, or formulation steps is, therefore, critical to ensure that there are sufficient barriers in the finished product to prevent the growth and toxin formation of C. botulinum type E and non-proteolytic types B and F during storage and distribution. These control procedures are covered in this chapter. You should ordinarily restrict brining and pickling loads to single species and to fish portions of approximately uniform size. This restriction minimizes the complexity of controlling the operation. You should treat brine to minimize microbial contamination or periodically replace it as a good manufacturing practice control. The controls discussed above are not sufficient to prevent toxin formation by C. botulinum type A and proteolytic types B and F. Strict refrigeration control (i.e., at or below 40F (4.4C)) during storage and distribution should, therefore, be maintained to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F and other pathogens that may be present in these products. Controlling the growth of proteolytic C. botulinum through refrigeration is covered in this chapter, and controlling the
Fish and fishery products generally (e.g., surimi based products, soups, or sauces) Blue crabmeat Dungeness crabmeat
F194F (F90C) = 10 minutes
12.6F (7C), for temperatures less than 194F (90C) 18F (10C) for temperatures above 194F (90C) 16F (9C) 15.5F (8.6C)
F185F (F85C) = 31 minutes F194F (F90C) = 57 minutes
In some pasteurized surimi-based products, salt, in combination with a milder pasteurization process, in the finished product container works to prevent growth and toxin formation by C. botulinum type E and non proteolytic types B and F. An example of a properly pasteurized surimi-based product in which 2.4% wps is present is one that has been pasteurized at an internal temperature of 185F (85C) for at least 15 minutes. This process may not be suitable for other types of products because of the unique formulation and processing involved in the manufacture of surimi-based products. Refrigerated (not frozen), reduced oxygen
packaged pickled fish, salted fish, caviar, and similar products
In pickled fish, salted fish, caviar, and similar products that have not been preserved sufficiently for them to be shelf stable, growth and toxin formation by C. botulinum type E and non-proteolytic types B and F is controlled by one of the following: Adding sufficient salt to produce a water phase salt level (i.e., the concentration of salt in the water portion of the fish flesh) of at least 5%;
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growth of other pathogenic bacteria through refrigeration is covered in Chapter 12. Refrigerated (not frozen), reduced oxygen
packaged raw, unpreserved fish and unpasteurized, cooked fishery products
Frozen, reduced oxygen packaged raw,

unpreserved fish and unpasteurized, cooked fishery products
For refrigerated, reduced oxygen packaged raw, unpreserved fish (e.g., refrigerated, vacuum-packaged fish fillets) and refrigerated, reduced oxygen packaged, unpasteurized, cooked fishery products (e.g., refrigerated, vacuum-packaged, unpasteurized crabmeat, lobster meat, or crayfish meat), the sole barrier to toxin formation by C. botulinum type E and non-proteolytic types B and F during finished product storage and distribution is refrigeration. These types of C. botulinum will grow at temperatures as low as 38F (3.3C). As was previously noted, maintenance of temperatures below 38F (3.3C) after the product leaves your control and enters the distribution system cannot normally be ensured. The use of a TTI on the smallest unit of packaging (i.e., the unit of packaging that will not be distributed any further, usually consumer or end-user package) may be an appropriate means of overcoming these problems in the distribution system. This chapter provides controls for the application of TTIs for packaging. If you intend to package these products in a reduced oxygen package and you do not intend to apply a TTI on each consumer package, you should evaluate the effectiveness of other preventive measures, either singularly, or in combination, that may be effective in preventing growth and toxin formation by C. botulinum. Such evaluation is customarily accomplished by conducting an inoculated pack study under moderate abuse conditions. A suitable protocol for the performance of such studies is contained in a 1992 publication by the National Advisory Committee on Microbiological Criteria for Foods, Vacuum or modified atmosphere packaging for refrigerated, raw fishery products.
For frozen, reduced oxygen packaged raw, unpreserved fish (e.g., frozen, vacuumpackaged fish fillets) and frozen, reduced oxygen packaged, unpasteurized, cooked fishery products (e.g., frozen, vacuumpackaged, unpasteurized crabmeat, lobster meat, or crayfish meat), the sole barrier to toxin formation by C. botulinum type E and non-proteolytic types B and F during finished product storage and distribution is freezing. Because these products may appear to the retailer, consumer, or end user to be intended to be refrigerated, rather than frozen, labeling to ensure that they are held frozen throughout distribution is critical to their safety. Controls should be in place to ensure that such products are immediately frozen after processing, maintained frozen throughout storage in your facility, and labeled to be held frozen and to be thawed under refrigeration immediately before use (e.g., Important, keep frozen until used, thaw under refrigeration immediately before use). Frozen, reduced oxygen packaged products that are customarily cooked by the consumer or end user in the frozen state (e.g., boil-in bag products and frozen fish sticks) need not be labeled to be thawed under refrigeration. For purposes of hazard analysis, other frozen products that do not contain the keep frozen statement should be evaluated as if they will be stored refrigerated because the consumer or end user would not have been warned to keep them frozen. Control procedures to ensure that product is properly labeled with keep frozen instructions are covered in this chapter.
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Control in unrefrigerated (shelf-stable),

reduced oxygen packaged fishery products

The following guidance will assist you in determining whether C. botulinum toxin formation is a significant hazard at a processing step:
1. Is it reasonably likely that C. botulinum will grow and produce toxin during finished product storage and distribution?
Examples of shelf-stable, reduced oxygen packaged fishery products are dried fish, acidified fish, canned fish, and salted fish. Because these products are marketed without refrigeration, either (1) the spores of C. botulinum types A, B, E, and F should be destroyed after the product is placed in the finished product container (covered by the LACF Regulation, 21 CFR 113) or (2) a barrier, or combination of barriers, should be in place that will prevent growth and toxin formation by C. botulinum types A, B, E, and F, and other pathogens that may be present in the product. Suitable barriers include: Adding sufficient salt to produce a water phase salt level (i.e., the concentration of salt in the water portion of the fish flesh) of at least 20%. Note that this value is based on the maximum salt level for growth of S. aureus, covered in this chapter; Reducing the amount of moisture that is available for growth (water activity) to below 0.85 (e.g., by adding salt or other substances that bind the available water). Note that this value is based on the minimum water activity for growth and toxin formation of S. aureus, covered in this chapter; Adding sufficient acid to reduce the pH to 4.6 or below. This barrier is covered by the Acidified Foods regulation, 21 CFR 114, and these controls are not required to be included in your HACCP plan; Drying the product sufficiently to reduce the water activity to 0.85 or below. Note that this value is based on the minimum water activity for growth and toxin formation of S. aureus, covered in Chapter 14.
Note: A heat treatment, addition of chemical additives, or other treatment may be necessary to inhibit or eliminate spoilage organisms (e.g., mold) in shelf-stable products.
The factors that make C. botulinum toxin formation during finished product storage and distribution reasonably likely to occur are those that may result in the formation of a reduced oxygen packaging environment. These are discussed in the section Understand the potential hazard, under the heading, Reduced oxygen packaging.
2. Can growth and toxin formation by C. botulinum that is reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
C. botulinum toxin formation should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. Preventive measures for C. botulinum toxin formation during finished product distribution and storage are discussed in the section, Understand the potential hazard, under the heading, Control of C. botulinum. Intended use Because of the extremely toxic nature of C. botulinum toxin, it is unlikely that the significance of the hazard will be affected by the intended use of your product.
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The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for C. botulinum toxin formation:
1. Is there an acidification step (equilibrium pH of 4.6 or below), a drying step, an in-package pasteurization step, a combination of cook and hot-fill steps, or a retorting step (commercial sterility) in the process? a. If there is, you should in most cases
Products dried to control the growth of C. botulinum type E and non-proteolytic types B and F and refrigerated to control the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present. In these cases, you should also identify the finished product storage step as a CCP for the hazard. Control of refrigeration is covered in this chapter for C. botulinum and in Chapter 12 for other pathogenic bacteria. Additionally, some pasteurized surimi based products rely on a combination of salt and a relatively mild pasteurization process in the finished product container for the control of C. botulinum type E and non-proteolytic types B and F. In these products, you should also identify the formulation step as a CCP for the hazard. Guidance provided in Control Strategy Example 4 - Pickling and Salting may be useful in developing controls at this step. Guidance for the C. botulinum control strategies listed above is contained in the following locations: Control of cooking and hot-filling is covered in Chapters 16 and 18; Control of pasteurization is covered in Chapters 16 and 18; Control of drying is covered in Chapter 14; Control of acidification is covered in the Acidified Foods regulation, 21 CFR 114; Control of retorting is covered in the LACF Regulation, 21 CFR 113.
Note: Acidification and retorting controls for C. botulinum required by 21 CFRs 113 and 114 need not be included in your HACCP plan.
identify the acidification step, drying step, pasteurization step, cook and hotfill steps, or retorting step as the CCP(s) for this hazard. Other processing steps where you have identified C. botulinum toxin formation as a significant hazard will then not require control and will not need to be identified as CCPs for the hazard. However, control should be provided for time and temperature exposure during finished product storage and distribution of the following products: Products pasteurized in the final container to kill C. botulinum type E and non-proteolytic types B and F and refrigerated to control the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present (e.g., pasteurized crabmeat and pasteurized surimi); Products cooked to kill C. botulinum type E and non-proteolytic types B and F, and then hot filled into the final container, and next refrigerated to control the growth of C. botulinum type A and proteolytic types B and F and other pathogens that may be present;
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b. If there is no acidification step
(equilibrium pH of 4.6 or below), drying step, pasteurization step, cooking and hot-filling, or retorting (commercial sterility) step in the process, then decide which of the following categories best describes your product and refer to the guidance below: Smoked and smoke-flavored fish; Fishery products in which refrigeration is the sole barrier to prevent toxin formation; Fishery products in which freezing is the sole barrier to toxin formation; Pickled fish and similar products. Smoked and smoke-flavored fish
1. Is the water phase salt level and, when permitted, the nitrite level, important to the safety of the product?
and the smoking step should be identified as a CCP for this hazard. The smoking step for hot-smoked fish should be sufficient to damage the spores and make them more susceptible to inhibition by salt. The smoking step for coldsmoked fish should not be so severe that it kills the natural spoilage bacteria. These bacteria are necessary so that the product will spoil before toxin production occurs. It is likely that they will also produce acid, which will further inhibit C. botulinum growth and toxin formation. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Smoking (1b - Cold Smoking and 1c - Hot Smoking).
3. Is the storage temperature important to the safety of the product?
For all products in this category, the water phase salt level is critical to the safety of the product, and the brining, dry salting and, where applicable, drying steps should be identified as CCPs. Nitrite, when permitted, allows a lower level of salt to be used. Salt and nitrite are the principal inhibitors to C. botulinum type E and non-proteolytic types B and F toxin formation in these products. The water phase salt level needed to inhibit toxin formation is partially achieved during brining or dry salting and is partially achieved during drying. Control should be exercised over both operations. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Smoking (1a - Brining, Dry Salting, and Drying).
2. Is the temperature of the heating or smoking process important to the safety of the product?
Refrigerated (not frozen) finished product storage is critical to the safety of all products in this category and should be identified as a CCP. Toxin formation by C. botulinum type A and proteolytic types B and F is not inhibited by water phase salt levels below 10%, nor by the combination of inhibitors present in most smoked or smoke-flavored fish. Bacillus cereus can grow and form toxin at water phase salt concentrations as high as 18%. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Smoking (1d - Refrigerated Finished Product Storage). In some cases, salted, smoked, or smokeflavored fish are received as ingredients for assembly into another product, such as a salmon pat. In other cases, they are received simply for storage and further distribution (e.g., by a warehouse). In either case, the refrigerated (not frozen) storage step is critical to the safety of the product and should be identified as a CCP. Control is the same as that provided under Control Strategy Example 1 - Smoking (1d - Refrigerated
For both cold-smoked and hot-smoked fish products, the temperature of smoking is critical,
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Finished Product Storage). Additionally, receiving of these products should be identified as a CCP, where control can be exercised over the time and temperature during transit. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Smoking (1e - Receipt of Products by Secondary Processor). Fishery products in which refrigeration is
the sole barrier to prevent toxin formation 1. Is the storage temperature important to the safety of the product?
This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 - Refrigeration With a TTI (2e Receipt of Product by Secondary Processor). As previously noted, maintenance of temperatures below 38F (3.3C) after the product leaves your control and enters the distribution system cannot normally be ensured. The use of a TTI on the smallest unit of packaging (i.e., the unit of packaging that will not be distributed any further, usually consumer or end-user package) may be an appropriate means of overcoming these problems in the distribution system. When TTIs are used in this manner, their receipt, storage, and application and activation should be identified as CCPs. This control approach is a control strategy referred to as Control Strategy Example 2 Refrigeration With TTI (2a - Unactivated TTI Receipt, 2b - Unactivated TTI Storage, and 2c - Application and Activation of TTI). Fishery products in which freezing is the
sole barrier to toxin formation 1. Is the storage temperature important to the safety of the product?
Refrigerated finished product storage is critical to the safety of all products in this category and should be identified as a CCP. These products contain no barriers (other than refrigeration) to toxin formation by C. botulinum type E and non-proteolytic types B and F during finished product storage and distribution. These types of C. botulinum will grow at temperatures as low as 38F (3.3C), necessitating particularly stringent temperature control. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 - Refrigeration With TTI (2d Refrigerated Finished Product Storage). In some cases, these products are received as ingredients for assembly into another product. In other cases, they are received simply for storage and further distribution (e.g., by a warehouse). In either case, the refrigerated storage step is critical to the safety of the product and should be identified as a CCP. Control is the same as that provided under Control Strategy Example 2 - Refrigeration With a TTI (2d - Refrigerated Finished Product Storage). Additionally, receiving of these products should be identified as a CCP, where control can be exercised over the time and temperature during transit.
Frozen finished product storage is critical to the safety of all products in this category. These products contain no barriers (other than freezing) to toxin formation by C. botulinum type E and non-proteolytic types B and F during finished product storage and distribution. As previously noted, because these products may appear to the retailer, consumer, or end user to be intended to be refrigerated, rather than frozen, labeling to ensure that they are held frozen throughout distribution is critical to their safety and should be identified as a CCP. This control approach is a control strategy referred to in this chapter as Control Strategy Example 3 - Frozen With Labeling.
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Pickled and salted fish and similar products

1. Is the water phase salt level, water activity, and/ or pH level important to the safety of the product?
For all products in this category, the water phase salt level, water activity, and/or pH level are critical to the safety of the product because they are the principal inhibitors to growth and toxin formation by C. botulinum type E and non-proteolytic type B and F. The levels of these inhibitors needed to inhibit toxin formation are achieved during the pickling, brining, or formulation step. Control should be exercised over the relevant step. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 - Pickling and Salting (4a Brining, Pickling, Salting, and Formulation).
2. Is the storage temperature important to the safety of the product?
Salting (4b - Refrigerated Finished Product Storage). Additionally, receiving of these products should be identified as a CCP, where control can be exercised over time and temperature during transit. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 - Pickling and Salting (4c - Receipt of Product by Secondary Processor).

The following guidance provides four control strategies for C. botulinum toxin formation. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. Control strategies contain several elements that may need to be used in combination to result in an effective control program. The following are examples of control strategies included in this chapter:
Unless pickling, brining, or formulation results in a water phase salt level of at least 20% (note that this value is based on the maximum salt concentration for growth of S. aureus), a pH of 4.6 or below, or a water activity of 0.85 or below (note that this value is based on the minimum water activity for growth of S. aureus), refrigerated finished product storage is critical to ensure the safety of the product and should be identified as a CCP. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 - Pickling and Salting (4b Refrigerated Finished Product Storage). In some cases, pickled fish or similar products are received as ingredients for assembly into another product. In other cases, they are received simply for storage and further distribution (e.g., by a warehouse). In either case, the refrigerated storage step is critical to the safety of the product and should be identified as a CCP. Control is the same as that provided under Control Strategy Example 4 - Pickling and
Smoking Refrigeration with TTI Frozen with labeling Pickling and salting
CONTROL STRATEGY EXAMPLE 1 - SMOKING This control strategy should include the following elements, as appropriate:
a. Brining, dry salting, and drying; b. Cold smoking; c. Hot smoking; d. Refrigerated finished product storage; e. Receipt of products by secondary
processor.
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1A. BRINING, DRY SALTING, AND DRYING

The minimum or maximum values for the critical factors of the brining, dry salting, and/or drying processes established by a scientific study. The critical factors are those that are necessary to ensure that the finished product has not less than 3.5% wps or, where permitted, the combination of 3% wps and not less than 100 ppm nitrite. The critical factors may include: brine strength; brine to fish ratio; brining time; brining temperature; thickness, texture, fat content, quality, and species of fish; drying time; input/output air temperature, humidity, and velocity; smoke density; and drier loading.
Monitor brine temperature at the start of the brining process with a temperature- indicating device (e.g., a thermometer), and then monitor ambient air temperature using a continuous temperature-recording device (e.g., a recording thermometer); AND
Monitor the drying time and the input/

output air temperature (as specified by the study) using a continuous temperature-recording device (e.g., a recording thermometer); AND Monitor all other critical factors specified by the study with equipment appropriate for the measurement;
OR

The critical factors of the established brining, dry salting, and/or drying processes. These may include: brine strength; brine to fish ratio; brining time; brining temperature; thickness, texture, fat content, quality, and species of fish; drying time; input/output air temperature, humidity, and velocity; smoke density; and drier loading; OR The water phase salt and, where appropriate, nitrite level of the finished product.
Collect a representative sample of the finished product and conduct water phase salt analysis and, when appropriate, nitrite analysis.

For brine strength:
At least at the start of the brining process;
AND
For brine time:

For monitoring critical factors:
Once per batch;
AND For manual brine temperature monitoring: At the start of the brining process and at least every 2 hours thereafter;
Monitor brine strength with a salinometer;

AND
Monitor brine time with a clock;
AND
Monitor brine temperature using:
A temperature-indicating device (e.g., a thermometer); OR
AND
Continuous monitoring by the device itself, with a visual check of the recorded data at least once per batch;
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AND For brine to fish ratio:
that is not hermetically sealed, or an LACF, or a frozen product); OR Destroy the product; OR Divert the product to a non-food use. AND
At the start of the brining process;
AND For time requirements of the drying process: Each batch; AND For all other critical factors specified by the study:
OR
As often as necessary to maintain control;
Adjust the salt and/or nitrite concentration in the brine; OR Adjust the air velocity or input air temperature to the drying chamber; OR Extend the drying process to compensate for a reduced air velocity or temperature or elevated humidity; OR Adjust the brine strength or brine to fish ratio; OR Cool the brine; OR Move some or all of the product to another drying chamber; OR Make repairs or adjustments to the drying chamber as necessary.
For water phase salt and, when appropriate, nitrite:
Each lot or batch of finished product.

Monitoring is performed by the device itself. The visual check of the data generated by the device, to ensure that the critical limits have been met consistently, may be performed by any person who has an understanding of the nature of the controls;


Printouts, charts, or readings from continuous temperature-recording devices; AND Record of visual checks of recorded data; AND Appropriate records (e.g., processing record showing the results of the brine strength and temperature, brine to fish ratio, size
Chill and hold the product until its safety can be evaluated; OR Reprocess the product; OR Divert the product to a use in which the critical limit is not applicable (e.g., packaging
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and species of fish, and time of brining) as necessary to document the monitoring of the critical factors of the brining, dry salting, and/or drying process, as established by a study; OR Results of the finished product water phase salt determination and, when appropriate, nitrite determination.
applicable, nitrite levels should be taken into consideration in the process establishment. A record of the process establishment should be maintained; AND Before a temperature-indicating device (e.g., a thermometer) or temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:

Process validation study (except where water phase salt analysis and, where appropriate, nitrite analysis of the finished product are the monitoring procedure):
Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a thermometer traceable to National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., air temperature, brine temperature, product internal temperature) within the temperature range at which it will be used;
The adequacy of the brining, dry salting, and drying processes should be established by a scientific study. It should be designed to consistently achieve a water phase salt level of 3.5% or 3% with not less than 100 ppm nitrite. Expert knowledge of salting and/ or drying processes may be required to establish such a process. Such knowledge can be obtained by education or experience, or both. Process validation study for establishment of brining, dry salting, and drying processes may require access to adequate facilities and the application of recognized methods. The drying equipment should be designed, operated, and maintained to deliver the established drying process to every unit of product. In some instances, brining, dry salting, and/or drying studies may be required to establish minimum processes. In other instances, existing literature, which establishes minimum processes or adequacy of equipment, is available. Characteristics of the process, product, and/or equipment that affect the ability of the established minimum salting, dry salting, and drying process to deliver the desired finished product water phase salt and, where
AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended
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by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-indicating device or temperature recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Devices subjected to high temperatures for extended periods of time may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Perform other calibration procedures as necessary to ensure the accuracy of the monitoring instruments; AND Do finished product sampling and analysis to determine water phase salt and, where appropriate, nitrite analysis at least once every 3 months (except where such testing is performed as part of monitoring); AND Review monitoring, corrective action,
and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
1B. COLD SMOKING

The smoker temperature must not exceed 90F (32.2C).

The smoker temperature.

Measure ambient smoker chamber temperature using a continuous temperaturerecording device (e.g., a recording thermometer).

Continuous monitoring by the device itself, with a visual check of the recorded data at least once per batch.

Monitoring is performed by the device itself. The visual check of the data generated by the device, to ensure that the critical limits have been met consistently, may be performed by any person who has an understanding of the nature of the controls.

Chill and hold the product until its safety can be evaluated; OR Divert the product to a use in which the critical limit is not applicable (e.g., packaging that is not hermetically sealed, or an LACF, or a frozen product); OR
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Destroy the product; OR Divert the product to a non-food use. AND

traceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used; AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Make repairs or adjustments to the smoking chamber; AND/OR Move some or all of the product to another smoking chamber.

Printouts, charts, or readings from continuous temperature-recording devices; AND Record of visual checks of recorded data.

Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NIST264
1C. HOT SMOKING
OR Destroy the product; OR Divert the product to a non-food use. AND


The internal temperature of the fish must be maintained at or above 145F (62.8C) throughout the fish for at least 30 minutes.

The internal temperature at the thickest portion of three of the largest fish in the smoking chamber.
Make repairs or adjustments to the heating chamber; OR Move some or all of the product to another heating chamber.

Use a continuous temperature-recording device (e.g., a recording thermometer) equipped with three temperature-sensing probes.

Printouts, charts, or readings from continuous temperature-recording devices; AND Record of visual checks of recorded data.

Continuous monitoring by the device itself, with visual check of the recorded data at least once per batch.


Monitoring is performed by the device itself. The visual check of the data generated by the device, to ensure that the critical limits have been met consistently, may be performed by any person who has an understanding of the nature of the controls.

Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR
Chill and hold the product until its safety can be evaluated; OR Reprocess the product; OR Divert the product to a use in which the critical limit is not applicable (e.g., packaging that is not hermetically sealed, or a LACF, or a frozen product);
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Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used;
preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
1D. REFRIGERATED FINISHED PRODUCT STORAGE

For refrigerated (not frozen) finished product storage:
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of
The product is held at a cooler

temperature of 40F (4.4C) or below. Note that allowance for routine refrigeration defrost cycles may be necessary. Also note that you may choose to set a critical limit that specifies a time and temperature of exposure to temperatures above 40F (4.4C);
OR For finished product stored under ice:
The product is completely and continuously surrounded by ice throughout the storage time.

For refrigerated finished product storage:
OR
The temperature of the cooler;
For finished product storage under ice:

OR
266

OR
Move some or all of the product in the malfunctioning cooler to another cooler;
OR
Freeze the product;
OR
AND Address the root cause: Make repairs or adjustments to the malfunctioning cooler; OR Make adjustments to the ice application operations.
Sufficient frequency to ensure control.



devices;
AND
OR

Results of ice checks: The number of containers examined and the sufficiency of ice for each; AND The approximate number of containers in the cooler.
Chill and hold the affected product until an evaluation of the total time and temperature exposure is performed; OR Destroy the product; OR Divert the product to a non-food use. AND

Prevent further deterioration:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR
Add ice to the product;
267
Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
of fish to ensure that the ice is sufficient to maintain product temperatures at 40F (4.4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
1E. RECEIPT OF PRODUCTS BY SECONDARY PROCESSOR
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND When visual checks of ice are used, periodically measure internal temperatures

For fish or fishery products delivered refrigerated (not frozen):
All lots received are accompanied by transportation records that show that the product was held at or below 40F (4.4C) throughout transit. Note that allowance for routine refrigeration defrost cycles may be necessary;
Product is completely surrounded by ice at the time of delivery;
OR
There is an adequate quantity of cooling media that remain frozen to have maintained product at 40F (4.4C) or below throughout transit; AND The internal temperature of the product at the time of delivery is 40F (4.4C) or below;
OR
For products delivered refrigerated (not frozen) with a transit time (including all time outside a controlled temperature environment) of 4 hours or less (optional control strategy):
268
Time of transit does not exceed 4 hours; AND Temperature of the product at the time of delivery does not exceed 40F (4.4C).
containers (e.g., cartons and totes) at the time of delivery.
Note: Processors receiving product with transit times of 4 hours or less may elect to use one of the controls described for longer transit times.
Establish Monitoring Procedures.

What Will Be Monitored?

OR
The internal temperature of the product throughout transportation; OR The temperature within the truck or other carrier throughout transportation;
Make visual observations of the adequacy of ice in a representative number of containers (e.g., cartons and totes) from throughout the shipment, at delivery;
For products delivered under ice:
OR For products delivered under chemical cooling media, such as gel packs:
OR
For products held under chemical cooling media, such as gel packs:
The quantity and frozen status of cooling media at the time of delivery; AND The internal temperature of a representative number of product containers (e.g., cartons and totes) at time of delivery; OR
Make visual observations of the adequacy and frozen state of the cooling media in a representative number of containers (e.g., cartons and totes) from throughout the shipment, at delivery; AND Use a temperature-indicating device (e.g., a thermometer) to determine internal product temperatures in a representative number of product containers from throughout the shipment, at delivery;
OR For products delivered refrigerated (not frozen) with a transit time of 4 hours or less:
For products delivered refrigerated (not frozen) with a transit time of 4 hours or less:
The date and time fish were removed from a controlled temperature environment before shipment and the date and time delivered; AND The internal temperature of a representative number of product
Review carrier records to determine the date and time the product was removed from a controlled temperature environment before shipment and the date and time delivered; AND
269
Use a temperature-indicating device (e.g., a thermometer) to determine internal product temperatures in a representative number of product containers (e.g., cartons and totes) randomly selected from throughout the shipment, at delivery. Measure a minimum of 12 product containers, unless there are fewer than 12 product containers in a lot, in which case measure all of the containers. Lots that show a high level of temperature variability may require a larger sample size.
Discontinue use of the supplier or carrier until evidence is obtained that the identified transportation-handling practices have been improved.

Results of continuous temperature monitoring: Printouts, charts, or readings from continuous temperaturerecording devices; AND Visual check of recorded data;
OR
Results of ice checks, including:
The number of containers examined and the sufficiency of ice for each; AND The number of containers in the lot;
OR
Results of the chemical media checks,
including: The number of containers examined and the frozen status of the media for each; AND The number of containers in the lot; AND/OR Results of internal product temperature monitoring, including: The number of containers examined and the internal temperatures observed for each; AND The number of containers in the lot; AND Date and time fish were initially removed from a controlled

Each lot received.


Chill and hold the affected product until an evaluation of the total time and temperature exposure is performed; OR Reject the lot. AND
270
temperature environment and date and time fish were delivered, when applicable.

Immersing the sensor in an ice slurry (32F (0C)), if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used;
recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Check the accuracy of temperature-recording devices that are used for monitoring transit conditions, for all new suppliers and at least quarterly for each supplier thereafter. Additional checks may be warranted based on observations at receipt (e.g., refrigeration units appear to be in poor repair or readings appear to be erroneous). The accuracy of the device can be checked by comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NIST-traceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used; AND When visual checks of ice are used, periodically measure internal temperatures of fish to ensure that the ice or is sufficient to maintain product temperatures at 40F (4.4C) or less; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
AND Once in service, check the temperature-
indicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational;
AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if
271
TABLE 13-1
CONTROL STRATEGY EXAMPLE 1 - SMOKING
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Smoking. This example illustrates how a processor of vacuum-packaged hotsmoked salmon can control C. botulinum toxin formation. It is provided for illustrative purposes only.
C. botulinum toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., aquaculture drugs, environmental chemical contaminants and pesticides, parasites, growth of other pathogenic bacteria, survival of other pathogenic bacteria through the cook step, and metal fragments).

(3) MONITORING WHAT HOW FREQUENCY WHO CORRECTIVE ACTION(S) (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
CRITICAL LIMITS FOR EACH PREVENTIVE MEASURE*
RECORDS
VERIFICATION
Brining Dial thermometer Every 2 hours
C. botulinum toxin formation in the finished product Maximum brine temperature: 40F Brine temperature Salt concentration of brine Salinometer Start of each brining process Brine room employee Minimum salt concentration of brine at the start of brining: 60 salinometer Minimum ratio of brine to fish: 2:1 Weight of brine (as determined by volume) Weight of fish Fish thickness Caliper Scale Visual, to mark on the tank Start of each brining process
Minimum brining time: 6 hours
Start time and end time of the brining process
Clock
Every batch
Brine room employee
Extend the brining process Hold and evaluate the product Cool the brine Add salt
Production record
Establish a brining and drying process
CHAPTER 13: Clostridium botulinum Toxin Formation Add brine Brine room employee Each batch Each batch (10 largest fish) Brine room employee Remove some fish and reweigh Hold and evaluate based on finished product water phase salt analysis
272
Production record
Check the dial thermometer for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Monthly calibration of the scale Production record Quarterly water phase salt analysis of the finished product Review monitoring, corrective action, and verification records within 1 week of preparation Production record
Maximum fish thickness 1 in. Note: To produce a minimum water phase salt level in the loin muscle of 3.5%
TABLE 13-1
CONTROL STRATEGY EXAMPLE 1 - SMOKING
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Smoking. This example illustrates how a processor of vacuum-packaged hotsmoked salmon can control C. botulinum toxin formation. It is provided for illustrative purposes only.
C. botulinum toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., aquaculture drugs, environmental chemical contaminants and pesticides, parasites, growth of other pathogenic bacteria, survival of other pathogenic bacteria through the cook step, and metal fragments).

(1)
(2)
RECORDS
VERIFICATION
Smoking and drying
C. botulinum toxin formation in finished product Internal temperature of fish and time at that temperature Digital data logger with three probes in thickest fish in cold spot of smoking chamber Continuous, with visual check of recorded data at the end of the batch Smoker employee
Minimum time open vent: 2 hours
Time of open vent
Clock
Each batch
Smoker employee
Production record
CHAPTER 13: Clostridium botulinum Toxin Formation Extend the drying process Hold and evaluate based on finished product water phase salt analysis Extend the heating process Make repairs or adjustments to the smoking chamber Hold and evaluate the product Continuous, with visual check of recorded data once per day Production employee Adjust or repair the cooler Hold and evaluate the product based on time and temperature of exposure Data logger printout Cooler air temperature Digital data logger
273
Establish a brining and drying process Quarterly water phase salt analysis of the finished product Review monitoring, corrective action, and verification records within 1 week of preparation Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation Digital data logger printout Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
Heating
C. botulinum toxin formation in the finished product
Internal temperature of fish held at or above 145F for at least 30 minutes
Finished product storage
C. botulinum toxin formation during finished product storage
Maximum cooler temperature: 40F (based on growth of vegetative pathogens)
*Note: The critical limits in this example are for illustrative purposes only and are not related to any recommended process.
CONTROL STRATEGY EXAMPLE 2 REFRIGERATION WITH TTI
Performance data from the manufacturer;
This control strategy should include the following elements, as appropriate:

a. Unactivated TTI receipt; b. Unactivated TTI storage; c. Application and activation of TTI; d. Refrigerated finished product storage; e. Receipt of product by secondary
AND For transportation conditions: The temperature within the truck or other carrier throughout transportation; OR Other conditions that affect the functionality of the TTI, where applicable;
AND For functionality at receipt:
processor.
2A. UNACTIVATED TTI RECEIPT

The TTI is suitable for use. It should be designed to perform properly under the conditions that it will be used. It should also be designed to produce an alert indicator (e.g., a color change of the device) at a combination of time and temperature exposures that will prevent the formation of non-proteolytic C. botulinum toxin formation (e.g., consistent with the Skinner-Larkin curve); AND Where transportation conditions (e.g., temperature) could affect the functionality of the TTI, all lots of TTIs are accompanied by transportation records that show that they were held at conditions that do not result in loss of functionality throughout transit; AND The TTI functions (i.e., produces an alert indicator, such as a color change of the device, when exposed to time and temperature abuse) at time of receipt.
The ability of the TTI to produce an alert indicator, such as a color change of the device, when exposed to time and temperature abuse at time of receipt.

For suitability of use:
Review performance data;
AND For transportation conditions: Use a continuous temperature-recording device (e.g., a recording thermometer) for ambient air temperature monitoring during transit;
AND For functionality at receipt:
Activate and then expose a TTI from the lot to ambient air temperature for sufficient time to determine whether it is functional (i.e., produces an alert indicator, such as a color change of the device).

The first shipment of a TTI model;

AND For transportation conditions and functionality at receipt:
274
Every shipment.

Records of visual checks of recorded data;
Anyone with an understanding of TTI validation studies and of the intended conditions of use;
AND
For functionality at receipt:
Anyone with an understanding of the nature of the controls.
Results of a TTI challenge test (i.e., whether the TTI produces an alert indicator, such as a color change of the device, when exposed to time and temperature abuse).

Check the accuracy of temperature-recording devices that are used for monitoring transit conditions, for all new suppliers and at least quarterly for each supplier thereafter. Additional checks may be warranted based on observations at receipt (e.g., refrigeration units appear to be in poor repair or readings appear to be erroneous). The accuracy of the device can be checked by comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NIST-traceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
2B. UNACTIVATED TTI STORAGE

Reject or return the shipment. AND

Discontinue use of the supplier until documentation of validation has been provided;
Discontinue use of the supplier or carrier until evidence is obtained that the identified production or transportation practices have been improved.

Manufacturers performance data;

The combination of storage conditions
AND For transportation conditions: Printouts, charts, or readings from continuous temperature-recording devices; AND
(e.g., temperature) that prevent loss of functionality throughout storage (based on manufacturers specifications).
275

Storage air temperature, where temperature affects functionality of the TTI; AND/OR Other storage conditions that affect functionality of the TTI.

Take the following corrective action to a TTI involved in a critical limit deviation:
Destroy the lot of TTIs. AND


For temperature:
Make repairs or adjustments to the malfunctioning cooler; AND/OR Make other repairs or adjustment appropriate for the condition.
AND/OR For other conditions:

Use instruments appropriate for the purpose.

For temperature:

devices;
AND
AND/OR Storage record showing the results of monitoring of other conditions.
AND/OR For other conditions:
With sufficient frequency to ensure control.


With continuous temperature-recording devices:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
276
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Perform other instrument calibration, as appropriate; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
2C. APPLICATION AND ACTIVATION OF TTI

Each consumer package has an activated TTI.

Packages for the presence of an activated TTI.

Visual examination.

Representative number of packages from each lot of product.


Hold the lot below 38F (3.3C) until TTIs are applied and activated. AND
Identify and correct the cause of the TTI application or activation deficiency.

Packaging control record that shows the results of the TTI checks.

277
2D. REFRIGERATED FINISHED PRODUCT STORAGE
Follow the guidance for Control Strategy Example 1 - Smoking (1d - Refrigerated Finished Product Storage), except that the where the critical limits list 40F (4.4C), they should list 38F (3.3C).
2E. RECEIPT OF PRODUCTS BY SECONDARY PROCESSOR
Follow the guidance for Control Strategy Example 1 - Smoking (1e - Receipt of Products by Secondary Processor), except that the where the critical limits list 40F (4.4C), they should list 38F (3.3C).
278
TABLE 13-2
CONTROL STRATEGY EXAMPLE 2 - REFRIGERATION WITH TTI
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Refrigeration With TTI. This example illustrates how a processor of refrigerated, vacuum-packaged, raw fish fillets can control C. botulinum toxin formation. It is provided for illustrative purposes only.
C. Botulinum toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., aquaculture drugs, environmental chemical contaminants and pesticides, parasites, growth of other pathogenic bacteria, and metal fragments).

(1)
(2)
Receipt of TTI
TTI is suitable for use
Performance data from the manufacturer
Review of performance data
First shipment of a TTI model
Quality assurance supervisor
Manufacturers performance data
Reject the shipment Discontinue use of the supplier until appropriate validation documentation is provided Discontinue use of the supplier or carrier until evidence is obtained that the identified transportation- handling practices have been improved Reject the shipment
Review monitoring, corrective action records within 1 week of preparation Receiving record Check the data logger for all new suppliers and for all suppliers at least quarterly thereafter
CHAPTER 13: Clostridium botulinum Toxin Formation All lots received are accompanied by truck records that show temperature was maintained at or below 40F Truck temperature Digital time and temperature data logger Continuous, with visual review and evaluation of temperaturemonitoring records for each shipment Receiving employee The TTI functions at receipt The ability of the TTI to change color when exposed to room air temperature Expose a TTI from the lot to room air temperature for sufficient time to determine whether it changes color Every shipment Quality assurance staff
279
Review monitoring, corrective action records within 1 week of preparation Discontinue use of the supplier or carrier until evidence is obtained that the identified production or transportationhandling practices have been improved TTI challenge record Review monitoring, corrective action records within 1 week of preparation
TABLE 13-2

(1)
(2)
TTI storage
CHAPTER 13: Clostridium botulinum Toxin Formation Cooler maintained below 38F Cooler temperature Digital time and temperature data logger Continuous, with visual check of recorded data once per day Quality assurance staff Each package has an activated TTI Packages for the presence of an activated TTI Visual examination Representative number of packages from each lot of product Production employee
Repair or adjust cooler Destroy the lot of TTIs
280
Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation Hold lot below 38F, and apply and activate TTIs Identify and correct the cause of TTI application deviation Packaging control record Review monitoring, and corrective action and verification records within 1 week of preparation
TTI attachment and activation
TABLE 13-2

(1)
(2)
Maximum cooler temperature 38F
Cooler air temperature
Digital data logger
CHAPTER 13: Clostridium botulinum Toxin Formation Continuous, with visual check of recorded data once per day Production employee
Adjust or repair cooler Hold and evaluate the product based on time and temperature of exposure
Digital logger printout
281
Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 3 - FROZEN WITH

LABELING


All finished product labels must contain a keep frozen statement (e.g., Important, keep frozen until used, thaw under refrigeration immediately before use).

Finished product labels for the presence of a keep frozen statement.

Visual examination.

Representative number of packages from each lot of product.


Segregate and relabel any improperly labeled product. AND

Segregate and return or destroy any label stock or pre-labeled packaging stock that does not contain the proper statement; AND Determine and correct the cause of improper labels.

Record of labeling checks.
282
TABLE 13-3
CONTROL STRATEGY EXAMPLE 3 - FROZEN WITH LABELING
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Frozen With Labeling. This example illustrates how a processor of frozen, vacuum-packaged, raw fish fillets can control C. botulinum toxin formation. It is provided for illustrative purposes only.
C. Botulinum toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, parasites, and metal fragments).
(1) MONITORING WHAT HOW FREQUENCY WHO
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
RECORDS
VERIFICATION
CHAPTER 13: Clostridium botulinum Toxin Formation All finished product labels must contain a keep frozen statement Finished product labels for the presence of a keep frozen statement Visual examination Representative number of packages from each lot of product Receiving employee
Receipt of labeling
Segregate and relabel any improperly labeled product Segregate and destroy any label stock that does not contain the proper statement Determine and correct the cause of improper labels
Label receiving record
283
CONTROL STRATEGY EXAMPLE 4 - PICKLING

AND SALTING
For unrefrigerated (shelf-stable), reduced oxygenpackaged products:
This control strategy should include the following elements, as appropriate:

a. Brining, pickling, salting, and
A water phase salt level of at least 20% (based on the maximum salt level for
growth of S. aureus);
OR
A pH of 4.6 or below;
OR A water activity of 0.85 or below (based on the minimum water activity for growth and toxin formation of S. aureus).
formulation;
b. Refrigerated finished product storage; c. Receipt of Product by secondary
processor.
4A. BRINING, PICKLING, SALTING, AND FORMULATION

The minimum or maximum values for the critical factors of the brining, pickling, or formulation process established by a scientific study. The critical factors are those that are necessary to ensure that the finished product has: For refrigerated, reduced oxygen-packaged fishery products:
A heat treatment, addition of chemical additives, or other treatment may be necessary to inhibit or eliminate spoilage organisms (e.g., mold) in shelfstable products.

The critical factors of the established pickling, brining, or formulation process. These may include: brine and acid strength; brine or acid to fish ratio; brining and pickling time; brine and acid temperature; thickness, texture, fat content, quality, and species of fish; OR The water phase salt, pH, and/or water activity of the finished product.
A water phase salt level of at least 5%; OR

A pH of 5.0 or below;
OR
A water activity of below 0.97;
OR A water phase salt level of at least 2.4% in surimi-based products, when
combined with a pasteurization process
in the finished product container
of 185F (85C) for 15 minutes
(pasteurization controls are covered in
Chapter 16);
OR
A combination of water phase salt,
pH, and/or water activity that, when combined, have been demonstrated to prevent the growth of C. botulinum type E and non-proteolytic types B and F.

For brine strength:
Use a salinometer;
AND For acid strength: Use a pH meter or titrate for acid concentration;
AND
For brine/acid temperature:
AND
284
For all other critical factors specified by the study:

Use equipment appropriate for the measurement;
OR
For water phase salt, pH, and/or water activity:
Chill and hold the product until it can be evaluated based on its water phase salt, pH, and/or water activity level; OR Reprocess the product (if reprocessing does not jeopardize the safety of the product); OR Divert the product to a use in which the critical limit is not applicable (e.g., packaging that is not hermetically sealed, or a LACF, or a frozen product); OR Divert the product to a non-food use; OR Destroy the product. AND
Collect a representative sample of the finished product, and conduct water phase salt, pH, and/or water activity analysis, as appropriate.

For brine and acid strength:
At the start of each brining, pickling, and formulation process;
AND
For brine and acid temperature:
At the start of each brining, pickling, and formulation process and at least every 2 hours thereafter;
AND For brine or acid to fish ratio:
At the start of each brining, pickling, and formulation process;
Adjust the brine or acid strength or brine or acid to fish ratio; OR Extend the brining or pickling time to compensate for an improper brine or acid temperature.
AND
For other critical factors specified by the study:
OR
Water phase salt, pH, and/or water activity analysis should be determined for each batch of finished product.

Records, as necessary, to document the monitoring of the critical factors of the brining or pickling process, as established by a study (e.g., a processing record showing the results of the brine or acid strength and temperature, brine or acid to fish ratio, size and species of fish, time of brining or pickling); OR Record of determinations of the finished product water phase salt, pH, or water activity.

For water activity:
Any person with sufficient training to perform the analysis;
OR
For other checks:
Any person with an understanding of the nature of the controls.
285

Process validation study (except where water phase salt, pH, or water activity analysis of the finished product is the monitoring procedure):
The adequacy of the pickling, brining, and formulation process steps should be established by a scientific study. For refrigerated, reduced oxygen-packaged products, it should be designed to consistently achieve: a water phase salt level of at least 5%; a pH of 5.0 or below; a water activity of below 0.97; a water phase salt level of at least 2.4% in surimi based products, when combined with a pasteurization process in the finished product container of 185F (85C) for at least 15 minutes; or a combination of salt, pH, and/or water activity that, when combined, prevent the growth of C. botulinum type E and non-proteolytic types B and F (established by a scientific study). For unrefrigerated (shelf-stable), reduced oxygen-packaged products, it should be designed to consistently achieve: a water phase salt level of at least 20% (based on the maximum water phase salt level for the growth of S. aureus); a pH of 4.6 or below; or a water activity of 0.85 or below (based on the minimum water activity for the growth of S. aureus). Expert knowledge of pickling, brining, and formulation processes may be required to establish such a process. Such knowledge can be obtained by education or experience, or both. Establishment of pickling, brining, and formulation processes may require access to adequate facilities and the application of recognized methods. In some instances, pickling, brining, and formulation studies may be required to establish minimum processes. In other instances, existing literature, which establishes minimum processes, is available. Characteristics of the process
and/or product that affect the ability of the established minimum pickling, brining, and formulation process should be taken into consideration in the process establishment. A record of the process establishment should be maintained; AND Before a temperature-indicating device (e.g., a thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary); OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., brine temperature) within the temperature range at which it will be used;
AND Once in service, check the temperatureindicating device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your
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facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Perform daily calibration of pH meters against standard buffers; AND Perform other calibration procedures as necessary to ensure the accuracy of the monitoring instruments; AND Do finished product sampling and analysis to determine water phase salt, pH, or water activity level, as appropriate, at least once every 3 months (except where such testing is performed as part of monitoring); AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and
any critical limit deviations that occurred were appropriately addressed.

4B. REFRIGERATED FINISHED PRODUCT STORAGE
Follow the guidance for Control Strategy Example 1 - Smoking (1d - Refrigerated Finished Product Storage).
4C. RECEIPT OF PRODUCT BY SECONDARY PROCESSOR
Follow the guidance for Control Strategy Example 1 - Smoking (1e - Receipt of Product by Secondary Processor).
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TABLE 13-4
CONTROL STRATEGY EXAMPLE 4 - PICKLING AND SALTING
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Pickling and Salting. This example illustrates how a pickled herring processor can control C. botulinum toxin formation. It is provided for illustrative purposes only.
C. botulinum toxin formation may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., histamine, environmental and chemical contaminants and pesticides, parasites, and metal fragments).

(1)
(2)
RECORDS
VERIFICATION
Pickling
Maximum finished product pH in the loin muscle of 5.0
Finished product pH in the loin muscle
Each pickling tank, each cycle
Quality control personnel
Continue the pickling process until pH meets the critical limit
Pickling control record
CHAPTER 13: Clostridium botulinum Toxin Formation Collect a sample of the product from each pickling tank at the end of each pickling cycle and analyze for pH using a pH meter Time and temperature data logger Continuous, with visual check of recorded data once per day Production employee Maximum cooler temperature: 40F (based on growth of vegetative pathogens) Cooler air temperature Adjust or repair cooler Hold and evaluate the product based on time and temperature of exposure
288
Daily calibration of the pH meter Review monitoring, corrective action, and verification records within 1 week of preparation Data logger printout Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Association of Food and Drug Officials. 2005. Cured, salted, & smoked fish establishments good manufacturing practices, including Listeria Control Manual. Association of Food and Drug Officials, York, PA. Baird-Parker, A. C., and B. Freame. 1967. Combined effect of water activity, pH and temperature on the growth of Clostridium botulinum from spore and vegetative cell inocula. J. Appl. Bact. 30:420-429. Betts, G. D., and J. E. Getts. 1995. Growth and heat resistance of psychotropic Clostridium botulinum in relation to sous vide products. Food Control 6:57-63. Boyd, J. W., and B. A. Southcott. 1971. Effects of sodium chloride on outgrowth and toxin production of Clostridium botulinum type E in cod homogenates. J. Fish. Res. Bd. Canada. 28:1071-1075. Brody, A. L. (ed.). 1989. Controlled/modified atmosphere/vacuum packaging of foods. Food and Nutrition Press, Inc., Trumbull, CT. Crisan, E.V., and A. Sands. 1975. Microflora of four fermented fish sauces. Appl. Microbiol. 29(1): 106-108. Christiansen, L. N., J. Deffner, E. M. Foster, and H. Sugiyama. 1968. Survival and outgrowth of Clostridium botulinum type E spores in smoked fish. Appl. Microbiol. 16:133-137.
Daniels, R. W. 1991. Applying HACCP to new-generation refrigerated foods at retail and beyond. Food Technol. 45:122, 124. Dufresne, I., J. P. Smith, J. N. Liu, and I. Tarte. 2000. Effect of films of different oxygen transmission rate on toxin production by Clostridium botulinum type E in vacuum packaged cold and hot smoked trout fillets. J. Food Saf. 20:251-268. Eklund, M. W., G. A. Pelroy, R. Paranjpye, M. E. Peterson, and F. M. Teeny. 1982. Inhibition of Clostridium botulinum types A and E toxin production by liquid smoke and NaCl in hot-process smoke-flavored fish. J. Food Prot. 44:935-941. Essuman, K. M., 1992. Fermented fish in Africa: a study on processing marketing and consumption. FAO Fisheries technical paper no. T329. FAO, Rome, Italy. ISBN: 9251032556. 80p. European Chilled Food Federation. 1997. Guidelines for good hygienic practice in the manufacture of chilled foods. Kettering, NN. Farber, J. M. 1991. Microbiological aspects of modified atmosphere packaging technology a review. J. Food Prot. 54:58-70. Garren, D. M., M. A. Harrison, and Y. W. Huang. 1994. Clostridium botulinum type E outgrowth and toxin production in vacuumskin packaged shrimp. Food Microbiol. 11:467-472. Gould, G. W. 1999. Sous vide foods: conclusions of an ECFF botulinum working party. Food Control 10:47-51. Graham, A. F., D. R. Mason, and M. W. Peck. 1996. Predictive model of the effect of temperature, pH and sodium chloride on growth from spores of non-proteolytic Clostridium botulinum. Int. J. Food Microbiol. 31:69-85. Hathaway, C.L. 1993. Clostridium botulinum and other Clostridia that produce botulinum. In Clostridium botulinum Ecology and Control in Foods. A.H.W Hauschild and K.L. Dodds (eds.), Marcel Dekker, New York. 1993.
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Hauschild, A. H. W., and R. Hilsheimer. 1979. Effect of salt content and pH on toxigenesis by Clostridium botulinum in caviar. J. Food Prot. 42:245-248. Hilderbrand, K. S. 1992. Fish smoking procedures for forced convection smokehouses, Special Report 887. Oregon State Extension Service, Newport, OR. Kautter, D. A., P. K. Lynt, T. Lily, and H. M. Solomon. 1981. Evaluation of the botulism hazard from nitrogen-packed sandwiches. J. Food Prot. 44:59-61. Kornacki, J. L., and D. A. Gabis. 1990. Microorganisms and Refrigeration Temperatures. Dairy, Food & Environ. Sanit. 10:192-195. Loha-unchit, K. 1998. How Fish Sauce is Made. Kasmas Thai Food and Travel. http://www.thaifoodandtravel.com/features/ fishsauce1.html. Lerke, P., and L. Farber. 1971. Heat pasteurization of crab and shrimp from the Pacific coast of the United States: public health aspects. J. Food Sci. 36:277-279. Lyon, W. J., and C. S. Reddmann. 2000. Bacteria associated with processed crawfish and potential toxin production by Clostridium botulinum type E in vacuumpackaged and aerobically packaged crawfish tails. J. Food Prot. 63:1687-1696. McClure, P. J., M. B. Cole, and J. P. P. M. Smelt. 1994. Effects of water activity and pH on growth of Clostridium botulinum. J. Appl. Bact. Symp. Suppl. 76:105S-114S. Moody, M.W., G.J. Flick, R.E. Martin, and A.L. Correa. 2000. Smoked, cured, and dried fish. In R.E. Martin, E.P. Carter, G.J. Flick, L.M. Davis, (eds.), Marine & Freshwater Products Handbook, 2000. Technomic Publishing Co. Lancaster, PA National Advisory Committee on Microbiological Criteria for Foods. 1992. Vacuum or modified atmosphere packaging for refrigerated raw fishery products.
Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, DC. http://www.fsis.usda.gov/OPHS/NACMCF/past/ map_ fishery.htm. Peck, M. W. 1997. Clostridium botulinum and the safety of refrigerated processed foods of extended durability. Trends Food Sci. Technol. 8:186-192. Pelroy, G. A, M. W. Eklund, R. N. Paranjpye, E. M. Suzuki, and M. E. Peterson. 1982. Inhibition of Clostridium botulinum types A and E toxin formation by sodium nitrite and sodium chloride in hot process (smoked) salmon. J. Food Prot. 45:833-841. Peterson, M. E., G. A. Pelroy, R. N. Paranjpye, F. T. Poysky, J. S. Almond, and M. W. Eklund. 1993. Parameters for control of Listeria monocytogenes in smoked fishery products: sodium chloride and packaging method. J. Food Prot. 56:938-943. Reddy, N. R., A. Paradis, M. G. Roman, H. M. Solomon, and E. J. Rhodehamel. 1996. Toxin development by Clostridium botulinum in modified atmosphere-packaged fresh tilapia fillets during storage. J. Food Sci. 61:632-635. Reddy, N. R., D. J. Armstrong, E. J. Rhodehamel, and D. A. Kautter. 1992. Shelflife extension and safety concerns about fresh fishery products packaged under modified atmospheres: a review. J. Food Saf. 12:87-118. Reddy, N. R., H. M. Solomon, H. Yep, M. G. Roman, and E. J. Rhodehamel. 1997. Shelf life and toxin development by Clostridium botulinum during storage in modified atmosphere-packaged fresh aquacultured salmon fillets. J. Food Prot. 60:1055-1063. Reddy, N. R., M. G. Roman, M. Villanueva, H. M. Solomon, D. A. Kautter, and E. J. Rhodehamel. 1996. Shelf life and Clostridium botulinum toxin development during storage of modified atmosphere-packaged fresh catfish fillets. J. Food Sci. 62:878-884. Refrigerated Foods and Microbiological Criteria Committee of the National Food
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Processors Association. 1988. Safety considerations for new generation refrigerated foods. Dairy Food Sanit. 8:5-7. Rhodehamel, E. J. 1992. FDAs concerns with sous vide processing. Food Technol. 46:73 76.Rhodehamel, E. J., H. M. Solomon, T. Lilly, Jr., D. A. Kautter, and J. T. Peeler. 1991. Incidence and heat resistance of Clostridium botulinum type E spores in menhaden surimi. J. Food Sci. 56:1562-1563, 1592. Ross, T., and P. Dalgaard. 2004. Secondary Models - A3.1.3. Salt, water-phase salt, and water activity. In R. C. McKellar and L. Xuewen (ed.), Modeling microbial responses in food. CRC Press, Boca Raton, FL. Schmidt, R. V., R. V. Lechowich, and J. F. Folinazzo. 1961. Growth and toxin production by type E Clostridium botulinum below 40F. J. Food Sci. 26:626-630. Segner, W. P, C. F. Schmidt, and J. K. Boltz. 1966. Effect of sodium chloride and pH on the outgrowth of spores of type E Clostridium botulinum at optimal and suboptimal temperatures. Appl. Microbiol.14:49-54. Skinner, G. E., and J. W. Larkin. 1998. Conservative prediction of time to Clostridium botulinum toxin formation for use with time-temperature indicators to ensure the safety of foods. J. Food Prot. 61:1154-1160. Sobel, J., et al., 2004.Foodborne botulism in the United States, 1990-2000. Emerging Infectious Diseases. 10(9): 1606-1611. Sugiyama, H., and K. S. Rutledge. 1978. Failure of Clostridium botulinum to grow in fresh mushrooms packaged in plastic film overwraps with holes. J. Food Prot. 41:348-350. U.S. Food and Drug Administration. 1996. Import Alert 16-74: automatic detention of salt-cured uneviscerated fish. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD.
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NOTES:
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CHAPTER 14: Pathogenic Bacteria Growth and Toxin Formation as a Result of Inadequate Drying

Pathogenic bacteria growth and toxin formation in the finished product as a result of inadequate drying of fishery products can cause consumer illness. The primary pathogens of concern are Staphylococcus aureus (S. aureus) and Clostridium botulinum (C. botulinum). See Appendix 7 for a description of the public health impacts of these pathogens. Control by Drying Dried products are usually considered shelf stable and are, therefore, often stored and distributed unrefrigerated. Examples of shelf-stable dried fish products are salmon jerky, octopus chips, dried shrimp, stock fish, and shark cartilage. The characteristic of dried foods that makes them shelf stable is their low water activity (Aw). Water activity is the measure of the amount of water in a food that is available for the growth of microorganisms, including pathogenic bacteria. A water activity of 0.85 or below will prevent the growth and toxin production of all pathogenic bacteria, including S. aureus and C. botulinum, and is critical for the safety of a shelf-stable dried product. S. aureus grows at a lower water activity than other pathogenic bacteria, and should, therefore, be considered the target pathogen for drying for shelf-stable products. You should select a packaging material that will prevent rehydration of the product under the
expected conditions of storage and distribution. Additionally, finished product package closures should be free of gross defects that could expose the product to moisture during storage and distribution. Chapter 18 provides guidance on control of container closures. Some dried products that are reduced oxygen packaged (e.g., vacuum packaged, modified atmosphere packaged) are dried only enough to control growth and toxin formation by C. botulinum type E and non-proteolytic types B and F (i.e., types that will not form toxin with a water activity of below 0.97). These dried products are then refrigerated to control growth and toxin formation by C. botulinum type A and proteolytic types B and F and by other pathogenic bacteria that may be present in the product, including S. aureus. The products might have the appearance of a fully dried product. Therefore, their packaging should include keep refrigerated labeling to ensure that temperature controls are applied throughout distribution. Distributing partially dried, reduced oxygen packaged products frozen also could be used to control these pathogens. However, labeling with keep frozen instructions would then be important to ensure food safety. More information on C. botulinum and reduced oxygen packaging is contained in Chapter 13. This chapter does not cover the growth of pathogenic bacteria, including S. aureus, which may occur as a result of time and temperature
293
abuse during processing, including before or during the drying process. That hazard is covered in Chapter 12. It also does not cover the control of C. botulinum type A and proteolytic types B and F and that of other pathogenic bacteria that may be present, including S. aureus, during refrigerated storage of reduced oxygen packaged, partially dried products. That hazard is covered in Chapters 12 and 13, respectively. Controlling pathogenic bacteria growth and toxin formation by drying is best accomplished by: Scientifically establishing a drying process that reduces the water activity to 0.85 or below if the product will be stored and distributed unrefrigerated (shelf stable). Note that a heat treatment, addition of chemical additives, further drying, or other treatment may be necessary to inhibit or eliminate spoilage organisms, for example, mold; Scientifically establishing a drying process that reduces the water activity to below 0.97 if the product will be stored refrigerated (not frozen) in reduced oxygen packaging; Designing and operating the drying equipment so that every unit of a product receives at least the established minimum process; Packaging the finished product in a container that will prevent rehydration. The drying operation used in the production of smoked or smoke-flavored fish is not designed to result in a finished product water activity of 0.85 or below. The controls for these products are described in Chapter 13. Because spores of C. botulinum are known to be present in the viscera of fish, any product that will be preserved by salting, drying, pickling, or fermentation should be eviscerated prior to processing (see the Compliance Policy Guide, Sec. 540.650). Without evisceration, toxin formation is possible during the process even with strict control of temperature. Evisceration should be thorough and performed to minimize contamination of the fish flesh. If even a portion
of the viscera or its contents is left behind, the risk of toxin formation by C. botulinum remains. Small fish, less than 5 inches in length, that are processed in a manner that eliminates preformed toxin and prevents toxin formation and that reach (1) a water phase salt content of 10%, a value based on the control of C. botulinum type A and proteolytic types B and F, in refrigerated products; or (2) a water activity of 0.85 or below (note that this is a value based on the minimum water activity for toxin production by S. aureus, in shelf-stable products); or (3) a pH (acidity) level of 4.6 or less in shelf-stable products are not subject to the evisceration recommendation. Strategies for controlling pathogenic
bacteria growth
Pathogens can enter the process on raw materials. They can also be introduced into foods during processing, from the air, unclean hands, insanitary utensils and equipment, contaminated water, and sewage. There are a number of strategies for the control of pathogenic bacteria in fish and fishery products. They include: Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in this chapter); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the pH in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 12);
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Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18); Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for C. botulinum, in Chapter 13; and for S. aureus in hydrated batter mixes, in Chapter 15); Killing pathogenic bacteria by cooking or pasteurization (covered in Chapter 16) or by retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (called the Low-Acid Canned Foods Regulation in this guidance document)); Killing pathogenic bacteria by processes that retain raw product characteristics (covered in Chapter 17).
if drying is not properly performed. Note that drying to control toxin formation by S. aureus will also control toxin formation by C. botulinum in these products.
2. For shelf-stable, dried products, can S. aureus toxin formation that is reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
Pathogenic bacteria growth and toxin formation as a result of inadequate drying should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard of S. aureus toxin formation (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measure that can be applied for pathogenic bacteria growth and toxin formation as a result of inadequate drying are: Proper design and control of the drying process (covered in this chapter);
3. For refrigerated or frozen, partially dried (i.e., not shelf stable) products, is it reasonably likely that C. botulinum type E and nonproteolytic types B and F will grow and form toxin in the finished product if the product is inadequately dried?

The following guidance will assist you in determining whether pathogenic bacteria growth and toxin formation as a result of inadequate drying is a significant hazard at a processing step:
1. For shelf-stable, dried products, is it reasonably likely that S. aureus will grow and form toxin in the finished product if the product is inadequately dried?
Table A-1 (Appendix 4) provides information on the conditions under which S. aureus will grow. If your food that is not distributed refrigerated or frozen and meets these conditions (i.e., in Table A-1) before drying, then drying will usually be important to the safety of the product, because it provides the barrier to S. aureus growth and toxin formation. Under ordinary circumstances, it would be reasonably likely that S. aureus will grow and form toxin in such products during finished product storage and distribution
Table A-1 (Appendix 4) provides information on the conditions under which C. botulinum type E and non-proteolytic types B and F will grow. Because of the need to prevent rehydration of dried products, these products generally will be contained in a reduced oxygen package. If your refrigerated (not frozen), reduced oxygen packaged food meets these conditions (i.e., Table A-1) before drying, then drying will usually be important to the safety of the product, because it provides the barrier to growth and toxin formation by C. botulinum type E and non-proteolytic types B and F. Note that refrigeration will control toxin formation by S. aureus and C. botulinum type A and non-proteolytic types B and F in these products. Under ordinary
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circumstances, it would be reasonably likely that C. botulinum type E and non-proteolytic types B and F will grow and form toxin in such products during finished product storage and distribution if drying is not properly performed. In addition, controlling labeling (e.g., keep refrigerated labeling) to ensure that the product is held refrigerated throughout distribution may be important to the safety of the product, because the product may appear to retailers, consumers, and end users to be shelf stable. However, if your dried, reduced oxygen packaged product is distributed frozen, then freezing may provide the barrier to growth and toxin formation by C. botulinum type E and non-proteolytic types B and F, rather than drying. In this case, labeling to ensure that the product is distributed frozen may be important to the safety of the product. Chapter 13 provides guidance on labeling controls to ensure that frozen product that supports the growth of non-proteolytic C. botulinum is distributed frozen.
4. For refrigerated or frozen, partially dried, reduced oxygen packaged dried products, can growth and toxin formation by C. botulinum type E and non-proteolytic types B and F that are reasonably likely to occur be eliminated or reduced to an acceptable level at this processing step?
Proper design and control of the drying process (covered in this chapter); Refrigeration (covered in Chapter 12) and labeling to ensure that the product is held refrigerated throughout distribution (covered in this chapter); Freezing (Chapter 13 provides guidance on labeling controls to ensure that a frozen product that otherwise supports the growth of non-proteolytic C. botulinum is distributed frozen). Intended use Because of the highly stable nature of S. aureus toxin and the extremely toxic nature of C. botulinum toxin, it is unlikely that the intended use will affect the significance of the hazard.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for pathogenic bacteria growth and toxin formation as a result of inadequate drying:
1. If you identified the hazard of pathogenic bacteria growth and toxin formation as a result of inadequate drying as significant because drying (rather than, or in addition to, refrigeration) is important to the safety of the product, you should identify the drying step as a CCP for this hazard.
Pathogenic bacteria growth and toxin formation as a result of inadequate drying should be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measures that can be applied for pathogenic bacteria growth and toxin formation as a result of inadequate drying for refrigerated or frozen, partially dried, reduced oxygen packaged products are:
Example: A salmon jerky processor that distributes the product unrefrigerated should set the CCP for controlling the hazard of pathogenic bacteria growth and toxin formation as a result of inadequate drying at the drying step. The processor would not need to identify the processing steps prior to drying as CCPs for that hazard. However, these steps may be CCPs for the control of other hazards, such as the growth of pathogenic bacteria as a result of time and temperature abuse during processing, covered by Chapter 12.
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This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Control by Drying.
2. If you identified the hazard of pathogenic bacteria growth and toxin formation as a result of inadequate drying as significant because refrigeration (in addition to drying) is important to the safety of the product, you should identify the finished product storage step and the labeling step, where you will ensure that the keep refrigerated labeling is included on every package, as a CCP, for this hazard.

The following guidance provides examples of two control strategies for pathogenic bacteria growth and toxin formation that occurs as a result of inadequate drying. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation. It is important to note that you may select a control strategy that is different from those that are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
Example: A partially dried catfish processor that distributes the product refrigerated and reduced oxygen packaged should set the CCPs for controlling the hazard of pathogenic bacteria growth and toxin formation as a result of inadequate drying at the drying step, finished product labeling step, and finished product storage step. The processor would not need to identify the processing steps prior to drying as CCPs for that hazard. However, these steps may be CCPs for the control of other hazards, such as the growth of pathogenic bacteria as a result of time and temperature abuse during processing, covered by Chapter 12. The control by drying is covered in Control Strategy Example 1 - Control by Drying. Control of labeling is referred to in this chapter as Control Strategy Example 2 Control by Refrigeration With Labeling. It should be used along with Control Strategy Example 1 - Control by Drying. Note that control of refrigerated finished product storage is covered in Chapter 12. Note also that Chapter 13 provides guidance on labeling controls to ensure that a frozen product that otherwise supports the growth of non proteolytic C. botulinum is distributed frozen.
CONTROL STRATEGY
Control by drying Control by refrigeration with labeling
CONTROL STRATEGY EXAMPLE 1 - CONTROL BY

DRYING

The minimum or maximum values for the critical factors established by a scientific study (i.e., for shelf-stable products, those which must be met in order to ensure that the finished product has a water activity of 0.85 or below; for refrigerated (not frozen), reduced oxygen packaged products, those which must be met in order to ensure that the finished product has a water activity of less than 0.97). These will likely include drying time, input/output air temperature, humidity, and velocity, as well as flesh thickness. Other critical factors that affect the rate of drying of the product may also be established by the study;
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OR The minimum percent weight loss established by a scientific study (i.e., for shelf-stable products, that which must be met in order to ensure that the finished product has a water activity of 0.85 or below; for refrigerated (not frozen), reduced oxygen packaged products, that which must be met in order to ensure that the finished product has a water activity of less than 0.97); OR For shelf-stable products:
AND For all other critical factors specified by the study:
OR
For percent weight loss:
Weigh all, or a portion, of the batch before and after drying;
Maximum finished product water activity of 0.85 or above;
OR
For water activity analysis:
OR
For refrigerated (not frozen), reduced oxygen packaged products:
Collect a representative sample of the finished product and conduct water activity analysis.
Maximum finished product water activity of less than 0.97.
For continuous drying equipment: For input/output air temperature:
Note: A heat treatment, addition of chemical additives, further drying, or other treatment may be necessary to inhibit or eliminate spoilage organisms (e.g., mold) in shelf-stable products.

Critical factors of the established drying process that affect the ability of the process to ensure the desired finished product water activity (i.e., 0.85 or below for shelf-stable products, less than 0.97 for refrigerated (not frozen), reduced oxygen packaged products). These may include drying time, air temperature, humidity, and velocity, as well as flesh thickness; OR Percent weight loss; OR Water activity of the finished product.
AND For drying time:
Measure: The revolutions per minute (RPM) of the belt drive wheel, using a stopwatch or tachometer; OR The time necessary for a test unit or belt marking to pass through the equipment, using a stopwatch;

For batch drying equipment: For drying time and input/output air temperature:
OR
Weigh all, or a portion, of the batch before and after drying;
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OR For water activity:
For water activity: Collect a representative sample of the finished product and conduct water activity analysis.
Each lot of finished product.


For batch drying equipment: For time and temperature:
Continuous monitoring, with a visual check of the recorded data at least once during each batch;
Monitoring is performed by the

equipment itself. The visual check of the data generated by this equipment, to ensure that the critical limits have consistently been met, may be performed by any person who has an understanding of the nature of the controls;
OR
Any person who has an understanding of the nature of the controls;
OR
OR
Each batch;
Each batch.
For water activity:
OR
For water activity:
For continuous drying equipment: For temperature: Continuous monitoring, with a visual check of the recorded data at least once per day;
Any person with sufficient training to perform the analysis.

AND For time:
At least once per day, and whenever any changes in belt speed are made;
Redry the product (provided that redrying does not present an unacceptable opportunity for pathogenic bacteria growth); OR Chill and hold the product for an evaluation of the adequacy of the drying process. The evaluation may involve water activity determination on a representative sample of the finished product. If the evaluation shows that the product has not received an adequate drying process, the product should be destroyed, diverted to a use in which
AND
For all other critical factors specified by the study:
OR
OR
Each lot of finished product;
299
pathogenic bacteria growth in the finished product will be controlled by means other than drying, diverted to a non-food use, or redried; OR Divert the product to a use in which the critical limit is not applicable because pathogenic bacteria growth in the finished product will be controlled by means other than drying (e.g., divert inadequately dried fish to a frozen fish operation); OR Divert the product to a non-food use; OR Destroy the product.
critical factors (e.g., a drying log that indicates input/output air humidity and/or velocity); OR Record of weight before and after drying; OR Record of water activity analysis. For continuous drying equipment: Record of continuous temperature monitoring; AND Record of visual checks of recorded data; AND Drying log that indicates the RPM of the belt drive wheel or the time necessary for a test unit or belt marking to pass through the drier; AND Records that are appropriate for the other critical factors (e.g., a drying log that indicates input/output air humidity and/or velocity); OR Record of weight before and after drying; OR Record of water activity analysis.
AND
Adjust the air temperature or velocity; OR Adjust the length of the drying cycle to compensate for a temperature or velocity drop, humidity increase, or inadequate percent weight loss; OR Adjust the belt speed to increase the length of the drying cycle.

Process validation study (except where a water activity analysis of the finished product is the monitoring procedure):

For batch drying equipment: Record of continuous temperature monitoring; AND Record of visual checks of recorded data; AND Record of notation of the start time and end time of the drying periods; AND Records that are appropriate for the other
The adequacy of the drying process should be established by a scientific study. For shelf-stable products, the drying process should be designed to ensure the production of a shelf-stable product with a water activity of 0.85. For refrigerated (not frozen), reduced oxygen packaged products, it should be designed to ensure a finished product water activity of less than 0.97. Expert knowledge of drying process calculations and the dynamics of mass transfer in processing equipment may be required
300
to establish such a drying process. Such knowledge can be obtained by education or experience or both. Establishment of drying processes may require access to adequate facilities and the application of recognized methods. The drying equipment should be designed, operated, and maintained to deliver the established drying process to every unit of a product. In some instances, drying studies may be required to establish the minimum process. In other instances, existing literature that establishes minimum processes or adequacy of equipment is available. Characteristics of the process, product, and/or equipment that affect the ability to achive the established minimum drying process should be taken into consideration in the process establishment. A record of the process establishment should be maintained; AND Finished product sampling and analysis to determine water activity at least once every 3 months (except where such testing is performed as part of monitoring); AND Before a temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a thermometer traceable to National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., air temperature) within the temperature range at which it will be used;
AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR
301
device). For example, devices subjected to high temperatures for extended periods of time may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Calibrate other instruments as necessary to ensure their accuracy; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
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TABLE 14-1
CONTROL STRATEGY EXAMPLE 1 - CONTROL BY DRYING
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example 1 - Control by Drying. This example illustrates how a processor of shelf-stable salmon jerky can control pathogenic bacteria growth and toxin formation as a result of inadequate drying. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.
Pathogenic bacteria growth and toxin formation as a result of inadequate drying may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., aquaculture drugs, environmental chemical contaminants and pesticides, parasites, and metal fragments).

(3) MONITORING WHAT HOW FREQUENCY WHO (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
RECORDS
VERIFICATION
Drying (forced convection oven)
Maximum product thickness: inch
Product thickness
Preset slicer to just less than inch
Once per day before operations
Slicer operator
Re-adjust slicer
Processing log
Documentation of drying process establishment Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Analyze the finished product sample once every 3 months for water activity Review of monitoring, corrective action and verification, records within 1 week of preparation
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TABLE 14-1

(1)
(2)
RECORDS
VERIFICATION
Drying (forced convection oven)
Minimum drying time: 5 hours
Drying time
Digital time and temperature data logger
Continuous, with visual check of recorded data each batch
Oven operator
Continue drying
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TABLE 14-1

(1)
(2)
RECORDS
VERIFICATION
Drying (forced convection oven) To achieve a final water activity of 0.85 or less
Minimum oven temperature: 140F
Oven air input temperature
Digital time and temperature data logger
Continuous, with visual check of recorded data each batch
Oven operator
Extend drying process Segregate the product and hold under refrigeration for evaluation Evaluate by performing water activity analysis on finished product Redry if less than 0.85
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CONTROL STRATEGY EXAMPLE 2 - CONTROL BY

REFRIGERATION WITH LABELING
AND Determine and correct the cause of improper labels.

Record of labeling checks.

All finished product labels must contain a keep refrigerated statement (e.g., Important, keep refrigerated until used).


Finished product labels for presence of keep refrigerated statement.

Visual examination.

Representative number of packages from each lot of a finished product.



Segregate and return or destroy any label stock or pre-labeled packaging stock that does not contain the proper statement;
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TABLE 14-2
CONTROL STRATEGY EXAMPLE 2 - CONTROL BY REFRIGERATION WITH LABELING
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Control by Refrigeration With Labeling. This example illustrates how a processor of refrigerated, partially dried catfish can control pathogenic bacteria growth and toxin formation as a result of inadequate drying. It is provided for illustrative purposes only. It may be necessary to select more than one control strategy in order to fully control the hazard, depending upon the nature of your operation.
Pathogenic bacteria growth and toxin formation as a result of inadequate drying may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and metal fragments).

(1)
(2)
Receipt of labeling
All finished product labels must contain a keep refrigerated statement
Finished product labels for the presence of the keep refrigerated statement
Visual examination
One label from each case of labels at receipt
Receiving employee
Segregate and re-label any improperly labeled product Segregate and return or destroy any label stock that does not contain the proper statement Determine and correct the cause of improper labels
CHAPTER 14: Pathogenic Bacteria Growth and Toxin Formation as a Result of Inadequate Drying Label receiving record
307
*Note: Chapter 12 covers control of pathogenic bacteria growth at the CCP of finished product storage.
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Hilderbrand, K. S. 1992. Fish smoking procedures for forced convection smokehouses, Special report 887. Oregon State University, Extension Service, Corvallis, OR. Hilderbrand, K. S., Jr. 1996. Personal communication. Oregon State University, Extension Service, Corvallis, Oregon. McClure, P. J., M. B. Cole, and J. P. P. M. Smelt. 1994. Effects of water activity and pH on growth of Clostridium botulinum. J. Appl. Bact. Symp. Suppl. 76:105S-114S. Tatini, S. R. 1973. Influence of food environments on growth of Staphylococcus aureus and production of various enterotoxins. J. Milk Food Technol. 36:559-563.
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CHAPTER 15: Staphylococcus aureus Toxin Formation in Hydrated Batter Mixes


Staphylococcus aureus (S. aureus) toxin formation in hydrated batter mixes can cause consumer illness. S. aureus is the bacterium responsible for Staphylococcal Food Poisoning (SFP). Ten to thirty outbreaks of SFP occur annually in the United States, from all sources. Symptoms include: vomiting, diarrhea, abdominal pain, nausea, and weakness. Symptoms usually start within 4 hours of consumption. Everyone is susceptible to intoxication by S. aureus toxin, with more severe symptoms, including occasionally death, occurring in infants, the elderly, and debilitated persons. Generally, it is a self-limiting illness. This chapter covers control of S. aureus toxin formation that occurs as a result of time and temperature abuse at the hydrated batter mix storage or recirculation step. This toxin in particular is a concern at this step because it is not likely to be destroyed by subsequent heating steps that the processor or the consumer may perform. Pathogenic bacteria other than S. aureus, such as those described in Chapter 12, are less likely to grow in hydrated batter mixes and/or are likely to be killed by subsequent heating. Control of S. aureus in batter mixes S. aureus can enter the process on raw materials. It can also be introduced into foods during processing, from unclean hands and insanitary utensils and equipment. The hazard develops when a batter mix is exposed to temperatures favorable for S. aureus growth for sufficient time to permit toxin development. S. aureus toxin does not normally
reach levels that will cause food poisoning until the numbers of the pathogen reach 500,000 to 1,000,000 per gram. S. aureus will grow at temperatures as low as 44.6F (7C) and at a water activity as low as 0.83 (additional information on conditions favorable to S. aureus growth is provided in Table A-1 (Appendix 4)). However, toxin formation is not likely at temperatures lower than 50F (10C) or at water activities below 0.85. For this reason, toxin formation can be controlled by minimizing exposure of hydrated batter mixes to temperatures above 50F (10C). Exposure times greater than 12 hours at temperatures between 50F (10C) and 70F (21.1C) could result in toxin formation. Exposure times greater than 3 hours at temperatures above 70F (21.1C) could also result in toxin formation. Strategies for controlling pathogen growth There are a number of strategies for the control of pathogens in fish and fishery products. They include: Managing the amount of time that food is exposed to temperatures that are favorable for pathogen growth and toxin production (covered in this chapter for S. aureus in hydrated batter mix; Chapter 13 for Clostridium botulinum; and Chapter 12 for other pathogenic bacteria and conditions); Killing pathogenic bacteria by cooking or pasteurizing (covered in Chapter 16), or retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (called the Low-Acid Canned Foods Regulation in this guidance document));
309
Killing pathogenic bacteria by processes that retain the raw product characteristics (covered in Chapter 17); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of acidity (pH) in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 4); Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18).
2. Can the hazard of S. aureus growth and toxin formation that was introduced at an earlier step be eliminated or reduced to an acceptable level at this processing step?
S. aureus toxin formation in hydrated batter mixes should be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measure that can be applied for S. aureus toxin formation in hydrated batter mixes is controlling the amount of time that hydrated batter mixes are exposed to temperatures above 50F (10C). Intended use Because of the highly heat-stable nature of S. aureus toxin, it is unlikely that the intended use will affect the significance of the hazard.

If the hazard of S. aureus toxin formation in hydrated batter mixes is significant, you should identify the hydrated batter mix storage or recirculation step as the critical control point (CCP) for this hazard. For hand-battering operations, where hydrated batter mix is stored at each hand-battering station, the hand-battering stations also should be identified as a CCP. This control approach is a control strategy referred to in this chapter as Control Strategy Example - Hydrated Batter Mix Control. Example: A mechanized breaded fish processor should set the CCP for controlling the hazard of S. aureus growth and toxin formation in hydrated batter mixes at the hydrated batter mix storage or recirculation step. The processor would not need to identify other processing steps as CCPs for that hazard.

The following guidance will assist you in determining whether S. aureus toxin formation in hydrated batter mixes is a significant hazard at a processing step:
1. Is it reasonably likely that S. aureus will grow and form toxin in the hydrated batter mix at the hydrated batter mix storage or recirculation step?
The previous section, Understand the Potential Hazard, provides information to help you decide whether the time and temperature conditions of your hydrated batter mix storage or recirculation step are favorable for S. aureus growth and toxin formation.
310

The following guidance provides an example of a control strategy for S. aureus toxin formation in hydrated batter mixes. It is important to note that you may select a control strategy that is different from that which is suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following is an example of the control strategy included in this chapter:

For continuous temperature-recording devices: Continuous monitoring, with a visual check of the recorded data at least once per day; OR For temperature-indicating devices: At least every 2 hours.

For temperature-recording devices: Monitoring is performed by the device itself. The visual check of the data generated by the device, to ensure that the critical limits have consistently been met, may be performed by any person who has an understanding of the nature of the controls; OR For temperature-indicating devices: Any person who has an understanding of the nature of the controls.
CONTROL STRATEGY
Hydrated batter mix control
CONTROL STRATEGY EXAMPLE - HYDRATED

BATTER MIX CONTROL

Hydrated batter mix should not be held for more than 12 hours, cumulatively, at temperatures between 50F (10C) and 70F (21.1C); AND Hydrated batter mix should not be held for more than 3 hours, cumulatively, at temperatures above 70F (21.1C).

Destroy the product and remaining hydrated batter mix; OR Divert the product and remaining hydrated batter mix to a non-food use; OR Hold the product and hydrated batter until it can be evaluated based on its total time and temperature exposure; OR Hold the product and hydrated batter mix until the hydrated batter mix can be sampled and analyzed for the presence of staphylococcal enterotoxin. AND

The temperature of the hydrated batter mix and the time of exposure at temperatures above 50F (10C) and above 70F (21.1C).

Use a continuous temperature-recording device (e.g., a recording thermometer); OR Use a temperature-indicating device (e.g., a thermometer) and observe the time of exposure.
311
Add ice to the hydrated batter mix storage and recirculation tank; AND/OR Make repairs or adjustments to the hydrated batter mix refrigeration equipment.
known accurate reference device (e.g., a thermometer traceable to National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., batter temperature) within the temperature range at which it will be used; AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
312

For continuous temperature-recording devices: Recorder thermometer charts or digital time and temperature data logger printouts;
AND
OR For temperature-indicating devices: Record of visual checks of devices (time and temperature).

Before a temperature-indicating device (e.g., a thermometer) or temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by: Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature;
OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point. Note that the temperature should be adjusted to compensate for altitude, when necessary; OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature reading on the device with the reading on a
TABLE 15-1
CONTROL STRATEGY EXAMPLE - HYDRATED BATTER MIX CONTROL
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example - Hydrated Batter Mix Control. This example illustrates how a breaded fish processor can control S. aureus toxin formation in hydrated batter mixes. It is provided for illustrative purposes only.
S. aureus toxin formation in hydrated batter mixes may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and metal fragments).

(1)
(2)
Batter mix recirculation tank
S. aureus growth and toxin formation
Recorder thermometer
CHAPTER 15: Staphylococcus aureus Toxin Formation in Hydrated Batter Mixes Hydrated batter mix temperature not to exceed 50F for more than 12 hours, cumulatively, nor 70F for more than 3 hours, cumulatively The temperature of the hydrated batter mix and the time of exposure at temperatures above 50F (10C) and above 70F (21.1C) Continuous, with visual check once per day Production employee Destroy hydrated batter mix and any product produced during the period of the deviation Adjust hydrated batter mix refrigeration equipment
Recorder thermometer chart
313
Check the recorder thermometer for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Baird-Parker, A. C. 1971. Factors affecting the production of bacterial food poisoning toxins. J. Appl. Bact. 34:181-197. Beckers, H. J., F. M. van Leusden, and P. D. Tips. 1985. Growth and enterotoxin production of Staphylococcus aureus in shrimp. J. Hyg., Camb. 95:685-693. Bryan, F. L. 1979. Staphylococcus aureus in food microbiology: public health and spoilage aspects. The Avi Publishing Company, Inc., Westport, CT. Buchanan, R. L. 1991. Microbiological criteria for cooked, ready-to-eat shrimp and crabmeat. Food Technol. 45:157-160. Dahl Sawyer, C. A., and J. J. Pestka. 1985. Foodservice systems: presence of injured bacteria in foods during food product flow. Ann. Rev. Microbiol. 39:51-67. Deibel, K. E. 1995. Potential of Staphylococcus aureus to produce enterotoxin in fish batter at various temperatures, p. 33. In Medallion Lab (ed.), Proceedings of the IFT Annual Meeting. Medallion Lab, Minneapolis, MN. Dengremont, E., and J. M. Membre. 1995. Statistical approach for comparison of the growth rates of five strains of Staphylococcus aureus. Appl. Environ. Microbiol. 61:4389 4395.
Duran, A. P., B. A. Wentz, J. M. Lanier, F. D. McClure, A. H. Schwab, A. Swartzentruber, R. J. Barnard, and R. B. Read. 1983. Microbiological quality of breaded shrimp during processing. J. Food Prot. 46:974-977. Godwin, G. J., R. M. Grodner, and A. F. Novak. 1977. Twenty-four hour methods for bacteriological analyses in frozen raw breaded shrimp. J. Food Sci. 42:750-754. Greenwood, M. H., E. F. C. Coetzee, B. M. Ford, P. Gill, W. L. Hooper, S. C. W. Matthews, S. Patrick, J. V. S. Pether, and R. J. D. Scott. 1985. The bacteriological quality of selected retail, ready-to-eat food products. III. Cooked crustaceans and mollusks. Environ. Health 93:236-239. Hughes, A., and A. Hurst. 1980. The effect of NaCl on the upper temperature limit for growth of and enterotoxin synthesis by Staphylococcus aureus. Can. J. Microbiol. 26:507-510. Lotter, L. P., and L. Leistner. 1978. Minimal water activity for enterotoxin A production and growth of Staphylococcus aureus. Appl. Environ. Microbiol. 36:377-380. Ostovar, K., and M. J. Bremier. 1975. Effect of thawing on growth of Staphylococcus aureus in frozen convenience food items. J. Milk Food Technol. 38:337-339. Potter, L., and L. Leistner. 1978. Minimal water activity for enterotoxin A production and growth of Staphylococcus aureus. Appl. Environ. Microbiol. 36:377-380. Raj, H. D. 1970. Public health bacteriology of processed frozen foods. Lab. Pract. 19:374 377, 394. Sutherland, J. P., A. J. Bayliss, and T. A. Roberts. 1994. Predictive modeling of growth of Staphylococcus aureus: the effects of temperature, pH and sodium chloride. Int. J. Food Microbiol. 21:217-236.
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CHAPTER 16: Pathogenic Bacteria Survival Through Cooking or Pasteurization


The survival of pathogenic bacteria through cooking or pasteurization can cause consumer illness. The primary pathogens of concern are Clostridium botulinum (C. botulinum), Listeria monocytogenes (L. monocytogenes), Campylobacter jejuni (C. jejuni), pathogenic strains of Escherichia coli (E. coli), Salmonella spp., Shigella spp., Yersinia enterocolitica (Y. enterocolitica), Staphylococcus aureus (S. aureus), Vibrio cholera (V. cholera), Vibrio vulnificus (V. vulnificus), and Vibrio parahaemolyticus (V. parahaemolyticus). See Appendix 7 for a description of the public health impacts of these pathogens. It is not practical to target viral pathogens in cooking or pasteurization processes because of their extreme heat resistance. Viral pathogens should be controlled through a rigorous sanitation regime as part of a prerequisite program or as part of Hazard Analysis Critical Control Point (HACCP) itself. The Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products regulation, 21 CFR 123 (called the Seafood HACCP Regulation in this guidance document) requires such a regime. Types of heat processing Cooking is a heat treatment, usually performed before the product is placed in the finished product container. It is applied to fishery products that are distributed either refrigerated or frozen. Generally, after cooking, fishery products are referred to as cooked, ready to eat. Examples of cooked, readyto-eat fishery products are crabmeat, lobster meat, crayfish meat, cooked shrimp, surimi-based analog products, seafood salads, seafood soups and sauces, and hot-smoked fish.
Pasteurization is a treatment (usually, but not always, the application of heat) applied to eliminate the most resistant pathogenic bacteria of public health concern that is reasonably likely to be present in the food for as long as the shelflife of the product, when stored under normal and moderate abuse conditions. With fishery products, pasteurization is usually performed after the product is placed in the hermetically sealed finished product container. It is applied to fishery products that are distributed either refrigerated or frozen. Examples of pasteurized fishery products are pasteurized crabmeat, pasteurized surimi-based analog products, and pasteurized lobster meat. In addition to eliminating bacterial pathogens, cooking and pasteurization also greatly reduce the number of spoilage bacteria present in the fishery product. These bacteria normally restrict the growth of pathogens through competition. Elimination of spoilage bacteria allows rapid growth of newly introduced pathogenic bacteria. Pathogenic bacteria that may be introduced after cooking or pasteurization are, therefore, a concern. This is especially true for pasteurization, because that process can significantly extend the shelf-life of the fishery product, providing more time for pathogenic bacteria growth and toxin formation. Retorting is a heat treatment that eliminates all food-borne pathogens and produces a product that is shelf stable. Mandatory controls for retorting are provided in the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113 (hereinafter, the Low Acid Canned Foods (LACF) Regulation), but are not covered in this chapter.
315
Goal of pasteurization Selection of the target pathogen is critical to the effectiveness of pasteurization. You should consider the potential that C. botulinum type E or non-proteolytic types B and F will survive the pasteurization process and grow under normal storage conditions or moderate abuse conditions. This is of particular concern if the product is reduced oxygen packaged (e.g., vacuum packaged or modified atmosphere packaged), does not contain a barrier that is sufficient to prevent growth and toxin formation by this pathogen, is not equipped with a time and temperature integrator, and is stored or distributed refrigerated (not frozen). In such products, you should ordinarily select C. botulinum type E and non-proteolytic types B and F as the target pathogen. For example, vacuum-packaged lobster meat that is pasteurized to kill L. monocytogenes, but not C. botulinum type E or non-proteolytic types B and F, and is not equipped with a Time-Temperature Indicator should be frozen to prevent growth and toxin formation by C. botulinum type E and non-proteolytic types B and F, and should be labeled to be held frozen and to be thawed under refrigeration immediately before use (e.g., Important, keep frozen until used, thaw under refrigeration immediately before use). If the product is not reduced oxygen packaged, or contains a barrier that is sufficient to prevent the growth and toxin formation by C. botulinum type E or non-proteolytic types B and F, or is equipped with a time and temperature integrator, or is distributed frozen, then selection of another target pathogen may be appropriate. L. monocytogenes may be selected as the target pathogen for pasteurization of this type of product because it is the most resistant bacterial pathogen of public health concern that is reasonably likely to be present. Surveys of retail display cases and home refrigerators indicate that temperatures above the minimum growth temperature of C. botulinum type E and non-proteolytic types B and F
(38F (3.3C)) are not uncommon. Therefore, refrigeration alone cannot be relied upon for control of the C. botulinum hazard. When freezing is relied upon to control the growth of C. botulinum type E and non-proteolytic types B and F, controls should be in place to ensure that the product is labeled with instructions that it be kept frozen throughout distribution. For pasteurization processes that target C. botulinum type E and non-proteolytic types B and F, generally a reduction of six orders of magnitude (six logarithms, e.g., from 103 to 10-3) in the level of contamination is suitable. This is called a 6D process. However, lower degrees of destruction may be acceptable if supported by a scientific study of the normal levels in the food before pasteurization. It is also possible that higher levels of destruction may be necessary in some foods, if especially high initial levels of the target pathogen are anticipated. Table A-4 (Appendix 4) provides 6D process times for a range of pasteurization temperatures, with C. botulinum type B (the most heat resistant form of non-proteolytic C. botulinum) as the target pathogen. The lethal rates and process times provided in the table may not be sufficient for the destruction of C. botulinum type E and non-proteolytic types B and F in dungeness crabmeat, because of the potential that naturally occurring substances, such as lysozyme, may enable the pathogen to more easily recover after heat damage. Examples of properly pasteurized products are fish and fishery products generally (e.g., surimi based products, soups, or sauces) pasteurized to a minimum cumulative total lethality of F194F (F90C) = 10 minutes, where z = 12.6F (7C) for temperatures less than 194F (90C) and z = 18F (10C) for temperatures above 194F (90C); blue crabmeat pasteurized to a minimum cumulative total lethality of F185F (F85C) = 31 minutes, where z = 16F (9C); and dungeness crabmeat pasteurized to a minimum cumulative total lethality of F194F (F90C) = 57 minutes, where z = 15.5F (8.6C). Equivalent processes at different temperatures can be calculated using the z values provided.
316
EXAMPLES OF PROPERLY PASTEURIZED PRODUCTS

PRODUCT MINIMUM CUMULATIVE TOTAL LETHALITY Z VALUE
Fish and fishery products generally (e.g., surimi based products, soups, or sauces) Blue crabmeat Dungeness crabmeat
F194F (F90C) = 10 minutes
12.6F (7C), for temperatures less than 194F (90C) 18F (10C) for temperatures above 194F (90C)
forming unit (CFU)/g and that approximately 91% are contaminated at less than 1 CFU/g. Less than 1% of raw seafood are contaminated at levels greater than 103 CFU/g and none at levels greater than 106 CFU/g. FDAs limit for L. monocytogenes in ready-to-eat products, nondetectable, corresponds to a level of less than 1 CFU/25g. Table A-3 (Appendix 4) provides 6D process times for a range of pasteurization temperatures, with L. monocytogenes as the target pathogen. Lower degrees of destruction may be acceptable if supported by a scientific study of the normal levels in the food before pasteurization. It is also possible that higher degrees of destruction may be necessary in some foods if especially high initial levels are anticipated. Products that are pasteurized in the finished product container are at risk for recontamination after pasteurization. Controls, such as container seal integrity and protection from contaminated cooling water, are critical to the safety of these products and are covered in Chapter 18. Goal of cooking for most products One reason for cooking products that will not be reduced oxygen packaged is to eliminate vegetative cells of pathogenic bacteria (or reduce them to an acceptable level) that may have been introduced to the process by raw materials or by processing that occurs before the cooking step. Selection of the target pathogen is critical to the effectiveness of cooking. Generally, L. monocytogenes is selected as the target pathogen because it is regarded as the most heat-tolerant, foodborne bacterial pathogen that does not form spores. Cooking processes are not usually designed to eliminate spores of bacterial pathogens. Determining the degree of destruction of the target pathogen is also critical. Generally, a reduction of six orders of magnitude (six logarithms, e.g., from 103 to 10-3) in the level of contamination is suitable. This is called a 6D process. Table A-3 provides 6D process times for a range of cooking temperatures, with L. monocytogenes as the target pathogen. Lower degrees of destruction
F185F (F85C) = 31 minutes F194F (F90C) = 57 minutes
16F (9C) 15.5F (8.6C)
In some pasteurized surimi-based products, salt, in combination with a milder heat pasteurization process in the finished product container, works to prevent growth and toxin formation by C. botulinum type E and non-proteolytic types B and F. An example of a properly pasteurized surimi-based product in which 2.4% water phase salt is present is one that has been pasteurized at an internal temperature of 185F (85C) for at least 15 minutes. This process may not be suitable for other types of products because of the unique formulation and processing involved in the manufacture of surimi-based products. Reduced oxygen-packaged foods that are pasteurized to control C. botulinum type E and non-proteolytic types B and F, but not C. botulinum type A and proteolytic types B and F, and that do not contain barriers to its growth should be refrigerated or frozen to control C. botulinum type A and proteolytic types B and F. Control of refrigeration is critical to the safety of these products. Further information on C. botulinum and reduced oxygen packaging is contained in Chapter 13. In cases where L. monocytogenes is selected as the target pathogen, a 6D process is also generally suitable. FDA and U.S. Department of Agricultures L. monocytogenes risk assessment indicates that approximately 8% of raw seafood are contaminated with from 1 to 103 colony
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may be acceptable if supported by a scientific study of the normal levels in the food before pasteurization. It is also possible that higher degrees of destruction may be necessary in some foods if especially high initial levels are anticipated. Goal of cooking refrigerated, reduced
oxygen-packaged products
properly cooked to eliminate C. botulinum type E and non-proteolytic types B and F is a soup or sauce that is cooked to a minimum cumulative total lethality of F194F (F90C) = 10 minutes, where z = 12.6F (7C) for temperatures less than 194F (90C) and z = 18F (10C) for temperatures above 194F (90C). Reduced oxygen-packaged soups or sauces that are cooked immediately before packaging to control C. botulinum type E and non-proteolytic types B and F, but not C. botulinum type A and proteolytic types B and F, and that do not contain barriers to its growth should be refrigerated or frozen to control C. botulinum type A and proteolytic types B and F. Control of refrigeration is critical to the safety of these products. Further information on C. botulinum and reduced oxygen packaging is contained in Chapter 13. Cooking processes that target C. botulinum type E and non-proteolytic types B and F have much in common with pasteurization processes. Like products that are pasteurized in the final container, products that are cooked and then placed in the final container also are at risk for recontamination after they are placed in the finished product container. Controls, such as container seal integrity and protection from contaminated cooling water, are critical to the safety of these products and are covered in Chapter 18. Additionally, because these products are cooked before they are packaged, they are at risk of recontamination between cooking and packaging. The risk of recontamination may be minimized by filling the container in a sanitary, automated, continuous filling system while the product is still hot (i.e., hot filling). This is another critical step for the safety of these products. This control strategy is suitable for products that are filled directly from the cooking kettle, where the risk of recontamination is minimized. It is not ordinarily suitable for products such as crabmeat, lobster meat, or crayfish meat that are handled between cooking and filling. Hot filling is also covered in Chapter 18.
Cooking is sometimes performed on products immediately before placement in reduced oxygen packaging (e.g., vacuum packaging or modified atmosphere packaging). These products include cooked, hot-filled soups, chowders, or sauces that are filled directly from the cook kettle using sanitary, automated, continuous filling systems designed to minimize risk of recontamination. They are often marketed under refrigeration, which is important for the control of C. botulinum type A and proteolytic types B and F. The cooking process for these products should be sufficient to eliminate the spores of C. botulinum type E and non-proteolytic types B and F. This is the case when the product does not contain other barriers that are sufficient to prevent growth and toxin formation by this pathogen. Generally, a 6D process (six logarithms, e.g., from 103 to 10 -3) is suitable. However, lower degrees of destruction may be acceptable if supported by a scientific study of the normal levels in the food before pasteurization. It is also possible that higher degrees of destruction may be necessary in some foods if especially high initial levels are anticipated. Table A-4 provides 6D process times for a range of cooking temperatures, with C. botulinum type B (the most heat-resistant form of non-proteolytic C. botulinum) as the target pathogen. The lethal rates and process times provided in the table may not be sufficient for the destruction of C. botulinum type E and non-proteolytic types B and F in soups or sauces containing dungeness crabmeat because of the potential that naturally occurring substances, such as lysozyme, may enable the pathogen to more easily recover after damage. An example of a product that is
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Control by cooking or pasteurization Controlling pathogenic bacteria survival through cooking or pasteurization is accomplished by: Scientifically establishing a cooking or pasteurization process that will eliminate pathogenic bacteria of public health concern or reduce their numbers to acceptable levels; Designing and operating the cooking or pasteurization equipment so that every unit of product receives at least the established minimum process; Continuously monitoring the critical process parameters to verify achievement of a scientifically established process (e.g., time and temperature). You may monitor End-Point Internal Product Temperature (EPIPT), a measurement of the temperature of the product as it exits the heat process, instead of performing continuous time and temperature monitoring. This approach is suitable if you have conducted a scientific study to validate that the EPIPT that you have selected will provide an appropriate reduction in the numbers of the target pathogen (e.g., 6D) in the slowest heating unit or portion of product under the worst set of heating conditions covered by the scientific study. You should (1) conduct a temperature distribution study within the heating system to identify any cold spots; (2) conduct a heat penetration study that accounts for the slowest heating product under the worst case heating conditions covered by the scientific study; and identify other critical factors of processing and/or packaging that affect the rate of product heating when scientifically establishing a cooking or pasteurization process (i.e., process validation). The EPIPT should be used as a monitoring technique only under those conditions that were evaluated by the scientific study. Those conditions may need to be identified as critical limits and monitored as part of the HACCP plan. EPIPT monitoring may not be an option when the objective is control of C. botulinum type E and non-proteolytic types B and F spores. These spores are far more heat resistant than vegetative
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cells of L. monocytogenes and destroying them requires an EPIPT that could be achieved only in a pressurized steam environment, making measurement impractical. Additional guidance on EPIPT monitoring can be found in Food Processors Association guidance document FPA Guidance Document: Establishing or Verifying a Heat Process for Cooked, Ready-to-Eat Seafood Products, and Heat Process Monitoring Considerations under HACCP, 2nd Edition, February 2005 and purchased at the Grocery Manufacturers Association, Washington DC 20005. Strategies for controlling pathogenic
bacteria growth
There are a number of strategies for the control of pathogenic bacteria in fish and fishery products. They include: Killing pathogenic bacteria by cooking or pasteurizing (covered in this chapter) or retorting (covered by the LACF Regulation, 21 CFR 113); Killing pathogenic bacteria by processes that retain the raw characteristics of the products (covered in Chapter 17); Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for C. botulinum, in Chapter 13; and for S. aureus in hydrated batter mixes, in Chapter 15); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of acidity (pH) in the product (covered by the Acidified Foods
regulation, 21 CFR 114, for shelf-stable acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 4); Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18).
of bacterial pathogens. For this reason, you should consider it reasonably likely that low numbers of pathogenic bacteria will be present in the product.
2. Can unsafe levels of pathogenic bacteria that were introduced at an earlier processing step be eliminated or reduced to an acceptable level at this processing step?

The following guidance will assist you in determining whether pathogenic bacteria survival through cooking and pasteurization is a significant hazard at a processing step.
1. Is it reasonably likely that unsafe levels of pathogenic bacteria will be introduced at this processing step (do unsafe levels of pathogenic bacteria come in with the raw material, or will the process introduce unsafe levels of pathogenic bacteria)?
Pathogenic bacteria survival through cooking or pasteurization should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measure that can be applied for pathogenic bacteria survival through cooking and pasteurization is proper design and control of the cooking or pasteurization process. Intended use Because cooked or pasteurized products are ready to eat, it is unlikely that the intended use will affect the significance of the hazard.
It is reasonable to assume that pathogens of various types, including those listed in Table A-1 (Appendix 4), will be present on raw fish and fishery products. They may be present only at low levels or only occasionally, but even such occurrences warrant consideration because of the potential for growth and toxin production. Pathogenic bacteria may also be introduced during processing, from the air, unclean hands, insanitary utensils and equipment, unsafe water, and sewage. Well-designed sanitation programs will minimize the introduction of pathogens. Such sanitation controls need not be part of your HACCP plan if they are monitored under your sanitation program (prerequisite program). In most cases, it is not reasonable to assume that they will fully prevent the introduction

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for the survival of pathogenic bacteria through cooking or pasteurization:
Will the finished product be pasteurized in the final container? 1. If the finished product will be pasteurized in the final container, you should identify the pasteurization step as the CCP. In this case, you would not need to identify the cooking step as a CCP for the hazard of pathogenic bacteria survival through cooking.
Example: A crabmeat processor cooks, picks, packs, and pasteurizes the crabmeat.
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The processor sets the CCP for pathogenic bacteria survival through cooking and pasteurization at the pasteurization step and does not identify the cooking step as a CCP for this hazard. This control approach is a control strategy referred to in this chapter as Control Strategy Example - Cooking and Pasteurization.
2. If the product will not be pasteurized, you should identify the cooking step as the CCP.
cook or pasteurization cycle (speed of the belt for a continuous cooker or pasteurizer), temperature of the steam or water used for cooking or pasteurization (or visual observation of minutes at a boil for cooking), initial temperature of the product, container size (e.g., can dimensions, pouch thickness), and product formulation. Other critical factors that affect the rate of heating of the product may also be established by the study; OR The EPIPT, established by a scientific study. Other critical factors that affect the rate of heating of the product may also be established by the study.
Note: EPIPT monitoring may not be an option when the objective is control of C. botulinum type E and non-proteolytic types B and F spores.
This control approach is the same as the one above and is a control strategy also referred to in this chapter as Control Strategy Example - Cooking and Pasteurization. For products in reduced oxygen packaging for which the cooking process does not target C. botulinum type E and non-proteolytic types B and F, see Chapter 13 for additional guidance.

The following guidance provides a control strategy for survival of pathogenic bacteria through cooking or pasteurization. You may select a control strategy that is different from that which is suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following is an example of the control strategy included in this chapter:

The critical factors established by a scientific study. These may include length of the cook or pasteurization cycle (speed of the belt for a continuous cooker or pasteurizer) and temperature of the steam or water used for cooking or pasteurization (or visual observation of minutes at a boil for cooking), initial temperature of the product, container size (e.g., can dimensions, pouch thickness), and product formulation; OR The EPIPT.
CONTROL STRATEGY
Cooking and pasteurization

For batch cooking or pasteurization equipment: For cooking or pasteurization temperature:
CONTROL STRATEGY EXAMPLE - COOKING AND

PASTEURIZATION

The minimum or maximum values for the critical factors established by a scientific study. These may include length of the
Use a continuous temperature-recording device (e.g., a recording thermometer). The device should be installed where it measures the coldest temperature of the cooking equipment (cold spot to be determined by a study). Where cooking
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is performed at the boiling point, visual observation of minutes at a boil may be an acceptable alternative; AND For the start and end of each cooking or pasteurization cycle:
Use equipment appropriate to the critical factor (e.g., initial temperature with a temperature-indicating device, (e.g., a thermometer);
OR For the EPIPT:
Visual observation;
AND For other critical factors: Use equipment appropriate to the critical factor (e.g., initial temperature with a temperature-indicating device, (e.g., a thermometer);
Use a temperature-indicating device (e.g., a thermometer).
For batch cooking or pasteurization equipment: For cooking or pasteurization temperature:
OR For the EPIPT:
Continuous monitoring, with a visual check of the recorded data at least once per batch;
Use a temperature-indicating device (e.g., a thermometer).
AND For the start and end of each cooking or pasteurization cycle:
For continuous cooking or pasteurization equipment: For cooking or pasteurization temperature:
Each batch;
AND For other critical factors: With sufficient frequency to achieve control;
Use a continuous temperature-recording device (e.g., a recording thermometer). The device should be installed where it measures the coldest temperature of the cooking equipment (cold spot to be determined by a study). Because of the extended time of operation of such equipment, it is unlikely that visual observation of boiling will be an acceptable alternative, even if cooking is performed at the boiling point;
OR
For the EPIPT:
Each batch.
For continuous cooking or pasteurization equipment: For cooking or pasteurization temperature:
AND For cooking or pasteurization time, use:
Continuous monitoring, with a visual check of the recorded data at least once per day;
A stopwatch or tachometer to monitor the speed of the belt drive wheel; OR A stopwatch to monitor the time necessary for a test unit or belt marking to pass through the equipment;
AND For cooking or pasteurization time:
At least once per day, and whenever any changes in belt speed are made;
AND
For other critical factors:
AND For other critical factors:
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With sufficient frequency to achieve control;
OR For the EPIPT:
AND At least every 30 minutes, and whenever any changes in product-heating critical factors occur.
Adjust the steam supply to increase the processing temperature; OR Extend the length of the cooking or pasteurization cycle to compensate for a temperature drop, using a process developed by a process authority; OR Process at a higher temperature to compensate for a low initial temperature, using a process developed by a process authority; OR Adjust the belt speed.
Who Will Perform the Monitoring?

AND For other monitoring:

For batch cooking or pasteurization equipment: For temperature monitoring:


OR
Recook or repasteurize the product; OR Chill and hold the product for an evaluation of the adequacy of the cooking or pasteurization process. If the product has not received an adequate process, it should be destroyed, diverted to a non-food use, or recooked or repasteurized; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert improperly cooked or pasteurized shrimp to a shrimp canning operation); OR Destroy the product; OR Divert the product to a non-food use.
Record of continuous temperature monitoring;

AND
Cooking log that indicates visual observation of boiling, where cooking is performed at the boiling point; AND Record of notation of the start time and end time of the cooking or pasteurization periods; AND Records that are appropriate for the other critical factors (e.g., a cooking or pasteurization log that indicates the initial temperature); OR Record of EPIPT results.
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For continuous cooking or pasteurization equipment: Record of continuous temperature monitoring; AND Record of visual checks of devices; AND Cooking or pasteurization log that indicates the RPM of the belt drive wheel or the time necessary for a test unit or belt marking to pass through the tank; AND Records that are appropriate for the other critical factors (e.g., a cooking or pasteurization log that indicates the initial temperature); OR Record of EPIPT results.

For cooking, process validation study (process establishment): The adequacy of the cooking process should be established by a scientific study. It should be designed to ensure an appropriate reduction in the number of pathogenic bacteria of public health concern. Selecting the target organism is critical. In most cases, it will be a relatively heat-tolerant vegetative pathogen, such as L. monocytogenes. However, in some cases where outgrowth of spore-forming pathogens, such as Clostridium perfringens and Bacillus cereus, during the post-cook cooling step must be prevented by eliminating these pathogens during the cook step (e.g., because cooling after cooking is not controlled (see Chapter 12)), then they will be the target organisms. Additionally, when cooking is performed immediately before reduced oxygen packaging (e.g., vacuum packaging or modified atmosphere packaging), for a product that will be marketed under refrigeration, it may be necessary for the cooking process to be sufficient to eliminate
the spores of C. botulinum type E and non proteolytic types B and F. This is the case when the product does not contain other barriers that are sufficient to prevent growth and toxin formation by this pathogen (e.g., refrigerated, vacuum packaged hot-filled soups and sauces). Generally, a 6D process is suitable, regardless of the target bacterial pathogen. However, lower degrees of destruction may be acceptable if supported by a scientific study of the normal levels in the food. Tables A-3 and A-4 provide 6D process times for a range of internal product temperatures, with L. monocytogenes and C. botulinum type B (the most heat-resistant form of non-proteolytic C. botulinum) as the target pathogens. The values provided in Table A-4 may not be sufficient for the destruction of C. botulinum type E and non-proteolytic types B and F in products containing dungeness crabmeat because of the potential protective effect of naturally occurring substances, such as lysozyme. Expert knowledge of thermal process calculations and the dynamics of heat transfer in processing equipment may be required to establish such a cooking process. Such knowledge can be obtained by education or experience, or both. Conducting a validation study for cooking processes may require access to suitable facilities and the application of recognized methods. The cooking equipment should be designed, operated, and maintained to deliver the established process to every unit of the product. In some cases, thermal death time, heat penetration, temperature distribution, and inoculated pack studies may be necessary to validate the minimum process. In many cases, establishing the minimum process may be simplified by repetitively determining the process needed to reach an internal product temperature that will ensure the inactivation of all vegetative bacterial pathogens of public health concern under the most difficult heating conditions likely to be encountered
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during processing. In other instances, existing literature or federal, state, or local regulations that establish minimum processes or adequacy of equipment are available. Characteristics of the process, product, and/ or equipment that affect the ability of the established minimum cooking process should be taken into consideration in the validation of the process. A record of the process validation study should be maintained; OR For pasteurization, process validation study (process establishment): The adequacy of the pasteurization process should be established by a scientific study. It should be designed to ensure an appropriate reduction in the number of target bacterial pathogens. Selecting the target organism is critical. In most cases, it will be the spores of C. botulinum type E and non proteolytic types B and F. In some cases (e.g., products that are distributed frozen or contain other barriers to prevent growth and toxin formation by C. botulinum type E and non-proteolytic types B and F), the process will target another pathogen, such as L. monocytogenes. Generally, a 6D process is suitable, regardless of the target pathogen. However, lower degrees of destruction may be acceptable if supported by a scientific study of the normal levels in the food. Tables A-3 and A-4 provide 6D process times for a range of internal product temperatures, with L. monocytogenes and C. botulinum type B (the most heat-resistant form of non-proteolytic C. botulinum) as the target pathogens. The values provided in Table A-4 may not be sufficient for the destruction of C. botulinum type E and non-proteolytic types B and F in products containing dungeness crabmeat because of the potential protective effect of naturally occurring substances, such as lysozyme. Expert knowledge of thermal process calculations and the dynamics of heat transfer
in processing equipment may be required to determine the target bacterial pathogen and to establish a pasteurization process. Such knowledge can be obtained by education or experience, or both. Conducting a validation study for pasteurization processes may require access to suitable facilities and the application of recognized methods. The pasteurization equipment should be designed, operated, and maintained to deliver the established process to every unit of the product. In some cases, thermal death time, heat penetration, temperature distribution, and inoculated pack studies may be necessary to validate the minimum process. In other instances, existing literature or federal, state, or local regulations that establish minimum processes or adequacy of equipment are available. Characteristics of the process, product, and/or equipment that affect the adequacy of the established minimum pasteurization process should be taken into consideration in the validation of the process. A record of the validation study should be maintained; AND Before a temperature-indicating device (e.g., a thermometer) or temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point (note that the temperature should be adjusted to compensate for altitude, when necessary); OR A combination of the above if the
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device will be used at or near room temperature; OR
Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a thermometer traceable to National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., steam temperature, water temperature, product internal temperature) within the temperature range at which it will be used;
show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Devices subjected to high temperatures for extended periods of time may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Calibrate other instruments as necessary to ensure their accuracy; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may
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TABLE 16-1
CONTROL STRATEGY EXAMPLE - COOKING AND PASTEURIZATION (COOKING MODEL)
This table is an example of a portion of a HACCP plan using Control Strategy Example - Cooking and Pasteurization (Cooking Model). This example illustrates how a processor of wild-caught cooked shrimp can control cooking using a continuous steam cooker. It is provided for illustrative purposes only.
Pathogenic bacteria survival through cooking and pasteurization may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, pathogenic bacteria growth and toxin formation during processing, food and color additives, and metal fragments).

(1)
(2)
Cooking
Pathogenic bacteria survival
Minimum cook time: 2.5 minutes
Length of the cook cycle
Belt speed measurement with stopwatch
Once per day and after any adjustment
Cooker operator
Cooking record
CHAPTER 16: Pathogenic Bacteria Survival Through Cooking or Pasteurization Minimum cook temperature: 210F Note: To achieve a 6D reduction of L. monocytogenes Temperature of steam in the cooker Digital time and temperature data logger Continuous, with visual check of recorded data once per day Cooker operator Extend process or elevate temperature to compensate for deviation from critical limit, based on alternate processes provided by the process authority Chill and hold for evaluation Data logger printout Maximum shrimp size: 40 count/pound Shrimp size Scale Hourly and after every raw material lot change or grader adjustment Grader operator Grading record
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Scientific study establishing the thermal process (process validation) Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Calibrate the scale monthly Review monitoring, corrective action and verification, records within 1 week of preparation
TABLE 16-2
CONTROL STRATEGY EXAMPLE - COOKING AND PASTEURIZATION (PASTEURIZATION MODEL)
This table is an example of a portion of a HACCP plan using Control Strategy Example - Cooking and Pasteurization (Pasteurization Model). This example illustrates how a processor of pasteurized, refrigerated blue crabmeat can control pasteurization. It is provided for illustrative purposes only.
Pathogenic bacteria survival through cooking and pasteurization may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, pathogenic bacteria growth and toxin formation during processing, recontamination after pasteurization, and metal fragments).

(1)
(2)
Batch pasteurization
Pathogenic bacteria survival
Minimum initial product temperature: 37F Minimum length of pasteurization cycle: 120 minutes Time up to 189F and time cycle ends Temperaturerecording device Each batch Pasteurizer operator
Initial temperature
Dial thermometer
Coldest can entering each batch
Pasteurizer operator
Pasteurization log
Process establishment
CHAPTER 16: Pathogenic Bacteria Survival Through Cooking or Pasteurization Extend the process or elevate the temperature to compensate for deviation from the critical limit Segregate and hold for evaluation Pasteurization log Minimum water bath temperature: 189F Temperature of water bath Temperaturerecording device Continuously, with visual check at end of batch Recorder thermometer, with visual check by pasteurizer operator Recorder thermometer chart
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Check the temperaturerecording device and dial thermometer for accuracy and damage and to ensure that they are operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, verification, and corrective action records within 1 week of preparation
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Cockey, R. R., and M. C. Tatro. 1974. Survival studies with spores of Clostridium botulinum type E in pasteurized meat of the blue crab Callinectes sapidus. Appl. Microbiol. 27:629-633. European Chilled Food Federation. 1997. Guidelines for good hygienic practice in the manufacture of chilled foods. Frazier, J. 2005. Establishing or verifying a heat process for cooked, ready-to-eat seafood products, and heat process monitoring considerations under HACCP. 2nd ed. Grocery Manufacturers Association (Food Products Association), Washington, DC. Hilderbrand, K. S., Jr. 1996. Personal communication. Oregon State University, Extension Service, Corvallis, OR. Lum, K. C. 1996. Personal communication. National Food Processors Association, Seattle, WA. Lynt, R. K., D. A. Kautter, and H. M. Solomon. 1982. Differences and similarities among proteolytic and nonproteolytic strains of Clostridium botulinum types A, B, E and F: a review. J. Food Prot. 45:466-474. Lynt, R. K., H. M. Solomon, T. Lilly, and D. A. Kautter. 1977. Thermal death time of Clostridium botulinum type E in meat of the blue crab. J. Food Sci. 42:1022-1025. Mackey, B. M., and N. Bratchell. 1989. The heat resistance of Listeria monocytogenes: a review. Lett. Appl. Microbiol. 9:89-94.
National Advisory Committee on Microbiological Criteria for Foods. 1990. Recommendations of the National Advisory Committee on Microbiological Criteria for Foods for Cooked Ready-to-Eat Shrimp and Cooked Ready-to-Eat Crabmeat. Executive Secretariat, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, DC. National Advisory Committee on Microbiological Criteria for Foods. 1990. Recommendations of the National Advisory Committee on Microbiological Criteria for Foods for Refrigerated Foods Containing Cooked, Uncured Meat or Poultry Products that are Packaged for Extended Refrigerated Shelf Life and that are Ready-to-Eat or Prepared with Little or No Additional Heat Treatment. Executive Secretariat, Food Safety and Inspection Service, U.S. Department of Agriculture, Washington, DC. National Advisory Committee on Microbiological Criteria for Foods. 1991. Listeria monocytogenes: recommendations of the National Advisory Committee on Microbiological Criteria for Foods for Refrigerated Foods. Intl. J. Food Microbiol. 14:185-246. Peterson, M. E., G. A. Pelroy, F. T. Poysky, R. N. Paranjpye, R. M. Dong, G. M. Pigott, and M. W. Eklund. 1997. Heat-pasteurization process for inactivation of nonproteolytic types of Clostridium botulinum in picked dungeness crabmeat. J. Food Prot. 60:928-934. Peterson, M. E., R. N. Paranjpye, F. T. Poysky, G. A. Pelroy, and M. W. Eklund. 2002. Control of nonproteolytic Clostridium botulinum types B and E in crab analogs by combinations of heat pasteurization and water phase salt. J. Food Prot. 65:130-139. Rippen, T., C. Hackney, G. Flick, G. Knobl, and D. Ward. 1993. Seafood pasteurization and minimal processing manual. Virginia Cooperative Extension Publication 600 0061. Virginia Sea Grant Publication VSG
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93-09. Virginia Seafood Research and Extension Center Publication VPI-SG-93-01. Blacksburg, VA. U.S. Food and Drug Administration and U.S. Department of Agriculture. 2003. Quantitative assessment of the relative risk to public health from foodborne Listeria monocytogenes among selected categories of ready-to-eat foods. http://www.fda. gov/Food/ScienceResearch/ResearchAreas/ RiskAssessmentSafetyAssessment/ucm183966. htm. U.S. Food and Drug Administration. Thermally processed low-acid foods packaged in hermetically sealed containers. In Code of Federal Regulations, 21 CFR 113. U.S. Government Printing Office, Washington, DC.
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CHAPTER 17: Pathogenic Bacteria Survival Through Processes Designed to Retain Raw Product Characteristics

The survival of pathogenic bacteria through processes designed to retain raw product characteristics can cause consumer illness. The primary pathogens of concern are Vibrio vulnificus (V. vulnificus) and Vibrio parahaemolyticus (V. parahaemolyticus). See Appendix 7 for a description of the public health impacts of these pathogens. Goal of processes designed to retain raw
product characteristics
Mild heat processing; Irradiation. HPP, IQF with extended frozen storage, mild heat processing, and irradiation are processes currently used for the treatment of raw molluscan shellfish to reduce the presence of V. vulnificus and V. parahaemolyticus to non-detectable levels. V. vulnificus and V. parahaemolyticus are naturally occurring pathogens (i.e., not associated with human or animal sources) that may be present in fish and fishery products, and in particular, raw molluscan shellfish. Non-detectable for these pathogens is defined under the National Shellfish Sanitation Program (NSSP) as less than 30 (MPN)/ gram. MPN means most probable number and it is an approximation of the bacterial population in analyzed product. Shellfish that are processed in a manner that achieves a non-detectable level for one or both of these pathogens may bear added safety labeling. Additionally, they need not meet the time from exposure to air (e.g., by harvest or receding tide) to refrigeration recommendations specific to V. vulnificus and V. parahaemolyticus described in Chapter 4. These processes also may have application to pathogens other than Vibrio spp. and to products other than raw molluscan shellfish, but such applications are not presently in commercial use in the U.S. fish and fishery products industry. Control of pathogenic bacteria growth and toxin formation during storage of these products may be important to their safety because: Pathogens that are more resistant than the target pathogen(s) may survive the process;
Some processes are designed to reduce specific pathogens to acceptable levels while retaining the sensory qualities (appearance, taste, and texture) of the raw product. These processes are particularly useful in addressing the hazard associated with the target pathogen in raw products such as raw molluscan shellfish (i.e., oysters, clams, mussels, and whole and roe-on scallops) that are intended for the raw readyto-eat market. Because these processes do not eliminate all pathogens of public health concern, they are not considered cooking or pasteurization processes. Finished products in which the raw sensory qualities are not maintained are covered in Chapter 16, Pathogenic Bacteria Survival Through Cooking and Pasteurization. Examples of processes designed to retain raw product characteristics include: High hydrostatic pressure processing (HPP); Individual quick freezing (IQF) with extended frozen storage;
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These processes may reduce the number of spoilage bacteria in the food, reducing competition for any surviving pathogenic bacteria. Strategies for controlling pathogenic bacteria growth and toxin formation are included in Chapter 12 (for pathogens other than Clostridium botulinum (C. botulinum)) and Chapter 13 (for C. botulinum). High Hydrostatic Pressure Processing (HPP) HPP is the application of hydrostatic compression in the range of 14,500 to 145,000 pound per square inch (100 to 1,000 megapascal (MPa)). These pressures are capable of inactivating pressure-sensitive pathogens, especially vegetative forms. Some pathogens are more sensitive to pressure than are others. For example, V. parahaemolyticus and V. vulnificus are particularly sensitive. However, HPP appears to have limited effect against bacterial spores like C. botulinum unless combined with other treatments, such as heat and acidity (pH). The effectiveness of the process is dependent upon the amount of pressure applied, the process temperature, and the duration of the process. However other organoleptic changes, such as texture, viscous liquor and a plumper appearance have been reported. Additionally, the pressure facilitates oyster adductor muscle changes; hence, HPP may result in a shucked oyster. Individual quick freezing (IQF) with
extended frozen storage
Mild heat processing Mild heat processing involves submerging the product first in a hot water bath for a prescribed time period followed by dipping it in an ice water bath. This process results in a reduction in the number of heat-sensitive pathogens. Some pathogens are more sensitive to heat than are others. V. parahaemolyticus and V. vulnificus are especially sensitive. Irradiation Ionizing radiation (i.e., irradiation) is used to eliminate or reduce the numbers of bacterial pathogens, parasites, and insects in food. It can also be used to delay physiological processes (e.g., ripening) in fruit and vegetables. Acceptable sources of ionizing radiation in the United States include: gamma rays from sealed units of the radionuclides cobalt-60 and cesium-137; electrons generated by machine sources (at energies not exceeding 10 million electron volts); and, x-rays generated by machine sources (at energies not exceeding 5 or 7.5 million electron volts, depending on the target material as set forth in 21 CFR 179.26 (a)). FDA has approved the use of ionizing radiation for the control of V. parahaemolyticus and V. vulnificus and other foodborne pathogens in fresh or frozen molluscan shellfish. Mandatory irradiation controls are described in the Irradiation in the Production, Processing and Handling of Food regulation (21 CFR 179). Irradiation of fresh and frozen molluscan shellfish may not exceed an absorbed dose of 5.5 kilograys (kGy) (21 CFR 179.26(b)). Some pathogens are more sensitive to ionizing radiation than are others. V. parahaemolyticus and V. vulnificus are highly sensitive, whereas Salmonella spp. and Listeria monocytogenes (L. monocytogenes) are more resistant. Bacterial spores (e.g., C. botulinum) are more resistant to ionizing radiation than are bacterial vegetative cells (e.g., L. monocytogenes). The effectiveness of the process is determined by the amount of the ionizing radiation absorbed
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IQF involves the use of cryogenic or blast freezing technology to rapidly lower the product temperature below freezing. This process results in a reduction in the number of freeze-sensitive pathogens. Some pathogens are more sensitive to freezing than are others. For example, V. parahaemolyticus and V. vulnificus are especially sensitive. To reduce V. parahaemolyticus and/ or V. vulnificus to non-detectable levels, the IQF process is followed by a period of frozen storage, which may vary depending on organism.
by the food. The amount of ionizing radiation absorbed depends on factors associated with the irradiator itself, for example, activity (energy output) of the source (e.g., x-ray intensity and electron or photon energy spectrum), source geometry (configuration or relationship between the product and the source), source-to-product distance, process path through the irradiator, and beam characteristics. The amount of absorption also depends on factors associated with the specific process, for example, length of time irradiated, conveyor speed, environmental temperature, product temperature, product composition and density, packaging size, shape and composition, and configuration of the load of product in the irradiator. It is important that every part of the product receive the prescribed absorbed dose within a specified range. Dosimetry mapping is used to document the distribution of absorbed dose throughout a process load for a particular set of irradiator parameters. All factors listed above should be considered in the establishment of the process and its verification. The parameters that could affect the absorbed dose should be monitored. A suitable dosimetry system should be used to verify the range of absorbed dose delivered to each lot of product. Control of processes intended to retain raw
product characteristics
If added safety labeling is to be used on the product or if the process is used as a substitute for the time from exposure to air (e.g., by harvest or receding tide) to refrigeration recommendations specific to V. vulnificus and V. parahaemolyticus described in Chapter 4, the ability of a process to reliably achieve the appropriate reduction of the target pathogen should be validated by a scientific study approved by the shellfish control authority with concurrence from FDA. A scientific study is conducted to initially validate the efficacy of the process and to revalidate it when there has been a change in the process. Additional guidance on the conduct of a validation study can be found in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision. Strategies for control of pathogens There are a number of strategies for the control of pathogens in fish and fishery products. They include: Killing pathogenic bacteria by processes that retain the raw product characteristics (covered in this chapter); Killing pathogenic bacteria by cooking or pasteurizing (covered in Chapter 16) or by retorting (covered by the Thermally Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113, called the Low-Acid Canned Foods Regulation in this guidance document); Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for C. botulinum, in Chapter 13; and for Staphylococcus aureus in hydrated batter mixes, in Chapter 15); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in Chapter 13);
Controlling pathogenic bacteria survival through processes intended to retain raw product characteristics is accomplished by: Scientifically establishing and validating a process that will reduce the target pathogen(s) to an acceptable level (the scientific study may be conducted by the processor or obtained from scientific literature); Designing and operating the processing equipment so that every unit of the product receives at least the established minimum process; Continuously monitoring the critical process parameters to verify achievement of a scientifically established process.
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Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of pH in the product (covered by the Acidified Foods regulation, 21 CFR 114 for shelf-stable acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the source of molluscan shellfish and time from exposure to air (e.g., by harvest or receding tide) to refrigeration in order to control pathogens from the harvest area (covered in Chapter 4); Controlling the introduction of pathogenic bacteria after the pasteurization process (covered in Chapter 18).
The shellfish control authority has conducted a risk evaluation and determined that the risk of V. parahaemolyticus illness from the consumption of oysters harvested from that growing area is reasonably likely to occur. Specific guidance for determining risk can be found in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision; The shellfish control authority has determined that harvesting occurs in the growing area at a time when average monthly daytime water temperatures exceed 60F for waters bordering the Pacific Ocean and 81F for waters bordering the Gulf of Mexico and the Atlantic Ocean (New Jersey and south), except where a more rigorous risk evaluation has led the shellfish control authority to conclude that the risk of V. parahaemolyticus illness from the consumption of oysters harvested from that growing area is not reasonably likely to occur; The waters of the state have been confirmed as the original source of oysters associated with two or more V. parahaemolyticus illnesses in the past 3 years.
2. Can unsafe levels of pathogenic bacteria that were introduced at an earlier processing step be eliminated or reduced to an acceptable level at this processing step?

The following guidance will assist you in determining whether pathogenic bacteria survival through processes designed to retain raw product characteristics is a significant hazard at a processing step:
1. Is it reasonably likely that unsafe levels of pathogenic bacteria will be introduced at this processing step (do unsafe levels of pathogenic bacteria come in with the raw material or will the process introduce unsafe levels of pathogens)?
Under ordinary circumstances, it would be reasonably likely that an unsafe level of V. vulnificus could enter the process from oysters harvested from states that have been confirmed as the original source of oysters associated with two or more V. vulnificus illnesses (e.g., states bordering the Gulf of Mexico). Under ordinary circumstances, it would be reasonably likely that an unsafe level of V. parahaemolyticus could enter the process from oysters harvested from an area that meets any one of the following conditions:
Pathogenic bacteria survival through processes designed to retain raw product characteristics should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. The preventive measure that can be applied for pathogenic
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bacteria survival through processes designed to retain raw product characteristics is proper design and control of the process. Intended use The controls for V. vulnificus and V. parahaemolyticus that are discussed in this chapter are only intended to be applied to oysters if they are intended for raw consumption. You should assume that most oysters will be consumed raw. However, controls need not be applied to oyster shellstock if tags on the containers of shellstock indicate that they must be shucked before consumption.

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for pathogenic bacteria survival through processes designed to retain raw product characteristics:
1. If the finished product is raw oyster shellstock intended for raw consumption, will it be subjected to a process in your facility that is designed to retain raw product characteristics (e.g., mild heat processed, IQF with extended frozen storage, high hydrostatic pressure processed, or irradiated) and is sufficient to reduce V. vulnificus or V. parahaemolyticus to acceptable levels (i.e., reduced to a non-detectable level, less than 30 MPN/gram)? a. If the finished product will be subjected
This control approach includes two control strategies referred to in this chapter as Control Strategy Example 1 - High Hydrostatic Pressure Processing, or Control Strategy Example 2 - IQF With Extended Frozen Storage. For guidance on controls for mild heat processing, see Control Strategy Example 1 - Cooking and Pasteurization, in Chapter 16; however, guidance on process validation for mild heat processing is more appropriately obtained from Control Strategy Example 1 - High Hydrostatic Pressure Processing, in this chapter. No specific guidance is given on control of irradiation.
b. If the product will not be subjected to a
process in your facility that is designed to retain raw product characteristics and is sufficient to reduce V. vulnificus or V. parahaemolyticus to acceptable levels, you should identify the receiving step as the CCP for V. vulnificus and/ or V. parahaemolyticus, as appropriate. Guidance for development of this control strategy is provided in Chapter 4.

The following guidance provides two control strategies for pathogenic bacteria survival through processes designed to retain raw product characteristics. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
MAY APPLY TO CONTROL STRATEGY PRIMARY PROCESSOR MAY APPLY TO SECONDARY PROCESSOR
to a process designed to retain raw product characteristics, you should identify that processing step as the CCP for the target pathogen. In this case, you would not need to identify the receiving step as a CCP for the control of the target pathogen. However, you may need to identify the receiving step as a CCP for control of other non-target pathogens (e.g., Salmonella spp. and norovirus), as described in Chapter 4.
High hydrostatic pressure processing IQF with extended frozen storage
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CONTROL STRATEGY EXAMPLE 1 - HIGH

HYDROSTATIC PRESSURE PROCESSING

For time and pressure:

The minimum or maximum values for the critical factors established by conducting a scientific study to validate the process (e.g., minimum pressure, minimum hold time at pressure, and minimum initial temperature of the product).
Continuous monitoring, with a visual check of the recorded data at least once per batch;
AND For initial temperature of the product:
Each batch;
AND For other critical factors: With sufficient frequency to achieve control.

Pressure; AND Hold time at pressure; AND Initial temperature of the product; AND Other critical factors that affect the effectiveness of the process, as specified by the study (e.g., pressurization time (step-up time), decompression time (step-down time), and treatment temperature).

For continuous-recording devices:

For time and pressure:
Use a continuous pressure-recording device (e.g., a pressure recorder);

AND
For initial temperature of the product:
Reprocess the product; OR Chill and hold the product for an evaluation of the adequacy of the high hydrostatic pressure process. If the product has not received an adequate high hydrostatic pressure process, the product should be destroyed, diverted to a non-food use, or reprocessed; OR Divert the product to a use in which the
AND
For other critical limits:
Use equipment appropriate to the critical limit.
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critical limit is not applicable (e.g., divert the improperly processed product to a canning operation); OR Destroy the product; OR Divert the product to a non-food use or a use without the added safety labeling. AND
Adjust or repair the processing equipment; AND/OR Extend the high hydrostatic pressure process to compensate for a pressure drop, using a process established by a scientific study.

Record of continuous pressure monitoring; AND Record of visual checks of recorded data; AND Record of visual observations of initial temperature of product; AND Records that are appropriate for other critical limit monitoring.
NSSP as less than 30 MPN/gram. If added safety labeling is to be used on the product or if the process is used as a substitute for the time from exposure to air (e.g., by harvest or receding tide) to refrigeration limitations described in Chapter 4, the ability of a post-harvest process to reliably achieve the appropriate reduction of the target pathogen should be validated by a study approved by the shellfish control authority with concurrence from FDA. A study is used to initially validate the efficacy of the process and to revalidate it when there has been a change in the process. Additional guidance on conducting a validation study can be found in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision (http://www.fda.gov/Food/ FoodSafety/Product-SpecificInformation/ Seafood/FederalStatePrograms/ NationalShellfishSanitationProgram/ ucm046353.htm). Expert knowledge of high hydrostatic pressure process calculations may be required to validate a high hydrostatic pressure process. Such knowledge can be obtained by education or experience, or both. Validating high hydrostatic pressure processes may require access to suitable facilities and the application of recognized methods. The equipment should be designed, operated, and maintained to deliver the established process to every unit of the product. In some instances, inoculated pack studies may be necessary to validate the minimum process. In other instances, existing literature or federal, state, or local regulations that establish minimum processes or adequacy of equipment may be available. Characteristics of the process, product, and/or equipment that affect the adequacy of the

Process validation study:
The adequacy of the high hydrostatic pressure treatment should be validated by conducting a scientific study. It should be designed to ensure an appropriate reduction in the number of the target pathogen(s). In the case of V. vulnificus or V. parahaemolyticus, it should be designed to reduce the presence of these pathogens to nondetectable levels. Non-detectable for these pathogens is defined under the
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established minimum high hydrostatic pressure process should be taken into consideration in the validation of the process. A record of process validation studies should be maintained; AND Before a temperature-indicating device (e.g., a thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
attached wires for damage or kinks. The device should be checked to ensure that it is operational; AND Calibrate the temperature-indicating device against a known accurate reference device (e.g., NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Check and calibrate other monitoring instruments as necessary to ensure their accuracy; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point (note that the temperature should be adjusted to compensate for altitude, when necessary); OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature indicated by the device with the reading on a known accurate reference device (e.g., a thermometer traceable to National Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used;
AND Once in service, check the temperatureindicating device daily before the beginning of operations. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any
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TABLE 17-1
CONTROL STRATEGY EXAMPLE 1 - HIGH HYDROSTATIC PRESSURE PROCESSING
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example 1 - High Hydrostatic Pressure Processing. This example illustrates how a raw oyster processor using a high hydrostatic pressure processor can control pathogen survival through processes designed to retain raw product characteristics. It is provided for illustrative purposes only.
Pathogen survival through processes designed to retain raw product characteristics may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., pathogens from the harvest area, environmental chemical contaminants, natural toxins, pathogenic bacteria growth and toxin formation during processing, food and color additives, and metal fragments).

(1)
(2)
SIG NIFICANT HAZARD(S)
High hydrostatic pressure processing
V. vulnificus survival
Minimum hold time: 250 seconds
Hold time at pressure
Pressurerecording device
Continuous, with visual check of the recorded data once per batch Continuous, with visual check of the recorded data once per batch Each batch Pressure equipment operator
Pressure equipment operator
Chill and hold for evaluation Adjust or repair equipment as needed
Pressure recording device printout
Process validation
CHAPTER 17: Pathogenic Bacteria Survival Through Processes Designed to Retain Raw Product Characteristics Pressure during the holding period Pressurerecording device Pressurerecording device printout Minimum initial temperature of product: 60F Initial temperature of product Dial thermometer Pressure equipment operator Initial temperature log
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Minimum pressure: 350 MPa
Check the dial thermometer for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 2 - IQF WITH

EXTENDED FROZEN STORAGE

For the IQF freezer:

There are minimum or maximum values for the critical factors established by conducting a scientific study to validate the process (e.g., amount of time to reach frozen state, maximum frozen storage temperature and minimum time)
With sufficient frequency to achieve control;
AND
For frozen storage temperature:
Continuous monitoring, with a visual check of the recorded data at least once per lot;

IQF freezer and product parameters critical to ensure that the product internal temperature is achieved within the time established by the scientific study. These variables may include, but are not limited to: initial product temperature, tunnel air temperature, time in tunnel, air velocity, belt speed, product moisture, product size, and loading pattern; AND Frozen storage temperature; AND Length of frozen storage.
AND For length of frozen storage:
Each lot, at the beginning and end of a batch.

AND For other monitoring:

Use equipment appropriate to the critical limit (e.g., initial temperature with a temperature-indicating device (e.g., a thermometer));

AND For frozen storage temperature:
Refreeze the product; OR Hold the product for an evaluation of the adequacy of the freezing process. If the product has not received an adequate process, it should be destroyed, diverted to a non-food use or other appropriate use, or refrozen; OR
AND For length of frozen storage:
Use a clock.
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Divert the product to a use in which the critical limit is not applicable (e.g., divert an improperly frozen product to a cooking or canning operation); OR Destroy the product; OR Divert the product to a non-food use or a use without the added safety labeling. AND

Process validation study:
Make repairs or adjustments to the IQF freezing equipment; OR Make repairs or adjustments to the frozen storage freezer; OR Move some or all of the product in the frozen storage freezer to a properly functioning freezer. AND/OR Extend the freezing cycle or frozen storage time period to compensate for a rise in temperature, using a process developed by a process authority;

The adequacy of the IQF with extended frozen storage process should be validated by conducting a scientific study. It should be designed to ensure an appropriate reduction in the number of the target pathogen(s). In the case of V. vulnificus or V. parahaemolyticus, it should be designed to reduce the presence of these pathogens to non-detectable levels. Non-detectable for these pathogens is defined under the NSSP as less than 30 MPN/gram. If added safety labeling is to be used on the product or if the process is used as a substitute for the time from harvest to refrigeration limitations described in Chapter 4, the ability of a post-harvest process to reliably achieve the appropriate reduction of the target pathogen should be validated by a study approved by the shellfish control authority with concurrence from FDA. A study is performed to initially validate the efficacy of the process and to revalidate it when there has been a change in the process. Process verification may also be required at predetermined intervals. Additional guidance on conducting a validation study can be found in the National Shellfish Sanitation Program Guide for the Control of Molluscan Shellfish 2007 Revision. Validating an IQF with extended frozen storage process may require access to suitable facilities and the application of recognized methods. The equipment should be designed, operated, and maintained to deliver the established process to every unit of the product. In some instances, inoculated pack studies may be necessary to establish the minimum process. In other instances, existing literature or federal, state, or local regulations that establish minimum processes or adequacy of equipment
Records that are appropriate to the monitoring;
AND
For frozen storage temperature:
Record of continuous temperature monitoring;
AND
For length of frozen storage:
Freezing log with notation of the start and end of frozen storage periods.
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may be available. Characteristics of the process, product, and/or equipment that affect the adequacy of the established minimum IQF with extended frozen storage process should be taken into consideration in the validation of the process. A record of the process validation studies should be maintained; AND Before a temperature-indicating device (e.g., a thermometer) or temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:
device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and has, where applicable, sufficient ink and paper; AND Calibrate the temperature-indicating device or temperature-recording device against a known accurate reference device (e.g., a NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Devices used to determine the core temperature of frozen fish or fishery products may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Immersing the sensor in an ice slurry (32F (0C)) if the device will be used at or near refrigeration temperature; OR Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point (note that the temperature should be adjusted to compensate for altitude, when necessary); OR Doing a combination of the above if the device will be used at or near room temperature; OR Comparing the temperature indicated by the device with the reading on a known accurate reference device (e.g., a NISTtraceable thermometer) under conditions that are similar to how it will be used (e.g., air temperature, product internal temperature) within the temperature range at which it will be used;
AND Once in service, check the temperatureindicating device or temperature-recording device daily before the beginning of operations. In addition to checking that the
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TABLE 17-2
CONTROL STRATEGY EXAMPLE 2 - IQF WITH EXTENDED STORAGE
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example 2 - IQF With Extended Storage. This example illustrates how a raw oyster processor using a continuous cryogenic freezer can control pathogen survival through processes designed to retain raw product characteristics. It is provided for illustrative purposes only.
Pathogen survival through processes designed to retain raw product characteristics may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., pathogens from the harvest area, environmental chemical contaminants and pesticides, natural toxins, pathogenic bacteria growth and toxin formation during processing, food and color additives, and metal fragments)

(1)
(2)
IQF freezer
V. vulnificus survival
The minimum or maximum values for the critical factors established by a scientific validation study* Length of frozen storage Clock Beginning and end of each lot Frozen storage operator
Critical factors that affect the effectiveness of the process, as specified by the study*
Use equipment appropriate to the critical limit*
With sufficient frequency to achieve control*
IQF equipment operator
Segregate and hold the product for evaluation Adjust or repair equipment as needed
IQF record
Process validation
CHAPTER 17: Pathogenic Bacteria Survival Through Processes Designed to Retain Raw Product Characteristics Frozen storage record Temperature of frozen storage Digital time/ temperature data logger Continuous, with visual check of recorded data once per lot Frozen storage operator Data logger printout
343
The minimum length of frozen storage established by a scientific validation study*
Check the data logger for accuracy and damage and to ensure that it is operational before putting into operation; check it daily, at the beginning of operations; and calibrate it once per year Review monitoring, corrective action, and verification records within 1 week of preparation
The maximum temperature of frozen storage established by a scientific validation study*
* Note: This plan is for illustrative purposes only. An actual plan should specify the actual critical limits for the IQF freezer, actual minimum frozen storage temperature, and actual minimum length of frozen storage. Additionally, an actual plan should specify the actual critical factors that will be monitored, the way in which they will be monitored, and the frequency of monitoring.
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Food Standards Program Codex Alimentarius Commission. 2003. Codex general standard for irradiated foods (CODEX STAN 106-1983, rev. 1-2003). Food and Agriculture Organization and World Health Organization, Rome, Italy. Food Standards Program Codex Alimentarius Commission. 2003. Recommended international code of practice for radiation processing of food (CAC/RCP 19-1979, rev. 2-2003). Food and Agriculture Organization and World Health Organization, Rome, Italy. Harewood, R. S. Rippey, and M. Montesalvo. 1994. Effect of gamma irradiation on shelf life and bacterial and viral loads in hardshelled clams (Mercenaria mercenaria). Appl. Environ. Microbiol. 60: 2666-2670. Subcommittee E10.01 on Radiation Processing: Dosimetry and Applications. 2003. Standard guide for irradiation of finfish and aquatic invertebrates used as food to control pathogens and spoilage microorganisms. ASTM International, West Conshohocken, PA. Subcommittee E10.01 on Radiation Processing: Dosimetry and Applications. 2004. Standards on dosimetry for radiation processing. ASTM International, West Conshohocken, PA.
U.S. Food and Drug Administration. Irradiation in the production, processing and handling of food. In Code of Federal Regulations, 21 CFR 179. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. Ionizing radiation for the treatment of food. In Code of Federal Regulations, 21 CFR 179.26. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. 2007. National Shellfish Sanitation Program, Guide for the Control of Molluscan Shellfish 2007 Revision. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD. http://www.fda.gov/Food/ FoodSafety/Product-SpecificInformation/ Seafood/FederalStatePrograms/ NationalShellfishSanitationProgram/ ucm046353.htm.
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CHAPTER 18: Introduction of Pathogenic Bacteria After Pasteurization and Specialized Cooking Processes

The introduction of pathogenic bacteria after pasteurization and certain specialized cooking processes can cause consumer illness. The primary pathogens of concern are Clostridium botulinum (C. botulinum), Listeria monocytogenes, Campylobacter jejuni, pathogenic strains of Escherichia coli, Salmonella spp., Shigella spp., Yersinia enterocolitica, Staphylococcus aureus (S. aureus), Vibrio cholerae, Vibrio vulnificus, and Vibrio parahaemolyticus. See Appendix 7 for a description of the public health impacts of these pathogens. Goal of pasteurization and specialized
cooking processes
competition. Rapid growth of pathogenic bacteria that may be introduced after pasteurization is, therefore, a concern. This chapter covers control of recontamination after pasteurization. For some products that are marketed refrigerated, cooking is performed immediately before reduced oxygen packaging (e.g., vacuum packaging, modified atmosphere packaging). For these products, the cooking process is targeted to eliminate the spores of C. botulinum type E and non-proteolytic types B and F, particularly when the product does not contain other barriers that are sufficient to prevent growth and toxin formation by this pathogen (e.g., many refrigerated, vacuum packaged hot-filled soups, chowders, and sauces). These specialized cooking processes, which are discussed in Chapter 16, have much in common with pasteurization processes, which are also discussed in Chapter 16. For example, control of recontamination after the product is placed in the finished product container is critical to the safety of these products. Additionally, because these products are cooked before they are packaged, they are at risk for recontamination between cooking and packaging. The risk of this recontamination may be minimized by filling directly from the cook kettle using a sanitary, automated, continuous-filling system (designed to minimize the risk of recontamination) while the product is still hot (i.e., hot filling). This control strategy may not be suitable for products such as crabmeat, lobster meat, or crayfish meat that are
Pasteurization is a heat treatment applied to eliminate the most resistant pathogenic bacteria of public health concern that is reasonably likely to be present in the food. With fishery products, pasteurization is usually performed after the product is placed in the hermetically sealed finished product container. It is applied to fishery products that are distributed either refrigerated or frozen. Examples of pasteurized fishery products follow: pasteurized crabmeat, pasteurized surimi-based analog products, and pasteurized lobster meat. In addition to eliminating pathogenic bacteria, the pasteurization process also greatly reduces the number of spoilage bacteria present in the fishery product. Spoilage bacteria normally restrict the growth of pathogenic bacteria through
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handled between cooking and filling. Hot filling is covered in this chapter. Control of pathogenic bacteria introduction
after pasteurization and after specialized cooking processes
provide limited lethality for any non-proteolytic C. botulinum spores present on the packaging material. It may also be prudent to use packaging that has been manufactured or treated to inactivate spores of C. botulinum type E and non-proteolytic types B and F (e.g., gamma irradiation and hot extrusion). FDA is also interested in comment on the utility of such measures. Strategies for controlling pathogenic
bacteria growth
There are three primary causes of recontamination after pasteurization and after cooking that is performed immediately before reduced oxygen packaging: Defective container closures; Contaminated container cooling water; Recontamination between cooking and reduced oxygen packaging. Poorly formed or defective container closures can increase the risk of pathogens entering the container through container handling that occurs after pasteurization or after the cooked product is filled into the reduced oxygen package. This risk is a particular concern during container cooling performed in a water bath. Contaminated cooling water can enter through the container closure, especially when the closure is defective. Container closure can be controlled by adherence to seal guidelines that are provided by the container or sealing machine manufacturer. Control is accomplished through periodic seal inspection. Contamination of cooling water can be controlled either by ensuring that a measurable residual of chlorine, or other approved water treatment chemical, is present in the cooling water or by ensuring that ultraviolet (UV) treatment systems for the cooling water are operating properly, particularly for systems in which the water is reused or recirculated. Recontamination between cooking and reduced oxygen packaging in continuous filling systems, where the product is packaged directly from the kettle, can be controlled by hot filling at temperatures at or above 185F (85C). FDA is interested in information on the value of adding a time component (e.g., 3 minutes) to this hot filling temperature recommendation to
There are a number of strategies for the control of pathogenic bacteria in fish and fishery products. They include: Controlling the introduction of pathogenic bacteria after the pasteurization process and after the cooking process performed immediately before reduced oxygen packaging (covered in this chapter); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by drying (covered in Chapter 14); Controlling the amount of moisture that is available for pathogenic bacteria growth (water activity) in the product by formulation (covered in Chapter 13); Controlling the amount of salt or preservatives, such as sodium nitrite, in the product (covered in Chapter 13); Controlling the level of acidity (pH) in the product (covered by the Acidified Foods regulation, 21 CFR 114, for shelf-stable acidified products, and by Chapter 13 for refrigerated acidified products); Controlling the source of molluscan shellfish and the time from exposure to air (e.g., by harvest or receding tide) to refrigeration to control pathogens from the harvest area (covered in Chapter 4); Killing pathogenic bacteria by cooking or pasteurization (covered in Chapter 16) or by retorting (covered by the Thermally
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Processed Low-Acid Foods Packaged in Hermetically Sealed Containers regulation, 21 CFR 113, called the Low Acid Canned Foods regulation in this guidance document); Killing pathogens by processes that retain the raw product characteristics (covered in Chapter 17); Managing the amount of time that food is exposed to temperatures that are favorable for pathogenic bacteria growth and toxin production (covered generally in Chapter 12; for C. botulinum, in Chapter 13; and for S. aureus in hydrated batter mixes, in Chapter 15).
pathogenic bacteria after pasteurization can include: Controlling container sealing; Controlling the residual of chlorine, or other approved water treatment chemical, in container cooling water; Controlling UV light intensity of bulbs used for treating container cooling water and the flow rate of the cooling water moving through the UV treatment system; Hot filling the product into the final container in a continuous filling system. Intended use It is unlikely that the intended use will affect the significance of this hazard.

The following guidance will assist you in determining whether introduction of pathogenic bacteria after pasteurization is a significant hazard at a processing step:
1. Is it reasonably likely that pathogenic bacteria will be introduced at this processing step (consider post-pasteurization and post-cooking processing steps only)?

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for introduction of pathogenic bacteria after pasteurization. If you identified the hazard as significant, you should identify the container sealing step, the water bath container cooling step, and the hot filling step (where applicable) as the CCPs for this hazard. Example: A crabmeat processor that pasteurizes the finished product cans after filling and cools them in a water bath should set the CCPs for introduction of pathogenic bacteria after pasteurization at the can seaming and water bath can cooling steps. This control approach is a control strategy referred to in this chapter as Control Strategy Example - Control of Recontamination.
It is reasonable to assume that in the absence of controls, pathogens of various types may enter the finished product container after pasteurization or after filling the cooked product into the reduced oxygen package. This is a particular concern for products that are cooled in a water bath.
2. Can the introduction of pathogenic bacteria after pasteurization be eliminated or reduced to an acceptable level here?
Introduction of pathogenic bacteria after pasteurization should also be considered a significant hazard at any processing step where a preventive measure is, or can be, used to eliminate the hazard (or reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. Preventive measures for introduction of
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The following guidance provides a strategy to control the introduction of pathogenic bacteria into the product after pasteurization. You may select a control strategy that is different from that which is suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following is an example of a control strategy included in this chapter:
For container cooling: For chemical treatment:
OR
Residual chlorine, or other approved water treatment chemical, in the cooling water;
For UV treatment:
Intensity of UV light; AND

Cooling water flow rate.
For hot filling: Product temperature as the product enters the final container.
CONTROL STRATEGY
Control of recontamination

For container sealing: Visual examination of containers (non destructive): Recommendations for visual examinations that ensure a reliable hermetic seal should be obtained from the container or sealing machine manufacturer. They should include:
CONTROL STRATEGY EXAMPLE - CONTROL OF

RECONTAMINATION

For container sealing: Container or sealing machine manufacturers seal guidelines. For container cooling: Measurable residual of chlorine, or other approved water treatment chemical, at the discharge point of the container cooling tank; OR Equipment manufacturers UV light intensity and flow rate guidelines. For hot filling: Product temperature of 185F (85C) or higher as the product enters the final container.
For double-seamed metal and plastic cans: The external features of the double seam should be examined for gross closure defects, including: cutovers, seam sharpness, false seams, deadheading, droop, damage to the countersink wall indicating a broken chuck, cable cuts, and product overlapping the flange. In addition, visual examination should include examination of the entire container for product leakage or other obvious defects; OR

For container sealing: Container integrity.
For pouches:
Visual examination should be sufficient to detect gross closure defects, including: cuts, fractures,
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non-bonding, malformation, puncture, abrasion, blister, contaminated seal, delamination, seal creep, wrinkle, flex cracks, crushed package, or other obvious defects; OR
testing (tensile strength), residual gas testing, electroconductivity testing, and dye testing; OR
For glass containers:

The examination should include cold water vacuum testing. Additional examinations may include: for lug-type caps, security values (lug tension) and for lug-type, twist caps, pull-up (lug position).
For glass containers:

Visual examination should be sufficient to detect gross closure and glass defects, including: cap tilt, cocked cap, crushed lug, stripped cap, cut through, and chipped and cracked glass finish;
For container cooling: For chemical treatment:
AND Detailed examination of containers (destructive): Recommendations for seal evaluation measurements that ensure a reliable hermetic seal should be obtained from the container or sealing machine manufacturer. They should include:
Measure residual of chlorine, or other approved water treatment chemical, at the discharge point of the container cooling tank;
OR For UV treatment:
For double-seamed metal and plastic cans: The examination should include a teardown examination of the can. If the micrometer method is used, three measurements, approximately 120 apart around the double seam, should be made. Measurements should include: cover hook, body hook, width, tightness, and thickness. If the optical method (seamscope or projector) is used, cuts should be made at at least two different locations, excluding the side seam juncture. Measurements should include body hook, overlap, tightness, and thickness; OR
Use a UV light meter; AND

Use a flow rate meter.
For hot filling: Use a continuous temperature-measuring instrument (e.g., a recorder thermometer).

For container sealing:
Visual examination of containers:
At least one container from each sealing head at least every 30 minutes of sealing machine operation. At a minimum, visual examinations should include those made at the beginning of the production day, and immediately after a jam in the sealing machine, or after machine adjustment, repair, or prolonged shutdown; AND
For pouches:
The examination should include burst, vacuum or bubble testing. It may also include: drop testing, peel
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Detailed examination of containers: At least one container from each sealing head at least every 4 hours of sealing machine operation. At a minimum, visual examinations should include those made at the beginning of the production day, and immediately after a jam in the sealing machine, or after machine adjustment, repair, or prolonged shutdown. For container cooling: For chemical treatment:

For container sealing: Repack and recook or repasteurize the affected product; OR Segregate and hold the product to evaluate the seriousness of the defects, which may include, but is not limited to, 100% visual inspection of all affected containers to remove the defective containers. Any containers that are found to be unsafe should be destroyed, diverted to a non-food use, or repacked and recooked; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert to a canning operation); OR Destroy the product; OR Divert the product to a non-food use. For hot filling: Recook the product; OR Segregate and hold the product for a safety evaluation. If the product is found to be unsafe, it should be destroyed, diverted to a non-food use, or recooked; OR Divert the product to a use in which the critical limit is not applicable (e.g., divert to a canning operation); OR Destroy the product; OR Divert the product to a non-food use. AND
OR
At least once every 4 hours of use;
For UV treatment:
At least daily.
For hot filling: Continuous monitoring, with a visual check of the instrument at least once per batch of cooked product.

For container sealing: Monitoring may be performed by any person who is trained and qualified to conduct container examinations. For container cooling: Monitoring may be performed by any person who has an understanding of the nature of the controls. For hot filling: For continuous temperature-measuring instruments:
Monitoring is performed by the

equipment itself. The visual check of the data generated by the equipment, to ensure that the critical limits have consistently been met, may be performed by any person who has an understanding of the nature of the controls.
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Take one or more of the following corrective actions to regain control over the operation after a critical limit deviation:
For hot filling: Record of continuous temperature monitoring; AND Record of visual checks of recorded data.
For container sealing: Identify and correct the source of the defect. For container cooling: If no measurable residual chlorine, or other approved water treatment chemical, is detected, add chlorine or adjust the chlorinemetering system and recheck for chlorine residual; OR If UV intensity is inadequate, replace or clean the bulbs or shields; OR If flow exceeds the critical limit, adjust or replace the pump. For hot filling: Adjust the cooking equipment to increase the processing temperature; OR Adjust the post-cook process to minimize time delays.

For container sealing: Obtain container seal guidelines from container or sealing machine manufacturer; AND Review monitoring and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed. For container cooling: Obtain UV light intensity and flow rate guidelines from the UV light manufacturer; AND Review monitoring and corrective action records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed. For hot filling: Before a temperature-recording device (e.g., a recording thermometer) is put into service, check the accuracy of the device to verify that the factory calibration has not been affected. This check can be accomplished by:

For container sealing: Record of visual examination of containers; AND Record of detailed examination of containers. For container cooling: For chemical treatment:
OR
Record of residual chlorine, or other approved water treatment chemical;
Immersing the sensor in boiling water (212F (100C)) if the device will be used at or near the boiling point (note that the temperature should be adjusted to compensate for altitude, when necessary); OR Comparing the temperature reading on the device with the reading on a known accurate reference device (e.g., a thermometer traceable to National
For UV treatment:
Record of UV intensity testing; AND Record of flow rate testing.
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Institute of Standards and Technology (NIST) standards) under conditions that are similar to how it will be used (e.g., product internal temperature) within the temperature range at which it will be used; AND Once in service, check the temperaturerecording device daily before the beginning of operations. Less frequent accuracy checks may be appropriate if they are recommended by the instrument manufacturer and the history of use of the instrument in your facility has shown that the instrument consistently remains accurate for a longer period of time. In addition to checking that the device is accurate by one of the methods described above, this process should include a visual examination of the sensor and any attached wires for damage or kinks. The device should be checked to ensure that it is operational and, where applicable, has sufficient ink and paper; AND Calibrate the temperature-recording device against a known accurate reference device (e.g., NIST-traceable thermometer) at least once a year or more frequently if recommended by the device manufacturer. Optimal calibration frequency is dependent upon the type, condition, past performance, and conditions of use of the device. Consistent temperature variations away from the actual value (drift) found during checks and/or calibration may show a need for more frequent calibration or the need to replace the device (perhaps with a more durable device). Devices subjected to high temperatures for extended periods of time may require more frequent calibration. Calibration should be performed at a minimum of two temperatures that bracket the temperature range at which it is used; AND
Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
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TABLE 18-1
CONTROL STRATEGY EXAMPLE - CONTROL OF RECONTAMINATION
This table is an example of a portion of a Hazard Analysis Critical Control Point plan using Control Strategy Example - Control of Recontamination. This example illustrates how a processor of pasteurized blue crabmeat, packed in steel cans, can control introduction of pathogenic bacteria after pasteurization. It is provided for illustrative purposes only.
Pathogenic bacteria recontamination after pasteurization may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides, pathogenic bacteria growth and toxin formation during processing, pathogenic bacteria survival through cooking and pasteurization, and metal fragments).

(1)
(2)
Container sealing
Pathogenic bacteria introduction
No visible cutovers, seam sharpness, false seams, deadheading, droop, damage to the countersink wall indicating a broken chuck, cable cuts, product overlapping the flange, product leakage, or other obvious defects Cover hook: .070 inch minimum; Container integrity Seamer operator
Container integrity
Visual seam examination
One can per seaming head every 30 minutes; at startup; and after jams, adjustments, repairs, and prolonged shutdowns
Seamer operator
Identify and correct the source of the defect Evaluate the seriousness of the defect, and hold for further evaluation if necessary Identify and correct the source of the defect
Visual seam examination record
CHAPTER 18: Introduction of Pathogenic Bacteria After Pasteurization and Specialized Cooking Processes Double seam teardown record tightness 80% Double seam teardown examination, using a micrometer at 3 points on the seam, 120 apart One can per seaming head every 4 hours; at startup; and after jams, adjustments, repairs, and prolonged shutdowns Rapid test Every batch Evaluate the seriousness of the defect, and hold for further evaluation if necessary Pasteurizer operator Add chlorine and recheck for residual Residual chlorine record Measurable residual chlorine Residual chlorine in water bath
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Obtain can seam guidelines from the can manufacturer Review monitoring and corrective action records within 1 week of preparation
body hook: .072-.088 inch;
width: .125 inch maximum;
thickness .052-.058 inch;
Water bath container cooling
Pathogenic bacteria introduction
* Note: The critical limits in this example are for illustrative purposes only and are not related to any recommended process
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Gavin, A., and L. M. Weddig (ed.). 1995. Canned foods principles of thermal process control, acidification, and container closure evaluation. National Food Processors Institute, Washington, DC.
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CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance
Causing Substances and Prohibited Food and Color Additives

Food allergens A number of foods contain allergenic proteins, which are natural constituents of the food that can pose a health risk to certain sensitive individuals. The symptoms of food allergies can include a tingling sensation in the mouth, swelling of the tongue and throat, difficulty in breathing, hives, vomiting, abdominal cramps, diarrhea, drop in blood pressure, loss of consciousness, and, in severe cases, death. The Food Allergen Labeling and Consumer Protection Act of 2004 amended the Federal Food, Drug, and Cosmetic Act (FFD&C Act). The FFD&C Act now requires that all foods that are not raw agricultural commodities and that contain a major food allergen be labeled to clearly identify the name of the food source from which the allergen is derived (21 CFR U.S.C. 343(w)(1)). The Act defines the following eight foods and any ingredients that contain protein derived from these eight foods (with certain exemptions noted in section 201(qq) (2) of the Act) as major food allergens: Milk; Eggs; Fish (e.g., bass, cod, or flounder); Crustacean shellfish (e.g., crab, lobster, or shrimp); Tree nuts (e.g., almonds, pecans, or walnuts); Peanuts; Wheat; and Soybeans.
The FFD&C Act requires that the name of the food source from which a major food allergen is derived be the same as the name of the major food allergen itself for the following five foods: milk; egg; wheat; peanuts; and soybeans (e.g., milk must be listed as milk). The name of the food source that must be listed on the label for tree nuts must be the specific type of tree nut (e.g., almonds, pecans, or walnuts). Likewise, the name of the food source that must be listed on the label for fish or crustacean shellfish must be the specific type of fish (e.g., bass, cod, or flounder) or crustacean shellfish (e.g., crab, lobster, or shrimp) (21 CFR U.S.C. 343(w)(2)). The market names of species of fish and crustacean shellfish should be used to identify the food source of these two major food allergens. The market names are found in the document Guidance for Industry: The Seafood List: FDAs Guide to Acceptable Market Names for Seafood Sold in Interstate Commerce revised 2009 ((http://www.fda.gov/ Food/GuidanceComplianceRegulatoryInformation/ GuidanceDocuments/Seafood/ucm113260.htm). You may add the term fish to the market name on the label if you believe that the market name may not otherwise be recognized to be fish by the consumer (e.g., gar fish). To meet the requirements of the FFD&C Act, the food labels of packaged fish and fishery products that are or contain a major food allergen must declare the name of the food source for the allergen, either: (1) Within the list of ingredients, in parentheses immediately after the common or usual
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives
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name of the ingredient that is a major food allergen, (e.g., whey (milk)) when its food source name: (a) is not already included as part of that ingredients common or usual name (e.g., the food source name milk is included in the name of the ingredient non-fat dried milk); or (b) does not appear elsewhere in the ingredient list (e.g., if the food contains both casein and whey and the label lists whey (milk), the term (milk) need not follow the term casein); or (2) In a separate Contains statement immediately after or adjacent to the list of ingredients in a print size no smaller than that used for the ingredient list (e.g., Contains shrimp and eggs). If a Contains statement is included on the label, it must identify the food source names of all major food allergens present as ingredients whether or not those food source names were previously mentioned within the list of ingredients (21 CFR U.S.C. 343(w)(1)). This chapter contains guidance on the kinds of preventive controls that may be suitable to ensure proper labeling if your fish or fishery product is made in whole or in part of a food that is a major food allergen. As a practical matter, this guidance covers all finfish and crustacean shellfish and all other fishery products (e.g., molluscan shellfish) that contain one or more of the other major food allergens. Labeling controls that are designed to ensure that any major food allergen that is present in a food is declared on the label are the most effective means of controlling this hazard. However, such controls are not suitable to prevent the unintentional introduction of allergenic proteins from foods that contain these allergens into foods that are not intended to contain them, through cross-contact (e.g., use of common equipment, improper production scheduling, or improper use
of rework material). Unintentional introduction of allergenic proteins should be controlled through rigorous process controls, either as part of a prerequisite program or as part of the Hazard Analysis Critical Control Point (HACCP) program itself. The Fish and Fishery Products regulation, 21 CFR 123 (called the Seafood HACCP Regulation in this guidance document), requires such a regime. Food and color additives Certain food and color additives can cause hypersensitivity reactions, or food intolerances, in some consumers. Although in most cases there are no known allergic mechanisms, symptoms may be similar to those caused by food allergens and can include a tingling sensation in the mouth, swelling of the tongue and throat, difficulty in breathing (e.g. asthma), hives, vomiting, abdominal cramps, and diarrhea. Examples of such food and color additives that are used in fish and fishery products include sulfiting agents and FD&C Yellow No. 5 (Yellow No. 5) described below. Sulfiting agents are mostly used during on board handling of shrimp and lobster to prevent the formation of black spot. They are sometimes used by cooked octopus processors as an antioxidant, to retain the red color of the octopus skin. They are also sometimes used by conch processors to prevent discoloration or are used as stabilizers in some breading meals added to fish. People sensitive to sulfiting agents can experience symptoms that can range from mild severity to life-threatening reactions. Yellow No. 5 is sometimes added to smoked fish to impart color. To help protect people who are sensitive to Yellow No. 5, FDAs regulation for Yellow No. 5 states that any food for human use that contains Yellow No. 5 must specifically declare the presence of the color additive by listing it as an ingredient (21 CFR 74.705(d)(2)). If Yellow No. 5 is added to smoked fish but is not declared, the product not only is misbranded
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under section 403 of the FFD&C Act, but also is adulterated under section 402(c). (21 U.S.C. 343(m) and 342(c)). People sensitive to Yellow No. 5 can experience symptoms that can range from mild to moderate severity. Under the FFD&C Act, a use or intended use of a food or additives is deemed unsafe unless the use or intended use either conforms with a regulation prescribing the conditions for safe use or the terms of an exemption for investigational use. A food additive that is a food contact substance also may be used in accordance with an effective notification (21 U.S.C. 348 and 21 U.S.C. 379e). Any food that contains an unsafe food additive or color additive is deemed adulterated under sections 402(a)(2)(C)(i) and 402(c) of the FFD&C Act, respectively (21 U.S.C 342(a)(2)(C)(i) and 342(c)). The FFD&C Act excludes from the definition of food additive substances that are generally recognized among experts qualified by scientific training and experience to evaluate their safety as having been adequately shown through scientific procedures (or, in the case of a substance used in food prior to January 1, 1958, through either scientific procedures or experience based on common use in food) to be safe under the conditions of their intended use (21 U.S.C. 321 (s)). A substance (other than a food contact substance) added to food for a use that is not generally recognized as safe (GRAS) under the conditions of its intended use and is not otherwise excluded from the food additive definition in section 201(s) of the FFD&C Act, must be used in accordance with a food additive regulation permitting that specific use (21 CFR 348). Otherwise, the use of that substance in food makes the food adulterated under section 402(a)(2)(C) of the FFD&C Act. Additionally, food may be deemed adulterated if it contains a poisonous or deleterious substance that may render the food injurious to health, but if the substance is not an added substance, the food is not considered adulterated if the quantity of the substance in the food does not ordinarily render
the food injurious to health (21 U.S.C. 342(a) (1)). It is important to note that there is no GRAS status for color additives. In addition to the statutory requirements that ensure the safety of substances added to food, there are labeling requirements that apply to ingredients in food. Under the FFD&C Act, a food is deemed misbranded unless the label bears the common or usual name of each ingredient with the exception of spices, flavorings, and color additives not subject to certification by FDA (21 U.S.C. 343(i)). This list of ingredients on the food label is especially important for people who need to avoid certain ingredients for health reasons. If a substance is an incidental additive and has no functional or technical effect in the finished product, then it need not be declared on the label. Incidental additives are usually either processing aids present in the finished food or substances that have migrated to the food from packaging or equipment. Sulfiting agents, which are added to food as preservatives, are considered to be incidental only if they have no technical effect in the food and are present at less than 10 parts per million (ppm) (21 CFR 101.100(a)(4)). Currently, there are six sulfiting agents allowed in processed food. The names by which they are listed on food labels are: sulfur dioxide (21 CFR 182.3862); sodium sulfite (21 CFR 182.3798); sodium bisulfite (21 CFR 182.3739); sodium metabisulfite (21 CFR 182.3766); potassium bisulfite (21 CFR 182.3616); and potassium metabisulfite (21 CFR 182.3637). The amount of any one or a combination of any of the six sulfiting agents that may be added to a processed food is restricted by Current Good Manufacturing Practices (CGMP) (See 21 CFR part 182, Subpart D). Under CGMPs, the quantity of sulfiting agents added to food should not exceed the amount necessary to achieve the
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technical effect. If the total amount of sulfiting agent added to food results in a concentration of 10 ppm or greater, which is the current limit of analytical detection identified in the Code of Federal Regulation 101.100(a)(4), then the sulfiting agents are not exempt from FFD&C Act food labeling requirements and must be listed as an ingredient on the product label (21 CFR 101.100(a)(4)). Table 19-1, Rationale for a Finished Product Sulfiting Agent Declaration, provides several examples of raw materials treated with sulfiting agents and the rationale for deciding whether or not the finished product requires a sulfiting agent declaration. Example: A processor receives frozen, raw, headless, shell-on shrimp that are labeled with a sulfiting agents declaration. The shrimp were treated with sulfiting agents to prevent the formation of black spot during on-board handling. The processor thaws, peels, and deveins the shrimp, and then adds it to a gumbo in which the processor has determined that the final sulfiting agents concentration is less than 10 ppm. Because the sulfiting agents no longer has a functional effect in the finished food, and because the concentration of the sulfiting agents is less than 10 ppm in the finished product, the processor is not required to have a sulfiting agents declaration on the label of the shrimp gumbo. Example: A processor receives frozen, raw, headless, shell-on shrimp that are labeled with a sulfiting agents declaration. The processor uses the shrimp to prepare a shell-on, deveined, easy-peel shrimp, which is packaged and refrozen. Because the sulfiting agents continue to have a functional (ongoing technical) effect in the finished product, the processor is required to have a sulfiting agents declaration on the finished product label, regardless of the concentration of sulfiting agents in the finished product.
Certain other food and color additives are specifically prohibited from use in food because of a determination by FDA that they present a potential risk to the public health (see 21 CFR part 189 and 21 CFR 81.10). Examples of such food and color additives are coumarin, safrole, and FD&C Red No. 4 (Red No. 4).
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TABLE 19-1
RATIONALE FOR A FINISHED PRODUCT SULFITING AGENT DECLARATION

Is a Sulfiting Agent Declaration Required?
EXAMPLES OF FINISHED FOOD <10 PPM SULFITING AGENT LEVEL IN FINISHED FOOD 10 PPM
EXAMPLES OF SULFITING AGENT USE
Raw, shell-on shrimp or lobster treated with sulfiting agents to prevent black spot YES1 Cooked octopus Conch meat
Raw, shell-on shrimp or lobster YES1
Sulfiting agents added to cooked octopus as an antioxidant to retain the red skin color of the octopus
Sulfiting agents added to conch meat to prevent discoloration Raw, peeled shrimp or lobster meat NO2 Food containing raw, peeled shrimp or lobster meat as an ingredient (e.g., seafood casserole) YES2
Raw, shell-on shrimp or lobster treated with sulfiting agents to prevent black spot
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Raw, shell-on shrimp or lobster treated with sulfiting agents to prevent black spot
1. The sulfiting agents have an ongoing technical or functional effect on/in the finished food and must be declared regardless of the level in the finished food 2. The sulfiting agents have no technical or functional effect in the finished food and do not have to be declared unless the level in the finished food is either 10 ppm or the sulfiting agents were added to the finished food at any level. To further clarify, if a sulfiting agent or a combination of sulfiting agents is added to finished food such that their collective concentration in/on the finished food is 10 ppm , then you must declare each by its approved label name (listed above)(21CFR101.100).

The following guidance will assist you in determining whether undeclared major food allergens, certain food intolerance causing substances, and prohibited food and color additives are a significant hazard at a processing step:
1. Is it reasonably likely that an undeclared major food allergen, undeclared food intolerance causing substance (e.g., sulfiting agents or Yellow No. 5), or prohibited food or color additive (e.g., coumarin, safrole, or Red No. 4) will be introduced at each processing step (e.g., does it come in with the raw material or will the process introduce it)?
variation in formulation to establish that sulfiting agents will not be present at 10 ppm or greater in the finished product; Product formulation step, if your finished product contains one or more of the major food allergens (including non-fishery allergens) listed in the previous section, Understand the Potential Hazard.; Product formulation step, if you have an ingredient that is or contains one or more of the major food allergens (including non-fishery allergens) or food intolerance causing substances in your facility or use such an ingredient in the formulation of any of your products; Product formulation step, if your finished product is cooked octopus or conch meat, because of the potential presence of sulfiting agents. However, you may not need to identify the hazard as significant if you do not have sulfiting agents in your facility and do not use it in the formulation of any of your products; Product formulation step, if your finished product is a formulated fishery product (i.e., a product in which two or more ingredients are combined) because of the potential presence of Yellow No. 5 or sulfiting agents. However, you may not need to identify the hazard as significant if you do not have Yellow No. 5 in your facility and do not use it in the formulation of any of your products; and Ingredient receiving step, if you receive ingredients in which you have reason to believe prohibited food or color additives (e.g., coumarin, safrole, or Red No. 4) may be present, based, for example, on an historic occurrence of the additive in that ingredient.
2. Can the hazard of undeclared major food allergens, and certain food intolerance causing substances, and prohibited food and color
Under ordinary circumstances, you should consider whether undeclared major food allergens, certain food intolerance causing substances, and prohibited food and color additives are a significant hazard at the: Receiving step, if your finished product is or contains finfish or crustacean shellfish, because they are major food allergens; Receiving step, if your finished product contains either shrimp or lobster, because there is a potential for sulfiting agents to be present. However, there may be circumstances that would allow you to conclude that the hazard is not reasonably likely to occur. For example, sulfiting agents may not be used in aquacultured shrimp from some regions. You should be guided by information about the historical use of sulfiting agents in your region. Also, in some formulated finished products that contain shrimp or lobster, the sulfiting agent may not have a functional effect and may not be present at 10 ppm or greater. You should conduct a study that tests the range of concentration of sulfiting agents in the raw material and possible
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additives that were introduced at an earlier step be eliminated or reduced to an acceptable level at this processing step?
ingredients in which you have reason to believe the additive may be present (with appropriate verification). Intended use In the case of undeclared major food allergens and certain food intolerance causing substances and prohibited food and color additives, it is not likely that the significance of the hazard will be affected by the intended use of the product.
Undeclared major food allergens, food intolerance causing substances and prohibited food and color additives should also be considered a significant hazard at a processing step if a preventive measure is or can be used to prevent or eliminate the hazard or to reduce the likelihood of its occurrence to an acceptable level. Preventive measures for undeclared major food allergens, food intolerance causing substances and prohibited food and color additives include: Reviewing finished product labels to ensure that the presence of certain food intolerance causing substances (e.g., sulfiting agents or Yellow No. 5) is declared; Testing incoming shrimp or lobster for residues of sulfiting agents; Reviewing a suppliers certification of the lack of sulfiting agent use on incoming lots of shrimp or lobster (with appropriate verification); Reviewing the labeling (or accompanying documents, in the case of unlabeled product) on shipments of shrimp or lobster received from another processor for the presence of a sulfiting agent declaration; Reviewing finished product labels to ensure that the presence of the major food allergens, listed in the previous section, Understand the Potential Hazard is declared; Testing incoming lots of ingredients for the presence of prohibited food and color additives that you have reason to believe may be present; Reviewing a suppliers certification of the lack of prohibited food and color additive use in incoming lots of

The following guidance will assist you in determining whether a processing step is a critical control point (CCP) for undeclared major food allergens, certain food intolerance causing substances and prohibited food and color additives:
1. In the case of shrimp or lobster for which you have identified sulfiting agents as a significant hazard, will the finished product label declare the presence of sulfiting agents? a. If the finished product label will declare
the presence of sulfiting agents, you should identify the finished product labeling step as the CCP and review the labels at that step. You would not need to identify the shrimp or lobster receiving step as a CCP for this hazard. Example: A frozen shrimp processor labels all of the finished product with a sulfiting agent declaration. The processor should set the CCP for sulfiting agents at the finished product labeling step, where labels would be reviewed for the presence of the declaration. The processor would not need to have a CCP for this hazard at the shrimp receiving step. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1
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- Finished Product Labeling for Control of Food Intolerance Causing Substances from Raw Materials.
b. If the finished product labeling will not
declare the presence of sulfiting agents, you should identify the raw material receiving step as the CCP, where you could screen incoming lots for the presence of sulfiting agents. Preventive measures that can be applied here include: Testing incoming shrimp or lobster for residues of sulfiting agents at or above 10 ppm. Example: A frozen shrimp processor receives shrimp directly from the harvest vessel and does not label the finished product with a sulfiting agent declaration. The processor should set the CCP for sulfiting agents at the raw material receiving step and test incoming lots of shrimp for the presence of sulfiting agents. The processor would not need to have a CCP for this hazard at finished product labeling. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 - Raw Material Testing for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives From Raw Materials. Receiving a suppliers certification of the lack of sulfiting agent use on incoming lots of shrimp or lobster (with appropriate verification). Example: A frozen shrimp processor receives shrimp directly from the harvest vessel and does not label the finished product with a sulfiting agent
declaration. The processor should set the CCP for sulfiting agents at the raw material receiving step and obtain certificates from the harvest vessels that sulfiting agents were not used on the shrimp. The processor should verify the effectiveness of the monitoring procedures by collecting quarterly samples of all incoming shrimp and samples of incoming shrimp from all new suppliers and analyzing for the presence of sulfiting agents. The processor would not need to have a CCP for this hazard at finished product labeling. This control approach is a control strategy referred to in this chapter as Control Strategy Example 3 Review of Suppliers Certificates for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives from Raw Materials. Reviewing the labeling (or accompanying documents, in the case of an unlabeled product) on shipments of shrimp or lobster received from another processor for the presence of a sulfiting agent declaration (with appropriate verification). Example: A frozen shrimp processor receives shrimp from another processor and does not label the finished product with a sulfiting agent declaration. The processor should set the CCP for sulfiting agents at the raw material receiving step and reject incoming lots that are identified as having been treated with a sulfiting agent (e.g., identified on the label or, in the case of unlabeled product, on documents accompanying the shipment). The processor should verify the effectiveness of the monitoring
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procedures by collecting quarterly samples of all incoming shrimp and samples of incoming shrimp from all new suppliers and analyzing for the presence of sulfiting agents. The processor would not need to have a CCP for this hazard at finished product labeling. This control approach is a control strategy referred to in this chapter as Control Strategy Example 4 - Review of Suppliers Labeling for Control of Food Intolerance Causing Substances from Raw Materials.
c. If the finished product label will declare
that the appropriate label is being applied based on the results of the raw material testing. The processor would not need to have a CCP for this hazard at the raw material receiving step, although controls would be exercised there by performing raw material testing at the receiving step. This control approach is a control strategy referred to in this chapter as Control Strategy Example 5 Finished Product Labeling Based on Raw Material Testing for Control of Food Intolerance Causing Substances from Raw Materials. Receiving a suppliers certification of the lack of sulfiting agent use on incoming lots of shrimp or lobster (with appropriate verification) and review of finished product labels. Example: A frozen shrimp processor receives shrimp directly from the harvest vessel and labels the finished product with a sulfiting agent declaration only if a lot of raw material shrimp is received without a certificate attesting to the absence of sulfiting agent use. The processor should set the CCP for sulfiting agents at the finished product labeling step and check that the appropriate label is being applied based on the presence or absence of a certificate. The processor should verify the effectiveness of the monitoring procedures by collecting quarterly samples of incoming shrimp for the presence of sulfiting agents. The processor would not need to have a CCP for this hazard at the raw material receiving step, although controls for the receipt of a certificate attesting to the absence of sulfiting agent use would be applied there. This control approach is a control
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the presence of sulfiting agents only when it is present in the raw material, you should identify the finished product labeling step as the CCP, where you can ensure that the appropriate label is placed on the package based on the results of screening performed at the receiving step for the presence of sulfiting agents. You would not need to identify the shrimp or lobster receiving step as a CCP for this hazard, although you would be exercising controls by performing raw material tests. Preventive measures that can be applied here include: Testing incoming shrimp or lobster for detectable residues of sulfiting agents at or above 10 ppm and review of finished product labels. Example: A frozen shrimp processor receives shrimp directly from the harvest vessel and labels the finished product with a sulfiting agent declaration only if testing at receiving step identifies a residue of a sulfiting agent. The processor should set the CCP for sulfiting agents at the finished product labeling step and check
strategy referred to in this chapter as Control Strategy Example 6 Finished Product Labeling Based on Review of Suppliers Certificates for Control of Food Intolerance Causing Substances from Raw Materials. Reviewing the labeling (or accompanying documents, in the case of an unlabeled product) on incoming shipments of shrimp or lobster received from another processor for the presence of a sulfiting agent declaration (with applicable verification), and review of finished product labels. Example: A frozen shrimp processor receives shrimp (as raw material) from another processor and labels the finished product with a sulfiting agent declaration only if the incoming lot was identified on the labeling (or, in the case of unlabeled product, on documents accompanying the shipment) as having been treated with a sulfiting agent. The processor should set the CCP for sulfiting agents at the finished product labeling step and check that the appropriate label is being applied based on the raw material label review. The processor should verify the effectiveness of the monitoring procedures by collecting quarterly samples of all incoming shrimp and collect at least one representative sample for each new supplier and analyzing for the presence of sulfiting agents. The processor would not need to have a CCP for this hazard at the raw material receiving step, although controls for reviewing the labeling (or, in the case of unlabeled product, on documents accompanying the shipment) would be applied there.
This control approach is a control strategy referred to in this chapter as Control Strategy Example 7 Finished Product Labeling Based on Review of Suppliers Labeling for Control of Food Intolerance Causing Substances from Raw Materials.
2. In the case of (1) cooked octopus or conch meat for which you have identified sulfiting agents as a significant hazard; (2) products for which you have identified Yellow No. 5 as a significant hazard because you use one of this color additive in the product formulation; and (3) products for which you have identified undeclared major food allergens as a significant hazard, you should identify the finished product labeling step as the CCP, where you can ensure that the appropriate label is placed on the package based on the results of a review of the product formula for that product. You would not need to identify the product formulation step as a CCP for this hazard, although you may be exercising control at that point.
Example: A smoked sablefish processor treats the fish with Yellow No. 5 before smoking. The processor should set the CCP for Yellow No. 5 at the finished product labeling step, where the labels would be examined to ensure that the color additive is declared. The processor would not need to have a CCP for this hazard at the treatment (product formulation) step. Example: A cooked octopus processor treats the fish with a sulfiting agent. The processor should set the CCP for sulfiting agents at the finished product labeling step, where the labels would be examined to ensure that the food additive is declared. The processor would not need to have a CCP for this hazard at the treatment (product formulation) step.
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Example: A breaded fish processor uses pollock fillets and a batter mix containing egg and wheat for some formulations but not others listing egg, wheat, and pollock on the label only when those ingredients are included in the formulation. The processor should set the CCP for undeclared major food allergens at the finished product labeling step, where labels would be reviewed for the presence of an ingredient declaration that matches the current product formula. This control approach is a control strategy referred to in this chapter as Control Strategy Example 8 Finished Product Labeling Controls for Major Food Allergens and Added Food Intolerance Causing Substances.
3. In the case of products for which you have identified prohibited food and color additives (e.g., coumarin, safrole, or Red No. 4) as a significant hazard because you have reason to believe that it may be present in an ingredient used in the finished product, you should identify the raw material receiving step as the CCP, where you could screen incoming lots for the presence of the additive. Preventive measures that can be applied here include:
Material Testing for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives from Raw Materials. Receiving a suppliers certification of the lack of prohibited food and color additive use in the ingredient lot (with appropriate verification). Example: A shrimp salad processor uses an imported ingredient that has historically contained Red 4. The processor should set the CCP for prohibited food and color additives at the ingredient receiving step and obtain certificates from the supplier that Red No. 4 was not used in the formulation of the ingredient lot. The processor should verify the effectiveness of the monitoring procedures by collecting quarterly samples of the imported ingredient for the presence of Red No. 4. This control approach is the same control strategy previously identified as Control Strategy Example 3 Review of Suppliers Certificates for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives from Raw Materials.
Testing the incoming ingredient

for the additive.
Example: A shrimp salad processor uses an imported ingredient that has historically contained Red No. 4. The processor should test the ingredient at receipt for the additive and set the CCP for prohibited food and color additives at the ingredient receiving step. This control approach is the same control strategy previously identified as Control Strategy Example 2 - Raw
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The following guidance provides eight control strategies for undeclared major food allergens, certain food intolerance causing substances, and prohibited food and color additives. You may select a control strategy that is different from those that are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
CONTROL STRATEGY EXAMPLE 1 - FINISHED

PRODUCT LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS

All finished product packages must bear a label that declares the presence of a sulfiting agent.

Labels on finished product packages for presence of sulfiting agent.
Finished product labeling for control of food intolerance causing substances from raw materials Raw material testing for control of food intolerance causing substances and prohibited food and color additives from raw materials Review of suppliers certificates for control of food intolerance causing substances and prohibited food and color additives from raw materials Review of suppliers labeling for control of food intolerance causing substances from raw materials Finished product labeling based on raw material testing for control of food intolerance causing substances from raw materials Finished product labeling based on review of suppliers certificates for control of food intolerance causing substances from raw materials Finished product labeling based on review of suppliers labeling for control of food intolerance causing substances from raw materials Finished product labeling controls for major food allergens and added food intolerance causing substances

Visual examination.

Representative number of packages from each lot of a finished product;


Modify labeling procedures, as appropriate; OR Make corrections to the label generation program or equipment; OR Discontinue use of the label supplier until evidence is obtained that the labeling will contain the appropriate declaration;
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AND/OR Segregate and return or destroy any label stock or pre-labeled packaging stock that does not contain the proper declaration.

Record of labeling checks of finished product packages.

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TABLE 19-2
CONTROL STRATEGY EXAMPLE 1 - FINISHED PRODUCT LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS
This table is an example of a portion of a HACCP Plan using Control Strategy Example 1 - Finished Product Labeling for Control of Food Intolerance Causing Substances from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.
Major food allergens, certain food intolerance causing substances and prohibited food and color additives may be only one of several significant hazards for this product. Refer to Tables 3-3 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and metal fragments).

(1)
(2)
Finished product labeling
Undeclared sulfiting agents
Visual
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives All finished product packages must bear labels that contain sulfiting agent declaration Labels on the finished product for the presence of sulfiting agent declaration One label at the beginning of the production of each lot and one label every hour thereafter Quality assurance employee Segregate and relabel improperly labeled product Discontinue use of the label supplier until evidence is obtained that labeling will contain the sulfiting agent declaration Record of labeling checks of finished product packages Review monitoring and corrective action records within 1 week of preparation
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CONTROL STRATEGY EXAMPLE 2 - RAW

MATERIAL TESTING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES AND PROHIBITED FOOD AND COLOR ADDITIVES FROM RAW MATERIALS

Reject the lot. AND


Incoming lots of shrimp or lobster must not contain a detectable level of sulfiting agents (Note that <10 ppm sulfiting agents may be present in finished product shell-off shrimp and lobster without a sulfiting agent declaration on the label if the sulfiting agents have no functional (ongoing technical) effect in the finished food. However, if the sulfiting agents have a functional (ongoing technical) effect in finished shell-on or shell-off shrimp or lobster product regardless of level, then they must be declared as ingredients on the product label). AND/OR An incoming lot of raw materials must not contain a detectable level of prohibited food or color additive.
Discontinue use of the supplier until evidence is obtained that control of sulfiting agents and/or prohibited food and color additives, as appropriate, has improved.

Test results for sulfiting agents and/or prohibited food and color additives, as appropriate.


Each lot at receipt for sulfiting agent residual analysis and/or prohibited food and color additive analysis, as appropriate.

Screening test for sulfiting agents and/ or prohibited food and color additives, as appropriate.

Representative sample from each incoming lot.

Any person who is qualified by training or experience to perform the screening test procedure.
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TABLE 19-3
CONTROL STRATEGY EXAMPLE 2 - RAW MATERIAL TESTING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES AND PROHIBITED FOOD AND COLOR ADDITIVES FROM RAW MATERIALS
This table is a an example of a portion of a HACCP plan using Control Strategy Example 2 - Raw Material Testing for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.
Major food allergens, certain food intolerance causing substances and prohibited food and color additives may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-3 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and metal fragments).

(1)
(2)
Shrimp receiving
Incoming lots of shrimp must not contain 10 ppm or greater sulfiting agents
Each lot of raw material shrimp for sulfiting agent residual
Malachite green test
Three shrimp selected randomly from each lot of incoming shrimp
Receiving employee
Reject any incoming lot of shrimp that contains a detectable level of sulfiting agent Discontinue use of the supplier until evidence is obtained that control of sulfiting agents has improved
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives Test results for sulfiting agents Review monitoring and corrective action records within 1 week of preparation
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CONTROL STRATEGY EXAMPLE 3 - REVIEW OF

SUPPLIERS CERTIFICATES FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES AND PROHIBITED FOOD AND COLOR ADDITIVES FROM RAW MATERIALS
AND

Incoming lots of shrimp or lobster must be accompanied by a suppliers lot-by lot certificate that sulfiting agents and/ or prohibited food and color additives, as appropriate, were not used.
Discontinue use of the supplier until evidence is obtained that certificates will accompany future shipments.

Suppliers lot-by-lot certificates; AND Receiving records showing lots received and the presence or absence of suppliers certificates.

The suppliers lot-by-lot certificate that no sulfiting agents and/or prohibited food and color additives, as appropriate, were used on the lot.

Collect at least one representative sample per quarter, randomly selected from each supplier, and analyze for sulfiting agents and/or prohibited food and color additives, as appropriate. Additionally, collect at least one representative sample from each new supplier, and analyze for sulfiting agents or prohibited food and color additives, as appropriate; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Visual examination of certificates.

Each incoming lot.


Reject the lot; OR Hold the lot until a certificate can be provided; OR Test the lot for sulfiting agents and/or prohibited food and color additives, as appropriate, and reject the lot if 10 ppm or greater sulfating agents or a detectable levels of prohibited food and color additives are found.
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TABLE 19-4
CONTROL STRATEGY EXAMPLE 3 - REVIEW OF SUPPLIERS CERTIFICATES FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES AND PROHIBITED FOOD AND COLOR ADDITIVES FROM RAW MATERIALS
This table is an example of a portion of a HACCP plan using Control Strategy Example 3 - Review of Suppliers Certificates for Control of Food Intolerance Causing Substances and Prohibited Food and Color Additives from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.
Major food allergens and certain food intolerance causing substances and prohibited food and color additives may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-3 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and metal fragments).

(1)
(2)
Shrimp receiving
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives All incoming lots of shrimp must be accompanied by a lot-by lot certificate stating that sulfiting agents were not used Suppliers lot-by-lot certificates stating that no sulfiting agents were used on the incoming lot Visual examination Every lot received Receiving employee Test the lot for sulfiting agents and reject the lot if a detectable level of sulfiting agents is found Discontinue use of the supplier until evidence is obtained that certificates will accompany future shipments Suppliers lot-by-lot certificates Receiving records showing lots received and the presence or absence of suppliers certificates Collect at least one representative sample per quarter and test for sulfiting agents; in addition, test at least one lot from each new supplier and analyze for sulfiting agents Review monitoring, corrective action, and verification records within 1 week of preparation
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CONTROL STRATEGY EXAMPLE 4 - REVIEW OF

SUPPLIERS LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS

Record of review of labeling or shipping documents for raw materials.

The labeling or shipping documents for incoming lots of shrimp or lobster received from another processor must not contain a sulfiting agent declaration.

Collect at least one representative sample per quarter, randomly selected from among your suppliers, and analyze for sulfiting agents. Additionally, collect at least one representative sample for each new supplier, and analyze for sulfiting agents; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Suppliers product labels or shipping documents for the presence of sulfiting agent declaration.

Visual examination of labels.

Every incoming lot.


Reject the lot; OR Test the lot for sulfiting agents and reject the lot if 10 ppm or greater of sulfiting agents are found. AND
Discontinue use of supplier until evidence is obtained that they will no longer provide a product in which sulfiting agents have been used.
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TABLE 19-5
CONTROL STRATEGY EXAMPLE 4 - REVIEW OF SUPPLIERS LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS
This table is an example of a portion of a HACCP plan using Control Strategy Example 4 - Review of Suppliers Labeling for Control of Food Intolerance Causing Substances from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.

(1)
(2)
Shrimp receiving
The labeling of incoming lots of shrimp received from another processor must not contain a sulfiting agent declaration
Suppliers product labels for the presence of sulfiting agent declaration
Visual examination of the labels
Every lot received
Receiving employee
Reject the lot Discontinue use of supplier until evidence is provided that they will not provide sulfiting agent treated shrimp
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives Record of labeling checks of raw materials Collect at least one representative sample per quarter and test for sulfiting agents; in addition, test at least one lot from each new supplier and analyze for sulfiting agents Review monitoring, corrective action, and verification records within 1 week of preparation
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PRODUCT LABELING BASED ON RAW MATERIAL TESTING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS

For finished product labeling:
AND

All finished product packages processed from raw materials that contain a detectable level of sulfiting agents must bear a label that contains a sulfiting agent declaration. Note that 10 ppm sulfiting agent may be present in finished product shell-off shrimp and lobster without a sulfiting agent declaration on the label. However, any detectable level of sulfiting agent in finished product shell-on shrimp or lobster would require a sulfiting agent declaration on the label, because the sulfiting agents continue to have a functional effect.
For raw material testing:
Any person who is qualified by training or experience to perform the screening test.



Labels on finished product packages for presence of sulfiting agent declaration; AND A representative sample of each lot of raw material for the presence of sulfiting agents.
Modify labeling procedures, as appropriate.

Record of labeling checks of finished product packages; AND Record of sulfiting agent test results.

For labels on finished packages:
AND
Visual examination of labels;
Establish Verification Procedures


AND
Screening test for sulfiting agents.

For finished product labeling: A representative number of packages from each lot of a finished product;
Each lot of raw material shrimp received.
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TABLE 19-6
CONTROL STRATEGY EXAMPLE 5 - FINISHED PRODUCT LABELING BASED ON RAW MATERIAL TESTING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS
This table is a an example of a portion of a HACCP plan using Control Strategy Example 5 - Finished Product Labeling Based on Raw Material Testing for Control of Food Intolerance Causing Substances from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.

(1)
(2)
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives All finished product packages processed from raw materials that contain 10 ppm or greater sulfiting agents must bear a label that contains a sulfiting agent declaration Analysis of raw material shrimp for sulfiting agent residual Malachite green test Three shrimp collected randomly from each lot of raw material shrimp Labels on finished product packages for the presence of a sulfiting agent declaration Visual examination of labels on finished product packages One label at the beginning of the production of each lot and one label every hour thereafter Quality control employee Segregate and relabel any improperly labeled product Modify labeling procedures, as appropriate Record of labeling checks of finished product packages Review monitoring and corrective action records within 1 week of preparation Quality control employee Analytical results
376

PRODUCT LABELING BASED ON REVIEW OF SUPPLIERS CERTIFICATES FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS


All finished product packages must bear a label that contains a sulfiting agent declaration unless they are processed from raw material shrimp or lobster that are accompanied by a suppliers lot-by-lot certificate that states that no sulfiting agents were used.


Record of labeling checks; AND Copy of certificates; AND Receiving record showing lots received and the presence or absence of a certificate.

Labels on finished product packages for the presence of a sulfiting agent declaration; AND Suppliers lot-by-lot certificates for raw material shrimp or lobster that no sulfiting agent was used on the lot.

Collect at least one representative sample per quarter from lots that are accompanied by a certificate, randomly selected from among your suppliers, and analyze for sulfiting agents. Additionally, collect at least one representative sample for each new supplier and analyze for sulfiting agents; AND Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

AND
Visual examination of the labels;
For suppliers lot-by-lot certificates:

AND
Visual examination of the certificates.

For finished product labeling: A representative number of packages from each lot of a finished product;
For suppliers lot-by-lot certificates:
Each incoming lot.

377
TABLE 19-7
CONTROL STRATEGY EXAMPLE 6 - FINISHED PRODUCT LABELING BASED ON REVIEW OF SUPPLIERS CERTIFICATES FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS
This table is an example of a portion of a HACCP plan using Control Strategy Example 6 - Finished Product Labeling Based on Review of Suppliers Certificates for Control of Food Intolerance Causing Substances from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.

(1)
(2)
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives Labels on finished product packages for the presence of a sulfiting agent declaration Lot-by-lot certificates stating that no sulfiting agent was used on the lot Visual examination of lot-by-lot certificates Each incoming lot Receiving employee Visual examination of labels on finished product packages One label at the beginning of the production of each lot and one label every hour thereafter Labeling supervisor Segregate and relabel any improperly labeled product Modify labeling procedure, as appropriate Record of labeling checks Record of raw material receiving Lot-by-lot certificates Collect at least one representative sample per quarter from lots that are accompanied by a certificate, selected randomly from among the suppliers and analyze for sulfiting agents; additionally, collect one representative sample from each new supplier and analyze for sulfiting agents Review monitoring, corrective action, and verification records within 1 week of preparation
378
All finished product packages must bear a label that contains a sulfiting agent declaration unless they are processed from raw material shrimp that are accompanied by a suppliers lot-by-lot certificate that states that no sulfiting agents were used

PRODUCT LABELING BASED ON REVIEW OF SUPPLIERS LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS


All finished product packages must bear a label that contains a sulfiting agent declaration if they are processed from raw material shrimp or lobster that are labeled with a sulfiting agent declaration or accompanied by documents that contain a sulfiting agent declaration.


Record of labeling checks of finished product packages; AND Record of review of raw material labeling or shipping documents.

Labels on finished product packages for the presence of a sulfiting agent declaration; AND Labeling or shipping documents for each lot of raw material shrimp or lobster received from another processor for the presence of a sulfiting agent declaration.

Collect at least one representative sample per quarter from lots that are not labeled with a sulfiting agent declaration or not accompanied by documents with a sulfiting agent declaration, randomly selected from among your suppliers, and analyze for sulfiting agents. Additionally, collect at least one representative sample for each new supplier, and analyze for sulfiting agents; AND Review monitoring, corrective action and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.

Visual examination of labels and shipping documents.

AND
A representative number of packages from each lot of a finished product;
For raw material labeling:
Each incoming lot.

379
TABLE 19-8
CONTROL STRATEGY EXAMPLE 7 - FINISHED PRODUCT LABELING BASED ON REVIEW OF SUPPLIERS LABELING FOR CONTROL OF FOOD INTOLERANCE CAUSING SUBSTANCES FROM RAW MATERIALS
This table is an example of a portion of a HACCP plan using Control Strategy Example 7 - Finished Product Labeling Based on Review of Suppliers Labeling for Control of Food Intolerance Causing Substances from Raw Materials. This example illustrates how a processor of shell-on shrimp can control sulfiting agents that are used on the harvest vessel. It is provided for illustrative purposes only.

(1)
(2)
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives Labels on finished product packages for the presence of a sulfiting agent declaration Visual examination of labels on finished product packages One label at the beginning of the production of each lot and one label every hour thereafter Each incoming lot Receiving employee Labeling supervisor Segregate and relabel any improperly labeled product Modify labeling procedure, as appropriate Records of raw material labeling checks Record of labeling checks Labeling for each lot of raw material shrimp received from another processor for the presence of a sulfiting agent declaration Visual examination of the raw material labeling Collect at least one representative sample per quarter from lots that are not labeled with a sulfiting agent declaration, randomly selected from among your suppliers, and analyze for sulfiting agents; additionally, collect at least one representative sample for each new supplier, and analyze for sulfiting agents Review monitoring, corrective action and verification records within 1 week of preparation
380
All finished product packages must bear a label that contains a sulfiting agent declaration if they are processed from raw material shrimp that are labeled with a sulfiting agent declaration or accompanied by documents that contain a sulfiting agent declaration

PRODUCT LABELING CONTROLS FOR MAJOR FOOD ALLERGENS AND ADDED FOOD INTOLERANCE CAUSING SUBSTANCES

Record of labeling checks of finished product packages.

All finished product labeling must accurately list any major food allergens and added sulfiting agents that have an on-going functional effect or Yellow No. 5 that are included in the product formulation.


Labels on finished product packages for comparison with the product formula (recipe), including the market name of any finfish or crustacean shellfish contained in the product.

Visual examination of the finished product labels and product formula.

A representative number of packages from each lot of a finished product.



Modify label procedures, as appropriate.
381
TABLE 19-9
CONTROL STRATEGY EXAMPLE 8 - FINISHED PRODUCT LABELING CONTROLS FOR MAJOR FOOD ALLERGENS AND ADDED FOOD INTOLERANCE CAUSING SUBSTANCES
This table is an example of a portion of a HACCP plan using Control Strategy Example 8 - Finished Product Labeling Controls for Major Food Allergens and Added Food Intolerance Causing Substances. This example illustrates how a breaded fish processor can control undeclared major food allergens in the production of breaded fish portions containing egg, wheat, and pollock. It is provided for illustrative purposes only.

(1)
(2)
Undeclared major food allergens
CHAPTER 19: Undeclared Major Food Allergens and Certain Food Intolerance Causing Substances and Prohibited Food and Color Additives Finished product labels must declare the presence of egg, wheat, and pollock Finished product labels for comparison with product formula Visual examination of the labels on finished product packages One label at the beginning of the production of each lot and one label every hour thereafter Quality assurance staff Segregate and relabel any incorrectly labeled product Modify labeling procedure, as appropriate Record of review of finished product labels Review monitoring and corrective action records within 1 week of preparation
382
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. U.S. Congress. Food Allergen Labeling and Consumer Protection Act of 2004. Title II of Public Law 108-282. http://www.fda.gov/Food/ LabelingNutrition/FoodAllergensLabeling/ GuidanceComplianceRegulatoryInformation/ ucm106187.htm. U.S. Food and Drug Administration. September 23, 1976. Termination of provisional listing and certification of FD&C Red No. 4 for use in maraschino cherries and ingested drugs. In Federal Register, vol. 41, no. 186. U.S. Food and Drug Administration. July 9, 1986. Food labeling: declaration of sulfiting agents. Final rule, CFR Part 101. In Federal Register, 25012, vol. 51, no. 131. U.S. Food and Drug Administration. May 29, 1992. Statement of policy: foods derived from new plant varieties. In Federal Register, vol. 57, no. 104. U.S. Food and Drug Administration. 1993. Substances prohibited from use in human food (cyclamate and its derivatives). In Code of Federal Regulations, CFR 21 189.135; 100.130. U.S. Government Printing Office, Washington, DC. U.S. Food and Drug Administration. 1997. Substances prohibited from use in human food (safrole). In Code of Federal Regulations, CFR 21 189.180. U.S. Government Printing Office, Washington, DC.
U.S. Food and Drug Administration. October 2003. Import sample collection assignment for undeclared sulfites - DFP #04-08. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD. U.S. Food and Drug Administration. Substances prohibited from use in human food. In Code of Federal Regulations, CFR 21 74.1304, 74.2303, 81.10, 81.30. U.S. Government Printing Office, Washington, DC. Wade, A. D. October 2005. Final status report on import sample collection assignment for undeclared sulfites - DFP #04-08. (Memorandum). Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD.
383
NOTES:
384
CHAPTER 20: Metal Inclusion


Ingesting metal fragments can cause injury to the consumer. These injuries may include dental damage, laceration of the mouth or throat, or laceration or perforation of the intestine. FDAs Health Hazard Evaluation Board has supported regulatory action against products with metal fragments 0.3 inch (7 mm) to 1 inch (25 mm) in length. The Federal Food, Drug, and Cosmetic Act (the FFD&C Act) prohibits interstate commerce of adulterated foods (21 U.S.C. 331). Under the FFD&C Act, a food containing foreign objects is considered adulterated (21 U.S.C 342). See FDAs Compliance Policy Guide, Sec. 555.425. In addition, foreign objects that are less than 0.3 inch (7 mm) may cause trauma or serious injury to persons in special risk groups, such as infants, surgery patients, and the elderly. Metal-to-metal contact (e.g., mechanical cutting or blending operations and can openers) and equipment with metal parts that can break loose (e.g., moving wire mesh belts, injection needles, screens and portion control equipment, and metal ties) are likely sources of metal that may enter food during processing. Control of metal inclusion Once introduced into a product, metal fragments may be removed from the product by passing it through a screen, magnet, or flotation tank. The effectiveness of these measures depends on the nature of the product. These measures are more likely to be effective in liquids, powders, and similar products in which the metal fragment will not become imbedded.
Alternatively, metal fragments may be detected in the finished food by an electronic metal detector. The use of electronic metal detectors is complex, especially with regard to stainless steel, which is difficult to detect. The orientation of the metal object in the food affects the ability of the equipment to detect it. For example, if a detector is not properly calibrated and is set to detect a sphere 0.08 inch (2 mm) in diameter, it may fail to detect a stainless steel wire that is smaller in diameter but up to 0.9 inch (24 mm) long, depending on the orientation of the wire as it travels through the detector. Processing factors, such as ambient humidity or product acidity, may affect the conductivity of the product and create an interference signal that may mask metal inclusion unless the detector is properly calibrated. You should consider these factors when calibrating and using this equipment. Finally, the hazard of metal inclusion may also be controlled by periodically examining the processing equipment for damage that can contribute metal fragments to the product. This measure will not necessarily prevent metal fragments from being incorporated into the product, but it will enable you to separate products that may have been exposed to metal fragments. Visually inspecting equipment for damaged or missing parts may only be feasible with relatively simple equipment, such as band saws, small orbital blenders, and wire mesh belts. More complex equipment that contains many parts, some of which may not be readily visible, may not be suitable for visual inspection and may require controls such as metal detection or separation.
385

The following guidance will assist you in determining whether metal inclusion is a significant hazard at a processing step:
1. Is it reasonably likely that metal fragments will be introduced at this processing step (e.g., do they come in with the raw material or will the process introduce them)?
2. Can the hazard of metal inclusion that was introduced at an earlier step be eliminated or reduced to an acceptable level at this processing step?
For example, under ordinary circumstances, it would be reasonably likely to expect that metal fragments could enter the process from the following sources as a result of worn, damaged, or broken equipment parts: Mechanical crabmeat pickers; Wire-mesh belts used to
convey products;
Saw blades used to cut
portions or steaks;
Wire from mechanical mixer blades; Blades on mechanical chopping,
filleting, or blending equipment;
Rings, washers, nuts, or bolts from breading, batter, sauce cooling, liquid dispensing, and portioning equipment; Injection needles; Metal ties used to attach
tags or close bags;
Can slivers from opening cans. Under ordinary circumstances, it would not be reasonably likely to expect that metal fragments could enter the food from the following sources: Utensils used for manual blending, cutting, shucking, or gutting; Metal processing tables or storage tanks.
Metal inclusion should also be considered a significant hazard at any processing step where a preventive measure is or can be used to prevent or eliminate the hazard (or is adequate to reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. Preventive measures for metal inclusion can include: Periodically checking equipment
for damaged or missing parts;
Passing the product through metal detection or separation equipment. Control of metal inclusion In most cases, you should assume that the product will be consumed in a way that would not eliminate any metal fragments that may be introduced during the process. However, in some cases, if you have assurance that the product will be run through a metal detector, for detection of metal fragments, or through screens or a magnet, for separation of metal fragments, by a subsequent processor, you would not need to identify metal inclusion as a significant hazard. Example: A primary processor produces frozen fish blocks by mechanically heading, eviscerating, and filleting fish in the round. The primary processor sells exclusively to breaded fish stick processors and has been given assurance by these processors that the finished breaded product will be subjected to a metal detector. The primary processor would not need to identify metal inclusion as a significant hazard.
386

The following guidance will also assist you in determining whether a processing step is a critical control point (CCP) for metal inclusion:
1. Will the product be run through a metal detector or a separation device, such as a screen, magnet, or flotation tank, on or after the last step where metal inclusion is identified as a significant hazard? a. If it will be, you should identify final
b. If the product will not be run through
such a device, you should have procedures to periodically check the processing equipment for damage or lost parts at each processing step where metal inclusion is identified as a significant hazard. In this case, you should identify those processing steps as CCPs. Example: A processor that cuts tuna steaks from frozen loins has identified the band saw cutting step as the only step that is reasonably likely to introduce metal fragments into the product. The processor should identify the band saw cutting step as the CCP for this hazard and should check the condition of the band saw blade every 4 hours to ensure that it has not been damaged. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 - Equipment Checks. Visually inspecting equipment for damaged or missing parts may only be feasible with relatively simple equipment, such as band saws, small orbital blenders, and wire mesh belts. More complex equipment that contains many parts, some of which may not be readily visible, may not be suitable for visual inspection and may require controls such as metal detection or separation.
metal detection or separation as the CCP. Then processing steps prior to metal detection or separation would not require controls and would not need to be identified as CCPs for the hazard of metal fragments. Example: A breaded fish processor uses saws, breading and batter machines, and wire conveyor belts. The processor should choose to use a metal detector on the finished product containers and should set the CCP for metal inclusion at the metal detection step for packaged products. The processor would not need to have CCPs for this hazard at each of the previous processing steps at which there was a reasonable likelihood that metal fragments could be introduced. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 - Metal Detection or Separation. You should recognize that by setting the CCP at or near the end of the process, rather than at the point of potential metal fragment entry into the process, you are likely to have more labor and materials invested in the product before the problem is detected or prevented.

The following guidance provides two examples of control strategies for metal inclusion. It is important to note that you may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations.
387
The following are examples of control strategies included in this chapter:

Continuous monitoring by the metal detection or separation device itself.

Monitoring is performed by the metal detection or separation device itself. Visual checks to ensure that the device is in place and operating may be performed by any person who has an understanding of the nature of the controls.
CONTROL STRATEGY
Metal detection or separation Equipment checks
CONTROL STRATEGY EXAMPLE 1 - METAL

DETECTION OR SEPARATION


All of the product passes through an operating metal detection or separation device; AND No detectable metal fragments are in the product that passes through the metal detection or separation device.
When processing occurred without an operating metal detector or intact or operating separation device:

The presence of an operating metal detection or separation device; AND The product for the presence of metal fragments.
Hold all of the product produced since controls were last confirmed as functioning properly until it can be run through a metal detection or separation device; OR Hold all of the product produced since controls were last confirmed as functioning properly until an inspection of the processing equipment that could contribute metal fragments can be completed to determine whether there are any broken or missing parts (may be suitable only for relatively simple equipment); OR Divert all of the product produced since controls were last confirmed as functioning properly to a use in which it will be run through a properly calibrated metal detector (e.g., divert fish fillets to a breading operation that is equipped with a metal detector); OR Destroy all of the product produced since controls were last confirmed as functioning properly;

Visual examination for the presence of an operating electronic metal detector, magnet, intact screen, or flotation tank; AND Product monitoring is performed by the metal detection or separation device itself.

Check that the metal detection or separation device is in place and operating at the start of each production day; AND
388
OR

For metal detectors: Develop sensitivity standards that are based on whether the potential hazard is ferrous, non-ferrous, or stainless steel, or obtain such standards from the equipment manufacturer. The standards should be designed to ensure that metal fragments will be detected in the product. Conduct a validation study to identify the range of values for each of the processing factors over which the equipment will detect the standards that affect its operation in your product (e.g., ambient humidity and product acidity), or obtain such a study from the equipment manufacturer. The study should identify the appropriate equipment settings over the range of each of the processing factors. The study also should consider the range of orientations in which the metal fragments may be present; AND Challenge the metal detector using validated sensitivity standards daily, at the start of production, every 4 hours during operation, when processing factors (e.g., ambient humidity and product acidity) change, and at the end of processing; AND For all metal detection and separation devices: Review monitoring, corrective action, and verification records within 1 week of preparation to ensure they are complete and any critical limit deviations that occurred were appropriately addressed.
Divert all of the product produced since controls were last confirmed as functioning properly to a non-food use.
AND When product is rejected by a metal detector:

AND
Hold and evaluate the rejected product; OR Rework the rejected product to eliminate metal fragments;
OR
Destroy the rejected product;
OR Divert the rejected product to a non-food use.
Correct operating procedures to ensure that the product is not processed without an operating metal separation or detection device; OR Attempt to locate and correct the source of the fragments found in the product by the metal detector or separated from the product stream by the magnets, screens, or other devices; OR Repair or replace the metal separation device.

Record documenting that the metal detection or separation device is in place and operating.
389
TABLE 20-1
CONTROL STRATEGY EXAMPLE 1 - METAL DETECTION OR SEPARATION
This table is an example of a portion of a Hazard Analysis Critical Control Point (HACCP) plan using Control Strategy Example 1 - Metal Detection or Separation. This example illustrates how a frozen fish sticks processor can control metal fragment inclusion. It is provided for illustrative purposes only.
Metal inclusion may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., environmental chemical contaminants and pesticides and Staphylococcus aureus toxin formation in the hydrated batter mix).

(1)
(2)
CHAPTER 20: Metal Inclusion All of the product passes through an operating metal detector Metal detector present and operating Visual examination Daily, at start of operations Production employee No detectable metal fragments are in the product passing the through the metal detector The product for the presence of metal fragments Electronic metal detector Continuous Equipment itself
Metal detection
Metal inclusion
390
If the product is processed without metal detection, hold it for metal detection Correct operating procedures to ensure that the product is not processed without metal detection Rework to remove metal fragments from any product rejected by the metal detector Identify the source of the metal found in the product and fix the damaged equipment
Metal detector operation log
Conduct a validation study to determine appropriate settings for the metal detector Develop metal detector sensitivity standards Challenge the metal detector with sensitivity standards daily, before start-up, every 4 hours during production, whenever processing factors change, and at the end of processing Review monitoring, corrective action and verification records within 1 week of preparation
CONTROL STRATEGY EXAMPLE 2 - EQUIPMENT

CHECKS


No broken or missing metal parts from equipment.
Hold all of the product produced since the previous satisfactory equipment check until it can be run through a metal detector; OR Divert all of the product produced since the previous satisfactory equipment check to a use in which it will be run through a properly calibrated metal detector (e.g., divert fish fillets to a breading operation that is equipped with a metal detector); OR Destroy all of the product produced since the previous satisfactory equipment check; OR Divert all of the product produced since the previous satisfactory equipment check to a non-food use. AND
Establish Monitoring Procedures. What Will be Monitored?

The presence of broken or missing metal parts from equipment.

Visually check the equipment for broken or missing parts. Examples:
Check saw blades for missing teeth or sections;

Check that all parts are present and
secure on blending equipment; Check for missing links or broken wires on metal belts.
How Often Will Monitoring Be Done?

Check before starting operations each day; AND Check every 4 hours during operation; AND Check at the end of operations each day; AND Check whenever there is an equipment malfunction that could increase the likelihood that metal could be introduced into the food.
Stop production; AND If necessary, adjust or modify the equipment to reduce the risk of recurrence.

Records of equipment inspections.


Any person who has a thorough understanding of the proper condition of the equipment.
391
TABLE 20-2
CONTROL STRATEGY EXAMPLE 2 - EQUIPMENT CHECKS
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Equipment Checks. This example illustrates how a frozen tuna steak processor can control metal fragment inclusion. It is provided for illustrative purposes only.
Metal inclusion may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., scombrotoxin (histamine) and parasites).

(1)
(2)
Fish cutting
Metal inclusion
CHAPTER 20: Metal Inclusion No damage or missing parts to the saw blade Check the saw blade Visual check Saw operator Before start-up, every 4 hours during operation, at the end of day, and after an equipment jam
Stop production Adjust equipment Hold all of the product since the last visual check until it can be run through a metal detector Destroy rejected product
392
Equipment maintenance log
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Olsen, A. R. 1998. Regulatory action criteria for filth and other extraneous materials. I. Review of hard or sharp foreign objects as physical hazards in food. Regul. Toxicol. Pharmacol. 28:181-189. U.S. Food and Drug Administration. 1999. Foods - Adulteration involving hard or sharp foreign objects. In Compliance Policy Guides, Sec. 555.425. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD.
393
NOTES:
394
CHAPTER 21: Glass Inclusion


Ingesting glass fragments can cause injury to the consumer. These injuries may include damage to teeth, laceration of the mouth and throat, or perforation of the intestine. FDAs Health Hazard Evaluation Board has supported regulatory action against products with glass 0.3 inch (7 mm) to 1 inch (25 mm) in length. The Federal Food, Drug, and Cosmetic Act (the FFD&C Act) prohibits interstate commerce of adulterated foods (21 U.S.C. 331). Under the FFD&C Act, a food containing foreign objects is considered adulterated (21 U.S.C 342). See FDAs Compliance Policy Guide, Sec. 555.425. Foreign objects that are less than 0.3 inch (7 mm) may cause trauma or serious injury to persons in special risk groups, such as infants, surgery patients, and the elderly. Glass inclusion can occur whenever processing involves the use of glass containers. Normal handling and packaging methods, especially mechanized methods, can result in breakage. Most products packed in glass containers are eaten with minimal handling on the part of the consumer providing little opportunity to detect glass inclusion. The purpose of this chapter is to address only the hazard of glass fragments that results from the use of glass containers. Glass fragments originating from sources such as overhead light fixtures must be addressed where applicable in a prerequisite sanitation program. The Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products regulation, 21 CFR 123 (called the Seafood HACCP Regulation in this guidance document), requires such a program.
Control of glass inclusion Once introduced into a product container, the hazard of glass fragments may be controlled by (1) removing the fragments by cleaning the containers before filling or (2) detecting the fragments by visual inspection before or after filling. Glass containers may be cleaned using water or compressed air and inverted during or after cleaning to help with glass removal. This measure may be suited only to processes that do not use automated filling systems which include filled container conveyors or capping equipment, because this equipment can result in glass breakage after glass container cleaning. The effectiveness of visual inspection depends on the nature of the product and the process. For most fishery products, this measure also may be suited only to processes that do not use automated filled container conveyors or capping equipment, because visual inspection after the glass containers are filled is not practical. However, for clear liquids (e.g., some fish sauces), candling may be used to visually inspect all filled containers. Candling is a visual inspection process in which the container is illuminated from behind. Alternatively, the hazard of glass inclusion may be controlled by periodically checking the processing areas and equipment for glass breakage. This measure will not necessarily prevent glass fragments from being incorporated into the product, but it will enable you to separate products that may have been exposed to glass fragments.
395

The following guidance will assist you in determining whether glass inclusion is a significant hazard at a processing step:
1. Is it reasonably likely that glass fragments will be introduced at this processing step (e.g., do they come in with the raw material or will the process introduce them)?
Periodically monitoring processing lines for evidence of glass breakage; Visually examining glass
containers containing transparent
liquid fishery products.
Intended use In most cases, you should assume that the product will be consumed in a way that would not eliminate any glass fragments that may be introduced during the process.
For example, under ordinary circumstances, it would be reasonably likely to expect that glass fragments could enter the process during the processing of any product that is packed in a glass container. These are likely areas of concern for glass containers: Glass container receiving; Glass container storage, when
cases are moved mechanically;
Mechanized glass container cleaning; Glass container conveyor lines; Glass container filling; Mechanized capping of glass containers; Pasteurizing product in glass containers.
2. Can glass fragments that were introduced at an earlier step be eliminated or reduced to an acceptable level at this processing step?

The following guidance will also assist you in determining whether a processing step is a critical control point (CCP) for glass inclusion:
1. Will the containers be visually inspected for detection of glass fragments or be cleaned (water or compressed air) and inverted on or after the last step where glass inclusion is identified as a significant hazard? a. If they will be, you should identify the
final visual inspection or cleaning as the CCP. For example, you should visually inspect the containers for broken glass or clean and invert the containers after the processing steps where breakage is reasonably likely to occur. For most fishery products, this method may be suited only to processes that do not use automated filling systems which include filled container conveyors or capping equipment. However, if your product is a clear liquid, you should visually inspect all filled containers by candling. In this case, the candling step would be designated as the CCP. Example: A processor that manually packs caviar into glass jars has identified the glass container receiving and storage steps as the only steps that are reasonably likely to introduce
396
Glass inclusion should be considered a significant hazard at any processing step where a preventive measure is or can be used to prevent or eliminate the hazard (or is adequate to reduce the likelihood of its occurrence to an acceptable level) if it is reasonably likely to occur. Preventive measures for glass inclusion can include: Visually examining the
empty glass containers;
Cleaning (water or compressed air) and inverting the empty glass containers;
glass fragments into the process. The processor should visually inspect each jar prior to the filling process. The processor should also collect a representative sample of inspected glass jars at the start of processing, every 4 hours during processing, at the end of processing and after any jams. The processor should identify the container inspection step as the CCP for this hazard. Example: Another processor that manually packs caviar has identified the glass container receiving and storage steps as the only steps that are reasonably likely to introduce glass fragments into the process. Just before filling, the empty glass jars are inverted and cleaned using filtered, compressed air. The processor should also collect a representative sample of cleaned glass jars at the start of processing, every 4 hours during processing, at the end of processing and after any jams. The processor should identify the container cleaning and inverting step as the CCP for this hazard. Example: A processor that bottles a transparent fish sauce has identified glass container receiving and storage, mechanical conveyor lines, mechanical filling, and mechanical capping as processing steps that are reasonably likely to introduce glass fragments into the process. The processor should visually inspect each filled and capped bottle for visible glass fragments by candling. The processor should also collect a representative sample of inspected glass jars at the start of processing, every 4 hours during processing, at the end of processing and after any
jams. The processor should identify the finished product candling step as the CCP for this hazard. This control approach is a control strategy referred to in this chapter as Control Strategy Example 1 Cleaning or Visual Inspection of Containers. You should recognize that by setting the CCP at or near the end of the process, rather than at the point of potential glass fragment entry into the process, you are likely to have more labor and materials invested in the product before the problem is detected or prevented.
b. If the containers will not be visually
inspected or cleaned and inverted on or after the last step, you should periodically check the processing areas and equipment for glass breakage at each processing step where glass inclusion is identified as a significant hazard. In this case, those processing steps should be CCPs. It would not ordinarily be necessary to identify these steps as CCPs in addition to identifying a final inspection or cleaning step as a CCP. Example: A processor bottles clam juice and has identified glass container receiving and storage, mechanical conveyor lines, mechanical filling, and mechanical capping as processing steps reasonably likely to introduce glass fragments into the process. The processor should visually inspect all processing areas for broken glass at start-up and once every 4 hours during processing. If broken glass is observed, the line should be stopped, the glass removed and the product that has moved through that area since the last inspection
397
placed on hold to be filtered or destroyed. The processor should identify glass container receiving and storage, mechanical conveyor lines, mechanical filling, and mechanical capping as the CCPs for this hazard. This control approach is a control strategy referred to in this chapter as Control Strategy Example 2 Equipment Checks.
Establish Monitor Procedures. What Will Be Monitored?

The presence of an operating glass container cleaning or inspection process; AND Cleaned or inspected containers for the presence of glass fragments.

Visual examination for the presence of equipment and employees for cleaning or inspecting glass containers; AND Visual examination of a representative sample of glass containers after cleaning or inspecting.

The following guidance provides examples of two control strategies for glass inclusion. You may select a control strategy that is different from those which are suggested, provided it complies with the requirements of the applicable food safety laws and regulations. The following are examples of control strategies included in this chapter:
How Often Will Monitoring Be Done?

Check that the glass container cleaning or inspection process is in place and operating at the start of each production day and after each shift change; AND Examine a representative sample of glass containers after cleaning or inspection daily, at the start of processing, every 4 hours during processing, at the end of processing, and after any breakdowns.
CONTROL STRATEGY
MAY APPLY TO PRIMARY PROCESSOR
MAY APPLY TO SECONDARY PROCESSOR
Cleaning or visual inspection of containers Equipment checks
CONTROL STRATEGY EXAMPLE 1 - CLEANING OR

VISUAL INSPECTION OF CONTAINERS


All containers pass through an operating glass container inspection or cleaning process; AND No detectable glass fragments are in glass containers that pass through the glass container inspection or cleaning process.

Hold and evaluate all of the product processed since controls were last confirmed as functioning properly; OR Destroy all of the product produced since controls were last confirmed as functioning properly;
398
OR Divert all of the product produced since controls were last confirmed as functioning properly to a non-food use; OR Rework all of the product produced since controls were last confirmed as functioning properly to eliminate glass fragments by visually examining for the presence of glass or by running the product through a filter or screen. AND
Correct operating procedures to ensure that the product is not processed without an operating glass container visual inspection or cleaning process; AND/OR Stop operations and locate and correct the source of the glass fragments.

Record documenting that the glass container cleaning or inspection process is in place and operating; AND Record documenting the visual examination of glass containers after cleaning or inspection.

399
TABLE 21-1
CONTROL STRATEGY EXAMPLE 1 - CLEANING OR VISUAL INSPECTION OF CONTAINERS
This table is an example of a portion of a HACCP plan using Control Strategy Example 1 - Cleaning or Visual Inspection of Containers. This example illustrates how a pro cessor of pickled herring in glass jars can control glass inclusion. It is provided for illustrative purposes only.
Glass inclusion may be only one of several significant hazards for this product. Refer to Tables 3-2 and 3-4 (Chapter 3) for other potential hazards (e.g., parasites, scombro toxin (histamine), environmental chemical contaminants and pesticides, unapproved food and color additives, metal fragments, Clostridium botulinum toxin formation, and pathogen growth as a result of temperature abuse).

(1)
(2)
CHAPTER 21: Glass Inclusion Visual check Visual examination of a representative sample of glass containers after cleaning One dozen jars after cleaning daily, at the start of processing, every 4 hours during processing, at the end of processing, and after any breakdowns All containers pass through an operating glass cleaning process No glass fragments are in glass containers passing through the glass container cleaning process The presence of glass fragments in cleaned containers The presence of the glass cleaning process At the start of the production and shift changes Quality control staff
Jar cleaning and inversion
Glass inclusion
Hold all of the product for an evaluation Correct operating procedures to ensure that the product is not processed without jar cleaning Stop operations and locate and correct the source of the glass fragments
Glass inspection record
400
CONTROL STRATEGY EXAMPLE 2 - EQUIPMENT

CHECKS


No broken glass on or near equipment.

The presence of broken glass on or near equipment.
Hold and evaluate all of the product produced since the previous satisfactory equipment check; OR Destroy all of the product produced since the previous satisfactory equipment check; OR Divert all of the product produced since the previous satisfactory equipment check to a non-food use; OR Rework the product packaged since the previous satisfactory equipment check by visually examining for the presence of glass or by running the product through a filter or screen. AND
Take one of the following corrective actions to regain control over the operation after a critical limit deviation:

Visually check the glass handling areas for broken glass. Examples:
Check pallets and packing cases
for damage, broken jars, and glass fragments;
Check mechanical glass cleaning area for broken glass;

Check floors around conveyors for broken
glass;
Check filling and capping equipment and
surrounding floors for broken glass; Check glass containers for breakage after exposure to heat (e.g., after heated product is added or after pasteurization).
Stop production; AND If necessary, adjust or modify the materials, equipment, and/or processes to reduce the risk of recurrence; AND Remove all broken glass from the equipment and surrounding area.

Check before starting operations each day; AND Check at least every 4 hours during operation; AND Check at the end of operations each day; AND Check whenever there is an equipment malfunction that could increase the likelihood that glass containers could be damaged.

Records of equipment and processing area inspections.

401

Any person who has a thorough understanding of the proper condition of the equipment and surrounding area.
TABLE 21-2
CONTROL STRATEGY EXAMPLE 2 - EQUIPMENT CHECKS
This table is an example of a portion of a HACCP plan using Control Strategy Example 2 - Equipment Checks. This example illustrates how a processor of clam juice in glass jars can control glass inclusion. It is provided for illustrative purposes only.
Glass inclusion may be only one of several significant hazards for this product. Refer to Tables 3-3 and3-4 (Chapter 3) for other potential hazards (e.g., pathogens from the harvest area, environmental chemical contaminants and pesticides, natural toxins, unapproved food and color additives, and metal fragments).

(1)
(2)
Glass inclusion
CHAPTER 21: Glass Inclusion No broken glass on or around processing equipment Broken glass on or around equipment Visual check Filler Operator Before start-up, every 4 hours during operations, after equipment jams, and end of day
Stop production Determine the source of the broken glass Adjust equipment that caused the breakage, if necessary Remove broken glass from the area Hold and evaluate the product since the last satisfactory check
Glass bottle receiving, mechanical bottle conveyors, mechanical filling, and mechanical capping
Glass inspection record
402
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Olsen, A. R. 1998. Regulatory action criteria for filth and other extraneous materials. I. Review of hard or sharp foreign objects as physical hazards in food. Regul. Toxicol. Pharmacol. 28:181-189. U.S. Food and Drug Administration. 1999. Foods Adulteration involving hard or sharp foreign objects. In Compliance Policy Guide, Sect. 555.425. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD.
403
NOTES:
404
APPENDIX 1: Forms
This appendix contains a blank model Hazard Analysis Critical Control Point (HACCP) Plan Form and a blank model Hazard Analysis Worksheet.
APPENDIX 1: Forms
405
HACCP PLAN FORM

PRODUCT DESCRIPTION:
FIRM NAME:
FIRM ADDRESS:
METHOD OF DISTRIBUTION AND STORAGE:
INTENDED USE AND CONSUMER: (3) MONITORING CORRECTIVE ACTION(S) RECORDS VERIFICATION (4) (5) (6) (7) (8) (9) (10)
(1)
(2)
APPENDIX 1: Forms
406 WHAT HOW FREQUENCY WHO
SIGNATURE OF COMPANY OFFICIAL: __________________________________________________________
DATE: _________________________ PAGE 1 OF ______________________________
HACCP PLAN FORM

(1)
(2)
APPENDIX 1: Forms
407
SIGNATURE OF COMPANY OFFICIAL: __________________________________________________________
DATE: _________________________ PAGE 1 OF _____________________________

APPENDIX 1: FORMS B

PRODUCT DESCRIPTION:
FIRM NAME:
FIRM ADDRESS:
METHOD OF DISTRIBUTION AND STORAGE:
INTENDED USE AND CONSUMER: (2) (3) (4) (5) (6)
(1)
APPENDIX 1: Forms
408
(YES/NO)
INGREDIENT/PROCESSING STEP
ARE ANY POTENTIAL FOOD SAFETY HAZARDS SIGNIFICANT AT THIS STEP? JUSTIFY YOUR DECISION FOR COLUMN 3
IDENTIFY POTENTIAL BIOLOGICAL, CHEMICAL, AND PHYSICAL HAZARDS ASSOCIATED WITH THIS PRODUCT AND PROCESS
WHAT PREVENTIVE MEASURE(S) CAN BE APPLIED FOR THE SIGNIFICANT HAZARDS?
IS THIS STEP A CRITICAL CONTROL POINT? (YES/NO)

(2) (3) (4) (5) (6)
IS THIS STEP A CRITICAL CONTROL POINT? (YES/NO)
(1)
INGREDIENT/PROCESSING STEP (YES/NO)
IDENTIFY POTENTIAL BIOLOGICAL, CHEMICAL, AND PHYSICAL HAZARDS ASSOCIATED WITH THIS PRODUCT AND PROCESS ARE ANY POTENTIAL FOOD SAFETY HAZARDS SIGNIFI CANT AT THIS STEP? JUSTIFY YOUR DECISION FOR COLUMN 3 WHAT PREVENTIVE MEASURE(S) CAN BE APPLIED FOR THE SIGNIFICANT HAZARDS?
APPENDIX 1: Forms
409
PAGE 1 OF _____________________________
NOTES:
APPENDIX 1: Forms
410
APPENDIX 2: Sample Product Flow Diagram

This appendix contains a sample product flow diagram that can be used as a model when you develop your own flow diagram.
411
CONTROL STRATEGY FIGURE A-1 SAMPLE PRODUCT FLOW DIAGRAM (SALMON FILLETS) RECEIVING
$
FISH PUMP
$
SORT
$
REFRIGERATED STORAGE
$
HEAD
$
GUT
$
WASH
$
FILLET
$
INSPECT
$
FREEZE
$
GLAZE
$
WEIGH/PACKAGE
$
FROZEN STORAGE
$
SHIP
412
APPENDIX 3: Critical Control Point Decision Tree

This appendix contains a decision tree that may be used to assist you with the identification of critical control points (CCPs). You should not rely exclusively on the decision tree, because error may result.
413
FIGURE A-2: CCP DECISION TREE Q1. DOES THIS STEP INVOLVE A HAZARD OF SUFFICIENT RISK AND SEVERITY TO WARRENT ITS CONTROL?
YES
NO
NOT A CCP
Q2.
DOES CONTROL MEASURE FOR THE HAZARD EXIST AT THIS STEP?
YES
NO
MODIFY THIS STEP, PROCESS OR PRODUCT
IS CONTROL AT THIS STEP NECESSARY FOR SAFETY?
YES
NO Q3.
NOT A CCP
STOP*
IS CONTROL AT THIS STEP NECESSARY TO PREVENT, ELIMINATE OR REDUCE THE RISK OF THE HAZARD TO CONSUMERS?
YES
NO
NOT A CCP
STOP*
CCP
This decision tree is derived from one that was developed by the National Advisory Committee on Microbiological Criteria for Foods.
414
BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. National Advisory Committee on Microbiological Criteria for Foods. 1992. Hazard Analysis and Critical Control Point System. Intl. J. Food Microbiol. 16:1-23.
415
NOTES:
416
APPENDIX 4: Bacterial Pathogen Growth and Inactivation

This appendix contains information on the growth and inactivation of bacterial pathogens. Table A-1 contains information on the minimum water activity (aw), acidity (pH), and temperature; the maximum, pH, water phase salt, and temperature; and oxygen requirements that will sustain growth for the bacterial pathogens that are of greatest concern in seafood processing. Data shown are the minimum or maximum values, the extreme limits reported among the references cited. These values may not apply to your processing conditions. Table A-2 contains information on maximum, cumulative time and internal temperature combinations for exposure of fish and fishery products that, under ordinary circumstances, will be safe for the bacterial pathogens that are of greatest concern in seafood processing. These maximum, cumulative exposure times are derived from published scientific information. Because the nature of bacterial growth is logarithmic, linear interpolation using the time and temperature guidance may not be appropriate. Furthermore, the food matrix effects bacterial growth (e.g., presence of competing microorganisms, available nutrients, growth restrictive agents). Consideration of such attributes is needed when using the information in Tables A-1 and A-2.
In summary, Table A-2 indicates that:
above 50F (10C) but below 135F (57.2C)) should be limited to 2 hours (3 hours if Staphylococcus aureus (S. aureus) is the only pathogen of concern), OR Alternatively, exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 2 of those hours are between 70F (21.1C) and 135F (57.2C); OR If at any time the product is held at internal temperatures above 50F (10C) but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern); OR The product is held at internal temperatures below 50F (10C) throughout processing, OR Alternatively, the product is held at ambient air temperatures below 50F (10C) throughout processing. For cooked, ready-to-eat products: If at any time the product is held at internal temperatures above 80F (26.7C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 1 hour (3 hours if S. aureus is the only pathogen of concern), OR
For raw, ready-to-eat products: If at any time the product is held at internal temperatures above 70F (21.1C), exposure time (i.e., time at internal temperatures
417
Alternatively, if at any time the product is held at internal temperatures above 80F (26.7C), exposure time (i.e., time at internal temperatures above 50F (10C) but below 135F (57.2C)) should be limited to 4 hours, as long as no more than 1 of those hours is above 70F (21.1C); OR If at any time the product is held at internal temperatures above 70F (21.1C) but never above 80F (26.7C), exposure time at internal temperatures above 50F (10C) should be limited to 2 hours (3 hours if S. aureus is the only pathogen of concern), OR Alternatively, if the product is never held at internal temperatures above 80F (26.7C), exposure times at internal temperatures above 50F (10C) should be limited to 4 hours, as long as no more than 2 of those hours are above 70F (21.1C); OR If at any time the product is held at internal temperatures above 50F (10C) but never above 70F (21.1C), exposure time at internal temperatures above 50F (10C) should be limited to 5 hours (12 hours if S. aureus is the only pathogen of concern); OR The product is held at internal temperatures below 50F (10C) throughout processing, OR Alternatively, the product is held at ambient air temperatures below 50F (10C) throughout processing. Note that the preceding recommended critical limits do not address internal product temperatures between 40F (4.4C), the recommended maximum storage temperature for refrigerated fish and fishery products, and 50F (10C). That is because growth of foodborne pathogenic bacteria is very slow
at these temperatures and the time necessary for significant growth is longer than would be reasonably likely to occur in most fish and fishery product processing steps. However, if you have processing steps that occur at these temperatures that approach the maximum cumulative exposure times listed in Table A-2 below for the pathogenic bacteria of concern in your product, you should consider development of a critical limit for control at these temperatures. It is not possible to furnish recommendations for each pathogenic bacteria, process, type of fish and fishery product, and temperature or combination of temperatures. Programmable models to predict growth rates for certain pathogens associated with various foods under differing conditions have been developed by the U.S. Department of Agricultures (Pathogen Modeling Program (PMP)) and the United Kingdoms (Food MicroModel (FMM) program). These programs can provide growth curves for selected pathogens. You indicate the conditions, such as pH, temperature, and salt concentration that you are interested in and the models provide pathogen growth predictions (e.g., growth curve, time of doubling, time of lag phase, and generation time). FDA does not endorse or require the use of such modeling programs, but recognizes that the predictive growth information they provide may be of assistance to some processors. However, you are cautioned that significant deviations between actual microbiological data in specific products and the predictions do occur, including those for the lag phase of growth. Therefore, you should validate the time and temperature limits derived from such predictive models. Table A-3 contains information on the destruction of Listeria monocytogenes (L. monocytogenes). Lethal rate, as used in this table, is the relative lethality of 1 minute at the designated internal product temperature as compared with the lethality of 1 minute at the reference internal product temperature of 158F (70C) (i.e., z = 13.5F (7.5C)). For example, 1
418
minute at 145F (63C) is 0.117 times as lethal as 1 minute at 158F (70C). The times provided are the length of time at the designated internal product temperature necessary to deliver a 6D process for L. monocytogenes. The length of time at a particular internal product temperature needed to accomplish a six logarithm reduction in the number of L. monocytogenes (6D) is, in part, dependent upon the food in which it is being heated. The values in the table are generally conservative and apply to all foods. You may be able to establish a shorter process time for your food by conducting scientific thermal death time studies. Additionally, lower degrees of destruction may be acceptable in your food if supported by a scientific study of the normal initial levels in the food. It is also possible that higher levels of destruction may be necessary in some foods, if especially high initial levels are anticipated. Table A-4 contains information on the destruction of Clostridium botulinum (C. botulinum) type B (the most heat- resistant form of non-proteolytic C. botulinum). Lethal rate, as used in this table, is the relative lethality of 1 minute at the designated internal product temperature as compared with the lethality of 1 minute at the reference product internal temperature of 194F (90C) (i.e., for temperatures less than 194F (90C), z = 12.6F (7.0C); for temperatures above 194F (90C), z = 18F (10C)). The times provided are the length of time at the designated internal product temperature necessary to deliver a 6D process for C. botulinum. The values in the table are generally conservative. However, these values may not be sufficient for the destruction of non proteolytic C. botulinum in dungeness crabmeat because of the potential protective effect of lysozyme. You may be able to establish a shorter process time for your food by conducting scientific thermal death time studies. Additionally, lower degrees of destruction may be acceptable in your food if supported by a scientific study of the normal innoculum in the food.
419
TABLE A-1 LIMITING CONDITIONS FOR PATHOGEN GROWTH

MIN. AW (USING SALT) MIN. TEMP. MAX. TEMP. MIN. pH MAX. pH MAX. % WATER PHASE SALT OXYGEN REQUIREMENT
PATHOGEN
BACILLUS CEREUS
0.92 0.987 0.935 0.97 5 9 5 37.9F 3.3C 113F 45C 4.6 9 10 4.9 9.5 1.7
4.3
9.3
10
CAMPYLOBACTER JEJUNI
CLOSTRIDIUM BOTULINUM, TYPE A, AND PROTEOLYTIC TYPES B AND F
39.2F 4C 86F 30C 50F 10C
131F1 55C 113F 45C 118.4F 48C
facultative anaerobe4 micro aerophile2 anaerobe3 anaerobe3
CLOSTRIDIUM BOTULINUM, TYPE E, AND NON PROTEOLYTIC TYPES B AND F
CLOSTRIDIUM PERFRINGENS
0.93 0.95 0.92 0.94 0.96 0.83 0.85 0.97 0.94 0.96 0.945 4.2 5 4.8 11 10 10 5 10 4 9.8 4 10 20 10 6 10 5 7 4.8 9.3 5.2 3.7 9.5 8 4.4 9.4 10 4 10 6.5
anaerobe3
PATHOGENIC STRAINS OF ESCHERICHIA COLI
LISTERIA MONOCYTOGENES
420
SALMONELLA SPP.
SHIGELLA SPP.
STAPHYLOCOCCUS AUREUS GROWTH
STAPHYLOCOCCUS AUREUS TOXIN FORMATION
VIBRIO CHOLERAE
VIBRIO PARAHAEMOLYTICUS
VIBRIO VULNIFICUS
YERSINIA ENTEROCOLITICA
50F 10C 43.7F 6.5C 31.3F -0.4C 41.4F 5.2C 43F 6.1C 44.6F 7C 50F 10C 50F 10C 41F 5C 46.4F 8C 29.7F -1.3C
125.6F 52C 120.9F 49.4C 113F 45C 115.2F 46.2C 116.8F 47.1C 122F 50C 118F 48C 109.4F 43C 113.5F 45.3C 109.4F 43C 107.6F 42C
facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4 facultative anaerobe4
1. 2. 3. 4.
Has significantly delayed growth (>24 hours) at 131F (55C). Requires limited levels of oxygen. Requires the absence of oxygen. Grows either with or without oxygen.
TABLE A-2 TIME AND TEMPERATURE GUIDANCE FOR CONTROLLING PATHOGEN GROWTH AND TOXIN FORMATION IN FISH AND FISHERY PRODUCTS
POTENTIALLY HAZARDOUS CONDITION GROWTH AND TOXIN FORMATION BY BACILLUS CEREUS PRODUCT TEMPERATURE MAXIMUM CUMULATIVE EXPOSURE TIME
GROWTH OF CAMPYLOBACTER JEJUNI GERMINATION, GROWTH, AND TOXIN FORMATION BY CLOSTRIDIUM BOTULINUM TYPE A, AND PROTEOLYTIC TYPES B AND F GERMINATION, GROWTH, AND TOXIN FORMATION BY CLOSTRIDIUM BOTULINUM TYPE E, AND NON-PROTEOLYTIC TYPES B AND F GROWTH OF CLOSTRIDIUM PERFRINGENS
39.2-43F (4-6C) 44-59F (7-15C) 60-70F (16-21C) Above 70F (21C) 86-93F (30-34C) Above 93F (34C) 50-70F (10-21C) Above 70F (21C) 37.9-41F (3.3-5C) 42-50F (6-10C) 51-70F (11-21C) Above 70F (21C) 50-54F (10-12C) 55-57F (13-14 C) 58-70F (15-21C) Above 70F (21C) 43.7-50F (6.6-10C) 51-70F (11-21C) Above 70F (21C) 31.3-41F (-0.4-5C) 42-50F (6-10C) 51-70F (11-21C) 71-86F (22-30C) Above 86F (30C) 41.4-50F (5.2-10C) 51-70F (11-21C) Above 70F (21C) 43-50F (6.1-10C) 51-70F (11-21C) Above 70F (21C) 50F (7-10C) 51-70F (11-21C) Above 70F (21C) 50F (10C) 51-70F (11-21C) 71-80F (22-27C) Above 80F (27C) 41-50F (5-10C) 51-70F (11-21C) 71-80F (22-27C) Above 80F (27C) 46.4-50F (8-10C) 51-70F (11-21C) 71-80F (22-27C) Above 80F (27C) 29.7-50F (-1.3-10C) 51-70F (11-21C) Above 70F (21C)
5 days 1 day 6 hours 3 hours 48 hours 12 hours 11 hours 2 hours 7 days 2 days 11 hours 6 hours 21 days 1 day 6 hours1 2 hours 2 days 5 hours 2 hours 7 days 1 day 7 hours 3 hours 1 hour 2 days 5 hours 2 hours 2 days 5 hours 2 hours 14 days 12 hours1 3 hours 21 days 6 hours 2 hours 1 hour2 21 days 6 hours 2 hours 1 hour2 21 days 6 hours 2 hours 1 hour2 1 day 6 hours 2.5 hours
GROWTH OF PATHOGENIC STRAINS OF ESCHERICHIA COLI GROWTH OF LISTERIA MONOCYTOGENES
GROWTH OF SALMONELLA SPECIES
GROWTH OF SHIGELLA SPECIES
GROWTH AND TOXIN FORMATION BY STAPHYLOCOCCUS AUREUS GROWTH OF VIBRIO CHOLERAE
GROWTH OF VIBRIO PARAHAEMOLYTICUS
GROWTH OF VIBRIO VULNIFICUS
GROWTH OF YERSINIA ENTEROCOLITICA
1. 2.
Additional data needed. Applies to cooked, ready-to-eat foods only.
421
TABLE A-3 INACTIVATION OF LISTERIA MONOCYTOGENES

INTERNAL PRODUCT TEMPERATURE (C) LETHAL RATE TIME FOR 6D PROCESS (MINUTES)
INTERNAL PRODUCT TEMPERATURE (F)
145 64 65 66 67 68 69 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 4.642 6.310 8.577 11.659 15.849 21.544 29.286 39.810 54.116 73.564 100.000 3.415 2.512 1.848 1.359 1.000 0.736 0.541 0.398 0.293 0.215 9.3 6.8 5.0 3.7 2.7 2.0 1.5 1.0 0.8 0.6 0.4 0.3 0.2 0.2 0.1 0.09 0.07 0.05 0.03 0.03 0.02 0.158 12.7
63
0.117
17.0
147
149
151
153
154
156
158
160
162
163
165
422
167
169
171
172
174
176
178
180
182
183
185
Note: z = 13.5F (7.5C).
TABLE A-4 INACTIVATION OF NON-PROTEOLYTIC CLOSTRIDIUM BOTULINUM TYPE B

INTERNAL PRODUCT TEMPERATURE (C) LETHAL RATE* TIME FOR 6D PROCESS (MINUTES)
INTERNAL PRODUCT TEMPERATURE (F)
423
185 187 189 190 192 194 196 198 199 201 203 205 207 208 210 212
85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100
0.193 0.270 0.370 0.520 0.720 1.000 1.260 1.600 2.000 2.510 3.160 3.980 5.010 6.310 7.940 10.000
51.8 37.0 27.0 19.2 13.9 10.0 7.9 6.3 5.0 4.0 3.2 2.5 2.0 1.6 1.3 1.0
Note: For temperatures less than 194F (90C), z = 12.6F (7.0C); for temperatures above 194F (90C), z = 18F (10C). *Note: These lethal rates and process times may not be sufficient for the destruction of non-proteolytic C. botulinum in dungeness crabmeat because of the potential that substances that may be naturally present, such as lysozyme, may enable the pathogen to more easily recover from heat damage.
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APPENDIX 5: FDA and EPA Safety Levels in Regulations and Guidance

This appendix lists FDA and EPA levels relating to safety attributes of fish and fishery products published in regulations and guidance. In many cases, these levels represent the point at or above which the agency will take legal action to remove products from the market. Consequently, the levels contained in this table may not always be suitable for critical limits.
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TABLE A-5 FDA AND EPA SAFETY LEVELS IN REGULATIONS AND GUIDANCE
PRODUCT READY-TO-EAT FISHERY PRODUCTS (MINIMAL COOKING BY CONSUMER) ALL FISH ALL FISH LEVEL Listeria monocytogenes - presence of organism in 25 gram sample. Salmonella spp. - presence of organism in 25 gram sample. 1. Staphylococcus aureus - positive for staphylococcal enterotoxin; or 2. Staphylococcus aureus - level equal to or greater than 104/g (MPN). Vibrio cholerae - presence of toxigenic O1 or O139 or non-O1 and non-O139 in 25 gram sample. Vibrio parahaemolyticus - levels equal to or greater than 1 x 104/g (Kanagawa positive or negative). Vibrio parahaemolyticus - levels less than 30/g (MPN).
READY-TO-EAT FISHERY PRODUCTS (MINIMAL COOKING BY CONSUMER) READY-TO-EAT FISHERY PRODUCTS (MINIMAL COOKING BY CONSUMER) POST-HARVEST PROCESSED CLAMS, MUSSELS, OYSTERS, AND WHOLE AND ROE-ON SCALLOPS, FRESH OR FROZEN, THAT MAKE A LABEL CLAIM OF PROCESSED TO REDUCE VIBRIO PARAHAEMOLYTICUS TO NON-DETECTABLE LEVELS COOKED READY-TO-EAT FISHERY PRODUCTS (MINIMAL COOKING BY CONSUMER) POST-HARVEST PROCESSED CLAMS, MUSSELS, OYSTERS, AND WHOLE AND ROE-ON SCALLOPS, FRESH OR FROZEN, THAT MAKE A LABEL CLAIM OF PROCESSED TO REDUCE VIBRIO VULNIFICUS TO NON-DETECTABLE LEVELS ALL FISH
Vibrio vulnificus - presence of organism. Vibrio vulnificus - levels less than 30/g (MPN).
Clostridium botulinum 1. Presence of viable spores or vegetative cells in products that will support their growth; or 2. Presence of toxin. Microbiological 1. E. coli or fecal coliform - 1 or more of 5 subs exceeding MPN of 330/100 g or 2 or more exceeding 230/100 g; 2. APC - 1 or more of 5 subs exceeding 1,500,000/g or 2 or more exceeding 500,000/g. Histamine - 500 ppm based on toxicity; 50 ppm defect action level. Polychlorinated Biphenyls (PCBs) - 2.0 ppm (edible portion).1 Aldrin and dieldrin - 0.3 ppm (edible portion). Benzene Hexachloride (BHC) - 0.3 ppm (edible portion). Carbaryl1 - 0.25 ppm. Chlordane - 0.3 ppm (edible portion). Chlordecone - 0.4 ppm crabmeat and 0.3 ppm in other fish (edible portion). DDT, TDE, and DDE - 5.0 ppm (edible portion). Diuron and its matabolites1 - 2.0 ppm. Endothall and its monomethyl ester - 0.1 ppm.1 Heptachlor and heptachlor epoxide - 0.3 ppm (edible portion). Mirex - 0.1 ppm (edible portion). Diquat - 0.1 ppm.1
CLAMS, OYSTERS, MUSSELS, AND WHOLE AND ROE-ON SCALLOPS, FRESH OR FROZEN
TUNA, MAHI-MAHI, AND RELATED FISH ALL FISH FINFISH AND SHELLFISH FROG LEGS OYSTERS ALL FISH ALL FISH ALL FISH FARM-RAISED, FRESHWATER FISH ALL FISH ALL FISH ALL FISH ALL FISH
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TABLE A-5 FDA AND EPA SAFETY LEVELS IN REGULATIONS AND GUIDANCE
PRODUCT FINFISH AND CRAYFISH FINFISH SHELLFISH FINFISH ALL FISH CHANNEL CATFISH AND FRESHWATER-REARED SALMONIDS FINFISH AND LOBSTER TROUT SALMONIDS AND CATFISH LEVEL Fluridone - 0.5 ppm.1 Glyphosate - 0.25 ppm.1 Glyphosate - 3.0 ppm.1 Simazine and its metabolites - 12 ppm.1 2,4-D - 1.0 ppm.1 Florfenicol - 1.0 ppm (muscle tissue).1 Oxytetracycline - 2.0 ppm (muscle tissue).1 Sulfamerazine - no residue permitted.1 Sulfadimethoxine/ormetoprim combination - 0.1 ppm for each drug (edible tissue).1 Drugs prohibited for extra-label use in animals - no residue per mitted: Chloramphenicol; Clenbuterol; Diethylstilbestrol (DES); Dimetridazole, Ipronidazole, and other Nitroimidazoles; Furazolidone, Nitrofurazone, and other nitrofurans; Fluoroquinilones; Glycopeptides. Methylmercury - 1.0 ppm.2 Paralytic Shellfish Poisoning - 0.8 ppm (80g/100g) saxitoxin equivalent. Neurotoxic Shellfish Poisoning - 0.8 ppm (20 mouse units/100 g) brevetoxin-2 equivalent. Diarrhetic Shellfish Poisoning - 0.2 ppm okadaic acid plus 35-methyl okadaic acid (DTX 1). Amnesic Shellfish Poisoning - 20 ppm domoic acid, except in the viscera of dungeness crab, where 30 ppm is permitted. Ciguatera Fish Poisoning - 0.01 ppb CTX equivalent for Pacific ciguatoxin and 0.1 ppb CTX equivalent for Caribbean ciguatoxin. Hard or sharp foreign object - generally 0.3 (7 mm) to 1.0 (25 mm) in length.
ALL FISH
ALL FISH ALL FISH CLAMS, MUSSELS, OYSTERS, AND WHOLE AND ROE-ON SCALLOPS, FRESH, FROZEN, OR CANNED CLAMS, MUSSELS, OYSTERS, AND WHOLE AND ROE-ON SCALLOPS, FRESH, FROZEN, OR CANNED ALL FISH ALL FISH ALL FISH
MPN = Most probable number. CTX = ciguatoxin. 1. These values are tolerances. 2. See Chapter 10, Methylmercury, for additional information. Note: The term fish refers to fresh or saltwater finfish, crustaceans, other forms of aquatic life other than birds or mammals, and all mollusks, where such animal life is intended for human consumption , as defined in the Fish and Fishery Products, Definitions, 21 CFR 123.3(d).
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NOTES:
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APPENDIX 6: Japanese and Hawaiian Vernacular Names for Fish Eaten Raw
Table A-1 contains a list of Japanese vernacular names and their corresponding U.S. market names; Table A-2 contains a list of Hawaiian vernacular names and their corresponding U.S. market names.
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These tables are not intended to be a complete list of species consumed raw.
TABLE A-1 COMMONLY USED JAPANESE VERNACULAR NAMES FOR FISH EATEN RAW WITH CORRESPONDING U.S. MARKET NAMES
WHEN THE JAPANESE VERNACULAR NAME IS THE U.S. MARKET NAME IS
AINAME AJI AKA-GAI AKAMANBO AKAUO AKODAI AKOU-DAI AMADAI AMAEBI ANAGO, HAMO ANKOU AOYAGI ASARI AWABI AYU BAIGAI BORA BURL DOJYOU EBI EBI EBODAI ESO EZOBORA FUEFUKIDAI FUGU FUGU FUNA GARIGANI GIN-SAKE HAKKAKU HAMACHI HAMAGURI HANASAKI KANI HATA HAYA HAZE HIGEDARA HIRAAJI HIRAME HIUCHIDAI HOSHI-GAREI HOTARUIKA HOTATE-GAI HOUBOU HOYA IBODAI IIDAKO
GREENLING MACKEREL, JACK CLAM, ARKSHELL OPAH MONKFISH MONKFISH ROCKFISH, RED TILEFISH PRAWN, SWEET CONGER EEL MONKFISH CLAM, SURF CLAM, SHORT NECKED ABALONE SMELT WHELK MULLET, GRAY YELLOWTAIL LOACH SHRIMP, FRESHWATER SHRIMP, PINK BUTTERFISH LIZARDFISH WHELK EMPEROR PUFFER GLOBEFISH CARP CRAYFISH SALMON, COHO SCULPIN YELLOWTAIL CLAM CRAB, HANASAKI GROUPER DACE GOBY LINGCOD JACK FLUKE, FLOUNDER ORANGE ROUGHY FLOUNDER SQUID SCALLOP, GIANT SEA ROBIN SEA SQUIRT BUTTERFISH OCTOPUS
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IKA IKANAGO IKURA INADA ISAKI ISAKI ISEEBI ISEEBI ISEEBI ISHIDAI, ISHIGAKIDAI ISHIMOCHI GUCHI ITOYORIDAI IWANA IWASHI JNADA KAJ I KA KAMASU KAMASUSAWARA KANI KANI KANI KANI KAREI KASAGO KATSUO KATSUO KAWAHAGI KAWAHGI KEGANI (KANI) KIJIHATA KINK KINME KINMEDAI KINTOKIDAI KISU KOBUDAI, BUDAI KOCHI KOHADA KOHADA KOI KOIKA KONOSHIRO KOSHODAI KURAGE KURODAI KURUMA-EBI KYABIA KYURINO MA-DAKO TAKO MA-IKA
SQUID SAND EEL SALMON, ROE YELLOWTAIL GRUNT GRUNT OR SWEETLIPS LOBSTER LOBSTER, NORWAY LOBSTER, SLIPPER KNIFEJAW CROAKER THREADFIN BREAM CHAR SARDINE YELLOWTAIL SCULPIN BARRACUDA WAHOO CRAB, BROWN CRAB, DEEP SEA CRAB, KING CRAB, SNOW FLOUNDER ROCKFISH BONITO SMALL TUNA TRIGGERFISH FILEFISH CRAB, KEGANI GROUPER THORNEYHEAD ALFONSINO ALFONSINO BIGEYE JAPANESE WHITING PARROTFISH FLATFISH GIZZARD SHAD SHAD CARP CUTTLEFISH GIZZARD SHAD GRUNT OR SWEETLIPS JELLYFISH PORGY SHRIMP, TIGER PRAWN CAVIAR SMELT OCTOPUS CUTTLEFISH
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MADAI MAGURO MAIWASHI MAKOGAREI MANAGA TSUO, ECHIOPIA MANBOH MANDAI MEBARU MEDAL MEKAJIKI MIRU-GAI MIZUDAKO MIZUIK MONGOIKA MONGORAKAWAHAGI NAMAKO NIBE NIJI-MASU NISHIN OHYOU ODORI OKAMASU OKAMSU ONAGADAI SABA SAIRA SAKANA SAKE SAME SAMMA SANMA SAWAGANI SAYORI, SAVORI SAZAE SAZAE SHINKO SHIIRA SHIMAAJI SHISHAMO SHITA-BIRAME SHIZU SUJI-KO SUKESODORA SUMIIKA SURUMEIKA SUZUKI SWARA TACHIUO TAI TAKO
SEA BREAM TUNA SARDINE FLOUNDER POMFRET SUNFISH, OCEAN OPAH ROCKFISH BLUENOSE SWORDFISH CLAM, GEODUCK OCTOPUS SQUID CUTTLEFISH TRIGGERFISH SEA CUCUMBER CROAKER TROUT, RAINBOW HERRING HALIBUT SHRIMP, TIGER PRAWN BARRACUDA BARRACUDA SNAPPER MACKEREL SAURY FISH SALMON, CHUM SHARK SAURY SAURY RIVER CRAB HALFBEAK TOP SHELL TURBOT, SHELL SHAD MAHI-MAHI JACK CAPELIN AND ROE SOLE BUTTERFISH SALMON, ROE POLLOCK AND ROE CUTTLEFISH SQUID SEA BASS MACKEREL, SPANISH CUTTLEFISH SEA BREAM, RED SNAPPER OCTOPUS
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TARA TARUMI FEUDA TARUMI FEUDAI TENEGADAKO TOBIUO TORIGAI TORO TSUBUGAI UMAZURAHAGI UNAGI UNI WAKASAGI WARASA YAMAME YARIIKA Y ANAGI-GAREI ZUWAI-GANI
COD AND ROE/MILT SNAPPER SNAPPER OCTOPUS FLYING FISH COCKLE TUNA WHELK TRIGGERFISH EEL SEA URCHIN ROE SMELT YELLOWTAIL SALMON, CHERRY SQUID FLOUNDER CRAB, SNOW
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TABLE A-2 COMMONLY USED HAWAIIAN VERNACULAR NAMES FOR FISH EATEN RAW WITH CORRESPONDING U.S. MARKET NAME
WHEN THE HAWAIIAN VERNACULAR NAME IS THE U.S. MARKET NAME IS
A'AWA A'U A'U A'U LEPE A'UKU AHA AHI AHI PALAHA AHOLEHOLE AKU AKULE ALA'IHI AMA'AMA API AUWEKE, MOANA KALI AWA AWEOWEO DEEPSEA MOI EHU HAHALALU HAPU'UPU'U HE'E MAULI HEBE HILU IHEIHE KAHALA KAKU KALA KALEKALE KAMANU KAWAKAWA KAWELE'A KOLE KUMU KUPIPI LAI LAINIHI MAHIMAHI MAHIMAHI MAI'I'I MAILKO MAKIAWA MAKUA MALOLO MAMO MANINI MOANA MOI MU NA'ENA'A
HOGFISH BLUE MARLIN BLACK MARLIN, SILVER MARLIN SAILFISH SWORDFISH NEEDLEFISH YELLOWFIN TUNA ALBACORE AHOLHOLE SKIPJACK TUNA BIGEYE SCAD SQUIRRELFISH MULLET SAILFIN TANG GOLDSADDLE GOATFISH MILKFISH BIGEYE TUNA BEARDFISH SQUIRRELFISH SNAPPER BIGEYE SCAD SEALES GROUPER OCTOPUS SHORTNOSE SPEARFISH BLACK STRIPED WRASSE HALFBEAK AMBERJACK BARRACUDA UNICORNFISH VON SIEBOLDS SNAPPER RAINBOW RUNNER KAWAKAWA JAPANESE BARRACUDA YELLOW-EYED SURGEON WHITE SADDLE GOATFISH GRAY DAMSELFISH LEATHERBACK RAZOR WRASSE DOLPHIN FISH SMALL DOLPHIN FISH BLACK AND BROWN SURGEON BLUELINED SURGEON SARDINE OCEAN SUNFISH FLYING FISH SERGEANT MAJOR DAMSEL CONVICT TANG MANYBAR GOATFISH THREADFIN PORGY ORANGE SPOT WRASSE
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TABLE A-2 COMMONLY USED HAWAIIAN VERNACULAR NAMES FOR FISH EATEN RAW WITH CORRESPONDING U.S. MARKET NAME
WHEN THE HAWAIIAN VERNACULAR NAME IS THE U.S. MARKET NAME IS
NENUE NUNU O'OPU KAI NOHU OILIPA OIO ONO OPAH OPAKAPAKA OPELU PAKI'I PAKU'IKU'I PALANI PANUUNUHU PAPAIKUALOA PO'ONUI PO'OPA'A PO'OU POMFRET PUALU PUHIUHA ROI SAMOAN CRAB SQUID STRIPED MARLIN TA'APE TO'AU U'U UHU UKIUKI UKU ULA ULAPAPA ULUA ULUA KIHIKIHI UOAUOA UPAPALU WALU WHITE WEKE
RUDDERFISH TRUMPETFISH LARGE-HEADED SCORPION BLUELINED LEATHER JACKET BONEFISH WAHOO MOONFISH PINK SNAPPER MACKEREL SCAD FLOUNDER ACHILLES TANG DUSSUMIERS SURGEON GAIMARDS PARROTFISH KONA CRAB BIGEYE TUNA HAWKFISH ROSE-COLORED WRASSE POMFRET ELONGATE SURGEONFISH WHITE EEL ARGUS GROUPER MANGROVE PURPLEBACK FLYING SQUID STRIPED MARLIN BLUE-STRIPED SNAPPER BLACK TAIL SNAPPER SQUIRRELFISH PARROTFISH BRIGHAMS SNAPPER GRAY JOBFISH, SNAPPER SPINY LOBSTER SLIPPER LOBSTER THICK-LIPPED TREVALLY THREADFIN JACK MULLET CARDINAL FISH OILFISH WHITE/SAMOAN GOATFISH
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BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Organization for Economic Co-operation and Development. 1995. Multilingual dictionary of fish and fish products. Fishing News Book. University Press, Cambridge. U.S. Food and Drug Administration. 2009. The seafood list. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Food Safety and Applied Nutrition, College Park, MD. http://www.fda.gov/Food/ GuidanceComplianceRegulatoryInformation/ GuidanceDocuments/Seafood/ucm113260. Tinker, S. W. 1991. Fishes of Hawaii. Hawaiian Service, Inc., Honolulu HI.
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APPENDIX 7: Bacterial and Viral Pathogens of Greatest Concern in Seafood Processing - Public Health Impacts
Bacillus cereus (B. cereus) is the bacterium responsible for B. cereus food poisoning. An estimated 27,400 foodborne cases of B. cereus food poisoning occur annually in the United States. There are two forms of the intoxication: one causes diarrhea, starting from 6 to 15 hours after consumption, and the other causes vomiting and nausea, starting from 30 minutes to 6 hours after consumption. Symptoms in both forms last about 24 hours. Everyone is susceptible to B. cereus food poisoning Campylobacter jejuni (C. jejuni) is the bacterium responsible for campylobacteriosis. An estimated 1,960,000 foodborne cases of campylobacteriosis occur annually in the United States. Symptoms include: diarrhea, fever, abdominal pain, nausea, headache, and muscle pain. Symptoms start from 2 to 5 days after consumption and last from 7 to 10 days. Everyone is susceptible to infection by C. jejuni. Clostridium botulinum (C. botulinum) toxin is the toxin responsible for botulism. An estimated 58 foodborne cases of botulism occur annually in the United States. Symptoms include: weakness; vertigo; double vision; difficulty in speaking, swallowing, and breathing; abdominal swelling; constipation; paralysis; and death. Symptoms start from 18 to 36 hours after consumption. Everyone is susceptible to intoxication by C. botulinum toxin; only a few micrograms of the toxin can cause illness. Mortality is high; without the antitoxin and respiratory support, death is likely. Clostridium perfringens (C. perfringens) is the bacterium responsible for perfringens food
poisoning. An estimated 249,000 foodborne cases of perfringens food poisoning occur annually in the United States. Symptoms include: abdominal cramps and diarrhea. Symptoms start from 8 hours to 1 day after consumption and last for about a day. Everyone is susceptible to perfringens food poisoning, but it is more common in the young and elderly. While most Escherichia coli (E. coli) are non pathogenic, certain strains of the bacterium are responsible for four types of illness: gastroenteritis or infantile diarrhea, caused by enteropathogenic E. coli (EPEC); travelers diarrhea, caused by enterotoxigenic E. coli (ETEC); bacillary dysentery, caused by enteroinvasive E. coli (EIEC); and hemorrhagic colitis, caused by enterohemorrhagic E. coli (EHEC). EHEC is the most severe, with potential for serious consequences, such as hemolytic uremic syndrome, particularly in young children. An estimated 173,000 foodborne cases from all four types of E. coli occur annually in the United States. Symptoms vary for the different forms of illness, but include: abdominal pain, diarrhea, vomiting, fever, chills, dehydration, electrolyte imbalance, high body fluid acidity, and general discomfort. Symptoms start from 8 hours to 9 days after consumption and last from 6 hours to 19 days, with both periods varying significantly between the illness types. Everyone is susceptible to all forms of infection from E. coli, but EPEC is most commonly associated with infants, and all types tend to result in more severe symptoms in the very young and elderly.
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Hepatitis A virus is responsible for foodborne hepatitis. An estimated 4,200 foodborne cases of hepatitis A occur annually in the United States. Symptoms include: fever, malaise, nausea, anorexia, abdominal discomfort, and jaundice. Symptoms start from 10 to 50 days after consumption and last 1 to 2 weeks. Unless previously infected or immunized, everyone is susceptible to infection by hepatitis A virus. Listeria monocytogenes (L. monocytogenes) is the bacterium responsible for listeriosis. An estimated 2,500 foodborne cases of listeriosis occur annually in the United States. L. monocytogenes can produce mild flu-like symptoms in all individuals. However, in susceptible individuals, including pregnant women, newborns, and the immunocompromised, it can result in more severe symptoms, which include: septicemia, meningitis, encephalitis, spontaneous abortion, and stillbirth. Symptoms start from 3 days to 3 weeks after consumption. Mortality is high in those that display the more severe symptoms. Norovirus (also known as Norwalk-like virus) is a major cause of viral gastroenteritis. An estimated 9,200,000 foodborne cases of norovirus occur annually in the United States. Symptoms include: diarrhea, nausea, vomiting, abdominal cramps, headache, body ache, and low-grade fever. Symptoms start from 2 to 4 days after consumption and generally last 2 days. Everyone is susceptible to infection by norovirus. Salmonella spp. is the bacterium responsible for salmonellosis. An estimated 1,340,000 cases of foodborne salmonellosis occur annually in the United States. Symptoms include: nausea, vomiting, abdominal cramps, diarrhea, fever, and headache. Symptoms start from 6 hours to 2 days after consumption and generally last from 1 to 2 days. The most severe form, typhoid fever, is caused by Salmonella typhi. Everyone is susceptible to infection by Salmonella spp., but symptoms are most severe in the elderly, infants, and the infirmed. Infections by Salmonella spp.
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and other closely related bacterial pathogens, such as Shigella spp., E. coli, and Yersinia enterocolitica infections can lead to chronic reactive arthritic symptoms in pre-disposed individuals. Shigella spp. is the bacterium responsible for shigellosis. An estimated 89,600 foodborne cases of shigellosis occur annually in the United States. Symptoms include: abdominal pain; cramps; diarrhea; fever; vomiting; blood, pus, or mucus in stools; continuous or frequent urges for bowel movement; and death. Symptoms start from 12 hours to 2 days after consumption and last from 1 to 2 weeks. Everyone is susceptible to infection by Shigella spp. Staphylococcus aureus (S. aureus) is the bacterium responsible for staphylococcal food poisoning. An estimated 185,000 foodborne cases of staphylococcal food poisoning occur annually in the United States. Symptoms include: vomiting, diarrhea, abdominal pain, nausea, and weakness. Symptoms usually start within 4 hours of consumption. Everyone is susceptible to intoxication by S. aureus toxin, with more severe symptoms, including occasional death, occurring in infants, the elderly, and debilitated persons. Vibrio cholerae (V. cholerae) O1 and O139 are the bacteria responsible for Asiatic or epidemic cholera. No major outbreaks of this disease have occurred in the United States since 1911, but an estimated 49 sporadic foodborne cases occur annually (including V. cholerae non-O1 and non-O139). Symptoms include: mild-to-severe diarrhea, abdominal cramps, nausea, vomiting, dehydration, shock, and death. Symptoms start from 6 hours to 5 days after consumption. Everyone is susceptible to infection by V. cholerae O1 and O139, but those with weakened immunity, reduced stomach acidity, or malnutrition may suffer more severe forms of the illness. V. cholerae non-O1 and non-O139 are bacteria that are also responsible for vibriosis. V. cholerae non-O1 and non-O139 may also cause gastroenteritis and, rarely, septicemia. The
symptoms of gastroenteritis include: diarrhea,

abdominal cramps, fever, vomiting, and
nausea. Symptoms start from 6 hours to 3 days
after consumption and last from 6 to 7 days.
Everyone is susceptible to gastroenteritis from V.
cholerae non-O1 and non-O139, but septicemia
usually develops only in those with underlying
chronic disease.
Vibrio parahaemolyticus (V. parahaemolyticus) is
another bacterium that is responsible for vibriosis.
An estimated 3,600 foodborne cases of vibriosis
from V. parahaemolyticus occur annually in the
United States. Vibriosis from V. parahaemolyticus,
as with Vibrio vulnificus, may cause gastroenteritis
and primary septicemia, although primary
septicemia is uncommon with V. parahaemolyticus.
The symptoms of gastroenteritis include: diarrhea;
abdominal cramps, nausea, vomiting, headache,
fever, and chills. Symptoms start from 4 hours to 4
days after consumption and last for about 2 days.
Everyone is susceptible to gastroenteritis from V.
parahaemolyticus, but septicemia usually develops
only in those with underlying chronic disease.
Vibrio vulnificus (V. vulnificus) is another
bacterium that is responsible for vibriosis. An
estimated 47 foodborne cases of vibriosis
caused by V. vulnificus (mostly septicemia)
occur annually in the United States, about half
of those resulting in death. Vibriosis caused
by V. vulnificus can take one of two forms,
gastroenteritis and primary septicemia. The
symptoms of gastroenteritis include: nausea,
chills, and fever. The symptoms of primary
septicemia include: septic shock and death.
Symptoms of gastroenteritis start from 16
hours to 2 days after consumption, and death
from septicemia may occur within 36 hours.
Everyone is susceptible to gastroenteritis from
V. vulnificus, but septicemia usually develops only in those with underlying chronic disease, particularly liver disease. Yersinia enterocolitica (Y. enterocolitica) is the bacterium responsible for yersiniosis. An estimated 86,700 foodborne cases of yersiniosis occur annually in the United States. Symptoms
include: fever, abdominal pain, diarrhea, vomiting, arthritis, and, rarely, septicemia. Symptoms start from 3 to 7 days after consumption and last from 1 to 3 days. Everyone is susceptible to infection by Y. enterocolitica, but symptoms are more severe in the very young, debilitated, elderly, and immunocompromised.
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BIBLIOGRAPHY.
We have placed the following references on display in the Division of Dockets Management, Food and Drug Administration, 5630 Fishers Lane, rm. 1061, Rockville, MD 20852. You may see them at that location between 9 a.m. and 4 p.m., Monday through Friday. As of March 29, 2011, FDA had verified the Web site address for the references it makes available as hyperlinks from the Internet copy of this guidance, but FDA is not responsible for any subsequent changes to NonFDA Web site references after March 29, 2011. Mead, P. S., L. Slutsker, V. Dietz, L. F. McCaig, J. S. Bresee, C. Shapiro, P. M. Griffin, and R. V. Tauxe. 1999. Food-related illness and death in the United States. Emerg. Infect. Dis. 5:607-625. Painter, J. 2004. Estimated cases of Vibrio parahaemolyticus in the United States. Personal communication. U.S. Food and Drug Administration. 2000. The bad bug book: foodborne pathogenic microorganisms and natural toxins handbook. http://www.cfsan.fda.gov/~mow/ intro.html.
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APPENDIX 8: Procedures for Safe and Sanitary Processing and Importing of Fish and Fishery Products
TITLE 21 OF THE CODE OF FEDERAL REGULATIONS PART 123 - FISH AND FISHERY PRODUCTS
SUBPART A - GENERAL PROVISIONS
Sec. 123.3 Definitions 123.5 Current good manufacturing practice 123.6 Hazard analysis and Hazard Analysis
SUBPART A - GENERAL PROVISIONS

Sec. 123.3 Definitions
The definitions and interpretations of terms in section 201 of the Federal Food, Drug, and Cosmetic Act (the act) and in part 110 of this chapter are applicable to such terms when used in this part, except where they are herein redefined. The following definitions shall also apply:
a. Certification number means a unique
Critical Control Point (HACCP) plan 123.7 Corrective actions 123.8 Verification 123.9 Records 123.10 Training 123.11 Sanitation control procedures 123.12 Special requirements for imported products SUBPART B - SMOKED AND SMOKE-FLAVORED
FISHERY PRODUCTS Sec. 123.15 General 123.16 Process controls
combination of letters and numbers assigned by a shellfish control authority to a molluscan shellfish processor.
b. Critical control point means a point, step,
or procedure in a food process at which control can be applied, and a food safety hazard can as a result be prevented, eliminated, or reduced to acceptable levels.
c. Critical limit means the maximum or
SUBPART C - RAW MOLLUSCAN SHELLFISH

Sec. 123.20 123.28
General Source controls
minimum value to which a physical, biological, or chemical parameter must be controlled at a critical control point to prevent, eliminate, or reduce to an acceptable level the occurrence of the identified food safety hazard.
d. Fish means fresh or saltwater finfish,
Authority: Secs. 201, 402, 403, 406, 409, 701,
704, 721, 801, 903 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321, 342, 343, 346, 348, 371, 374, 379e, 381, 393); secs. 301, 307, 361 of the Public Health Service Act (42 U.S.C. 241, 2411, 264).
crustaceans, other forms of aquatic animal life (including, but not limited to, alligator, frog, aquatic turtle, jellyfish, sea cucumber, and sea urchin and the roe of such animals) other than birds or mammals,
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and all mollusks, where such animal life is intended for human consumption.
e. Fishery product means any human food
product in which fish is a characterizing ingredient.

f. Food safety hazard means any biological, chemical, or physical property that may cause a food to be unsafe for human consumption.
changing into different market forms, manufacturing, preserving, packing, labeling, dockside unloading, or holding. (2) The regulations in this part do not apply to: (i) Harvesting or transporting fish or fishery products, without otherwise engaging in processing.
g. Importer means either the U.S. owner
or consignee at the time of entry into the United States, or the U.S. agent or representative of the foreign owner or consignee at the time of entry into the United States, who is responsible for ensuring that goods being offered for entry into the United States are in compliance with all laws affecting the importation. For the purposes of this definition, ordinarily the importer is not the custom house broker, the freight forwarder, the carrier, or the steamship representative.
h. Molluscan shellfish means any edible
(ii) Practices such as heading, eviscerating, or freezing intended solely to prepare a fish for holding on board a harvest vessel. (iii) The operation of a retail establishment.
l. Processor means any person engaged
species of fresh or frozen oysters, clams, mussels, or scallops, or edible portions of such species, except when the product consists entirely of the shucked adductor muscle.
i. Preventive measure means physical,
in commercial, custom, or institutional processing of fish or fishery products, either in the United States or in a foreign country. A processor includes any person engaged in the production of foods that are to be used in market or consumer tests.
m. Scombroid toxin-forming species means
chemical, or other factors that can be used to control an identified food safety hazard.
j. Process-monitoring instrument means an
tuna, bluefish, mahi mahi, and other species, whether or not in the family Scombridae, in which significant levels of histamine may be produced in the fish flesh by decarboxylation of free histidine as a result of exposure of the fish after capture to temperatures that permit the growth of mesophilic bacteria.
n. Shall is used to state mandatory
instrument or device used to indicate conditions during processing at a critical control point.
k. (1) Processing means, with respect to
requirements.
o. Shellfish control authority means a Federal,
fish or fishery products: Handling, storing, preparing, heading, eviscerating, shucking, freezing,
State, or foreign agency, or sovereign tribal government, legally responsible for the administration of a program that includes activities such as classification
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of molluscan shellfish growing areas, enforcement of molluscan shellfish harvesting controls, and certification of molluscan shellfish processors.
p. Shellstock means raw, in-shell molluscan
Sec. 123.6 Hazard Analysis and Hazard Analysis Critical Control Point (HACCP) plan a. Hazard analysis. Every processor
shellfish.
q. Should is used to state recommended
or advisory procedures or to identify recommended equipment.

r. Shucked shellfish means molluscan
shellfish that have one or both shells removed.

s. Smoked or smoke-flavored fishery products
means the finished food prepared by: (1) Treating fish with salt (sodium chloride), and (2) Subjecting it to the direct action of smoke from burning wood, sawdust, or similar material and/ or imparting to it the flavor of smoke by a means such as immersing it in a solution of wood smoke.
t. Tag means a record of harvesting
shall conduct, or have conducted for it, a hazard analysis to determine whether there are food safety hazards that are reasonably likely to occur for each kind of fish and fishery product processed by that processor and to identify the preventive measures that the processor can apply to control those hazards. Such food safety hazards can be introduced both within and outside the processing plant environment, including food safety hazards that can occur before, during, and after harvest. A food safety hazard that is reasonably likely to occur is one for which a prudent processor would establish controls because experience, illness data, scientific reports, or other information provide a basis to conclude that there is a reasonable possibility that it will occur in the particular type of fish or fishery product being processed in the absence of those controls.
b. The HACCP plan. Every processor
information attached to a container of shellstock by the harvester or processor.

Sec. 123.5 Current good manufacturing practice a. Part 110 of this chapter applies in
determining whether the facilities, methods, practices, and controls used to process fish and fishery products are safe, and whether these products have been processed under sanitary conditions.
b. The purpose of this part is to set
shall have and implement a written HACCP plan whenever a hazard analysis reveals one or more food safety hazards that are reasonably likely to occur, as described in paragraph (a) of this section. A HACCP plan shall be specific to: (1) Each location where fish and fishery products are processed by that processor; and (2) Each kind of fish and fishery product processed by the processor. The plan may group kinds of fish and fishery products
forth requirements specific to the processing of fish and fishery products.
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together, or group kinds of production methods together, if the food safety hazards, critical control points, critical limits, and procedures required to be identified and performed in paragraph (c) of this section are identical for all fish and fishery products so grouped or for all production methods so grouped.
c. The contents of the HACCP plan. The
process sufficient to kill the parasites, or where the processor represents, labels, or intends for the product to be so consumed; (viii) Unapproved use of direct or indirect food or color additives; and (ix) Physical hazards; (2) List the critical control points for each of the identified food safety hazards, including as appropriate: (x) Critical control points designed to control food safety hazards that could be introduced in the processing plant environment; and (xi) Critical control points designed to control food safety hazards introduced outside the processing plant environment, including food safety hazards that occur before, during, and after harvest; (3) List the critical limits that must be met at each of the critical control points; (4) List the procedures, and frequency thereof, that will be used to monitor each of the critical control points to ensure compliance with the critical limits; (5) Include any corrective action plans that have been developed in accordance with Sec. 123.7(b), to be followed in response to deviations from critical limits at critical control points;
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HACCP plan shall, at a minimum: (1) List the food safety hazards that are reasonably likely to occur, as identified in accordance with paragraph (a) of this section, and that thus must be controlled for each fish and fishery product. Consideration should be given to whether any food safety hazards are reasonably likely to occur as a result of the following: (i) Natural toxins;
(ii) Microbiological contamination; (iii) Chemical contamination; (iv) Pesticides; (v) Drug residues; (vi) Decomposition in scombroid toxin-forming species or in any other species where a food safety hazard has been associated with decomposition; (vii) Parasites, where the processor has knowledge or has reason to know that the parasite-containing fish or fishery product will be consumed without a
(6) List the verification procedures, and frequency thereof, that the processor will use in accordance with Sec. 123.8(a); (7) Provide for a recordkeeping system that documents the monitoring of the critical control points. The records shall contain the actual values and observations obtained during monitoring.
d. Signing and dating the HACCP plan.
safety hazards that are reasonably likely to occur.

f. Sanitation. Sanitation controls may
be included in the HACCP plan. However, to the extent that they are monitored in accordance with Sec. 123.11(b) they need not be included in the HACCP plan, and vice versa.
g. Legal basis. Failure of a processor
(1) The HACCP plan shall be signed and dated, either by the most responsible individual onsite at the processing facility or by a higher level official of the processor. This signature shall signify that the HACCP plan has been accepted for implementation by the firm. (2) The HACCP plan shall be dated and signed: (i) Upon initial acceptance;
to have and implement a HACCP plan that complies with this section whenever a HACCP plan is necessary, [or] otherwise operate in accordance with the requirements of this part, shall render the fish or fishery products of that processor adulterated under section 402(a) (4) of the act. Whether a processors actions are consistent with ensuring the safety of food will be determined through an evaluation of the processor overall implementation of its HACCP plan, if one is required.
Sec. 123.7 Corrective actions a. Whenever a deviation from a critical
(ii) Upon any modification; and (iii) Upon verification of the plan in accordance with Sec. 123.8(a)(1).
e. Products subject to other regulations.
limit occurs, a processor shall take corrective action either by: (1) Following a corrective action plan that is appropriate for the particular deviation, or (2) Following the procedures in paragraph (c) of this section.
b. Processors may develop written
For fish and fishery products that are subject to the requirements of part 113 or 114 of this chapter, the HACCP plan need not list the food safety hazard associated with the formation of Clostridium botulinum toxin in the finished, hermetically sealed container, nor list the controls to prevent that food safety hazard. A HACCP plan for such fish and fishery products shall address any other food
corrective action plans, which become part of their HACCP plans in accordance with Sec. 123.6(c) (5), by which they predetermine the corrective actions that they will take whenever there is a deviation from a critical limit. A corrective action plan that is appropriate for a particular deviation is one that describes
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the steps to be taken and assigns responsibility for taking those steps, to ensure that: (1) No product enters commerce that is either injurious to health or is otherwise adulterated as a result of the deviation; and (2) The cause of the deviation is corrected.
c. When a deviation from a critical limit
trained in accordance with Sec. 123.10, to determine whether the HACCP plan needs to be modified to reduce the risk of recurrence of the deviation, and modify the HACCP plan as necessary.
d. All corrective actions taken in accordance
occurs and the processor does not have a corrective action plan that is appropriate for that deviation, the processor shall: (1) Segregate and hold the affected product, at least until the requirements of paragraphs (c)(2) and (c)(3) of this section are met; (2) Perform or obtain a review to determine the acceptability of the affected product for distribution. The review shall be performed by an individual or individuals who have adequate training or experience to perform such a review. Adequate training may or may not include training in accordance with Sec. 123.10; (3) Take corrective action, when necessary, with respect to the affected product to ensure that no product enters commerce that is either injurious to health or is otherwise adulterated as a result of the deviation; (4) Take corrective action, when necessary, to correct the cause of the deviation; (5) Perform or obtain timely reassessment by an individual or individuals who have been
460
with this section shall be fully documented in records that are subject to verification in accordance with Sec. 123.8(a)(3)(ii) and the recordkeeping requirements of Sec. 123.9.
Sec. 123.8 Verification a. Overall verification. Every processor
shall verify that the HACCP plan is adequate to control food safety hazards that are reasonably likely to occur, and that the plan is being effectively implemented. Verification shall include, at a minimum: (1) Reassessment of the HACCP plan. A reassessment of the adequacy of the HACCP plan whenever any changes occur that could affect the hazard analysis or alter the HACCP plan in any way or at least annually. Such changes may include changes in the following: Raw materials or source of raw materials, product formulation, processing methods or systems, finished product distribution systems, or the intended use or consumers of the finished product. The reassessment shall be performed by an individual or individuals who have been trained in accordance with Sec. 123.10. The HACCP plan shall be modified immediately whenever a reassessment reveals that the plan is no longer adequate to fully meet the requirements of Sec. 123.6(c).
(2) Ongoing verification activities. Ongoing verification activities including: (i) A review of any consumer complaints that have been received by the processor to determine whether they relate to the performance of critical control points or reveal the existence of unidentified critical control points;
corrective actions were taken in accordance with Sec. 123.7. This review shall occur within 1 week of the day that the records are made; and (iii) The calibrating of any process control instruments used at critical control points and the performing of any periodic endproduct or in-process testing that is part of the processors verification activities. The purpose of these reviews shall be, at a minimum, to ensure that the records are complete, and that these activities occurred in accordance with the processors written procedures. These reviews shall occur within a reasonable time after the records are made.
b. Corrective actions. Processors shall
(ii) The calibration of processmonitoring instruments; and, (iii) At the option of the processor, the performing of periodic end-product or in-process testing. (3) Records review. A review, including signing and dating, by an individual who has been trained in accordance with Sec. 123.10, of the records that document: (i) The monitoring of critical control points. The purpose of this review shall be, at a minimum, to ensure that the records are complete and to verify that they document values that are within the critical limits. This review shall occur within 1 week of the day that the records are made;
immediately follow the procedures in Sec. 123.7 whenever any verification procedure, including the review of a consumer complaint, reveals the need to take a corrective action.
c. Reassessment of the hazard analysis.
(ii) The taking of corrective actions. The purpose of this review shall be, at a minimum, to ensure that the records are complete and to verify that appropriate
Whenever a processor does not have a HACCP plan because a hazard analysis has revealed no food safety hazards that are reasonably likely to occur, the processor shall reassess the adequacy of that hazard analysis whenever there are any changes that could reasonably affect whether a food safety hazard now exists. Such changes may include, but are not limited to changes in: Raw materials or source of raw materials, product
461
formulation, processing methods or systems, finished product distribution systems, or the intended use or consumers of the finished product. The reassessment shall be performed by an individual or individuals who have been trained in accordance with Sec. 123.10.
d. Recordkeeping. The calibration of
case of refrigerated products and for at least 2 years after the date they were prepared in the case of frozen, preserved, or shelf-stable products. (2) Records that relate to the general adequacy of equipment or processes being used by a processor, including the results of scientific studies and evaluations, shall be retained at the processing facility or the importers place of business in the United States for at least 2 years after their applicability to the product being produced at the facility. (3) If the processing facility is closed for a prolonged period between seasonal packs, or if record storage capacity is limited on a processing vessel or at a remote processing site, the records may be transferred to some other reasonably accessible location at the end of the seasonal pack but shall be immediately returned for official review upon demand.
c. Official review. All records required
process-monitoring instruments, and the performing of any periodic end-product and in-process testing, in accordance with paragraphs (a) (2)(ii) through (iii) of this section shall be documented in records that are subject to the recordkeeping requirements of Sec. 123.9.
Sec. 123.9 Records a. General requirements. All records
required by this part shall include: (1) The name and location of the processor or importer; (2) The date and time of the activity that the record reflects; (3) The signature or initials of the person performing the operation; and (4) Where appropriate, the identity of the product and the production code, if any. Processing and other information shall be entered on records at the time that it is observed.
b. Record retention.
by this part and all plans and procedures required by this part shall be available for official review and copying at reasonable times.
d. Public disclosure.
(1) All records required by this part shall be retained at the processing facility or importers place of business in the United States for at least 1 year after the date they were prepared in the
(1) Subject to the limitations in paragraph (d)(2) of this section, all plans and records required by this part are not available for public disclosure unless they have been previously disclosed to the public as defined in Sec. 20.81 of this chapter or they relate to a product or ingredient that has
462
been abandoned and they no longer represent a trade secret or confidential commercial or financial information as defined in Sec. 20.61 of this chapter. (2) However, these records and plans may be subject to disclosure to the extent that they are otherwise publicly available, or that disclosure could not reasonably be expected to cause a competitive hardship, such as generic-type HACCP plans that reflect standard industry practices.
e. Tags. Tags as defined in Sec. 123.3(t)
a. Developing a HACCP plan, which
could include adapting a model or generic-type HACCP plan, that is appropriate for a specific processor, in order to meet the requirements of Sec. 123.6(b);
b. Reassessing and modifying the
are not subject to the requirements of this section unless they are used to fulfill the requirements of Sec. 123.28(c).
f. Records maintained on computers.
HACCP plan in accordance with the corrective action procedures specified in Sec. 123.7(c)(5), the HACCP plan in accordance with the verification activities specified in Sec. 123.8(a)(1), and the hazard analysis in accordance with the verification activities specified in Sec. 123.8(c); and
c. Performing the record review
required by Sec. 123.8(a)(3). The trained individual need not be an employee of the processor.
Sec. 123.11 Sanitation control procedures a. Sanitation SOP. Each processor
The maintenance of records on computers is acceptable, provided that appropriate controls are implemented to ensure the integrity of the electronic data and signatures.
Sec. 123.10 Training
At a minimum, the following functions shall be performed by an individual who has successfully completed training in the application of HACCP principles to fish and fishery product processing at least equivalent to that received under a standardized curriculum recognized as adequate by the U.S. Food and Drug Administration or who is otherwise qualified through job experience to perform these functions. Job experience will qualify an individual to perform these functions if it has provided knowledge at least equivalent to that provided through the standardized curriculum.
should have and implement a written sanitation standard operating procedure (herein referred to as SSOP) or similar document that is specific to each location where fish and fishery products are produced. The SSOP should specify how the processor will meet those sanitation conditions and practices that are to be monitored in accordance with paragraph (b) of this section.
b. Sanitation monitoring. Each processor
shall monitor the conditions and practices during processing with sufficient frequency to ensure, at a minimum, conformance with those conditions and practices specified in part 110 of this chapter that are both appropriate to the plant and the food being processed and relate to the following:
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(1) Safety of the water that comes into contact with food or food contact surfaces, or is used in the manufacture of ice; (2) Condition and cleanliness of food contact surfaces, including utensils, gloves, and outer garments; (3) Prevention of cross-contamination from insanitary objects to food, food packaging material, and other food contact surfaces, including utensils, gloves, and outer garments, and from raw product to cooked product; (4) Maintenance of hand washing, hand sanitizing, and toilet facilities; (5) Protection of food, food packaging material, and food contact surfaces from adulteration with lubricants, fuel, pesticides, cleaning compounds, sanitizing agents, condensate, and other chemical, physical, and biological contaminants; (6) Proper labeling, storage, and use of toxic compounds; (7) Control of employee health conditions that could result in the microbiological contamination of food, food packaging materials, and food contact surfaces; and (8) Exclusion of pests from the food plant. The processor shall correct in a timely manner, those conditions and practices that are not met.
c. Sanitation control records. Each
document the monitoring and corrections prescribed by paragraph (b) of this section. These records are subject to the requirements of Sec. 123.9.
d. Relationship to HACCP plan. Sanitation
controls may be included in the HACCP plan, required by Sec. 123.6(b). However, to the extent that they are monitored in accordance with paragraph (b) of this section they need not be included in the HACCP plan, and vice versa.
Sec. 123.12 Special requirements for imported products
This section sets forth specific requirements for imported fish and fishery products.
a. Importer verification. Every importer of
fish or fishery products shall either: (1) Obtain the fish or fishery product from a country that has an active memorandum of understanding (MOU) or similar agreement with the Food and Drug Administration, that covers the fish or fishery product and documents the equivalency or compliance of the inspection system of the foreign country with the U.S. system, accurately reflects the current situation between the signing parties, and is functioning and enforceable in its entirety; or (2) Have and implement written verification procedures for ensuring that the fish and fishery products that they offer for import into the United States were processed in accordance with the requirements of this part. The procedures shall list at a minimum:
464
processor shall maintain sanitation control records that, at a minimum,
(i)
Product specifications that are designed to ensure that the product is not adulterated under section 402 of the Federal Food, Drug, and Cosmetic Act because it may be injurious to health or have been processed under insanitary conditions, and,
(ii) Affirmative steps that may include any of the following: A. Obtaining from the foreign processor the HACCP and sanitation monitoring records required by this part that relate to the specific lot of fish or fishery products being offered for import; B. Obtaining either a continuing or lot- bylot certificate from an appropriate foreign government inspection authority or competent third party certifying that the imported fish or fishery product is or was processed in accordance with the requirements of this part; C. Regularly inspecting the foreign processors facilities to ensure that the imported fish or fishery product is being processed in accordance with the requirements of this part;
465
D. Maintaining on file a copy, in English, of the foreign processors HACCP plan, and a written guarantee from the foreign processor that the imported fish or fishery product is processed in accordance with the requirements of this part; E. Periodically testing the imported fish or fishery product, and maintaining on file a copy, in English, of a written guarantee from the foreign processor that the imported fish or fishery product is processed in accordance with the requirements of this part or, F. Other such verification measures as appropriate that provide an equivalent level of assurance of compliance with the requirements of this part.
b. Competent third party. An importer
may hire a competent third party to assist with or perform any or all of the verification activities specified in paragraph (a)(2) of this section, including writing the importers verification procedures on the importers behalf.
c. Records. The importer shall maintain
records, in English, that document the performance and results of the affirmative steps specified in paragraph (a)(2)(ii) of this section.
These records shall be subject to the applicable provisions of Sec. 123.9.

d. Determination of compliance. There
must be evidence that all fish and fishery products offered for entry into the United States have been processed under conditions that comply with this part. If assurances do not exist that the imported fish or fishery product has been processed under conditions that are equivalent to those required of domestic processors under this part, the product will appear to be adulterated and will be denied entry. SUBPART B - SMOKED AND SMOKE-FLAVORED
FISHERY PRODUCTS Sec. 123.15 General
such processing does not include a treatment that ensures the destruction of vegetative cells of microorganisms of public health concern.
Sec. 123.28 Source controls a. In order to meet the requirements of
subpart A of this part as they apply to microbiological contamination, chemical contamination, natural toxins, and related food safety hazards, processors shall include in their HACCP plans how they are controlling the origin of the molluscan shellfish they process to ensure that the conditions of paragraphs (b), (c), and (d) of this section are met.
b. Processors shall only process molluscan
This subpart augments subpart A of this part by setting forth specific requirements for processing smoked and smokeflavored fishery products.
Sec. 123.16 Process controls
In order to meet the requirements of subpart A of this part, processors of smoked and smoke-flavored fishery products, except those subject to the requirements of part 113 or 114 of this chapter, shall include in their HACCP plans how they are controlling the food safety hazard associated with the formation of toxin by Clostridium botulinum for at least as long as the shelf life of the product under normal and moderate abuse conditions. SUBPART C - RAW MOLLUSCAN SHELLFISH
Sec. 123.20 General
shellfish harvested from growing waters approved for harvesting by a shellfish control authority. In the case of molluscan shellfish harvested from U.S. Federal waters, the requirements of this paragraph will be met so long as the shellfish have not been harvested from waters that have been closed to harvesting by an agency of the Federal government.
c. To meet the requirements of paragraph
This subpart augments subpart A of this part by setting forth specific requirements for processing fresh or frozen molluscan shellfish, where
466
(b) of this section, processors who receive shellstock shall accept only shellstock from a harvester that is in compliance with such licensure requirements as may apply to the harvesting of molluscan shellfish or from a processor that is certified by a shellfish control authority, and that has a tag affixed to each container of shellstock. The tag shall bear, at a minimum, the information required in Sec. 1240.60(b) of this chapter. In place of the tag, bulk shellstock shipments may be accompanied by a bill of lading or similar shipping document that contains the information required in Sec.
1240.60(b) of this chapter. Processors shall maintain records that document that all shellstock have met the requirements of this section. These records shall document:
(1) The date of harvest; (2) The location of harvest by State and site; (3) The quantity and type of shellfish; (4) The date of receipt by the processor; and (5) The name of the harvester, the name or registration number of the harvesters vessel, or an identification number issued to the harvester by the shellfish control authority.
d. To meet the requirements of paragraph
2. Section 1240.3 is amended by revising paragraph (r), and by adding new paragraphs (s), (t), and (u) to read as follows: Sec. 1240.3 General Definitions a. Molluscan shellfish. Any edible species of
fresh or frozen oysters, clams, mussels, and scallops or edible portions thereof, except when the product consists entirely of the shucked adductor muscle.
b. Certification number means a unique
combination of letters and numbers assigned by a shellfish control authority to a molluscan shellfish processor.
c. Shellfish control authority means a Federal,
(b) of this section, processors who receive shucked molluscan shellfish shall accept only containers of shucked molluscan shellfish that bear a label that complies with Sec. 1240.60(c) of this chapter. Processors shall maintain records that document that all shucked molluscan shellfish have met the requirements of this section. These records shall document: (1) The date of receipt; (2) The quantity and type of shellfish; and (3) The name and certification number of the packer or repacker of the product. PART 1240 - CONTROL OF COMMUNICABLE
DISEASES 1. The authority citation for 21 CFR part 1240 continues to read as follows: Authority: Secs. 215, 311, 361, 368 of the Public
State, or foreign agency, or sovereign tribal government, legally responsible for the administration of a program that includes activities such as classification of molluscan shellfish growing areas, enforcement of molluscan shellfish harvesting controls, and certification of molluscan shellfish processors.
d. Tag means a record of harvesting
information attached to a container of shellstock by the harvester or processor.

3. Section 1240.60 is amended by revising the section heading, by redesignating the existing text as paragraph (a) and adding the word molluscan before the word shellfish the two times that it appears, and by adding new paragraphs (b), (c), and (d) to read as follows: Sec. 1240.60 Molluscan Shellfish a. All shellstock shall bear a tag that discloses
Health Service Act (42 U.S.C. 216, 243, 264, 271).
the date and place they were harvested (by State and site), type and quantity of shellfish, and by whom they were harvested (i.e., the identification number assigned to the harvester by the shellfish control authority, where applicable or, if such identification numbers are not assigned, the name of the harvester
467
or the name or registration number of the harvesters vessel). In place of the tag, bulk shellstock shipments may be accompanied by a bill of lading or similar shipping document that contains the same information.
b. All containers of shucked molluscan
shellfish shall bear a label that identifies the name, address, and certification number of the packer or repacker of the molluscan shellfish.
c. Any molluscan shellfish without such
a tag, shipping document, or label, or with a tag, shipping document, or label that does not bear all the information required by paragraphs (b) and (c) of this section, shall be subject to seizure or refusal of entry, and destruction.
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Fish and Fishery Products Hazards and Controls Guidance

Fourth Edition APRIL 2011

Fish and Fishery Products Hazards and Controls Guidance

II. DISCUSSION A. Scope and Limitations

B. Changes in This Edition

If the product is held at internal

The product is held at internal

CHAPTER 1: General Information

CHAPTER 1: General Information

CHAPTER 1: General Information

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

THE HACCP PLAN FORM

THE HAZARD ANALYSIS WORKSHEET

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

Describe the food;

Describe the method of distribution and storage;

STEP 2: Describe the food.

Hazard Analysis Worksheet Set up the Hazard Analysis Worksheet;

Fresh tuna steaks; Frozen, surimi-based, imitation king crab

Establish corrective action procedures;

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

STEP 3: Describe the method of distribution and storage.

STEP 5: Develop a flow diagram.

STEP 4: Identify the intended use and consumer.

HAZARD ANALYSIS WORKSHEET

STEP 7: Identify the potential species-related hazards.

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

STEP 9: Understand the potential hazard.

STEP 8: Identify potential process-related hazards.

STEP 10: Determine whether the potential hazard is significant.

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

STEP 11: Identify critical control points.

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

HACCP PLAN FORM

STEP 13: Set critical limits.

STEP 14: Establish monitoring procedures.

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

STEP 15: Establish corrective action procedures.

STEP 16: Establish a recordkeeping system.

CHAPTER 2: Conducting a Hazard Analysis and Developing a HACCP Plan

STEP 17: Establish verification procedures.

STEP 18: Complete the HACCP Plan Form.

CHAPTER 3: Potential Species-Related and Process-Related Hazards

CHAPTER 3: Potential Species-Related and Process-Related Hazards

ACTUAL MARKET NAME OF PRODUCT

PRODUCT INAPPROPRIATELY LABELED AS

Escolar Puffer fish

Sea bass Monkfish

Parasites Ciguatera Fish Poisoning

CHAPTER 3: Potential Species-Related and Process-Related Hazards

POTENTIAL VERTEBRATE SPECIES-RELATED HAZARDS

AHOLEHOLE ALEWIFE OR RIVER HERRING ALFONSINO

Kuhlia spp. Alosa pseudoharengus

Beryx spp. Centroberyx spp. Alligator mississipiensis Alligator sinensis CFP

ALLIGATOR, AQUACULTURED AMBERJACK AMBERJACK OR YELLOWTAIL AMBERJACK OR YELLOWTAIL, AQUACULTURED

Alligator mississipiensis Alligator sinensis Seriola spp. Seriola lalandi

ASP5 ASP ASP

Sphyraena spp. BARRACUDA S. barracuda S. jello BARRAMUNDI Lates calcarifer

CFP CFP CFP

CHAPTER 3: Potential Species-Related and Process-Related Hazards