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Which Rule Book do I check?

Question – does FSMA covers Canned Seafood Manufacturing – well yes and no –

There was a couple of recalls for canned seafood this week — one of which was:

The Spot of Garibaldi, Oregon is voluntarily recalling ALL canned salmon and tuna with any codes starting with “OC” because it has the potential to be contaminated with Clostridium botulinum, a bacterium which can cause life-threatening illness or death. Consumers are warned not to use the product even if it does not look or smell spoiled.

Canned Seafood is currently governed by the Seafood HACCP and the Low Acid Canned Food Regulations, so it would not be covered by FSMA’s Preventive Measures for Human Foods as of now, it could evolve in the future. But if the “seafood” is sourced from overseas, then FSMA’s Foreign Suppler Verification Regulation would be required. Wonder if the supplier is still required to communicate the Hazards to the customer and then verify that the customer has preventive measures in place?

Let’s say that the Canned Seafood is Pasteurized Crab Meat and there is a requirement that the temperature has to be managed for Food Safety – then the main portion of the Sanitary Transportation Rule kicks in for temperature control. There are many other aspects to the Sanitary Transportation Rule in regards to truck inspections and communication of product holding requirements to the carrier that would require compliance. The compliance for this rule falls upon the “shipper” of the product as you can see that would require a higher level of communication that what was done in the past.

Not in reference to these recalls, but interesting as well – if a processor manufactures sausage, then they are governed by the USDA – FSIS HACCP regulations and are required to have inspectors on site to audit HACCP records. The FDA does not require inspectors to be on site for Food Product that they regulate.

It can be confusing as hell – for example, if the sausage manufacturing is done in a grocery store, then it is not covered by the USDA FSIS – it is covered by the state health or local agriculture departments rules  – and if a restaurant cooks the sausage and sell it to customers in a sit down or take out fashion, then it is covered by the FDA Food Code. – damn I wish we had only one food safety body in the US —

And for Produce, which is not covered by FSMA’s Preventive Measures for Human Foods unless it is further processed, would be covered by FSMA’s Produce Safety Rule. Of course, they are still trying to determine what is a farm and what is a further processor. More guidance is coming in the future.

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