HACCP FOR SILURIFORMES OPERATIONS UNDER THE US FDA AND THE USDA-FSIS SYSTEMS- A COMPARISON OF HOW TO ADDRESS HAZARDS AND ENVIRONMENTAL SAMPLING FINDINGS UNDER BOTH SYSTEMS

The USDA Food Safety Inspection Service now oversees the safety and other aspects of Siluriformes. These, as with other species of fish/seafood, were under the US FDA. This is an attempt to show potential differences between general HACCP programs under the USDA-FSIS and the US FDA. The current model for Siluriformes follows 9CFR (HACCP Regulation for Siluriformes), assuming the installation has adequate prerequisite programs in place (at minimum SSOPs to meet SCPs and Good Manufacturing Practices-cGMPs, 21CFR117B). The earlier model followed 21CFR123 (FDAs Seafood HACCP). Moreover, the model uses both the FDA's Fish and Fishery Products Hazards and Controls Guidance - 4th edition (http://www.fda.gov/downloads/Food/GuidanceRegulation/UCM251970.pdf) and the Hazard Analysis and Critical Control Point. Training Curriculum. 5th Edition (http://seafood.oregonstate.edu/.pdf%20Links/HACCP-Training-Curriculum-5th-Ed-2011.pdf) as well as the FSIS Compliance Guideline for Establishments that Slaughter or Further Process Siluriformes Fish and Fish Products, as well as other references. Since both HACCP plans identify similar hazards associated with the product/processes, the main differences are in the ways in which the hazards are analyzed and justified. Regardless of plan, both plans identify similar potential hazards but differ in which are elevated or could be elevated to significant hazards leading to a difference in critical control points.

Environmental sampling of food contact (FC) and nonfood contact (NFC) sites in channel catfish operations under FDA and just after FSIS HACCP implementation show similar findings in terms of pre-op and post-production samples (see Table). Selected sites seemed to be persistent for Listeria sp.  and may need additional attention in a sanitation SOP.