Narrative. REVISED SEPTEMBER 2017 Commercial Processing Example: Wholesale/Distribution of Histamine Fish

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National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 Commercial Processing Example: Wholesale/Distribution of Histamine Fish Example: This is a Special Training Model for illustrative purposes only. The SHA models are based on guidance contained in FDA s Fish and Fishery Products Hazards and Guidance (4 th Edition, 2011) and additional information available since the 2011 edition. It was produced by the National Seafood HACCP Alliance (SHA) strictly as an example for training. This Model does not represent a specific requirement or recommendation from FDA. Keep in mind that this model may not apply to all situations. Narrative Product Market Names Amberjack (Yellowtail), Bluefish, Mackerel, Mahi-mahi, and Tuna (Large) (Thunnus albacares) Receive Wild caught fish are received from various suppliers. No fish are purchased directly from fishermen. All fish are fresh (not previously frozen). All five fish species are shipped from suppliers throughout the year by refrigerated truck in containers in which the product is thoroughly iced. Weekly shipments of tuna are received from one supplier by air freight. The tuna shipped by air is surrounded by frozen gel packs in insulated containers. Bluefish and mackerel are received during times of seasonal availability from a local supplier in a nonrefrigerated truck in containers that are thoroughly iced. No fish are received or shipped in reduced oxygen containers. Store Fresh fish are immediately moved into a refrigerated storage cooler where they are stored in containers in which the product is thoroughly iced. Customer orders are stored in the same storage units overnight if necessary. Pack/Repack & Label For each customer s order the products are removed from cooler, re packed on ice as necessary, labeled and then loaded onto company trucks or placed back into refrigerated storage overnight for delivery the next day. The maximum time out of refrigerated conditions for this step is less than 30 minutes. Intended Use: All fish are distributed with intentions to be consumed cooked by the consumer. There is no prior knowledge that the fish products will be consumed raw. Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 1 of 14

Wholesale/Distribution of Histamine Fish Processing Flow Chart RECEIVING REFRIGERATED STORAGE Dashed arrow indicates product returned to same storage unit PACK/REPACK and LABEL *Both refrigerated storage steps occur in the same cooler Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 2 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 Commercial Processing Example: Wholesale/Distribution of Histamine Fish Example: For Illustrative Purposes Only. Models are based in current guidance contained in FDA s Fish and Fishery Products Hazards and Guidance. Keep in mind that this model does not apply to all situations. Description Company: ABC Wholesale Company Fish or Shellfish Species Where Product Is Purchased From Fisherman From Fish Farm From Processor Refrigerated How Product Is Received Iced Frozen Shelf-Stable Refrigerated How Product Is Stored Iced Frozen Shelf-Stable Refrigerated How Product Is Shipped Iced Frozen Shelf-Stable How Product is Packaged Air Packed ROP* How Product Will Be Consumed Raw to be cooked Raw RTE* Cooked RTE* Intended Consumer General Public At Risk Population Common Name: Amberjack or Yellowtail Market Name: Amberjack Scientific Name: Seriola lalandi Common Name: Bluefish Market Name: Bluefish Scientific Name: Pomatomus saltatrix Common Name: Atlantic Mackerel Market Name: Mackerel Scientific Name: Scomber scombrus Common Name: Mahi-mahi or Dolphinfish Market Name: Mahi-mahi Scientific Name: Coryphaena spp. Common Name: Yellowfin Tuna Market Name: Tuna (Large) Scientific Name: Thunnus albacares + Gel Packs *ROP = Reduced Oxygen Packaging; *RTE = Ready-to Eat Potential Food Safety Hazards: All potential food safety hazards based on the product description and processing flow diagram associated with this product and process are identified using Tables 3 2 (species related) and 3 4 (process related) in the FDA Hazards and s Guidance (2011 edition). Processors should be aware that additional guidance may be periodically posted on FDA Seafood HACCP websites, and additional hazards not covered by this guidance may be relevant to certain products under certain circumstances. Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 3 of 14

REVISED SEPTEMBER 2017 National Seafood HACCP Alliance for Training and Education Recommendations in the FDA Guidance indicate 4 potential hazards that that are species or process related as listed in Tables 3 2 and 3 4. Each potential hazard must be addressed in the Hazard Analysis. The potential food safety hazards that must be considered in this firm s Hazard Analysis are: Species related hazards: 1. (Histamine formation) (All 5 fish species; species related hazard, chapter 7) Process-related hazards: 2. Food Allergens (natural) (All 5 fish species; process related hazard, chapter 19) 3. Metal Inclusion (if used in packaging) (All 5 fish species; process related hazard, chapter 20) FDA listed hazards NOT INCLUDED: 4. Environmental chemicals (Bluefish; species-related, chapter 5) because this potential hazard is addressed by the primary processor/supplier. 5. Pathogenic Bacteria Growth Temperature Abuse will not apply will not be included in the hazard analysis; products are to be cooked by or for the consumer by restaurant prior to consumption). 6. Food Additives (process-related hazards, chapter 19) was not included in the hazard analysis because the fish have not been exposed to any food additives prior to delivery or during further processing. SANITATION CONTROL PROCEDURES (SCP) are monitored throughout all processing steps and the daily SCP records accompany the HACCP records. Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 4 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 Hazard Analysis Worksheet Firm Name ABC Wholesale Company Finished Product Description: Amberjack (Yellowtail), Bluefish, Mackerel, Mahi-mahi, and Tuna (Large) *see note below Method of Storage & Distribution: Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer: Raw fish that will be cooked before it is eaten, to be consumed by the general public. Histamine Fish: Amberjack (Yellowtail), Bluefish, Mackerel, Mahi-mahi and Tuna (Large) (1) Processing Step (2) List all potential food safety hazards that could be associated with this product and process. (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this step? ( or No) (4) Justify the decision that you made in column 3 (5) What control measure(s) can be applied to prevent this significant hazard? (6) Is this step a Critical Point? ( or No) Temperature abuse during shipping could cause histamine Proper icing or temperature control during shipping Food Allergens Amberjack, Bluefish, Mackerel, Mahi-mahi and Tuna are food allergens Each species will be labeled with the correct market name at pack/ repack & label step No Metal Inclusion No Not likely to occur at this step; no introduction of metal fragments Histamine could form if temperature abuse occurs in storage Histamine fish will be stored on ice in the refrigeratred cooler Food Allergens Amberjack, Bluefish, Mackerel, Mahi-mahi and Tuna are food allergens Each species will be labeled with the correct market name at pack/ repack & label step No Metal Inclusion No Not likely to occur at this step; no introduction of metal fragments No Time-temp abuse not likely because of short time at this step Food Allergens Amberjack, Bluefish, Mackerel, Mahi-mahi and Tuna are food allergens Each container must be labeled with the market name of the fish species at this step Metal Inclusion No Not likely to occur at this step No Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 5 of 14

REVISED SEPTEMBER 2017 (1) Processing Step (2) List all potential food safety hazards that could be associated with this product and process. (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this step? ( or No) (4) Justify the decision that you made in column 3 National Seafood HACCP Alliance for Training and Education (5) What control measure(s) can be applied to prevent this significant hazard? (6) Is this step a Critical Point? ( or No) Histamine could form if temperature abuse occurs in storage Histamine fish will be stored on ice in the refrigerated cooler Refrigerated storage (final) Food Allergens No Each species was labeled with the correct market name at pack/ repack & label step Metal Inclusion No Not likely to occur at this step; no introduction of metal fragments * Note - All five fish species are shipped from suppliers throughout the year by refrigerated truck in containers in which the product is thoroughly iced. Weekly shipments of tuna are received from one supplier by air freight. The tuna shipped by air is surrounded by frozen gel packs in insulated containers. Bluefish and mackerel are received during times of seasonal availability from a local supplier in a non-refrigerated truck in containers that are thoroughly iced. Wholesale/Distribution of Histamine Fish Processing Flow Chart Shaded steps are Critical Points CCP 1A, 1B, RECEIVING CCP 2 REFRIGERATED STORAGE Dashed arrow indicates product returned to same storage unit CCP 3 PACK/REPACK and LABEL *Both refrigerated storage steps occur in the same cooler Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 6 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 HACCP Plan Form Firm Name ABC Wholesale Company Product Description Amberjack (Yellowtail), Bluefish, Mackerel, Mahimahi, and Tuna (large) Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure What How Frequency Who Corrective Action Verification Records CCP 1A: RECEIVING (surrounded by ice in refrigerated truck) All products are completely surrounded with ice at receipt Amount of ice Visual check of representative number of containers in shipment in comparison with pictured standards Every shipment Receiving Manager IF: containers do not have enough ice; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards; Discontinue use of supplier until their transport procedures are corrected. Retrain involved staff. Review Daily Receiving Log and Corrective Actions once per week. Conduct periodic internal product temperature checks with temperature probe to assess proper icing. Thermometer calibration and accuracy checks monthly Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Signature: Date: Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 7 of 14

REVISED SEPTEMBER 2017 HACCP Plan Form National Seafood HACCP Alliance for Training and Education Firm Name ABC Wholesale Company Product Description Tuna (large) delivered by air freight using gel packs to maintain product temperature Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) CCP 1B: RECEIVING (delivered by air freight using gel packs to maintain product temperature) Critical Limits for each Measure What How Frequency Who Corrective Action Verification There is an adequate quantity of frozen gel packs surrounding the fish at the time of delivery, AND The internal temperature of the fish at the time of delivery is 40 F or below The quantity and frozen status of gel packs at the time of delivery, and The internal temperature of the fish at the time of delivery Visual observation of the adequacy and frozen state of the gel packs in a representative number of containers throug delivery, and Use a thermometer to measure the internal temperature in a representative number of fish from throughout the shipment at delivery Every shipment of tuna by air freight Receiving Manager IF: containers do not have enough gel packs or the gel packs are not frozen or the internal temperature of the fish in any container is above 40 F; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards; Discontinue use of supplier until their transport procedures are corrected. Retrain involved staff. Review Daily Receiving Log and Corrective Actions once per week. Check the accuracy of the thermometer used to measure the internal temperature of fish before each use. Calibrate this thermometer annually or according to manufacturer specifications. Records Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Signature: Date: Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 8 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 HACCP Plan Form Firm Name ABC Wholesale Company Product Description Bluefish and Mackerel seasonally received from a local s delivered on an unrefrigerated truck. Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure CCP 1C: RECEIVING (surrounded by ice in unrefrigerated truck) All fish are completely surrounded with ice at the time of delivery, and The internal temperature of the fish at the time of delivery is 40 F or below What How The adequacy of ice surrounding the fish at the time of delivery, AND The internal temperature of the fish at the time of delivery Visual observation of the adequacy of ice in a representative number of containers throughout the shipment at the time of delivery, AND Use a thermometer to measure the internal temperature in a representative number of fish from throughout the shipment at delivery Frequency Who Corrective Action Verification Every shipment of bluefish and mackerel received in an unrefrigerated truck Receiving Manager IF: containers do not have adequate ice or the internal temperature of the fish in any container is above 40 F; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards; Discontinue use of supplier until their transport procedures are corrected. Retrain involved staff. Review Daily Receiving Log and Corrective Actions once per week. Check the accuracy of the thermometer used to measure the internal temperature of fish before each use. Calibration this thermometer annually or according to manufacturer specifications. Records Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Signature: Date: Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 9 of 14

REVISED SEPTEMBER 2017 HACCP Plan Form National Seafood HACCP Alliance for Training and Education Firm Name ABC Wholesale Company Product Description Amberjack (Yellowtail), Bluefish, Mackerel, Mahi-mahi, and Tuna (large) Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure What How Frequency Who CCP 2: REFRIGERATED STORAGE (INITIAL AND FINAL) All products are completely surrounded with ice while stored in the cooler Amount of ice Visual check of representative number of containers in shipment in comparison with pictured standards Every 4 hours during business operating hours Cooler manager Corrective Action IF the amount of ice is not adequate; THEN: Chill and hold the product until it can be evaluated based on its total time and temperature exposure, including exposures during prior processing operations; Reject suspect and obviously abused products To regain control, determine and document the cause for improper icing; document the problem and corrections through further training of involved staff. Verification Review Daily Receiving Log and Corrective Actions once per week. Conduct periodic internal product temperature checks with temperature probe to assess proper icing. Thermometer calibration and accuracy checks monthly Records Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Signature: Date: Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 10 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 HACCP Plan Form Firm Name ABC Wholesale Company Product Description Amberjack (Yellowtail), Bluefish, Mackerel, Mahi-mahi, and Tuna (large) Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure What How Frequency Who Corrective Action Verification Records CCP 3: PACK/REPACK AND LABEL Food Allergens All containers or packages of fish must be identified with their market name Label on Product Containers Visual check for each delivery Each container for each delivery Packing Supervisor IF the container does not contain the market name, THEN label the container and invoice as necessary for correct identification Regain control by identifying, recording and correcting the cause for the problem. Retrain involved staff. Review Packing Log and Corrective Actions once per week Train packing room workers to correctly identify all products with appropriate labels Packing Log and Corrective Actions Signature: Date: Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 11 of 14

REVISED JUNE 2017 Firm Name ABC Wholesale Company HACCP Plan Form (landscape format) National Seafood HACCP Alliance for Training and Education Product Description Amberjack, Bluefish, Mackerel, Mahi-mahi, and Tuna (large) Method of Storage & Distribution Stored and distributed packed in ice under refrigeration in oxygen permeable containers Intended Use & Consumer Raw fish that will be cooked before it is eaten, to be consumed by the general public. Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure Monitoring Corrective Action Verification Records What How Frequency Who CCP 1A Receiving (surrounded by ice in refrigerated truck) All products are completely surrounded with ice at receipt Amount of ice Visual check of representative number of containers in shipment in comparison with pictured standards Every shipment Receiving Manager IF: containers do not have enough ice; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards. Discontinue use of supplier until their transport procedures are corrected. Review Daily Receiving Log and Corrective Actions once per week. Conduct periodic internal product temperature checks with temperature probe to assess proper icing. Thermometer calibration and accuracy checks monthly Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Retrain involved staff. CCP 1B Receiving (delivered by air freight using gel packs to maintain product temperature) There is an adequate quantity of frozen gel packs surrounding the fish at the time of delivery, AND The internal temperature of the fish at the time of delivery is 40 F or below The quantity and frozen status of gel packs at the time of delivery, and The internal temperature of the fish at the time of delivery Visual observation of the adequacy and frozen state of the gel packs in a representative number of containers throughout the shipment at the time of delivery, and Every shipment of tuna by air freight Receiving Manager IF: containers do not have enough gel packs or the gel packs are not frozen or the internal temperature of the fish in any container is above 40 F; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards; Discontinue use Review Daily Receiving Log and Corrective Actions once per week. Check the accuracy of the thermometer used to measure the internal temperature of fish before each use. Calibration this thermometer annually or according to manufacturer specifications. Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 12 of 14

National Seafood HACCP Alliance for Training and Education REVISED SEPTEMBER 2017 Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure Monitoring Corrective Action Verification Records What How Frequency Who Use a thermometer to measure the internal temperature in a representative number of fish from throughout the shipment at delivery of supplier until their transport procedures are corrected. Retrain involved staff. CCP 1C Receiving (surrounded by ice in unrefrigerated truck) All fish are completely surrounded with ice at the time of delivery, AND The internal temperature of the fish at the time of delivery is 40 F or below The adequacy of ice surrounding the fish at the time of delivery, and The internal temperature of the fish at the time of delivery Visual observation of the adequacy of ice in a representative number of containers throughout the shipment at the time of delivery, AND Use a thermometer to measure the internal temperature in a representative number of fish from throughout the shipment at delivery Every shipment of bluefish and mackerel received in an unrefrigerated truck Receiving Manager IF: containers do not have adequate ice or the internal temperature of the fish in any container is above 40 F; THEN: reject product To regain control: Call supplier to let them know CL was not met and provide product delivery specifications and standards; Discontinue use of supplier until their transport procedures are corrected. Retrain involved staff. Review Daily Receiving Log and Corrective Actions once per week. Check the accuracy of the thermometer used to measure the internal temperature of fish before each use. Calibrate this thermometer annually or according to manufacturer specifications. Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 13 of 14

REVISED JUNE 2017 Critical Point (CCP) Significant Hazard(s) Critical Limits for each Measure National Seafood HACCP Alliance for Training and Education Monitoring Corrective Action Verification Records What How Frequency Who Refrigerated Storage (Initial and Final) All products are completely surrounded with ice while stored in the cooler Amount of ice Visual check of representative number of containers in shipment in comparison with pictured standards Every 4 hours during business operating hours Cooler manager IF the amount of ice is not adequate; THEN: Chill and hold the product until it can be evaluated based on its total time and temperature exposure, including exposures during prior processing operations. Reject suspect and obviously abused products Review Daily Receiving Log and Corrective Actions once per week. Conduct periodic internal product temperature checks with temperature probe to assess proper icing. Thermometer calibration and accuracy checks monthly Daily Receiving Log; Corrective Actions and thermometer calibration and accuracy records To regain control, determine and document the cause for improper icing; document the problem and corrections through further training of involved staff. Pack / Repack and Label Food Allergens All containers or packages of fish must be identified with their market name Label on Product Containers Visual check for each delivery Each containers for each delivery Packing Supervisor IF the container does not contain the market name, THEN label the container and invoice as necessary for correct identification Regain control by identifying, recording and correcting the cause for the problem. Retrain involved staff. Review Packing Log and Corrective Actions once per week Train packing room workers to correctly identify all products with appropriate labels Packing Log and Corrective Actions Signature: Date: * All five fish species are shipped from suppliers throughout the year by refrigerated truck in containers in which the product is thoroughly iced. Weekly shipments of tuna are received from one supplier by air freight. The tuna shipped by air is surrounded by frozen gel packs in insulated containers. Bluefish and mackerel are received during times of seasonal availability from a local supplier in a non-refrigerated truck in containers that are thoroughly iced. Seafood HACCP Models: Wholesale/Distribution of Histamine Fish Page 14 of 14