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Am I a Processor?

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I get asked this question a lot, mostly because it dictates the level to which you are regulated by local, state, and federal agencies. Many small-scale producers are surprised to find out that the answer is yes, according to regulators. Offloading, holding, and transporting fish is considered “processing” if you are engaged in sales to anyone other than an end user. That means that you are a processor if you sell to restaurants or retail markets, even if you never cook a crab or fillet a fish. HINT: If anyone has EVER asked you for a HACCP letter, you are most likely a processor.

(k)(1) Processing means, with respect to fish or fishery products: Handling, storing, preparing, heading, eviscerating, shucking, freezing, 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.

(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.
— CFR 21 Part 123.3

The way the regulations are written can be confusing. You do NOT need a HACCP plan for any action you perform on board a vessel and you do not need HACCP plans if you are a retail store. If your situation is unclear, get in touch for a free compliance review and I can point you in the right direction. 

Okay, so you're a processor, now what? Well, you are held to a higher food safety standard. Meet our old pal 21 CFR part 123. In fact, you are now required to have HACCP plans for everything you sell as well as written sanitation monitoring, staff training records, and a recall plan. The good news is that there's a lot of open-source HACCP information out there, the bad news is that you are legally obligated to monitor anything you list on your HACCP plans as a Critical Control Point (CCP). I've reviewed many HACCP plans that go overboard, committing a fisher to a crazy amount of unnecessary documentation. It makes sense to have an expert review your plans should you choose to create them yourself prior to implementation.

The goal of a good HACCP plan is to properly identify and fully address CCP's while not committing to processes and documentation that are not part of the regulations. You will very likely go above and beyond your HACCP plans in your day to day operations for the sake of quality, but you do not want to list quality control measures in your plan. Why? Anything you list in your plan must be documented and that documentation must be reviewed within seven days of its creation. You also must provide verification of your CCP's via a scientific study or an excerpt from the Fish and Fisheries Products Hazards and Controls Guidance. Essentially, anything you put in your HACCP plan is going to generate paperwork and suck up your time, so you only put in what is necessary. It is common for a well-organized processor to have a HACCP plan that addresses the 21 CFR Part 123 requirements and other internal documents and Standard Operating Procedures that fully outline all quality control measures taken. When it comes to seafood HACCP, keeping it simple is always best.

If you suspect (Or know.) that you are a processor and you are lagging on your compliance paperwork, it's not too late to get compliant. It's always best to get your systems in place before you get a citation or even worse, an order to stop production. As you can tell, I love talking about this stuff. Get in touch and I can help you get on track.