HACCP
Hazard Analysis and Critical Control Point - Florida Sea Grant
Hazard Analysis and Critical Control Point - Florida Sea Grant
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Chapter 2<br />
• Traceability and product recalls: Procedures should be in place to ensure<br />
that raw material and finished products are coded and identified properly<br />
in order to trace the product backward (from receipt) and forward (into<br />
distribution). Traceability procedures are required by the Public Health<br />
Security and Bioterrorism Preparedness and Response Act of 2002<br />
(Bioterrorism Act). A product recall system should also be in place so that<br />
products can be removed from the marketplace quickly when necessary.<br />
Recall procedures can be found in Code of Federal Regulation (CFR) 21,<br />
Part 7, Enforcement.<br />
• Preventive maintenance: Facility and equipment often require routine<br />
maintenance before problems develop. Preventive maintenance schedules<br />
and procedures should be established and documented using manufacturer<br />
and other information as needed.<br />
Finally, there are a number of requirements that are also considered<br />
prerequisite programs that a processor should know (Slide 7). This course<br />
cannot discuss all prerequisite program in detail. Depending on the product or<br />
business, there will be additional compliance requirements that apply to the<br />
foods being processed.<br />
Slide 7<br />
Other requirements that are considered prerequisite programs:<br />
• Local regulations<br />
• Food defense and biosecurity requirements – Department of<br />
Homeland Security (DHS)<br />
• Allergen labeling requirements – Food Allergen Labeling and<br />
Consumer Protection Act of 2004<br />
• Country of origin labeling (COOL) requirements – 2002 Farm Bill<br />
• Nutritional labeling – Nutritional Labeling and Education Act, 1994<br />
(NLEA) Requirements<br />
• Regulatory food standards<br />
• Procedures to guard against economic fraud<br />
There may be specific state or local code requirements for food processing<br />
establishments in your area that specify where your operation should be<br />
located, and how it is constructed and maintained. You may also need to<br />
obtain specific permits or licenses from state or local authorities. There may<br />
be product-specific requirements for nutritional and allergen labeling. If the<br />
product is being imported, it is necessary to meet the requirements in the<br />
Bioterrorism Act.<br />
FDA Eight Key Sanitation Areas<br />
10<br />
FDA’s seafood <strong>HACCP</strong> regulation focuses on eight key areas of sanitation (Slide<br />
8). These eight areas of sanitation are derived from the GMPs (see Appendix<br />
3). FDA’s seafood <strong>HACCP</strong> regulation does not require that SCPs program be<br />
written. However, FDA requires that these eight key areas of sanitation be<br />
monitored and that the results be recorded along with any corrections for<br />
deficiencies.