Seafood and food safety issues related to aquaculture

The U.S. FDA HACCP regulations can provide aquaculturists with processing and handling guidelines to effectively operate their business.

Aquaculturists who process their own fish are directly affected by the U.S. Food and Drug Administration (FDA) HACCP regulation. Those that sell fish to a processor are indirectly affected by the HACCP regulation. Processors of domestic, as well as, imported fishery products will take greater responsibility for incoming materials, which will directly affect aquaculture producers. If the supplier, such as an aquaculture producer, does not provide satisfactory information about how the fish were handled, the HACCP plan will strengthen the processor’s position in refusing to accept shipment. The aquaculture producer, thus, will be responsible for providing specific information to fish processors who purchase their fish or allow these fish processors or their representative to visit their sites to collect information on their aquaculture practices. This information may include proper use of aquaculture drugs and prevention of product contamination with environmental chemical contaminants and agriculture chemicals. Aquaculturists can expect to bear increased responsibility for documenting compliance with the HACCP regulations, as it is doubtful the FDA will permit direct sale of aquaculture products to end users without HACCP controls, even when fish production and harvesting, trucking, and retail are excluded from the regulation.

Aquaculturists who sell their fish to a fish processor will be expected to work out some type of arrangement that will help ensure the safety of the product. This fish processor or one of his representatives may visit  the fish farm one or more times per year to observe proper use of aquaculture drugs and agricultural and industrial practices near the fish production areas. At this time, samples may be collected for drug residue, environmental chemical contaminants, and pesticide analysis. The aquaculturist may also perform these same duties and provide a certificate to the fish processor, with each lot of fish sold, verifying that these specific areas were monitored. A third party certificate is also allowable if the aquaculturist operates under a Quality Assurance Program that covers aquaculture drug usage, environmental chemical contaminants, and pesticides.

There are practices that are exempt from the FDA HACCP regulations, but the aquaculture producer will still need to comply with specific state and/or local regulations where applicable. For instance, an aquaculture producer would not be subject to the FDA HACCP regulations when he harvests and boxes his fish whole, on ice, for immediate transportation to a wholesaler or retailer within the state or outside the state. The aquaculture producer would not be subject to the HACCP regulation whether he sold his boxed, whole fish to a wholesaler at the farm site and the wholesaler transported the fish off-farm and to a retail market or if the producer did the transportation. But, if the aquaculture producer holds the product after harvesting and prior to distribution for 24 hours or more, that operation would be subject to the regulations. Holding is deemed processing as defined by the HACCP regulation. If the aquaculture producer performs any other activities as defined by the regulations such as heading, eviscerating and freezing, he would be subject to the regulations.

Other practices that are exempt from the FDA HACCP regulations include live fish hauling to various market outlets, custom processing the fish directly for a costumer who does not resell it, and fee fishing operations. Fish may be taken to some location in the same state or may be taken to another state for consumption.

Aquaculture producers who do not process their own fish may not be directly affected by the FDA HACCP regulations, but may in many ways be affected indirectly. It is important that all aquaculture producers take it upon themselves to become aware of the HACCP regulations to circumvent any surprises when it comes time to market their fish.

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