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conducted on the basis of Hazard Analysis Critical Control 

 Point, or "HACCP," principles. 



C. Domestic Inspection: HACCP 



HACCP is a system of preventive controls that are established 

 and maintained by a processor for the purpose of keeping 

 hazards from occurring. As my testimony has already described, 

 there are a variety of environmental and processing hazards to 

 which seafood can be exposed from water to table. It is 

 imperative that those who handle and process seafood 

 commercially understand the hazards and keep them from 

 occurring through a system of routine preventive controls. 



In essence, HACCP requires that processors have a written plan 

 that (1) identifies the likely hazards that could affect their 

 products; (2) identifies "critical control points" where a 

 failure is likely to cause or permit the hazard to occur; (3) 

 establishes "critical limits," or measurable operating 

 parameters at each critical control point, such as cooking and 

 refrigeration temperatures; and (4) establishes both monitoring 

 procedures and recordkeeping procedures to systematically 

 record the results of the monitoring. 



FDA has consistently advocated HACCP controls for the seafood 

 industry since the 1980 's and, along with the National Oceanic 



