Under HACCP 

 IHleS, crab 

 processors must 



record the time 



off problems in the first place was the 

 best way to know the food was safe. 



Under the FDA's seafood regula- 

 tion, companies first have to scrutinize 

 their operations for "hazards that are 

 reasonably likely to occur and would 

 cause illness or injury to the consumer." 



These include biological hazards 

 such as bacteria and viruses; chemical 

 hazards such as histamine, which is 

 produced naturally by bacteria on 

 certain fish and can cause severe allergic 

 reactions in some people; and physical 

 hazards such as broken glass. 



Businesses then must find ways to 

 fend off any risks they discover through 

 steps called "critical control points." To 

 keep bacteria from growing on fish, for 

 example, they refrigerate it. Or to reduce 

 the risk of disease-causing bacteria, they 

 harvest oysters, clams and mussels only 

 from approved, unpolluted waters. 



The businesses also have to explain 

 how they will detect and respond to 

 problems and how they can verify that 

 their HACCP program works. 



In addition, all companies that 

 handle seafood must show they follow 

 eight basic sanitation rules. For ex- 

 ample, unsanitary objects cannot touch 

 food and food packages. They also must 



document that their water comes from a 

 safe source. They can't allow employees to 

 work if they're sick or have certain wounds 

 or sores. 



Early on, Johnson was excited about 

 HACCP' s promise because it seemed to 

 be a way for businesses to tailor food 

 safety programs to fit their own opera- 

 tions. He earned HACCP certification six 

 years ago, long before most people had 

 heard of the program, and he has made 

 several changes to help his business meet 

 HACCP standards. Johnson built a 

 separate ice room, and he used a Fishery 

 Resource Grant from the state to install 

 an automated monitoring 

 system that checks the 

 temperature of the coolers, 

 freezers, crab cooker and 

 pasteurizer. The company also 

 sponsored its own HACCP 

 training class for dealers and 

 fishers this spring. 



"I don't know anybody in 

 North Carolina who's done 

 more to get ready than we've 

 done," he says. 



That's why Johnson says 

 he was disappointed, but not 

 surprised, by the FDA's 

 inspection this summer. He 

 speaks highly of the inspector 

 who conducted the review, but 

 he says the agency took a 

 "cookie-cutter approach" by 

 penalizing his plant because its 

 HACCP plan didn't mirror the 

 FDA's guidebook in two areas. 



"We used it as a guide, and 

 they're using it as the Bible," 

 Johnson says about the HACCP 

 guidebook. In both areas, the 

 company handled a potential risk through 

 its sanitation standard operating procedures 

 rather than as a separate critical control 

 point. 



One question concerned the way the 

 company cools freshly picked crabmeat. 

 All the company had to do was change 

 the designation of that process to a 

 critical control point because it was 



10 HOLIDAY 1998 



