According to law, certain HACCP functions must be performed by someone who has completed training equivalent to the HACCP Training Curriculum (publication UNC-SG-96-02) developed by The National Seafood HACCP Alliance for Training and Education. These functions include developing the plan, changing the plan, and conducting record review. This training may be obtained through classroom instruction or by equivalent on-the-job training. See Sec. 123.10 of the regulations for details. This generic HACCP plan for Pacific oysters is based on the principles detailed in that manual, in guidance contained in the FDA's Fish and Fisheries Products Hazards and Controls Guide, First Edition, September 1996, and the National Shellfish Sanitation Program Manual of operations, Part II, Sanitation of the Harvesting, Processing, and Distribution of Shellfish, 1995 Revision.

Oyster processors also should be aware that FDA's HACCP regulation (Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products; Final Rule, December 18, 1995) requires that they monitor and keep records on their sanitation procedures. This is best done by writing and implementing an SSOP (Sanitation Standard operating Procedure). Examples of this can be found on University of California's Seafood NIC Web site .

Kenneth S. Hilderbrand, Jr.
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