NOAA Inspection Manual 25
Chapter Four: Policies, Procedures, and Requirements for the Audit of Fisheries Products on a Lot by Lot Basis
Authority for the USDC Seafood Inspection Program (SIP) to provide product inspection (audit) services can be found within the Agricultural Marketing Act of 1946, the Fish and Wildlife Act of 1956, and the regulations promulgated under these authorities (i.e., 50 CFR Part 260.)
Lot inspection (audit) and sampling services are performed by the USDC Seafood Inspection Program on a voluntary, fee-for-service basis. Product inspection services can be provided to determine adherence to:
- Minimum Acceptable Quality (MAQ)
- U.S. Grade A, B, or C Attributes
- Buyer Specifications (i.e., Net weight, size, count and/or other product attributes as defined by the buyer)
These services conform to global activities to harmonize inspection protocols. These services are designed to enhance the safety, wholesomeness, economic integrity, and quality of seafood available to consumers. If there are no Buyer Specifications from the applicant, the minimum inspection effort applied to every lot inspection will be adherence to the Minimum Acceptable Quality Standard of Quality and Condition, Flavor and Odor.
The purpose of product audits is to facilitate the distribution of fish and fishery products that are safe, wholesome, properly labeled, and of desired uniform quality. Any individual, processor, retail operation, warehouse operation, or import/export dealer, foreign or domestic, may use the services of this program.
- Application for Services
- Lot Identification
On the Request for Inspection Services form, the applicant will clearly identify the lot to be inspected, including the lot number, brand, product name, number of cartons/cases and size, and the total pounds. Any additional codes and/or identification marks on the containers should also be noted. The application will also indicate where the product is physically located, and the applicant is responsible for making sure that the product is available for inspection.
- Reworked or Reconditioned Product
USDC SIP inspectors and licensed samplers will neither inspect nor certify products which have been reworked or reconditioned for subsequent delivery to other Federal agencies, i.e., Defense Personnel Support Center or U.S. Department of Agriculture, without first having written confirmation from the purchasing agency that reworking or reconditioning of the lot is acceptable. The fact that the lot is derived in whole or in part from reworked or reconditioned product shall be noted on the certificate, as well as specific reference to the letter/document received from the purchasing agency which authorized its use or inclusion.
- Equipment Checklist
For the accurate and efficient performance of product audits, each regional office shall have the appropriate and necessary equipment available to perform such audits. Equipment that is required is specific to each Standard or product evaluation, and could include the following:
- Appropriate inspection forms and score sheets
- Balance accurate to 0.01 gram
- Boilable bags
- Box cutter
- Can press
- Candling table/light
- Deep fryer with wire basket
- Digital camera
- Drill – high speed, ¼” bit
- Forceps with blunt points
- Magnifying glass with 6X or greater power
- Microwave oven
- Nut pick
- Nylon mesh bags (other materials may be used, as appropriate)
- Packing tape
- Paper towels
- Plastic or glass bowls, various sizes
- Plastic grid marked in ¼”, ½”, and 1” squares for measuring defects
- Roe tub opener
- Sanitary can opener
- Seam micrometer
- Seam nippers
- Shallow baking pan
- Sieves – U.S. No. 8 (8” and 12”), U.S. No. 20, and U.S. No. 4 (12”)
- Sink with cold water and stand pipe
- Spatula, 4” blade with rounded tip
- Stirring device capable of rotating paddle at 120 rpm
- Stop watch or timer, readable to the second
- Thermometer – dial or digital probe
- Thermometer – immersion type, accurate to ±2°F
- Two-vaned paddle, each vane measuring about 1” by 3”
- Vacuum gauge
- Water bath
- Wire whip
- 2-gallon container, about 9” diameter
- Accuracy Checks and Calibration of Equipment
All thermometers, scales, and balances shall be verified according to USDC SIP official accuracy check and calibration procedures, which include equipment calibration at least twice per year, or more frequently depending on storage and usage conditions. Accuracy check and calibration records shall be maintained on file at the local inspection office.
- Labeling Policies
- Label Review and Approval
- PUFI Policy
- Country of Origin Labeling
- Customs Labeling
- Declaration of Phosphates
- Date Labeling of Fresh Fish
- Retail Labeling of Fish Portions
- Scrod Labeling
- Metric Declaration of Quantity of Contents
- Specification Review and Approval Instructions
- New Product Specifications
- Generic Product Specifications
- Policy for Use of Official Marks and Advertising
- Procedures for Child Nutrition (CN) Label Approval
- Minimum Inspection Effort for Lot Inspection
- Sample Selection
- Use of Acceptance Numbers
- Subsample Size (Revised Sub-Sampling Policy for Container Size Group 3 (Table II) – 50 CFR 260.61 Sampling Plan)
- Container Integrity
- Label Review Procedures
- Net or Drained Weight Determination
- Glaze Determination of Frozen Product
- Fish Flesh Determination
- On-line Flesh Determination
- Procedures for Cooking Samples
- Determination of Ammonia in Dogfish
- Rounding Rules/Dropping and Retention of Numbers
The 50 CFR 260.61 Sampling Plans were created to balance the need for accurate results with the desire to minimize the costs associated with destructive sampling. The 50 CFR 260.61 Sampling Plans permit sub-sampling for Table II - Container Size Groups 4 (over 10 lbs but not over 100 lbs) and 5 (over 100 lbs), but currently do not allow sub-sampling for Table II - Container Size Groups 3 (over 4 lbs but not over 10 lbs).
During a review of the 50 CFR Part 260.61 Sampling Plans, it was determined that the USDC could decrease destructive sampling associated with Table II - Container Group Size 3 by allowing for sub-sampling without affecting the performance of the Sampling Plan. Effective September 22, 2011, it is now allowed to use 3 pound sub-sampling units from container sizes in Group 3 (over 4 lbs but not over 10 lbs) when using the 50 CFR Part 260.61 Sampling Plan Table II to perform product inspection, grading or other evaluations. All products subject to Container Size Group 3 may be sub-sampled per the instructions for Container Groups 4 and 5 which allows for a three-pound sub sample.
- Sample Selection
- Product (Lot) Inspection Procedures
- Whole and Dressed Fish (reference grade std)
- Frozen (block)
- Whole and Dressed Fish (reference grade std)
- Fish Fillets (reference grade std)
- Frozen (block)
- Fish Steaks and Portions (reference grade std)
- Canned/Pouched Tuna and Salmon (reference CID)
- Shrimp (reference grade std)
- Frozen Raw Breaded
- Determination of Count per Pound in Shrimp
- Shrimp Illustration
- Crustacean Shellfish
- Frozen Raw
- Molluscan Shellfish - Shucked
- Scallops (Raw) (reference grade std)
- Scallop Moisture Determination
- Frozen Breaded/Battered Fish (reference grade std)
- Simulated Seafood Products
- Live Products
- Crustacean Shellfish
- Molluscan Shellfish
- Harvester Tag
- Dealer Tag
- Miscellaneous Live Fish
- Dry Ingredients
- Reworked or Reconditioned Product
- Inspection of Endangered Species
- Lot Acceptance/Rejection
- Appeal Procedures
An application for an appeal inspection may be made by any interested party who disagrees with the results of an inspection as stated in an inspection certificate, if the lot of processed products can be positively identified by the inspection service as the lot from which officially drawn samples were previously inspected. Such application shall be made within thirty (30) days following the day on which the initial inspection was performed, unless an extension is approved by the Chief Quality Officer, SIP.
Application for an appeal inspection may be filed with: (1) the inspector who issued the inspection certificate on which the appeal is requested; or (2) the Regional Inspection Branch nearest the place where the processed product is located. The application for appeal inspection shall state 1) the location of the lot of processed products and 2) the reasons for the appeal, as well as 3) the date and serial number of the certificate covering inspection of the processed product on which the appeal is requested. The application may also be accompanied by a copy of the previous inspection certificate and any other information that may facilitate inspection. The application for appeal shall be made in writing.
An application for appeal inspection may be withdrawn by the applicant at any time before the appeal inspection is performed, but the applicant must pay for any time incurred by the inspector in connection with such application, any travel expenses, telephone, or other expenses which have been incurred by the inspection service in connection with such application.
Appeals are granted by the appropriate Regional Branch Chief. An application for an appeal inspection may be refused if it is determined that:
- The reasons for the appeal inspection are frivolous or not substantial;
- The quality or condition of the processed product has undergone a material change since the initial inspection;
- The lot in question is not, or cannot be made accessible for the selection of officially drawn samples;
- The lot relative to which the appeal inspection is requested cannot be positively identified by the inspector as the lot from which officially drawn samples were previously inspected; or
- There is a noncompliance with the regulations in this part. Such applicant shall be notified promptly of the reason for such refusal.
The Processed Under Federal Inspection (PUFI) Mark identifies fishery products processed under USDC inspection in an approved establishment, inspected for safety, wholesomeness and proper labeling, and conforms to quality and other criteria in an approved specification.
PUFI Statement using the company name:
U.S. DEPARTMENT OF COMMERCE
The PUFI Mark may be used for:
- retail packages,
- cases or shipping cartons,
- point-of-sale notices, and
- advertisements/promotional literature.
The use of the PUFI Mark requires that the:
- participant be under USDC contract agreement for in-plant inspection service,
- facility/vessel meets applicable USDC sanitation requirements,
- product specifications and labels be approved by USDC,
- products conform to USDC approved specifications,
- product meets principal display panel declarations,
- PUFI mark or statement be affixed to or next to certified PUFI products only, and
- product be processed and packaged under USDC approved inspection program.
The lot is accepted if the number of non-conforming units is less than or equal to the acceptance number for that sample size. Note: There is no acceptance number for decomposition. If the number of non-conforming units exceeds the acceptance number for that sample size, the lot is rendered nonconforming, or Grade Not Certified. The applicant shall be notified immediately in the case a lot is deemed nonconforming.
After the inspection, samples are returned, destroyed, or given to charity, based on the disposition instructions provided on the Request for Inspection Services form.
Certificates are issued according to the type of sampling and inspection performed, i.e., Lot Inspection Certificate, Export Health Certificate, Certificate of Origin, Certificate of Sampling, EU Certificate. All certificates must be filled out completely by the inspector performing the services or his/her designee, in ink, and include the inspector’s name and ID number, and date of service.
Certificates will attest to the inspection results of the MAQ attributes, grade attributes, or Buyer Specifications. If weights and counts were not requested as part of the lot inspection, a statement to the effect will be placed on the certificate, “Vendor weights and counts used, but not verified”. If, however, the inspector suspects short weights and/or counts, s/he is obligated to evaluate and report the results.
The Lot Inspection Certificate will be issued regardless of whether the product is accepted or deemed nonconforming, since it is an official record of the inspection findings. Lot Inspection Certificates shall be completed and distributed as described in the Instructions for Completing Lot Inspection Certificate, Chapter 7, Section 2.
An appeal inspection shall be performed by an inspector or inspectors (other than the initial inspector) authorized for this purpose by NMFS and, whenever practical, such appeal inspection shall be conducted jointly by two inspectors. However, the inspector who made the initial inspection may be authorized to draw the samples when another inspector or licensed sampler is not available in the area where the product is located.
After an appeal inspection has been completed, an inspection certificate shall be issued showing the results of the appeal inspection, and such certificate shall supersede the inspection certificate originally issued. Each superseding (appeal) inspection certificate shall clearly identify the number and date of the inspection certificate which it supersedes. The superseded certificate becomes null and void upon the issuance of the superseding (appeal) inspection certificate and shall no longer represent the quality or condition of the processed product described therein.
- Fees and Charges
The applicant is responsible for all fees and charges associated with the sampling and inspection of the product. In the event of an appeal inspection, if the applicant for both the initial and appeal inspections is the same and the results of the appeal inspection are in favor of the applicant, there will be no charge to the applicant for the appeal inspection. If, however, the results of the appeal are not in favor of the applicant, the applicant will be charged for the appeal inspection and all related travel expenses. The inspector will complete a Daily Record of Charges, which includes time spent sampling, inspecting, and completing certificates, as well as any travel expenses incurred. The Regional Inspection Branch will, under separate cover, charge the applicant for the associated fees and charges of the inspection and submit the bill to NOAA Finance, with NOAA Finance billing the applicant. The current fee schedule for inspection and analytical services can be found in Chapter One, Section 15a.
U.S. Department of Commerce/NOAA Fisheries • 1315 East West Highway • Silver Spring, MD 20910 • Phone (301) 427-8300 • Toll Free (800) 422-2750
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- To ensure the safety and quality as well as enhance the marketability and sustainability of seafood products for the benefit of the American consumer by providing science based inspection services to the seafood industry.