ASSURANCE and OPERATING POLICY MANUAL for the BLUE CRAB INDUSTRY Written By George J. Flick Thomas E. Rippen Geoffrey M. Knobl Cameron R. Hackney William H. Robinson Virginia Polytechnic Institute and State University Virginia Sea Grant Program Robert E. Croonenberghs Robert J. Wittman B. Keith Skiles Virginia Department of Health Division of Shellfish Sanitation Alpha A. Diallo Virginia Department of General Services of Consolidated Laboratory Services Stephen H. McNamara Brian J. Donato Mary Beth Neraas kAilC)NkL Sk GRANlOEPOSIT@V PELL LIBRARY BUILDING URl~R~Y&‘US Hyman, Phelps & McNamara,P.C. Washington, DC. Irvine, California January, 1994 Virginia Sea Grant Publication VSG-93-10 K- ;s CONTENTS Organizational Chart 1 Product Descriptions 2 Floor Plan 3 Process Flow Chart - Control Points/Critical Control Points 4 Employee Education Programs 5 Unit Processing Operations Policies 6 Special Thermal Processing Operation - Pasteurization/Listericidals 7 Hazard Analysis Critical Control Point (HACCP) Plan 8 Cleaning and Sanitation Programs 9 Cleaning and Sanitation Verification Protocol 10 Forms 11 Pest Control Program 12 Product Recall Plan 13 Consumer Complaint File 14 Control of Hazardous Energy Source (Lockout/Tagout)s 15 Written Hazard Communication Program 16 A Brief Guide to Recordkeeping Requirements for Occupational Injuries and Illnesses 17 The FDA Inspection 18 Federal Rules and Regulations for Good Manufacturing Practices 19 Virginia Department of Health Rules and Regulations 20 Federal Enforcement Actions 21 Virginia Marine Resources Commission Rules and Regulations 22 Append ix - HACCP Plan Overview/How to Develop a HACCP Plan 23 For any Future Chapters 24-31 PLEASE TAKE NOTE: The section on HACCP is only a guide for assisting you in developing your own tailored plan. It is not meant to be used for preparing a HACCP plan for submission to a state or federal food regulatory agency. Foreword This manual is designed to guide blue crab processors in the efficient operation of their firms and in the sanitary production of crab meat. Preparing and implementing an operational plan that complies with state and federal food regulations is the first best step toward the production of wholesome, high quality crab meat free from disease-causing microorganisms. Since no two processing facilities are identical, it is impossible to provide a manual to satisfy the specific requirements of all firms’operations. Some chapters of the manual deal with critical matters, however, and provide information uniform to all companies. Chapter 20, for example, contains statutory requirements of the Virginia Department of Health. The Virginia Department of Labor and Industry statutory requirements are covered in Chapters 15, 16, and 17. Chapter 22 deals with those of the Virginia Marine Resources Commission, the U.S. Food and Drug Administration’s statutes are covered in Chapter 19, and statutes governing thermal processing procedures are dealt with in Chapter 7. None of the foregoing chapters should be changed for a firm’s application without the assistance of a qualified individual. Chapters 18 and 21 contain legal information that should be useful to your business. All the other chapters (l-6 and 8-14) may and should be tailored to an individual firm’s needs. In addition, Chapters 4, 6, 8, and 9 have been assigned a lettering system as an easy means for identifying all operating policies for a specific unit operation. The authors realize that it may be difficult for some firms to develop a personal plan without some initial technical assistance. Please do not hesitate to contact us if you have any questions or comments concerning this manual or if you require assistance in modifying the information to meet your firm’s requirements. In addition, the following agencies have indicated a willingness to make arrangements to provide personal assistance to any firm requesting it: Virginia Polytechnic Institute and State University Sea Grant Program Food Science and Technology Department, Blacksburg (703) 231-6965 Virginia Seafood Research and Extension Center, Hampton (804) 727-4861 Virginia Department of Health, Richmond Division of Shellfish Sanitation (804) 786-7937 Virginia Department of General Services, Richmond Division of Consolidated Laboratory Services (804) 786-0592 This manual was published in a ring notebook format to facilitate the adding, modifying, or deleting of information as an individual firm’s needs dictate. The authors’ occasional updates will be made available to those manual owners whose names they have recorded, and those updates may be added easily to the manual. The funds used to produce and distribute this manual were provided through a special Virginia General Assembly appropriation, without which financial assistance this project would not have been possible. Acknowledgments The authors thank Mr. Weston Conley, Jr., RCV Seafood Corporation; Mr. Charles Chase, Rappahannock Oyster Company, Inc.; and Mr. John Graham, Jr., Graham and Rollins Crab Company, Inc. for their assistance in preparing this manual. Thanks are also extended to Dr. Dale Fredell, Ecolab Research Center, for his technical advice in developing the cleaning and sanitation programs. Special thanks are extended to Ms. Diane Mahaffey and Sarah Moore for typing the manuscript and to Ms. Mary Holliman and Lynn Davis for their editorial assistance. This work was sponsored by the Office of Sea Grant, NOAA, U.S. Department of Commerce, under Grant No. NA90AA-D-SGO45 to the Virginia Graduate Marine Science Consortium and the Virginia Sea Grant Program. The U.S. Government is authorized to produce and distribute reprints for governmental purposes, notwithstanding any copyright that may appear hereon. Virginia Tech does not discriminate against employees, students, or applicants on the basis of race, sex, handicap, age, veteran status, national origin religion, or political affiliation. Anyone having questions concerning discrimination should contact the Employment/Affirmative Action Office. Dear Manual Recipient: The authors hope this manual is useful to you and your firm’s personnel. It is obvious that no one publication can be written that applies to all blue crab processing firms. Consequently, any suggestions you have toward improving the publication would be appreciated. These could include: addition of new forms, modifications of existing test, addition of new materials (including new chapters), or improved methods of information presentation. Please call or send your comments to the following: 1. Science and Technology Comments George J. Flick Geoffrey M. Knobl Cameron R. Hackney Food Science and Technology Department Virginia Tech Blacksburg, VA 2406l-0418 Phone (703) 231-6965 FAX (703) 231-9293 Robert E. Croonenberghs Robert J. Wittman B. Keith Skiles Division of Shellfish Sanitation Virginia Department of Health Commonwealth of Virginia 1500 E. Main Street Richmond, VA 23219 Phone (804) 786-7937 FAX (804) 786-5567 Alpha A. Diallo Division of Consolidated Laboratory Services Virginia Department of General Services 1 North 14th Street Richmond, VA 23219 Phone (804) 786-0592 FAX (804) 371-0666 2 Legal Comments Stephen H. McNamara, Esq. Mary Beth Nerass, Esq. Hyman, Phelps & McNamera, P.C. 700 Thirteenth Street, N.W. Washington, DC 20005 Phone (202) 737-5600 FAX (202) 737-9329 Brian J. Donato, Esq. Hyman, Phelps & McNamera, P.C. 2603 Main Street Suite 1066 Irving, CA 92714 Phone (714) 553-7400 FAX (714) 553-7433 Any cooperation you provide in making this manual more useful to the industry will be greatly appreciated. NOTE: Chapters 4 , 6, 8, and 9 of the manual have been given corresponding alphabet designations. This uniform lettering system will enable manual users to easily identify all operating policies for a specific unit operation. Examplle - For Illustrative Purposes Only Example Blue Crab Company 1. Organizational Chart President President and/or owner of Example Blue Crab Company. He or she reviews the overall operational plan with the Production, Quality Assurance, and Sales Managers. Production Manager Reports to the President. Responsible for day-to-day operations of the facility. Responsible for directing production and for any new processes or procedures for the facility. Reviews the operational plan with President, Quality Assurance Manager, and Sales Manager. Responsible for purchasing all of the raw packaging and labeling materials. Quality Assurance Manager Reports to President.Responsible for carrying out the HACCP, training, and quality assurance plans, together with any changes related to the plans. Responsible for handling customer complaints and initiating recalls. Oversees the Quality Assurance Technicians and production personnel who perform all of the duties specified in the HACCP and quality assurance plans. Reviews HACCP, quality assurance, and training plans with the President, Production Manager, and Sales Manager. Production Supervisor Reports to the Production Manager. Oversees daily production in the facility. Works closely with the Production Manager to supervise the process of turning raw material into finished products. Decides the production schedule for the day. Responsible for overseeing all personnel in the production and refrigerated storage areas. Sanitation Manager Reports to the Production Manager.Oversees the daily cleanup and sanitation of the facility. Coordinates implementation and verification of HACCP, quality assurance, and training plans with Quality Assurance Manager. l-l Example - For Illustrative