Food Safety Audit Report

FOOD SAFETY AUDIT REPORT

# SYS-B-195 Fresh Point Overton Distributors, Inc. 1100 6th Ave N Nashville, TN 37208-2649

By SUSAN P. DOOLEY Food Safety Auditor October 16, 2007

AIB International 1213 Bakers Way • PO Box 3999 • Manhattan, KS 66505-3999 (785-537-4750) • (800-633-5137) • Fax (785-537-0106) http://www.aibonline.org/ RATING

A food safety audit was conducted at this facility on October 16, 2007. The writer was accompanied throughout the audit by Mr. Marty Grove, Operation Manager.

Excellent cooperation was received by the writer, and on some occasions, the items were immediately corrected.

At the conclusion of the audit, a meeting was held to discuss the observations, recommendations, and rating.

Based on the observations made, the information obtained, and the criteria set forth in the AIB Consolidated Standards for Food Distribution Centers, the overall food safety level of this facility was considered to be:

SUPERIOR (920)

SYSCO HACCP VERIFICATION (135)

The “serious” or “unsatisfactory” items are shaded, boxed, and bolded in the text of the report. Refer to the definitions in the AIB Consolidated Standards.

The “improvement needed” items are designated in bold type and require prompt attention.

The AIB International states that the report as given herein is to be construed as its findings and recommendations as of the date of this report. The AIB International accepts no responsibility and does not assume any responsibility for the food safety program in effect with (customer). That further AIB International is only making report of the food safety conditions of (customer) as of the date of this report and assumes no responsibility or liability as to whether (customer) carries out the recommendations as contained in this report or does not carry out the recommendations as contained in this report.

#SYS-B-195-p.1 RATING ANALYSIS

DATE OF AUDIT: October 16, 2007

TYPE OF AUDIT: Unannounced

OVERALL RATING: SUPERIOR

ADEQUACY OF FOOD SAFETY PROGRAM 190

PEST CONTROL 180

OPERATIONAL METHODS AND PERSONNEL PRACTICES 175

MAINTENANCE FOR FOOD SAFETY 195

CLEANING PRACTICES 180

TOTAL: 920

#SYS-B-195-p.2 RATED ITEMS

UNSATISFACTORY ITEMS:

None

SERIOUS ITEMS:

None

IMPROVEMENT NEEDED ITEMS:

Item #39

#SYS-B-195-p.3 FACTUAL OBSERVATIONS AND SPECIFIC RECOMMENDATIONS

ADEQUACY OF FOOD SAFETY PROGRAM

.1A current organizational chart was maintained and dated April 20, 2006. The responsibility and authority for ensuring food safety and security, and the facility's compliance with federal, state, governmental, and/or any other appropriate regulatory laws or guidelines were clearly assigned to the General Manager/VP. This responsible person remains up to date on regulatory issues and has obtained the required regulatory food security registration. The food security registration information was available in the Security Guidance document dated April 4, 2007, (rev) and reviewed by the Auditor.

.2The department responsible for maintaining the distribution center’s food safety program had established written procedures outlining the specific responsibilities of each department manager and employee in an operations or procedure manual. The HACCP manual included a statement defining the company’s intention to meet its obligations to keep the products safe with appropriate signatures from the President, Executive Vice President and VP/General Manager of the Nashville Distribution Center, dated April 4, 2007. The auditor reviewed the job descriptions for the Distribution Manager, dated April 30, 2004, and Shipping Manager (HACCP Team Leader), dated February 6, 2007.

.3This facility had established a multidisciplinary food safety committee to conduct monthly inspections of the entire warehouse. Due to the size of the facility, facility managers rotated each month to a different area of the facility to inspect. A “Monthly GMP Self-Inspection Checklist” was used for identifying the GMP exceptions. Documentation of the monthly inspections included identified deficiencies, specific assignments, and actual accomplishments. Follow-up inspections were done to ensure that the items were corrected. Based on the facility review of the inspections conducted in June 28, 2007, and more previously, the inspections conducted on September 27, 2007, August 27, 2007, and July 7, 2007, with conditions noted on the inspections corrected. However, it was recommended that the facility inspections become more detailed in identifying and correcting potential food safety issues, such as the allergen storage practices discussed in the “operational practices section” and the cleaning of the tomato grading room discussed in the noted during the survey.

.4The facility appeared to maintain an adequate budget and support to maintain the proper and timely acquisition of appropriate tools, materials, equipment, monitoring devices, chemicals, and pest control materials.

#SYS-B-195-p.4 .5A Master Cleaning Schedule (MCS) for periodic cleaning assignments and a daily housekeeping schedule were developed as a formalized, written plan and implemented in this facility. This MCS specified frequency and responsibility. Postcleaning evaluations were conducted. The schedules were documented as current, and the conditions observed in the warehouse supported the documentation. The MCS consisted of weekly, monthly and “as needed” sanitation checklists. The calendar of events was reviewed from September, May and April 2007, as being completed. The schedules included the outside grounds, buildings, drains, and equipment. The schedule was reviewed periodically to ensure that it was still applicable. In addition, the supervisors conducted an end of shift check for area cleanliness with the shift report dated March 16, 2007, reviewed by the auditor.

.6Detailed, written cleaning procedures were developed and on file for most cleaning tasks in the facility relating to the cleaning of food storage equipment, the building and the exterior grounds. It was recommended that additional tasks of cleaning the walls and curbs in the tomato room be developed and rack cleaning procedures for the racks in the dry storage room.

.7All incoming material entering the facility was inspected for objectionable material according to a written procedure, “Receiving Dock Procedure”, dated March 24, 2006. This procedure included a visual inspection for pests, damage, cleanliness, and product integrity. A stamp is used to document the condition of the trailer on the Purchase Order, which is the receiving record. In addition, receiving records (logs) were maintained that included the date of receipt, carrier, quantity, and information to facilitate a recall. Seal numbers were recorded when applicable. The auditor reviewed the “daily receiving log” and “driver sign-in record”, dated October 16, 2007. Procedures dated March 16, 2007, for “Seafood Receiving” and a procedure dated February 2, 2007, for “Tomato Receiving” were followed by the facility. The auditor reviewed the receiving documentation and trailer inspection documentation for “apples” dated October 16, 2007.

.8A hazard analysis for all products being stored or shipped from the center had been conducted. Where fish and seafood products were being stored in the facility, a Hazard Analysis Critical Control Point (HACCP) program had been developed and implemented for all of these products. The program included the following components:

.a Description of the products manufactured and hazards inherent to them

.b Identification of critical control points (CCP) and critical limits

.c Procedures to control the CCPs

#SYS-B-195-p.5 .d Determination of the monitoring frequency for the CCPs and designation of the person(s) responsible for testing

.e Established and documented deviation procedures

.f Written verification program, with proper documentation

.g Documentation of procedures, records of conformance, and corrective actions

The facility identified one CCP in the operation as “product receiving temperature”. The HACCP Plan was last reviewed in February 15, 2007.

.9The company had established written employee guidelines and food safety policies. Specific written procedures were on file for providing food safety training to all personnel, including temporary personnel and contractors. Records of training completion for new employees and annual refresher training documentation were maintained for all personnel. The most recent employee training was conducted through the Safety meetings with various months reflecting some GMP/Food Safety Topics. Training for Food Security, HACCP and Food Safety training documents were reviewed from February 1, 2007. Additional training for cross- contamination, handwashing and sanitation were noted from July 10, July 10, and July 19, 2007. Microbiological training (E.coli) was conducted to truck drivers on May 21, 2007.

.10A formalized, written program for evaluating customer complaints, particularly those related to adulteration, was established at this location.

.11A written recall program, “Product Recall Procedure”, dated March 16, 2007, was on file and routinely reviewed. Contact names and phone numbers with regulatory phone numbers were on file and dated March 2007. Distribution records were maintained to identify the initial point of distribution to facilitate segregation and recall of specific lots. Test traces and mock recalls were conducted every six months with appropriate documentation maintained on file. The date of the last date of an actual recall was July 26, 2007, on a “Spring Mix” produce. The recalled product was 100% traced to customers and product that was maintained on hand.

.12Written procedures, “Returned Product Policy”, dated April 30, 2004, “Return Product QA Receiving” and “Product Hold”, dated March 16, 2007 were in place to control damaged or returned product. Records were kept of the corrective actions and disposition of the product and adjustments were made to the product inventory records to accurately account for the damaged or destroyed materials.

#SYS-B-195-p.6 .13A written policy on how to handle regulatory and third party inspections was on file. These procedures included the person(s) delegated to accompany all inspectors and company policies regarding photographs, records, and samples. Included in this area was a policy on “Media Response”, dated July 2007. The most recent regulatory inspection was conducted by the Tennessee Department of Agriculture on February 5, 2007. The facility score was 99%. The issue noted was corrected. .14A written policy, “Glass & Hard Plastics Policy And Clean-Up Procedures”, dated March 16, 2007, stating that no glass was to be used in the facility, except where absolutely necessary was in place. Included in the policy was a procedure to handle any glass breakage in the facility. A list of all essential glass had been developed and was audited during a monthly GMP inspection to ensure that any accidental breakage was found and addressed. The auditor reviewed the glass inspection conducted June 28, 2007. .15A preventive maintenance program and maintenance checklist system was contracted to an outside maintenance service company for maintaining and servicing structural, forklift equipment, or cooling maintenance problems that could cause food adulteration. The service included a quarterly PM/cleaning schedule. A program to ensure that the safety of the product was not jeopardized during maintenance operations was implemented at this facility.

PEST CONTROL

.16A formalized pest control program was established with written procedures outlining the requirements of the program to reduce the potential for product contamination from pest activity or use of materials and/or procedures designed to control pest activity.

.17Facility management contracted Terminix Pest Control Company to provide monthly pest control services. A copy of the service agreement dated February 13, 2007, that included materials to be used, methods, and precautions was maintained on file. Copies of the current liability insurance (expiration date January 1, 2009) and current applicator's license (expiration date December 31, 2007) were maintained on file.

.18Material Safety Data Sheets (MSDS) and sample labels were maintained on file for all pesticides applied on the premises. The rodenticide used on site was Generation Blue Max Miniblocks (EPA Reg. No. 7173-239).

.19A service report was left after each visit by the outside pest control service. These records included the treatments and tasks carried out, documentation of the checks and findings for the pest monitoring devices, descriptions of the current levels of pest activity, and recommendations for actions needed to correct conditions allowing a potential for pest activity.

#SYS-B-195-p.7 .20Documentation of all pesticides applied on the premises, including rodenticides, included materials applied, target organism, amount applied, specific area where pesticide was applied, method of application, rate of application or dosage, date and time treated, and applicator's signature. This documentation indicated that the applications were made in accordance with the label directions.

.21A schematic, dated March 14, 2007, depicting the locations of the interior and exterior pest control devices, including mechanical rodent traps, glue boards, pheromone lures, insect light traps, and bait stations, was maintained on file and appeared current.

.22Thirty-one mechanical mousetraps (Tin Cats) were installed to monitor for rodent activity inside the facility. These traps were properly positioned along walls and beside doors to the outside. The PCO checked the traps monthly and a designated facility person checked the traps the remainder of the month. The PCO recorded the information through the “Scan Master” database program and facility recorded the information on the “Pest Control Weekly In-House Checks” record. The interior traps were checked weekly up through September 24, 2007; however, week of October 7 and 14, 2007, had not been completed at the time of the inspection by the facility person. It was understood that a transition of responsibility was currently in the facility. The traps that had been serviced appeared properly maintained and a record was maintained of service and cleaning of each rodent control device though the “Scan- Master” program. A rodent activity log was used to record captures and help direct any necessary corrective actions. The traps randomly examined appeared properly maintained. The traps should be checked on a weekly basis to maintain an effective program in the event of a live catch.

.23Twenty bait stations for rodent control were installed around the exterior perimeter of the facility at appropriate intervals. These stations were tamper resistant, properly positioned, anchored in place, locked, and properly labeled in compliance with regulatory requirements. All stations were serviced at least monthly. Fresh bait had been supplied in the stations randomly examined. The service and results of the checks were documented on the “Scan-Master” database program and printout.

.24No pesticides or pesticide application equipment was observed to be stored on site at the time of the survey.

.25No evidence of insect, rodent, or bird activity was noted in or around the facility.

.26The internal rodent trap (Tin Cat) #14 in the Main Cooler was missing the site window, which made the tin cat inoperative.

OPERATIONAL METHODS AND PERSONNEL PRACTICES

#SYS-B-195-p.8 .27Damaged or soiled materials and any materials shipped in dirty or infested trailers or containers were rejected at the time of receipt.

.28Eighteen-inch perimeters were unable to be maintained in all produce storage areas to provide cleaning and inspection access. However, adequate space for cleaning was maintained between rows of stored products. A program for cleaning of the coolers was in place for cleaning floors beneath the racks and along the curbing of the floor/wall junctions.

.29Ice broccoli was observed in storage on floor level to prevent melted ice runoff from contaminating other products. Trays were observed in place for use when storing product in the upper sections of the bays within the storage rack.

.30Pallet racking was used to maintain storage conditions. Each pallet or case (of small quantity goods) of merchandise was identified with the appropriate information to ensure "first-in, first-out" rotation. Printed pallet tags (item number, PO & receiving date). Colors are designated by week to help with FIFO rotation of produce. The auditor reviewed the rotation practices of the following specialty products and main cooler:

.a Black plums – received 10/11/07; no additional product in storage

.b Watercress - received 10/15/07; no additional product in storage

.c Shredded Slaw Mix – Dated 10/23/07 on top of pallet; 10/25/07 on bottom of pallet

.d Whole onions – Dated 10/26/07 on top of pallet; 10/25/07 in middle of pallet; and, 10/29 in back of pallet

.e Chopped Romaine – Dated 10/21/07; only one pallet with this date

.31All perishable materials were stored at or below 40F (4C), and the frozen materials were at or below 0F (-18C). A graph and a digital read out program was in place in all coolers and freezers. The refrigerated and frozen storage areas were fitted with quick-opening doors to maintain proper temperatures. The temperatures of the coolers and storage rooms at the time of the inspection were as follows:

.a Room 1 was 65F at the time of the observation on the digital readout. The temperature control was set at 65F.

.b Room 2 was 52F at the time of the observation on the digital readout. The temperature control was set at 52F.

.c Room 3 was 52F at the time of the observation on the digital readout. The temperature control was set at 53F.

#SYS-B-195-p.9 .d Room 4 was 55F at the time of the observation on the digital readout. The temperature control was set at 54F. .e Main Cooler (4 zones) was 41F at the time of the observation on the digital readout. The temperature control was set at 37F. This cooler was in the defrost cycle.

.f Small Freezer #1 was –5F at the time of the observation .g Freezer #2 was –7F at the time of the observation. .32Toxic chemicals, including the cleaning solutions, maintenance compounds, and non-food-related materials, were completely segregated from all food ingredients and packaging materials. The cleaning materials were stored in a designated and locked caged area within the warehouse with limited key access. .33Protective measures were provided where iced-down product was observed to be stored over like or dissimilar products in order to keep the melting ice runoff from contaminating the product below. The iced-down vegetable produce that was in storage was palletized and on the floor level within the storage racks. .34Rubbish and waste materials were properly stored outside the facility in a suitable compactor/dumpster, which was emptied as necessary. The area was generally well maintained and free of excessive spillage. It was observed the dumpster in use at the time of the facility perimeter walk. The dumpster is emptied on a daily basis. .35Damaged goods were removed to an identified recoup area in the main cooler for repacking or eventual disposal. Damaged items were removed for suitable disposal weekly or as needed. Repacked materials were identified so as to maintain traceability. .36The washrooms were maintained in an acceptable sanitary condition. The lockers were inspected monthly as a sanitary control, and no open food or drink was allowed. “Wash Hands” signs were displayed in the rest rooms, lunchroom, and smoking areas. .37Shipping vehicles were inspected prior to loading for cleanliness and structural defects that could jeopardize product integrity. Temperatures of precooled vehicles to transport refrigerated or frozen product were checked prior to loading. The auditor verified a trailer pre-cooling prior to loading on the dock. At the time of the observation, the temperature on the delivery truck was 47F. Issues that were found were documented with the outside lease service.

.38All employees observed during the survey appeared to be practicing good personal hygiene habits. Eating, drinking, and smoking were restricted to designated areas.

#SYS-B-195-p.10 .39Three boxes of sunflower seeds that had an “allergen sticker” on each box were observed being stored in the ‘specialty storage cooler’ with the boxes of dried mangos located on the second shelf of one of the storage shelves along the wall. It was recommended that the allergen containing products be stored on the bottom shelf to prevent potential allergen contamination issues from occurring while product is in storage. It was further suggested that employee training be conducted with those individuals responsible for receiving this product. (IMPROVEMENT NEEDED)

.40The auditor verified the proper MSDS sheet on file for the “HDQ-C2” a cleaner, disinfectant, deodorizer for use in cleaning the Rubbermaid containers for shipping of iced, cased fish to the designated location. The containers are cleaned and dried after each use and sanitized with Hepacide Quat II following the procedure, dated March 16, 2007. The plastic pallet used to store the ice seafood products in the cooler prior to transporting was also cleaned and sanitized after each use.

MAINTENANCE FOR FOOD SAFETY

.41The site was maintained and located so as to prevent contamination and enable the storage of safe and legal products. Site security strategies included locked doors, surveillance cameras, truck seals, employee screening, truck driver security check, and employee awareness training.

.42The exterior grounds were maintained in a manner that prevented pest harborage. Litter and waste were not evident and weed growth was controlled.

.43The building was appropriate in size and layout to facilitate the maintenance and sanitary operation for food storage. It was mentioned that the facility lease was up in 2008 and would be relocating.

.44Potable water was supplied from the Metro Water Department of Davidson County. The facility had a program was in place to test the water quality using an outside laboratory every six months. The date of the last such testing was September 7, 2007. No know contaminants were noted, coliform and E.coli, were negative.

.45The floors, walls, and ceilings throughout the plant were of sound construction and well maintained. No roof leakage was evident.

#SYS-B-195-p.11 .46Adequate lighting was provided in all areas, and the light bulbs, fixtures, mirrors, skylights, or other glass suspended over the general stock storage and exposed product areas were of the safety type or otherwise protected to prevent accidental breakage. All lighting observed during the audit was protected with plastic sleeves and protective end caps.

.47The physical building was maintained to provide necessary barriers for effective protection against rodent, birds, and insects. Close fitting external doors were noted and doors appeared to be well maintained at the time of the survey.

.48Continuous recording thermometers or indicating thermometers were used in all rooms or areas where perishable or frozen foods were stored or handled. Documentation of the temperatures, whether through continuous temperature monitoring systems or manual checks, was maintained and was readily available. This documentation was maintained on the “Weekly room Temperature Checklist”, and manual temperature verifications were conducted twice per day (AM/PM).

.49A calibration program for “Cooler Temperature Verification Procedure, dated March 16, 2007, and “Thermometer Calibration”, dated March 16, 2007, was in place for all regulating and recording controls. The facility had a program in place for calibration of recording thermometers used upon loading of product on pre-cooled trailers. These thermometers were calibrated on a daily basis. The thermometer calibrations were documented and records were maintained. Scale calibrations were contacted through a service company.

.50Some minor rust development was noted in Tomato Room Cooler #4 on the overhead ceiling adjacent to the cooling unit. This area should be cleaned and maintained to prevent any potential contamination issues.

.51The roof of the facility was not inspected due to restricted access.

CLEANING PRACTICES

.52Adequate cleaning equipment and tools were available and stored away from the warehouse storage areas.

.53The overhead areas were cleaned frequently enough to prevent insects or filth from contaminating the food products in storage.

.54The dock levelers were cleaned regularly to prevent excessive soil and litter accumulations.

#SYS-B-195-p.12 .55Most pallet racks and storage shelves were cleaned frequently enough to remove spillage and dirt buildups and prevent pest development. However, the channel cross-bars in the storage racks in the dry good storage area were dusty and dirty as the cross-bars were in a channel-shape and were accumulating debris. It was suggested to turn the cross-bars over to prevent a collection point if all possible, or, increase the frequency of cleaning to maintain the racks in sanitary condition and prevent the attraction for pests and/or activity.

.56The floor areas were cleaned on a regular schedule to eliminate food residues and maintain a good cosmetic appearance.

.57The facility grounds were well maintained and free of miscellaneous trash and debris.

.58The trash compactor area was maintained in an acceptable sanitary condition.

.59Minor tomato product residues were noted along the walls and along the curbing in the tomato grading room. Minor webbing was noted in the south corner ceiling/wall junction. It was recommended that the walls and curbing be cleaned and the MSC reviewed for increased frequency of cleaning activities in the room.

.60Heavy dust buildup was noted on each of the fan guards in the three ceiling cooling units. The heaviest dust accumulation was noted on the fan guards closest to the roll-up entrance door. The fan guards should be cleaned and placed on the MCS at a designated frequency so that the fans covers are better maintained.

.61The floor area and floor/wall junctions beneath the vending machines in the employee break room were dirty with stains, dust, debris and papers. The floor vending machines should be cleaned on a periodic basis to prevent pest attraction. This activity should be placed on the MSC.

.62The driver check-in booth locked cage was observed with several dead insects and moths on the shelves and the floor area was dusty and dirty. It was recommended that the drivers clean this area periodically as it was adjacent to the shipping dock area.

.63All cooler and storage rooms were inspected, including outside grounds.

#SYS-B-195-p.13 SYSCO HACCP VERIFICATION CHECKLIST

SECTION I

HACCP MANUAL REVIEW (Contents)

 HACCP manual is present (Yes/No): Yes If no, explain:

 HACCP team list is current and in manual (Yes/No): Yes List 3 members by name and title: Marty Grove, Operations Manager; Neal Bennett, QA Manager; Jeff Hall, General Manager If no, state the name(s) of the team members that are not current:

 HACCP Coordinator is identified (Yes/No): Yes Name of HACCP Coordinator: David Smith HACCP Coordinator training certificate is on file. Date: July 25 & 26, 2006

 HACCP Annual Reassessment Form is in manual and signed. (Yes/No) Date: Yes, February 15, 2007

 HACCP Annual Reassessment Approval Form is in manual and signed. (Yes/No) Date: Yes, February 19, 2007

 Overview of facility is in manual. (Yes/No): Yes Does it include: SYSCO Foodservice (Yes/No): Yes Location (Yes/No): Yes Statement of seafood products handled (Yes/No): Yes

#SYS-B-195-p.14  One-paragraph descriptions of prerequisite programs are in manual and include: GMP’s (Yes/No): Yes SSOP’s (Yes/No): Yes Pest Control (Yes/No): Yes Chemical Control (Yes/No): Yes Recall/Traceability (Yes/No): Yes Customer Complaints (Yes/No): Yes

 Flowchart of facility is in manual. Diagram depicts actual operation of Receiving, Put Away, Storage, Order Selection, and Loading. (Yes/No): Yes

 Blank NUOCA (Notice of Unusual Occurrence and Corrective Action) in manual. (Yes/No): Yes

Non-Compliance Summary for Section I:

#SYS-B-195-p.15 SECTION II

PRODUCT REVIEW

HS0001 ALL FROZEN SEAFOOD OTHER THAN RAW MOLLUSCAN SHELLFISH

Item Number: Not Available Description: Cooked Baby Shrimp Frozen, 5 lb. Hazard Analysis (Yes/No) If no, explain: HACCP Plan Form is not required. Yes

Non-Compliance Summary:

REFRIGERATED, READY TO EAT SEAFOOD PRODUCTS (including Seafood Salads, Soups, Pasteurized Crab Meat, Pasteurized Lobster, and Surimi Based Products) (HS0004, HS0005)

Item Number: Product Description: HS Code Number: Hazard Analysis (Yes/No) If no, explain: HACCP Plan Form (Yes/No) If no, explain: Receiving CCP; TTR – requires printout to CL: Product must not be exposed to be attached to P.O. temperatures over 40F for a cumulative time of more that 4 hours or over 70F for more than 1 hour or cooling media present must e in sufficient amount to maintain product temperature of 40F. Records: Printout of TTR attached to P.O. OR confirmation of adequate cooling media OR temperature and transport time recorded on P.O. Verification: Review monitoring (P.O.), corrective action (NUOCA) and verification records within one week of preparation. TTR document must be signed and dated indicating verification by HACCP trained individual. Storage CCP temperature: CL: Product must not be exposed to temperatures over 40F or must have adequate cooling media. (Records and verification are discussed in section III)

#SYS-B-195-p.16 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number

REQUIREMENTS Receiving CCP (List “cooling media – (Yes/No)”, OR RECORD Actual “Temperature and Transport Time” * documented on P.O., OR “TTR- (Yes/No)” indicating confirmation of TTR and Proper Handling) Printout from TTR attached to PO (Yes/No/N/A) TTR is signed and dated indicating verification within one week. (Yes/No/N/A) List Date: Receiving Signature (Yes/No) Receiving Date: (List date) Verification Signature on P.O. and different from person monitoring CCP (Yes/No) Verification Date: (List date) NUOCA Required (Yes/No) NUOCA Date: (List date if required)

*Note: If TTR or adequate cooling media is not used as the receiving monitoring point, the facility must have a document attached to the PO that indicates transportation time from the supplier to the DC is less than 4 hours and the temperature at receipt must be at or below 40F as documented on the P.O.

#SYS-B-195-p.17 HSOO17 RAW OR LIVE OYSTERS, CLAMS, MUSSELS

Item Number: No item number available Product Description: Blue Hill Bay Mussels 10 lb. Bag Hazard Analysis (Yes/No) If no, explain: Yes HACCP Plan Form (Yes/No) If no, explain: Yes Receiving CCP (TTR –requires printout to be CL: Product must not be exposed to attached to P.O. OR temperature F OR temperatures over 45F for a cumulative confirm adequate ice): time of more that 4 hours or over 70F for more than 1 hour. Records: Printout of TTR attached to P.O. OR confirmation of adequate cooling media OR temperature and transport time recorded on P.O. Verification: Review monitoring, corrective action and verification records within one week of preparation. Receiving CCP’s; photo copy shell stock tags CL: All shell stock must be properly or master tag (REQUIRED): tagged and from a licensed dealer. Records: Receiving P.O. to include photocopy of tags or master tag (master tag is any document tat includes the required information from the tag for the shipment) Verification: Confirm validity of dealers license by review of a current accurate listing of certified deals at least monthly. Storage CCP Temperature CL: Product must not be exposed to temperatures above 45F. (Records and verification are discussed in section III)

#SYS-B-195-p.18 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number Not Available Not Available Not Available

REQUIREMENTS Receiving CCP (List “cooling media – (Yes/No)”, OR Record Actual “Temperature and Transport Time”* documented on P.O., OR “TTR- (Yes/No)” indicating confirmation of TTR and Proper Handling) Yes, TTR Yes, TTR Yes, TTR Printout from TTR attached to PO (Yes/No/N/A) Yes Yes Yes TTR is signed and dated indicating verification within one week. (Yes/No/N/A) List Date: Yes, 9/24/07 Yes, 8/22/07 Yes, 7/25/07 Receiving CCP Master tag or photocopies of case tags are attached to P.O. (Yes/No) Yes Yes Yes Receiving Signature (Yes/No) Yes Yes Yes Receiving Date: (List date) 9/22/07 8/21/07 7/25/07 Verification Signature on P.O is within one week and different from person monitoring CCP (Yes/No) Yes, on bill of lading Yes, on bill of lading Yes, on bill of lading Verification Date: (List date)9/24/07 8/22/07 7/25/07 NUOCA Required (Yes/No) No No No NUOCA Date: (List date if required) N/A N/A N/A

Non-Compliance Summary:

#SYS-B-195-p.19 HS0018 and HS0020 REFRIGERATED RAW FIN FISH IN VACUUM PACKAGING, MAP OR CAP (Raw non-Scombroid species and raw Scombroid species)

Item Number: Product Description: HS Code Number: Hazard Analysis (Yes/No) If no, explain: HACCP Plan Form (Yes/No) If no, explain: Receiving CCP: CL: A Time/Temperature Integrator must be on each packaging and the color of the TTI must not indicate temperature abuse. Records: P.O. to include documentation of visual observation of TTI. Verification: Review monitoring, corrective action and verification records within one week of preparation. Storage CCP’s include (list temperature F): Product must not be exposed to temperatures above 38F. (Records and verification are discussed in section III)

#SYS-B-195-p.20 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number

REQUIREMENTS Receiving CCP(s) (TTI CONFIRMATION) (Yes/No) Receiving Signature (Yes/No) Receiving Date: (List date) Verification Signature on P.O is within one week and is different from person monitoring CCP (Yes/No) Verification Date: (List date) NUOCA Required (Yes/No) NUOCA Date: (List date if required) Non-Compliance Summary:

HS0022, HS0023, HS0024, HS0025 REFRIGERATED, PARTIALLY COOKED AND UNCOOKED SEAFOOD PRODUCTS

Item Number: Product Description: HS Code Number: Hazard Analysis (Yes/No) If no, explain: HACCP Plan Form (Yes/No) If no, explain: Receiving CCP’s; Temperature OR Ice: CL: The product surface temperature must not exceed 40F. Records: Receiving P.O. worksheet to include product temperature of confirmation of ice or cooking media sufficient to surround the product. Verification: Review monitoring, corrective action and verification records within one week of preparation. Storage CCP temperature: CL: Product must not be exposed to temperatures above 40F. (Records and verification are discussed in section III)

#SYS-B-195-p.21 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number

REQUIREMENTS Receiving CCP temperature or adequate cooling media. (List actual temperature documented on PO or “cooling media – yes”) Receiving Signature (Yes/No) Receiving Date: (List date) Verification Signature on P.O. and different from person monitoring CCP (Yes/No) Verification Date: (List date) NUOCA Required (Yes/No) NUOCA Date: (List date if required)

Non-Compliance Summary:

#SYS-B-195-p.22 HS0029 FROZEN RAW MOLLUSCAN SHELLFISH (oysters, mussels and clams)

Item Number: Product Description: Hazard Analysis (Yes/No) If no, explain: HACCP Plan Form (Yes/No) If no, explain: Receiving CCP CL: All frozen raw molluscan shellfish must possess a valid certification number and a lot identification on each case. Records: Receiving P.O. worksheet to include verification of valid certification number and lot identification. Verification: Review monitoring, corrective action and verification records within one week of preparation. Current ICSS list available on site (Yes/No) List of current certified vendor (or ICSS list) available to receiving personnel (Yes/No):

#SYS-B-195-p.23 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number

REQUIREMENTS Receiving CCP: Valid certification number confirmed on P.O. (Yes/No) Lot Numbers(s) Documented on P.O. (Yes/No) Receiving Signature (Yes/No) Receiving Date: (List date) Verification Signature on P.O is within one week and different from person monitoring CCP (Yes/No) Verification Date: (List date) NUOCA Required (Yes/No) NUOCA Date: (List date if required)

Non-Compliance Summary:

HS0037 REFRIGERATED RAW FIN FISH (Raw, non-Scromboid species fish other than vacuum-packed, MAP, and CAP)

Item Number: Product Description: Hazard Analysis (Yes/No): If no, explain: No HACCP Plan Form Product is intended to be fully cooked prior to consumption.

Non-Compliance Summary:

#SYS-B-195-p.24 HS0040 RAW (FRESH) SHUCKED SHELLFISH (oysters, clams, mussels partially or completely out of the shell)

Item Number: Not Available Product Description: Melpeque Oysters, 100 ct. Hazard Analysis (Yes/No) If no, explain: Yes HACCP Plan Form (Yes/No) If no, explain: Yes Receiving CCP CL: Product must not be exposed to temperatures over 45F for a cumulative time of more that 4 hours or over 70F for more than 1 hour or cooling media present must be in sufficient amount to maintain product temperature of 45F. Records: Printout of TTR attached to P.O. OR confirmation of adequate cooling media OR temperature and transport time recorded on P.O. Verification: Review monitoring, corrective action and verification records within one week of preparation. Receiving CCP: CL: All shucked shellfish must be properly labeled and from a licensed dealer. Records: Receiving P.O. worksheet to include shuck date/use by date, confirmation of valid certification number, date of receipt, quantity and type of shellfish, and name of vendor. Verification: Confirm validity of dealers’ license by review of a current accurate listing of certified deals at least monthly. Storage CCP temperature CL: The product must not be exposed to temperatures above 45F. (Records and verification are discussed in section III) Current ICSS list available on site (Yes/No)

List of current certified vendor (or ICSS list) available to receiving personnel (Yes/No):

#SYS-B-195-p.25 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number Not Available Not Available Not Available

REQUIREMENTS Receiving CCP: (List “cooling media – (Yes/No)”, OR Record Actual “Temperature and Transport Time” * documented on the P.O., OR “TTR- (Yes/No)” indicating confirmation of TTR and Proper Handling) Yes, TTR Yes, TTR Yes, TTR Printout from TTR attached to PO (Yes/No/N/A) Yes Yes Yes TTR is signed and dated indicating verification within one week. (Yes/No/N/A) List Date: Yes, 9/13/07 Yes, 8/15/07 Yes, 7/25/07 Receiving CCP Valid certification number confirmed on P.O. (Yes/No) Yes Yes Yes Name of Vendor Documented: (Yes/No) Yes Yes Yes Quantity Documented: (Yes/No) Yes Yes Yes Type of Shellfish Documented: (Yes/No) Yes Yes Yes Shuck Date OR Use by Date Documented. (List Date) 9/9/07 8/9; 8/12, 2007 7/20; 7/22, 2007 Receiving Signature (Yes/No) Yes Yes Receiving Date: (List date) 9/9/07 8/15/07 7/25/07

#SYS-B-195-p.26 Verification Signature on P.O is within one week and different from person monitoring CCP (Yes/No) Yes Yes Yes Verification Date: (List date)9/13/07 8/15/07 7/25/07 NUOCA Required (Yes/No) No No No NUOCA Date: (List date if required) N/A N/A N/A

Non-Compliance Summary:

REFRIGERATED RAW FIN FISH (Fish that have fins) (HS0057)

Item Number: Not Available Product Description: Mahi Mahi Fillet 12 lb. Hazard Analysis (Yes/No): If no, explain: Yes HACCP Plan Form (Yes/No) If no, explain: Yes Receiving CCP CL: Product must not be exposed to temperatures over 40F for a cumulative time of more that 4 hours or over 70F for more than 1 hour or cooling media present must be in sufficient amount to maintain product temperature of 40F. Records: Printout of TTR attached to P.O. OR confirmation of adequate cooling media OR temperature and transport time recorded on P.O. Verification: Review monitoring, corrective action and verification records within one week of preparation. Storage CCP: CL: Product must not be exposed to temperatures over 40F or must have adequate cooling media. (Records and verification are discussed in section III)

#SYS-B-195-p.27 Select three dates within the 30, 60 and 90 days to verify:

Purchase Order Number Not Available Not Available Not Available

REQUIREMENTS Receiving CCP (List “cooling media – (Yes/No)”, OR Record Actual “Temperature and Transport Time” * documented on P.O, OR “TTR- (Yes/No)” indicating confirmation of TTR and Proper Handling) Yes, TTR Yes, TTR Yes, TTR Printout from TTR attached to PO (Yes/No or N/A) Yes Yes Yes TTR is signed and dated indicating verification within one week. (Yes/No/ or N/A) List Date: Yes, 9/13/07 Yes, 8/15/07 Yes, 7/23/07 Receiving Signature (Yes/No) Yes Yes Yes Receiving Date: (List date) 9/11/07 8/15/07 7/18/07 Verification Signature on P.O is within one week and is different from person monitoring CCP (Yes/No) Yes, on bill of lading Yes, on bill of lading Yes, on bill of lading Verification Date: (List date)9/13/07 8/15/07 7/23/07 NUOCA Required (Yes/No) No No No NUOCA Date: (List date if required) N/A N/A N/A

Non-Compliance Summary:

#SYS-B-195-p.28 SECTION III - VERIFICATION

Verification activities for thermometers and receiving CCPs

 Dial thermometers are used for taking the seafood HACCP temperatures. (Yes/No) (If no, skip to the next bullet point): No Calibration frequency of dial thermometers. List frequency: (Daily is required per plan.) Records are signed and dated by person doing the calibration. (Yes/No): Records are signed and dated by person doing the verification. (Yes/No) List dates reviewed:

 “Other” thermometers (RF temperature devices, continuous computer monitoring, recording charts) are used for taking the seafood HACCP temperatures. (Yes/No): Yes Calibration frequency of temperature devices. List frequency: (Weekly is required per plan.) Weekly No records to review. Verification records include temperature of known Weekly calibrations accurate thermometer and reading from were missing for continuous monitoring and/or indicating storage weeks of 5/26; 6/2; thermometer. (Yes/No): 6/9; 6/16; 6/23; and 6/30/07. No additional calibrations were available for review from 7/14/07 to 10/16/07. Records are signed and dated by person doing the calibration. (Yes/No): No records to review. Records are signed and dated by person doing the verification. (Yes/No) List dates reviewed: No records to review.

#SYS-B-195-p.29  Storage temperatures (except frozen) are continuously monitored with a signed and documented visual check at least five Yes times per week. (Yes/No): Storage CCP temperature records verification is conducted. (Yes/No): Yes Verification of monitoring and corrective action Yes, however, week of records occurs within 1 week. (Yes/No) If no, 9/10/07 verification explain: was completed on 9/24/07 Records are signed and dated by person doing Yes, 9/24/07; 9/10/07; verification. (Yes/No) List dates reviewed: 9/6/07; 8/16/07, and 8/17/07. Certificate for NIST certified thermometer is current. (Yes/No) List expiration date: No. Expired 7/26/07

 Certification for Temptale 4 from Sensitech is on file for Op Co.s using TTR on HS0004, HS0005, HS0017, HS0040, and HS0057 products (Yes/No): Yes  Shellfish shipper numbers are verified monthly against the ICSS list. (REQUIRED for Plans HS0017 and HS0040) Documentation is present. Yes (Yes/No):

NUOCA Forms for Storage Temperatures and Verification

 NUOCA forms were required. (Yes/No): No NUOCA forms were on file (required for control limits exceeded, missing information). (Yes/No): N/A Date(s) of NUOCA: N/A Reason(s): N/A NUOCA forms were required and not on file. (Yes/No) If yes, explain: N/A

#SYS-B-195-p.30 Employee Interview

 Interview one employee who has direct responsibility for collection of HACCP data: First name and title of individual interviewed: Neal, QA Manager HACCP responsibility: Checking and monitoring temperatures at receiving and storage of product Appears to understand food safety Neal has been with the components of HACCP. (i.e. critical company 17 years and is very limits, corrective action if limits are knowledgeable of the HACCP exceeded, etc.) (Yes/No) If no, explain: program and food safety concepts.

Non-Compliance Summary for Section III:

Inconsistent weekly thermometer calibrations were completed in last three months (July-Oct), therefore, overall calibration records were incomplete in this category. The storage CCP temperature verification of monitoring for week of September 10, 2007 was verified on September 24, 2007, which was past the one-week requirement. And, the NIST thermometer had expired on July 26, 2007.

NON RATED QUESTION FOR INFORMATION ONLY:

Auditor: Review all NUOCA forms completed since the last AIB HACCP verification and verify that documented corrective actions match the plans. List dates reviewed and any discrepancies.

Dates Reviewed: None for review

Discrepancies with Plan? (Yes/No) If yes, explain:

#SYS-B-195-p.31 Rating Guidance for HACCP - VERIFICATION:

Rating of HACCP Verification:

SECTION I

For each missing element subtract 5 points from 200 down to a minimum rating of 175.

Exceptions:  HACCP manual could not be located - Unsatisfactory  No HACCP Coordinator identified - Unsatisfactory  No supporting evidence that HACCP Coordinator has been trained or has been scheduled for training - Unsatisfactory

Section I Rating: 200

SECTION II

Each purchase order is to be considered as a single element for purposes of rating. Any missing information or deficiencies from one to multiple omissions on a single purchase order results in a rating of 155 (SERIOUS).

If one or two purchase orders have any missing information or deficiencies, the score is still rated as 155 (SERIOUS).

If three or more purchase orders are missing information or deficiencies, rate as 135 (Unsatisfactory).

Section II Rating: 200

SECTION III

Each question is considered as a separate element. One or two missing or deficient elements are rated as 155 (SERIOUS).

Three or more missing or deficient elements are rated as 135 (UNSATISFACTORY)

Section III Rating: 135

OVERALL HACCP VERIFICATION RATING: 135 (overall rating is the lowest of the three scores)

#SYS-B-195-p.32