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Smoked & Ready-to-Eat Seafood HACCP Checklist

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Verify hazard analysis and critical control points for smoked and ready-to-eat fishery products, focusing on Clostridium botulinum and Listeria monocytogenes control through brining, smoking, and post-process handling.

21 CFR 123FDA Fish and Fishery Products Hazards Guide21 CFR 123.6FDA Compliance Policy Guide 540.650

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Hazard Analysis & Plan

  • Does the HACCP plan address Clostridium botulinum toxin formation and Listeria monocytogenes as significant hazards for the smoked product? *
  • Are histamine (scombrotoxin) and environmental pathogen contamination evaluated where applicable to the species? *
  • Is the product's water-phase salt or water activity target defined to control C. botulinum? *

Brining & Salt Uptake

  • Is brine concentration, time, and temperature controlled and monitored to achieve the target water-phase salt level? *
  • Is finished-product water-phase salt (or water activity) verified by testing at the required frequency? *
  • Record the target minimum water-phase salt for the product (%). *

Smoking & Thermal Process

  • Are smokehouse temperature and time monitored as critical limits (heating step for hot-smoked; salt/aw for cold-smoked)? *
  • Are recording thermometers or data loggers used and calibrated for the smoking process? *
  • Are cooling and refrigeration controlled to prevent toxin formation after the heat step? *

Post-Process Listeria Control

  • Is an environmental monitoring program in place to detect Listeria on food-contact and non-food-contact surfaces in the post-lethality area? *
  • Are corrective actions defined for critical-limit deviations and for positive Listeria findings? *
  • Are HACCP monitoring, verification, and corrective-action records maintained and reviewed? *

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