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NSSP 2007 Section IV Chapter III .04 Shellstock Tagging
Section IV. Guidance Documents
Chapter III. Harvesting, Handling, Processing, Distribution
.04 Shellstock Tagging
Shellstock tagging has a very direct role in public
health protection. In the event of a shellfish related illness, tags
are a tool, which, used in concert with records, should provide for
trace ability of live shellstock from the final consumer back through
every middle man, (retailer, wholesaler, carrier, and dealer) who
handled the product, to a specific growing area, harvest date, and
ultimately, if possible, the individual person who harvested the shellstock.
When an outbreak of disease attributable to shellfish
occurs, health departments and other appropriate state and federal
agencies must be able to determine the source of shellfish
contamination to prevent any further outbreaks from this source. This
can be done most effectively by using the records kept by the
shellfish harvesters and dealers to trace a shellfish shipment,
through all the various dealers who have handled it, back to its
point of origin. Shellstock tags are the first important records
concerning the origin of shellfish.
Harvesters must provide information necessary to
create a record of the origin, quantity, and date of harvest, which
can be used to trace a lot of questionable shellstock back to its
source or sources. Investigation of disease outbreaks can be severely
hindered if the source of the shellfish cannot be readily identified.
Inability to identify the source can result in shellstock from the
unacceptable source continuing to be used and continuing to cause
illness. Health authorities may be forced to close a safe growing
area, to ban a safe shellstock shipment or to seize a safe lot of
shellstock as a public health precaution if the source of
contaminated shellfish cannot be accurately and rapidly determined.
Maintaining adequate records is considered by some
industry members to be a burden. This has resulted in various
unacceptable practices being encountered by health officials,
including no written records of purchase, undated shellstock shippers
tags maintained in an unordered manner, new shipping tags being
placed on a lot of shellstock without records to correlate the
original identity of the lot with the new identity, and shellfish on
the premises with no tags. Although these dealers often have
"records" in the most general sense, these records are not
in the form that meets the intent of the NSSP certification
requirement to provide trace ability on a lot-by-lot basis. As a
result, follow-up investigations of disease outbreaks have been
stymied, identification of the cause of the outbreak has been
delayed, and outbreaks have continued. For more information
concerning dealer certification, see the NSSP Guidance Document:
Chapter III. 03: Dealer Certification and the Interstate Certified
Shellfish Shippers List.
An example where the failure to maintain adequate
records was identified as one of the principal contributing factors
to a series of continuing shellfish associated disease outbreaks
occurred in 1981 and 1982. The outbreaks continued for several months
and affected thousands of people. An investigation by the states
involved and FDA revealed that some states were unable to enforce the
record keeping and tagging requirements of the NSSP. FDA found in one
state that approximately one-third of the certified dealers inspected
failed to maintain adequate records. State officials realized that an
improved tagging, labeling or manifest system was needed to track
shellfish in the marketplace back to the distributor and to the harvester.
When a lot of shellstock is sold in bulk (e.g. by the
truckload without being placed in containers), the harvester or
dealer must provide a transaction record prior to shipment. If the
transaction record is generated by the harvester, the record must
contain information identical to that required on the harvester’s
tags and must also include the name of the consignee. If the
transaction record is generated by the dealer, the record must
contain information identical to that required on dealer’s tags
and must include the name of the consignee.
The NSSP recognizes two types of shellstock tags:
harvester tags and dealer tags. Many of the requirements are the same
for both tag types. There are some additional requirements for dealer
tags when the product has been wet stored or depurated. Transaction
records which provide the same information as the harvester’s or
dealer’s tag may be used in lieu of tags for lot of shellstock
sale and lot of shellstock shipment.
Shellstock harvest location needs to be consistently
defined on all tags. The tags should provide the most precise
identification of the harvest location or aquaculture site as is
practicable; this identification must include at least the state
(initials) in which the shellstock were harvested in the designated
growing area within the state as assigned by the Authority of the
producer state. If harvest areas have not been indexed by the
Authority, then an appropriate geographical or administrative
designation must be used (e.g. Long Bay, Decadent County, lease
number, bed or lot number).
Each harvester or aquaculturist and each dealer must
affix an approved, durable, waterproof tag, containing all the
information required by the NSSP Model Ordinance, to each container
of shellstock. Minimal required tag size is 2 5/8 by 5 1/4 inches
(6.7 by 13.3 cm). Example tags are provided in Attachment 1. The
harvester's tags must be in place while the shellstock is being
transported to the dealer unless the harvest has occurred at more
than one harvest location or aquaculture site; then each container
must be tagged at the harvest location or aquaculture site. In
certain situations, the truck may be considered the container for
transport of bulk loads of shellstock from the growing area to the
dealer. For dealers, tagging must be done prior to shipment. When the
dealer is also the harvester, the dealer's tag may also be used as
the harvester's tag.
HARVESTER TAG REQUIREMENTS
Information on the harvester's tags must be legible,
indelible and arranged in the following specific order:
-
A place may be provided where the dealer's name,
address and certification number as assigned by the Authority may be added;
-
The harvester's identification number as assigned by
the Authority;
-
The date of harvesting;
-
The most precise identification of the harvest
location or aquaculture site as is practicable; this identification
must include at least the state (initials) in which the shellfish
were harvested and the designated growing area with that state as
assigned by the Authority of the producer state. If growing areas
have not been indexed by the Authority, then an appropriate
geographical or administrative designation must be used (e.g. Long
Bay, Decadent County, lease number, bed or lot number);
-
Type and quantity of shellfish;
-
The following statement, in bold capitalized type on
each bag: "THIS TAG IS REQUIRED TO BE ATTACHED UNTIL CONTAINER
IS EMPTY OR RETAGGED AND THEREAFTER KEPT ON FILE FOR 90 DAYS." and
-
All shellstock intended for raw consumption shall
include a consumer advisory and follow the Time-Temperature Matrix
Control. The following statement, from section 3-603.11 of the 2001
Food Code, or an equivalent statement shall be included on all
shellstock: “RETAILERS, INFORM YOUR CUSTOMERS”
“Consuming raw or undercooked meats, poultry, seafood, shellfish
or eggs may increase your risk of food borne illness, especially if
you have certain medical conditions”
DEALER TAG REQUIREMENTS
Dealer tagging is required upon harvest or receipt
from a harvester, processing and packaging of shellstock by the
dealer, or sale and shipment of shellstock by the dealer to other
dealers for subsequent sale, processing or additional packaging. The
information on the dealer’s tags must be legible, indelible and
arranged in the following specific order:
-
The dealer's name, address, and certification number
as assigned by the Authority;
-
The original shellstock shipper's certification number;
-
The date of harvesting;
-
The most precise identification of the harvest
location or aquaculture site as is practicable; this identification
must include at least the state (initials) in which the shellfish
were harvested and the designated growing area with that state as
assigned by the Authority of the producer state. If growing areas
have not been indexed by the Authority, then an appropriate
geographical or administrative designation must be used (e.g. Long
Bay, Decadent County, lease number, bed or lot number);
-
Type and quantity of shellstock;
-
The following statement, in bold capitalized type,
that “THIS TAG IS REQUIRED TO BE ATTACHED UNTIL CONTAINER IS
EMPTY AND THEREAFTER KEPT ON FILE FOR 90 DAYS." and
-
All shellstock intended for raw consumption shall
include a consumer advisory and follow the Time-Temperature Matrix
Control. The following statement, from section 3-603.11 of the 2001
Food Code, or an equivalent statement shall be included on all
shellstock: “RETAILERS, INFORM YOUR CUSTOMERS”
“Consuming raw or undercooked meats, poultry, seafood, shellfish
or eggs may increase your risk of food borne illness, especially if
you have certain medical conditions.”
When both the dealer and harvester tags appear on the
container, the dealer tag is not required to list the date of
harvesting, and the harvest location or the aquaculture site. A
harvester's tag must be in place while the shellstock is being
transported to a dealer. The dealer must keep the harvester’s
tag in place until the container of shellstock is shipped or until it
is broken open for washing, grading and packing. Once the container
is broken open, the dealer must:
-
keep the harvester tag for 90 days;
-
keep track of the growing area and date of harvest of
all shellstock; and
-
maintain the lot identity of all shellstock in an
intermediate stage.
Except for shellstock that originated from a
depuration-processor, shellstock transported across state lines and
placed in wet storage must include the following information on its
shipping tag after removal from wet storage:
-
All information required on a dealer’s tag as
specified above; and
-
The statement that “THIS PRODUCT IS A PRODUCT OF
(NAME OF STATE) AND WAS WET STORED AT (FACILITY CERTIFICATION NUMBER)
FROM (DATE) TO (DATE)”
Lot of shellstock tagging in the washing, packing and
staging of shellstock is permissible only when the lot container
(i.e., the pallet) is tagged as required in a protocol approved by
the Authority. The protocol shall provide for lots of shellstock to
be separated and identified to prevent commingling or
misidentification. The tag on each lot of shellstock shall contain
the following minimum information:
ALL SHELLFISH CONTAINERS IN THIS LOT HAVE THE SAME
DATE AND AREA OF HARVEST.
Harvest Date__________________________________________
Harvest Area__________________________________________
Original Dealer/Shipper #_________________________________
# of units in this lot container_______________________________
The dealer's tag must be put on all containers of
shellstock before they are shipped to another dealer or retailer.
Prior to shipment, all containers of shellstock must remain easily
identified and continue to be separated to prevent commingling or
misidentification. The protocol approved by the Authority shall
provide for lots of shellstock to be separated and identified so as
to prevent commingling or misidentification. The allowable means of
identification are:
-
A harvester’s tag containing the information
required above on harvester’s tags;
-
A dealer's tag containing the information required
above on dealers tags; and
-
A lot of shellstock tag designed in the manner
required above for lot tags.
TAG REQUIREMENTS FOR RELAYING
In relay operations, the method of shellstock
identification (tagging, bulk load records, etc.) is left to the
discretion of the Authority. When the relay process is conducted
using containers, a need exists to develop a container identification
system to locate and avoid removal of containers before the natural
cleansing process is complete. Once the relay operation is complete,
the shellstock is subject to the tagging requirements for harvesters
and dealers.
DEPURATION TAG REQUIREMENTS
Shellstock that has been subjected to depuration
requires an increased level of control because of the increased
potential for contamination. These controls must include packaging
and tagging that will serve to help identify the depuration cycle of
each harvest lot and to deter illegal commingling of shellstock which
has not been depurated with depurated shellstock. The Authority may
require the harvester to use special tags or to provide additional
information on the tags. At a minimum, the harvester’s tags (or
transaction records used for bulk shipments) must identify the
growing area, provide the harvester’s special license number,
and specify the harvest date and the quantity of shellstock.
The dealer’s (i.e. the depuration processor) tags
must, at a minimum, include the following information in a legible
and indelible form:
-
The dealer’s name and address;
-
The dealer’s certification number as assigned by
the Authority;
-
The date of depuration processing;
-
The depuration cycle number or lot number;
-
The most precise identification of the harvest
location as is practicable including the initials of the state of
harvest, and the Authority’s designation of the growing area by
indexing, administrative or geographic designation. If growing areas
have not been indexed by the Authority, then an appropriate
geographical or administrative designation must be used (e.g. Long
Bay, Decadent County, lease number, bed or lot number);
-
The type and quantity of shellstock;
-
The statement, in bold capitalized type, that
"THIS TAG IS REQUIRED TO BE ATTACHED UNTIL CONTAINER IS EMPTY
AND THEREAFTER KEPT ON FILE FOR 90 DAYS." and
-
All shellstock intended for raw consumption shall
include a consumer advisory and follow the Time-Temperature Matrix
Control. The following statement, from section 3-603.11 of the 2001
Food Code, or an equivalent statement shall be included on all
shellstock: “RETAILERS, INFORM YOUR CUSTOMERS”
“Consuming raw or undercooked meats, poultry, seafood, shellfish
or eggs may increase your risk of food borne illness, especially if
you have certain medical conditions.”
Attachment 1
In the event of a shellfish related illness, tags are
a tool, which, used in concert with records, should provide for trace
ability of live shellstock from the final consumer back through every
middle man, (retailer, wholesaler, carrier, and dealer) who handled
the product, to a specific growing area, harvest date, and
ultimately, if possible, the individual person who harvested the shellstock.
The following options are recommended for inclusion on
tags to improve the effectiveness of the NSSP tagging program.
-
Include the statement "Perishable; keep
refrigerated" on the tag in bold print.
-
Include the "Date Shipped" on the tag.
-
Maintain flexibility in the tagging program to take
advantage of evolving materials and technology (e.g. UPC coding)
Tag Construction: Durable, waterproof and a minimum
size of 2 5/8 inches by 5 1 / 4 inches (6.7 cm by 13.3 cm)
While both of the previous examples contain the
minimum required information in the required order, many firms also
customize the tags with additional information. Such information
might include space for the consignee’s address, date shipped,
reshipper certification number, date reshipped, and a
“Perishable- Keep Refrigerated” statement. Some firms also
opt to preprint the types of shellfish with a check-off space. When
customizing the tag, the order of the minimum required information
cannot be changed.
When shellstock is transported interstate and placed
in wet storage, special tagging requirements must be met. See the
NSSP Model Ordinance for details. This tag is an example of a dealer
tag modified for labeling product transported across State lines and
subsequently wet stored.
Tags are available through various sources. In some
states, the Authority sells the tags which are sequentially numbered
for accountability. There are also grower’s associations which
bulk purchase tags for their members at considerable savings.
Individual dealers can also have tags printed at local print shops.
Tyvek is one example of a durable waterproof material
commonly used for shellstock tags.
Some states require additional information on tags
which exceeds the NSSP requirements. A dealer should verify the
receiving state’s requirements prior to shipment to that state.
Note: The above excerpts are not the full US FDA
regulations regarding harvest regulations of shellfish. For more
information please visit US
Food and Drug Administration Website |
