A number of dealers ship via a common carrier truck. The truck would make several stops to pick up oysters from different dealers. Each time it would be A3 product that has not been cooled to 50 F. How is the time/temperature recording device requirement handled?
My thought is that either each dealer would have to place a time/temperature recording device with their own shipment or they could all get together and arrange with the truck owner to have a single time/temperature recording device in the refrigerated cooler throughout the process. So the truck starts off with a time/temperature recording device and just keeps it in there the whole time. Actually I'm thinking that the truck could be equipped with a device that produces a continuous recording chart then each receiving dealer could look at the chart. Unless we would require that they keep the chart as a record. Hopefully we would allow them to just say in their record that they looked at the chart and it indicated continuous cooling. Of course it's probably not going to be continuous cooling because every time they open the truck door up the temperature will go up some. But that's going to be a reality regardless. I say it's not continuous cooling if the temperature ever goes up when the door opens we're going to have to say one truck can't carry more than one shipment because the only way that's not going to happen is if they never open the door once the first shipment is placed in and the door is closed.
REFERENCE: Chapter IX.05, Chapters XI, XIII, & XIV – Receiving CCP
Based on NSSP MO Chapter XIII.01.D(2) the dealer could either opt for a single recording device or the truck’s as long as it has “continuing cooling.” Rises in temperatures as the door is opened are common in shellstock storage but the overall “continuing cooling” should be demonstrated and can be demonstrated with a single or joint use time temperature recording device. It’s an overall “continuing cooling.” Either approach can be used as long as every dealer can be provided with the recording device information that meets NSSP MO Chapter XIII.01.A.
Should NSSP Guide Chapter X.08.A(2) include:
It could but it would require a proposal to the ISSC to add. Currently it is required as a Transportation Document under NSSP MO Chapter IX.05.
Is a shipping document required when a Reshipper goes to a certified dealer to pick up shellstock that is below 50 degrees internal temperature, and then deliver that product directly to his retail customers? If so, who is considered the shipping dealer, the original certified dealer supplying the product to the reshipper, or the reshipper supplying the product to his retail customers?
REFERENCE: Chapters XI, XIII, & XIV – Receiving CCP
NSSP MO Chapter X.08.A.(1) Each shellfish shipment shall be accompanied by a shipping document. Chapter IX.05. also requires a transportation record.
Under NSSP-MO Chapter IX.05, the dealer who sells the product to the reshipper must provide this transportation record and the selling dealer must verify in a transportation record that the truck he puts the product in (even if he doesn’t own it) meets NSSP-MO Chapter IX.05.
Must firms address the temperature of shellfish at shipping on the transportation record?
REFERENCE: Chapters XI, XIII, & XIV – Storage CCP
The temperature of shellfish is not required, but the temperature of the conveyance must be below 45°F prior to shipment.The requirement for Chapter IX.05 deals only with the conveyance.
NSSP MO Chapter IX.05 requires all shipment of SHELLSTOCK be accompanied with documentation indicating time of shipment and conveyances compliance to Chapter IX.04 which is shellstock adequately iced, or in a conveyance prechilled at or below 45F ambient air.
NSSP MO Chapter XIII.D.(2) requires SHELLSTOCK be cooled to meet Chapter XIII.B.(3) or meet Chapter XIII.B.(4) prior to shipment but does not require it on the transportation record unless the Transportation record is also used as a HACCP record to meet the Shellstock Shipping CCP.
Does stamping or pre-printing invoices with the following text: “Truck pre-chilled to 45o, shellfish 50o or colder”, or, “Truck is pre-chilled to 45 o or cooler” meet the new time temperature transportation record requirements?
REFERENCE: Chapter IX.05
NO, per NSSP MO Chapter IX.04 the document must reflect that the presence of ice or that the temperature of the conveyance was observed. A check mark next to a pre-printed statement would be allowed but an observation must be made and indicated. Stamping would suggest that an observation has occurred. A preprinted invoice would not. In addition, the time of shipment must be added as required per NSSP MO Chapter IX.05
Regarding calculation of Maximum Temps.
VIII@.02 Shellstock Time to Temperature Controls “C. The Authority shall establish the water or air temperature to be applied to the requirements above for each growing area by averaging the previous five (5) years maximum monthly water or air temperatures”
Does this mean take the Monthly Maximum temperature (1 measurement per month) then average for 5 years OR take the daily maximum temps for each month and average over 5 years (i.e. ~30 measurements per month per year)?
In Rhode Island the way that this is calculated could result in either 6 months >80degrees or only 2 months. Under the first method of calculation April would exceed the limits even though the average daily maximum temp is only 60.6 and the average daily mean temp is 51.
Send for further review
I don't know where to point to in the Model Ordinance to show that A3 product has to be placed under refrigeration within any particular time frame. The A3 matrix doesn't say anything about refrigeration. The time limits are "Maximum Hours from Exposure to Receipt at a Dealer's Facility." 2009 Model Ordinance IX.02C.(2) required that a dealer place shellstock under refrigeration within 2 hours of receiving them but when the all the changes were made to Chapter IX they deleted that and, as far as I can tell, didn't replace it with anything. The "2 hours at points of transfer thing" only applies "once shellstock have been placed under refrigeration. So do you have something I can point to?
You are correct, there is not a requirement that a dealer receiving Shellstock from a harvester that was harvested under Chapter VIII.@.02.A.(3) place shellstock under refrigeration within 2 hours of receiving. Chapter XIII.03.F.(6) requires the following:
All shellstock obtained from a licensed harvester shall be
To achieve compliance with Chapter VIII.@.02.A.(1) and (2), the records of a dealer receiving Shellstock from a harvester must reflect that the Shellstock was iced or placed in refrigeration within the time period established in state vibrio plans.To achieve compliance with Chapter VIII.@.02.A.(3), the records of a dealer receiving shellstock from a harvester must indicate that the shellstock was received at the facility within the time periods outlined in Chapter VIII.@.02.A.(3). The refrigeration requirement for shellstock intended for shucking, that is not harvested under a state vibrio plan, can be found in Chapter XI.03.F.(11).Refrigeration is required unless the dealer begins shucking within two hours.For shellstock not intended for shucking, the refrigeration requirements for the dealer can be found in Chapter XIII.03.F.(6). If a dealer is not processing the shellstock, they must immediately ice the shellstock or place the shellstock in refrigeration. If the dealer is processing the shellstock, the processing must be completed within two hours.
Is the requirement to record the temperature of the truck a firm is using to transport their shellfish, that it has to be included in the HACCP plan and is a HACCP record? It is my understanding that this is not a HACCP critical limit and does not have to be included in the plan. But the record still has to be kept and available for review.
REFERENCE: Chapters IX.05
The shipping dealer has to include the information in Chap IX 04 and 05 for each shipment. It is not considered a HACCP record for the shipping dealer. The information is considered a HACCP record for the receiving dealer and the information must be included in the HACCP plan and maintained as a HACCP record as outlined in NSSP MO Chapter XIII.A.(2).
Is the shipping documentation required for surf clams or ocean quahogs that are going to be further processed? Chapter VIII @02 G. exempts ocean quahogs and surf clams from temperature control plans when intended for thermal processing but I do not see an exemption from the transportation documentation. J.H. Miles is questioning MD requiring their MD entity to provide this documentation. All processes are not necessarily thermal, frozen breaded clam strips and frozen raw clams, but none of this product is eaten raw.
Chapter VIII @02 (G.) exempts ocean quahogs and surf clams from the requirement of complying with State Vv, Vp, and the (A.)(3.) max hours from exposure to receipt at a dealer's facility only. It does not exempt them from the Chapter IX 05. Transportation Records requirement , which states "All shipments of shellstock shall be accompanied with documentation indicating the time of shipment and that all shipping conveyances comply with the requirements of Chapter IX. 04. This documentation must include a notice of all shellstock harvested under the requirements of Chapter VIII.@.02 A. (3) that has not been cooled to an internal temperature of 50°F (10°C) and indicate the presence of a time/temperature recording device.". If they wish to be exempt from IX 05., it would require a proposal submission to change the MO.
In the Guidance document, it states:
"To comply with the time to temperature requirements for shellstock intended for Wet Storage, Depuration, Post Harvest Processing (PHP), or “For Shucking Only by a Certified Dealer”, the dealer must comply with one of the options below:
The dealer must shuck or introduce into Wet Storage or Depuration, within the applicable time to temperature controls of Chapter VIII. @.02 A (3) and Chapter XIII .03; or
The dealer must place the shellstock in temperature control within the applicable time to temperature controls of Chapter VIII. @.02 A (3) and Chapter XIII .03.
Ocean Quahogs (Arctica islandia) and Surf Clams (Spisula solidissima) are excluded from the time to temperature controls of State Vibrio Control Plans or the matrix outlined in Chapter VIII. @.02 A. (1) (2) and (3). This exclusion applies only when these products are intended for thermal processing. Authorities may exclude other species when intended for thermal processing.
However, there is still not an exemption from transportation documentation required under IX.05.
When a firm supplies a TTR with each shipment do they have to also manually document the time of shipment and the temperature of the truck, which will be on the TTR when read at the end destination? I am requiring in MD that the temperature of the shellstock be included on the shipping documentation but firms that are either voluntarily/or customer mandated supplying the TTR want to know if that meets the other 2 shipping documentation requirements. The shipping documentation would read "TTR included in shipment, temperature of shellstock__________."
IX.05 specifically states that the transportation record include the time of shipment, a statement that the shipment complies with IX.04, and for VIII.@02.(A.)(3.) not cooled to 50F a statement stating such, and indicate the presence of a TTR. In the example provided, "TTR included in shipment, temperature of shellstock__________, time of shipment__________, a statement that the conveyance is iced/mechanical refrigeration less than/equal to 45F, and a VIII@02.(A.)(3.) statement if necessary" must be included to meet the requirements of IX.05.
Dealers in other States are requiring that the shipping documentation be signed by the shipping dealer. One of my dealers almost had a load rejected for this reason. I would appreciate that the ISSC reiterate that shipping documentation is not a HACCP record for the shipping dealer and does not require a signature.
The transportation documentation required in IX.05 is not a HACCP record for the shipping dealer, only the receiving dealer, and as such, does not require the shipping dealers signature.
Finally, some dealers are refusing to provide the shipping documentation because they drop the product off at transfer station for shipment by a common carrier. Dealers concerns are that they cannot document this information because they are not present when the product is shipped. The receiving dealer is then in violation of his HACCP plan since no documentation is provided. I am not sure how the ISSC wants to address this since the shipping firm may never know the exact time of shipping or be able to document the truck temp or shellstock temp at shipping. It is unlikely that any shipping firm will do this. Even when our firms provide this info on the Bill of Lading the carrier does not always provide it at delivery.
The shipping dealer is required to provide the receiving dealer with a transportation document. IX.05 states that it must accompany the shipment but this does not preclude the shipping dealer from also providing the information via fax or scanned/emailed to the receiving dealer. In this specific example, a prudent shipping dealer would include a TTR so that the receiving dealer had evidence that continuous cooling had occurred during shipment or that the shipment was maintained at 45F or below for the entire shipment time allowing them to meet the CLs at the receiving CCP. If a dealer is relinquishing control of the product, they must find a way to meet the requirement. Receiving dealers should reject the product if paperwork is not present.