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Issue Number: Council I 023
Title
Issue you would like the Conference to consider
Modification of the 2009 FDA Food Code to add language that addresses the use of shellstock being simultaneously used from different sources or growing areas. The facility's record-keeping system must be able to distinguish the shellstock that was served to each customer.
Public Health Significance
The Interstate Shellfish Sanitation Conference (ISSC) continues to address illnesses associated with consumption of raw molluscan shellfish. Our primary focus is to improve our response time associated with illness outbreaks and to evaluate the effectiveness of control programs associated with pathogens which may result in illnesses.
These activities utilize illness investigation information from retail establishments. In recent years there has been improvement and the suggested change is intended to further improve the ability of illness investigators to accurately identify shellstock sources and growing areas. The ISSC and the Conference for Food Protection (CFP) have jointly worked to enhance record keeping at the retail level. In an effort to provide more accurate information which could be used for illness response and program evaluation, the need for this improvement was demonstrated in recent illness data reported by the Centers for Disease Control (CDC).
Recommended Solution: The Conference recommends...
1. that a letter be sent to the FDA requesting the 2009 Food Code (as modified by the Supplement issued in 2011) be amended as follows (new language underlined and deleted language shown with strikethrough):
Section 3-203.12, Shellstock, Maintaining Identification
(C) The identity of the source of shellstock that are sold or served shall be maintained by retaining shellstock tags or labels for 90 calendar days from the date that is recorded on the tag or label, as specified under ¶ B of this section, by: Pf
(1) Using an approved record keeping system that keeps the tags or labels in chronological order correlated to the date that is recorded on the tag or label, as specified under ¶ B of this section; Pf and
(2) If shellstock are being used from different sources or growing areas simultaneously that the system can distinguish the source and growing area of the shellstock that was served to each customer; Pf and
(23) If shellstock are removed from its tagged or labeled container
and
2. that the Conference for Food Protection (CFP) and the Interstate Shellfish Sanitation Conference (ISSC) jointly write a letter to State retail food programs requesting that retailers be advised of shellstock identification record requirements for the purpose of improving compliance.