DOAG: Shellfish Handling

Shellfish Handling

Only those Connecticut shellfish dealers appearing under Connecticut in the FDA Interstate Certified Shellfish Shippers List ("List") are licensed by DA/BA to wholesale or harvest shellfish for market. These CT shellfish dealers, including market harvesters, operate in conformance with the National Shellfish Sanitation Program Model Ordinance (NSSP-MO). They must be trained in HACCP (Hazard Analysis and Critical Control Points) principles and develop a HACCP plan for their operations. They are routinely inspected for compliance by the DA/BA. Market shellfish are those shellfish - oysters, clams, mussels or scallops (when sold or offered whole or roe on) harvested from areas classified as Approved or Conditionally Approved-Open or depurated at a licensed depuration plant and sold for direct consumption. Market shellfish licenses include Shellstock Shipper (SS), Shucker-Packer (SP), Repacker (RP), Reshipper (RS) and Depuration (DP).

All market shellfish must be handled and shipped by individuals or firms appearing on the "List" under the appropriate state and nation. Individuals who purchase shellfish in another state, transport them back to Connecticut and sell the product to various restaurants and other outlets must be licensed by DA/BA and appear on the FDA "List". The DA/BA investigates proper shellfish handling, shipping and record keeping practices of its licensees. Shellfish in the shell must be properly identified by a shipping tag identifying the licensed dealer, the harvesting area and the harvesting date. Containers of shucked shellfish, minced, chopped or repacked, fresh or frozen must have labels that identify the licensed packer or repacker and state or origin. Containers of less than 0.5 gallons must also display a "sell by" date. Containers of 0.5 gallons or greater capacity must include a "shucked date." The retail sale of shellfish from a local fish market, restaurant, grocery store or booth at a fair to the final consumer is not considered a wholesale sale and would not require a DA/BA license, however, these operations are under the jurisdiction of the local Director of Health and may require a local license. Local health inspectors should periodically check invoices when routinely checking shellfish shipping tags to determine that all shippers and dealers wholesaling shellfish to retail outlets are on the FDA "List". Shellfish shipped from a dealer or transported by a dealer (unless common carrier) not on the "List" must be considered suspect. Local officials should embargo or remove from sale suspect product until verification can be provided that the product was obtained from "Approved" shellfishing areas and properly handled and shipped by licensed or certified dealers, before releasing the product for sale. Dealers no longer on the "List" may not have been inspected in sufficient time to meet the printing deadline or may not be licensed pending correction of sanitary conditions. The local officials may discuss the situation with the dealer or shipper of concern, but should obtain verification only from the state officials responsible for licensing such activities. The state licensing officials appear in the back pages of the FDA "List." Telephoning these officials from the facility being investigated usually results in a prompt response and can resolve the situation. Any additional questions can be directed to this office at (203) 874-0696.

Product shipping and handling criteria mandated by FDA/ISSC require that the product be maintained at 45 degrees Fahrenheit (7.2 degrees Celsius) or less and kept separated from other products that because of dripping or leakage could contaminate the shellfish. Deliveries must be prompt. The delivered product should be placed into appropriate refrigerated units. Product should not be left outside a merchant's door. If the delivered product is left outside the merchant's door it will be considered suspect until verification can be provided that the proper product temperature was maintained and no tampering or contamination occurred.

Shipments of shellfish originating out-of-state, whether delivered to or picked up by a Connecticut wholesaler or retailer may only be obtained from dealers on the "List" for that state. Out-of-state vendors working in Connecticut or Connecticut shellfish harvesters involved in roadside vending operations must have an appropriate license from their state and be included in the "List." They must conform to local requirements in the town where they intend to sell their products. Since these sales usually represent retail distribution, the responsibility for investigating these operations for compliance with food safety, sanitation and conformance with local laws and ordinances rests with local health officials. Investigating these operations is an important responsibility for ensuring public health protection, especially with those operations selling shellfish that will be consumed raw or partially cooked. Direct handling of the product should be minimized since hand-washing facilities usually are not available. Cross contamination could result from handling other seafood products or from unsanitary practices.

Proper handling procedures must extend to fairs, picnics and similar gatherings. The product must originate from approved sources, be maintained at 45 degrees Fahrenheit (7.2 degrees Celsius) or less for fresh product and be kept, handled, transported and stored in a manner that prevents contamination and adulteration from all sources including ice melt water. In no case should the product be floated or submerged to de-sand or otherwise alter or enhance the product flavor or coloration.