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Ready-to-Eat Seafood Product Sampling Requirements

Seafood Processors who produce a frozen or refrigerated ready-to-eat (RTE) seafood product are required to submit to a qualified laboratory 12 random product samples from the first lot produced each calendar year for Listeria monocytogenes and Salmonella testing. The lot must be held until test results are completed and show that the product lot meets the seafood product standards of no detected Listeria monocytogenes or Salmonella species. This requirement applies whether the product is sold and distributed domestically or exported. 

Ready-to-eat (RTE) food is defined as any seafood product that is normally eaten in its raw state or any other food, including processed food, for which it is reasonably foreseeable that the food will be eaten without further processing that would significantly minimize biological hazards.

In short - RTE foods are eaten without any further cooking (or kill step for bacteria control).

Examples of refrigerated or frozen RTE seafood products

  • Cooked products (crab, sea cucumbers, shrimp)
  • Cold smoked products (lox, gravlax)
  • Hot smoked products 
  • Roe (ikura, sujiko, salted, frozen, caviar)
  • Sushi or sashimi
  • Salads or dips
  • Pickled seafood products (if not shelf-stable)

Product Testing Requirements

  • Select from the first RTE lot of the calendar year 12 samples; hold lot sampled from until testing results are received
  • Submit samples to a Qualified Laboratory  
  • Request testing for Listeria monocytogenes and Salmonella species
  • If any of the 12 product samples from the first lot test positive for Listeria monocytogenes or Salmonella immediately contact the Department for further guidance. Program staff will assist you in the next steps to take.

Environmental Monitoring

 If a seafood processor is implementing a scientifically valid environmental monitoring program that verifies the effectiveness of their sanitation program, that processor may request a waiver of the product testing requirements. 

To request a waiver the processor must submit to the department the form Request for Waiver of Seafood Product Sampling Requirements (PDF), the $150.00 fee and written procedures.

The written procedures must be specific to the processing facility and must identify the:

  1. test microorganism(s);
  2. number of samples to be taken and the locations from which samples will be collected; sample locations should be documented on a floor plan, including sites likely to harbor the environmental pathogen of concern and developed based on the size of the plant, plant features, product flow, characteristics of the ready-to-eat food products, processing methods, and previous sampling results;
  3. timing and frequency for collecting and testing samples;
  4. tests to be conducted and the analytical method(s) used (if in-house, a description of test equipment and procedures);
  5. laboratory conducting the testing; and
  6. corrective action procedures if a sample tests positive for test microorganisms.

For more information, visit our Seafood website

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