This memo provides confirmation and clarification of the Seafood Inspection Program’s (SIP) policy regarding the collection of records from users of SIP services and the use of photography and photocopying by SIP personnel during facility audits, sanitation reviews, and product inspection.
Under existing SIP policy, (NOAA Handbook 25) USDC Approved Establishments are required to allow SIP auditors to collect copies of records and take photos during facility audits, sanitation evaluation and product inspection. This policy extends as well to any necessary photographs or copies of records necessary to finalize product inspection and certification for U.S. Grade or Acceptance to Approved Specifications.
SIP program participants that process products under the USDC Seafood Inspection Program on a contract basis (Approved establishments) must receive approval of buildings, facilities, and the applicable processes prior to the inauguration of such service. Approved establishments and vessels are verified by on-site audits by SIP personnel to meet U.S. Food and Drug Administration and U.S. Department of Commerce regulations governing the construction and maintenance of facilities and equipment, processing techniques, and employee practices in the production of fishery products for human consumption. Approved establishments are included on a list published on the SIP’s official website. Inclusion on this list is contingent upon the firm’s continued ability to maintain USDC SIP requirements.
When SIP audits an Approved Establishment, the SIP personnel conducts document and record reviews, evaluates sanitation, observes processing operations, documents conditions via observation, interview and photographic evidence. This language for procedures has been in the program manual (NOAA Handbook 25) since 2001.
The collection of information, by copy or photograph, of firm records during an audit allows the SIP auditor to obtain evidence of both compliance and non-compliance observed during the process. The collection of evidence also allows for supporting evidence of the system design and implementation along with the ability to document conditions before and after corrective action is taken. SIP auditors will collect copies of records as necessary during all audits of USDC Approved Establishments. SIP auditors shall keep confidential all information obtained or created during the performance of the audit activities and shall not release or disclose that information except as required by law.
