Shellfish Dealer Training

Welcome to the Shellfish Dealer Training. Review the following information before taking the Shellfish Dealer Quiz.

About this Training

All individuals involved in manufacturing, processing, packing, or holding shellfish are required to complete educational training (per the National Shellfish Sanitation Program's Guide for the Control of Molluscan Shellfish). This training needs to be completed prior to receiving a Washington State Shellfish Dealer License or within 30 days of hire.

By reviewing this information, taking the quiz, and printing the screen that says you passed the quiz, you will satisfy this education requirement. For questions and additional information, contact your shellfish inspector or our commercial shellfish operations staff.

Washington's Shellfish

There are four main types of shellfish that are harvested from Washington's waters: clams, mussels, oysters, and scallops (whole animals only).

Shellfish harvest and processing are regulated by the Washington State Department of Health (DOH) and the United States Food and Drug Administration (FDA) using the National Shellfish Sanitation Program (NSSP). The NSSP is recognized by the Interstate Shellfish Sanitation Conference (ISSC) for the sanitary control of shellfish produced and sold for human consumption.

Hazards

Shellfish are filter-feeders that take in nutrients from the water where they grow. Water can include hazards like bacteria, viruses, and chemicals. If there are enough of these hazards in the water, they can build up in the shellfish and may make people sick. Even if cooked to proper temperatures, shellfish can contain heat resistant viruses and chemicals that can make people sick.

Illnesses frequently associated with shellfish include Paralytic Shellfish Poisoning (PSP), norovirus, Hepatitis A, and Vibriosis. It's important to know the hazards and take appropriate steps to control them.

Controlling the Hazards

To control the hazards (bacteria, viruses, and chemicals) three things must be considered: Location, Temperature, and Time.

Location

The first step in ensuring that shellfish are safe is making sure they come from waters that are open and approved for growing and harvesting. Shellfish growing areas are classified into four different types:

  • Approved: All shellfish harvesting is allowed.
  • Conditionally Approved: Area is open except under certain conditions as described in the DOH management plan for that area. For example, an area around a marina may be open only during times of the year when there is low boating activity.
  • Prohibited: No harvest is allowed for market-size shellfish.
  • Restricted: Only shellfish intended for additional permitted processes (relaying or depuration) are allowed for harvest.

In addition, the growing or harvest area waters must meet the fecal coliform standards set out in NSSP. This means the water must be regularly tested for levels of fecal coliform, which DOH does regularly.

Harvest Site Certificates – All sites used to harvest or store shellfish by commercial shellfish operations must be approved by DOH. Shellfish Licensing and Certification staff work with Growing Area staff to make sure water quality in the area is safe for shellfish harvest and storage and that the site is not impacted by pollution. Harvest Site Certificates are used to identify and contact impacted shellfish companies when a closure is necessary.

Growing Area Closures – Licensed harvesters should be signed up for the Commercial Shellfish Growing Area Management Email List, which allows you to receive emails when a growing area has been closed. The Department of Health requires your phone number (that has voicemail) so we can contact you when a growing area has been closed. You can also call us during business hours at 360-236-3330 or visit our Commercial Shellfish Map and select "Current Closures" for growing area closures.

Harvesting shellfish from closed or prohibited areas is illegal. For more information on how waters are classified visit our Shellfish Growing Areas Program.

Tagging Shellstock

Correct shellstock identification is very important in protecting consumer health. Tags and records are used to trace shellstock from the consumer back to where and when the product was harvested. Shellstock needs to be retagged with a dealer tag when purchased from a harvester.

Once the product is retagged, the original harvester or dealer tag must be kept on file for 90 days.

Dealer tags need to include:

  • Who – The shellfish operation's certification number, name, and address.
  • When – Harvest date.
  • Where – Harvest area (must include “WA” and the growing area name).
  • What – Type of shellfish and quantity.
  • And following statements:
    • Consumer Advisory Statement.
    • “Keep Refrigerated” or equivalent.
    • In bold and capitalized: THIS TAG IS REQUIRED TO BE ATTACHED UNTIL CONTAINER IS EMPTY OR IS RETAGGED AND THEREAFTER KEPT ON FILE, IN CHRONOLOGICAL ORDER, FOR 90 DAYS.” “RETAILERS: DATE WHEN LAST SHELLFISH FROM THIS CONTAINER SOLD OR SERVED (INSERT DATE) ______."

View the Shellstock Tag Example for Dealers (PDF).

Bulk Tagging – A bulk tag can be used on a shellstock lot with an estimated total quantity. A bulk tag statement must be on the tag that reads “All shellstock containers in this lot have the same harvest date and area of harvest.”

Temperature

Temperature control must be applied to all shellstock as soon as practically possible after the harvested shellstock is no longer submerged to prevent bacteria from growing. This can be done by immediately placing shellstock in ice (from an approved source) or in a mechanically refrigerated unit.

Time

Shellstock must be harvested following the time to temperature requirements of NSSP's Guide for the Control of Molluscan Shellfish, Chapter VIII @.02. For the purposes of time to temperature controls, time begins once the first shellstock harvested is no longer submerged. Harvesters must document and provide trip records to the initial dealer demonstrating compliance with the time to temperature requirements.

For oysters harvested during the Vibrio Control Plan months of May through September, there are additional time requirements to prevent Vibrio parahaemolyticus bacteria from growing. The amount of time allowed depends on the month the oysters were harvested in.

  • May 1 – September 30: Vibrio Control Plan time period when oysters only must be harvested within the time to temperature controls listed in WAC 246-282-006 (11).
  • October 1 – April 30: All shellstock must follow the time to temperature requirements of NSSP's Guide for the Control of Molluscan Shellfish. See "Chapter VIII @.02.Shellstock Time to Temperature Controls."

Learn more about the Vibrio control plan rule requirements.

Handling

After the shellstock has been removed from the water, steps should be taken to keep it from environmental contamination. Dirt and filth from birds, unclean water, chemicals, and other environmental contaminants can transfer to shellstock and make consumers sick.

Protect shellfish from contamination during handling by making sure work surfaces are covered to protect from birds and bird droppings and sorting tables are kept clean. Also, rinse any mud or sand on shellfish with approved growing area water or water from an approved source and store shellstock covered in clean plastic totes.

When harvesting, don't mix shellfish lots. This is called commingling and it is prohibited. A lot is considered one day of harvested shellfish of a specific species. For example, pacific oysters harvested on January 1 would be labeled Lot A while pacific oysters harvested on January 2 would be Lot B.

Once in the plant, shellstock should be handled and stored in a way that protects them from contaminants. For example, muddy shellstock should be rinsed prior to processing/storage to protect other shellstock, utensils, or other food contact surfaces from contamination. Shellstock that is dead, unwholesome, or unsafe should not be processed because they may contaminate the rest of the lot.

Wet Storage

Wet storage is when a dealer stores shellstock using these possible methods:

  • Container or float located in an approved or open conditionally-approved growing area that is not the original harvest area.
  • Tank containing natural growing area water at a permitted land-based facility.
  • Tank containing synthetic sea water at a permitted land-based facility.

All wet storage activities require a detailed wet storage plan. The plan must be submitted and approved by DOH prior to beginning any wet storage activity.

In addition to a wet storage plan, all onshore wet storage tanks require a wet storage permit.

Shipping Shellstock

Vessel/Vehicle Condition and Sanitation

To keep shellstock safe during transport on your vessel or vehicle the following guidelines must be followed:

  • Use an approved marine sanitation device on board the vessel to contain sewage.
  • Prevent contaminating shellstock with bilge water.
  • Keep potential sources of contamination (such as fuel cans) away from shellstock.
  • Cats, dogs, or other animals are not allowed on vessels or in the vehicle where shellstock are stored.
  • Store shellstock on a pallet or in a tote.

Shipping Temperature Control

All shellstock shipments must be accompanied by documentation that includes:

  • Time the product was shipped.
  • And the written observation the conveyance was pre-chilled to 45° F or less prior to shipping OR written observation the product was shipped adequately iced.

For more information about shipping requirements, see Commercial Shellfish Shipping Documentation for Dealers (PDF).

Facility Sanitation

All dealers are required to monitor the eight key points of sanitation during operation.

  1. Safety of water for processing and ice production – Ensure the water supply that comes into contact with food or food contact surfaces or used to manufacture ice is safe and from an approved source.
  2. Conditions and cleanliness of food contact surfaces – Monitor and ensure the construction, maintenance, and cleanliness of food contact surfaces including utensils, gloves, and outer garments.
  3. Prevention of cross contamination – Protect shellfish, food packaging materials, and other food contact surfaces from unsanitary objects.
  4. Maintenance of handwashing, hand sanitizing, and toilet facilities – Handwashing sinks, hand sanitizing, and toilets are required and shall be kept clean, functional, and supplied with necessary amenities.
  5. Protection from adulteration – Protect shellfish, packaging material, and food contact surfaces from microbial, chemical, and physical contaminants.
  6. Proper labeling, storage, and use of toxic compounds – Store, label, and use toxic chemicals such as sanitizers, pesticides, fuel, lubricants, etc. properly.
  7. Control of employee health conditions – Workers with illness, wounds, or other conditions that could be a source of contamination cannot not have contact with food, food packaging materials, and food contact surfaces.
  8. Exclusion of pests – Prevent conditions that would attract pests and keep pests from entering the facility.

Monitoring Records - When documenting monitoring activities, dealers must include the date/time of monitoring and note any deficiencies. If deficiencies are found, appropriate corrections should also be recorded. These records must be maintained at the dealer's facility and made available during the inspections.

Hazard Analysis Critical Control Point (HACCP)

Hazard Analysis Critical Control Point, or HACCP, is a preventative food safety approach to minimize, significantly reduce, or eliminate hazards associated with a product or process.

Sanitation controls and good manufacturing practices address environmental and operational conditions which provide the foundation for the HACCP system.

HACCP is made up of seven principles:

  1. Conduct a hazard analysis.
  2. Determine the critical control points in the process.
  3. Establish the critical limits.
  4. Establish monitoring procedures.
  5. Establish corrective actions.
  6. Establish verification procedures.
  7. Establish record keeping procedures.

All dealers are required to be HACCP trained. DOH routinely offers shellfish HACCP training.

Shellfish dealers must also develop and implement a written HACCP plan. HACCP plans must be:

  • Specific to each shellfish operation, location, and processes.
  • Reviewed and signed annually or after the plan is changed.

A HACCP plan is a written procedure for controlling hazards using the seven principles. The plan includes the following:

  • Critical Control Points – Point in the process where control can be applied to prevent, eliminate, or reduce a food safety hazard to an acceptable level.
  • Critical Limits – Setting a limit/value/parameter to which a hazard must be controlled at a critical control point.
  • Monitoring – Deliberate observations/measurements to assess if a critical control point is under control and record the observations that demonstrate the critical limits have been met. Includes the: what, how, frequency, and who will conduct monitoring.
  • Corrective Actions – Procedure to follow when a critical limit deviation occurs.
  • Verification – Procedure to ensure the validation of the critical limit adequacy.
  • Record Keeping – Records used to document the monitoring and verification procedures.

Recall Plans

A recall plan is the process to follow when a dealer recalls their product from the marketplace. This may occur if the product is mislabeled or the food may present a health hazard because the food is contaminated or has caused a foodborne illness outbreak.

Dealers are required to develop a written recall plan. The recall plan must include a list of customers with current contact information and contact information for Washington State Department of Health. For more information, see the resources on recall procedures and notification.

Take the Quiz

Using the information on this page, take the Shellfish Dealer Quiz.

Once you pass the online quiz, print out the screen that says, "Congratulations! You have passed the quiz and completed your shellfish dealer training." Keep this print-out in your records and for our inspectors to review during site visits.