NOAA HANDBOOK 25

U.S. Department of Commerce

Seafood 

Inspection 

Program

Items in red are under construction or unavailable at this time
Our Mission:

To ensure the safety and quality, as well as enhance the marketability and sustainability, of seafood 

products for the benefit of the American consumer by providing science based inspection services to 

the seafood industry.

Our Vision:

“An informed society that has confidence in the seafood that they purchase,

sell and consume today and in the future.”

USDC/NOAA Fisheries

Seafood Inspection Program

1315 East West Highway

Silver Spring, MD 20910

Phone 301-713-2355 • Fax 301-713-1081
Table of Contents

PART 1 – ADMINISTRATION AND POLICY...................................................................1

Chapter 1 – Administration......................................................................................................................................... 1

Section 1: EEO Policy................................................................................................................................................. 1

Section 2: Ethical Conduct and Professional Demeanor............................................................................................ 1

Ethical Conduct........................................................................................................................................................ 1

Dress Code ............................................................................................................................................................... 6

Section 3: Time and Attendance Policies and Procedures.......................................................................................... 6

Leave Policy............................................................................................................................................................. 6

Time and Attendance Reporting Policy ..................................................................................................................... 8

Section 4: Travel Policies and Procedures................................................................................................................14

Official Travel Policy..............................................................................................................................................14

NOAA Travel Handbook ........................................................................................................................................15

DOC Travel Guidance.............................................................................................................................................15

Local Travel Guidance............................................................................................................................................15

Compensatory Time for Travel...............................................................................................................................15

Proper Use of Travel Credit Card ...........................................................................................................................15

Section 5: Awards.......................................................................................................................................................15

Awards Policy.........................................................................................................................................................15

Type of Awards.......................................................................................................................................................15

Section 6: Employee Relations...................................................................................................................................15

Alternative Dispute Resolution ...............................................................................................................................15

Appeals ...................................................................................................................................................................15

Case Decisions........................................................................................................................................................15

Conduct ...................................................................................................................................................................15

Discipline ................................................................................................................................................................15

Filing of NOAA Accident/Illness Report................................................................................................................15

Employee Assistance Program................................................................................................................................15

Grievances...............................................................................................................................................................15

Probationary Periods...............................................................................................................................................15

Reasonable Accommodations.................................................................................................................................15

Substance Abuse .....................................................................................................................................................15

Section 7: Performance Management ........................................................................................................................15

Pay Demo................................................................................................................................................................15

Five Level Performance Management System........................................................................................................15

Quality Step Increases.............................................................................................................................................16

Section 8: Benefits......................................................................................................................................................16

Benefits Overview...................................................................................................................................................16

Section 9: Badges.......................................................................................................................................................16

Badges.....................................................................................................................................................................16

Section 10: Diversity ..................................................................................................................................................16

Diversity..................................................................................................................................................................16

Section 11: Labor Relations.......................................................................................................................................16

Federal Labor-Management Relations Statutes.......................................................................................................16

Labor-Management Relations.................................................................................................................................16

Labor Relations Basics............................................................................................................................................16

Section 12: Separation ...............................................................................................................................................16

Leave Audit.............................................................................................................................................................16

Lump Sum or Compensatory Time Payment ..........................................................................................................16

Request for Personnel Action..................................................................................................................................16

Separation Clearance Certificate.............................................................................................................................16
Section 13: Internal Seafood Inspection Program Operations ..................................................................................16

Financial Management............................................................................................................................................16

Billing Procedures and Delinquencies.................................................................................................................16

Submitting Charges for Services..........................................................................................................................18

Payment Guarantees.............................................................................................................................................20

Use and Security of Stamping Devices...................................................................................................................23

Security of Accountable Documents.......................................................................................................................26

Rotation of Inspection Staff ....................................................................................................................................28

Processing Cross-License Applications ..................................................................................................................29

Providing Information to DASS..............................................................................................................................35

Chapter 2 – NOAA SIP Policy....................................................................................................................................35

Section 1: Inspection Policies ....................................................................................................................................35

Appeal Inspections..................................................................................................................................................35

RAPID.....................................................................................................................................................................39

Fresh Fish Inspections.............................................................................................................................................40

Minimum Inspection Effort for Lot Inspection .......................................................................................................40

Section 2: Labeling and Inspection Mark Policies.....................................................................................................40

PUFI Policy.............................................................................................................................................................40

Country of Origin Labeling.....................................................................................................................................40

Customs Labeling ...................................................................................................................................................40

Label Declaration of Phosphates.............................................................................................................................40

Date Labeling of Fresh Fish....................................................................................................................................41

Retail Labeling of Fish Portions..............................................................................................................................42

Scrod Labeling ........................................................................................................................................................42

Metric Declaration of Quantity of Contents............................................................................................................42

Section 3: State and Federal Memorandum of Understanding ..................................................................................46

Memorandum of Understanding with the FDA ......................................................................................................46

State and Federal Agreements.................................................................................................................................49

Section 4: Support for Sustainable Fisheries and Endangered Species.....................................................................49

Statement of Support for NOAA Sustainable Fisheries..........................................................................................49

Inspection of Endangered Species...........................................................................................................................50

PART 2 – INSPECTION PROCEDURES AND DOCUMENTATION..............................51

Chapter 1 – Inspector Instructions............................................................................................................................51

Section 1: Quality Management Program..................................................................................................................51

Reclaimed Fishery Material ....................................................................................................................................51

Retention of Preliminary Sanitation Documents.....................................................................................................51

Section 2: Label Submittal and Review Instructions..................................................................................................51

Section 3: Specification Submittal and Review Instructions ......................................................................................61

Section 4: Instructions for Inspection for the EU.......................................................................................................61

Section 5: Instructions for Inspection for the People’s Republic of China ................................................................61

Section 6: Instructions for DSPC...............................................................................................................................62

Section 7: Guidelines for Retail Inspections..............................................................................................................62

Section 8: Guidelines for Meeting the CN Requirements of the Food and Nutrition Services...................................62

Section 9: Instructions for Inspection of Fish Meal Establishments..........................................................................63

Section 10: Instructions for Collecting and Submitting Analytical Samples to the NSIL...........................................63

Section 11: Inspection of Products Subjected to a Process Involving Carbon Monoxide Gas ..................................63

Chapter 2 – Operational Inspector Instructions.......................................................................................................64

Section 1: Monthly Activities Report..........................................................................................................................64

Section 2: Submittal of Daily and Monthly Summary Reports...................................................................................64

Section 3: Procedures for Processing Requests for Type I Inspection.......................................................................69

Section 4: Procedures for Processing Requests for Type II Inspection......................................................................71

Section 5: Procedures for Processing Requests for Type III Consultation Inspections.............................................73
Section 6: Reporting Violations of the Agricultural Marketing Act ...........................................................................73

Section 7: Reporting Violations of the Food, Drug and Cosmetic Act to the Food and Drug Administration ..........82

Section 8: Processing Consumer Complaints ............................................................................................................84

PART 3 – PRODUCT EVALUATION, GRADING AND DOCUMENTATION.................85

Chapter 1 – Fish and Fishery Product Grade Standards ........................................................................................85

Section 1: U.S. Standard for Whole and Dressed Fish...............................................................................................85

Grading Whole and Dressed Fish............................................................................................................................85

Section 2: U.S. Standard for Whole and Dressed Whiting .........................................................................................85

Grading Frozen Headless Whiting ..........................................................................................................................85

Procedures for Rounding Off and Retention Numbers ...........................................................................................85

Section 3: U.S. Standard for Grades of Fish Steaks...................................................................................................85

Reserved..................................................................................................................................................................85

Grading Frozen Halibut Steaks...............................................................................................................................85

Grading Frozen Salmon Steaks...............................................................................................................................85

Section 4: U.S. Standard for Grades of Fish Fillets...................................................................................................85

Grading Fish Fillets.................................................................................................................................................85

Section 5: U.S. Standard for Grades of Cod Fillets...................................................................................................85

Grading Frozen Cod Fillets.....................................................................................................................................85

Section 6: U.S. Standard for Grades of Flounder and Sole Fillets............................................................................85

Grading Flounder and Sole Fillets ..........................................................................................................................85

Section 7: U.S. Standard for Grades of Haddock Fillets ...........................................................................................85

Grading Frozen Haddock Fillets.............................................................................................................................86

Section 8: U.S. Standard for Grades of Ocean Perch Fillets and Pacific Ocean Perch Fillets.................................86

Grading Ocean Perch Fillets and Pacific Ocean Perch Fillets.................................................................................86

Section 9: U.S. Standard for Grades of Frozen Fish Blocks and Products Made Therefrom....................................86

Grading Frozen Fish Blocks....................................................................................................................................86

Section 10: U.S. Standard for Grades of Frozen Minced Fish Blocks.......................................................................86

Grading Frozen Minced Fish Blocks ......................................................................................................................86

Section 11: U.S. Standard for Grades of Frozen Raw Fish Portions.........................................................................86

Grading Frozen Raw Fish Portions.........................................................................................................................86

Section 12: U.S. Standard for Grades of Frozen Raw Breaded Fish Sticks...............................................................86

Grading Frozen Raw Breaded Fish Sticks ..............................................................................................................86

Section 13: U.S. Standard for Grades of Frozen Raw Breaded Fish Portions ..........................................................86

Grading Frozen Raw Breaded Fish Portions...........................................................................................................86

Section 14: U.S. Standard for Grades of Frozen Fried Fish Sticks............................................................................86

Grading Frozen Fried Fish Sticks............................................................................................................................86

Section 15: U.S. Standard for Grades of Frozen Fried Fish Portions.......................................................................86

Grading Frozen Fried Fish Portions........................................................................................................................86

Section 16: U.S. Standard for Grades of Fresh and Frozen Shrimp ..........................................................................86

Grading Fresh or Frozen Shrimp.............................................................................................................................86

Section 17: U.S. Standard for Grades of Raw Breaded Shrimp.................................................................................86

Grading Frozen Raw Breaded Shrimp ....................................................................................................................86

Section 18: U.S. Standard for Grades of Raw Frozen Scallops.................................................................................86

Grading Frozen Raw Scallops.................................................................................................................................86

Section 19: U.S. Standard for Grades of Raw Breaded Scallops and Frozen Fried Scallops....................................86

Grading Frozen Raw Breaded Scallops and Frozen Fried Scallops........................................................................87

Section 20: U.S. Standard for Grades of North American Freshwater Catfish and Products made Therefrom........87

Grading North American Freshwater Catfish and Products Made Therefrom........................................................87

Chapter 2 – Other Government Standards and Specifications...............................................................................87

Section 1: Consumer Item Descriptions.....................................................................................................................87

Canned Tuna ...........................................................................................................................................................87

Canned Salmon .......................................................................................................................................................87

Pollock Nuggets......................................................................................................................................................87
Section 2: Codex Alimentarius Standards for Fish and Fishery Products.................................................................87

General Standard for Quick Frozen Fish Fillets......................................................................................................87

Quick Frozen Blocks of Fish Fillet, Minced Fish Flesh and Mixtures of Fillets and Minced Fish Flesh ...............87

Quick Frozen Finfish...............................................................................................................................................87

Quick Frozen Fish Sticks, Portions, and Fish Fillets – Breaded or in Batter ..........................................................87

Quick Frozen Shrimp or Prawns.............................................................................................................................87

Quick Frozen Lobster..............................................................................................................................................87

Quick Frozen Raw Squid ........................................................................................................................................87

Canned Finfish ........................................................................................................................................................87

Canned Salmon .......................................................................................................................................................87

Canned Tuna and Bonito.........................................................................................................................................87

Canned Sardines and Sardine-type Products...........................................................................................................87

Canned Shrimp or Prawns.......................................................................................................................................87

Canned Crab Meat...................................................................................................................................................87

Salted Fish and Dried Salted Fish ...........................................................................................................................87

Dried Shark Fin.......................................................................................................................................................88

Crackers from Marine and Freshwater Fish, Crustacean and Molluscan Shellfish.................................................88

Section 3: USDC Model Retail Specifications ...........................................................................................................88

Chapter 3 – Methodology ...........................................................................................................................................88

Section 1: Net or Drained Weight Determination ......................................................................................................88

Section 2: Glaze Determination of Frozen Products..................................................................................................90

Section 3: Fish Flesh Determination..........................................................................................................................90

Section 4: Cooking Methods.......................................................................................................................................90

Section 5: On-Line Flesh Determination ...................................................................................................................91

Section 6: Scallop Moisture Determination ...............................................................................................................91

Section 7: Determination of Ammonia in Dogfish......................................................................................................92

Section 8: Dry Ingredient Inspection Procedures......................................................................................................94

Section 9: Determination of Count per-pound in Shrimp...........................................................................................97

Section 10: Codex Guidelines for Sensory Evaluation of Fish and Shellfish in Laboratories...................................99

Section 11: Use of Acceptance Numbers....................................................................................................................99

Chapter 4 – Certification Instructions.......................................................................................................................99

Section 1: Instructions for Completing the Certificate of Inspection..............................................................................................99

Section 2: Instructions for Completing the Lot Inspection Certificate.....................................................................102

Section 3: Instructions for Completing the Export Health Certificate .....................................................................106

Section 4: Instructions for Completing the Certificate of Origin .............................................................................108

Section 5: Instructions for Completing the EU Fish and Fishery Product Certificates and Documentation...........110

Instructions for completing EU Non-Molluscan Health Certificates....................................................................110

Instructions for Completing the EU Certificate for Molluscan Shellfish ..............................................................114

Instructions for Completing the EU IUU Catch Certificate ..................................................................................116

Issuance of IUU Catch Certificates for Shipments Going to Non-EU Countries..................................................119

Section 6: Instructions for Certifying Fish and Fishery Products to the People’s Republic of China.....................119

Section 7: Instructions for Certifying Salmonid Products to Australia....................................................................119

Section 8: Instructions for Certifying Fish and Fishery Products to French Colonial Territories..........................119

Chapter 5 – Prohibitions in Certification of Seafood .............................................................................................120

Section 1: Artificial Color in Cooked Shrimp ..........................................................................................................120

Section 2: Canada’s Position on Artificial Color in Cooked Shrimp.......................................................................120

Section 3: Bloody Catfish.........................................................................................................................................120

Chapter 6 – Certification of Processing Methods...................................................................................................120

Section 1: Inspection and Certification of Cryovac Vacuum Packaged Marine Fresh Fish Products (Salt Water 

Species Only)............................................................................................................................................................120

Section 2: Inspection and Certification of Vacuum Packaged Hot-Processed Smoked or Hot-Processed SmokeFlavored Salmon ......................................................................................................................................................120
Section 3: Inspection and Certification of Vacuum and Modified Atmosphere Packaged (VAC and MAP) Marine 

and Estuarine Bulk Raw Fishery Products Held at Only Refrigerated Temperatures (non-Frozen).......................120

Chapter 7 – Technical Information..........................................................................................................................120

Section 1: Technical Notes.......................................................................................................................................120

Section 2: Codex Alimentarius Code of Practice for Fish and Fishery Products....................................................120

Section 3: General Information................................................................................................................................120
NOAA HANDBOOK 25

1

Administration and Policy

Chapter 1 – Administration

Section 01: EEO Policy

The NOAA Seafood Inspection Program, as a component of NOAA Fisheries, prohibits 

discrimination because of race, color, religion, national origin, sex, age (40 years and over), 

and/or physical or mental handicap and retaliation for participating in activities protected by the 

civil rights statutes. Please refer to the NOAA Workforce Web Site at: 

http://www.wfm.noaa.gov/employees.html

Section 02: Ethical Conduct and Professional Demeanor

Ethical Conduct and Disclosure of Confidential Information

The following policy has been established to ensure that each Seafood Inspection Program 

employee has a full knowledge and understanding of the Department of Commerce (DOC) 

regulations covering employee responsibilities and conduct, and his/her obligations with regard 

to the disclosure of confidential information obtained in connection with his/her official duties. 

As a DOC employee responsible for enforcing the Regulations Governing Processed Fishery 

Products, the employee must follow acceptable professional standards of conduct during the 

discharge of his/her duties. The references cited here spell out clearly and comprehensively the 

responsibilities and conduct required of DOC employees; and delineate the penalties for the 

unauthorized disclosure of confidential information. Although the regulations pertain to all DOC 

employees, they are particularly germane to Program personnel who, in the normal course of 

their duties, acquire an intimate knowledge of the policies, operational methods, production 

levels, etc., of official establishments. Such employees must be ever mindful of an establishment’s 

inviolable right to safeguard its operational procedures from unauthorized persons, including 

competitive establishments.

A. Consumer Safety Officers/Inspectors/Food Technologists/Trainers

1. All identified personnel are required to read and understand 15 CFR 0, Employee 

Responsibilities and Conduct (See ATTACHMENT #1.)

2. All identified personnel are required to read and understand 18 USC 1905, Disclosure of 

Confidential Information (See ATTACHMENT #2.)

PART 

1

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NOAA HANDBOOK 25

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3. All identified personnel are required to sign the Ethical Conduct Agreement annually (see 

ATTACHMENT #3.)

B. Branch Chiefs. The Branch Chief is responsible for assuring that all identified personnel under 

his/her supervision read and understand 15 CFR 0 and 18 USC 1905. He/She is also responsible 

for assuring that each identified employee signs the Ethical Conduct Agreement at least once 

annually.

The signed Ethical Conduct Agreement will be maintained in the office of the Branch Chief and 

be available for review at any time by any authorized party.

ATTACHMENT #1

Title 15 - Commerce and Foreign Trade

SUBTITLE A - Office of the Secretary of Commerce

CHAPTER I - Bureau of the Census, Department of Commerce 

PART 0 - Employee Responsibilities and Conduct

15 CFR Subtitle A (1-1-02 Edition)

Subpart A-General Provisions

0.735-1 Purpose.

0.735-2 Relation to basic provisions.

0.735-3 Applicability.

0.735-4 Definitions.

Subpart B-General Policy

0.735-5 General principles.

0.735-6 Standards required in the Federal service.

0.735-7 Special requirements of the Department.

0.735-8 Limitations on private activities and interests.

Subpart C-Statutory Limitations Upon Employee Conduct

0.735-9 Employee responsibilities.

Subpart D-Regulatory Limitations Upon Employee Conduct

0.735-10 Administrative extension of statutory limitations.

0.735-10a Proscribed actions.

0.735-11 Gifts, entertainment, and favors.

0.735-12 Outside employment or other activity.

0.735-13 Financial interests.

0.735-14 Use of Government time or property.

0.735-15 Misuse of employment or information.

0.735-16 Indebtedness.

0.735-17 Gambling, betting, and lotteries.

0.735-18 General conduct prejudicial to the Government.

0.735-19 Reporting undue influence to superiors.

Subpart E-Statements of Employment and Financial Interests

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NOAA HANDBOOK 25

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0.735-20 General provisions.

0.735-21 Form and content of statements.

0.735-22 Employees required to submit statements.

0.735-22a Employee’s complaint on filing requirement.

0.735-23 Employees not required to submit statements.

0.735-24 Time and place for submission of original statements.

0.735-25 Supplementary statements.

0.735-26 Interests of employees’ relatives.

0.735-27 Information not known by employees.

0.735-28 Information not required.

0.735-29 Confidentiality of employees’ statements.

0.735-30 Relation of this part to other requirements.

0.735-31 Special Government employees.

Subpart F-Supplementary Regulations

0.735-32 Departmental.

0.735-33 Operating units.

0.735-34 Effective date of supplementary regulations.

Subpart G-Administration

0.735-35 Responsibilities of employees.

0.735-36 Responsibilities of operating units.

0.735-37 Procedure.

0.735-38 Availability for counseling.

0.735-39 Authorizations.

0.735-40 Disciplinary and other remedial action.

0.735-41 Inquiries and exceptions.

Subpart H-Disciplinary Actions Concerning Post-Employment Conflict of Interest Violations

0.735-42 Scope.

0.735-43 Report of violations and investigation.

0.735-44 Initiation of proceedings.

0.735-45 Notice.

0.735-46 Hearing.

0.735-47 Decision absent a hearing.

0.735-48 Administrative appeal.

0.735-49 Sanctions.

0.735-50 Judicial review.

Appendix A-Statutes Governing Conduct of Federal Employees 

Appendix B-Position Categories, Grade GS-13, and Above, Requiring Statements of

Employment and Financial Interests by Incumbents

Appendix C-Position Categories below GS-13 Requiring Statements of Employment and 

Financial Interests by Incumbents

ATTACHMENT #2

TITLE 18 – Crimes and Criminal Procedure
NOAA HANDBOOK 25

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PART I. Crimes 

CHAPTER 93. Public Officers and Employees 

SECTION 1905. Disclosure of Confidential Information

18 USC 1905 (1/03/2007)

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NOAA HANDBOOK 25

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ATTACHMENT #3

U.S. Department of Commerce

NOAA Fisheries

Seafood Inspection Program

Silver Spring, MD 20910

ETHICAL CONDUCT AGREEMENT

For Seafood Inspection Program Personnel

In my capacity as an employee of the Department of Commerce, I hereby state that I will not, 

either individually or as a member of a group, directly or indirectly, ask for, accept, or receive any 

gift, favor, service, loan or entertainment, which might reasonably be interpreted as tending in any 

degree to influence the performance of my official duties, from any person whom I might 

reasonably expect to have official relations.

In addition, I will not divulge any confidential commercial or financial information to any other 

members of industry or to any NOAA Fisheries personnel who are not directly involved in the 

inspection activities of the plant. This includes, but is not limited to, production procedures, 

equipment, proposed changes in production and food safety and quality assurance plans and 

procedures. I furthermore state that I have no private business activities or interests which might 

conflict with the proper performance of my official duties and will not acquire such interests or 

activities during my employment with the Department. I have read and understand the 

Department of Commerce regulations on Employee Responsibilities and Conduct which are 

attached.

Signature Date
NOAA HANDBOOK 25

6

Dress Code

To establish uniformity in inspector appearance during the performance of official inspection 

duties, each inspector is responsible for complying with the following dress code and for assuring 

that his/her appearance is clean, neat and befitting that of a professional food inspector 

representing the Federal Government. Each inspector shall also have a clearly visible logo 

indicating his/her position with the USDC Seafood Inspection Program, in order to be readily 

identified as a representative of the Federal Government on official duty. This logo may be on 

the outside of a lab coat, shirt, freezer coat, or headgear. During in-plant inspections, inspectors

should wear the following:

A. Clothing

– solid color pressed slacks or corduroy pants – no jeans

– clean button-down shirt, blouse, or Polo-type shirt – no tee shirts

– socks

– lab coat (optional) 

B. Shoes

– work shoes or boots appropriate for work environment

– no sneakers or tennis shoes

– no high-heeled or open-toed shoes

C. Headgear

– safety headgear – bump caps or hard hats, depending on the hazardous conditions, or soft 

caps, as appropriate. All headgear worn during the performance of official duties shall bear 

the USDC logo. No other company logo is permitted.

– hair nets, as dictated by the individual's hair length and plant processing conditions

– beard nets, if appropriate

Each inspector is responsible for his/her safety. The official policy of NOAA/Fisheries is that 

safety headgear (bump caps or hard hats) are to be worn during inspection, though the decision 

to wear a particular type of headgear is at the discretion of the inspector. Note that in cases where 

the local supervisor deems the wearing of a soft cap does pose a safety hazard to the inspector, 

the inspector must wear a bump cap or hard hat. The USDC is not liable for head injuries 

incurred if inappropriate headgear is worn. 

Section 03: Time and Attendance Policies and Procedures 

Time and Attendance Policies and Procedures

Leave Policy

Summary Sheet 

All full-time employees must account for 80 working hours (excluding lunch) in a pay period. 

These 80 hours may be any combination of regular hours and approved leave hours. All part-time 

employees must account for the number of hours designated in their hiring plan (excluding 

lunch) in a pay period. These hours may be any combination of regular hours and approved leave 

hours. The work schedule may be adjusted as work needs change by filing an SF-52.

All mixed tour employees must account for the number of hours designated in their hiring plan 
NOAA HANDBOOK 25

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(excluding lunch) in a pay period. The number of hours may be any amount from 80 down to 16 

hours per pay period. These hours may be any combination of regular hours and approved leave 

hours. The work schedule may be adjusted as work needs change by filing an SF-52.

All intermittent employees shall work a designated number of hours mutually agreed upon by 

employee and supervisor. This agreement should be made the week prior to a new pay period or 

at a time mutually agreed upon by both parties. No paper work is needed to adjust this schedule.

– Annual Leave – Signed SF 71 (Application for Leave) required for absences. 

– Sick Leave – Signed SF 71 required, appropriate documentation may be required. Sick leave 

may not be used in lieu of annual leave. 

– Leave Without Pay – An approved leave category requiring a signed SF 71.

– Credit Hours – Earning Credit Hours requires prior approval and the use of Credit Hours 

requires a signed SF 71 (Application for Leave). 

To earn credit hours you must obtain your supervisor’s approval in advance. This approval may 

initially be verbal but must be followed up in writing, i.e., having your supervisor sign your T&A 

worksheet. Please remember that workload must justify the need for credit hours. Working 

compensatory time or overtime requires similar prior approval by your supervisor. 

If timekeepers do not receive supervisory approval for these types of hours with the worksheet, 

they are to check with the employee about approval. If the timekeeper cannot locate the 

employee they are not to enter the designated credit, compensatory or overtime hours onto the 

timesheet. If appropriate, a change may be made at a later date. 

For any sick and annual leave, please inform your supervisor as far in advance as possible. While 

unexpected absences will arise, please make every effort to inform your supervisor as soon as 

possible during these circumstances. 

Tour of Duty

A tour of duty is the hours of a day (a daily tour of duty) and the days of an administrative pay 

period that constitute an employee’s work schedule. The basic work requirement for a full-time 

employee is 80 hours in a biweekly pay period. In addition to the traditional workweek, several 

alternative options are available. There are two categories of Alternate Work Schedules (AWS): 

compressed and flexible. It is the employee’s responsibility to obtain supervisory approval of the 

intended work schedule. The timekeeper must be provided with the approved scheduled. 

Flexible and Compressed Work Schedules – Definition and Features 

Flexible and compressed work schedules provide various work schedule arrangements in which 

fixed times (e.g., 8 – 5) of arrival and departure are replaced by a working day composed of 

schedules different from the traditional 8 – 5. 

Flexible

The employee has the basic work requirement of 80 hours for a biweekly period and may 

vary the number of hours worked on a given workday or the number of hours each week, 

within established limits. The opportunity to earn credit hours may be provided to those 

eligible to accumulate credit hours. 

Compressed

5/4-9 - a full-time employee works 9-hour days for eight workdays and eight hours for one 

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workday during an 80-hour biweekly pay period, with a fixed day off each pay period. 

4-day workweek - a full-time employee works four 10-hour workdays per week during an 80-

hour biweekly pay period, with a fixed day off each pay period. Credit hours are not 

permitted under a Compressed Work Schedule. 

Time and Attendance Reporting Policy 

Work plan 

Each employee must complete and have on file with their supervisor a work plan, indicating 

hours that you intend to work on a regular basis (e.g., 9 – 5:30). A supervisor may require that a 

work plan be filed on a biweekly basis. 

Time and Attendance (T&A) Report 

Employees shall use the official T&A report form, provided by the timekeeper, to record their 

actual work on a daily basis. 

Complete and signed T&A reports should be provided by the employee to the timekeeper by 

mid-day Friday before the beginning of the new pay period. T&A reports, leave slips (which are 

the responsibility of the employee) and associated documents must be submitted together. 

Employees who will be away when T&A reports are due must provide the timekeeper in advance 

with the information necessary to complete an accurate T&A report. 

The timekeeper shall review all individual T&A reports, work plans, and other accompanying 

documentation to ensure project and task numbers and hours of work and leave are properly 

recorded. If no discrepancies are found, the timekeeper shall generate a Draft T&A Report using 

the NOAA T&A reporting system. 

The timekeeper shall report discrepancies to the supervisor/leave approving official. Once all 

discrepancies are corrected and initialed, a Draft T&A Report shall be generated. 

Draft T&A Reports shall be completed by the timekeeper and initialed by the employee no later 

than mid-day Monday following the end of the pay period. If the employee is away, the best 

available data, including draft work plans, shall be used for submitting the T&A report. 

Corrections to any incomplete T&A records shall be completed during the pay period in which 

the employee returns. 

Timekeepers shall make every attempt to provide a Draft T&A Report to employees for 

confirmation before the T&A is finalized and transmitted. By COB on the Monday following the 

end of the pay period, the timekeeper shall forward the Draft T&A documents to the supervisor 

for review. 

The supervisor shall then review all T&A documents. If the supervisor determines that an 

employee’s T&A documents are acceptable, the supervisor shall sign the documents and return 

them to the timekeeper for transmission via NOAA’s T&A Reporting System. If the supervisor 

has concerns regarding a T&A package provided, the supervisor shall address these issues directly 

with the employee, as appropriate, prior to ultimate approval and transmission. 

The timekeeper in charge of transmitting shall transmit the final, Certified T&A data to the 

National Finance Center for payment. This shall be done no later than 4:00 P.M. eastern time 

Tuesday following the end of the pay period. If, under extenuating circumstances, the supervisor 
NOAA HANDBOOK 25

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or his/her designee cannot approve the Certified T&A reports, the Certified T&A reports shall 

be transmitted and reviewed after the fact. 

Attendance Policy

Any employee taking unscheduled or emergency leave is responsible for notifying his or her 

immediate supervisor as early as possible, preferably before the beginning of the regular tour of 

duty. If the supervisor is not available, the employee should leave a message with a phone 

number where he or she may be contacted as necessary. However, every effort should be made to 

call during a time when the leave approving official would normally be available. It is the 

employee’s responsibility to communicate with the leave approving official directly. 

Employees should not assume that leave has been granted unless written or verbal confirmation 

has been received from the supervisor. Also, when calling in, employees should alert their 

supervisor of pending deadlines, file locations, etc., that will assist office coverage during their 

absence. 

An employee’s supervisor is not required to grant leave. If the supervisor determines that the 

needs of the work unit precludes granting leave, or if the reasons expressed by the employee for 

absence are not acceptable, the supervisor may order the employee to report to duty. Failure in 

obtaining approval of leave requests shall be charged as absent without leave (AWOL). Abuse of 

leave, including multiple instances of being AWOL, may result in disciplinary action that may lead 

to dismissal. 

Annual Leave

Annual leave is a period of approved absence with pay from official duty. It is intended to allow 

the employee vacation, rest, and recreation. It is also intended for the employee's use in attending 

to personal or emergency business, to extend the time available to the employee under some 

other leave programs, and for use with specific military leave entitlements. All full-time 

employees assigned to an 80-hour tour of duty shall earn and be credited with annual leave for 

each full biweekly pay period in accordance with 5 U.S.C. 6303. Annual leave accruals shall be 

credited at the end of each pay period. An employee may not use leave that has yet to be credited, 

i.e., leave cannot be earned and used within the same pay period. 

Employees must make every effort to report planned absences to their supervisor at least two 

weeks in advance, using Form SF-71, Application for Leave, for all annual leave. An employee 

may request leave in quarter hour increments. As with any absence, an employee should alert the 

supervisor of pending deadlines, file locations, etc., that will assist office coverage during his/her 

absence. The employee is also responsible for coordinating with colleagues to ensure coverage of 

essential tasks during the employee’s period of leave and access to files, computers, etc. 

– Advance annual leave – leave may be advanced up to the amount of annual leave an 

employee would accrue in the remainder of the leave year. It is at the discretion of the 

supervisor to approve a request for advanced annual leave. 

Abuse of Annual Leave

When an employee violates procedures (for example, by chronic requests for unplanned 

emergency leave, whether under dubious circumstances or not), the employee may be 

required to comply with special leave procedures more stringent than those applied to other 

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employees. For example, the employee may be required to notify the leave-approving official, 

in person, of an unanticipated absence or to document, with evidence, any unscheduled, 

emergency absences. An employee who is placed on special leave procedures must be notified 

in writing, before procedures take effect, of the details of the procedures, their duration, as 

well as the possible results of non-compliance. 

Granting Advanced Annual Leave

Employees may request and be granted annual leave which is expected to accrue under their 

current appointment by the close of the leave year. 

An employee must request advanced annual leave by submission of an SF-71 annotated to 

indicate “advanced annual leave.” Supervisors authorized to approve advanced leave should 

have reasonable assurance that the employee will be in duty status long enough to repay or 

liquidate the advanced leave granted. When it is known at the time the advanced leave is 

requested that the employee will not be returning to duty, advanced annual leave may not be 

granted. 

When an employee has been granted the maximum amount of advanced leave he or she is 

eligible to be granted in a leave year, further grants of advanced leave cannot be approved. In 

cases where the employee is subsequently required to be absent from duty and other types of 

leave are not appropriate for the absence, the employee may request to be placed in a non-pay 

status. The granting of such a request is at management's discretion. 

Sick Leave

Sick leave accruals shall be credited at the end of each pay period. Sick leave not used during the 

year in which it accrues shall accumulate without limitation and be available for use in succeeding 

years. All full-time employees assigned to an 80 hour tour of duty shall earn sick leave at the rate 

of one-half day (4 hours) for each full biweekly pay period. 

All sick leave must be requested, either in advance using Form SF-71, Application for Leave, or 

after leave has been verbally approved by the supervisor. A supervisor may request evidence or 

supporting documentation when granting sick leave. However, for an absence in excess of 3 

workdays, or for a lesser period when determined necessary by a supervisor, a medical certificate 

or other administratively acceptable documentation regarding the reason for an absence is 

required. 

In accordance with the Family Friendly Leave Act, sick leave may also be used by an employee to 

provide for the health care needs of a family member. In all cases of sick leave used for family 

care, the supervisor shall require an employee to submit an SF-71, Application for Leave, and 

may also require the employee to provide medical certification regarding the family member’s 

need for personal care and/or psychological comfort. In these instances, the health care provider 

must document: (1) that the family member requires physical and/or psychological care; (2) that 

the family member would benefit from the employee’s care or presence; and (3) the period of 

incapacitation over which the employee will need to care for the family member. 

– Advanced sick leave – a maximum of 30 days of sick leave may be advanced to an 

employee with a medical emergency or for purposes related to the adoption of a child. 

A maximum of 5 days of sick leave may be advanced for family care or bereavement 

purposes. It is at the discretion of the supervisor to approve a request for advanced sick 
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leave. 

It should be noted that while annual leave may be used in lieu of sick leave, sick leave may NOT 

be used in lieu of annual leave. 

Granting Advanced Sick Leave

Unless it is otherwise restricted, employees may be advanced sick leave in addition to the sick 

leave to their credit regardless of whether they have annual leave to their credit. 

By law, the amount advanced to a full-time employee who has completed a probationary or 

trial period in the Federal government may not exceed 240 hours. Part-time employees or 

those with uncommon tours of duty are advanced sick leave on a pro rata basis. 

Supervisors are advised not to advance sick leave in excess of 13 days (104 hours) to 

probationary employees or to advance sick leave to temporary employees in excess of the 

amount which they will earn during the period of temporary employment. 

An employee must request advance sick leave by submission of an SF-71, Application for 

Leave, annotated to indicate “advanced sick leave.” Supervisors authorized to approve 

advanced sick leave should have reasonable assurance that the employee will be in duty status 

long enough to repay or liquidate the advanced leave granted. When it is known at the time 

advanced leave is requested that the employee will not return to duty, advanced sick leave 

may not be granted. Sick leave must not be advanced to an employee who has filed 

application for disability, inasmuch as payment for such leave is not recoverable upon the 

employee’s subsequent separation from service. 

When an employee has been granted the maximum amount (240 hours) of advanced sick 

leave, no further requests of advanced sick leave may be approved. However, when an 

employee’s advanced sick leave balance is subsequently reduced (e.g., by sick leave accruals), 

an advance of sick leave may again be granted. 

Leave Without Pay

Leave without pay (LWOP) is a temporary non-pay status and absence from duty that may be 

granted at the employee’s request. An employee may request LWOP for 30 calendar days or less 

by filing an SF-71, Application for Leave. In most instances, granting LWOP is a matter of 

supervisory discretion. The employee's time and attendance reports will show the exact dates of 

LWOP. For LWOP in excess of 30 calendar days or requests for extension of LWOP which in 

total would exceed 30 calendar days, the supervisor must provide the Human Resources Office 

with an SF-52, Request for Personnel Action. If the LWOP request is made for health reasons, 

the employee may be requested to furnish a statement from a physician, or other licensed health 

care practitioner, indicating the need for the absence and the prognosis of the employee's ability 

to return to work at the end of the LWOP period. Employees have an entitlement to LWOP in 

the following situations: 

The Family and Medical Leave Act of 1993 (FMLA) (Public Law 103-3, February 5, 1993), 

provides covered employees with an entitlement up to a total of 12 weeks of unpaid leave 

(LWOP) during any 12-month period for certain family and medical needs. (See 5 CFR part 630, 

subpart L.) 
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The Uniformed Services Employment and Reemployment Rights Act of 1994 (Pub.L. 103-353) 

provides employees with an entitlement to LWOP when employment is interrupted by a period 

of service in the uniformed services. (See 5 CFR 353.106.) 

Executive Order 5396, July 17, 1930, provides that disabled veterans are entitled to LWOP for 

necessary medical treatment. Employees should be aware that the accumulation of LWOP may 

affect certain Federal benefits and entitlements. 

Absence Without Official Leave 

Absence Without Official Leave (AWOL) is a period of absence without pay for which the 

employee did not obtain approval or for which a request for approved leave was denied. AWOL 

is based on the supervisor's determination that no form of leave (annual, sick, LWOP, etc.) has 

been or should be approved for the absence based on existing evidence. AWOL may be 

converted to appropriate leave when a supervisor receives and is satisfied with documentation 

justifying the absence. AWOL is not disciplinary in nature, but may be the basis for disciplinary 

action. A supervisor must consult with the Consulting Services Division, Human Resources 

Office when considering disciplinary action. 

Credit Hours

Credit hours are base, non-overtime hours which an employee on a flexible work schedule

voluntarily chooses to work, with supervisory approval, during the office hours. An employee 

may earn a maximum of two credit hours per day and carryover a maximum of 24 credit hours to 

the next pay period. It is the supervisor’s responsibility to approve the work assignment and 

credit hours in advance. Credit hours shall not be approved based on the employee’s desire to 

obtain additional leave, i.e., workload must justify the need for credit hours. These accumulated 

hours may be used by an employee as substitution for working an equivalent number of office 

hours on another business day or across multiple days. Credit hours are not overtime and should 

not be confused as such. Credit hours are hours worked voluntarily by the employee with 

supervisory approval. 

The following specifications apply to credit hour accrual: 

– An employee’s right to use earned credit hours is subject to supervisory approval. 

– Supervisors may limit the number of credit hours an employee may work on a daily 

(maximum of 2 hours per day), weekly, or biweekly basis. 

– Supervisors may set the time frame within which an employee may apply credit hours 

after they have been earned. 

– An employee is restricted by law from carrying forward more than 24 credit hours to 

the next pay period. 

– An employee may not be paid Sunday pay or holiday pay for credit hours. 

– Credit hours are distinguished from overtime hours in that management has not, in 

advance, officially ordered the employee to work. Rather, the employee, by choice, and 

with proper approval, has decided to work additional hours. 

– Credit hours may not be earned for training or during travel status. 

– Use of credit hours shall be requested using Form SF-71. 

Overtime and Compensatory Time

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The Fair Labor Standards Act (FLSA) provides for minimum standards for both wages and 

overtime entitlement, and spells out administrative procedures by which covered work time must 

be compensated. 

Overtime and compensatory time are hours of work that management officially orders and/or 

approves in advance on Form CD-81 and that are in excess of the employee’s daily work 

schedule. 

“Overtime hours” for employees on a flexible AWS schedule means all hours in excess of 8 in a 

day or 40 hours in a week which are officially ordered in advance, not including credit hours. If 

the employee wants to work more than 8 hours in a day or 40 hours in a week they will earn 

credit hours, if they are told they need to work more than 8 hours in a day or 40 hours in a week 

they will be paid overtime.

For employees on a compressed schedule, overtime is hours of work which are officially ordered 

or approved and which are in excess of the employees’ basic work requirement. Compensatory 

time off is time off on an hour for hour basis in lieu of overtime pay. 

FLSA non­exempt employees (all inspectors and admin staff) must indicate their voluntary 

consent to substitute comp time for overtime pay by signing their name in column 10 of the CD81 form authorizing the comp time. In addition, no employee may carry over more than 80 hours 

of comp time into a new leave year. The Director, Chiefs, and Supervisors are considered exempt 

and will not be paid overtime, all other Seafood Inspection employees are eligible for overtime 

and will only receive comp time when requested by the employee.

Adjustment of Work Schedules for Religious Observances

To the extent that modifications in work schedules do not interfere with the efficient 

accomplishment of an agency's mission, an employee whose personal religious beliefs require that 

he or she abstain from work at certain times of the workday or workweek must be permitted to 

work alternative work hours so that the employee may meet the religious obligation. The hours 

worked in lieu of the normal work schedule do not create any entitlement to premium pay 

(including overtime pay). Adjustments of work schedules for religious observances may be 

approved for an employee who is employed in or under an executive agency, as defined in section 

105 of title 5, United States Code. Agencies should require employees to submit a written request 

for an adjusted work schedule in advance. An employee should specifically state that his or her 

request for an adjusted work schedule is for religious purposes and should provide acceptable 

documentation of the need to abstain from work.

The following leave policy, in compliance with Civil Service Commission, DOC, and NOAA 

regulations, applies to all field personnel working in processing plants. The chief inspector of 

each field inspection office is responsible for applying the leave policy stated herein equally and 

impartially to each Consumer Safety Officer (CSO) and Consumer Safety Inspector (CSI) under 

his/her supervision.

It is the policy of this division to assure whenever possible that each employee be scheduled a 

period of annual leave during each calendar year. Therefore, each chief inspector will establish at 

the beginning of each calendar year a mutually agreeable leave schedule for each employee under 

his/her supervision.

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It is also the policy of this division to assign other productive work to inspectors who have 

become temporarily inactivated due to scheduled or unscheduled shutdowns of the plant(s) to 

which they have been assigned. To the maximum extent possible, such inspectors will be assigned 

revenue-producing work. If revenue-producing work is not available, inspectors may be assigned 

to non-revenue-producing activities which are essential to the efficient, effective, and timely 

conduct of the inspection program. Whenever possible, work will be assigned in the following 

order:

1. Revenue producing, such as contract, lot, consultative services, etc., or consumer/trade 

education efforts.

2. Special assignments, such as staff assignments and/or special projects commensurate 

with employees’ abilities.

3. Training assignments which will increase employees’ knowledge, expertise, and ability 

to function more efficiently on the job.

When no such assignments are available during a scheduled or unscheduled shutdown, 

administrative leave and annual leave will be used as follows:

1. Administrative Leave

a. When an unscheduled plant shutdown occurs for less than one full day, inspectors will 

be granted administrative leave for the inoperative hours.

b. When an unscheduled plant shutdown occurs for one or more days, inspectors will be 

granted a minimum of one (1) workday of administrative leave during the inoperative 

period. A maximum of three (3) workdays of administrative leave may normally be 

granted when the shutdown occurred because of emergency conditions. Emergency 

conditions are defined as unanticipated breakdown of equipment, power failure, fuel 

shortages, water shortages, raw material shortages, repairs to plant facilities which are 

required to correct conditions which are contributing to product contamination, or 

other conditions which the supervisor judges to be of a like nature.

c. Administrative leave will normally not be granted in excess of three (3) workdays per 30 

day period in either of the above situations. However, administrative leave may be 

granted for a period not to exceed 5 workdays per 30 day period under unusual 

conditions. Unusual conditions are those in which several shutdowns occur during a 30 

day period for separate and distinct reasons.

2. Annual Leave

a. Inspectors will be placed on annual leave when a plant has been scheduled for shutdown. 

A scheduled plant shutdown is one which was planned and the inspection service notified 

one week or more in advance of the intended shutdown.

b. Inspectors will be placed on annual leave during unscheduled plant shutdowns for nonwork periods in excess of that time for which administrative leave was granted, as detailed 

above. 

Section 04: Travel Policies and Procedures

Official Travel Policy 
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NOAA Travel Handbook 

DOC Travel Guidance 

Local Travel Guidelines 

Compensatory Time for Travel 

Proper Use of Travel Credit Card 

Travel Manager System

Section 05: Awards 

Awards Policy 

Type of Awards 

Section 06: Employee Relations 

Alternative Dispute Resolution 

Appeals 

Case Decisions 

Conduct 

Discipline 

Filing of NOAA Accident/Illness Reporting Form 

Employee Assistance Program 

Grievances 

Probationary Periods 

Reasonable Accommodations 

Substance Abuse 

Section 07: Performance Management

Pay Demo 

Five Level Performance Management System 

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Quality Step Increases

Section 08: Benefits

Benefits Overview 

Section 9: Badges

Subsection A Badge Policy and Procedures 

Section 10: Diversity

Diversity Information 

Section 11: Labor Relations

Federal Labor-Management Relations Statutes 

Labor-Management Relations 

Labor Relations Basics 

Section 12: Separation

Leave Audit 

Lump Sum or Compensatory Time Payment 

Request for Personnel Action 

Separation Clearance Certificate

Section 13: Internal Seafood Inspection Program Operations

Financial Management 

Billing Procedures and Delinquencies

There are two types of services available: 

A. Official Establishment & Product Inspection – Contract Basis: Under this service, one or 

more inspectors are assigned to a processing plant when the inspected product is being 

processed. Only fishery products packed in official plants operating under this inspection and in 

compliance with USDC inspection regulations may be labeled with the official USDC grade or 

inspection marks. 

B. Non-Contract Inspection or consultation – Officially & Unofficially Drawn Samples: This 

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service is designed to provide inspection services for specific lots of fishery products in which the 

applicant has a financial interest. Results of this inspection are reported on an official certificate. 

This service is performed at the request of the applicant upon acceptance by the USDC SIP. 

Miscellaneous Inspection & Consultative Service: These services include any inspection or related 

service, such as, but not limited to, initial and final establishment surveys, appeal inspection, 

sanitation evaluation, sampling, product evaluation, and label and product specification review, 

for which the charges based on the foregoing types are not applicable. 

Billing Procedure 

A. Billing Requirement: Fees and charges for inspection and grading services shall be billed 

monthly to contract participants and by individual invoice for non-contract participants. Fees and 

charges so billed shall be paid by the participant for such service in accordance with the 

applicable provisions in Part 260, Chapter II, Title 50 of the Code of Federal Regulations (CFR), 

as amended. 

B. Surety Bond: Participants under contract for inspection services shall post a surety bond 

equal to approximately three (3) months cost for providing the inspection service prior to the 

initiation of such service. Inspection services shall not be initiated at the participant’s 

establishment until such surety bond has been posted and received by NOAA. All inspection 

services at the establishments operating under contract shall be discontinued at such time as the 

receivables due are of an amount equal to or greater than the amount of the surety bond posted 

by the participant. Inspection services, where discontinued under these conditions, shall be 

reinstituted only after the accounts receivable from the participant are sufficiently reduced. 

C. Billing Forms: The Inspection Collection and Billing Management (ICBM) computer 

program will be used for bill preparation. Additional copies may be prepared, if necessary, for 

local administrative purposes. Bills should be prepared in such detail that the participant can 

readily ascertain what inspection services the bill covers, i.e., contract, lot or sample inspection, 

travel expense, consultative services, etc., including inclusive dates services were provided. 

D. Computation of Billing Amount: Unless otherwise provided for in a written agreement 

between the applicant and the Secretary, the fees to be charged and collected for any inspection 

service performed under the regulation, in Part 260, Title 50 of the CFR, shall be based on the 

applicable rates specified in the said Part, as amended by publication in the CFR, for the type of 

service performed. The monthly billing amount will be computed by the ICBM computer system. 

Bill Collection

All fees and charges for any inspection service performed, pursuant to the regulations in part 260 

of the CFR, shall be paid by check, wire transfer, bank draft, or money order made payable to 

NOAA, Department of Commerce. Such payment shall be remitted to NOAA within thirty (30) 

days from the date of the billing. An automated (ICBM System) follow-up letter shall be mailed 

sixty (60) days after the date of the bill; a second follow-up letter shall be mailed ninety (90) days 

after the date of the bill advising the participant that inspection services will be discontinued and 

the surety bond collected if payment is not received within fifteen (15) days. Copies of all followup letters shall be sent to the appropriate supervisor immediately after each issuance so that 

he/she is alerted to the delinquency. 

Uncollectible Bills

Every reasonable effort shall be made to collect all outstanding bills. Debt collection procedures 

should provide for the use of all reasonable means of collection available and that are consistent 

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with good business practices and the participant’s ability to pay, such as: 

A. Timely and aggressive demands embodying adequate description of the debt. 

B. Efforts to locate the participant. 

C. Set-off, when appropriate, of amounts due indebted participant under NOAA’s contracts. 

D. Application of the procedures prescribed in 4 GAO 55 relative to set-off amounts due 

indebted participants under contract with other agencies. 

E. Set-off amounts due individuals when authorized by law, with particular reference to the 

withholding authority in Public Law 497, approved July 15, 1954 (5 U.S.C. 46d and 46e), and 

Public Law 633, approved August 3, 1950 (5 U.S.C. 46b). 

F. Requests upon other agencies for cooperation in collecting debts from persons who are in 

their employ or service, or who are otherwise currently receiving payments from them. 

After a diligent effort for collection has failed, the January 16, 1985 procedures for 

administratively uncollectible debts shall be followed as set forth in 4 GAO 56. This circular 

replaces NOAA Circular 75-72 dated August 6, 1975, filed as NOAA Directives Manual 34-53. 

ATTACHMENT

USDC Seafood Inspection Fees

Submitting Charges for Services

This national uniform procedure is to be used by inspection personnel in recording charges to be 

used for billing applicants.

Inspector - It will be the responsibility of each inspector to keep a daily record for each 

assignment and to submit this completed record (see attached NOAA Form 89-811) on the last 

day of each month to his/her respective regional director.

Regional Inspection Director - It will be the responsibility of each director to assure he has received 

and verified the required records from all inspectors for all official work stations they have been 

assigned to during the month for billing.

The following procedures will be used in filling out the “Daily Record of Charges” (NOAA Form 

89-811).

A. Header Section

Block 1 – Insert the name of the establishment to be billed.

Block 2 – Leave Blank.

Block 3 – Enter the current month.

Block 4 – Enter the current calendar year.

Block 5 – Enter the complete billing address of the establishment (this address will be used

for billing purposes).

B. Type Section

Block 6.a. – Enter the total number of REGULAR hours of TYPE I inspection services
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rendered to the establishment on a daily basis by each inspector assigned to the 

establishment on the same day, the combined number of hours will be entered in 

the appropriate block(s) by the inspector-in-charge and each inspector’s surname 

will be entered in REMARKS. ONLY ONE FORM WILL BE COMPLETED 

MONTHLY FOR EACH ESTABLISHMENT (except for lot inspection where 

it may be necessary to complete more than one).

Block 6.b. – Same as 6.a. except applies only to OVERTIME.

Block 6.c. – Same as 6.a. except applies only to SUNDAY AND HOLIDAYS.

BLOCK 7.a. – Same as 6.a. except applies only to TYPE II.

Block 7.b. – Same as 6.b. except applies only to TYPE II.

Block 7.c. – Same as 6.c. except applies only to TYPE II.

Block 7.d. – Enter the numeral “1” to indicate MINIMUM FEE.

Block 8 – Write in specific TYPE III service performed (i.e. consulting, contract lot, lab, etc.).

Block 8.a. – Same as 6.a. except applies only to TYPE III.

Block 8.b. – Same as 6.b. except applies only to TYPE III.

Block 8.c. – Same as 6.c. except applies only to TYPE III.

Block 8.d. – Same as Block 7.d.

Block 9 – Enter the number of miles only (The computer will compute the cost.).

Block 10 – Remarks.

C. Validation Section

Block TTL – Enter Column (a) - (d) totals for each type service performed. Block Other 

Costs - Complete OTHER COSTS as applicable at the bottom of form; check

the applicable rate; sign form and forward monthly to the Regional Inspection 

Office.

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ATTACHMENT

Payment Guarantees

To establish uniform requirements and procedures for handling guarantee of payment 

requirements posted by contract establishments. 

The Chief of the regional inspection office which serves the area in which inspection services are

to be performed shall require a guarantee of payment in a minimum amount equal to three (3) 
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months cost for providing the contracted inspection services prior to the initiation of such 

service. Inspection services at an establishment operating under contract shall be discontinued at 

such time as the receivables due are of an amount equal to the amount of the guarantee of 

payment posted by the participant. When discontinued under these circumstances, inspection 

services shall be reinstituted only after the accounts receivable from the participant are 

significantly reduced.

Procedures

Two options are available to participants by which they may comply with the contract 

requirement for providing a guarantee of payment for inspection services rendered.

A. An advance of funds in a minimum amount equal to three (3) months cost from providing 

inspection services may be posted. The advance shall be paid by check, wire transfer or credit 

card. The regional office will forward to NOAA Finance noting funds are in lieu of surety bond. 

The deposit will be non-interest bearing.

B. A surety bond in a minimum amount equal to three (3) months cost from providing 

inspection services may be posted. NOAA form 89-801, Surety Bond (attached) may be used for 

this purpose. Upon receipt, the regional office should review the bond to determine that is has 

been properly completed, signed and seals affixed, and that a power of attorney from the bonding 

company is attached that authorized its representative to sign the bond on its behalf. A copy will 

be retained in the regional office and the original will be forwarded along with the contract to 

headquarters. The surety bond requires the surety to provide thirty (30) days written notice to 

Seafood Inspection Headquarters and the regional office prior to terminating the bond. Should 

the regional office receive notice that a surety bond is being withdrawn on a specific date, the 

office should take immediate steps to advise the participant that a new surety bond or other 

guarantee of payment will be required effective on or before the termination date of the existing 

bond if inspection services are to continue beyond that date.

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ATTACHMENT
NOAA HANDBOOK 25

23

Use and Security of Stamping Devices 

To assure that all official stamping devices are stored, used, and managed in a manner such that 

only authorized personnel have access to them, and are accountable for them; and to assure that 

such devices are used only by or under the supervision of USDC personnel or officially crosslicensed personnel on products approved to bear official marks and in the manner prescribed by 

the regulations.

General

The Inspection Program has taken a number of steps to improve its control of official marks and

devices. These steps include redesigning of the official stamping devices to include an 

accountable number, requiring the signature receipt of each device issued to authorized 

personnel, and restricting the purchase, use, and storage of U.S. Grade “A” and PUFI mark 

stamping devices used on approved products. These instructions contain the procedures for 

implementing an official stamping device management system which will be operated by the 

Documentation Approval and Supply Services (DASS) of the Technical Services Branch (TSB).

Procedures

A. Documentation Approval and Supply Services Section

1. Devices

a. The USDC Lot Inspection Devices [50 CFR 260.86(d)]

(1) Officially Sampled; and

(2) Accepted Per Specifications

b. Official U.S. Grade A and Processed Under Federal Inspection (PUFI) Marking Devices 

[50 CFR 260.86(a), (b), and (c)]

2. Unit of Issue: Each

3. Source: All official stamping devices for use by inspectors will be purchased, inventoried, 

and issued using and documenting certified mail with return receipt requested by the TSB, 

DASS, Pascagoula, Mississippi.

4. Issuing Authority: Approving Officer, DASS, TSB, Pascagoula, Mississippi.

5. Accountability: Official Stamping Devices. The DASS will be accountable for all pre-serial

numbered official stamping devices issued to requesting regions.

6. Missing official stamping devices: Upon being notified of lost or stolen official stamping 

devices, it will be the responsibility of the DASS to alert all RIB offices via Fax and/or 

interoffice electronic mail within twenty-four (24) hours listing any identifying and pertinent 

information.

B. Regional Inspection Chiefs

1. Accountability: It will be the responsibility of the director to:

a. assure that all official stamping devices are used and stored by personnel under his/her

supervision as prescribed by this instruction;

b. establish and maintain an inventory (log) which incorporates the issue and receipt of 

stamping devices (transfers, resignations, or discharges), a copy of which will be submitted 

quarterly to the DASS; 

c. require that the accountability document (see Attachment), which accompanies each 

device(s) issued to field personnel be signed and returned to the Regional Inspection 

Office. Also, if the signed accountability document is not received within 10 days by the 

regional office, the requesting party must be called to determine whether the device(s) have 

been received, with follow-up action taken as indicated by the facts; and 
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d. use and document certified mail with return receipt requested when issuing devices.

2. Ordering: It will be the responsibility of each regional director to order new or replacement 

official stamping devices in a timely manner from the DASS, using two-way memorandums, 

to assure that sufficient useable devices are on hand when needed.

3. Missing official stamping devices: It will be the responsibility of each regional director to 

notify the DASS of lost or stolen official stamping devices within twenty-four (24) hours of 

receipt of such information from an inspector. Notice will be via electronic mail or fax and 

shall include:

a. Inspector to whom devices(s) were issued.

b. Amount and type of devices(s), as well as inspector identification number(s).

c. Locations and brief description of incident resulting in missing device(s).

d. Date and approximate time of loss.

C. USDC Inspectors and Other Authorized Personnel

1. All USDC inspectors and other authorized personnel will be responsible for the security of 

all accountable stamping devices issued to them. Storage will be in a locked drawer, cabinet, 

safe, or other secure area safeguarded by key or combination which is available to or known 

by only official NMFS or cross-licensed inspection personnel.

2. All devices which are out-of-date, damaged, worn, or otherwise unusable must be returned 

to the DASS, through the Regional Inspection Director, for destruction by certified mail, 

return receipt requested.

3. When a USDC inspector or other authorized person is transferred, resigns, or is 

discharged, all official devices used by such a person must be returned to the Regional 

Inspection Office in person or by certified mail, return receipt requested.

4. All USDC inspectors or other authorized personnel will be responsible for reporting lost or 

stolen stamping devices to the regional director within twenty-four (24) hours with the 

required information in V.B.3 above.

D. Official Devices: The approved inspection marks and devices listed in 50 CFR 260.86 will be 

under the official device management system.
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ATTACHMENT

PLEASE COMPLETE AND RETURN TO ADDRESS GIVEN BELOW

I, _________________________________, do hereby acknowledge that

(Name - Please Print)

I have received the below listed item(s):

I.D. NO. ITEM NAME

and understand that I am held responsible for said item(s) as long as I am officially employed or 

cross-licensed as a Federal USDC Inspector.

I understand that: (1) if I resign or am transferred, said item(s) must be returned and receipted prior 

to leaving said duty station; and (2) if said item(s) are worn or broken and need repair or replacement, 

said item(s) will be returned to supply point listed below for repair or replacement.

SUPPLY POINT

SIGNATURE

TECHNICAL SERVICES BRANCH

DASS SECTION

3207 FREDERIC ST., STE. B

P. O. DRAWER 1207

PASCAGOULA, MS 39568-1207

________________________

LOCATION

________________________

MAILING ADDRESS

________________________

STATE ZIP

________________________

DATE
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Security of Accountable Documents

The purpose of this section is to assure official certificates are properly stored, issued, and 

managed in such a manner that only authorized personnel have access to, and are thereby 

accountable for, such documents; and that such documents are executed and issued in such a 

manner that the potential for their misuse is severely restricted.

General

A recent internal control review was conducted to insure controls for accountable documents 

were in place. The findings indicated that although they were operating properly, a “finetuning” was needed to achieve national uniformity. This manual section contains the 

procedures for implementing an efficient certificate management system which will be 

operated by the Documentation Approval and Supply Services (DASS) Section, of the 

Technical Services Branch (TSB).

Procedures

A. Documentation Approval and Supply Services (DASS) Section

1. Responsibilities: It is the responsibility of the DASS Section to:

a. order un-embossed serially numbered certificates from Central Logistics Supply 

Center in Missouri as needed, inventory and store both certificates and certificate log 

(software) under lock;

b. provide access to computer and certificate log only to authorized personnel;

c. emboss all certificates and designate the region issued to, issuing officers, and date 

issued on each certificate book cover prior to shipment;

d. send all shipments via certified mail, return receipt requested, and document such in 

a postal log book and maintain all returned receipts in same;

e. include with all shipments to the regional inspection offices an accountability

document containing certificate types, quantities, serial numbers, the region issued to, 

and make a machine copy and maintain such until the original returns for replacement;

f. enter into the certificate log the data from properly completed records of certificates 

along with any included voided certificates.

2. Missing Certificates: When notified of lost or stolen certificates, the DASS Section will 

alert all RIB offices and program participants via Fax and inter-office electronic mail 

within twenty-four (24) hours, listing any identifying and other pertinent information.

B. Regional Inspection Directors

1. Responsibilities: It is the responsibility of each regional inspection director to:

a. store certificates and certificate log under lock;

b. establish and maintain the certificate log using the following procedures:

[1] Receiving Certificates

[a] check contents of each shipment against the attached accountability document, 

sign if correct, and return promptly to the DASS Section;

[b] enter into the certificate log the date and by whom received, certificate type(s), 

and serial numbers;

[2] Issuing Certificates

[a] check certificate log to remove required certificates sequentially, recording type 

and serial numbers, to whom issued, by whom issued, postal receipt number, or 

hand delivery where applicable, and issue date;

[b] complete each certificate book cover as to inspector issued to, issuing officer, 
NOAA HANDBOOK 25

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date issued, and make a machine copy and maintain such until a machine copy is 

made from the returned, completed record of certificates (reverse side of certificate 

book cover) for replacement;

[c] include with all shipments to field personnel an accountability document 

containing certificate types, quantities, serial numbers, the inspector issued to, and 

make a machine copy and maintain such until the original returns for replacement. 

Also, if the signed accountability document is not received within 10 days by the

regional inspection office, the requesting party must be called to determine 

whether the certificates have been received, with follow-up action taken as 

indicated by the facts;

[d] send all shipments via certified mail, return receipt requested, document such 

in a postal log book, and maintain all returned receipts in same and;

[e] check each returned record of certificates along with any included certificates 

prior to returning such to the DASS Section for completion as to certificate 

numbers, to when issued, date of issue, as well as any voided and superseded 

by/superseded certificate notations and maintain a machine copy file.

2. Ordering Certificates: Each regional inspection director is to order certificates from the 

DASS Section semi-annually based upon projected requirements. Orders will be placed on 

the first Monday in February and August of each year, by two-way memorandum (OF-27).

3. Missing Certificates: Each regional inspection director will notify the DASS Section of 

lost or stolen certificates within 24 hours of receipt of such information. Notice will be via 

electronic mail or fax and shall include:

a. inspector to whom certificate(s) were issued.

b. type and amount of certificate(s) missing.

c. serial number(s) of missing certificate(s).

d. location and description of incident resulting in missing certificate(s).

e. date and approximate time of incident.

f. any pertinent data which might be useful in identifying and substantiating loss.

C. USDC Inspectors and Other Authorized Personnel

1. Responsibilities: It is the responsibility of all USDC inspectors and other

authorized personnel to:

a. store certificates under lock with the key or combination available to or known only 

by official NMFS or cross-licensed inspection personnel;

b. check contents of each shipment against the attached accountability document, sign 

if correct and return promptly to the regional inspection office;

c. enter into the record of certificates (reverse side of certificate book cover) the serial 

number; to whom issued, and date of issue when issuing certificates. Also, all voided 

and superseding certificates must be so noted on their respective record of certificates 

and returned along with same to the regional inspection office. Also, a copy of the 

superseding certificate must be attached to the superseded one.

2. Missing Certificates: All USDC inspectors and other personnel will notify their regional 

inspection office of lost or stolen certificates within 24 hours, with the information required in 

Procedures, B.3., above.

Index

A. Documentation Approval and Supply Services (DASS) Section

1. Responsibilities

a. order certificates
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b. computer access

c. emboss certificates

d. shipping certificates

e. accountability document

f. record records of certificates

2. Missing Certificates

B. Regional Inspection Directors

1. Responsibilities

a. storing certificates

b. certificate log

[1] Receiving Certificates

[a] check shipments

[b] enter shipment into log

[2] Issuing Certificates

[a] remove and record certificates

[b] complete certificate book cover

[c] include accountability document

[d] shipping certificates

[e] check records of certificates

2. Ordering Certificates

3. Missing Certificates

C. USDC Inspectors and other Authorized Personnel

1. Responsibilities

a. storing certificates

b. check shipments

c. complete records of certificates

2. Missing Certificates

Rotation of Inspection Staff Between Assignments

The following procedures have been implemented to establish a national policy on the rotation of 

Consumer Safety Officers/Inspectors between inspection assignments. 

Regular rotation of inspectors between assignments helps minimize the potential for inspectors to 

become overly familiar with plant personnel and plant operational practices to the extent that 

they could become less objective in their performance of inspectional duties. Within the USDC 

Seafood Inspection Program, inspectors are rotated insofar as practical given the financial 

constraints imposed upon the program by its self-supporting mandate. Rotation is done on a 

regional basis at the discretion of the Region Inspection Branch Chiefs, under informal direction 

furnished by the Central Office.

It is Seafood Inspection Program policy to rotate Consumer Safety Officers/Inspectors between 

work assignments at intervals not exceeding one (1) year, wherever two (2) or more inspectors are 

located within the same commuting area, i.e., where no permanent change of station is required, 

and where the change of assignment does not require the payment of mileage allowances to the 

inspector(s).

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The Region Inspection Branch Chief is responsible for assuring that inspectors are rotated in 

accordance with this policy, and for maintaining records of inspector assignments. Records will 

be made available to authorized persons upon request.

Processing Cross-License Applications 

The purpose of this section is to assure uniform review and handling of cross license 

applications.

General

Under agreements between cooperating states and NMFS, and between USDA and NMFS, each 

agency has agreed to adopt certain uniform operational procedures to perform the inspection, 

grading, and certification of fishery products, and to conduct sanitation of USDC official 

establishments. Cross-licensed inspectors are used to carry out inspection, grading, and 

certification procedures on behalf of this agency.

To license a state or USDA inspector, information is needed about the applicant’s educational 

background, professional experience and training. 

Forms Required

A. License Application, NOAA Form 89-859.

B. Training Form

Procedures

A. State Applicants: State applicants will submit the following to the Chief of the appropriate 

Inspection Branch.

1. A completed License Application, NOAA Form 89-859. 

2. Two (2) passport-size photos.

3. Completed Training Form.

B. USDA Applicants: USDA applicants will submit the following to the Chief of the appropriate 

Inspection Branch.

1. A completed License Application, NOAA Form 89-859. 

2. Two passport size photos.

C. Inspection Branch Offices: The Chief, Inspection Branch Office will:

1. Review all applications for completeness. The attached checklist (Attachment A) and 

sample application (NOAA Form 89-859) (Attachment B) may be used as guidance when 

reviewing the completed form. All information on the form is requested. If a particular

block is incomplete or left blank and the checklist for that block specifies that it is 

“required”, the regional inspection branch will obtain the information either through 

follow-up calls or through returning the form. The application will not be approved by 

Head Quarters of the Seafood Inspection Program without all of the “required”

information. 

2. Forward acceptable applications to Head Quarters of the Seafood Inspection Program for 

final processing.

D. Head Quarters will:

1. Complete the processing of all applications and issue licenses.

2. Maintain the cross-license file.
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3. Monitor the file for licenses due to expire, and alert the regions of such.

Use of Non-licensed Applicants

A. An applicant shall not function as cross-licensed inspector until the License Application has 

been approved by Head Quarters.

B. A non-licensed applicant may receive on-the-job training while awaiting cross-license 

approval, but may not certify product.

NOTE: The license is valid for four years unless rescinded earlier for cause. If the inspector 

leaves service before the end of the four years, the license must be surrendered.

Cross License Application Checklist

The following information categories correspond to the numbered categories on the attached 

sample License Application (Attachment #1a-c). Each major block should be marked. If the 

information requested does not apply to the applicant, the block should be marked “N/A”.

1. Type of license requested. Required. This block should be completed by the regional 

office before mailing to the applicant and should be based on the intended function of the 

inspector. Using the definitions in the regulations governing processed fishery products, 50 

CFR Part 260, as guidance, the following definitions apply (Check only one):

Grader: Do not use since the definition for inspector includes grading functions. Cross out 

this choice before mailing to the applicant.

Inspector: authorized to investigate, sample, inspect, and certify in accordance with the 

regulations in this part to any interested party the class, quality, and condition of processed 

products and to perform related duties in connection with the inspection service. If the 

inspector will be doing sanitation inspection only, put an asterisk next to this block and 

add the statement “Sanitation Only” in the Remarks section.

Sampler: authorized to draw samples of processed products for inspection, to inspect for 

identification and condition of containers in a lot.

2. Applicant’s Name: Required.

3. Home Phone: Not required.

4. Home Address: Not required.

5. Business Address: Required. Also require a business phone number.

6. Do you own any part of any business: Required.

7. Are you a United States citizen? Required.

8. Date of birth: Not required.

9. Have you been previously licensed. Required.

10. Height. Not required.

11. Weight. Not required.

12. For use by USDC. Not to be filled in by applicant.

13. Remarks. To be completed after review by regional office and completion of appropriate 

training for the applicant.

THIS IS A VERY IMPORTANT SECTION. This section should describe clearly what training 

has been provided. The general commodity and the training on specific U.S. Standards for 

Grades associated with that commodity (in parenthesis) that the applicant has received should be 

reflected as follows:

Fish (Whole & dressed, Fillets, Steaks)

Blocks and Breaded Fish (Blocks, Sticks, Portions, Nuggets)

Shrimp (General Shrimp, Breaded Shrimp)

Other Crustacea (Lobster, Crabs, Crayfish)

Molluscan Shellfish (Scallops, Oysters, Clams, Mussels)
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Formulated Products (Surimi and Analogs, Fish Cakes)

Cephalopods (Squid, Octopus)

This section should also explain the training for sanitation that the applicant received. “Basic 

sanitation training” (plant visit, forms and procedures review) should be provided in most cases. 

There may be occasions where the supervisor determines that no in-plant visit is required and a 

“sanitation overview” to include forms, procedures, and an explanation of sanitation “hot-spots”

is provided. In either case, the remarks section will indicate whether the applicant has had “basic 

sanitation training” or “sanitation overview.”

14. Regional Inspection Director and Date: Required.

15. Chief, Inspection Services Branch and Date: Required after Washington Office review.

16. Experience: Required. The specific experience of interest is that covering the past ten years 

related to sanitation, food processing, and inspection. Information in all of the blocks is 

required, except for “salary”.

17. Education: Required. If the applicant did not attend college, insert “N/A.”

18. Specialized Training: Required. If the applicant has had no specialized training, insert “N/A.”

The training information should include the title or brief description of training content, 

duration (hours), and who provided the training.

19. References: Required ONLY for private samplers.

20. Questions: Required.

21. Signature of Applicant and Date: Required.
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ATTACHMENT #1a
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ATTACHMENT #1b
NOAA HANDBOOK 25

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ATTACHMENT #1c
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CROSS-LICENSED INSPECTOR TRAINING FORM

Name of Cross-Licensed Inspector in Training:

Product forms this inspector is likely to be inspecting most often:

The above training was provided to the identified cross-licensed inspector to certify him/her for a 

[check one] Sample Only ____ , 

Sanitation Only ____, Sample, Inspect, and Certify ____ cross-license for the inspection of fishery 

products for the USDC Seafood Inspection Program.

Signature of USDC Supervisory CSO Printed Name Date

Providing Information to DASS 

Chapter 2 – NOAA SIP Policy

Section 01: Inspection Policies

Appeal Inspections

The following procedure is for processing requests for the reinspection of unreworked lots of 

fishery products which have been inspected and certified previously by NOAA. This procedure 

supersedes Inspection Manual Transmittal No. 129, dated 12/18/84, Part, Chapter, and Section 

as above.

DATE: TRAINED BY DESCRIPTION OF COURSE/TRAINING HOURS

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NOAA HANDBOOK 25

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Policy

It is NOAA policy to perform one appeal inspection of any un-reworked lot of product when 

substantial reasons for a re-inspection are furnished by the applicant; provided the request for the 

appeal inspection conforms to the criteria contained in 50 CFR 260. The results of an appeal 

inspection are final; that is, the results of an appeal inspection supersede the results of the original 

inspection.

General

An application for an appeal inspection may be made by any interested party who is dissatisfied 

with the results of an inspection as stated in an inspection certificate. The regulations, 50 CFR 

260.36 through 260.41, govern the way applications for appeal inspections are submitted and 

accepted or refused, and the way appeal inspections are performed. They also direct the manner 

in which appeal inspection certificates are issued and distributed. The major points are:

A. An appeal inspection may be requested by any party who has a financial interest in the

product and who disagrees with the results of the findings reported on the original certificate.

NOAA may refuse to perform an appeal inspection if:

1. The reason(s) for the appeal inspection is frivolous or not substantial.

2. The quality or condition of the product has undergone a material change since the original 

inspection. In this instance, the product may be inspected as a new lot, and a certificate 

issued to replace the original certificate.

3. The lot is not, or cannot be made accessible for sampling.

4. The lot cannot be positively identified as the lot which was originally inspected.

B. An application for an appeal inspection should be made within thirty (30) days of the original 

inspection. Extensions may be granted by the Regional Inspection Branch Chief when adjudged 

to be appropriate.

C. Applications for appeal inspections may be made orally or in writing. Oral requests must be 

confirmed promptly in writing.

D. Following an appeal inspection, a lot inspection certificate will be issued showing the detailed, 

factual results of the inspection. The “appeal” inspection certificate will supersede the original 

certificate (or original results if no certificate was issued), which will become null and void.

NOTE: To assure national uniformity in the handling of appeal inspections, each Regional

Inspection Branch Chief will formally designate a supervisory inspector to serve as the

Regional Appeal Inspection Coordinator. The Director of Field Operations will serve as the

National Appeal Inspection Coordinator.

Responsibilities and Procedures

A. Inspection Branch Chief: It is the responsibility of the Inspection Branch Chief to:

1. Appoint formally a supervisory inspector to serve as the Regional Appeal Inspection 

Coordinator, and to notify each Field Inspection Branch and the National Appeal 

Inspection Coordinator of the appointment.

2. Establish a roster of inspectors experienced in the inspection/grading of the appealed 

product. The selection of appeal inspectors will be made from this roster. This roster shall

be kept current and updated at least annually.

B. Applicant: It is the responsibility of the applicant to:

1. File an application for the appeal inspection with:

a. The regional inspection office which issued the inspection certificate on which the 

appeal covering the product is requested; or

b. The regional inspection office nearest the place where the product is stored.
NOAA HANDBOOK 25

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2. Furnish to the Regional Appeal Inspection Coordinator that information which is 

necessary to determine whether the appeal inspection will be performed, where it will be 

performed, and by whom it will be performed. As a minimum, the information will

include:

a. Product location.

b. Reason(s) why the appeal should be conducted.

c. The date and serial number of the certificate covering the inspection on which the 

appeal is requested.

C. Regional Appeal Inspection Coordinator: It is the responsibility of the Regional Appeal

Inspection Coordinator to:

1. Review the application for an appeal inspection for completeness of information.

2. Determine whether the application for appeal can be accepted or refused; that is, does the 

applicant have substantial reason(s) for requesting a re-inspection of a product that has 

already been inspected? For example, a request for an appeal inspection of a product 

simply because it failed to meet the requirements for it to be labeled as U.S. Grade “A”

cannot be accepted unless there is strong evidence that the inspector failed to sample and 

inspect/grade the product as prescribed by the regulations, or was unqualified to 

inspect/grade the product presented.

3. Determine where the appeal inspection will be performed.

a. If the product is located in a storage facility with adequate accommodations for 

performing the inspection, and a qualified appeal inspector is available, the appeal 

should be conducted at that site. If the product is located in a geographical area other 

than where the request for appeal is received, the Regional Appeal Inspection 

Coordinator who received the request will coordinate the appeal with the Regional 

Appeal Inspection Coordinator of the Region where the product is located.

b. If adequate accommodations for inspection are not available at the product location, or 

if a qualified appeal inspector is not available there, the Regional Appeal Inspection 

Coordinator must coordinate the official product sampling and shipment of the samples 

to a location satisfactory for the performance of the inspection. If samples must be 

shipped to a distant location because a qualified appeal inspector is not available at the 

product’s location, the cost of shipping the sample will be borne by NOAA.

c. When an appeal inspection involves a product which has been shipped to a location 

distant from the processing plant, and the processor desires to be present during the 

appeal inspection, the Regional Appeal Inspection Coordinator may arrange for official 

sampling at the product's location for shipment to the original (processing) area for the 

appeal inspection. In this case the cost of their transportation will be borne by the 

processor.

4. Select a qualified inspector to perform the appeal inspection. When possible, two (2) 

inspectors should be assigned to perform the inspection. The inspector who performed 

the original inspection will not be permitted to conduct or participate in an appeal 

inspection; although he/she may be permitted to conduct official sampling for the appeal 

in the event that another inspector or licensed sampler is not available in the area where 

the product is located.

5. Fix the location, date, and time for the appeal inspection and notify all concerned parties.

6. Review the results of the appeal inspection as stated on the inspection certificate to 

determine that the information is reported accurately and completely.

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D. Appeal Inspector: It is the responsibility of the appeal inspector to:

1. Conduct the appeal inspection at the appointed date, time, and location. Unless otherwise 

requested by the applicant, the product will be examined only for those factors contested 

by the applicant.

2. Issue a lot inspection certificate showing the inspection results.

3. Distribute copies of the certificate to all parties who received a copy of the original 

certificate.

4. When the results of an appeal inspection indicate that the product is mislabeled, e.g., bears 

a U.S. Grade mark but does not meet the designated grade requirements, notify the 

product owner that the labels must be removed within ten (10) days in accordance with 50 

CFR 260.86 (e). In instances where a product fails to meet a U.S. Grade requirement 

because of an apparent change in flesh content due to moisture migration during handling 

and storage, the appeal inspector will consult with his/her supervisor prior to making a 

label removal decision.

E. National Appeal Inspection Coordinator: It is the responsibility of the National Appeal 

Coordinator to:

1. Coordinate, when necessary, appeal inspections which involve more than one Regional 

Inspection Branch.

2. Resolve inspection operational problems which may arise during appeal inspections.

Special Situations

Defense Personnel Support Center (DPSC)

The Defense Personnel Support Center purchases foods for use by the military services. It 

operates an audit program that randomly surveys items for adherence to purchase specifications. 

Products inspected at origin by USDC inspectors are subject to these audits, and warranty action 

is taken by DPSC if they do not comply with DPSC acceptance criteria. In addition, products are 

inspected upon receipt at receiving depots to assure that products are in good condition, and 

meet required temperature, condition of container, and marking requirements. Noncomplying products are rejected.

A. DPSC Responsibilities:

1. When a shipment of fishery products is rejected upon delivery at destination, or when a 

shipment is found to be nonconforming following an audit, DPSC will notify the vendor.

2. The vendor may request a re-inspection of a rejected product. If DPSC grants a reinspection it will furnish all appropriate information to the NOAA Regional Inspection 

Branch which services the area where the product is located.

B. USDC Responsibilities:

1. The Regional Appeal Inspection Coordinator will arrange the appeal as prescribed above. 

If the region performing the inspection is different from the one that certified the product 

at origin, the coordinator will notify the origin coordinator of the reason for the rejection, 

and the time and place of the appeal inspection. The Regional Appeal Inspection 

Coordinator will also notify DPSC and the vendor of the scheduled time and place of the 

appeal inspection.

2. When the re-inspection has been completed, the Regional Appeal Inspection Coordinator 

will communicate the results to DPSC, the Regional Appeal Inspection Coordinator at the 

region where the origin inspection was performed, and the vendor. The written results of 

the re-inspection will be forwarded to all parties as soon as possible.

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NOAA HANDBOOK 25

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Fees and Charges

The assessment of fees and charges for performing appeal inspections are prescribed in 50 CFR 

260.74.

A. If the results of an appeal inspection disclose that a material error was made in the original 

inspection on which the appeal was made, no inspection fee will be assessed to the applicant.

B. If the results of an appeal inspection disclose that no material error was made in the original 

inspection on which the appeal was made, fees and charges for Type II inspection services will be 

assessed to the applicant.

Regulation and Policy Interpretive Decisions (RAPID) 

The following policy has been established to provide a uniform procedure whereby USDC 

Seafood Inspection Program Branches and personnel may request regulation and policy 

interpretive decisions, and to have those decisions disseminated for use by all inspectors in a 

timely manner. 

Periodically a situation arises during the conduct of Program business which appears to be 

outside the scope of the regulations, policies, or procedures. Sometimes these situations require 

interpretive decisions which may impact on the routine conduct of inspection services. Prompt 

decisions are always desirable, but some questions require legal or policy guidance, or 

coordination between agency units, and possibly industry, before a decision can be issued.

Requests for Regulation and Policy Interpretive Decisions

1. Requests shall be submitted in writing to the Chief Quality Officer, or his designee. The 

request should be submitted via e-mail, but a fax or memorandum is acceptable. In an 

emergency situation, when telephone requests are deemed necessary, they must be followed by 

a written confirmation from the requester.

2. Requests must contain 1) a clear statement of the problem, 2) its immediate and potential 

impact on the Seafood Inspection Program, 3) all feasible alternatives to the problem, and 4) 

recommended solution(s). The solution(s), as well as all listed alternatives, must be well 

researched and documented in the request. Reasons for the recommended course of action 

should be provided, as well as all references to research which are pertinent to the issue and 

used to arrive at the recommended course of action.

3. Requests will be logged and tracked upon receipt at the Headquarters Office.

4. The Chief Quality Officer, or his designee, will evaluate the request, conduct any additional 

research necessary, and provide a complete package to the Director of the Seafood Inspection 

Program. It will be the responsibility of the Chief Quality Officer to obtain concurrence on the 

proposed course of action, or a modified course of action, from appropriate Program 

Management and support units, depending on the nature of the issue.

5. Once a decision is made regarding the request, the Chief Quality Officer will provide a 

written reply to all parties affected.
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Fresh Fish Inspections 

Minimum Inspection Effort for Lot Inspection 

The USDC Voluntary Inspection Program’s mission is to provide service to our lot inspection 

clients which the program does well in meeting the clients' needs. However, it has been noted 

that there have been differences in the application of the inspection effort between the regions. 

To resolve the differences and provide uniform services in conducting lot inspection across the 

nation, this memorandum defines the minimum inspection effort and the policy on conducting 

lot inspection. 

Not withstanding an inspection document that requires further investigation of the fishery 

product, such as a buyer specification, foreign country requirements or an applicants request, the 

minimum inspection effort applied for lot inspection of fishery products will be Quality and 

Condition. However, should obvious label violations be noted during the lot inspection, they will 

be reported on the lot inspection certificate with the results of the quality and condition. Quality 

and Condition are defined in 50 CFR 260 and are listed as follows. 

Quality: refers to the wholesomeness of the product. Which means the minimum basis of 

acceptability for human food purposes. Condition: refers to packaging and product, meaning the 

degree of soundness of the product which may affect its merchantability and include, but not 

limited to those factors which are subject to change as a result of age, improper preparation and 

processing, improper packaging, improper storage, or improper handling. 

On completion of the inspection, the Lot Inspection Certificate will attest to the factors of 

Quality and Condition found. If weights and counts were not requested as part of the lot 

inspection, a statement to the effect will be placed on the certificate, “Vendor weights and counts 

used, but not verified.”

Section 02: Labeling and Inspection Mark Policies

Inspection Mark Policy 

Country of Origin Labeling

Customs Labeling 

Label Declaration for Phosphates

To provide guidance in the use of phosphate compounds, such as sodium tripolyphosphate and 

sodium hexametaphosphate, in fishery products, and to assure that products containing them are 

labeled in accordance with the regulations promulgated by the Food and Drug Administration 

(FDA). This section replaces the Label Alert issued July 24, 1979, subject: Declaring the Food 

Additive Sodium Tripolyphosphate (STP) on Labels.

Policy

It is NMFS policy to assure that all products processed under USDC inspection contain only 

FDA approved ingredients, additives, or substances that are used in accordance with good 

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manufacturing practice, and are declared properly on the product label.

General

Sodium tripolyphosphate has been used for several years by fishery products processors to 

reduce the loss of natural moisture in products during processing. Other phosphate compounds 

have also been used, e.g., sodium hexametaphosphate. These products are approved by FDA as 

general purpose substances and/or sequestrants which are generally recognized as safe (GRAS) 

for their intended use, when used in accordance with good manufacturing practice. However, 

their use in products for which definitions and standards of identity have been established by 

FDA is governed by the applicable definition or standard of identity. For example, the use of 

phosphate compounds is not permitted in the raw shrimp material in the processing of the 

standardized food, frozen raw breaded shrimp.

Procedure

A. Use in Products.

1. The use of phosphate compounds in foods is governed by regulations promulgated by 

FDA and published in 21 CFR 182.1(b). This section defines good manufacturing practice 

to include the following restrictions:

(a) The quantity of a substance added to food does not exceed the amount reasonably 

required to accomplish its intended physical, nutritional, or other technical effect in food; 

and

(b) The quantity of a substance that becomes a component of food as a result of its use in 

the manufacturing, processing, or packaging of food, and which is not intended to 

accomplish any physical or other technical effect in the food itself,

shall be reduced to the extent reasonably possible.

(c) The substance is of appropriate food grade and is prepared and handled as a food 

ingredient.

2. The quantity of phosphate compounds which may be added to fishery products to meet 

the aforementioned restrictions, i.e., to comply with the good manufacturing practice 

definition, should not exceed 0.5 percent by weight.

3. There is no test method for determining the amount of phosphate added to fishery

products readily available to the inspector. However, extreme overuse of these products 

will result in a translucent appearance of the product.

B. Labeling. Products containing phosphate compounds must have the name of the

compound(s) declared on the product label. This is required regardless of whether the product 

was manufactured from raw material (fishery products) containing them, or whether they were 

added during the manufacturing process. The common or usual name of the compound(s) added 

must be used. NOTE: Because they are GRAS substances (see 21 CFR 182.1810 and 21 CFR 

182.6760) and are not exempt under 21 CFR 101.100, their presence must be declared to avoid 

being misbranded under the provisions of section 403 of the Food, Drug, and Cosmetic Act. 

Their declaration must be either:

1. On the principal display panel as a separate statement, or

2. In the ingredients statement in their descending order of predominance either on the

principal display panel or the information panel as required in 21 CFR 101.4 and 101.2.

Date Labeling of Fresh Fish

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The purpose of this section is to establish an official NMFS policy regarding the date labeling of 

fresh (perishable) fishery products. There is no Federal policy on the date labeling (open dating) 

of foods. Several States and the District of Columbia have some form of mandatory date labeling. 

In some of these States certain products are exempt, e.g., fresh meat, fresh poultry, fresh fish, 

fresh fruits, and fresh vegetables.

NOAA Fisheries believes that the use of date labeling can be beneficial to both the processor and

the consumer. It can encourage better handling practices by processors, wholesalers, retailers, and 

consumers by drawing attention to expediting the sale and use of fresh products nearing the end 

of their shelf life. It can also increase consumer confidence in the freshness of products 

purchased. In the case of fresh, highly perishable fishery products, however, the processor has 

limited, if any, control over the factors which affect the shelf life of a product once it enters the 

distribution chain. To attempt to determine and use the “average” shelf life of a product may 

discriminate unfairly against a product handled and marketed properly; and, on the other hand, 

mislead the consumer who purchases an improperly handled and marketed product.

NOAA Fisheries can determine and certify the condition (and quality if applicable) of fresh 

fishery products only at the time of inspection, and grading if appropriate.

Policy

It is NOAA policy to not require the date labeling of fresh fishery products which have been 

packed under USDC inspection, and graded if applicable. In the interest of making fresh

products of good quality available to consumers on a continuing basis, it is also the policy of

NOAA to encourage and assist official establishments in the development and use of open-date

labeling consistent with their products’ inherent shelf-life characteristics, the processing, handling,

and preservation methods to which they have been exposed, and the degree of quality control

exercised by responsible persons in the distribution chain.

In the event NOAA determines that there is chronic abuse of product bearing official inspection 

mark(s), it will be the policy of NOAA to notify responsible or potentially impacted parties of 

their findings. This will include parties with identified involvement with the product, such as 

processors/distributors identified on the label. It is the policy of NOAA to use all available 

sanctions to remedy such abuse situations.

Retail Labeling of Fish Portions 

Scrod Labeling 

Metric Declaration of Quantity of Contents 

This section is to establish general and specific guidance for the voluntary use of metric units of 

quantity to state the net quantity of contents on the labeling, including the principal display panel, 

of a fishery product commodity.

General

The Metric Conversion Act of 1975 (80 stat 1007) was enacted to voluntarily increase the use of 

the metric system of weights and measures in the United States. In support of this policy, the 

FDA has developed guidance on the use of the metric system in declaring the net quantity of 

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contents on the labels of FDA-regulated commodities.

Procedures

A. Policy

1. A metric declaration of quantity of contents is not considered to be “other printed label 

information” that would be subject to the separation requirements of 21 CFR 101.105(f). 

Other printed label information must be separated from the net weight statement.

2. On packages of foods labeled in English, with an alternate principal display panel in a 

foreign language, FDA does not object to the foreign language panel bearing only a metric 

declaration of net contents. This assumes, of course, that the container labeling otherwise 

complies fully with the Federal Food, Drug, and Cosmetic Act, the Fair Packaging and 

Labeling Act, and the regulations promulgated thereunder.

B. Prefixes

1. In symbols or names for units having prefixes, i.e. kilogram, no space is left between letters 

making up the symbol or the name.

EXAMPLE: kg, kilogram

2. Prefixes chosen should result in:

a. numerical values between 0.1 and 1000, and

b. decimal fractions of no more than two places.

C. Units

1. Unless FDA advises otherwise, a declaration of quantity of contents:

a. In units of weight, is expressed in terms of the kilogram, gram, milligram, or microgram.

b. In units of liquid measure, is expressed in terms of the liter or milliliter at 20 C, except 

for:

• a commodity that is normally sold and consumed while frozen, the declaration 

expresses the volume at the frozen temperature, and

• a commodity that is normally sold in the refrigerated state, the declaration

expresses the volume at 4 degrees C.

2. A number of foreign countries use “re” rather that “er” spellings for the ending of metric 

units of measure (e.g., metre, litre, etc.). The “er” spellings are preferred for all products 

sold in the U.S. FDA suggests that firms using “re” spellings revise their labels to contain 

“er” spellings as their labels are reprinted.

3. Unit names, including prefixes, are not capitalized except at the beginning of a sentence 

and in titles, headings and other instances in which all main words are capitalized.

4. A space is left between a numeral and the unit name or symbol to which it refers.

EXAMPLE: 22 mg, 22 g

5. The decimal marker is a dot on the line. (This is the practice in the United States and 

Canada; however, many countries use a comma or a raised dot.)

6. Decimal notation is preferred with metric measurements, but simple fractions are

acceptable, such as those where the denominator is 2, 4 and 8. A fraction should be

reduced to its lowest terms.

7. A zero before the decimal point should be used in numbers between 1 and -1 to prevent 

the possibility that a faint decimal point will be overlooked.

EXAMPLE: The oral expression “point seven five” is written 0.75

D. Symbols

1. The following symbols for metric units are used in the declaration of quantity:

kilogram kg microgram Mg

gram g liter L
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milligram mg milliliter mL

2. Symbols, except for liter, are not capitalized unless the unit is derived from a proper name. 

Periods should not be used after the symbol. Symbols for units are the same in singular 

and plural.

EXAMPLE: 1 m, 100 m

3. The “L” symbol for liter and “mL” symbol for milliliter are preferred. FDA suggests that 

firms using “l” and “ml” symbols revise their labels to contain “L” and “mL” as their 

labels are reprinted.

E. Calculations

1. Conversion - The following conversion factors should be used to determine metric 

equivalents from inch-pound units:

Quantity: VOLUME

Convert From To Multiply By

fluid ounce (U.S.) liter (L) 0.029 573 53

pint (U.S. liquid) liter (L) 0.473 176 5

quart (U.S. liquid) liter (L) 0.946 352 9

gallon (U.S. liquid) liter (L) 3.785 412

cubic foot liter (L) 28.316 85

bushel (U.S. liquid) liter (L) 35.239 07

Quantity: MASS (Weight)

Convert From To Multiply By

grain milligram (mg) 64.798 91

ounce (avoirdupois) gram (g) 28.349 523

ounce (avoirdupois) kilogram (kg) 0.028 349 52

pound (avoirdupois) gram (g) 453.592 37

pound (avoirdupois) kilogram (kg) 0.453 592 37

2. Rounding - When the digits to be discarded begin with a 5 or more, increase by one unit 

the last digit retained.

EXAMPLE: 8.3745, if rounded to three digits, would be 8.37; 8.3745, if rounded to 

four digits, would be 8.375.

NOTE: These rounding rules are to be used for conversion of weights to metric units

for labeling purposes ONLY. They are not to be confused with USDC Handbook 25

- Part III, Chapter 2, Section 05, Transmittal No. 141, Procedures for Rounding Off

and Retention of Numbers, used during inspection computations.

3. Significant Digits - significant digits as defined by the American Heritage Dictionary are 

“digits of the decimal form of a number beginning with the leftmost nonzero digit and

extending to the right to include all digits warranted by the accuracy of measuring devices 

used to obtain the numbers.” Although zero digits at the beginning of a number (e.g., 0.1, 

0.01) are never significant digits, zero digits at the end of a number (e.g., 0.10, 10, 10 000) 

may be significant digits if the digit is known to be reasonably reliable. The Metric 

Editorial Guide advises that “Zeros at the end of a number are not considered significant 

unless their use results in a number that is closer to the true value than would be the case if 

the number were increased or decreased by 1.” The position of a decimal point in a 

number does not affect the number of significant digits in that number (e.g., the numbers 

2834, 28.34 and 0.0002834 all have four significant digits).

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The Metric Editorial Guide provides the following rules concerning significant digits:

a. If the first significant digit of the metric value is EQUAL TO OR LARGER than the 

first significant digit of the inch-pound value, round the metric value to the SAME 

NUMBER of significant digits as there are in the inch-pound value.

EXAMPLE: (1st significant digit underlined.)

15 oz X 0.02834952 kg/oz = 0.425 2428 kg

which rounds to 0.43 kg;

1 lb X 0.45359237 kg/lb = 0.45359237 kg

which rounds to 0.5 kg

b. If the first significant digit of the metric value is SMALLER than the first significant 

digit of the inch-pound value, round the metric value to ONE MORE significant digit 

than is in the inch-pound value.

EXAMPLE: (1st significant digit underlined.)

42 oz X 0.02834952 kg/oz = 1.19067984 kg

which rounds to 1.19 kg;

5 lb X 0.45359237 kg/lb = 2.26796185 kg

which rounds to 2.3 kg

F. Placement

1. When a metric declaration of quantity of contents appears on a principal display panel 

(PDP) of an FDA-regulated fishery product commodity within the bottom 30 percent of 

the area of the PDP, the metric declaration should be placed with the required inch-pound 

declaration of net quantity of contents.

2. A metric declaration in the bottom 30 percent of the PDP may appear as the primary 

declaration of quantity of contents on the PDP. This metric declaration may appear above 

or below or to the left or the right of the inch-pound declaration of quantity. The inchpound declaration of quantity should not be omitted from the PDP. However, on an 

alternate PDP that serves solely as a foreign language PDP, FDA does not object to the 

foreign language PDP bearing only a metric declaration of net contents. This assumes, of 

course, that the container labeling otherwise complies fully with the Federal Food, Drug 

and Cosmetic Act, the Fair Packaging and Labeling Act, and the regulations promulgated 

thereunder.

3. A metric declaration in the bottom 30 percent of a PDP should comply with all provisions 

of FDA regulations [e.g., 21 CFR 101.105 (foods)] pertaining to the required inch-pound 

declaration of net quantity of contents, except for provisions pertaining to a statement of 

count or dual statement of count or a dual statement of quantity. Manufacturers should 

exercise care to assure that the combined inch-pound/metric declaration complies with all 

regulations and with the principles set forth in this guide. Because lower case letters are 

required for most metric symbols, care must be exercised to insure that both upper and 

lower case letters meet all letter height requirements. In lieu of the symbol, the full name of 

the metric unit may be used, e.g., “GRAM” or “gram” or “Gram,” provided the lower case 

letters meet type size requirements. Exponents should be one-half the type size of the 

symbol letters used.

4. Use the term “Net Weight” or “Net Wt” whenever the required declaration of net quantity 

of contents is in terms of weight. The metric declaration may be placed before or after such 

terms.

5. Whenever the required declaration of net quantity of contents is in terms of fluid measure 

or numerical count, the terms “net” or “Net Contents” may be used in the declaration. The 

metric declaration may be placed before or after such terms.
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6. Always use parentheses for the second expression of a dual inch-pound declaration [e.g., 

net weight 24 oz (1 lb 8 oz)]. Additional parentheses should be used when the metric and 

U.S. customary declaration appear on one line.

7. Examples of inch-pound/metric declarations:

a. Net Wt 425 g (15 oz) or Net Weight 15 oz (425 g) assumes ounces are known to 3 

significant digits, i.e., 15.0 oz

b. Net Wt 680 g (24 oz) (1 lb 8 oz) or Net Weight 680 g (24 oz (1 lb 8 oz)) or Net Wt 24 

oz (1 lb 8 oz) 680 g or NET WEIGHT (680 g) 24 oz (1 lb 8 oz) assumes ounces are 

known to 3 significant digits, i.e., 24.0 oz

Compliance

All labels are to be submitted to the National Seafood Inspection Laboratory, Division of

Documentation Approval and Supply Services for compliance review and program approval.

Section 03: State and Federal Memorandum of Understanding

Memorandum of Understanding with the Food and Drug Administration

The purpose of this section is to standardize the implementation of the provisions of the 

Memorandum of Understanding (MOU) so as to promote an effective working relationship 

between the participating agencies which will benefit industry, consumer, and government. 

General

The success of the MOU (see ATTACHMENT #1) will depend in large part on the appropriate 

and timely exchange of information between the two agencies. The NMFS Branch inspection 

offices play a significant role in communications with the FDA District offices. A current listing 

of the FDA District offices is furnished to the Branch offices at each updating.

Memorandum of Understanding Responsibilities

The MOU provides ten services to be provided by NMFS, eight responsibilities for FDA, and 

eleven points of mutual agreement. Many of the aspects of the MOU involving the Branch 

offices are self-explanatory, and spell out functions, responsibilities, and requirements which

inspectors are responsive to on a continuing basis. The following aspects are modifications or

additions to current procedures and will be implemented upon receipt of this manual release. The 

item numbers refer to their respective paragraph numbers of the MOU.

A. The National Marine Fisheries Service:

1. Item A.l. - Branch offices will immediately advise the Division Office in writing when 1) 

participating plants withdraw or are suspended from inspection service, 2) contracts are 

terminated, 3) inspection services are denied because of insanitation or current good 

manufacturing practice deficiencies, and 4) plants are reinstated in the USDC voluntary 

Seafood Inspection Program. The Inspection Division Office will provide FDA headquarters 

with a complete list of plants operating under NMFS inspection on a contract basis, and will 

notify FDA headquarters of any changes in plant status with reasons therefore. A copy of the

notification will be furnished to the appropriate FDA District office.

2. Item A.4. - Branch offices will furnish any pertinent information regarding specific lots of 

products inspected or graded by NMFS to the appropriate FDA District office upon request. 

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Telephone requests will be followed by written confirmation. In addition, the Branch office 

will furnish a copy of the information to the Division Office.

3. Item A.6. - Branch offices will report by telephone or other electronic means, with followup written confirmation, to the appropriate FDA District office, information regarding any 

product found by NMFS to be adulterated or misbranded under the Federal Food, Drug, and 

Cosmetic Act and/or exceeds the criteria published in the FDA Compliance Policy Guides 

UNLESS the product is reconditioned so as to comply with FDA requirements, or is 

segregated and disposed of for non-food use or otherwise LAWFULLY shipped or sold. This

applies to products inspected by NMFS under Types I, II, and III inspections without 

exception. The Branch offices will follow the provisions of the Rejection and Retention of 

Products and Equipment section of this manual, in the handling and reporting of products in 

Type I establishments.

4. Item A.7. - The re-inspection of samples of product which have previously been inspected 

or graded by NMFS and are subject to FDA seizure, prosecution, injunction, or import 

detention action will be performed by NMFS only when clearance has been received.

B. The Food and Drug Administration

1. Item B.5. - FDA review of labels, legends, stamps, and other official works will be directed 

to the Chief, Inspection Services Division, NMFS for submittal to FDA. Requests for such 

review will not be made to FDA District offices. 2. Item B.8. - The NMFS inspector should 

make every effort to participate and cooperate in inspections of official establishments 

conducted by FDA inspectors. Joint inspections are mutually beneficial, and educational to 

both inspectors.

C. Mutual Responsibilities:

1. Item C.7. - Branch inspection offices should develop and maintain close working 

relationships with appropriate FDA District offices. Meetings may be held on a scheduled or 

unscheduled basis but should be held periodically to coordinate, evaluate, and review 

inspectional matters of mutual interest.

Reports

In addition to the reports required by the MOU and the Rejection and Retention of Products and 

Equipment section of this manual, Branch inspection offices will complete the NMFS/FDA 

Liaison Activities Report (see ATTACHMENT #2), on a monthly basis and forward one copy to 

the Division Office, ATTN: Chief, Inspection Services Division, and retain a copy in the Branch 

office file.

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ATTACHMENT #1

ATTACHMENT #2

MEMORANDUM FOR: F/SI - Director, Seafood Inspection Program

FROM: F/SI - Chief, Inspection Branch

SUBJECT: NMFS/FDA Liaison Activities Report for (Month, Year)

The following FDA contacts were made during the report period.

(The report should be substantially as follows.)

Number the contacts, i.e., a separate paragraph for each contact.

For each contact include:

NMFS inspector/official present.

FDA inspector/official present.

Location of visit - plant, office, etc.

Purpose of visit.

Summary of discussions.

Follow-on actions required.

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State and Federal Agreements 

The purpose of this section is to assure uniform implementation of Federal/State agreements 

which provide for the inspection of fishery products by USDC licensed state inspectors based 

upon Federal requirements.

Policy

It is the policy of the Seafood Inspection Program to use cross-licensed state inspectors to 

perform the inspection, grading, and certification of fishery products, and to conduct sanitation 

inspections of USDC official establishments within the boundaries of the states with whom the 

NMFS has entered into formal inspection agreements.

General

Under standardized cooperative agreements between the states and NMFS each agency has

agreed to adopt certain uniform operational procedures to carry out the program. 

Implementation of the provisions and their procedures rests with the chief inspectors that are 

responsible for the overall effectiveness of inspection activities in their geographical area of 

concern. They will work directly with their counterparts in the state agency to arrange for crosslicensing, training and technical supervision of state personnel. 

Procedures

Many of the aspects of the agreements are self-explanatory. The responsibilities of each agency 

are given in the cooperative agreement with the respective state. The following points are 

intended to further explain or clarify some of their general provisions. They are numbered to 

correspond with the paragraphs of the cooperative agreement.

2. (A) The chief inspector responsible for the administration of the respective Federal/State 

Agreement will arrange for the cross-licensing of state inspectors as mutually agreed upon by 

both parties.

2. (D) NOAA administrative and supervisory inspection personnel will periodically review 

inspections performed by state personnel to determine that they are conducted in accordance 

with applicable Federal regulations and operational procedures contained in this inspection 

manual.

2. (H) NOAA will furnish to each state inspection agency sufficient supplies of inspection 

standards, specifications, instructions, score sheets, certificates and official stamps necessary 

for it to carry out its inspections under the cooperative agreement. It is the responsibility of 

the chief inspector administering the agreement to make certain that an adequate supply of all 

necessary materials are available for use by licensed state inspectors.

4. (A) At a minimum, onsite and on-the-job training will be provided to specific state 

inspectors at the time the first request for inspection is received by the state agency, and 

thereafter as the need arises.

4. (G) The chief inspector will request a copy of each State’s annual audit report as required 

by this paragraph of the Agreement.

Section 04: Support for Sustainable Fisheries and Endangered Species

Statement of Support for NOAA Sustainable Fisheries

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Inspection of Endangered Species 

The purpose of this section is to alert the inspector to those species of fish, reptiles, amphibians, 

snails, clams, and other marine life currently designated as endangered or threatened so he may 

not inadvertently inspect and certify such products for use as food, in violation of applicable

regulations.

General

The Endangered Species Act of 1973 sets forth specific guidelines regulating the taking, 

possessing, importing and exporting of endangered and threatened wildlife intended for interstate 

or foreign commerce, sale or offer for sale. The inspector should keep abreast of information 

relevant to species of marine life which have been determined to be threatened or endangered.

Policy

Inspectors will not inspect, certify, or participate in the inspection and certification of seafood 

products manufactured from threatened or endangered species, nor will they provide inspection 

services which aid in facilitating acts specifically prohibited under 50 CFR 17.21 and 17.31.

Procedures

Species of marine life currently covered under the Endangered Species Act are listed at 

http://www.nmfs.noaa.gov/pr/species/esa/.

When requested to provide inspection or certification services on products which have been

manufactured from any of the species at the above website, the inspector shall contact the nearest

NMFS Enforcement Office to determine whether any change in status has occurred, and whether 

the products in question may be legally taken and sold for use as food.

In those instances where a listed species may be legally certified by NOAA seafood inspectors,

the concerned inspector will make a written statement on the inspection certificate to that effect, 

including the name of the NMFS Enforcement Officer and time and date of the discussion.

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Inspection Procedures and Documentation

Chapter 1 – Inspector Instructions

Section 01: Quality Management Program 

Reclaimed Fishery Material

Retention of Preliminary Sanitation Documents

Section 02: Label Submittal and Review Instructions

The purpose of this section is to establish standard procedures for processing fishery product 

labels submitted by official establishments for DOC approval; present the new procedures for 

label review/approval; standardize the temporary approval and disapproval criteria.

General

A. Title 50 of the Code of Federal Regulations (CFR)requires that establishments contracting for 

fishery product inspection service obtain DOC approval of labels prior to use on products 

that will be processed under federal inspection, regardless of whether or not they bear official 

inspection or grade marks. Additionally, “Policy for Advertising Services and Marks,” identify 

additional labeling and advertising of marks and services that must be approved prior to use. 

Exceptions to this requirement are noted below. Procedures for Child Nutrition (CN) label 

approval are found in this document.

EXCEPTIONS: This procedure does not apply to products inspected and certified 

for the Department of Defense for troop feeding or other Federal agencies that have 

specific labeling requirements. However, we recommend that these labels be 

submitted for review and record-keeping purposes.

B. The Approving Officer, DOC Seafood Inspection Program (SIP), Technical Services Branch, 

Documentation Approval and Supply Service (DASS) Section, Pascagoula, MS, is responsible 

for administering the Label Review/Approval System and assuring that this system is 

operational. 

C. Processing specifications for all nonstandardized products shall be submitted for approval 

concurrently with labels. See Specificiation Submittal and Review Instructions in this 

PART 

2
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document for product specifications for nonstandardized products. A copy of previously 

approved specifications must be submitted with each label submittal.

Submittal Instructions

A. Contracting Party

1. New and revised labels: The processor is required to submit five label proofs and/or 

finished labels (CN labeling requires five), prior to use, to the assigned Consumer Safety 

Inspector (CSI)/Consumer Safety Officer (CSO) or supervisory CSO. Proofs of new or 

revised labels are not required, but are encouraged. Proof review affords establishments 

the opportunity to obtain information on the compliance of the proof with labeling 

regulations and may prevent the need for modification to finished labels thus reducing 

costs.

2. All label/proof submittals must be accompanied by NOAA Form 89-819, Specification 

and Label Submittal Action Request, (see Attachment 1), through the assigned CSI/CSO, 

or through the immediate supervisor when the CSI/CSO is not available. It is the 

responsibility of the submitting establishment to complete the NOAA Form 89-819 prior 

to submitting the package to the assigned CSI/CSO for review. Please read the 

information concerning the NOAA Form 89-819 at the beginning of Attachment 1. 

Establishments are reminded to complete separate NOAA Forms 89-819 for institutional 

labels, case labels (nonretail), retail labels and CN labels. Only one group, for example 

retail labels, are to be submitted on a NOAA Form 89-819. Use another NOAA Form 

89-819 for submitting CN labels and do likewise for institutional and/or case labels. 

Further, there are to be no more than four different labels of the same group, e.g., 

institutional labels, on one NOAA Form 89-819.

3. Cancellations: When products are withdrawn from inspection, a completed NOAA Form 

89-819, Specification and Label Submittal Action Request, indicating the label approval 

number, specification number, and approval date is submitted to the assigned CSI/CSO 

or supervisory CSO for signature. Establishments are encouraged to submit a copy of the 

original NOAA Form 89-819 on which the label was approved to expedite the process.

Note: For purposes of this manual release, retail labels are defined as any label bearing 

mandatory nutrition labeling.

4. In the absence of the assigned CSI/CSO, Block 10, USDC Inspector's signature, may be 

left blank and a statement placed in Block 13, Remarks, indicating the name of the 

CSI/CSO's supervisor with whom submittal was discussed and who authorized the 

submittal. Such submittals will be verified by the Approving Officer.

5. HACCP-based inspection establishments are not required to have the NOAA Form 89-

819 signed by a CSI/CSO or supervisory CSO. Such establishments may submit labels, 

depending on group or type, with the form directly to the Approving Officer. 

6. After review and signature by the assigned CSI/CSO, the establishment is responsible for 

mailing the submittal package (labels, specifications, and NOAA Form 89-819). 

Institutional, case, retail, and CN labels are mailed to the Approving Officer.

7. Approving Officer

DOC NOAA Fisheries

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Seafood Inspection Program

Technical Services Branch

Documentation Approval and Supply Service Section

3207 Frederic Street, Suite B

P. O. Drawer 1207

Pascagoula, MS 39568-1207

Phone (228) 762-1892

Fax (228) 769-1436 or 769-2581

B. DOC, SIP, Regional Inspection Branch (RIB), CSI or CSO

The assigned CSI or CSO will:

1. Assure that only those label proofs and/or finished labels which have been authorized for 

submittal by a properly designated official of the establishment are sent to the Approving 

Officer, and that separate NOAA Form 89-819’s are completed for retail, CN, institution 

and case labels;

2. Review all label proofs and/or finished labels in accordance with Attachment 2 to assure 

that the label information agrees with the product represented. Discrepancies should be 

resolved with the processor. The CSI/CSO will identify any noted discrepancies in Block 

#13, Remarks, on the NOAA Form 89-819, or by a note attached to the form, or directly 

on one copy of the label submitted, and sign the noted discrepancies;

3. Determine that the corresponding specification used to prepare the product has been 

approved or is being submitted for approval with the label;

4. Determine that specifications, and product samples if requested, are submitted in 

accordance with the instructions contained in Part I, Chapter 3, Section 08;

5. Review and sign NOAA Form 89-819 after assuring it is completed in accordance with 

the instructions, and retain the Field Copy of the form in the office file until approval 

action has been completed; and

6. Return the signed NOAA Form 89-819 to the establishment for submission to the 

Approving Officer, DASS.

Note: One-Run Approval. The assigned CSI/CSO or supervisory CSO may give onerun approval for a plant to use a label only after reviewing the label in accordance with 

these instructions and receiving verbal approval from the Approving Officer.

C. Approving Officer

1. Label Review and Approval or Temporary Approval or Disapproval

a. Institutional, case, retail, and CN labels will be reviewed by the Approving Officer to 

determine compliance with the Fair Packaging and Labeling Act, Federal Food, Drug 

and Cosmetic Act, as amended, Nutritional Labeling and Education Act, and other 

applicable labeling regulations.

b. The Approving Officer will complete the portion of NOAA Form 89-819 designated 

“Action Taken,” and sign and date the form. Copies will be distributed as follows:

(1) Original and Inspector Copy - To the DOC CSI/CSO stationed at the 

establishment submitting the labels or proofs. The CSI/CSO will forward the 

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original to the processor, file the Inspector Copy, and discard the Field copy. 

Copies for HACCP-based inspection establishments will be returned directly to 

the submitting establishment.

(2) DASS Office Copy - Retained by the Approving Officer, or submitted to DASS 

by the Regional Consumer Safety Officer.

(3) Regional Office Copy - will be forwarded to the RIB by DASS.

2. Label Cancellation

The Approving Officer will assure that requests for a label cancellation result in proper 

notation of such labels in the master files. Distribution of NOAA Form 89-819 for 

cancellation will be the same as that for label approval actions.

Label and Proof Status as Defined by Action Taken

A. Proofs

1. Proofs submitted for review that comply with the labeling regulations will be “Approved 

To Print As Is.” When the proof is printed, the finished label must be submitted for final 

approval.

2. Proofs submitted that are not in compliance with the labeling regulations will be 

“Approved To Print With Changes Noted.” When printed with the corrections, finished 

label(s) must be submitted for final approval.

B. Labels

1. Labels that are submitted and are in compliance with all labeling laws and regulations will 

be given a “Final Approval.” This approval is good for five years, then the labels must be 

resubmitted for approval to assure and validate that the labels are current and in use.

2. Labels submitted that are not in compliance with the labeling laws and regulations, 

standards of identity or other applicable regulations will be given a “Temporary 

Approval” for minor compliance provided that the noncompliance does not warrant a 

“Disapproval.” (Disapproval is identified below). 

The temporary approval is granted to allow establishments time to correct the label and 

resubmit the corrected label.

3. Maximum time limits for “Temporary Approval” are:

a. four months for flat labels (i.e., those affixed to cartons, packages and cases);

b. nine months for printed bags; and

c. twelve months for printed cartons.

4. Temporarily approved labels may be resubmitted for an extension of the temporary 

approval. The processor must provide information on the stock remaining and the 

expected usage rate before an extension will be granted. Further, a noncompliance may 

warrant that the label(s) be over-stickered before any additional use of the label is allowed. 

This condition will be noted on the NOAA Form 89-819, identifying the time-frame for 

over-stickering.

5. Labels in a noncompliance will be given a “Disapproval” for the following reasons: 

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a. Labels bearing USDC Inspection Marks that do not accurately convey the degree of 

inspection effort. Example, a label bearing a PUFI Mark while the product is lot 

inspected.

b. Labels bearing USDC Inspection Marks or references to USDC Inspection that are 

not approved by the “Policy and Guidelines for Advertising USDC Inspection 

Marks.”

c. Labels that fail to bear mandatory nutrition labeling and that is not exempt by the 

regulations.

d. Labels bearing ingredient statements that do not declare or disclose all ingredients 

identified by the specification for that product or that fail to declare the use of flavors, 

artificial colors, preservatives, and/or food additives, or that substantially misidentifies 

an ingredient to the point that it is false or misleading.

e. Labels that bear nutrient content claims when the claim does not conform to the 

regulations for nutrient content claims.

f. Labels bearing identity statements that do not conform to the standard of identity for 

that product.

g. Labels bearing a statement of identity that does not identify the product by common 

or usual name.

h. Labels that are required to bear Country of Origin labeling and fail to disclose the 

country of origin or misrepresent the country of origin.

i. Labels that utilize an information panel and fail to provide all required information 

without intervening material (information not required).

j. Labels that provide nutrition information and fail to declare the correct serving size in 

relation to the reference serving size, resulting in a misrepresentation of the nutrient 

levels and erroneous nutrition information.

k. Labels that contain four or more violations of the requirements contained in the 

subparts of 21 CFR 101 or other applicable regulations.

Label Review/Approval Conditions that Warrant Billing

A. Rate. As established in the Notice of Charges and Fees for the U.S. Department of 

Commerce Seafood Inspection Program, establishments submitting labels for 

review/approval may be charged for the time required. The rate for label review/approval is 

established as Type I, and the minimum charge is established as one half hour. 

B. Conditions. The following are the current conditions that warrant charging for label 

review/approval: 

1. Nonapplicant review and opinion on labels.

2. Consultation on labels and specifications for contract and noncontract establishments.

3. Potential clients of the program that have labels reviewed or approved that do not 

subsequently enter the program.

NOAA Form 89-819 Specification and Label Submittal Action Request

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A. The information required on NOAA Form 89-819 (see Attachment 1) is to be completed by 

the submitting establishment and the information required is self explanatory.

B. Paperwork Reduction Act

1. NOAA Form 89-819, “Specification and Label Submittal Action Request” is one of 

several NOAA Forms identified by the Office of Management and Budget (OMB) 

subject to the Act. Participants in the USDC Seafood Inspection Program are 

encouraged to read the “Information Collection Notification” by OMB prior to 

completing the form.

2. Information Collection Notification, NOAA Form 89-819

a. This information collection is authorized under 50 CFR §260.97©) (12), (13), and 

(15).

The information will be used to ensure compliance with mandatory labeling 

regulations established by the U.S. Food and Drug Administration as well as proper 

use of the official marks of the voluntary NOAA Seafood Inspection Program. 

Public reporting burden for this collection of information is estimated to average 30 

minutes per response, including the time for reviewing instructions, searching existing 

data sources, gathering and maintaining the data needed, and completing and 

reviewing the collection of information. Send comments regarding this burden 

estimate or any other aspect of the collection of information, including suggestions 

for reducing this burden to the Seafood Inspection Program, 1315 East-West 

Highway, Silver Spring, MD 20910. This information is required in order to obtain 

the benefits of the use of official marks [50 CFR §260.86].

b. Notwithstanding any other provision of the law, no person is required to respond to, 

nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the Paperwork Reduction Act, unless that 

collection of information displays a currently valid OMB Control Number.

LABEL REVIEW LIST

A. The “principal display panel” (PDP) is defined as that part of the label that is most likely to 

be shown under customary conditions of display for retail sale. The area of the PDP for a 

rectangular package is the product of the height times width

B. The “information panel” is for additional information required by 21 CFR 101 and means 

that part of the label 

. A cylindrical container or near 

cylindrical container PDP is 40% of the product of the height times the circumference. In 

cases of any other shaped container, the PDP area is 40% of the total surface of the 

container. (21 CFR 101.1).

immediately contiguous and to the right of the PDP. However, if the 

panel is too small or otherwise unusable, the panel immediately contiguous and to the right of 

this part of the label may be used. If the package has alternate principal display panels, the 

information panel is immediately contiguous and to the right of any principal display panel. 

If the top of the package/container is the PDP, the information panel is any panel adjacent to 

the PDP.

NOTE: Specific information is required by regulations in 21 CFR 101 to appear on the 

principal display panel or the information panel. When required information appears on 

the information panel, this information must be together without intervening material. 

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Intervening material is defined as any printed matter, picture, vignette, etc. not required by 

regulation.

The following information, when required to appear on the label of any package, must 

appear either on the PDP or the information panel. Regulations may specify specific location 

on the label.

1. Identity labeling of the food - must appear on the PDP.

2. Statement of Ingredients - PDP or Information Panel.

3. Name and place of business of processor, packer, distributor, etc. PDP or information 

panel. 

4. Number of Servings – if nutrition information is present, it is required. On the PDP or 

on the information panel.

5. Nutrition Information – required on retail labeling unless product or business is exempt. 

PDP or information panel. 

6. Net Quantity of Contents. Must appear on the PDP.

C. Specific requirements for the above information is listed below.

1. Identity labeling of the food, referred to as the Statement of Identity (21 CFR 101.3)

a. The identity of the food must appear on the PDP.

b. The identity of the food shall conform to that name established by a standard of 

identity or other regulation, e.g. raw breaded shrimp; or be the common or usual 

name of the food, e.g. breaded fish sticks; or be an appropriately descriptive term or 

fanciful name commonly used by the public for such food.

c. The identity shall be in bold face type.

d. The identity of the food shall be in a type size reasonably related to other printed 

information on the panel.

Note: FDA has determined that this means not less than 1⁄2 the type size of the largest type 

on the PDP.

e. The identity shall be generally parallel to the base on which the package rest.

Note: FDA applies the condition that the identity be not greater than a 22 degree angle from 

the base.

2. Food, designation of ingredients, (21 CFR 101.4).

a. Ingredients required to be declared by regulation shall be listed by common or usual 

name.

b. Ingredients shall be declared in descending order of predominance by weight.

c. The descending order of predominance by weight does not apply to ingredients 

present in amounts of 2 percent or less, however, the statement “contains 2 percent 

or less of “ must precede the ingredients that are listed in other than descending 

order of predominance by weight.

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d. The name of an ingredient shall be a specific name and not a collective (generic) 

name. Example, Pollock instead of fish, sunflower oil instead of vegetable oil.

e. Specific methods of listing ingredients when in their self are made of other 

ingredients are found in 21 CFR 101.4(b)(2)(i & ii). In general the ingredients may be 

listed by common or usual name followed by a parenthetical listing of its ingredients, 

or by incorporating into the statement of ingredients (descending order of 

predominance by weight required) the common or usual name of every component of 

the ingredient without listing the ingredient itself.

f. Listing for specific ingredients is found in 21 CFR 101.4(b)(3-12).

g. And/or listings are allowed for only the following, vegetable oils, leavening agents, 

yeast nutrients, dough conditioners and firming agents.

h. Specific ingredient labeling for spices, flavorings, color agents and chemical 

preservatives is located in 21 CFR 101.22.

i. Minimum type size for ingredients is 1/16 inch based on lower case “o” or “e” when 

both upper and lower case letters are used.

3. Food, Allergen Labeling and Consumer Protection Act (FALCPA) of 2004 (Publication 

108-282)

a. Food Allergen Labeling and Consumer Protection Act (FALCPA) directs all foods 

that are regulated by the Federal Food Drug and Cosmetic Act that are labeled on or 

after January 1, 2006 must comply with FALCPA.

b. Under FALCPA, a major food allergen is an ingredient that contains a protein derived 

from: milk, egg, fish, crustacean shellfish, tree nuts, peanuts, wheat and soybeans.

c. FALCPA requires the species be declared for fish (e.g., bass, flounder, or cod), 

crustacean shellfish (crab, lobster, or shrimp) and tree nuts (e.g., almonds, pecans, or 

walnuts)

d. Allergens present in food must be declared with a “Contains” statement immediately 

below the ingredient statement, in the same size font and print. For example, 

“Contains Shrimp, wheat, soy” would follow the ingredient statement with no 

intervening material.

4. Food, name and place of business of manufacturer, packer, or distributor (21 CFR 101.5).

a. Labels shall specify conspicuously the name and place of business of the 

manufacturer, packer, or distributor.

b. Corporations must specify the actual corporation name which may be preceded or 

followed by the name of the particular division.

c. When the food is not manufactured by the facility whose name appears on the label, 

it shall be qualified by a phrase which identifies the connection; examples, 

manufactured for, distributed by, packed for.

d. The statement of the place of business shall include the street address, city, state and 

zip code. The street address may be omitted if it is shown in a current city directory 

or telephone directory.

e. Minimum type size is 1/16 inch letter height based on lower case "o" or "e" when 

upper and lower case letters are used.

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5. Labeling of food with number of servings (21 CFR 101.8).

a. Labels that bear a representation as to the number of servings contained in the 

package shall bear in immediate conjunction, in the same type size, a statement of the 

net quantity of each serving.

b. Statement may be in terms of household units.

c. Statement must not be misleading in anyway.

d. If nutrition information is required the serving size and net quantity of this serving 

shall be consistent with the requirements set forth in the nutrition labeling regulations 

21 CFR 101.12.

6. Nutrition labeling of foods (21 CFR 101.9).

Due to the length of this section, the only major points will be addressed by the review 

list.

a. Nutritional information is required on all processed food for retail sale.

b. Serving Size shall be expressed in terms of household units, except where such units 

are not applicable, e.g., discrete units such as pieces, portions, etc., or where 

household units are not applicable, ounces may be used with an appropriate visual 

unit of measure.

c. Servings Per Container shall be expressed and be in whole numbers except numbers

between 2 and 5 shall be rounded to the nearest 0.5 serving.

d. Specific nutrients are required to be listed, if present. Calories, Calories from fat, 

Total fat, Saturated Fat, Trans Fat, Cholesterol, Sodium, Total carbohydrates, Dietary 

fiber, Sugars, Protein, Vitamin A, Vitamin C, Calcium and Iron. Values are checked 

per supplied analytical data.

e. Nutrients shall be listed in the increments required by the regulations for each 

nutrients requiring listing.

f. The Nutrition Information shall be displayed in a “Nutrition Facts” panel and the 

panel will conform to the requirements contained in the regulation.

g. The letter height and spacing shall conform to the formatting requirements of the 

regulations.

h. Formatting is dependent space available for Labeling and the correct format for the 

“Nutrition Fact” panel is evaluated on identified space.

7. Declaration of net quantity of content (21 CFR 101.105).

a. The statement shall appear on the PDP and may appear on more than one line.

b. The statement shall be separated by a space equal to the height of the N in net from 

other printed information appearing above or below the declaration and by a space 

equal to twice the width of the N in net from other printed matter to the right and left 

of the statement.

c. The term “net weight” shall be used when stating the net quantity of contents.

d. The statement shall appear in the lower 30% of the PDP.

e. The statement shall be generally parallel to the base of the label.

f. The statement shall comply with the following type sizes: not less than 1/16 in. height 

when the PDP is 5 sq. inches or less, or not less than 1⁄8 in. height when the PDP is 
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more than 5 sq. in. but not more than 25 sq. in., or not less than 3/16 in. letter height 

when the PDP is more than 25 sq. in. but not more than 100 sq. in., or not less than 

1⁄4 in. letter height when the PDP is more than 100 sq. in.; except not less than 1⁄2 in. 

if the PDP is more than 400 sq. in.

g. When upper and lower case letters are used, the measurement for type size is based 

on the lower case “o” or “e”.

h. The statement shall, on packages containing less than 4 pounds, be expressed both in 

ounces and, if applicable, (l lb or more), be followed in parentheses by pounds. [i.e. 24 

oz (1.5 lb)].

i. The statement shall, on packages containing 4 pounds or more, be expressed in 

pounds with any remainder in ounces or common or decimal fractions of the pound. 

Decimal may be carried to no more than two places and common fractions are to be 

such as 1⁄2, 1/3, or 1⁄4.

j. Metric declaration is optional and is not to be part of the required statement through 

the use of parentheses.

Examples: Inch-pound/declaration

Net Wt. 15 oz - 425g voluntary

Net Wt. 48 oz (3 lb)

Net Wt. 4 lb

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ATTACHMENT 1

Section 03: Specification Submittal and Review Instructions

Section 04: Instructions for Inspections for the European Union

Section 05: Instructions for Inspections for the People’s Republic of China
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Section 06: Instructions for DSPC

Section 07: Guidelines for Retail Inspections

Section 08: Guidelines for Meeting the Child Nutrition Requirements of the Food and Nutrition Service 

The purpose of this section establishes standard procedures for use by official establishments 

when submitting fishery product labels and specifications for approval of a Child Nutrition (CN) 

label statement.

General

A. In order to assure that fishery products are approved to bear a CN label statement and can be 

credited toward meeting the meal pattern requirements, USDC and USDA/FNS are cooperating 

in the review and approval process of labels.

B. To assure acceptance by the schools of seafood products produced under Federal inspection, 

the products shall bear, at a minimum, the “Processed Under Federal Inspection” (PUFI) mark. 

The seafood components for all CN labeled products shall possess good flavor and odor 

characteristic of the species as defined in the appropriate U.S. Standards for Grades of Fishery 

Products. For those products bearing the PUFI mark only, the product may contain less than the 

minimum fish flesh requirement identified in the standard, as long as it contains the meat/meat 

alternate requirement of the CN statement.

Procedures

A. Contracting Party must:

1. be a USDC official establishment with an approved contract for a minimum of 4 hours of 

Type I inspection per week;

2. submit and receive approval of specifications used for CN labeled product in accordance 

Part I, Chapter 3, Section 08 of NOAA Inspection Manual 25. Specifications may be 

submitted prior to or along with CN label approval requests, using NOAA Form 89-819;

3. follow the USDA procedures, Child Nutrition Labeling for Seafood Products, identified as 

attachments to this section; and 4. in the absence of the assigned inspector, may leave 

Block 11, USDC Inspector’s Signature, blank and place a statement in Block 14, Remarks, 

indicating the name of the inspector s supervisor with whom the submittal was discussed 

and who authorized the submittal. Such submittals will be verified by the Approving 

Officer prior to action.

NOTE: Contracting parties may initially submit a NOAA Form 89-819 with a draft 

specification and label sketch to the Approving Officer, Documentation Approval 

and Supply Services Section, for review and comment by NMFS and USDA/FNS 

before formal submittal. Inquiries regarding the status of the label review are to be 

directed to the USDC Approving Officer.

B. Inspector will:

1. review appropriate specification and CN label, and sign application form (NOAA Form 

89-819) after ensuring completeness in accordance with the attachments to this section.

2. forward five (5) copies of all labels and specifications with NOAA Form 89-819 to:

Approving Officer, Documentation Approval and Supply Services Section

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3207 Frederic Street, Suite B - P.0. Drawer 1207

Pascagoula, MS 39568-1207

3. retain and file the Field Copy of the NOAA Form 89-819 until receipt of approval notice.

C. Approving Officer:

1. will review the request for completeness, legibility, and accuracy; sign and forward to 

USDA/FNS for CN label statement concurrence.

2. will distribute the approved/disapproved request as follows:

a. original and Inspector Copy - to the USDC inspector who will forward the Original to 

the processor, file the Inspector Copy, and discard the Field Copy.

b. DASS Office Copy - retained by the Approving officer.

c. Regional Office Copy - forwarded to the Chief of the Regional Inspection Branch.

3. will resubmit the contracting party’s corrected application, if necessary.

ATTACHMENT CN Guidelines

Section 09: Instructions for Inspection of Fish Meal Establishments

Section 10: Instructions for Collecting and Submitting Analytical Samples to the National Seafood Inspection 

Laboratory

Section 11: Inspection of Products Subjected to a Process Involving Carbon Monoxide Gas

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Chapter 2 – Inspector Instructions

Section 01: Monthly Activities Report

The Monthly Inspection Activities Report provides information about field inspection activities 

on a current basis. The usefulness of the information depends in large part on its timeliness and 

accuracy. Its availability should reduce the need for hurried calls to field inspection offices for 

information and data.

Instructions

A. Report Preparation:

1. The report will be submitted in memorandum format using the paragraph headings

shown in the attached example (see Attachment #2).

2. Information will be entered under the appropriate paragraph in accordance with the

instructions contained in the example.

3. Paragraphs which are not applicable will be annotated “not applicable,” “N/A,” or

“none.”

4. Much of the information required will be obtained from the Daily Production Summary,

NOAA Form 89-812, submitted by an official establishment’s assigned inspector. To 

further simplify data collection it is suggested that the “Remark” paragraph of the 

Production Summary be used by the inspector to convey information through the Chief 

of the Regional Inspection Branch to the Division Chief. Such usage will eliminate the 

need for additional paperwork, and serve as a permanent record. Information such as lot 

inspection data, FDA liaison visits, etc., could be recorded here.

B. Report Submittal:

The report will be mailed to the Central Office not later than the 16th of the month following the 

month covered by the report.

Section 02: Submittal of Daily and Monthly Summary Reports

The Daily Summary is used to record poundage of products inspected, and/or graded on a daily 

basis for a one month period. The Monthly Summary is used to record data and information 

about contract and lot inspection activities on a monthly basis. The summaries are consolidated 

by the Seafood Inspection Program (SIP) to report regional and national inspection data.

Form Overview

A. Daily Summary (NOAA Form 89-812). (See Attachment #1)

1. This form is used by the inspector and establishment personnel (HACCP) to record, on a 

daily basis, the type of inspection performed on the products and the poundage of 

products inspected. The form’s use will simplify the completion of the Monthly 

Summary.

2. The instructions for completing the form are located on the form’s back and are selfexplanatory.

3. Canned product information is recorded on this form on a 1,000 pound basis and not as a 

number of units of an identified can size.

4. After the data from the daily summary has been transferred to the Monthly Summary, the 

form will be filed in the Regional Inspection Branch (RIB).

B. Monthly Summary (NOAA Form 89-812A) (See Attachment #2)
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1. This form is used by the inspector and establishment personnel (HACCP) to record data 

and information about contract and lot inspection activities on a monthly basis and is 

easily completed from the information recorded on the Daily Summary.

2. As with the Daily Summary, the instructions for completing the Monthly Summary are 

located on the form’s back and are self-explanatory.

3. Canned product information is recorded on this form on a 1,000 pound basis and not as a 

number of units of an identified can size.

4. After the data has been recorded on the Monthly Summary, the form will distributed as 

follows:

a. Original - FIS14 - Approving Officer, Seafood Inspection Program, Technical Services 

Branch, DASS, P.O. Drawer 1207, Pascagoula, MS 39568-1 207.

b. Copy – Chief, Regional Inspection Branch.

c. Copy – Inspector’s file.

Commodity Codes List (See Attachment #3):

A. The Commodity Code numbers for completion of NOAA Form 89-812 and NOAA Form 

89-812A are contained in Attachment #3. The established code numbers are to be used in 

identifying the various commodities that are inspected.

B. As with previous releases of the Commodity Code List, inspectors and establishment 

personnel will not construct codes for commodities that may be produced that have no readily 

identifiable code. Refer to the unclassified codes.

C. As new codes are developed, they will be distributed by the normal Quarterly Mailouts.

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ATTACHMENT #1

Guidelines and Reminders for Completing the Daily Summary

Select the Type of Inspection by checking either “In-Process” or “Lot”. A separate form must be 

completed for each type of Inspection or if the poundage is for non-human food or rejected 

products.

“In-Process” inspection means that sanitation and processing methods for the product lot 

were considered as part of the inspection. That is, the product was inspected and certified 

under either a Type 1, IQA, or HACCP contract.

“Lot” inspection means the product lot was inspected as an end-item inspection only –

regardless of whether the plant had a Type 1, HACCP, IQA, or Type 3 contract. Therefore, 

for product bearing the USDC Lot Inspected mark, the Type of Inspection is “Lot”.

Under “REGION”, enter “N”, “S”, or W” to represent the region in which the facility is located.

Under “STATE”, enter the two character abbreviation for the state in which the facility is 

located.

Under “CONTR NO”, enter the last four digits of the contract number (e.g., 0001).

Under “MONTH”, enter the two-digit month number in which the inspection occurred (e.g., 05 

for May, 11 for November)

Under “YEAR”, enter the four digit year number (e.g., 2004).

Under “PLANT NAME”, enter the name of the facility. Abbreviations are OK.
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Data are counted according to the specific marks on the container(s). If the ‘Officially Sampled’

stamp or the ‘Accepted Per Specification’ stamp is the only mark on the master container, report 

the data under “NO MARK”.

Do Not Double Report! Do not duplicate where you report the data – it goes under only one 

category! If there is a situation (e.g., product to China) where an exported product bears a mark 

on the container (e.g., USDC Lot Inspected), include the data in “Export”. If it is unknown 

whether the product will be exported, record the data as appropriate at the time of reporting.

Rejections – If a lot of product is presented (e.g., as Grade A) and doesn’t pass, the data are 

reported as “Rejected.” If, however, the same lot is reworked as a new lot, is re-inspected and 

passed, then the data are recorded in the “Inspected and Passed” section. That is, the data are 

reported in both sections. If the rejected lot is NOT reworked, inspected and passed, then the 

data are reported only as “Rejected”.

Use abbreviated descriptions for the reason for the rejection; such as

“Adulterated”: meets the definition of adulterated food under Section 402 of the FD&C Act.

“Misbranded”: mislabeled, misrepresentation – meets the definition of misbranded under 

Section 403 of the FD&C Act.

“Substandard Quality”: fails to meet minimum quality requirements of a U.S. Grade Standard 

or Standard of Identity under Title 21.

“Failed grade/spec”: fails to meet intended grade or quality specification.

REMINDER: Be certain that the data are correctly expressed in thousands. That is, 1,534,834 

pounds is 1,534.8 thousands of pounds.

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ATTACHMENT #2

Guidelines and Reminders for Completing the Monthly Summary

Select the Type of Inspection by checking either “In-Process” or “Lot”. A separate form must be 

completed for each type of inspection or if the poundage is for non-human food products.

“In-Process” inspection means that sanitation and processing methods for the product were 

considered as part of the inspection. That is, the product was inspected and certified under 

either a Type 1, IQA, or HACCP contract.

“Lot” inspection means the product was inspected as an end item inspection only –

regardless of whether the plant had a Type 1, HACCP, or Type 3 contract. Therefore, for 

product bearing the USDC Lot Inspected mark, the Type of Inspection is “Lot”.

Under “REGION”, enter “N”, “S”, or “W”, representing the region in which the facility is 

located.

Under “STATE”, enter the two character abbreviation for the state in which the facility is 

located.

Under “CONTR NO”, enter the last four digits of the contract number (e.g., 0001).

Under “MONTH”, enter the two-digit month number in which the inspection occurred (e.g., 05 

for May, 11 for November).

Under “YEAR”, enter the four digit year number (e.g., 2004).
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Under “PLANT NAME”, enter the name of the facility. Abbreviations are OK.

Data are counted according to the specific marks on the container(s). If the “Officially Sampled’

stamp or the ‘Accepted Per Specification’ stamp is the only mark on the master container, report 

the data under “NO MARK”.

Do Not Double Report! Do not duplicate where you report the data it goes under only one 

category. If there is a situation (e.g., product to China) where an exported product bears a mark 

on the container (e.g., USDC Lot Inspected), include the data in “Export”. If it is unknown 

whether the product will be exported, record the data as appropriate at the time of reporting.

Rejections – If a lot of product is presented (e.g., as Grade A) and doesn’t pass, the data are 

reported as “Rejected.” If, however, the same lot is reworked as a new lot, is re-inspected and 

passed, then the data are recorded in the “Inspected and Passed” section. That is, the data are 

reported in both sections. If the rejected lot is NOT reworked, inspected and passed, then the 

data are reported only as “Rejected”.

Use abbreviated descriptions for the reason for the rejection; such as

“Adulterated”: meets the definition of adulterated food under Section 402 of the FD&C Act.

“Misbranded”: mislabeled, misrepresentation--meets the definition of misbranded under 

Section 403 of the FD&C Act.

“Substandard Quality”: fails to meet minimum quality requirements of a U.S. Grade Standard 

or Standard of Identity under Title 21.

“Failed grade/spec”: fails to meet intended grade or quality specification.

REMINDER: Be certain that the data are correctly expressed in thousands. That is, 1,534,834 

pounds is 1,534.8 thousands of pounds.

ATTACHMENT #3

Commodity Codes

Section 03: Procedures for Processing Requests for Type I Inspection 

It is important that applications for inspection service filed in accordance with the referenced 

regulations be processed expeditiously. Unnecessary delays in responding to requests for 

inspection service may have an adverse effect on the industry’s ability to sell, market and/or 

distribute the product and further, have an adverse effect on the DOC Seafood Inspection 

Program (SIP) inspection service image. 

It is DOC SIP policy that:

A. Contracts will not be approved for less than four (4) hours of Type I inspection services per 

week. This does not preclude the negotiation of contracts which will run for specified time 

periods, such as those for seasonal products.

B. Contracts will be reviewed and adjusted as necessary when the actual number of inspection 

hours used by an official establishment varies four (4) hours or more per week from the 

contractual agreement.

C. All contractual amendments will be on a mutually agreed upon basis.

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D. Plants cannot be guaranteed inspection services beyond the period of time stipulated in the 

contract.

Procedures

A. Regional Inspection Branch (RIB)

1. Upon receipt of an application for contract inspection it should be reviewed to ascertain 

that information necessary to perform an inspection on the processed product(s) is 

furnished as required by 50 CFR 260.15.

2. The applicant should be furnished a copy of the regulations and advised of the 

requirements for plants operating under inspection on a contract basis contained therein. 

(50 CFR 260.96)

3. An initial plant survey will be conducted to determine whether the plant sanitation, 

hygienic practices, and subject processes are in accordance with DOC requirements. If 

necessary, a final plant survey will be conducted following the plant’s correction of 

discrepancies noted on the initial survey.

4. When it has been determined that the plant facilities, etc., are in accordance with DOC 

regulations, the inspection supervisor will determine the inspection man-hours necessary 

to perform the requested inspection. This should initially be based on the best estimate of 

the number of hours needed to produce the products for which inspection is desired.

5. The RIB will advise the applicant of his responsibilities as stated in 50 CFR 260.97.

6. The Chief, RIB, will forward the completed application for inspection services to the 

Director, DOC SIP, with a recommendation for approval. A copy of the final plant 

survey report and a surety bond should accompany the application.

B. Inspector Assignment

1. When the number of inspection man-hours required has been determined, the 

supervisory inspector shall promptly advise the applicant, in writing, if an inspector can 

be assigned for duty immediately.

2. If an inspector is not immediately available for assignment to the plant, the supervisory 

inspector will advise the applicant, in writing, of the non-availability of an inspector, and, 

if known, the approximate date of availability.

3. If delays are encountered in obtaining an inspector, such as lack of personnel availability, 

hiring restrictions, etc., the applicant will be advised, in writing, of the reason therefore.

4. Copies of all correspondence relative to applications for inspection service will be 

furnished to Headquarters.

NOAA Form 89-800, Contract of Agreement For:

A. The information to complete the form must be received from the applicant, and the 

information required by NOAA Form 89-800 is self-explanatory (see Attachment)

B. Paperwork Reduction Act.

1. NOAA Form 89-800, “Contract of Agreement For” is one of several NOAA Forms 

identified by the Office of Management and Budget (OMB) as subject to the Act. 

Participants in the USDC Seafood Inspection Program are encouraged to read the 

Information Collection Notification by OMB prior to completing the form.

2. Information Collection Notification, NOAA Form 89-800

a. This information collection is authorized under 50 CFR §260.96. The information will 

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be used to register participants requesting regular inspection services on a contractual 

basis. Any changes to the contract require a contract amendment, using this form. 

Public reporting burden for this collection of information is estimated to average 5 

minutes per response, including the time for reviewing instructions, searching existing 

data sources, gathering and maintaining the data needed, and completing and 

reviewing the collection of information. Send comments regarding this burden 

estimate or any other aspect of the collection of information, including suggestions 

for reducing this burden to the USDC Seafood Inspection Program, 1315 East-West 

Highway, Silver Spring, MD 20910. This information is required in order to receive 

inspection services on a contract basis.

b. Notwithstanding any other provision of the law, no person is required to respond to, 

nor shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the Paperwork Reduction Act, unless that 

collection of information displays a currently valid OMB Control Number.

Section 04: Procedures for Processing Requests for Type II Inspection

It is important that applications for lot inspection service be complete and processed 

expeditiously. Incomplete information or improper/delayed handling may result in 

misunderstandings of inspection needs, the inability of the requestor to meet the certification 

needs of the buyer and unnecessary costs to conduct the inspection.

Procedures

A. Requests for inspection may be made by telephone or in writing to the lot inspection office 

nearest the product location.

B. The applicant is responsible for making the product available at its storage location.

C. Generally, requests for lot inspection services are received by telephone or by e-mail. 

Whether received by telephone or in writing, the information contained on NOAA Form 89-814, 

Request for Inspection Services, must be obtained from the applicant. If written by the applicant, 

he/she must sign the request, and the completed request must be filed with the certificate issued 

upon completion of the inspection. The information required of NOAA Form 89-814 is selfexplanatory (see attachment). It is vital that there be a clear understanding between the applicant 

and the inspection office as to the type of inspection requested, i.e., what does the applicant want 

to know about the product. It is also essential that the applicant clearly state what the inspector is 

to do with the samples following completion of their examination. This information should be 

recorded in the form block entitled, “Disposition of Samples.”

D. Sampling. Sample size is determined using the appropriate sampling table of the regulations, 

50 CFR 260.

Samples are drawn randomly from the cartons on the various pallets and from random 

positions on the pallets. If the lot consists of more than one production date code the 

inspector should sample as many different codes as possible. Samples are inspected in 

accordance with the standard, specification or other document requested by the applicant.

E. Certification. Certificates are issued according to the type of sampling and inspection 

performed, i.e., lot, unofficial, export, etc.

F. Fees and Charges. The applicant is responsible for all fees and charges associated with the 

inspection of the product. The Regional Inspection Branch (RIB) will, under separate cover, 
NOAA HANDBOOK 25

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charge the applicant for the associated fees and charges of the inspection and submit the bill to 

NOAA Finance, with NOAA Finance billing the applicant.

Paperwork Reduction Act

1. NOAA Form 89-814, Request of Inspection Services is one of several NOAA Forms 

identified by the Office of Management and Budget (OMB) as subject to the Act. Participants in 

the USDC Seafood Inspection Program are encouraged to read the Information Collection 

Notification by OMB prior to completing the form.

2. Information Collection Notification, NOAA Form 89-814.

a. This information collection is authorized under 50 CFR §260.15. The information will be 

used to record applicants requesting inspection services on non-contractual basis. Public 

reporting burden for this collection of information is estimated to average 5 minutes per 

response, including the time for reviewing instructions, searching existing data sources, 

gathering and maintaining the data needed, and completing and reviewing the collection 

of information. Send comments regarding this burden estimate or any other aspect of the 

collection of information, including suggestions for reducing this burden to the USDC

Seafood Inspection Program, 1315 East-West Highway, Silver Spring, MD 20910. This 

information is required in order to receive inspection services on non-contract basis.

b. Notwithstanding any other provision of the law, no person is required to respond to, nor 

shall any person be subject to a penalty for failure to comply with, a collection of 

information subject to the requirements of the Paperwork Reduction Act, unless that 

collection of information displays a currently valid OMB Control Number.

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ATTACHMENT

Section 05: Procedures for Processing Requests for Type III Consultation Inspections

Section 06: Reporting Violations of the Agricultural Marketing Act and Regulations Governing Processed Fishery 

Products
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The purpose of this policy is to provide the basic information necessary to assist inspectors in 

reporting violations of the Agricultural Marketing Act and the regulations promulgated 

thereunder, i.e., 50 CFR 260; and to point out evidence which may be necessary to prepare cases 

involving violations of the law and regulations for debarment action. The procedures described 

are general guidelines and not intended to be inflexible rules.

The Agricultural Marketing Act of 1946 (the Act), as amended, provides for the voluntary 

inspection and grading of numerous agricultural commodities, including fish and shellfish, under 

regulations promulgated by the U.S. Department of Commerce (USDC). The Act protects 

consumers against false claims concerning the Federal inspection or grading of seafood, and 

makes it a criminal offense for anyone knowingly to represent that seafood has been officially 

inspected or graded under the provisions of the Act when, in fact, it has not been so inspected or 

graded.

Strict enforcement of the Act is necessary to protect consumers and processors who operate 

under the USDC Voluntary Seafood Inspection Program. Our goal is to assure full compliance 

with the Act and regulations. One method of encouraging compliance is for the Consumer Safety 

Officer/Inspector to advise interested persons and processing firms of the Act’s requirements on 

a timely and continuing basis. Inspectors should be thoroughly familiar with the Act and USDC 

regulations so they may effectively communicate with concerned parties.

The following procedures must be followed whenever violations to the Act are suspected:

A. Establishing Proof of Alleged Irregularities or Violations. It is necessary that each instance of 

detected or reported irregularity or violation of the Act or its implementing regulations is 

thoroughly investigated. The information contained in Attachment #1 will be helpful to 

inspection personnel during the investigative processes.

B. Investigating and Reporting Alleged Irregularities and Violations.

1. Assigned Inspector: When an irregularity or violation is detected by or reported to the assigned 

inspector he/she shall:

a. Notify his/her supervisor immediately by the most expeditious means.

b. Secure evidence to support a possible debarment, suspension, or legal action. See 

Attachment #2.

(1) Observe, when possible, the irregularity or violation in progress and record the incident, 

noting the date and time of occurrence. A witness, if possible, should verify the irregularity 

or violation.

(2) Explore all recorded sources which could provide reliable information relevant to the 

incident.

(3) Interview individuals who might have knowledge of the incident.

c. Prepare, with the direct assistance of the supervisor, a written draft of the situation 

including all pertinent information available. See Attachments #3 and #4.

d. Forward a copy of the report through the supervisor to the Regional Chief for review.

2. Supervisor: When a supervisor receives a report of an alleged violation he/she shall:

a. Assist the assigned inspector in developing and conducting the investigation.

b. Assist the assigned inspector in preparing a written draft of the incident to assure that all 

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information, evidence, and reports from the assigned inspector are complete, accurate, and 

properly documented.

c. Advise the Regional Chief of the situation and keep him/her informed of developments.

3. Regional Chief: The Regional Chief shall:

a. Provide necessary assistance to the supervisor to assure that the investigation is properly 

conducted.

b. Review the draft report prepared by the assigned inspector for completeness, accuracy, 

proper documentation, etc., and prepare the final report for submission to Headquarters.

c. Keep Headquarters advised of the status of the investigation.

4. Headquarters: The Headquarters staff shall:

a. Initiate all correspondence from NMFS to the alleged violator when the investigation 

conducted by field inspection personnel indicates that a violation of the Act or its 

implementing regulation did in fact occur. The correspondence will specify the details of 

the alleged violation and the provisions of the law; and will provide the opportunity for the 

violator to present written or oral views concerning the alleged violations.

b. Act in a liaison capacity with appropriate Government agencies (i.e., Food and Drug 

Administration, Federal Trade Commission, Department of Defense, Department of 

Justice, etc.), which may be involved in investigating products, records, etc., which are 

located in facilities outside of NMFS jurisdiction.

c. When substantial evidence of a violation exists, (a) refer the matter to the Office of General 

Counsel with a request to initiate debarment action or (b) forward the case to the 

Department of Justice recommending the initiation of criminal action.

ATTACHMENT #1

DEVELOPING PROOF

A. Agricultural Marketing Act

The purpose of the Act is to provide for the voluntary inspection and grading of agricultural 

products, e.g., to “inspect, certify, and identify the class, quality, quantity, and condition of 

agricultural products.” No person is required to use the services provided for in the Act. The 

Secretary of Commerce has issued extensive regulations under the Act providing for the 

inspection, sampling, and grading of various commodities, and the issuance of licenses to 

perform such functions. This Act also provides the criminal penalties which may be assessed 

upon conviction for violations of the Act. It is the responsibility of inspectors to check on 

reported irregularities and/or investigate alleged violations of the Act. The Agricultural Marketing 

Act provides sanctions as follows:

“Whoever knowingly shall falsely make, issue, alter, forge, or counterfeit any official certificate, 

memorandum, mark or other identification, or device for making such mark or identification, 

with respect to inspection, class, grade, quality, size, quantity, or condition, issued or authorized 

under this section or knowingly cause or procure, or aid, assist in, or be a party to, such false 

making, issuing, altering, forging, or counterfeiting, or whoever knowingly shall possess, without 

promptly notifying the Secretary of Agriculture or his representative, utter, publish, or use as true, 

or cause to be uttered, published or used as true, any such falsely made, altered, forged, or 

counterfeited official certificate, memorandum, mark, identification, or device, or whoever 

knowingly represents that an agricultural product has been officially inspected or graded (by an 

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authorized inspector or grader) under the authority of this section when such commodity has in 

fact not been so graded or inspected shall be fined not more than $1,000 or imprisoned not more 

than one year, or both.”

(7 U.S.C. 1622(h))

B. Information Required Defined:

The following information should be helpful in establishing and reporting alleged irregularities 

and/or alleged violations. The chart lists the elements of the various offenses prohibited by 

Section 203(h) and the subsequent information describes the meaning of the various terms used 

in the law.

Evidence is needed on one or more of the elements in each column as indicated.

1. Knowingly Falsely

1. Make

2. Issue

3. Alter

4. Forge or

5. Counterfeit

Official

1. Certificate

2. Memorandum

3. Mark or other 

identification or

4. Device for making such 

mark or identification

With respect to inspection, class,

grade, quality, size, quantity, or

condition, issued or authorized under 

Sec. 203

2. Knowingly 1. Cause or procure

2. Aid

4. Assist in or

5. Be a party to

Such false

1. Making

2. Issuing

3. Altering

4. Forging or

5. Counterfeiting

3. Knowingly 1. Possess, without promptly notifying the Secretary of 

Agriculture or his representative

2. Utter

3. Publish

4. Use as true or

5. Cause to be

a. Uttered

b. Published or

c. Used as true

Any such falsely made, altered, forged, 

or counterfeited official

1. Certificate

2. Memorandum

3. Mark

4. Identification or

5. Device

4. Knowingly Represent that an agricultural product has been officially 

inspected or graded under the authority of Sec. 203

When such product has not been so 

inspected or graded

1. Knowingly: Defendant’s knowledge of the law is not required, but the defendant must have 

knowledge of the facts constituting the offense. Defendant is responsible only for intentional, 

rather than accidental or inadvertent, acts. For example, in order to establish the offense of false 

making of an official identification by use of an approved U.S. Grade A label on fishery products 

that had not been graded under the Act, proof would be needed to show that the defendant knew 

that the label was applied to non-graded fishery products, but it would not be necessary to show 

that the defendant knew that such application was illegal. If the label was accidentally or 

inadvertently applied, no offense was committed.

Falsely Make: Proof of falsity and proof of making must be shown. For example, to prosecute 

defendant for falsely making an official identification, it would be proper to prove that he applied 

an approved U.S. Grade A label to fishery products which had not been graded under the Act. 

Falsely making is deemed to include, among other things, manufacturing of official devices 

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without authorization, inserting incorrect information in an official certificate, and applying an 

official grade or inspection mark to fishery products which have not been graded or have not 

been inspected under the Act. The same activities may constitute falsely making and 

counterfeiting.

Falsely Issue: Issue means to put into circulation. The offense of falsely issuing is deemed to 

include the distribution of labels bearing official grade identifications by a label or box 

manufacturer to plants not eligible to use such labels when there is proof that the manufacturer 

knew that the labels would be used on products for which they were not eligible.

Falsely Alter: Proof is needed of alteration and of falsity. For example, proof that the defendant 

altered an inspection certificate issued under the Act so as to show more product had been 

inspected or graded than was actually the case.

Forge: This offense consists of the false making or material altering, with intent to defraud, of any 

writing which, if genuine, might be of legal efficacy. For example, the writing of an inspector’s 

signature on a certificate by someone other than the inspector himself and without his consent.

Counterfeit: This offense consists of the making of any official certificate, memorandum, mark, 

or other identification or device under the Act without authority. Proof is needed that the article 

made closely resembled and was represented to be, but was not, the genuine article and that the 

defendant made it without authority from this Department.

Official Certificates, Memoranda, Marks, other Identifications and Devices: The Act prohibits the 

offenses specified above only with respect to certificates, memoranda, marks, other 

identifications, and devices which are defined by the regulations under the Act as “official.” (See 

260.7 of the voluntary fishery products inspection and certification regulations.) 

With Respect to Inspection, Class, Grade, Quality, Size, Quantity or Condition Issued or 

Authorized Under Section 203: The certificates, memoranda, marks, other identifications, or 

devices must relate to inspection, class, grade, quality, size, quantity, or condition and must be 

issued or authorized under Section 203 of the Agricultural Marketing Act.

2. Knowingly: See remarks under 1. For an offense in this group, there must be enough

evidence to establish a false making, issuing, altering, forging, or counterfeiting of an official 

certificate, memorandum, mark, or other identification as discussed under 1., and proof that the 

defendant knowingly caused, procured, aided, assisted in, or was a party to such offense.

3. Knowingly: See remarks under 1.

Possess: Need proof that the defendant consciously had possession and did not promptly notify 

the Secretary of Commerce or his representative of such possession.

Utter, Publish: These terms mean about the same thing. Need proof that the defendant put into 

circulation or made public as genuine the offending article involved. 

Use as True: Need proof of use by defendant under circumstances showing the offending article 

was represented to be genuine. For example, selling fishery products bearing pressure-sensitive 

stickers with counterfeit U.S. Grade A marks.
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Cause to be Uttered, Published, or Used as True: Need proof of acts by the defendant which 

caused the utterance, publication, or use as true of the offending article. For example, a statement 

of an employee of the defendant that the defendant ordered him to apply pressure- sensitive 

stickers bearing counterfeit U.S. Grade A marks to non-graded fishery products and deliver them 

to a purchaser.

Falsely Made, Altered, Forged, or Counterfeited Official Certificate, Memorandum, Mark, Other 

Identification, or Device: See remarks under 1.

4. Knowingly: See remarks under 1.

Represent That an Agricultural Product Has Been Officially Inspected or Graded Under the Act: 

Need proof of such a representation with respect to fish and shellfish, and products thereof. The 

representation may be made in any way that conveys the idea to the public that the product was 

officially inspected or graded under the Act. For example, by label or sticker, retail store window 

sign or counter placard, store employee’s statement or newspaper advertisement; and either by 

use of an official inspection or grading mark or by descriptive words. Report all the facts in these 

cases very precisely. Give exact words used that are deemed to constitute the representation. 

Obtain copies of labels, stickers, or advertisements if possible. Determine the quality of the 

fishery products under the United States standards or indicate that such a determination could 

not be made, in each case involving representation of grade. When it appears appropriate, 

purchase one or more packages of the product allegedly in violation. Do not remove or alter 

anything printed or written thereon. Hold product for future reference or evidence to be used in 

connection with a court action.

C. Typical Violations of the Agricultural Marketing Act

1. Advertising by trade periodical, newspaper, or circular, U.S. inspected or graded fishery 

products when such products have not been so inspected or graded.

2. Using U.S. inspection or grade marks in connection with fishery products not so inspected or 

graded.

3. False alteration of official memoranda or certificates.

ATTACHMENT #2

INVESTIGATING ALLEGED VIOLATIONS

A. Information Sources

To check on or investigate an alleged violation of the Agricultural Marketing Act, we must first 

have some indication that a violation has taken place. Such information can be developed in 

various ways. A common source is from someone in the fishery products business. Since the 

industry is highly competitive, it would be rare if any person or firm could operate in violation of 

the Agricultural Marketing Act for a long period of time without having their actions detected 

and reported to us. On many occasions we may get valuable information from city, county, or 

state officials and officials of other Federal agencies, particularly those in the area of health and 

food control. Inspectors should make it their business to know these people and to be helpful to 

them in return for their help to us. 

Many good leads come from inspectors as a result of observations made in the course of their 

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duties in official establishments and elsewhere. Each irregularity or violation should be followed 

through. The preliminary investigation should be made in such a way that it will not be 

embarrassing to the person or firm suspected in the event that there is no foundation to the 

alleged violation. If an informant requests that his identity be kept secret, such a request must be 

strictly honored; otherwise, sources of information would disappear. In some cases, the 

informant may be an employee of the company which is the alleged offender and the situation 

should be handled in such a manner that his position would not be jeopardized. Maintenance of 

good relationships with members of industry and the public is essential. Situations should never 

be permitted to develop where any of these contacts will be harmed without just reason. 

Investigations should always be conducted in such a manner as to avoid damage to the reputation 

of innocent persons. Inspectors should make sure that anyone who might be a potential source of 

reliable information knows them and knows where and how they may be reached. Regardless of 

how the information is presented, we should be sure they know our office address, phone 

number, and office hours.

B. Interviews

Information discussed during an interview may be extremely important in the event legal action 

becomes necessary or is deemed appropriate. Therefore, information which will be of value as 

evidence should be recorded in the form of a written signed statement. Such a policy will protect 

the inspector against claims by witnesses of being misquoted or misunderstood and will fortify 

the witness in resisting pressure to alter his testimony.

Simple, clear-cut language, readily understood, and in words customarily used by the person 

making the statement should be used. Under no circumstances should intimidation, inducement, 

or force of any kind be used against the subject of an investigation (or any other person) in order 

to obtain a statement. Methods of obtaining signed statements will vary with individual 

inspectors. Some will emphasize the importance to all involved that a true recital of the facts 

should be established and some will point out that this insures that the signer’s side of the case 

will be accurately presented. Others will show by their very manner that they take it for granted 

that the subject would be willing to sign a statement of truth. In the event the interviewee 

furnishes sufficient information for the preparation of a statement and afterwards declines to sign 

the statement, the unsigned statement should be retained for use in the report. Reasons for 

refusal to sign should be reported. Under no circumstances should an interviewee be provided 

with a copy of an unsigned statement. They may be provided with a copy of a signed copy upon 

request.

C. Proof of Violation

To secure successful prosecution, we must have proof of the alleged violation. This is often 

difficult to get, but without proof we have no case against the alleged violator. As an example, we 

cannot assume that fishery products were not federally graded and/or inspected; rather, we must 

prove that fishery products were not so graded or inspected. The Office of the General Counsel 

and the Justice Department will not take legal action unless there is good and sufficient evidence. 

The proof of a violation must be based on evidence. This may be in the form of personal 

observation, copies of invoices, bills of lading, freight waybills, cancelled checks, labels, sections 

of containers, receipts, receiver’s statements, and statements made by those having knowledge of 

the facts. The more clearly this evidence proves that a specified amount of fishery products 

bearing official inspection or grade marks was not inspected or graded, the better the case.
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ATTACHMENT #3

DEVELOPING THE REPORT

A. Initiating Reports

The reporting of information developed in connection with an alleged violation is a very 

important phase of investigation work. Each and every step taken must be clearly documented, 

fully explained, and spelled out in the report. Both positive and negative evidence must be 

included, otherwise, the reviewer may wonder, “Did he check on ________ _________ _______ 

_________?” Reports must be factual and based on observations and evidence and not on 

assumptions or opinions. The inspectors’ reports should be prepared in a clean, neat, and 

grammatically correct manner. Just as people in the NMFS may form an opinion of the inspector 

from the appearance of the records he prepares, so people outside our organization will form an 

opinion of the NMFS from the documents we present. You can imagine the reaction of the 

Office of the General Counsel or a U.S. Attorney when reviewing a narrative containing 

incomplete sentences, misspelled words, erasures, and improperly documented evidence. Their 

interest in proceeding with a poorly presented case is reduced while a well-documented report 

will naturally bring better results.

The following self-examination shall be made in preparing a case file:

1. Is there sufficient evidence to support the allegation?

2. Does it include all the facts at hand?

3. Are there references to supporting documents in the narrative?

4. Are the narrative and other documents properly paragraphed? Margin neat? Correctly 

punctuated? Acceptably free of smudges and erasures? Properly assembled?

5. Have I correctly identified the legal and/or ownership status of the firm or person involved?

6. Have I checked references to names, addresses, dates, and numbers in different parts of the 

report so I am sure they are accurate and identical?

A complete case file on a violation should contain such information as the reason for the 

investigation, the manner in which the investigation was conducted, the evidence secured, and the 

conclusion of the inspector. The numbered exhibits in the file should be referred to by number as 

the report progresses.

B. Writing Reports

An investigation report may be generally divided into four sections, which should be clearly 

defined either by headings or paragraphing. The sections can be generally categorized (1)

Introduction and Justification, (2) Synopsis or Brief, (3) Details, and (4) Conclusions.

1. The opening paragraph of the report should contain the true and/or legal name and 

address of the person, partnership, company, or corporation under investigation. Citation 

of the statute or the regulation under which the investigation is being made should be 

shown. In case the individual or company does business under other names and at 

different addresses than its legal name and address, these should also be recorded.

2. A brief summary of the evidence as disclosed by the investigation is helpful to persons who 

are required to review reports. The synopsis or brief should be limited to one short 

paragraph where possible, except that in the case of lengthy and complex reports, a longer 

brief may be necessary. In short reports dealing with relatively simple subject matter, the 

brief or summary may be eliminated. In no case, however, should the brief exceed the 

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detailed reporting of the case.

3. In the ‘Details’ section of the report, the inspector should narrate in detail how he 

conducted the investigation and obtained evidence of the violation. Evidence per se is of 

the utmost importance in dealing with these violations but the method by which evidence 

is obtained is also important. In charging wrong-doings, the burden of proof is on the 

Government. Therefore, extreme care should be exercised so that the person who is 

suspected shall not be deprived of rights guaranteed by the law and rigidly enforced by the 

courts. In narrating the details of an investigation, the inspector should refrain from 

imparting extraneous details and trivia which have no bearing on the issues. Reviewing 

reports loaded with details which are not germane can become extremely tedious and 

consequently the report may completely fail to inform the reader of the subject. The 

inspector must be able to assure himself that he can support any statements made by him 

in the report of investigation. All supporting evidence should be described, and the resting 

place of such evidence should be carefully noted in the report, as in the work papers, etc.

4. Finally, the ‘Conclusion’ section of the report should relate the conclusions formed by the 

inspector on the basis of the evidence obtained during the investigation. Since the 

inspector is neither the prosecutor nor the judge, it is unnecessary to go into great detail as 

to the value of the evidence, but he can briefly describe his attitude toward the allegation 

based on the evidence.

C. Sources of Information

1. Commercial bills of lading and shippers certificates are excellent evidence that a product 

has moved interstate. This is especially true if we can also secure a copy of the delivery 

receipt.

2. Copies of invoices, delivery receipts, order forms, and cancelled checks.

3. Labels and master cartons from fishery products involved.

4. Reference to letters of caution or correspondence establishing knowledge of the respective 

law violated. If possible, two sets of all papers making up the file should be forwarded to 

the Headquarters office. Recommendations may be made by the inspector by a separate 

memorandum.

D. Conclusion

We must bear in mind that each violation is different and the development of the investigation is 

different. We must also bear in mind our goal is to obtain compliance with the law and related 

regulations under which the inspection and grading program operates. As indicated previously, 

criminal and/or debarment action is usually reserved for those persons or firms who, by record, 

have knowledge of the provisions of the law referenced herein and who in turn subsequently, 

with intent, violate this law or regulation.

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ATTACHMENT #4

REPORT FLOW

VIOLATIONS OF THE AGRICULTURE MARKETING ACT AND

REGULATIONS GOVERNING PROCESSED FISHERY PRODUCTS

Section 07: Reporting Violations of the Food, Drug and Cosmetic Act to the Food and Drug Administration

 Table of Contents

Supervisor

Notifies - Reviews Reports

Regional Chief

Notifies – Coordinates Investigation

Reviews Reports

Headquarters

Notifies – Conducts Liaison

Institutes Investigation Requests

Other Government Agencies

Information and Investigation

Alleged Violator

Associate Director

Resource Utilization

Department of

Justice

Inspector

Receives - Investigates

Notifies - Reports

Office of 

General 

Counsel

Written and oral reports

Provides assistance as needed
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This section provides basic information necessary to assist inspectors in reporting violations of 

the Agricultural Marketing Act and the regulations promulgated thereunder, i.e., 50 CFR 260; and 

to point out evidence which may be necessary to prepare cases involving violations of the law and 

regulations for debarment action. The procedures described are general guidelines and not 

intended to be inflexible rules.

General

The Agricultural Marketing Act of 1946, as amended, provides for the voluntary inspection and 

grading of numerous agricultural commodities, including fish and shellfish under regulations 

promulgated by the U.S. Department of Commerce (USDC). The Act protects consumers against 

false claims concerning the Federal inspection or grading of seafood, and makes it a criminal 

offense for anyone knowingly to represent that seafood has been officially inspected or graded 

under the provisions of the Act when, in fact, it has not been so inspected or graded. Strict 

enforcement of the Act is necessary to protect consumers and processors who operate under the 

USDC Voluntary Fishery Products Inspection Program. Our goal is to assure full compliance 

with the Act and regulations. One method of encouraging compliance is for the fishery products 

inspector to advise interested persons and processing firms of the Act’s requirements on a timely 

and continuing basis. He should be thoroughly familiar with the Act and USDC regulations so he 

may effectively communicate with concerned parties.

Procedures

A. Establishing Proof of Alleged Irregularities or Violations. It is necessary that each instance of 

detected or reported irregularity or violation of the Act or its implementing regulations be 

thoroughly investigated. The information contained in ATTACHMENT #1 will be helpful to 

inspection personnel during the investigative processes.

B. Investigating and Reporting Alleged Irregularities and Violations.

1. Assigned Inspector. When an irregularity or violation is detected by or reported to the 

assigned inspector he shall:

a. Notify his supervisor immediately by the most expeditious means.

b. Secure evidence to support a possible debarment, suspension, or legal action. See 

ATTACHMENT #2.

(1) Observe, when possible, the irregularity or violation in progress and record the 

incident, noting the date and time of occurrence. A witness, if possible should verify 

the irregularity or violation.

(2) Explore all recorded sources which could provide reliable information relevant to 

the incident.

(3) Interview individuals who might have knowledge of the incident.

c. Prepare, with the direct assistance of his supervisor, a written draft of the situation 

including all pertinent information available. See Attachments #3 and #4.

d. Forward a copy of the report through his immediate supervisor to the Chief Inspector 

for review.

2. Area Supervisor. When an area supervisor receives a report of an alleged violation he shall:

a. Assist the assigned inspector in developing and conducting his investigation.

b. Assist the assigned inspector in preparing a written draft of the incident to assure that all 

information, evidence, and reports from the assigned inspector are complete, accurate, 

and properly documented.

c. Advise the Chief Inspector of the situation and keep him informed of developments.

3. Chief Inspector. The Chief Inspector will:

a. Provide necessary assistance to the Area Supervisor to assure that the investigation is 
NOAA HANDBOOK 25

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properly conducted.

b. Review the draft report prepared by the assigned inspector for completeness, accuracy, 

proper documentation, etc.; and prepare the final report for submission to the Chief, 

Fishery Products Inspection and Safety Division.

c. Keep the Director of Inspection Services advised of the status of the investigation.

4. Director of Inspection Services. The Director of Inspection Services will:

a. Keep the Chief, Fishery Products Inspection and Safety Division advised of the case 

status.

b. Act in a liaison capacity with appropriate Government agencies (i.e., Food and Drug 

Administration, Federal Trade Commission, Department of Defense, Department of 

Justice, etc.), which may be involved in investigating products, records, etc., which are 

located in facilities outside of NMFS jurisdiction.

5. Chief, Fishery Products Inspection and Safety Division. The Chief of the Division will:

a. Initiate all correspondence from NMFS to the alleged violator when, in his judgment, 

the investigation conducted by field inspection personnel indicates that a violation of 

the Act or its implementing regulation did in fact occur. The correspondence will 

specify the details of the alleged violation and the provisions of the law; and will 

provide the opportunity for the violator to present written or oral views concerning the 

alleged violations.

b. When, in his judgment, substantial evidence of a violation exists, (a) refer the matter to 

the Office of General Counsel with a request to initiate debarment action or (b) 

forward the case to the Department of Justice recommending the initiation of criminal 

action.

ATTACHMENTS 1-4

Section 08: Processing Consumer Complaints 

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Product Evaluation, Grading and Documentation

Chapter 1 – Fish and Fishery Product Grade Standards

Section 01: U.S. Standard for Whole and Dressed Fish 

Grading Whole and Dressed Fish

Section 02: U.S. Standard for Whole and Dressed Whiting 

Grading Frozen Headless Dressed Whiting

Procedures for Rounding Off and Retention of Numbers

Section 03: U.S. Standards for Grades of Fish Steaks 

[Reserved]

Grading Frozen Halibut Steaks

Grading Frozen Salmon Steaks

Section 04: U.S. Standards for Grades of Fish Fillets 

Grading Fish Fillets

Section 05: U.S. Standards for Grades of Cod Fillets 

Grading Frozen Cod Fillets 

Section 06: U.S. Standards for Grades of Flounder and Sole Fillets 

Grading Flounder and Sole Fillets

Section 07: U.S. Standards for Grades of Haddock Fillets 

PART 

3

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Grading Frozen Haddock Fillets

Section 08: U.S. Standards for Grades of Ocean Perch Fillets and Pacific Ocean Perch Fillets 

Grading Ocean Perch Fillets and Pacific Ocean Perch Fillets

Section 09: U.S. Grade Standards for Grades of Frozen Fish Blocks and Products Made Therefrom 

Grading Frozen Fish Blocks 

Section 10: U.S. Grade Standards for Grades of Frozen Minced Fish Blocks 

Grading Frozen Minced Fish Blocks

Section 11: U.S. Grade Standards for Grades of Frozen Raw Fish Portions 

Grading Frozen Raw Fish Portions

Section 12: U.S. Grade Standards for Grades of Frozen Raw Breaded Fish Sticks 

Grading Frozen Raw Breaded Fish Sticks 

Section 13: U.S. Grade Standards for Grades of Frozen Raw Breaded Fish Portions 

Grading Frozen Raw Breaded Fish Portions

Section 14: U.S. Grade Standards for Grades of Frozen Fried Fish Sticks 

Grading Frozen Fried Fish Sticks

Section 15: U.S. Grade Standards for Grades of Frozen Fried Fish Portions 

Grading Frozen Fried Fish Portions

Section 16: U.S. Grade Standards for Grades of Fresh and Frozen Shrimp 

Grading Fresh or Frozen Shrimp

Section 17: U.S. Standards for Grades of Raw Breaded Shrimp 

Grading Frozen Raw Breaded Shrimp

Section 18: U.S. Standards for Grades of Raw Frozen Scallops 

Grading Frozen Raw Scallops

Section 19: U.S. Standards for Grades of Frozen Raw Breaded Scallops and Frozen Fried Scallops

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Grading Frozen Raw Breaded Scallops and Frozen Fried Scallops

Section 20: U.S. Standards for Grades of North American Freshwater Catfish and Products Made Therefrom 

Grading North American Freshwater Catfish and Products Made Therefrom

Chapter 2 – Other Government Standards and Specifications

Section 01: Consumer Item Descriptions

Canned Tuna

Canned Salmon

Pollock Nuggets

Section 02: Codex Alimentarius Standards for Fish and Fishery Products

General Standard for Quick Frozen Fish Fillets

Quick Frozen Blocks of Fish Fillet, Minced Fish Flesh and Mixtures of Fillets and Minced Fish 

Flesh

Quick Frozen Finfish

Quick Frozen Fish Sticks (Fish Fingers), Fish Portions and Fish Fillets – Breaded or in Batter

Quick Frozen Shrimp or Prawns

Quick Frozen Lobsters

Quick Frozen Raw Squid

Canned Finfish

Canned Salmon

Canned Tuna and Bonito

Canned Sardines and Sardine-Type Products

Canned Shrimp or Prawns

Canned Crab Meat

Salted Fish and Dried Salted Fish of the Gadidae Family of Fishes

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Dried Shark Fins

Crackers from Marine and Freshwater Fish, Crustacean and Molluscan Shellfish

Section 03: USDC Model Retail Specifications 

Chapter 3 – Methodology

Section 01: Net or Drained Weight Determination 

To standardize nationally the method that will be used to determine the net weight of each form 

of unbreaded frozen shrimp, and to assure national uniformity in certification of results. 

Adherence to the provisions of this manual section is required by USDC Seafood Inspection 

Program (SIP) fishery products inspectors, and by other Federal and State inspectors who have 

been cross-licensed by the program, when inspecting and certifying shrimp products on behalf of 

the SIP. Any departure from these procedures must be approved before the fact.

Definitions

For the purpose of this manual section, the following terms shall have the following meanings:

Clump - A cluster of two or more shrimp or pieces of shrimp frozen together, and which 

cannot be separated readily.

Drained weiqht - The weight of the shrimp of a sample unit after the sample unit has been 

completely thawed and drained.

Glaze - A layer (coating) of ice applied to the product’s surface to serve as a barrier to air, to 

retard dehydration of the product. It must be removed to determine accurately a packaged 

product’s net weight.

Glazed Weight - The weight of the entire package contents (i.e., excluding the weight of 

packaging material), of a sample unit that has been covered (coated) with a protective layer of 

ice.

Gross weight - The weight of the entire packaged sample unit, including its packaging 

material.

Individually Quick Frozen (IQF) - The freezing of each shrimp separately and apart from 

other shrimp, i.e., not frozen together in a block or clump. Shrimp frozen in this manner are 

usually glazed before packaging to delay the onset of dehydration.

Net Contents or Net Weight - The weight of the shrimp in a sample unit which remains after 

all deductions for tare and/or glaze have been made.

Tare (Tare Weight) - The weight of the container, wrapper, or other packaging material, of a 

sample unit that is deducted from the gross weight to obtain the net weight.

Official methods of weight determination

The procedures contained in the publication: Official Methods of Analysis of AOAC 

International, 17th Edition, 2000, will be used to determine the weight of the various forms of 

unbreaded shrimp. The procedures are identified by bold-face paragraph numbers in the 

publication. For the purpose of this manual section, a “common name,” i.e., a term descriptive of 

the principal action involved in the procedure has been assigned to each of the methods. The 

procedures, (Attachment 1), and the products to which they apply are as follows:

A. AOAC 963.26B(a) - Net Contents of Frozen Food Containers Unglazed Frozen Foods. 

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(Subsequently referred to as the Net Contents Method) This method will be used to determine 

the net weight of packaged, unglazed shrimp products. Results will be reported as net weight.

B. AOAC 963.18(a) - Net Contents of Frozen Seafoods – Drained Weight Glazed Seafoods. 

(Subsequently referred to as the Spray - Deglazed Method) This method will be used to 

determine the net weight of packaged, glazed, IQF shrimp products. This method will not be

used for block-frozen shrimp, nor for shrimp that are of such small size that the glaze cannot be 

removed practically by an inspector without thawing, or partially-thawing, some of the shrimp. 

This method also will not be used for IQF products that contain clumps or clusters in excess of 

15 percent by weight of the glazed weight. Results of this method will be reported as net weight, 

regardless of the designation “Drained Weight” in the paragraph heading. The product is not 

thawed before draining, hence it is not a drained weight.

C. AOAC 967.13 and 970.60 - Drained Weight of Frozen Shrimp and Crabmeat. (Subsequently 

referred to as the Immersion-Thaw Method) This method will be used to determine the drained 

weight of shrimp frozen together in a block. The shrimp are not readily separable in the frozen 

state. This method will also be used for IQF shrimp of such small size that the glaze cannot be

removed practically without thawing some of the shrimp. It will also be used for IQF products 

which contain clumps or clusters in excess of 15 percent by weight of the glazed weight. Results

of this method will be reported as drained weight.

Note: As the instructions that follow indicate, drained weight can be determined whenever 

requested, however net weight cannot be determined and certified on all lots. When net 

weight and drained weight can both be determined and the applicant has requested both, the 

inspector must draw two separate sets of samples, one set for determining the net weight, and 

one set for determining the drained weight. The applicant must be advised before sampling 

that two separate sets of samples will be drawn.

Discussion

The methods cited herein for determining the weight of the various forms of packaged 

unbreaded frozen shrimp have been in use for several years without difficulty. Recently, there 

have been several controversies over apparent short weights of shipments of tiny IQF, peeled, 

cooked shrimp in retail packages, where the net weight has been determined by the official 

AOAC spray-deglazed method. These “salad-type” shrimp are extremely small -- frequently over 

300 count-per pound. It is extremely difficult if not impossible for an experienced shrimp 

inspector to deglaze them properly without at least partially thawing them. They lose moisture 

rapidly when defrosted, and continue to bleed for some time. The criticality of the deglazed -

without thawing - process, and the exactness to which the two-minute drain time must be

controlled render the method almost impossible to perform accurately by the average inspector. 

For this reason, provision has been made in paragraph V.B., for the inspector to refuse to

perform the spray-deglazed method (net weight) on shrimp of such small size that the glaze 

cannot be removed practically without at least partially thawing some of the shrimp. This is a 

judgement call to be made by the inspector’s supervisor if necessary. If the applicant has 

requested a net weight determination (not a drained weight determination), and the inspector

believes it cannot be performed accurately, the applicant must be so advised, and permission 

received to perform a drained weight determination in lieu thereof. In the event that an applicant 

has requested a net weight determination, and the product contains in excess of 15 percent

clumped product, the applicant must be advised that a net weight cannot be determined 

accurately, and permission received to perform a drained weight (immersion method) 

determination instead.

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Certification

It is important that the certificate state exactly what “weight” was determined, i.e., net weight, 

drained weight, or both. Further, the inspector must include the AOAC methods used (by 

identifying section number) on the certificate along with the number of the edition of the AOAC 

manual used.

Summary

A. Adherence to the requirements of this manual section is mandatory when determining the net 

or drained weight of packaged, unbreaded, frozen shrimp. Any departure from these procedures

must be approved before the fact by the Program manager or the Director of Field Operations in 

the Central Office.

B. Only the official methods contained in the publication: Official Methods of Analysis of 

AOAC International, 17th Edition, 2000, will be used to determine the net weight or drained 

weight of the various forms of unbreaded shrimp.

C. The net contents method (963.26B(a)) will be used to determine the net weight of packaged, 

unglazed, shrimp products.

D. The spray-deglazed method (963.18(a)) will be used to determine the net weight of packaged, 

glazed, IQF shrimp that can be deglazed without thawing or partially thawing some or all of the 

shrimp.

Note: Exception to method 963.18(a): For large packages/cases/containers of shrimp, a 

representative sub-sample is removed from the total contents to facilitate deglazing and for 

purposes of grading the product by the standard. The except ion have been reviewed and

found acceptable by AOAC’s General Referee for Seafood, Dr. John M. Tennyson and 

General Referee Elect for Seafood, R. Steve Winters.

E. The immersion-thaw method (967.13 and 970.60) will be used to determine the drained 

weight of:

1. block-frozen shrimp;

2. packaged, glazed, IQF shrimp of such small size that the glaze cannot be removed 

practically without thawing or partially thawing at least some of the shrimp;

3. packaged, glazed, IQF shrimp that contains clumps or clusters in excess of 15 percent by 

weight of the glazed weight.

Note: Exception to methods 967.13 and 970.60: Nylon mesh bags are used in lieu of a wire 

mesh basket. They are easier to· use, more portable and retain the defects for purposes of 

grading the product. The exception have been reviewed and found acceptable by AOAC’s 

General Referee for Seafood, Dr. John M. Tennyson and General Referee Elect for Seafood,

R. Steve Winters.

F. When both net weight and drained weight determinations are requested on the same lot, two 

separate sets of samples must be drawn, one set for each determination.

ATTACHMENT 

Section 02: Glaze Determination of Frozen Products

Section 03: Fish Flesh Determination

Section 04: Cooking Methods

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Section 05: On-Line Flesh Determination 

Section 06: Scallop Moisture Determination 

The purpose of this section establishes uniform inspection procedures when certifying scallops 

for total moisture content. This policy will only affect scallops for domestic use and will also not 

be required for lots less than 200 pounds unless other conditions warrant it (e.g., compliance 

history, buyer’s requirements). Product intended for export will be inspected and certified relative 

to the importing country’s requirements.

General

On August 31, 1992, the Food and Drug Administration (FDA) through the Office of Seafood 

developed a policy memo entitled “Interim Labeling Policy Established for Scallops. The purpose 

of the policy was to... “provide consumers with a better indication about the amount of water in 

the scallop products they buy.” At that time the FDA and the Seafood Inspection Program (SIP)

along with many sectors of the industry including retailers and consumer groups were concerned 

that the practice of adding water and phosphate compounds to scallop adductor muscle meats 

was potentially deceptive, fraudulent and in violation of the Food, Drug and Cosmetic (FD & C) 

Act as it relates to adulterated food (21 USCS, 5 342(b)(4)): “A food shall be deemed to be 

adulterated... if any substance has been added thereto or mixed or packed therewith so as to

increase its bulk or weight, or reduce its quality or strength, or make it appear better or of greater 

value than it is.”

The FDA “Interim Labeling Policy” established moisture percentages that would differentiate 

non-treated scallops or what has been referred to as natural scallops from scallops that were 

subjected to water and/or a phosphate treatment. Scallops less than 80.0% total moisture, if not 

subjected to processing conditions utilizing excessive water and/or phosphate treatment, could 

be labeled simply as scallops. As opposed to scallop products whose total moisture analysis 

demonstrated a percentage of 80.0 % to 84.0% would have to be labeled “X % Water Added 

Scallop Product” appearing in the principal display panel of the label. The statement, “Processed 

with Sodium Tripolyphosphate,” or any other polyphosphates used, is also to appear in the 

identity statement if the product has been processed with the ingredient. In addition, the 

ingredient statement on the labels for these products must include water and sodium 

tripolyphosphate (or other phosphate, as appropriate). Products having moisture content over 

84.0 % were considered adulterated under the FD&C Act.

It has been the SIP’s policy since the inception of the FDA policy to test all lots of scallops for 

total moisture using the “Ohaus method” or the official AOAC method. The results of these 

analyses are noted on the certificate and the product would have to be labeled accordingly. On 

May 18, 2004, the FDA rescinded their interim Labeling Policy of August 1992. In effect, the 

percentages that FDA used for defining labeling statements are no longer being enforced.

However, scallop products that are subjected to processing conditions that will result in added 

moisture and/or to food additives (e.g., phosphates) must be properly labeled both in the identity 

statement (i.e., on the principal display panel) and in the ingredient statement.

Policy

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Because the FDA has rescinded its policy regarding the action levels of moisture content in 

scallops, the SIP will no longer use that criterion. However, because of the concern over 

improper labeling or misuse of the process, the SIP will continue to require that all lots of 

scallops over 200 pounds destined for domestic use be tested for total moisture using the “Ohaus 

method” or the AOAC method for total moisture. The results of the analysis will be noted on the

certificate, score sheet or memorandum. If the inspector has definitive knowledge that the 

product has been treated in some way to add water to the product, the label must reflect that. 

Also if the product tests over 83.0 % for total moisture, the SIP will assume that the product has 

been treated and must be properly labeled. This assumption is based on studies and data collected 

by various governmental agencies, academia, and other organizations that have demonstrated

total moisture content of scallops consistently less than 83%.

At this time there is no upper limit for moisture content.

The SIP will closely follow the development of the international Proposed Draft Standard for 

Quick Frozen Scallop Adductor Muscle Meat under the Codex Alimentarius Commission (the

joint Food Standards Program of the Food and Agriculture Organization of the United Nations 

and the World Health Organization).The issues of moisture content limits, phosphate usage, and 

proper labeling are central elements in this draft standard. The SIP will evaluate the data

submitted regarding these issues during the development of this international standard, as well as 

any data that are obtained directly from foreign agencies or other sources with the intent of 

establishing appropriate moisture content and phosphate usage criteria for use by this Program.

{Note: “X%-water-added” is calculated by knowing the natural moisture content (A) and the 

moisture content after treatment (B). X = (B-A)/(l -B)}

Section 07: Determination of Ammonia in Dogfish 

This section prescribes a method for use by USDC Inspectors to measure ammonia 

concentration in dogfish, Squalus acanthias, and to prescribe procedures for handling and

reporting results.

General

Dogfish develops an odor of ammonia if fish are not properly handled. It has been shown that

one of the best indicators of dogfish quality is ammonia content. Belgium and France have

established limits for the amount of ammonia permitted in dogfish as determined by chemical

testing. On the basis of such testing, a number of U.S. shipments to these countries have been, 

rejected. Belgium denies entry to dogfish if the concentration of ammonia exceeds 55 milligrams 

per 100 grams of fish (55 mg percent) as determined by the accelerated microdiffusion method 

referenced below. In France, the norm for fresh dogfish is considered to be 50 to 70 mg percent 

ammonia, and the outer limit is 100 mg percent as determined by a chemical method. However, 

France does not specify a chemical method.

Three methods for ammonia measurement in dogfish were studied. Comparable results were

obtained by use of all three methods. A rapid enzymatic method was selected for use by NMFS 

Inspectors. The other two methods were:

A. the Association of Official Analytical Chemists (AOAC) procedure for determining ammonia 

in crabmeat, Methods of Analysis, AOAC, 13th Edition, 18.027 - 18.030; and

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B. the accelerated micro-diffusion test of Vyncke described in Fishing News International,

July, 1968, pages 49 - 53.

Policy

Dogfish destined for export to France and Belgium, and to other countries with known ammonia 

content limits, will be sampled and tested for ammonia content by a trained NMFS Inspector 

prior to certification.

Responsibility

A. NMFS Inspector - With appropriate training, NMFS Inspectors will perform ammonia

analyses on dogfish by means of the enzymatic test kit described herein. Inspectors will order

supplies as necessary using the sources listed on Attachment 1.

B. National Seafood Quality and Inspection Laboratory (NSQIL) - NSQIL will provide training 

in the use of the enzymatic test kit or will assist in locating local laboratories which will perform 

tests for NMFS.

Procedures

The method to be used by NMFS Inspectors to measure ammonia in dogfish is known as the

“Quantitative Ultraviolet Determination of Ammonia in Plasma at 340 nm”. The test is

performed with Sigma Chemical Company Kit No. 170-B. It is important that the analyst read

and understand the instruction booklet accompanying the kit. The instruction booklet is to be

followed with modifications listed below for sample collection, preparation, and ammonia assay 

procedure.

A. Sample Collection

From each lot, collect eight sample units and place the sample units in separate plastic bags.

1. Dogfish backs - Remove one dogfish back from each of eight randomly selected shipping 

cases. Cut a two- to four-inch section from each end of the dogfish back (anterior and 

posterior), and place both sections in one plastic bag. Each sample unit then consists of 

two pieces weighing approximately 90 grams.

2. Dogfish belly flaps - Remove one flap from each of eight randomly selected cases. Place 

each sample unit in a plastic bag. Sample units should weigh approximately 70 grams.

All sample units must be maintained in the frozen state until chemical analyses are performed.

B. Sample Preparation and Handling

Dogfish samples shall be prepared for analysis by the kit method as described below.

Reusable glassware must be scrupulously cleaned and rinsed with ammonia-free water.

All water used in dilutions must be ammonia-free. During blending operations, avoid

overheating samples, and avoid splashing samples on the walls of the blender.

1. Weigh the sample unit, recording the result to the nearest 0.1 gram. Chop the sample unit 

into small pieces and place the pieces in a Waring-type blender jar. Add three equivalent 

weights water (e.g., 90.0 grams dogfish, 270 ml water). Blend until homogeneous 

(approximately two minutes).

2. Weigh 40.0 grams of the blended dogfish sample. Use a graduated cylinder to measure 360 

ml water. Use enough water (60 ml) to completely transfer the 40.0 gram sample to a clean 

blender jar, then add the remainder of the water to the jar. Blend for one minute.

3. Filter the homogenate through fluted Whatman #1 paper into a clean container. Save

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approximately 20 ml of filtrate for analysis. Discard the remainder of the homogenate.

4. Assay for ammonia immediately or store the filtrate in an airtight container and refrigerate. 

Filtrates must be frozen if stored overnight. Filtrates must be brought to room 

temperature before analyses are performed.

C. Ammonia Assay Procedure

The kit instructions with regard to “Procedure” are modified as follows:

Where the instructions are to add “plasma,” substitute “dogfish filtrate.”

See Attachment 5 for a full description of reagents and modified procedure.

D. Results and Calculations

Record test results and calculations on a copy of the attached form entitled, “Results”

(Attachment 2). An example of results and calculations is provided as Attachment 3 to this 

manual release. Attachment 3 also contains important instructions for calculating results. A 

table is included in this release as Attachment 4 to facilitate calculations and to provide 

guidelines wherein results are accurate.

Rejections

A lot of dogfish must be rejected when the ammonia content of any sample unit is determined to 

be in excess of 40 mg percent in both original and check analysis. When the analyst is unsure as 

to interpretation of results, he or she should consult a chemist at the National Seafood Inspection 

Laboratory in Pascagoula, Mississippi. Dogfish may, of course, be rejected for reasons other than 

ammonia content such as unfavorable organoleptic results.

Reporting Results

Report the ammonia content as milligram percent ammonia and reference the method used to 

determine the ammonia content on the USDC Inspection Certificate.

EXAMPLE

Dogfish were analyzed by a chemical method, the “Quantitative Ultraviolet Determination of

Ammonia in Plasma at 340 nm”. The results in milligrams ammonia per 100 grams dogfish

were:

SAMPLE NO. MG PERCENT AMMONIA

1 10

2 15

3 10

4 12

5 9

6 11

7 10

8 14

ATTACHMENTS

Section 08: Dry Ingredient Inspection Procedures

This section’s purpose is to establish inspection procedures and methods of examination for use 

by USDC inspectors to detect the presence of insects in dry ingredients used in the manufacture 

of processed fishery products and to prescribe uniform procedures for handling such ingredients

when found to be infested.
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General

Insect infestation can occur in dry ingredients and related food products during their 

manufacture, distribution, and storage. Most routine inspection procedures will detect

contamination (i.e., live or dead insects, larvae or other evidence of insect activity). When

evidence of an insect problem is found, it must be thoroughly investigated to determine the

extent and cause of the problem.

Many fishery products contain dry ingredients such as flours, meals, batters, breaders, binders,

and spices. These are vulnerable to insect infestation. Infested materials are deemed adulterated 

under section 402 of the Food Drug and Cosmetic Act as amended, and subject to regulatory 

action by the Food and Drug Administration.

These procedures should prevent the adulteration of seafood products caused by the use of insect 

infested ingredients. They are intended for in-plant screening, not as official methods of analysis.

Policy

Inspectors shall not permit the use of any dry ingredients which are contaminated with insects 

(adult, pupae, larvae).

Responsibility

A. Inspectors’ Responsibility

USDC inspectors are responsible for certifying the wholesomeness of inspected products in

official establishments. USDC inspectors assure that all dry ingredients used in the manufacture 

of fishery products are free from insect contamination, and advise plant management of an 

immediate or potential infestation problem.

The ability to identify insects and the knowledge of their reproduction cycles and feeding habits

are helpful to the inspector in determining their presence and source and extent of their activity. 

Inspectors are encouraged to become knowledgeable in this area. The identification of insects 

and insect fragments, should it become necessary, should be performed by personnel qualified in 

entomology.

B. Plant Responsibility

The plant management is ultimately responsible for the wholesomeness and safety of the

products they produce. Each plant should develop and implement its own in-house program for 

evaluating and controlling insects. This program should include as a minimum:

1. Inspection of raw materials upon receipt

2. Inspection of carrier vehicles

3. Inspection of storage areas and warehouses

4. Effective rotation of all supplies and ingredients including packaging materials

5. Inspection of raw materials during processing

6. Inspection of finished products

7. Effective cleaning program

8. Effective pest control program

Procedures

A. Ingredient Receiving Areas

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1. Exterior of containers should be examined for evidence of insects, particularly those areas 

most likely to harbor insects.

2. When evidence of insect activity is found:

a) Make a closer examination of the container and, if possible, inspect carrier.

b) Determine extent and source of the problem. When live insects are discovered, they are 

usually beetles. If the growth cycle has progressed far enough, larvae will also be present 

in the ingredients. When larvae are present, insect infestation is established.

3. In the absence of evidence of external insect activity, random samples may be taken at this 

time and examined by using test method(s) prescribed in Section IX B. If insect infestation 

is found in the dry ingredients refer to Section X.

B. Storage Areas and Warehouses

1. Exterior of containers of ingredients should be examined for evidence of insects.

2. Possible insect harborage should be inspected for insect activity.

3. The inspector should observe the stored product on routine inspection rounds, particularly 

products in inventory for an extended period of time. In the absence of evidence of 

external insect activity, random samples may be taken as local conditions dictate.

4. When evidence of insect activity is noted, the stored product will be sampled and

examined.

C. On-Line Processing

1. Visual examination of the dry ingredients should be accomplished at this time along with 

routine examinations.

2. Dry ingredients may also be examined in the equipment systems.

3. If any insect activity is noted refer to Section X.

Sampling

A. All samples shall be taken in accordance with acceptable sanitary sampling methods.

B. Sample size (number of containers) shall be as designated in Table IV of 50 CFR 260 Section 

260.61.

C. Containers from which samples have been taken should be properly sealed and returned to 

storage for use at the first opportunity, unless contamination is suspected.

Methods of Examination

The following procedures will be used alternately or together when examining dry ingredients 

that are suspected of insect activity.

A. Container Examination

1. Bags

Exterior of bags should be examined for insects or evidence of insect activity. Special

attention should be given to gussets, sewing tape on open-mouthed bags and spouts on

valve type bags.

The outer layer of multi-wall kraft bags should be removed for closer examination of

insect activity (i.e., adults, pupae, larvae and cast skins). If insect activity is noted refer to 

IX.B. for product examination procedures.

2. Drums/Boxes

Exterior of drums/boxes should be examined for evidence of insect activity.

Drums/boxes should be opened and polyliner inspected for evidence of insect activity. If 

insect activity is noted refer to Methods of Examination B of this section for product 

examination procedures.
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B. Product Examination

The evaluation of dry ingredients for insect infestation may be accomplished by one or all of

the following methods using a 250 gram sample per test method.

1. Slick

A sample of product should be placed on a flat black surface. Product should be stroked 

with trier in such a manner as to give a flat even layer of product. Look for movement of 

live insects and larvae. Examine product with a magnifying glass of 6X or greater power to 

confirm presence of insects or larvae.

2. Flotation

Mix sample of product with water in large mixing bowl or other suitable container with

wire whip. Mix thoroughly to remove all lumps of products. Let product settle and

examine surface of water for floating insects (adults, pupae, larvae). Slowly empty

container examining product residue for evidence of insect activity.

3. Sieve

Using a No. 20 U.S. Standard Sieve, place sample of product in sieve and shake over a flat 

black surface. During shaking, insects will normally rise to the top of the product. Certain 

insects are small enough to pass through a No. 20 Sieve. Therefore, material passing 

through the sieve should be examined with a magnifying glass of 6X or greater power.

Handling of Infested Ingredients

When infestation is found in dry ingredients, or infested ingredients have been used in finished 

products, the inspector shall follow the procedures outlined in Rejection and Retention of 

Products and Equipment of the Inspection Manual.

Section 9: Determination of Count per-pound in Shrimp 

This section establishes procedures to be used by USDC Consumer Safety Officers and

Inspectors in Determining Count per pound in frozen raw breaded shrimp.

General

Because the U.S. Standards for Grades of Frozen Raw Breaded Shrimp do not provide a 

procedure for determining count per pound, it is the intent of this agency to establish a national 

policy to provide a uniform method for determining count per pound.

Policy

All Inspectors will use the following method for determining count per pound when grading 

and/or certifying frozen raw breaded shrimp.

Procedure

A. Definitions.

(1) Whole Shrimp - Frozen raw breaded shrimp consisting of 5 or more segments of 

unmutilated shrimp flesh which meet the styles and types as defined in 265.153 and

265.154.

(2) Damaged Shrimp - Any frozen breaded shrimp consisting of less than five segments or 

that have been crushed or otherwise mutilated to the extent that their appearance is 

materially affected.

(3) Adjusted Net Weight - The weight of only whole shrimp as defined in A.(1) above in the 

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sample unit. It is determined by deleting the weight of damaged shrimp as defined in 

A.(2) above and shrimp not meeting the declared type and/or style from the net weight of 

the shrimp in the sample unit and is expressed in ounces.

Example: The declared product is “Breaded Round Shrimp with the Tail-fin.”

Shrimp in the sample unit that would NOT be included in the adjusted weight would be 

shrimp with less than 5 segments, damaged shrimp, shrimp with the tail-fin detached,

butterflied and split shrimp.

(4) Sample Unit - For purpose of determining count per pound the sample unit will be:

(a) The entire contents of a package up to and including three pounds declared net 

weight; or

(b) Randomly selected aliquot of at least three pounds of frozen raw breaded shrimp 

from containers in excess of three pounds declared net weight.

B. Procedure.

(1) In determining count, only whole shrimp as defined in A.(1) above are counted.

(2) Count per pound refers to the number of frozen raw breaded shrimp per pound. It is 

determined by dividing the number of whole shrimp in the sample unit by the adjusted 

weight of the package in ounces, and then multiplying by 16.

Count/lb.= Number of Whole Shrimp X 16

Adjusted Weight (ounces)

Example: The adjusted weight of the sample unit (the shrimp meeting the definition

in A.(3)) is 52 ounces (3.25 pounds). There are 58 whole shrimp in the container.

58 X 16 = 17.85

52 ounces

Lot Compliance and Certification

A. Lot Compliance

A lot is considered in compliance when the average count/pound of the sample units

(packages) meets the declared count per pound.

For determining lot compliance, the resultant count per pound is to be rounded to the

nearest whole number using the rounding rules found in the Rounding Off and the Retention 

of Numbers in this manual.

Example

3 pound package 16/20 declared count

Number of

Whole Shrimp

Package

Weight

Calculated 

Count per Pound

1st package 45 48.50 oz. 14.84

2nd package 50 49.25 oz. 16.24

3rd package 52 48.75 oz. 17.07

Average count per pound = 16.05 (round down to 16)

Lot passes. Average count per pound meets the declared count per pound.

NMFS is investigating the use of MAVs (Maximum Allowable Variations) and may amend this 

policy at a later date.
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Section 10: Codex Guidelines for Sensory Evaluation of Fish and Shellfish in Laboratories 

Section 11: Use of Acceptance Numbers

Chapter 4 – Certification Instructions

Section 01: Instructions for Completing the Memorandum Report of Inspection/Certificate of Loading

These instructions establish and implement a procedure which will assure national uniformity in 

the completion and issuance of the Memorandum Report of Inspection/Certificate of Loading

General

(NOAA Form 89-804) for computer based certificates.

A. The Memorandum Report of Inspection/Certificate of Loading

1.

is a dual-purpose form: 

Memorandum Report of Inspection, 

2.

which is used to attest to certain facts about more 

than one lot of products that are available for inspection at one time, and which may or 

may not have been inspected previously, and 

Certificate of Loading,

B. NOAA Form 89-804 shall be used only when lot samples have been drawn officially as 

provided in 50 CFR 260, or other USDC validated system (e.g. IQA, HACCP-QMP). Identify 

the basis for certification in the remarks section of the official certificate.

which is used to attest to certain facts about a shipment at the point 

of loading onto a truck, rail car, ship, or other means of conveyance. 

C. Products which pass/fail to meet requirements or criteria specified by the applicant shall not 

be listed/certified on the same document. A separate certificate should be issued for passing 

and failing products. A Lot Inspection Certificate

D. The 

(NOAA Form 89-803) may also be issued 

for these items. 

Certificate of Loading shall be issued only if an authorized inspector is present during 

loading, has observed the loading process, and has identified the lots which comprise the load. 

Procedures for Certifying Products on the Memorandum Report of Inspection

A. Requests for Inspection: Whether received by e-mail, telephone, fax, or in writing, the 

information listed on NOAA Form 89-814, (Request For Inspection Services

B. Completing the Memorandum Report of Inspection: The Memorandum is prepared by 

transferring to it the information and data taken from the inspection request, the certificate of 

sampling, score sheet, work sheet, or other notes or records relative to the inspection. The 

certificates will be printed on official watermarked paper only. The numbered paragraphs 

below correspond to the circled numbers on the example in the attachment. 

), must be 

obtained from the applicant. If a written request does not contain the information necessary to 

perform the inspection, contact the requestor for pertinent information. 

 

CERTIFICATE REFERENCE NUMBER 

(Certificate reference numbers will be 11 characters/number)

I Northeast Region: First Digit – Enter N

Southeast Region: First Digit – Enter S

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Western Region: First Digit – Enter W

II/III Export Certificates: Use two character country ISO codes at the following link.

http://www.iso.org/iso/english_country_names_and_code_elements

Lot Inspection Certificate: Use LC

Certificate of Inspection: Use CN

Memorandum Certificate/Certificate of Loading: Use MC

Certificate of Origin: Use CR

IV-VII Enter Four-Digit Inspector/Officer number.

VIII-XI Enter Four-Digit numerical reference number starting new with each inspector/officer. 

e.g., First cert 0001, next 0002, and so on.

1. Check the box indicating 

2. Enter the date the Memorandum was prepared. 

Memorandum of Inspection. 

3. Enter the USDC contract number if the product is inspected at a USDC establishment. If not, 

enter “Not Applicable,” or “N/A.”

4. Enter the location of the product(s), i.e. where the samples were drawn. 

5. Enter the name and address of the applicant, i.e. the person or firm who requested the 

inspection.

6. Enter the name and address of the person or firm to whom the product is to be shipped. If 

unknown, enter “Documentary Consignee”.

7. For each lot of product, enter a description of the product, with its brand if so labeled. Enter 

the type, e.g., fresh, frozen, canned etc., and the style,

8. Enter the lot numbers assigned by the plant or warehouse for bookkeeping purposes. If none 

exists enter “none.”

e.g., skin-on, cooked, raw, whole, 

eviscerated, etc.

9. Enter all codes appearing on the containers that designate the day the product was produced. 

If none are available enter the date of the Official Stamp applied to cases. 

10. Enter the total number of cases in the lot. 

11. Enter the labeled net weight of the container(s)

12. Enter the total weight of the product by multiplying the number of containers by the weight 

of the container. If catch weight is used, use vendor’s weight and note this in the remarks 

section.

13. Enter the summarized results of the inspection in this section, including the condition of the 

containers.

14. Enter pertinent information such as the date of sampling, quantity covered by certificate, 

special statements, such as appeal inspections, restricted coverage, or other suitable, 

appropriate information. 

15. Enter the address of the local office to which the inspector is assigned. 

16. Enter signature, inspector number, and the date of inspection on each copy of the certificate. 

17. Place the impression of the “Officially Sampled” or “Accepted Per Specification” stamp in 

this location. 

C. Distribution of the Completed Memorandum Report of Inspection 

ALL CERTIFICATES WILL BE PRINTED ON OFFICIAL WATERMARKED PAPER

1 Print two copies, sign stamp and forward to the customer. Additional copies at request.
NOAA HANDBOOK 25

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2 Print and file copies in accordance with SIP filing plan. 

Procedures for Completing the Certificate of Loading

A. This document is normally used in conjunction with the Certificate of Inspection (NOAA 

Form 89-802)). It is used to certify that the product loaded is the same as that listed on the 

other document. It is commonly used for DPSC contracts and for USDA Commodity 

Purchases. In most cases at least one copy of each document will be given to the responsible 

person of the transit company, such as the truck driver or freight forwarder.

B. Completing the Certificate of Loading: The certificate is prepared by transferring to it the 

pertinent information taken from its accompanying Certificate of Inspection and observations 

made during the inspection. It should be printed legibly by hand, but may be typed if time 

allows. The numbered paragraphs below correspond to the circled numbers on the example in 

the attachment.

1. Check the box indicating Certificate of Loading. 

2.-12. Follow the instructions in this section “B. Completing the Memorandum Report of 

Inspection” 2 through 12 above

13. Enter the results of your observations of the loading procedure. 

14. Enter pertinent information such as the car, trailer or container number; the seal 

number, if used; the time the refrigeration unit was turned on; the temperature of the 

unit at the time loading began or any other appropriate information that may impact 

the quality or safety of the product. Also, always enter the number(s) and date(s) of 

the accompanying certificate(s) for reference purposes. 

15.-17. Follow Nos. 15-17 in this section “B. Completing the Memorandum Report of 

Inspection” above.

C. Distribution of the Completed 

ALL CERTIFICATES WILL BE PRINTED ON OFFICIAL WATERMARKED PAPER

Certificate of Loading. 

1 Print two copies, sign stamp and forward to the customer. Additional copies at request.

2 Print and file copies in accordance with SIP filing plan

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ATTACHMENT

Section 02: Instructions for Completing the Lot Inspection Certificate 

To establish and implement a procedure which will assure national uniformity in the completion 

and issuance of the Lot Inspection Certificate (NOAA Form 89-803) for computer printed 

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certificates.

General

A. The Lot Inspection Certificate is used for certifying any number of containers of the same 

size and type which contain a processed product of the same type and style located in the same or 

adjacent warehouses and which are available for inspection at any one time. Usually these 

products have not been inspected during processing in an official establishment; therefore, the 

sanitary conditions of the processing plant, and the processing methods used are unknown.

B. Products inspected and certified on a lot basis may not bear any U.S. Grade or “Processed 

Under Federal Inspection” (PUFI) mark or be U.S. Grade or PUFI certified on the certificate 

unless they have been inspected and passed during processing in an official establishment

C. NOAA Form 89-803 shall be used only when lot samples have been drawn officially by an 

authorized inspector or sampler as provided in 50 CFR 260.

D. The certificate shall be issued regardless of whether the product meets the requirements or 

criteria specified by the applicant. The certificate is an official record of the inspection findings

Procedures

A. Requests for Inspection: Whether received by e-mail, telephone, fax or in writing, the 

information requested on NOAA Form 89-814, Request for Inspection Services, must be 

obtained from the applicant. If a written request contains the information necessary to perform 

the inspection, a NOAA Form 89-814 needs to be completed by SIP personnel prior to 

performing the inspection. The written request or NMFS-completed NOAA Form 89-814 will be 

filed with the file copy of the certificate as part of the permanent record. 

B. Completing the Lot Inspection Certificate: The form will be printed from computer by 

completing the blocks, which are numbered in the example (see Attachment) to correspond with 

the following numbers. Certificates will be printed on USDC watermarked paper only.

CERTIFICATE REFERENCE NUMBER 

(Certificate reference numbers will be 11 characters/number)

I Northeast Region: First Digit – Enter N 

Southeast Region: First Digit – Enter S 

Western Region: First Digit – Enter W 

II/III Lot Inspection Certificate: Use LC 

IV-VII Enter Four-Digit Inspector/Officer number. 

VIII-XI Enter Four-Digit numerical reference number starting new with each 

inspector/officer. e.g., First cert 0001, next 0002, and so on.

1. Enter the date the certificate is prepared. 

2. Enter the company name of applicant. 

3. Enter the address of applicants’ facility. 

4. Enter the name of company to which inspection is performed. 

5. Enter the address of company to which inspection is performed.

6. Enter the product inspected, as to the production commodity code. 
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7. Enter the location of product and sampling/inspection. 

8. Enter container information. (e.g. Master Container size, Warehouse Storage Lot numbers)

9. Enter Label information (e.g. Brand, Processor, Product, Type style, market form size etc.)

10. Enter Container identification marks (e.g. pack dates. Best Before dates)

11. Enter Container ID Number when appropriate (e.g. Product codes.)

12. Enter Case Information (USDC Stamp number and date that identify the inspected product.)

13. Results (e.g. All pertinent information from the inspected product, weights, sizes, glaze 

Percentage, breading percentages etc.)

14. Remarks (Temperatures, condition of containers, special applicant requested information.)

15. Enter Regional Office name and address

16. Place the stamp that identifies the inspected product.

17. Enter Inspector name and number. Apply signature to original certificates.

C.

OFFICIAL CERTIFICATES WILL BE PRINTED ON USDC WATERMARKED PAPER 

ONLY

Distribution of Certificates

1 Two originals will be printed signed and stamped to be given to the applicant.

2 Print and file copies according to SIP filing plan. 

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ATTACHMENT

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Section 03: Instructions for Completing the Export Health Certificate 

To establish and implement a procedure which will assure national uniformity in the completion 

and issuance of the Export Health Certificate (NOAA Form 89-807) for computer based 

certificates.

General

A. The Export Health Certificate is used for certifying products for export to countries for 

which bilingual certificates have not been developed.

B. The Export Health Certificates will be issued for products which have been requested as 

“Ship Stores in Transit”. This will be for product identified as exporting to various port 

destinations, never leaving bond and loading onto and consumption aboard cruise ships only.

C. The Export Health Certificates will not be issued for products which fail to meet FDA 

regulations which govern the sale of products for domestic use, except that the certificate may be 

issued if the product meets the importing country requirements, or if official authorization is 

received by NMFS from the improving country which acknowledges that the product fails to 

meet U.S. laws and regulations, but nevertheless sanctions shipment of the product to that 

country. In these instances the product must be marked “For Export Only” on the outside of 

each container

Procedures

A. Requests for Inspection:

B.

Whether received by e-mail, telephone, fax or in writing, the 

information requested on NOAA Form 89-814, Request for Inspection Services, must be 

obtained from the applicant. If a written request contains the information necessary to perform 

the inspection, a NOAA Form 89-814 needs to be completed by SIP personnel prior to 

performing the inspection. The written request or NMFS-completed NOAA Form 89-814 will be 

filed with the file copy of the certificate as part of the permanent record. 

Completing the Export Health Certificate: The form will be printed from computer by 

completing the blocks, which are numbered in the example (see Attachment) to correspond with 

the following numbers. Certificates will be printed on USDC watermarked paper only. 

CERTIFICATE REFERENCE NUMBER 

(Certificate reference numbers will be 11 characters/number)

I Northeast Region: First Digit – Enter N 

Southeast Region: First Digit – Enter S 

Western Region: First Digit – Enter W 

II/III Export Certificates: Use two character country ISO codes at the following link. 

http://www.iso.org/iso/english_country_names_and_code_elements

IV-VII Enter Four-Digit Inspector/Officer number. 

VIII-XI Enter Four-Digit numerical reference number starting new with each 

inspector/officer. e.g., First cert 0001, next 0002, and so on.

1. Enter the date the certificate is printed. 

2. Enter the name designation and address of the issuing office. 

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3. Enter the name and address of the applicant or shipper of the product. 

4. Enter the name of the consignee if available. If not available, enter “Documentary Consignee”. 

5. Enter the means by which the product will be shipped, i.e., vessel, air, rail, truck, etc., and 

identify the carrier by number or name, if known. 

6. Enter the port of embarkation, i.e. the city/port from which the product will be shipped, if 

known. 

7. Enter the port of debarkation, i.e. the city/port to which product is being shipped, if known. 

8. Enter the USDC Stamp date/number that can be used to identify the product. 

9. Enter the total number of master cases being shipped. (Primary container numbers can be 

placed in parentheses) 

10. Enter the total marked declared net weight of the shipment. The weight shall be expressed in 

the metric system of weights and measures, followed by its U.S. equivalent in parentheses, 

(e.g., 13,607.9 kg (30,000 lbs.). 

11. Enter the identity of the product. (e.g., Shrimp Tiger 16/20, IQF) 

12. Describe the product, (e.g., Raw P/D)

13. Enter the lot number(s) or production code(s) which appear(s) on the cases in the shipment. 

14. Describe the container size as it appears on the case. 

15. Enter the total number of cases in the lot. (Primary packages may follow in parentheses) 

16. Enter the declared net weight of the lot of product inspected in this row. The weight shall be

expressed in the weights and measures declared on the label.

17. Enter the brand name of the product. If no brand name is present, enter “unlabeled”. 

18. The results/remarks sections are used to summarize the information which has been recorded 

in detail on the score sheet or other worksheet. The remarks must contain pertinent 

information about the lot including, but not limited to the “fitness of the product for export”, 

country of origin, wild caught or farm raised, lab analysis information, inspection criteria 

used, sampling procedures and billing references.

EXAMPLE

The above products were inspected and found to be of condition and quality fit for export. 

Product labels were sufficient to meet US FDA regulations that govern products for domestic 

use. Declared country of origin was USA. Product was not laboratory tested for 

bacteriological or toxin content. Product was inspected and sampled per U.S Regulations 

governing fishery products. Billing is on “Contract Basis”

19. The “officially sampled” stamp impression is placed in this location.

20. Enter the name and number of the CSI/CSO who performed the inspection. 

Procedures for Distribution of Certificates

OFFICIAL CERTIFICATES ARE TO BE PRINTED ON USDC WATERMARKED PAPER 

ONLY

1. Print three originals, sign, stamp and forward to the Applicant. 

2. Print and file copies according to SIP filing plan.

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ATTACHMENT

Section 04: Instructions for Completing the Certificate of Origin 

To establish and implement a procedure which will assure national uniformity in the 

completion and issuance of the Fish Certificate of Origin for computer printed certificates.

General

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The Fish Certificate of Origin is used for applicants’ requests to identify country of origins as 

listed on inspected product labels. This certificate will usually be issued in combination with the 

Export Health Certificate or the Lot inspection Certificate.

Procedures

A. Requests for Inspection:

B.

Whether received by e-mail, telephone, fax, or in writing, the 

information requested on NOAA Form 89-814, Request for Inspection Services, must be 

obtained from the applicant. If a written request contains the information necessary to perform 

the inspection, a NOAA Form 89-814 needs to be completed by SIP personnel prior to 

performing the inspection. The written request or NMFS-completed NOAA Form 89-814 will be 

filed with the file copy of the certificate as part of the permanent record. 

Completing Fish Certificate of Origin:

1. Certificate Reference Number

The form will be printed from computer by 

completing the blocks, which are numbered in the example (see Attachment) to correspond with 

the following numbers. All Official Certificates will be printed on USDC watermarked paper.

(Certificate reference numbers will be 11 characters/numbers)

I Northeast Region: First Digit – Enter N

Southeast Region: First Digit – Enter S

Western Region: First Digit – Enter W

II/III Certificate of Origin : Enter - CR

IV/VII Enter Four-Digit Inspector/Officer number.

VIII/XI Enter Four-Digit numerical reference number starting new with each 

inspector/officer.

(e.g. First cert 0001, next 0002 and so on.)

2. Enter the name of the applicant.

3. Enter the date the product will be shipped.

4. Enter shipment information.

5. Enter origins listed on label of product inspected.

6. Enter final destination of product inspected.

7. Enter product information for inspected items. (e.g. Grouper Frozen Fillets)

8. Enter the USDC Stamp number and date that identifies the cases inspected.

9. Enter total case count for shipment.

10. Enter declared size of product where applicable. (e.g. 10-20 LB)

11. Enter the count of fish if applicable. (e.g. 1200 Pieces of H/G TUNA IQF) Net Weights 

may be added in this data block.

12. Enter the appropriate certificate number and date of accompanying USDC Certificate.

13. Enter the CSI/CSO Name and number. Sign this location. 

14. Enter the date the certificate was completed.

15. Place the USDC stamp that identifies the inspected product here. 

Distribution

OFFICIAL CERTIFICATES WILL BE PRINTED ON USDC WATERMARKED PAPER 

ONLY

1. Print three copies, sign stamp and forward to the customer. 

2. Print and file copies according to SIP filing plan.
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ATTACHMENT

Section 05: Instructions for Completing the EU Fish and Fishery Product Certificates and Documentation

Instructions to USDC Inspectors/Officers for Completing EU Non-Molluscan Health 

Certificates for Fishery Products

To establish procedures that will assure national uniformity in the completion and issuance of the 
NOAA HANDBOOK 25

111

EU Health Certificates

1. General Directions Printing

• Print all pages on sheets of watermark paper. Front and 

back printed required.

• All pages must contain the Certificate Reference 

number. 

• All pages must be numbered sequentially. (e.g. Page 

2/3)

• All certificates must bear original signature and stamp.

Signature

• Must be different than particulars on certificate.

Stamp

• Must be different than particulars on certificate.

2. Procedures Date

• Enter the date the certificate is issued.

Certificate Reference Number

• Enter number with color other than certificate print 

color.

• Certificate reference numbers will 11 

characters/numbers

A. Northeast Region: First Digit – Enter N

Southeast Region: First Digit – Enter S

Western Region : First Digit – Enter W

B. Enter ISO Code for Country of Destination

C. Enter Four-Digit Inspector/Officer number.

D. Enter Four-Digit numerical reference number 

starting new with each inspector/officer.

(e.g., First cert 0001, next 0002 and so on.)

Example: In Boston MA, Product going to Spain, from inspector 

Smith (#6789), first certificate of Export for inspector Smith. Certificate reference number would be: NES67890001

Note: Each inspector will have a running 

tally of EU certificates based on numbers not 

country of destination. When certificate 

number 10,000 is reached (after 9999), the 

reference number re-starts at 0001

Note: ISO country names and codes can be 

found at: 

http://www.iso.org/iso/english_country_na

mes_and_code_elements
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3. Part I – Details Identifying 

Fishery Products

Description of fishery/aquaculture product

Enter an appropriate description of the product(s) being 

shipped, i.e., “Frozen, Dressed Head-off Coho Salmon.”

Cross out either “fishery” or “aquaculture,”whichever does 

not apply.

Species (scientific name)

Enter the scientific name of the species being shipped, e.g., 

“Oncorhynchus kisutch” for Coho salmon. Refer to the 

FDA Seafood List for a listing of common and species fish 

names.

Presentation of Product and Type of Treatment

Enter “frozen,” “canned,” “dried,” “smoked,” “preserved,”

or other description as appropriate.

Code Number (where available)

Enter lot number if available. If none, leave blank.

Type of Packaging

Enter a description of the packaging, e.g., “Fiberboard 

Master Cartons with Plastic Liners.”

Number of Packages

Enter the exact number of packages in the shipment.

Net Weight

Enter the total net weight of the shipment.

Requisite Storage and Transport Temperature

Enter the manufacturer’s recommendation for shipping 

temperature, e.g., “45°F or 6°C.” General storage terms, 

such as “ambient,” “refrigerated,” “iced,” or “frozen” are 

acceptable.

4. Part II – Origin of Products Name(s) and Official Approval/Registration 

number(s) of establishment(s), factory vessel(s), or 

Cold Store(s) Approved or Freezer Vessel(s) 

Registered by the Competent Authority to the EC

For Value-Added Processors: Enter the name of the last 

Value-Added Processor, city, state, and CFN or FEI 

number. If the processor is a vessel, enter the vessel 

name. If the shipment includes product from more than 

one establishment, the names and CFN or FEI numbers 

of all the establishments should be entered.

Example: Basalt Cove Seafood, Somewhere City, AK

CFN: 1234567

Fresh Fish Express, Inc., Astoria, OR

FEI: 9999999999

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Note: Always check the link below to assure 

company is in good standing with the FDA and 

is currently on the Approved List without 

exemptions.

http://www.fda.gov/Food/FoodSafety/ProductSpecificInformation/Seafood/ImportsExports/ucm1

26413.htm
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If the product has been value added by several different 

establishments, the EU Certificate should identify the 

last establishment that processed the product. For 

example, if salmon were eviscerated and frozen at 

establishment “A”, portioned at establishment “B”, and 

breaded and placed in the final package at 

establishment “C”, then the EU Certificate should 

identify establishment “C” as the processor.

For establishments acting solely as dispatchers: Enter 

the names, city, state, and CFN or FEI numbers of the 

last value added processor of the product being shipped.

If the establishment uses fish and fishery products from 

a foreign source, the inspector shall determine that the 

firm and country appear on the European Union website 

at: 

http://ec.europa.eu/food/international/trade/third_en.htm.

This information should be recorded and retained for a 

period of three years.

For other than Value-Added Processors: Enter the name, 

city, state, and CFN or FEI numbers of the Processor 

shipping the product.

5. Part III – Destination of 

Products

The Products are Dispatched: From

Enter the city/state the product left the country, e.g., 

Los Angeles, CA, USA.

The Products are Dispatched: To

Enter the port of debarkation, e.g., “Le Havre, France,”

or if it is an air shipment, “Charles De Gaulle 

International Airport, Paris, France.”

By the Following Means of Transport

Enter the means of transport, e.g., “Air freight 

Northwest Airlines Flight 789.”

Name and Address of Dispatcher 

Enter the establishment name and address of the 

company or person that is making the shipment, e.g., 

“East West Seafood, P.O. Box 123 Seattle, WA, USA”

Name and Address of Consignee at Place of 

Destination

Enter the name and address of the final destination, 

e.g., “Pierre’s Seafood, 508 Rue Lafayette, Paris, 

France.”

Note: Flight information is optional but 

advisable, as there may need to be additional 

confirmation of this sort by some EU 

countries. Container numbers and seal 

numbers are optional per customer request)
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6. Part IV – Health 

Attestation/Certification

Place

Enter the location address of the issuing NOAA field 

office.

Date

Enter the date the certificate is issued.

Official

Enter the Name/Number/Title of Inspector/Officer 

signing certificate. Sign and stamp certificate in color 

other than printed certificate particulars.

Instructions for Completing the EU Certificate for Molluscan Shellfish

I.1. Consignor 

Enter the name, address, zip code, and telephone number of the company or person that owns 

the product(s). 

I.2. Certificate reference number 

Assign the certificate number per standard procedure. 

I.3. Central Competent Authority 

Enter “United States Department of Commerce Seafood Inspection Program”

I.4. Local Competent Authority 

Enter the name and address of the State Shellfish Control Authority, e.g. “Commonwealth of 

Massachusetts, Dept. of Public Health, Div. of Food and Drug, 305 South Street, Jamaica Plain, 

MA 02130”. (See the State Program Officers Responsible for Interstate Shellfish Sanitation 

Certificates Interstate Certified Shellfish Shippers List 

https://info1.cfsan.fda.gov/shellfish/sh/shellfis.cfm#state )

I.5. Consignee 

Enter the name, address, postal code, and telephone number of the company of person that is 

purchasing the product(s). 

I.7. Country of origin 

Enter the ISO name and the ISO code for the country of origin, e.g. - “United States” and “US”

respectively. (See the ISO website at 

http://www.iso.org/iso/english_country_names_and_code_elements)

I.8. Region of origin 

Enter the Name and Code (Approval Number) of the production area. (See attached List of 

Production Areas EUMoll6.pdf) 

I.9. Country of destination 

Enter the ISO name and the ISO code for the country of destination. (See the ISO website at 

http://www.iso.org/iso/english_country_names_and_code_elements)

I.11. Place of origin 

Enter the name, address, CFN or FEI number of the company shipping the products. 

I.13. Place of loading 

Enter the place the product will leave the country, e.g., “Seattle, WA USA.”

1.14. Date of departure 

Enter the actual date of the voyage or flight. 

I.15. Means of transport 

Check the appropriate box for the means of transport 

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115

Identification: - Enter the flight number, name of the vessel, etc. as appropriate. 

Documentary references: - Enter the commercial document (Bill of Lading) number. 

I.16. Entry BIP in EU 

Enter the port of debarkation, e.g., “Le Havre, France,” or if it is an air shipment, “Charles De 

Gaulle International Airport, Paris, France.”

Note: This must be one of the border inspection posts listed in the most recent amendment 

to the 2001/881/EC: Commission Decision of 7 December 2001 drawing up a list of border 

inspection posts agreed for veterinary checks on animals and animal products from third 

countries

http://eur-lex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=en&model=guicheti&numdoc=32001D0881http://eurlex.europa.eu/smartapi/cgi/sga_doc?smartapi!celexapi!prod!CELEXnumdoc&lg=en&model=guicheti&numdoc=32001D0881 

I.19. Commodity Code (HS code) 

For Molluscan Shellfish use “03 07”

I.18. Description of commodity 

Enter a general description of the commodity or commodities, e.g., live oysters, frozen scallops, 

chilled mussels, etc. 

I.20. Quantity 

Enter the total net weight, in Kilograms (Kg) of the shipment. 

I.22. Number of packages 

Enter the exact number of packages (master cases) in the shipment. 

I.23. Identification of container/Seal number 

Enter the container number(s) and the seal number(s), if applicable. Enter “N/A” if not 

applicable. 

I.24. Type of packaging 

Enter the type of packaging. Enter “Various” if necessary. 

I.25. Commodities certified for 

Check the box for “Human Consumption.”

I.27. For import or admission into EU 

Check the box for “For import or admission into the EU 

I.28. Identification of the commodities 

Species (Scientific name) - Enter the common name and the scientific name (in parenthesis) 

for each species from each establishment, e.g., Pacific Oysters (Crassostrea gigas). The FDA 

Seafood List is a listing of common and species fish names. It can be viewed on the FDA website 

at www.cfsan.fda.gov/~frf/seaintro.html

Nature of commodity – leave blank 

Approval number of establishments Manufacturing plant - Enter the name and CFN or FEI 

number of last establishment that processed or handled the molluscan shellfish for each species. 

Note: The establishment must be listed in the most recent Interstate Shellfish Shippers List

at https://info1.cfsan.fda.gov/shellfish/sh/shellfis.cfm

Number of packages - Enter the number of boxes or containers for each species from each 

establishment. 

Net weight - Enter the net weight, in Kilograms (Kg), for each species from each establishment. 

II.a. Certificate reference number 

Same as 1.2 

II.b. 

- Official Inspector 
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116

Name – Enter the name of the certifying person in capital letters. 

Date -Enter the date the certificate is signed 

Additional Instructions: 

- Printing - Print 2 Sided (back-to-back) on Legal paper (must select before printing) 

- Animal health attestation - Mark (draw a diagonal line) through the Animal health attestation 

paragraph (II.2.) on page 2 in non-black ink 

- Official Inspector (continued): 

Qualification and title – Complete qualification and title in non-black ink 

Signature of official inspector - Sign in non-black ink. 

Stamp - Apply the official stamp as indicated.

Instructions for Completing the EU IUU Catch Certificate

To establish and implement a procedure which will assure national uniformity in the completion 

and issuance of the EU-IUU Catch Document from computer based requests (online request 

system) and work orders (PDF requests).

General

In order to meet the European Commission Regulation 1005/2008 (“the IUU Regulation”) to 

prevent, deter and eliminate illegal, unregulated and unreported (IUU) fishing, the NOAA 

Fisheries Service Seafood Inspection Program (SIP), also known as the USDC Seafood 

Inspection Program, will begin to issue catch documents for wild fishery products caught by U.S. 

flagged vessels on or after January 1, 2010 and intended for export to the European Union (EU). 

The catch document (See Attachment 1 & 2) will be available individually or in a package with 

the already required EU export health certificate. There is a fee for a single certificate or the 

package of both documents. Both documents may be requested electronically but only the catch 

document can be delivered electronically to the requestor at this time. The health certificate may 

only be delivered via Fed Ex or picked up in person at the nearest inspection office. 

To request export certificates for products going to the EU, a requestor must now enter a request 

for export certification through the SIP’s online web-based request system. To access the system, 

the requestor must sign up for a user account by submitting an access request to the SIP online at 

https://seafoodinspection.nmfs.noaa.gov/customer/customerlogin.html. This is not a lengthy 

process and will facilitate all future requests for certificates.

Procedures for Certifying Products using the EU IUU Catch Document

A. Requests for Inspection: Whether a request is received through the online request system, 

telephone, fax, or in writing, the information listed on NOAA Form 89-814, (Request For 

Inspection Services

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), must be obtained from the applicant. If a written request does not 

contain the information necessary to issue the certificate, contact the requestor for pertinent 

information. (On-line applicants will be notified automatically by the online request system 

during the application process if information is missing or incomplete.) The EU IUU Catch 

Document is prepared by transferring to it the information and data below, taken from the 

inspection request and records relative to the shipment. The form will be distributed 
NOAA HANDBOOK 25

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electronically from the SIP issuing Office on computer only. 

B. Completion: 

1. This certificate number will be generated by the online request system or the Inspection 

Office staff for PDF forms using SIP policy for numbering certificates.

The numbered paragraphs below correspond to the numbers on the example 

catch document, attached below. The SIP will complete Page 1 ONLY. The SIP cannot 

complete the fields contained under Section 6, EU Importer Declaration; Section 7, Import 

Control Authority; or, Section 8, European Community Re-Export Certificate contained on 

page 2 of the catch document. The information contained in these sections is intended to be 

completed upon import into the EU and upon re-export from the EU after the document is 

issued by SIP. Page two will be issued as a separate document. 

2. Enter the Regional Office Information 

3. Enter the USDC Local Office. 

4. Enter the USDC Local Office telephone number.

5. Enter the USDC Local Office fax number.

6. Enter the USDC Local Office address. 

7. Enter the requesting company name. 

8. Enter the requesting company address. 

9. The representative of the requesting company that has supplied the certificate 

information should provide an electronic signature and email address to be inserted into 

this block. 

10. The date of the representative electronic signature application should be entered in this 

block. 

11. The requesting company may provide an Official Seal or Company Logo electronically to 

be inserted into this block. This is an optional block to fill.

12. Enter the commodity description. For each lot of product, enter a description of the 

product, with its brand if so labeled. Enter the type e.g., fresh, frozen, canned etc., and 

the style,

13. Enter the scientific name of each product. 

e.g., skin-on, cooked, raw, whole, eviscerated, etc.

14. Enter the total net weight of each item covered in this block. Separate product will 

require breakdown of weights. 

15. Enter the 4 digit product HS code for each product.

16. Enter the FAO Catch Area for each product.

17. Enter the catch date or a range of catch dates during which the product was caught for 

the product listed. 

18. The Inspectors digital signature is placed here. 

19. The date of Inspector signature is placed here.

20. The NOAA Logo is placed in this location. 

C. Distribution: Completed EU IUU Catch Certificate 

1. Forward an electronic copy of the IUU certificate to the requestor for completion. 
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ATTACHMENT #1

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NOAA HANDBOOK 25

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ATTACHMENT #2

The Issuance of IUU Catch Certificates for Shipments Going to Non-EU Countries

Section 06 Instructions for Certifying Fish and Fishery Products to the People’s Republic of China

Section 07: Instructions for Certifying Salmonid Products to Australia 

Section 08: Instructions for Completing the French Certificate for Fish and Fishery Products to French Colonial 

Territories 
NOAA HANDBOOK 25

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Chapter 5 – Prohibitions in Certification of Seafood

Section 01: Artificial Color in Cooked Shrimp

Section 02: Canada’s Position on Artificial Color in Cooked Shrimp

Section 03: Bloody Catfish 

Chapter 6 – Certification of Processing Methods

Section 01: Inspection and Certification of Cryovac Vacuum Packaged Marine Fresh Fish Products (Salt Water 

Species Only) 

Section 02: Inspection and Certification of Vacuum Packaged Hot-Processed Smoked or Hot-Processed SmokeFlavored Salmon

Section 03: Inspection and Certification of Vacuum and Modified Atmosphere Packaged (VAC and MAP) Marine 

and Estuarine Bulk Raw Fishery Products Held at Only Refrigerated Temperatures (non-Frozen) 

Chapter 7 – Technical Information

Section 01: Technical Notes 

Section 02: Codex Alimentarius Code of Practice for Fish and Fishery Products

Section 03: General Information 

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