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**Effective immediately the main phone number for the Seafood Inspection Program is 301-427-8300**
**NOAA Inspection Manual 25**
Return to Table of Contents

**Chapter Four: Policies, Procedures, and Requirements for the Audit  of Fisheries Products on a Lot by Lot Basis**
- Authority

Authority  for the USDC Seafood Inspection Program (SIP) to provide product inspection  (audit) services can be found within the Agricultural Marketing Act of 1946,  the Fish and Wildlife Act of 1956, and the regulations promulgated under these  authorities (i.e., 50 CFR Part 260.)
- Introduction  

Lot inspection  (audit) and sampling services are performed by the USDC Seafood Inspection  Program on a voluntary, fee-for-service basis. Product inspection services can  be provided to determine adherence to:    
-  Minimum  Acceptable Quality (MAQ)
- U.S.  Grade A, B, or C Attributes
- Buyer  Specifications (i.e., Net weight, size, count and/or other product attributes  as defined by the buyer)

These services conform to global activities to  harmonize inspection protocols. These services are designed to enhance the  safety, wholesomeness, economic integrity, and quality of seafood available to  consumers. If there are no Buyer Specifications from the applicant, the minimum  inspection effort applied to every lot inspection will be adherence to the  Minimum Acceptable Quality Standard of Quality and Condition, Flavor and Odor. 
- Scope       The  purpose of product audits is to facilitate the distribution of fish and fishery  products that are safe, wholesome, properly labeled, and of desired uniform  quality. Any individual, processor, retail operation, warehouse operation, or  import/export dealer, foreign or domestic, may use the services of this  program. 
- Definitions
- Application for       Services
- Lot       Identification         On the Request for Inspection Services form, the  applicant will clearly identify the lot to be inspected, including the lot  number, brand, product name, number of cartons/cases and size, and the total  pounds. Any additional codes and/or identification marks on the containers  should also be noted. The application will also indicate where the product is  physically located, and the applicant is responsible for making sure that the  product is available for inspection. 
- Reworked or       Reconditioned Product       USDC SIP inspectors and licensed samplers will neither  inspect nor certify products which have been reworked or reconditioned for  subsequent delivery to other Federal agencies, i.e., Defense Personnel Support  Center or U.S. Department of Agriculture, without first having written  confirmation from the purchasing agency that reworking or reconditioning of  the lot is acceptable. The fact that the lot is derived in whole or in part  from reworked or reconditioned product shall be noted on the certificate, as  well as specific reference to the letter/document received from the purchasing  agency which authorized its use or inclusion. 
- Equipment       Checklist

For the accurate and  efficient performance of product audits, each regional office shall have the  appropriate and necessary equipment available to perform such audits. Equipment  that is required is specific to each Standard or product evaluation, and could  include the following:
- Appropriate  inspection forms and score sheets
- Balance accurate to  0.01 gram
- Boilable bags
- Box cutter
- Can press
- Candling table/light
- Deep fryer with wire  basket
- Digital camera
- Drill – high speed,  ¼” bit
- Forceps with blunt  points
- Knife
- Magnifying glass with  6X or greater power
- Microwave oven
- Nut pick
- Nylon mesh bags  (other materials may be used, as appropriate)
- Packing tape
- Paper towels
- Plastic or glass  bowls, various sizes
- Plastic grid marked  in ¼”, ½”, and 1” squares for measuring defects
- Roe tub opener
- Sanitary can opener
- Seam micrometer
- Seam nippers
- Shallow baking pan
- Sieves – U.S. No. 8  (8” and 12”), U.S. No. 20, and U.S. No. 4 (12”)
- Sink with cold water  and stand pipe
- Spatula, 4” blade  with rounded tip
- Stirring device  capable of rotating paddle at 120 rpm
- Stop watch or timer,  readable to the second
- Thermometer – dial or  digital probe
- Thermometer –  immersion type, accurate to ±2°F
- Tongs
- Trier
- Two-vaned paddle,  each vane measuring about 1” by 3”
- Vacuum gauge
- Water bath
- Wire whip
- 2-gallon container, about 9” diameter
- Accuracy Checks and Calibration of Equipment

All thermometers, scales, and balances shall be  verified according to USDC SIP official accuracy check and calibration  procedures, which include equipment calibration at least twice per year, or  more frequently depending on storage and usage conditions. Accuracy check and  calibration records shall be maintained on file at the local inspection office.
- Labeling       Policies  
Label  Review and Approval
PUFI  Policy

The Processed Under Federal Inspection (PUFI) Mark identifies fishery products processed under USDC inspection in an approved establishment, inspected for safety, wholesomeness and proper labeling, and conforms to quality and other criteria in an approved specification.
****
**PUFI  Statement using the company name:**

******PROCESSED BY™****------------------------------****UNDER FEDERAL INSPECTION              U.S. DEPT. OF COMMERCE**

**PUFI Statement:**

**Processed Under Federal Inspection™**
**U.S. DEPARTMENT OF COMMERCE**
The  PUFI Mark may be used for:       - retail packages,       - cases or shipping cartons,       - point-of-sale notices, and       - advertisements/promotional literature. 

The use of the PUFI Mark requires that the:       - participant be under USDC contract agreement for in-plant  inspection service,       - facility/vessel meets applicable USDC sanitation requirements,       - product specifications and labels be approved by USDC,       - products conform to USDC approved specifications,       - product meets principal display panel declarations,        - PUFI mark or statement be affixed to or next to certified PUFI  products only, and        - product  be processed and packaged under USDC approved inspection program.
Country  of Origin Labeling
Customs  Labeling
Declaration  of Phosphates
Date  Labeling of Fresh Fish
Retail  Labeling of Fish Portions
Scrod  Labeling
Metric  Declaration of Quantity of Contents
Specification  Review and Approval Instructions
New  Product Specifications
Generic  Product Specifications
Policy for Use  of Official Marks and Advertising
Procedures for Child  Nutrition (CN) Label Approval

- Minimum       Inspection Effort for Lot Inspection 
- Methodology       - Sample  Selection      - Use of Acceptance  Numbers 
  - Container  Integrity
  - Label  Review Procedures
  - Net  or Drained Weight Determination
  - Glaze  Determination of Frozen Product
  - Fish  Flesh Determination
  - On-line  Flesh Determination
  - Procedures  for Cooking Samples
  - Determination  of Ammonia in Dogfish
  - Rounding  Rules/Dropping and Retention of Numbers 
- Product (Lot)       Inspection Procedures       - Whole  and Dressed Fish (reference grade std)                   - Fresh
    - Frozen (block)
    - IQF
Fish  Fillets (reference grade std)
- Fresh
- Frozen (block)
- IQF
Fish  Steaks and Portions (reference grade std)
- Fresh
- IQF
Canned/Pouched  Tuna and Salmon (reference CID)
Shrimp  (reference grade std)
- Fresh
- Frozen
- Frozen Raw Breaded
- “Hand-Breaded”
- Determination of  Count per Pound in Shrimp 
- Shrimp Illustration
Crustacean  Shellfish
- Frozen Raw
- Cooked
Molluscan  Shellfish - Shucked
Scallops  (Raw) (reference grade std)
- Fresh
- Frozen
- Scallop Moisture  Determination
Frozen  Breaded/Battered Fish (reference grade std)
Simulated  Seafood Products
Cephalopods
Roe
Live  Products
- Crustacean Shellfish
- Molluscan Shellfish
Harvester  Tag
Dealer  Tag

- Miscellaneous Live  Fish
Dry  Ingredients
Reworked  or Reconditioned Product 
Inspection  of Endangered Species

- Lot       Acceptance/Rejection
The lot is accepted  if the number of non-conforming units is less than or equal to the acceptance  number for that sample size. **Note: There  is no acceptance number for decomposition.** If the number of non-conforming  units exceeds the acceptance number for that sample size, the lot is rendered  nonconforming, or Grade Not Certified. The applicant shall be notified  immediately in the case a lot is deemed nonconforming.      
After the inspection, samples are returned, destroyed,  or given to charity, based on the disposition instructions provided on the  Request for Inspection Services form. 
Certificates

Certificates are  issued according to the type of sampling and inspection performed, i.e., Lot  Inspection Certificate, Export Health Certificate, Certificate of Origin,  Certificate of Sampling, EU Certificate. All certificates must be filled out  completely by the inspector performing the services or his/her designee, in  ink, and include the inspector’s name and ID number, and date of service.    
Certificates will  attest to the inspection results of the MAQ attributes, grade attributes, or  Buyer Specifications. 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”. If, however, the inspector  suspects short weights and/or counts, s/he is obligated to evaluate and report  the results.

The Lot Inspection Certificate will be issued  regardless of whether the product is accepted or deemed nonconforming, since it  is an official record of the inspection findings. Lot Inspection Certificates  shall be completed and distributed as described in the Instructions for  Completing Lot Inspection Certificate, Chapter 7, Section 2. 
Appeal       Procedures
An application for an appeal inspection may  be made by any interested party who disagrees with the results of an inspection  as stated in an inspection certificate, if the lot of processed products can be  positively identified by the inspection service as the lot from which  officially drawn samples were previously inspected. Such application shall be  made within thirty (30) days following the day on which the initial inspection  was performed, unless an extension is approved by the Chief Quality Officer,  SIP.      
Application for an appeal inspection may be  filed with: (1) the inspector who issued the inspection certificate on which  the appeal is requested; or (2) the Regional Inspection Branch nearest the  place where the processed product is located. The application for appeal  inspection shall state 1) the location of the lot of processed products and 2)  the reasons for the appeal, as well as 3) the date and serial number of the  certificate covering inspection of the processed product on which the appeal is  requested. The application may also be accompanied by a copy of the previous  inspection certificate and any other information that may facilitate  inspection. The application for appeal shall be made in writing.

An application for appeal inspection may be  withdrawn by the applicant at any time before the appeal inspection is  performed, but the applicant must pay for any time incurred by the inspector in  connection with such application, any travel expenses, telephone, or other  expenses which have been incurred by the inspection service in connection with  such application.

Appeals are granted by the appropriate  Regional Branch Chief. An application for an appeal inspection may be refused  if it is determined that:
-  The reasons for the appeal inspection are  frivolous or not substantial;
-  The quality or condition of the processed  product has undergone a material change since the initial inspection;
-  The lot in question is not, or cannot be  made accessible for the selection of officially drawn samples;
-  The lot relative to which the appeal  inspection is requested cannot be positively identified by the inspector as the  lot from which officially drawn samples were previously inspected; or
-  There is a noncompliance with the  regulations in this part. Such applicant shall be notified promptly of the  reason for such refusal.

An appeal inspection shall be performed by an  inspector or inspectors (other than the initial inspector) authorized for this  purpose by NMFS and, whenever practical, such appeal inspection shall be  conducted jointly by two inspectors. However, the inspector who made the  initial inspection may be authorized to draw the samples when another inspector  or licensed sampler is not available in the area where the product is located.

After an appeal inspection has been  completed, an inspection certificate shall be issued showing the results of the  appeal inspection, and such certificate shall supersede the inspection  certificate originally issued. Each superseding (appeal) inspection certificate  shall clearly identify the number and date of the inspection certificate which  it supersedes. The superseded certificate becomes null and void upon the  issuance of the superseding (appeal) inspection certificate and shall no longer  represent the quality or condition of the processed product described therein.
- Fees and Charges
   The applicant is  responsible for all fees and charges associated with the sampling and  inspection of the product. In the event of an appeal inspection, if the  applicant for both the initial and appeal inspections is the same and the  results of the appeal inspection are in favor of the applicant, there will be  no charge to the applicant for the appeal inspection. If, however, the results  of the appeal are not in favor of the applicant, the applicant will be charged  for the appeal inspection and all related travel expenses.            The inspector will complete a Daily Record of Charges,  which includes time spent sampling, inspecting, and completing certificates, as  well as any travel expenses incurred. The Regional Inspection Branch will,  under separate cover, 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. The current fee schedule for inspection and analytical services can  be found in Chapter One, Section 15a.