The U.S. Department of Agriculture has found Thailand’s food safety inspection system for fish of the order Siluriformes (catfish) to be equivalent to that of the United States. Thailand joins China and Vietnam in achieving equivalency status for catfish. Another dozen or more countries also export catfish to the U.S. by providing additional information for each shipment.

After two visits this year to Thailand, the in-country audit by USDA’s Food Safety and Inspection Service (FSIS) announced it will permit at least four Siluriformes fish slaughter and raw processing establishments to export product to the United States.

Congress transferred responsibility for both domestic and foreign catfish from the Food and Drug Administration to FSIS two years ago.

Catfish help keep Thailand in the world’s top 15 seafood exporters. And while it seeks equivalency status through the USDA process, Thailand has already been exporting catfish to the United States.

From March 1, 2016, to December 31, 2017, FSIS import inspectors performed 100 percent re-inspection for labeling and certification on 48,424 pounds of raw intact Siluriformes fish products exported by Thailand to the USA.  FSIS also completed re-inspection for additional types of inspection, including testing for chemical residues and refused 2,337 pounds because of public health reasons related to the presence of furazolidone in the product.

Furazolidone is a nitrofuran antibacterial agent and monoamine oxidase inhibitor used in both human and veterinary medicine.

The equivalence finding means Thailand will likely export more catfish to the United States under fewer restrictions. FSIS auditors visited Thailand from May 7-11 this year and returned for follow-up work Aug. 27-31. Thailand’s governing authority for regulating Siluriformes is the Department of Fisheries (DOF).

Government oversight is the first of six equivalence components that must stack up against the U.S. standards.

DOF is part of Thailand’s Ministry of Agriculture and Cooperatives and with three divisions, it regulates the nation’s fishing industry. One of those, the Fish Quarantine and Inspection Division (FQID) “is responsible for controlling and ensuring that Siluriformes fish and fish products exported from Thailand are safe, wholesome, and meet standards and requirements of importing countries by regulating, inspecting and controlling the sanitation of establishments as well as the safety and traceability of fish products from processing through reaching consumers.”

The FSIS audit team observed the FIQD inspectors at two facilities and reviewed records. Two other facilities were not in production during the in-country visit.

FSIS found Thailand lacking in sanitation standard operating procedures and maintaining records, and in verification procedures for Hazard Analysis and Critical Control Points (HACCP).

Thailand’s Department of Fisheries promised to correct any shortcomings identified by the FSIS auditors within 30 days and the U.S. said all documentation would have to be available at the time Thailand plans to export catfish.

FSIS auditors also reviewed was Government Statutory Authority and Food Safety and Other Consumer Protection Regulations as the second of the six
equivalence components.

“The food safety inspection system is to provide for regulatory controls,” says the 67-page audit report, “including but not limited to, control over condemned materials; complete separation of eligible Siluriformes fish products from ineligible products; government inspection of production activities at least once per production shift when producing products for export to the United States; and periodic supervisory visits to certified establishments to evaluate the performance of inspection personnel.”

The FSIS auditors found the pre-harvest operation (i.e., farm) did not maintain a tracking log of the movement of Siluriformes fish per the DOF’s regulations. FSIS said the DOF did not verify that the farm maintained a log of Siluriformes fish movements to facilitate traceback. And they found DOF without regulatory requirements to ensure that product labels include special handling statements and safe handling instructions.

Sanitation is the third area for the equivalency review.

“The FSIS auditors observed that product contact surfaces were soiled due to breakage of intestines during the establishment’s evisceration process. No immediate actions were taken by the establishment or the government inspector to restore sanitation conditions or prevent cross-contamination,” according to the report.

The fourth equivalency standard is the HACCP review.

“The FSIS auditors verified through records review that an establishment wishing to produce Siluriformes fish products must first submit a full HACCP program to the FIQD for review, which must meet the criteria of HACCP regulations for Siluriformes fish product processing,” the report said. “In interviews conducted during the audit, the DOF stated that the FIQD officials conduct verification of the acceptability of the certified establishments’ written HACCP programs in accordance with Codex Alimentarius HACCP principles.”

The fifth area for the on-site equivalency audit involves chemical residue.

“The food safety inspection system develops and implements a chemical residue testing program that is organized and administered by the national government,” its says. “The program includes a random sampling of muscle from Siluriformes fish, for chemical residues identified by Thailand’s inspection authorities or by FSIS as potential contaminants.

The FSIS auditors verified that the DOF developed the National Residue Control Program (NRCP). The NRCP is designed by a committee comprised of representatives of different fishery sectors, including the Coastal Fisheries Research Division; the Inland Fisheries Research Division; Fishery Quarantine Division; the DOF experts representing, the Aquatic Animal Feed and Research Division, Legal Affairs Division, Planning Division, and the FIQD.”

“The sixth of six equivalence components that the FSIS auditors reviewed was Government Microbiological Testing Programs. The system is to implement certain sampling and testing programs to ensure that Siluriformes fish and fish products prepared for export to the United States are safe and wholesome,” the report continues.

“Thailand currently has presented four establishments certified as eligible to export Siluriformes fish products to the United States. These establishments do not produce any low-acid canned or ready to eat Siluriformes fish products for export to the United States; therefore, government microbiological verification testing for Listeria monocytogenes and Salmonella is not required. FSIS does not have any regulatory requirements for a microbiological sampling of raw intact Siluriformes fish products. As a result, FSIS concluded that the DOF has developed and implemented a microbiological testing program that meets FSIS criteria for this component.”

The bottom line from the report is this:

“The FSIS audit determined that Thailand’s food safety inspection system governing fish of the order Siluriformes and their products is being implemented as documented in the SRT and according to the corrective actions taken in response to the deficiencies noted during the initial audit. FSIS auditors reviewed and analyzed each component and the corrective actions undertaken by Thailand and did not identify any findings that represented a potential to endanger public health.”

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