Wednesday Januray 02, 2002

Notice to Seafood Suppliers
Your Address

Dear Sir:
Great Northern Products Ltd has implemented product food safety specifications in an effort to comply with U.S.F.D.A. HACCP regulations that became effective on December 18, 1997. As part of this regulation, the U.S. Food and Drug Administration requires that all seafood importers have, and implement such product specifications.

The following product specification sheet addresses the food safety aspects that may apply to the seafood supplied by your firm. In implementing these specifications, it is expected you will take appropriate steps to control the potential food safety hazards associated with the product; sanitation monitoring; and following good manufacturing practices.  Please note these product specifications relate to food safety issues only. Please review the table of U.S. guidelines to determine if any other levels, not appearing on our specifications, apply to your product.  Although not listed here, your product must also conform to non-safety FDA action levels and guidelines (e.g. decomposition, filth, product weights and labeling, etc)

Please read these specifications to determine if your seafood would qualify for inclusion into Great Northern Products Ltd's seafood product roster. 

Thank you

Very truly yours,

Great Northern Products Ltd.

Import Department

Following Pages      1.  FDA HACCP Regulation

• Product Specifications
• FDA Good Manufacturing Practices Regulation
• Excerpt from FDA's Hazards Guide

PRODUCT FOOD SAFETY SPECIFICATION SHEET

Product Name:  Farm Raised and Wild Caught Sea Products
Product Form:  Fresh, Frozen and Smoked

Purpose: Firms processing and supplying fresh, frozen and smoked seafood to Great Northern Products Ltd. must make a good faith effort to comply with: (1) the U.S. Food and Drug Administration (FDA) mandatory HACCP regulation, and (2) the product specifications identified hereunder. [Note: U.S. seafood importers are required by the U.S. Food and Drug Administration HACCP regulation, as of December 18, 1997, to implement seafood product specifications related to potential safety hazards]. Your signature at the end of this specification sheet indicate you have read this specification and agree to its provisions. Your cooperation in assuring our customers are receiving safe products is appreciated.

Product Specification - Potential Chemical Hazards

1. Environmental Chemicals and Pesticides

The FDA has determined that the possible use or presence of environmental contaminants such as pesticides near aquaculture ponds or areas requires that suppliers of seafood farm-raised and wild evaluate the ``significance" (likelihood) of these food safety hazards occurring when conducting their hazard analysis. The FDA tolerance, action and/or guidance levels listed in the following Table must not be exceeded.  Moreover, if there is likelihood that levels could be exceeded, suppliers may need to process under an appropriate HACCP plan to assure legal levels are met.

CHEMICAL CONTAMINANT FDA LEVEL

• ALDRIN/DIELDRIN    0.3 PPM
• CHLORDANE    0.3 PPM
• CHLORDECONE    0.3 PPM
• DDT, TDE, DDE    5.0 PPM
• DIQUAT     0.5 PPM
• FLOURIDONE     0.5 PPM
• GLYPHOSATE   0.25 PPM
• HEPTACHLOR/HEPTACHLOR EPOXIDE 0.3 PPM
• MIRAX    0.1 PPM
• PCB      2.0 PPM
• SIMAZINE     12.0 PPM
• 2,4 D      1.0 PPM  

Aquaculture Drugs

The FDA has determined that unregulated drug use in farm-raised products poses a potential health hazard.  To control this hazard only drugs approved by FDA and those, which are considered low regulatory priority, can be used.  When drugs are used they must adhere to established FDA limits. These farm raises seafood provided to Great Northern Products Ltd must be processed under an appropriate HACCP plan which controls the potential hazard of inappropriate drug use.

Potential Biological Hazards

FDA has established action levels for certain pathogenic (disease causing) microorganisms. Suppliers must adhere to the following limits: no detectable salmonella, and for Staphylococcus auerus, no enterotoxin, and less that 10,000'g (Kanagawa positive or negative). In addition, suppliers should adhere to the sanitation monitoring provisions in the FDA HACCP regulation and assure its sanitation operating procedures and good manufacturing practices minimize the occurrence of other potentially harmful bacteria.

Potential Physical Hazards
No metal fragments in product

As an importer of fish and fishery products, our firm will perform the following procedures to be sure that all fish imported by us meets our obligation under the HACCP regulations.

Every time we import fish we will either:

1. Import from a country that has an active MOU or similar agreement with the Food and Drug Administration that covers the fish we are importing.

Or, if we are not importing from a country with a MOU, we will

2. Have product specifications for each fish or fishery product imported by us. These specifications will alert our processors to potential safety hazards to make sure that the product we received from them is not adulterated because it was processed under sanitary conditions or may be injurious to health.  We will have each of our foreign processors sign a copy of our product specifications and return it to us for our files.
   And, we will do one of the following verification steps:
• We will have the foreign processor's HACCP and sanitation monitoring records on file for the specific lot we are importing;
• We will have a continuing or lot-by-lot government or third party certificate stating that the imported fish was processed under the HACCP regulations;
• We will regularly inspect the foreign processor to be sure the imported fish is being processed according to HACCP regulations;
• We will maintain a copy, in English, of the foreign processor's HACCP plan, and a written guarantee from the processor that the imported fish is processed according to HACCP regulations;
• We will periodically test the imported fish, and have a copy, in English, of a written guarantee from the foreign processor that the imported fish is processed according to HACCP regulations;
• We will do any other verification procedures as needed to provide an equivalent level of assurance of compliance with the HACCP regulations

Should you have any further questions regarding the above content, please do not hesitate to contact me directly at the above address, or fax #, or email me at: haccp@northernproducts.com

Great Northern Products Ltd. PO Box 7622 Warwick, Rhode Island 02887 USA
Tel: (401) 492 4590 - Fax: (401) 490 5595
Copyright 2002 Great Northern Products LTD- E-mail GNP