FDA WARNING_LETTER - All American Trading Of Houston, Inc. - September 10, 2012

On November 19, 2012, the FDA issued a Warning Letter to All American Trading of Houston, Inc. following an inspection from September 6-10, 2012. The inspection revealed serious violations of the seafood Hazard Analysis and Critical Control Point (HACCP) regulation (21 CFR Part 123). As a result, the firm's refrigerated herring marinades and sauces, caviar, and cod roe products are deemed adulterated under Section 402(a)(4) of the Federal Food, Drug, and Cosmetic Act.

Key violations include: 1. **Lack of HACCP Plan:** The firm does not have a HACCP plan for capelin caviar to control pathogen growth and toxin formation, including *C. botulinum*, violating 21 CFR 123.6(a) and (b). 2. **Inadequate Hazard Analysis:** The HACCP plan for herring and cod roe fails to list pathogen growth and toxin formation, including *C. botulinum*, as a reasonably likely food safety hazard, violating 21 CFR 123.6(a) and (c)(1). 3. **Insufficient Critical Limits:** The HACCP plan for herring and cod roe lists an inadequate critical limit at the receiving critical control point (CCP). The stated critical limit, "Temperature Check Must be under (b)(4)," does