Riverfront Egg Robbers Inc. – FDA Warning Letter, Jan 12, 2012

On June 20, 2012, the FDA issued a Warning Letter to Riverfront Egg Robbers, Inc. following an inspection of their seafood processing facility in Biscoe, Arkansas, from January 10-12, 2012. The inspection and subsequent review of their revised HACCP plan revealed serious violations of the seafood Hazard Analysis and Critical Control Point (HACCP) regulation (21 CFR Part 123) and food labeling requirements (21 CFR Part 101).

The FDA determined that the firm's sturgeon and paddlefish roe (caviar) products were adulterated under Section 402(a)(4) of the Federal Food, Drug, and Cosmetic Act, as they were prepared, packed, or held under insanitary conditions. Specific HACCP violations included an inadequate critical limit for water phase salt at the "Salting" critical control point, which was not sufficient to control pathogens like *Clostridium botulinum* growth and toxin production. Additionally, monitoring procedures were found to be inadequate; at "Receiving," the firm failed to monitor the adequacy of ice, and at "Salting," the use of a (b)(4) for determining water phase salt was deemed unreliable.

Labeling violations included the absence of a net quantity of contents statement (21 CFR 101.105) and misleading storage instructions. Despite products being stored frozen and