Sources & templates

Show your work, share your gear

A gap analysis nobody can check is just an opinion. Every claim on this site traces back to something on this page — and the plan checklist below is what a California operator actually has to write down today.

Food safety plan building blocks

Drawn from FDA's preventive controls requirements, the Connecticut Sea Grant hazards guide, and a working California wild-harvest plan. Where no standard exists, the requirement becomes: decide, justify, and write it down.

01

Harvest / grow-site screening record

Site name and coordinates, nearest outfall or creek mouth, MPA check, sanitary survey notes, and the reason you consider the site suitable. Write down what would make you stop harvesting there.

02

Rainfall and closure hold

California wild-harvest practice in the field is a 72-hour hold after significant rainfall, plus deferral to CDPH biotoxin advisories and phytoplankton monitoring. Put your trigger, your rain gauge source, and your hold period in writing — no rule sets it for you yet.

03

Biotoxin and bloom watch

Which advisory you monitor, how often, who checks it, and what happens to product already harvested when an advisory posts.

04

Cold chain from cut to chill

Time from harvest to ice or chill, transport temperature, and your maximum allowable delay. Record actuals per lot, not just the target.

05

Wash and foreign material removal

Water source and quality, wash steps, epibiont and sand removal, screening, and your visual acceptance standard.

06

Drying step definition

Method, temperature, airflow, duration, load depth, and endpoint. If you have a water activity meter, record readings — this is the single most valuable dataset the state currently lacks.

07

Packaging decision

If you vacuum-pack or reduce oxygen, document the barrier keeping C. botulinum out: water activity, salt, acidification, or refrigeration. This is the highest-consequence step with the least guidance.

08

Testing plan and reference limits

Which panels, which lab, what frequency, and — critically — which limits you're comparing against and why, since no federal seaweed action level exists.

09

Labeling positions

Species naming, iodine per serving, and your written decision on crustacean epibiont allergen advisory language.

10

Sanitation SOPs and logs

Water safety, food-contact surfaces, cross-contamination, handwashing, chemical control, and pest control — the eight sanitation keys, with a signed daily record.

11

Traceability and recall

Lot coding from harvest site and date forward, one-up one-back records, and a written recall procedure with contact list.

12

Records and reanalysis

Where records live, how long you keep them, and the date of your last hazard reanalysis.

Source library

13 primary sources behind the regulation pages, gap register, and roadmap.

Guidance
Connecticut Sea Grant / CT Dept. of Agriculture Bureau of Aquaculture · 2020

Seaweed Production and Processing in Connecticut: A Guide to Understanding and Controlling Potential Food Safety Hazards

The most complete state-level seaweed hazard analysis in the country. Companion to FDA's Fish and Fishery Products Hazards and Controls Guidance. California has no equivalent.

Legal analysis
National Sea Grant Law Center · 2024

Regulation of Dried or Dehydrated Seaweed (NSGLC-24-04-05)

Documents that states give growers conflicting answers on whether dried seaweed is a processed food. This is the single clearest federal-level gap.

Report
National Sea Grant Law Center / Seaweed Food Safety Working Group · 2021

Building Consensus on Seaweed Food Safety: Workshop Proceedings (NSGLC-21-06-02)

Where seaweed fits in the federal framework, hazard inventory, and the Part 117 vs. Part 123 question laid out side by side.

Guidance
National Sea Grant Law Center / National Seaweed Hub · 2023

Seaweed Food Safety: Comparing Compliance with Preventive Controls for Human Foods and Seafood HACCP

Side-by-side compliance comparison for growers caught between two federal rules.

Guidance
NOAA Fisheries / Southern California Offshore Aquaculture Interagency Working Group · 2025

Guide to Leasing, Permitting, and Authorizing Commercial Aquaculture Operations off the California Coast

The best existing map of who authorizes what off California — siting and leasing, not food safety.

Draft plan
California Ocean Protection Council · 2026

Draft Statewide Marine Aquaculture Action Plan

Open state planning process — the most immediate vehicle for getting seaweed food safety language into California policy.

Regulation
California Department of Fish and Wildlife · current

Commercial Harvest of Kelp and Other Marine Algae

Kelp Harvesting and Drying License requirements, administrative kelp beds, harvest reporting.

Regulation
U.S. Food and Drug Administration · in force

21 CFR Part 117 — Current Good Manufacturing Practice, Hazard Analysis, and Risk-Based Preventive Controls for Human Food

The rule most seaweed processors currently fall under, by default rather than by design.

Regulation
U.S. Food and Drug Administration · in force

21 CFR Part 123 — Fish and Fishery Products (Seafood HACCP)

Applies to fish and fishery products. Whether seaweed is inside this definition is still argued state to state.

Guidance
U.S. Food and Drug Administration · 2022 updates

Fish and Fishery Products Hazards and Controls Guidance (4th ed.)

No seaweed-specific chapter. Growers and states borrow from molluscan shellfish and other chapters by analogy.

Regulation
Interstate Shellfish Sanitation Conference / FDA · current

National Shellfish Sanitation Program Model Ordinance

The structural model most often proposed for seaweed: classified growing waters, state authority, interstate recognition. Seaweed is not in it.

Industry practice
Kelpful · 2020

Kelpful Food Safety Plan (California wild-harvest operation)

A working California wild-forage plan: harvest site screening, 72-hour rain closure, CDPH phytoplankton monitoring, cold-chain, sanitation logs. Shared with the project as real-world practice.

Report
UN Global Compact / Lloyd's Register Foundation · 2020

The Seaweed Manifesto

Global case for scaling seaweed, including the recognition that regulatory and safety frameworks lag the industry.