Concepts in Safety of Fish Products

Traditional food safety programs concentrate the responsibility to the processors and heavily rely on
end-product testing. There are, however, problems associated with this method:

 It is costly. A well equipped laboratory will be needed as well as trained personnel. The running
costs of a laboratory are high. Also, the cost of product “lost” to testing may be very high;
 The results are retrospective, and all costs and expenses have already been incurred if any hazard is
identified;
 It may take several days before results from end-product testing are available;
 The chances of finding a hazard will be variable, depending on the distribution of the
contaminants.

In response to these problems, new approaches to food safety have been emerging in recent years.
Assuring the safety of aquaculture commodities is now recognized as the responsibility of all involved
in its production, processing, trade and consumption. These include the producers, feed millers,
processors, transporters, distributors and the consuming public as well as the government that enforce
the safety regulations. These approaches integrate a preventive system where problems regarding
safety are anticipated and safety is built into the product right from the start.

Some of these methods are outlined below:

Generic requirements- these are measures which an establishment should comply in order to produce
safe aquaculture commodities. These are required before specific approaches (e.g. HACCP) can be
employed, also called prerequisite programs:
 Good Aquaculture Practice (GAP) - defined as those practices of the aquaculture sector that are
necessary to produce safe aquaculture commodities conforming to food laws and regulations.
 Good Manufacturing Practice (GMP) – those procedures for a particular manufacturing
operation which practitioners of, and experts in, that operation consider to be the best available
using current knowledge.
 Good Hygienic Practices (GHP)/ Sanitary Standard Operating Procedures (SSOP) – all
practices regarding the conditions and measures necessary to ensure the safety and suitability of
food at all stages- from production to consumption.

Prerequisites to HACCP:

The Processing Plant-

Operational conditions & procedures:

 Safety of water and ice.

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  Protection of food from adulterants.
 Proper labeling, storage and use of toxic compounds.
 Control of employee health condition.
 Pest control: exclusion or prevention of access, restriction by avoidance of conducive
environment for habituation of pest and destruction and eradication to be carried out by
qualified personnel
 Waste management
 Transportation and storage
 Traceability and recall
 Training

Specific Requirements

 Hazard Analysis Critical Control Points (HACCP)- a systematic approach which identifies,
evaluates, and control hazards which are significant for food safety. It is based on seven principles.

Application of HACCP
 Assemble HACCP Team
 Describe product
 Identify intended use and consumer
 Construct flow diagram
 On-site confirmation of flow diagram
 Conduct Hazard Analysis (principle 1). Hazard Analysis is the process of collecting and
evaluating information on hazards and conditions leading to their personnel to decide which are
significant for food safety and therefore should be addressed in the HACCP system.
 Determine Critical Control Points (CCPs) (principle 2)or the point, step or procedure at which
control can be applied and a food safety hazard can be prevented, eliminated or reduced to
acceptable levels.
 Establish Critical Limits (principle 3) or criteria which separate the acceptable from not
acceptable.
 Establish Monitoring Procedures (principle 4). Monitoring is the act of conducting a planned
sequence of observations or measurements of control parameters to assess whether a CCP is under
control
 Establish Corrective Actions (principle 5). Corrective action is any action to be taken when the
results of monitoring at the CCP indicate a loss of control
 Establish Verification Procedures (principle 6). The application of methods, procedures, tests
and other evaluations, in addition to monitoring to determine compliance with the HACCP system.
 Establish Record- Keeping and Documentation Procedures (principle 7). Ensures that the
information resulting from the HACCP study and implementation of the resulting HACCP plan is
available for validation, verification, auditing and other purposes.

Other Approaches to Food Safety- these approaches deal with quality aspect which is wider in scope
and also covers food safety:
 Quality Control (QC) – defined as the operational techniques and activities that are used to fulfill
a requirement.
 Quality Assurance (QA) / Quality Management (QM) – the best known Quality Assurance
Standards are the ISO (International Organization for Standardization) Standards. Two ISO
Standards are relevant for the aquaculture commodity:

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1. ISO 9000 Series which include ISO 9001 Quality systems - Model for quality assurance in design/
development, production, installation and servicing and ISO 9002 Quality systems - Model for quality
assurance in production and installation.

2. ISO 22000:2005 which specifies requirements for a food safety management system where an
organization needs to demonstrate its ability to control food safety hazards in order to ensure that food
is safe at the time of human consumption.

 Quality Systems- covers organizational structure, responsibilities, procedures, processes and the
resources needed to implement comprehensive quality management.
 Total Quality Management (TQM) - is an organization’s management approach, centered on
quality and based on participation of all its members and aimed at long-term success through
customer satisfaction and benefits to the members of the organization and the society.

International Regulatory Framework

Fishery product safety framework is defined by the major international organization:

WTO (World Trade Organization)

WTO, which succeeded the GATT (General Agreement on Tariff and Trade), was established by the
Final Act of the Uruguay Round of multilateral trade negotiation. This negotiation also produced two
binding agreements which are significant to food safety:

 Agreement on the Application of Sanitary and Phytosanitary Measures (SPS)

The purpose of the SPS Agreement is to ensure that the measures established by governments to
protect human, animal and plant life and health, in the agriculture sector, including fisheries, are not
disguised restrictions. The standards used should be based on CAC (Codex Alimentarius Commission).
Importing countries can, however, impose stricter measures if there is scientific justification for doing
so and if the level of protection afforded by the Codex is deemed not appropriate.
 Agreement on Technical Barriers to Trade

The TBT Agreement provides that all technical standards and regulations must have a legitimate
purpose and that the input or cost of implementing the standards must be proportional to the purpose of
the standard. It also states that if there are two or more ways of achieving the same objective, the least
restrictive trade alternative should be followed. It covers standard relating to all types of products
including industrial products and quality requirements for foods (except requirements related to SPS
measures) and includes measures designed to protect the consumer against deception and economic
fraud.

FAO (Food and Agriculture Organization

 Codex Alimentarius Commission

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The CAC (Codex Alimentarius Commission) implements the Joint FAO/WHO (World Health
Organization) Food Standards Programme. It is an intergovernmental body with a membership of 165
Member governments and primarily aims for the protection of the health of consumers, the assurance
of fair practices in food trade and the coordination of work on food standards.

The CAC is divided into various committees and the work of the Committees on Hygiene, Fish and
Fishery Products, Veterinary Drugs and Import/Export inspection and certification systems are relevant
in ensuring the safety of fishery products. The Codex Standard produce by these committees are
supposedly voluntary and should be adopted by consensus but with the entry into force of SPS and
TBT agreements, it can no longer be called voluntary.

 Code of Conduct for Responsible Fisheries

The Code was adopted on the 31 st of October 1995 by the 28 th session of the FAO Conference on
Fisheries. In a non mandatory manner, it establishes principles and standards applicable to the
conservation, management and development of fisheries. Article 11 elaborates the guidelines on post
harvest practices and trade. Provision of this Article (11.12, 11.13 and 11.14) encourages the States to
establish and maintain effective national safety and quality assurance systems, to promote the
implementation of CAC Standards and Code and cooperate to achieve harmonization or mutual
recognition, or both, of the national sanitary measures and certification programmes.

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Source: excerpts from ASSESSMENT and MANAGEMENT of SEAFOOD SAFETY and QUALITY
(FAO Technical paper no 444) by H. HUss, L Ababouch and L Gram, 2004