FISHING INDUSTRY MEETING FOOD AND ASSOCIATED INDUSTRIES 15 OCTOBER 2010 CAPE TOWN

Transcription

1 FISHING INDUSTRY MEETING FOOD AND ASSOCIATED INDUSTRIES 15 OCTOBER 2010 CAPE TOWN 1

2 FISHING INDUSTRY MEETING FOOD AND ASSOCIATED INDUSTRIES 15 OCTOBER 2010 CAPE TOWN 2 Presented by: Andre de Wet

3 1. REQUIREMENTS FOR EMPLOYEES ENGAGED IN THE HANDLING, PREPARATION, PROCESSING, PACKAGING & STORAGE OF THE PRODUCT 1.1 STAFF NOT MEDICALLY EXAMINED FOR COMMUNICABLE DISEASES AND NO MEDICAL RECORDS KEPT FOR EACH EMPLOYEE. 3

4 FACTORIES 4

5 2. FACTORY CONSTRUCTION, LAYOUT AND CONDITIONS 2.1 OUTDOOR WORK AREAS, PATHWAYS AND ROADS SHALL HAVE A PERMANENT SURFACE OF CONCRETE, BRICK, BITUMEN OR OTHER DURABLE SURFACE THAT IS NOT LIABLE TO PRODUCE DUST. 2.2 ADEQUATELY FENCED TO KEEP OUT LARGER ANIMALS SUCH AS CATS AND DOGS AND ALSO UNAUTHORIZED PERSONS AND VEHICLES. 5

6 3. CONSTRUCTION AND MAINTENANCE PROBLEMS WITH FLOOR SURFACES OR DRAINAGE: 3.1 POOR CONDITION OF FLOORS IN PROCESSING AREAS, CHILLERS AND PACKAGING AREAS. - FLOORS TOO WET, NOT DRAINING PROPERLY LEAVING PUDDLES OF WATER ON FLOORS - PIPING FROM WATER TO FILLETING MACHINES, SKINNING MACHINES OR FROM EVAPORATORS IN CHILLERS, SPILLING WATER ON FLOORS NEAR PRODUCT 3.2 FLOOR TO WALL AND WALL TO WALL COVINGS DAMAGED OR ABSENT 3.3 WALL SURFACES OR WALL PANELS AND CEILING SURFACES IN BAD CONDITION (INCLUDING RUST AND FLAKING PAINT ON CHROMADECK PANELS, PILLARS AND OVERHEAD BEAMS) 3.4 STORAGE AREAS FOR INGREDIENTS/ PACKAGING MATERIALS TO BE DUSTPROOF. 3.5 CONDENSATION PROBLEMS AND DRIPPING FROM CEILINGS/OVERHEAD STRUCTURES IN PROCESSING AEAS 6

7 CONTINUED 3.6 PACKAGING MATERIALS STORED IN AISLES, PRODUCT RECEPTION AREAS ETC. DUE TO A LACK OF SPACE IN MAIN PACKAGING MATERIAL STORES. 3.7 DOORS TO ANTEROOMS, PROCESSING AREAS OR STORES NOT TIGHT FITTING TO PROTECT AGAINST VERMIN AND DUST. 3.8 DOOR POLICY NOT ADHERED TOO. IF THE DOORS TO THE OUTSIDE OF THE FACTORY ARE OPEN, THE DOORS TO THE PROCESSING AREAS NEED TO REMAIN CLOSED. 3.9 LACK OF PROPER VENTILATION IN PROCESSING AREAS AREAS OR CORIDORS USED FOR TRANSFER OF OPEN PRODUCT OR ICE, MOVEMENT OF STAFF WITH PROTECTIVE CLOTHING ON, WASHING OR STORAGE OF FISH BINS ARE NOT ENCLOSED TO PROTECT FROM EVIRONMENTAL CONTAMINATION. 7

8 CONTINUED 3.11 UTENSIL WASHING AREA LACKING OR NOT SEPARATE FROM PROCESSING AREAS OR NO FACILITIES TO WASH PLASTIC PROTECTIVE CLOTHING RUSTED TABLES AND FRAMES OR RUST ON SOME OTHER PROCESSING EQUIPMENT. TABLE FRAMES NOT DESIGNED AND SO CONSTRUCTED TO PREVENT THE DEVELOPMENT OF UNHYGIENIC CONDITIONS AND BACTERIAL BUILD-UP UNAVAILABILITY OF CORRECT EQUIPMENT TO CLEAN AND WASH FISH. 8

9 4. GMP AND HYGIENE CONTROLS GENERAL 4.1 NRCS REPEAT FINDINGS IGNORED BY FACTORIES. 4.2 CONDUCT OF EMPLOYEES ENGAGED IN THE HANDLING, PREPARATION, PROCESSING AND PACKAGING OF THE PRODUCT OFTEN INDICATES A LACK OF KNOWLEDGE ON HOW TO OPREATE CORRECTLY, REFLECTING A SERIOUS LACK OF TRAINING/COMMITMENT PERTAINING TO OPERATION AND SANITATION. 4.3 THE SAME BINS ARE USED FOR PRODUCT, OFFAL OR STANDS WHILE BINS ARE ALSO PLACED DIRECTLY ON THE FLOOR INSTEAD OF PROPER BIN STANDS OR PALLETS (NO PROPER BIN POLICY). 4.4 BINS AND TUBS ARE STILL CONTAMINATED WITH DIRT, FISH SCALES AND OTHER EXTRANEOUS MATTER AFTER CLEANING. 4.5 PEOPLE WALK OUTSIDE CLEAN AREAS OF THE FACTORY DRESSED IN THEIR PROTECTIVE CLOTHING. 4.6 STAFF STORING PROTECTIVE CLOTHING UNHYGIENICALLY WITH THEIR PERSONAL BELONGINGS AND GENERAL CLOAKROOM OPERATION AND SANITATION IN POOR STATE 9

10 CONTINUED 4.7 PROTECTIVE COVERING AROUND PACKAGING MATERIALS IN STORAGE ROOMS DAMAGED OR REMOVED, OR OPENED PACKAGING MATERIALS NOT RESEALED IN DUST PROOF BAGS. 4.8 EXCESS FISH OR FISH WASTE AND SCALES DROPPED ON FLOOR AND ALLOWED TO ACCUMULATE. 4.9 DEFROSTING OF FISH TAKES PLACE IN CONTAINERS WITH STAGNANT WATER UTENSILS USED IN CONTACT WITH THE FISH, WASHED IN SANITIZERS OR DISINFECTANT WHICH IS NOT RINSED OFF WITH CLEAN WATER BEFORE RE-USING (CRITICAL FINDING) ICE STORED AT ICE PLANTS NOT PROPERLY PROTECTED AGAINST CONTAMINATION AND ICE NOT VISUALLY INSPECTED FOR FOREIGN MATTER PRIOR TO USE HOSE PIPES NOT STORED ON HOSE REELS WHEN NOT IN USE FISH SCALES AND DIRT STILL PRESENT ON VARIOUS TYPES OF 10 EQUIPMENT AFTER CLEANING AND SANITATION.

11 5. PROCESS CONTROL 5.1 PRODUCT STOPPAGES AND DELAYS ON PROCESSING LINES, INADEQUATE CONTROL OF RAW MATERIALS CAUSE UNNECESSARY INCREASES IN PRODUCT TEMPERATURES. PRODUCT TEMPERATURES ARE NOT MONITORED AND CONTROLLED. 5.2 COLD STORES FROSTED UP AND NOT SUBJECT TO A CLEANING PROGRAMME. TEMPERATURE RECORDERS NOT DOWNLOADED FREQUENTLY AND NO EVIDENCE THAT TEMPERATURE RECORDS WERE INSPECTED AND SIGNED OFF. 11

12 6. EU DIRECTIVES, REGULATIONS AND COMPULSORY SPECIFICATIONS NOT AVAILABLE TO INCUMBANTS AT FACTORIES 12

13 VESSELS 13

14 VESSELS OWN CHECK SYSTEMS ON ICE VESSELS AND FREEZER VESSELS ARE TOO GENERIC AND WERE COMPILED BY CONSULTANTS AS FAR BACK AS 1995 AND ARE NOT APPLICABLE TO THE OPERATION OF THE VESSEL. THE OWN CHECK SYSTEM DOES NOT MAKE REFERENCE TO THE INSPECTION FORMS BEING USED. THE OPERATORS IN CHARGE OF THE OWN CHECK SYSTEM SHOULD AT LEAST HAVE COMPLETED A BASIC COURSE ON HACCP AND GMP S. RECORDS COMPLETED FOR THE COOLING RATE OF TUNA OPERATORS REQUEST INSPECTIONS OF THEIR FISHING VESSELS WITHOUT THE NECESSARY DOCUMENTS (MEDICAL/CALIBRATION CERTIFICATES) IN PLACE. 14

15 CONTINUED... FISHING COMPANY REPRESENTATIVES SCHEDULE INSPECTIONS OF THEIR FACTORY FREEZER/FREEZER VESSELS WITH US. INSPECTORS THEN RECORD FINDINGS SUCH AS UNCLEANED FACTORY AREAS, PROCESSING EQUIPMENT AND UTENSILS, ETC. INSPECTORS ARE ALSO CALLED OUT WHILE CONTRACTORS ARE STILL BUSY WORKING ON THE VESSEL, LEAVING CERTAIN AREAS WITH WET PAINT AND LEAVING PROCESSING AREAS COVERED WITH STRONG CHLORINE BASED POWDERS. OUR INSPECTORS ONLY SEE THESE VESSELS TWICE IN A 12 MONTH CYCLE. WHEN CONDUCTING THE INSPECTION, OUR INSPECTORS EXPECT TO SEE THAT THE VESSEL WAS SIGNED OFF BY THE MANAGEMENT REPRESENTATIVE OF THE COMPANY TO BE CLEAN AND COMPLIANT WITH ALL THE RELEVANT EU REGULATIONS AT THE TIME OF THE INSPECTION. IF THE VESSELS ARE NOT COMPLIANT, THE NRCS WILL NOT BE IN A POSITION TO CERTIFY ANY FISH FROM THAT VESSEL AND MAY ALSO SUSPEND THE VESSEL UNTIL SUCH TIME THE NECESSARY CORRECTIVE ACTIONS ARE TAKEN AND IMPLEMENTED PRIOR TO RE-INSPECTING THE VESSEL. 15

16 CONTINUED... STORAGE OF FISH IN ICE SLURRIES REJECTIONS ON FINAL PRODUCTS FROM FREEZER VESSELS HACCP /OWN CHECK SYSTEMS 16

17 THANK YOU 17