Seafood Safety and HACCP. Ron Kinnunen (Michigan Sea Grant Extension) and Jill Bentgen (Mackinac Straits Fish Company)

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1 Seafood Safety and HACCP Ron Kinnunen (Michigan Sea Grant Extension) and Jill Bentgen (Mackinac Straits Fish Company)

2 Small to Large Scale Fish Processing Facilities in Michigan

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11 HACCP Hazard Analysis and Critical Control Point

12 HACCP is Preventive, not reactive A management tool used to protect the food supply against biological, chemical and physical hazards

13 Origins of HACCP Pioneered in the 1960 s First used when foods were developed for the space program Adopted by many food processors and the U.S. government

14 HACCP HACCP is not a zero-risk system It is designed to minimize the risk of food safety hazards

15 Seven Principles of HACCP Conduct hazard analysis and identify preventive measures Identify critical control points (CCPs) in the process Establish critical limits Monitor each CCP Establish corrective actions Establish verification procedures Establish record-keeping and documentation procedures

16 International use: Codex European Union Canada Australia New Zealand Japan

17 HACCP is not a stand-alone system A preventive system for ensuring foodsafety control, but it is not a stand-alone system

18 Inspection Methods Traditional Inspection Methods for Food-Safety Control versus The HACCP Approach

19 HACCP Inspections HACCP inspections complement traditional HACCP: inspection methods. Emphasizes process control Concentrates on the points in the process that are critical to the safety of the product Stresses communication between the regulator and industry

20 Hazards in Fish Processing Biological, Chemical, Physical

21 Hazard A biological, chemical or physical agent that is reasonably likely to cause illness or injury in the absence of its control

22 Hazards In HACCP, hazards refer to conditions or contaminants in foods that can cause illness or injury. It does not refer to undesirable conditions or contaminants such as: Insects Hair Filth Spoilage Economic fraud Violations of regulatory food standards not directly related to safety

23 The Seafood HACCP Regulation

24 Fishery Product Any human food product where fish is a characterizing ingredient

25 Who Must Comply? Importer Processor - domestic and foreign

26 Processor Any person engaged in commercial, custom or institutional processing of fish or fishery products either in the United States or in a foreign country

27 Processing Handling, storing, preparing, heading, eviscerating, shucking, freezing, changing into different market forms, manufacturing, preserving, packing, labeling, dockside unloading or holding fish or fishery products

28 This Regulation Does Not Apply to: The harvest or transport of fish and fishery products Practices such as heading, eviscerating, or freezing intended solely to prepare a fish for holding on a harvest vessel The operation of a retail establishment

29 Sanitation Controls and the HACCP Plan Sanitation controls are not required to be included in the HACCP plan Sanitation controls that are not part of the HACCP plan must be monitored according to the sanitation provisions of the regulation

30 Eight key sanitation conditions/practices Safety of water Condition and cleanliness of foodcontact surfaces Prevention of crosscontamination Maintenance of handwashing, handsanitizing and toilet facilities Protection from adulterants Labeling, storage and use of toxic compounds Employee health conditions Exclusion of pests

31 Legal Basis FDA s application of HACCP is primarily based on the Federal Food Drug and Cosmetic Act Any fish or fishery products processed or imported in violation of this regulation can be considered adulterated and subject to regulatory action

32 Seafood and Food Safety Issues Related to Aquaculture

33 Aquaculture Practices Exempt From the HACCP Regulation Harvesting and boxing unprocessed fish on ice for immediate transportation Live fish hauling to various market outlets Custom processing the fish directly for the consumer who does not resell it Fee fishing operations

34 Seafood HACCP Since 1997 Michigan Sea Grant conducted twenty-three Seafood HACCP workshops in the Great Lakes Region Most of workshops on tribal reservations, training 600 commercial fishers, processors, and aquaculturist

35 Application of HACCP

36 Development of Plan Fully understand your equipment and processes Draw a detailed process diagram for each product Not all measurement points are critical control points Operational control points are usually not the critical control point

37 Implementation of HACCP Plan Take the plan seriously Train all employees Keep measurement equipment in good condition Owner/manager needs to pay attention and provide ongoing, timely, specific feedback Make sure you control to the plan

38 Implementation of HACCP Plan Make the plan easy for employees to understand and document Standardized batches Standardized tasks Standardized form

39 Documentation Internal Production Documents CCP RECORD FREQUENCY Cooler Temperature Time/Temperature Charts (2) Continuous Smoker Temperature Time/Temperature Charts (2) Continuous Cross Contamination Daily Sanitation Records (2) Up to 3X per day Salt Content Process Sheet for each product (4) Each Lot Labeling Production Log (3) Every package

40 Documentation External Verification Documents PRAMATER MEASUREMENT FREQUENCY Salt Content % WPS, % Moisture Semi-annually Time/Temperature Charts Thermocouple Calibration Annually Weight Scales Weight Calibration Annually Water Quality City Water Quality Report Annually Fish Quality Canadian List of Qualified Exporters Letters of Compliance Commercial Fish License Annually

41 Benefits of HACCP Cheap Liability Insurance Produces a Higher Quality Product Allows Development of Innovative Products

42 Questions?