Seafood Safety and HACCP Ron Kinnunen (Michigan Sea Grant Extension) and Jill Bentgen (Mackinac Straits Fish Company)
Small to Large Scale Fish Processing Facilities in Michigan
HACCP Hazard Analysis and Critical Control Point
HACCP is Preventive, not reactive A management tool used to protect the food supply against biological, chemical and physical hazards
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
HACCP HACCP is not a zero-risk system It is designed to minimize the risk of food safety hazards
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
International use: Codex European Union Canada Australia New Zealand Japan
HACCP is not a stand-alone system A preventive system for ensuring foodsafety control, but it is not a stand-alone system
Inspection Methods Traditional Inspection Methods for Food-Safety Control versus The HACCP Approach
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
Hazards in Fish Processing Biological, Chemical, Physical
Hazard A biological, chemical or physical agent that is reasonably likely to cause illness or injury in the absence of its control
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
The Seafood HACCP Regulation
Fishery Product Any human food product where fish is a characterizing ingredient
Who Must Comply? Importer Processor - domestic and foreign
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
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
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
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
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
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
Seafood and Food Safety Issues Related to Aquaculture
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
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
Application of HACCP
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
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
Implementation of HACCP Plan Make the plan easy for employees to understand and document Standardized batches Standardized tasks Standardized form
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
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
Benefits of HACCP Cheap Liability Insurance Produces a Higher Quality Product Allows Development of Innovative Products
Questions?