Hector has put together a very valuable précis of the EU Regs which serves
me well. I would however point out that in drawing up an HACCP study we
deal primarily with food safety issues, not those of quality. I am unable
to think of a safety hazard that represents a realistic risk due to the
temperature changing by several degrees during the 2 year shelf life of a
frozen fish product; microbiological activity having been effectively
halted. I am not sure, therefore why a fairly arbitrary figure of -18ºC
(the centigrade equivalent of a better sounding 0ºF) should be so critical.
I believe that 75% of the water in the tissue remains frozen even at -7ºC
and bio-chemical processes are slowed to an acceptable level at warmer
temperatures than -18ºC (sorry but I have no backup evidence for this which
is an assumption based on not having come across micro problems in
temperature abused frozen fish). Flavour deterioration, lipid oxidation and
toughening, which are quality issues, will be more rapid in product that
suffers abuse through temperature rise and fluctuation but I still I do not
see that freezing is a safety CCP other than to kill parasites. The only
other way in which it is a CCP is as Hector says as a regulatory CCP, i.e. a
legal requirement but if we bring in all the legal requirements as CCPs,
whether safety or quality, are we not digressing from the point of analyzing
for safety hazards and risk? After all the border inspection posts are
welcome to turn a product back on the grounds of a poor temperature history
but this does not make it a matter of safety.
With respect to the Lake Victoria fishery, we deal with this too and I am
aware of all the issues raised by Alain. It is as he says serviced by high
quality factories that would certainly pass muster here in the UK. The
refusals for entry to the EU that I have heard of have been on the grounds
of out of specification micro counts, although I would not be surprised to
hear of organoleptic issues being raised too. Sometimes the refusal has
stood, sometimes it has been recanted; in the latter case there is an
indication that commercial interests were at stake i.e. that the purchaser
had over ordered.
The catching side of the fishery is very difficult to advance, particularly
with respect to getting ice onto the dhows and canoes in remote areas; ice
means purified water, which means plant and power, maintenance, safety from
theft and putting into vessels that are not designed for the carrying ice.
The alternative is to use supplies from existing distant sources. In
addition the lake water is always at least 24ºC and the fish may hang in it
for 8 or more hours due to the difficulty and dangers of navigating to nets
in remote areas. It is a night fishery and staying with the nets brings in
the serious dangers of attack by armed pirates (expressed to me by
fishermen) and changes in weather conditions.
The temperature issue though vital, is one of quality not safety.
Regards, Richard Chivers
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
Of Schalk Alain
Sent: 12 October 2005 08:53
To: seafood@ucdavis.edu
Cc: Lupin, Hector (FIIU); oscar.doporto
Subject: RE: inquiry about cold storage being considered as CCP
Dear friends,
This debate is again very interesting and the presentation made by Hector is
indeed very good….
To me there is a simple example to illustrate the importance of the
temperature records in the life and quality of a given product…
Perche fillets from Victoria lake in Tanzania represent a huge economical
potential for this country. The product is attractive and cheap but has huge
difficulties to
enter the EU because it very often fails the EU quality regulations. This is
something very difficult to understand when one knows that the processing
plants are mostly supported by foreign investments and can be qualified to
my point of view as high tech. plants…..so why can’t they match the quality
standards for EU ?
Their storage area are beautiful and well maintained so nobody would find a
risk exposure there but ahead of the plant in the field there is a lot to
say about the “artisanal” catch Process which gives little
importance/consideration to the cooling/icing and storage parameters and the
product unfortunately reaches the plant already with a rather poor quality
because of a lack of proper temperature chain management….and the risk
exposure, the CP, the CCP or whatever you call it was there and as a result
of not being addressed properly the fish gets damaged and looses quality
as well as shelf life…
So all along a given supply chain, the temperature must remain safe and in
certain cases a deviation at a certain point might even create a KP killing
point for the entire process. In fact depending on the field reality a
storage or transport temperature assessment might be given more or less
critical importance and unfortunately there is no book or manual which could
clearly give instructions on the subject.
Surprised to see that Paul Dion has not spoken yet on the subject….
Regards.
Alain Schalk
_____
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of oscar.doporto
Sent: 12 October 2005 00:03
To: Lupin, Hector (FIIU)
Cc: seafood@ucdavis.edu
Subject: Re: inquiry about cold storage being considered as CCP
Dear Hector,
Each time I am approaching the condition of being ready for the "psy" after
suffering from exotic interpretations of the EU regulations, you point out
the matter.
In fact, many European (national services inspectors, going on time to time
to give some "help" to third countries) spread the idea of all hygiene
aspects being associated to critical points. I so manuals and guidelines
proposing HACCP model plans containing about 15 critical points for the most
simple case of little processes raw product...Additionally the regulation
introduce the idea of "own-checks" supposed to be equivalent to HACCP but
they do not trust in the companies "own-control" and, as a consequence in
many third countries, the inspectors are still convinced that the results
depends on the inspector presence and interference.
About limits of temperature the interpretations ca be really extreme. My
view is that frozen storage should no be considered a CCP. How important
should be a deviation for involving the idea of "Hazard", given in the point
(c) bellow?.
But what do you think about rejecting (with consequent destruction) tons of
lobsters because not arriving alive either at a temperature of 0°C to +2°C
(the criteria for fresh fish in the 493, but referred to the transportation
and preservation of fresh product in the respective chapter, being a final
product and not a raw material) having the only problem of being captured
and not having the time to cool down in the abundant ice present!!!
The problem comes from mixing "hygiene" with process parameters control, and
taking out from its intention and framework certain regulatory texts.
(b) CCP is called "Critical Point"
(c) "Hazard is a potential to cause harm to health and is anything covered
by the hygiene objectives of Directive 91/493/EEC" (bold and Italics mine)
In addition, with the horizontalisation of regulation, the situation will
suffer further deterioration.
Tanks for the opportunity to talk about ,
Best regards
Oscar do Porto
International Consultant
----- Original Message -----
From: Larry Wyatt <mailto:larrywyatt@foodhorizon.com>
To: Lupin, Hector (FIIU) <mailto:Hector.Lupin@fao.org>
Cc: richard@fishonline.co.uk <mailto:richard@fishonline.co.uk> ; alma tina
<mailto:almaorodiotina@yahoo.com> ; seafood@ucdavis.edu
<mailto:seafood@ucdavis.edu>
Sent: Tuesday, October 11, 2005 6:33 PM
Subject: Re: inquiry about cold storage being considered as CCP
Hector,
I think your explanation of the difference between HACCP and regulatory
actions based on HACCP is excellent, and more important, is that it is too
often overlooked.
Larry Wyatt
FoodHorizon Inc.
www.foodhorizon.com <http://www.foodhorizon.com>
Lupin, Hector (FIIU) wrote:
Dear colleagues:
This is a very interesting discussion, that pops up very frequently. I think
that there are some general considerations:
(i) Regulatory HACCP is not HACCP (e.g. in the sense of HACCP according the
Codex Alimentarius) but a regulation based on HACCP. Therefore, in
principle, you have to comply with a regulation and not just with the dry
HACCP principles and/ or steps.
(ii) Regulations, as any other piece of knowledge, is open to
interpretations. "Interpretations" are usually a problem. Inspection
agencies in general make every possible effort to make interpretations, of
their own officers, uniform. But not always succeed.
(iii) One of the aspects of HACCP-based regulations is that they determine
directly or indirectly "regulatory hazards"; this means hazards that you
shall be taken into account in your HACCP plan, regardless which could be
your own technical opinion. In the case of the US FDA HACCP-based
regulations theoretically you may eventual appeal (if you are in the US),
based on scientific grounds. However, for most "regulatory hazards" the
possibility somebody could demonstrate they are not hazards (e.g. histamine
in pelagic fish) is usually very remote.
Regarding the EU directives there are a couple of things to clarify
(translate from EU English to USA English):
(a) HACCP for fish and fish products is called "own-checks".
(b) CCP is called "Critical Point"
(c) "Hazard is a potential to cause harm to health and is anything covered
by the hygiene objectives of Directive 91/493/EEC" (bold and Italics mine)
(from Commission Decision 94/356/EC of 20 May 1994)
Going to Council Directive 91/493/EEC we found the following:
(1) "- frozen fishery products, with the exception of frozen fish in brine
intended for the manufacture of canned foods, must be kept at an even
temperature of -18 º C or less in all parts of the product, allowing for the
possibility of brief upward fluctuations of not more than 3 º C, during
transport;" (Council Directive 91/493/EEC, Annex, Chapter VIII, Storage and
Transport, Point 1) (bold mine)
(2) "3. Storage rooms must have a temperature recording device in place
where it can easily be read. The temperature sensor of the recorder must be
located in the area furthest away from the cold source, i.e. where the
temperature in the storage room is the highest. Temperature charts must be
available for inspection by the supervisory authorities at least during the
period in which the products are stored." (Council Directive 91/493/EEC,
Annex, Chapter IV, Special Conditions for Handling Fishery Products on
Shore, II Conditions fro frozen products, Point 3) (bold mine)
And finally, and perhaps the most important for this discussion:
(3) "Critical limits may be derived from a variety of sources. When not
taken from regulatory standards (e.g. frozen storage temperature) or from
existing and validated guides of good manufacturing practices, the team
should ascertain their validity relative to the control of identified hazard
and critical points" (Commission Decision 94/356/EC, Chapter II, Point 1).
(bold mine)
In this case the regulation is not saying that the cold storage temperature
is a CP (a CCP); but is given all the indications in that sense (critical
limit, tolerance, measurement and record keeping and use it as regulatory
example). The need for corrective actions, in the case of deviations, is
obviously a result; and the need for verifications of measurement and record
equipment fall into the general principle of verification and calibration
and re-calibration of measurement equipment. Therefore we have our
regulatory hazard and CP (or CCP).
Again, the possibility that in this situation a fish inspector from the EU
do not consider the temperature in a cold storage room a CP (a CCP) is
remote. He/ she may eventually accept that continuous records could be
replaced by recorded lectures, say every 3-5 hours (taking into account the
thermal inertia of cold storage rooms); but hardly that it is not a CP
(CCP).
The discussion about the rationality or not of frozen storage temperature as
a CP (or CCP) is interesting; I am tempted to go on that, but not time now.
In any case we should keep in mind that HACCP based regulations (or by the
case all Risk Analysis) are based on Science, they are not Science.
I have worked with people in developing countries that want to export their
fish. People normally ask you to provide an advice that put them into the
safe side. Which advise would you provide in this case?
(Warning: from 1 January 2006 there will be a new set of EU regulations
dealing with HACCP, and a new careful reading of regulations is necessary
for all trading fish with the EU)
Kind regards.
Hector M. Lupin
Senior Fishery Industry Officer (Quality Assurance)
Fish Utilization and Marketing Service (FIIU)
Fishery Industries Division (FI)
Fisheries Department, FAO, Room F 606
Viale delle Terme di Caracalla
00100 Rome, Italy
Tel + 39 06 570 56459
Fax + 39 06 570 55188
E-mail: hector.lupin@fao.org <mailto:hector.lupin@fao.org>
-----Original Message-----
From: owner-seafood@ucdavis.edu <mailto:owner-seafood@ucdavis.edu> [
mailto:owner-seafood@ucdavis.edu] On Behalf Of Richard Chivers
Sent: 07 October 2005 16:36
To: alma tina; seafood@ucdavis.edu <mailto:seafood@ucdavis.edu>
Subject: RE: inquiry about cold storage being considered as CCP
Hi Alma,
<!--[if !supportEmptyParas]--><!--[endif]-->
These are my views:
<!--[if !supportEmptyParas]--><!--[endif]-->
1. There are no EU directives that set CCPs, these are up to the
processor to determine.
2. I assume you refer to the Competent Authority. I would not consider
cold (frozen) storage a CCP simply because a product that is intended to be
kept in be frozen condition would be in breach of specifications and GMP,
drawing in quality and safety issues. I would set the temperature control
as a prerequisite programme; a given if you like. I.e. if the product
temperature were outside the limits, that would be the end of it for its
primary purpose and disposal or alternative use should be considered.
3. Pathogen growth is unlikely to present a food safety hazard due to the
reasonable expectation that the product would be cooked. That is unless
there were an issue with spore formers or with heat resistant toxins then
there would be a problem. These matters would be highlighted in the
analysis part of the HACCP. Unfortunately it is not an argument that sways
opinion in international trade which will set stringent micro counts.
4. It is not illegal but may mean that your analysis was invalid if a CCP
were missed. In the UK this alone would not lead to prosecution but could
become evidence to support a prosecution if there were more serious matters
arising from temperature abuse i.e. food poisoning.
<!--[if !supportEmptyParas]--><!--[endif]-->
I hope this helps
<!--[if !supportEmptyParas]--><!--[endif]-->
Richard Chivers
<!--[if !supportEmptyParas]--><!--[endif]-->
-----Original Message-----
From: owner-seafood@ucdavis.edu <mailto:owner-seafood@ucdavis.edu> [
mailto:owner-seafood@ucdavis.edu]On Behalf Of alma tina
Sent: 07 October 2005 06:34
To: seafood@ucdavis.edu <mailto:seafood@ucdavis.edu>
Subject: inquiry about cold storage being considered as CCP
<!--[if !supportEmptyParas]--><!--[endif]-->
Dear List,
Please give me some insight or enlightening regarding the issue of
considering cold storage as CCP.
These are my questions:
1.Is there an EU directives that considers storing at cold storage as CCP.
2.Can the competitive authority insist on us to consider storing at cold
storage as CCP.
3. Is my thinking correct, that since our product is to be fully cooked
before consumption, then pathogen growth is not a hazard? By the way our
products are frozen octopus and shrimps.
4. Is it illegal not to have CCP for a particular item?
Plese provide some information on this issue, we badly needed the info.
Thanks,
Alma O. Tina
almaorodiotina@yahoo.com <mailto:almaorodiotina@yahoo.com>
_____
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