Ignacio has a dispute with his local fishery inspector and I am in no
position to comment on the application of local regulations, but his message
raises an interesting point of general interest relating to the relevance of
medical inspection, and possible certification of food handlers.
The booklet 'Food Hygiene Basic Texts, 2nd edn.. Recommended International
Code of Practice General Principles of Food Hygiene' published by the Codex
Alimentarius Commission, 1999, recommends in Section VII - Establishment:
personal hygiene: "Medical examination of a food handler should be carried
out if clinically or epidemiologically indicated." This suggests that
medical examination of food handlers is dictated by circumstances and need
not be a routine practice.
The EU requirements for food hygiene are laid out in Regulation (EC) No
852/2004 of the European Parliament and of the Council of 29 April 2004 on
the hygiene of foodstuffs. Handling of fish aboard fishing vessels is
covered in Annexe I, Primary Production, Part A: General Hygiene Provisions
for Primary Production and Associated Operations. Section 4 requires that:
"Food business operators rearing, harvesting or hunting animals or producing
primary products of animal origin are to take adequate measures, as
appropriate: ....(e) to ensure that staff handling foodstuffs are in good
health and undergo training on health risks; ... ". This provision could be
construed as governing the welfare of the crew of the fishing vessel, rather
than the human health safety of the product. I am sure it is wise that
anyone serving on a fishing vessel at sea to be in good health and there is
no harm in training someone to avoid health risks. I am being facetious, but
Section 4 (e) is a good example of poor drafting.
However, the EU Regulation redeems itself in Annexe II, General Hygiene
Requirements for All Food Business Operators (Except When Annex I Applies).
Chapter VIII Personal Hygiene, requires that "No person suffering from, or
being a carrier of a disease likely to be transmitted through food or
afflicted, for example, with infected wounds, skin infections, sores or
diarrhoea is to be permitted to handle food or enter any food-handling area
in any capacity if there is any likelihood of direct or indirect
contamination. Any person so affected and employed in a food business and
who is likely to come into contact with food is to report immediately the
illness or symptoms, and if possible their causes, to the food business
operator." This is quite clear and the requirement is spelled out in detail.
The EU regulation puts the onus on operators of food premises to apply the
provisions of the regulation, and must do so as part of the continuous
control of the safety of the products. There is no requirement in the
regulation for medical examination of food handlers, and I assume this is
left to the operator to decide as he thinks fit. As Ignacio points out a
medical examination does not exclude a person's subsequently becoming a
carrier of a disease likely to be transmitted through food. The emphasis, as
it is in other matters concerning safety, has to be on continuous monitoring
rather than spot checks.
Generally chilled raw fish as handled on a fishing vessel is considered as
posing a very low risk of causing bacteriological illness. Even if
pathogenic organisms are transmitted to the product from handlers or
surroundings chance of proliferation is low because the fish is kept
chilled - indeed icing is a requirement of the EU regulations - and the
product is almost invariably cooked before consumption. However, Ignacio
tells me his boat is handling tuna for sashimi, and though well chilled
would not have this final protection of cooking before consumption. Anyone
care to estimate the risk of illness from consumption of sashimi produced
from tuna contaminated from handlers on the catching vessel, and the likely
reduction of this risk by medical examination of the handlers?
Peter Howgate
----- Original Message -----
From: <ignaciopesca@mac.com>
To: <seafood@ucdavis.edu>
Sent: Monday, May 01, 2006 8:49 PM
Subject: Medical Certificate on fishing boat crew
> Dear Experts
>
> In order to be listed by our "competent authority" to be allowed to sell
> our fish to exporters intending to send products to Europe, the local
> inspector says that all crew on board need to have annual medical
> certificates... I asked him to provide me with a reference of the
> requirement but he does want to...
>
> I have read Regulations 852, 853, 854/2004 from the EC and found no
> reference to medical certificates... they talk about product handlers
> with good health... which is understandable... and we would not embark (we
> have a small longliner) some one looking sick anyway... small confined
> space and away from medical care... would be silly...
>
> Does anyone have a exact reference for a medical certificate in the EU
> regs?
>
> What is the point of having a medical certificate if you could be really
> sick a month later, anyway?
>
> Would a visual check of the general health (no dripping orifices, eyes,
> nose, ears and so on?) before embarking and recorded in our daily
> checklist satisfy the requirements?
>
> Your help is appreciated
>
> Ignacio Irunaga
>
>
>
>
This archive was generated by hypermail 2b29 : Tue May 02 2006 - 13:46:49 PDT