ISSN In total, there are 6 sections that explain: Section 1: Introduction The background to the guide and the principles of risk assessment

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2 The guide was developed by Michael Gallagher (Bord Iascaigh Mhara) and edited by Marianne Green (Killybegs Fishermen s Organisation), with assistance from Conor Nolan, Maeve Earley, Frances O Dwyer and Elizabeth O Leary (Bord Iascaigh Mhara). ISSN Purpose of this guide This guide provides an overview of the legal requirements that traditional whitefish, freezer and factory vessels must meet regarding structure, layout, hygiene, handling, training and record keeping. A significant portion of the guide is devoted to the specific requirements that freezer and factory vessels must fulfil to attain Approval from the Sea Fisheries Protection Authority (SFPA) in accordance with the legislation, which permits them to place fishery products on the market. The guide serves as a reference document and forms the main course content to an element of the BIM FETAC approved course Risk Based HACCP for Seafood, which allows allocated crew to develop Food Safety Management Systems for their vessels, which is an integral part of attaining Approval. In total, there are 6 sections that explain: Section 1: Introduction The background to the guide and the principles of risk assessment Section 2: Your Vessel Self Assessment Assessment of food safety requirements using checklists Section 3: Your Food Safety Management System How to develop a Food Safety Management System Section 4: Your Crew s Training Needs Training needs for each vessel category Section 5: Your Official Inspection The official inspection process and the steps required to gain Approval Section 6: Reference Material Relevant food safety legislation DISCLAIMER The information contained within this User Friendly Guide is solely for guidance purposes and does not purport to be a legal interpretation of the legislative instruments referred to.

3 Contents Glossary Section 1: Introduction Introduction Risk Assessment Vessel Classification Section 2: Your Vessel - Self Assessment Vessel Requirements Checklist Tables - All Vessels Checklist Tables - Approved Vessels Section 3: Your Food Safety Management System The Four Step Approval Process for a Freezer and Factory Vessel Your Food Safety Management System (FSMS) Developing a Pre-Requisite Programme Plan Steps to Developing your HACCP Based FSMS Managing your Food Safety Management System Section 4: Your Crew s Training Needs Traditional Whitefish Vessel Training Training for Approved Vessels Course Details Section 5: Your Official Inspection The Sea Fisheries Protection Authority (SFPA) Inspection Post-Inspection Procedures Ongoing Inspections Can Approval be Withdrawn? Section 6: Reference Material Relevant Legislation Page

4 Glossary Additive A food additive is a natural or manufactured substance, added to foods for a variety of reasons to restore colours lost during processing (e.g. colours), to provide sweetness in low-sugar products (e.g. sweeteners), to prevent deterioration during storage and to guard against food poisoning (e.g. preservatives). Approval A vessel which gains Approval from the Sea Fisheries Protection Authority (SFPA), has been officially inspected and found to be adhering to all the relevant EU legislation regarding food safety. Approval Number A number that is awarded by the Sea Fisheries Protection Authority (SFPA) to vessels, which carry out any stage of: production, processing and distribution of food, after primary production, to show that they have adhered to all relevant EU legislation, regarding food safety. Associated operations The transport, storage and handling of primary products, which are not substantially altered. Batch A group or set of identifiable products obtained from a given process under practically identical circumstances and produced in a given place within one defined production period. Clean water Uncontaminated seawater. Codex The Codex Alimentarius Commission was created in 1963 by the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO) to develop food standards, guidelines and related texts such as codes of practice under the Joint FAO/WHO Food Standards Programme. Competent Authority The Sea Fisheries Protection Authority (SFPA) in Ireland. Critical Control Point (CCP) Critical Control Points are hazards in the operational steps where failure to effectively control them may create unacceptable risks. Due diligence Provides provision of proof from a food business operator that they took all reasonable precautions in order to ensure the production of safe food. Factory vessel A vessel, on which any fishery product undergoes; filleting, slicing, shelling, shucking, mincing or processing, which is then followed by wrapping or packaging and chilling. Fishery products All seawater and freshwater animals, wild or farmed, and all edible forms, parts and products of such fish. Food business operator The skipper or owner of the vessel who is responsible for ensuring that the laws regarding food are understood and adhered to by the crew. Freezer vessel A vessel on which fishery products can be; bled, headed, gutted and have their fins removed, which is then followed by wrapping or packaging and freezing. Fresh fishery products Whole or prepared fish that have been chilled, and/or packaged under vacuum or in a modified atmosphere. Food Safety Management System (FSMS) A documentation system, which provides evidence to support due diligence for a food business. Good Manufacturing Practice (GMP) Good Manufacturing Practice is the control and management of manufacturing. Hazard Analysis Critical Control Point (HACCP) A systematic preventative approach to food safety outlined by the Codex Alimentarius Commission. Histamine Histamine is a chemical, high levels of which can cause histamine poisoning and occurs when the amino acid histidine is broken down by bacteria. Histamine poisoning is linked with pelagic fish and high temperatures. Impervious Does not permit the penetration of water or other substances. Induction hygiene training All crew are required to undergo training when they start working on a vessel to ensure they understand food hygiene. Operations after primary production Post handling and treatment of fish, that is additional to slaughter, bleeding, heading, gutting, removal of fins, refrigeration and wrapping. Organoleptic Use of taste, colour, odour and touch to assess fish quality. Potable water Drinking water. Prepared fishery products Unprocessed products that have been gutted, headed, sliced, filleted or chopped. Primary products Products caught while fishing. Primary production Slaughter, bleeding, heading, gutting, removal of fins, refrigeration and wrapping onboard. Processing An action that substantially alters the fish, including cooking or marinating. Processed products Finished food products, which result from the processing of unprocessed products (e.g. marinated fish). Pre-requisite programme (PRP) Basic conditions and activities that are necessary to maintain a hygienic environment throughout the food chain suitable for the production, handling and provision of safe end products for human consumption. Total Volatile Basic Nitrogen (TVBN) A chemical measurement of spoilage in fish. Traceability Traceability is the ability to trace and follow a food through all stages of production, processing and distribution. Traditional whitefish vessel A vessel that carries out activities such as slaughter, bleeding, heading, gutting, removal of fins, refrigeration and wrapping only. Trimethylamine nitrogen (TMA-N) A chemical measurement of spoilage in fish. Unprocessed products A food product which has not been processed and can include fish products that have been skinned, cleaned, trimmed, chilled or deep frozen. Where necessary When this term is used, it is up to the skipper or owner to decide if a requirement is necessary, appropriate, adequate or sufficient to achieve the objectives of the relevant Regulations. 2

5 Section 1: Introduction As running costs and competition from international markets have steadily increased, fishermen have focused attention on adding value to their catch by size grading, packing, filleting and freezing. The first challenge to adding value onboard is to gain the necessary technical expertise. Bord Iascaigh Mhara have been providing support in areas such as freezing and packing prawns (Nephrops norvegicus), and more recently, have developed a user-friendly guide and DVD on how to tail monkfish (Lophius spp.). The second challenge is to ensure that appropriate food safety measures are in place. The minimum legal hygiene requirements for producing safe food are covered by the EU hygiene package 1, which contains 5 pieces of legislation. These came into effect on the 1st of January 2006, and replace 17 older EU directives. Although the legislation simplifies food safety requirements, it places a greater responsibility on the skippers or owners to ensure that the necessary measures are in place to assure food safety onboard their vessels. This guide seeks to inform fishermen on how to comply with the principle requirements in the legislation. However it is not a substitute to the legislation, which should also be consulted directly. Although the food safety requirements are higher for vessels seeking to add value onboard, they are readily achievable. A large proportion of smaller scale onshore premises that must meet the same food safety requirements are generally successful at gaining Approval. Using this guide and associated training resources, BIM can support you through the process of gaining Approval. 1 The legislation contained in the hygiene package can be found on the Food Safety Authority of Ireland website ( 3

6 Risk Assessment Risk assessment is used widely in many businesses to identify and categorise potential threats, and put in place mitigating measures to optimise safety and performance. It is also used as a tool for assuring food safety. Each food business operator, which includes skippers, must assess the levels of risk associated with their onboard activities. In the seafood context, risk can be defined as the severity of a food safety issue (e.g. illness from contamination) and the likelihood of it occurring for a specific activity (e.g. contamination during filleting fish) as outlined in Figure 1. For traditional vessels simply engaged in primary production, e.g. gutting, washing, grading, boxing, and icing, the food safety risks are generally low 2 and consequently good standards of handling, traceability and hygiene are sufficient (see Section 2). However vessels engaged in operations after primary production and associated operations, are classed either as freezer or factory vessels (see Glossary for definitions). The risk levels are higher for these vessels and the process of hazard analysis and risk assessment must be more structured (detailed in Section 3, page 24). Although most vessels have good in house standards of handling and hygiene in place already, these must be documented in a clear manner to allow the Sea Fisheries Protection Authority (SFPA) check that your crew are trained appropriately, your vessel has appropriate layouts and fittings and that all the food safety risks have been identified and addressed within a specific Food Safety Management System (FSMS). More detail on how you develop your Food Safety Management System is provided in Section 3. 2 Dipping prawns to control melanosis should be classed as medium risk due to the potential risk of residue contamination from incorrect additive use. However if correct guidelines from the additive producers are followed and crew understand the potential risks from their misuse, then this activity can be classed as low risk. BIM are producing a prawn handling guide that will outline the recommended user instructions for the most popular additive products. Figure 1 High Hazard Severity Low Low Gutting Significant Hazard Filleting Likelihood of Occurrence of a Food Safety Issue Cooking High 4

7 Vessel Classification It is important to classify your vessel correctly, either as traditional, freezer or factory, as this will have a bearing on regulatory requirements that must be adhered to. All commercial fishing vessels must be registered with the Licensing Authority for Sea Fishing Boats at the Department of Agriculture, Fisheries and Food, however freezer and factory vessels must also be Approved by the SFPA to permit them place products on the market. Traditional vessels are generally classed as low risk, and therefore, have fewer food safety requirements (see Section 2). There are separate definitions for both freezer and factory vessels in the Regulations ((EC) No. 853/2004) (see Glossary). As you can see from Table 1, factory vessels have the scope to carry out a wider range of activities than freezer vessels. However, for the vast majority of Irish vessels, the food safety requirements are almost identical for both classes, as the current onboard practices carry similar food safety risks (e.g. freezing, filleting). Therefore, the requirements for gaining Approval from the Sea Fisheries Protection Authority (SFPA) are similar. More detail on how to determine the level of risk for each activity, is provided in this guide (Section 3, page 24). It is important to note that if you plan to carry out high risk activities such as cooking, the food safety requirements are significantly more stringent and more sophisticated Food Safety Management Systems will be required. Table 1 Gutting, washing and bleeding Packing Dipping with sulphite Heading or tailing Freezing Extraction of by-products (e.g. cheeks from monkfish) Removing skin Filleting Mincing Cooking Traditional vessel Low risk GMP Low risk GMP Low risk GMP Freezer vessel Medium risk GMP and PRP Medium risk GMP and PRP Factory vessel Medium risk GMP PRP FSMS Medium risk GMP PRP FSMS Medium risk GMP PRP FSMS Medium risk GMP PRP FSMS High risk GMP PRP CCP FSMS GMP - Good Manufacturing Practices must be in place PRP - Pre-Requisite Programme must be in place FSMS - Food Safety Management System must be in place CCP - Critical Control Point measures must be in place 5

8 Table 2 Section 2: Your Vessel Self Assessment Vessel Requirements For each vessel category there are specific food safety requirements you must fulfil. There is a lot of information within the legislation dealing with this area. To simplify this, Checklist Tables (Table 2 to 12) are provided in this Section, which will allow you to quickly establish if you meet the relevant requirements and identify outstanding issues that you must address. It is important to state that in addition to vessels seeking Approval, traditional vessels must meet criteria outlined in Tables 2-7. Vessel Checklist Is your vessel constructed and designed so that: The fishery products cannot be contaminated by bilge-water, sewage, smoke, fuel, oil, grease or other substances, which could leave a residue or taint the fish? Annex III, 853/2004 The surfaces, that the fishery products come into contact with, are made from corrosion-resistant material that is smooth and easy to clean (e.g. stainless steel equipment, food grade plastic, smooth wood)? Annex III, 853/2004 The surface coatings, that the fishery products come into contact with, are durable and non-toxic (e.g. food grade plastic, non-oily wood)? Annex III, 853/2004 The equipment and material, used for working on the fishery products, is made from corrosion-resistant material that is easy to clean and disinfect (e.g. stainless steel knives)? Annex III, 853/2004 The intake of water avoids contamination of the water supply? Annex III, 853/2004 If your vessel holds fish for more than twenty four hours, is it constructed and designed so that: The holds, tanks or containers for the storage of the fishery products maintain them at a temperature of melting ice? Annex III, 853/2004 The holds are separated from the engine compartments and crew quarters? Annex III, 853/2004 If your vessel is equipped for chilling fishery products in cooled seawater, do you: All registered fishing vessels (traditional, freezer and factory) must comply with the requirements in Checklist Tables 2-7 Have a chilling system that cools the water throughout the tank? Annex III, 853/2004 Ensure that the temperature of the fish and clean seawater reaches 3ºC, six hours after loading and 0ºC after 16 hours? Annex III 853/2004 Ensure that the cooling system has a temperature gauge that can be read easily? Annex III, 853/2004 6

9 Table 3 Handling Fish Checklist Do you: Ensure that the fish are protected from contamination? Annex I, 852/2004 Have measures in place to control contamination from the air and water? Annex I, 852/2004 Keep your vessel clean? Annex I, 852/2004 Disinfect areas of your vessel such as the handling area, using approved food grade detergents, after cleaning? Annex I, 852/2004 As far as possible, ensure the fish are kept clean? Annex I, 852/2004 Use potable water, or clean seawater, when cleaning to prevent contamination? Annex I, 852/2004 Ensure that crew handling the fish are in good health and undergo induction training? Annex I, 852/2004 (see Section 4 for information on training requirements) As far as possible, try to prevent animals and pests, such as seagulls, from causing contamination? Annex I, 852/2004 Store and handle waste and hazardous substances, such as paint or other chemicals, in a way that prevents contamination of the fish? Annex I, 852/2004 As soon as you take the fish onboard do you: Ensure that, when in use, the storage areas or containers for storing fishery products are kept clean and well maintained? Annex III, 853/2004 Make sure that the storage areas or containers cannot be contaminated by fuel or bilge water? Annex III, 853/2004 Protect them from contamination, the effects of the sun and any other source of heat? Annex III, 853/2004 Wash them with either potable or clean seawater? Annex III, 853/2004 Handle and store the fish in a way that prevents bruising? Annex III, 853/2004 Chill the fishery product as soon as possible after loading, or land as soon as possible? Annex III, 853/2004 Use ice that is made of potable water or clean seawater? Annex III, 853/2004 Head and/or gut hygienically as soon as possible after capture, and wash the product immediately and thoroughly with potable or clean seawater? Annex III, 853/2004 Chill or freeze by-products for human consumption (e.g. liver or roe)? Annex III, 853/2004 7

10 Do you: Ensure that operations such as heading and gutting are carried out hygienically? Annex III, 853/2004 (See whitefish quality guides and whitefish handling guide) Ensure that if fish are gutted, the operation is carried out as quickly as possible after the products have been caught or landed? Annex III, 853/2004 Ensure that gutted fish are washed with clean seawater immediately after gutting? Annex III, 853/2004 Ensure that containers used for despatching or storing prepared fishery products with ice, allow melt water to drain away from the products (e.g. fish boxes with drainage holes)? Annex III, 853/2004 Do you ensure that: Only safe fishery products are placed on the market? (i.e. the fishery products can be used for human consumption and are not injurious to health) Article 14, 178/2002 If a fishery product from a batch is found to be unfit for human consumption or injurious to health, the whole batch is assessed for safety? Article 14, 178/2002 If a fishery product is found to be unsafe, it is not placed on the market or it is withdrawn from the market? Article 14, 178/2002 The labelling of the fishery products does not mislead the consumer? Article 16, 178/2002 You check that the fishery products you place on the market comply with the relevant legislation? (e.g. they are fresh and maintained at a temperature of melting ice) Article 17, 178/2002 The fishery products are traceable to the next stage in the chain? Article 18, 178/2002 You have records to show who the fishery products were supplied to? Article 18, 178/2002 Table 4 Wrapping and Packaging of Fishery Products Checklist Do you: Ensure that the containers, in which the fishery products are kept under ice, are water resistant (e.g. plastic fish boxes, wax cartons)? Annex III, 853/2004 Ensure that the containers, in which the fishery products are kept under ice, allow the melt water to drain away from the products (e.g. fish boxes with drainage holes)? Annex III, 853/2004 Ensure that if the fishery products are wrapped onboard, the wrapping material is: Not a source of contamination? Annex III, 853/2004 Stored so that it cannot be contaminated? Annex III, 853/2004 Easy to clean and disinfect if intended for re-use? Annex III, 853/2004 Maintain fresh fishery products at a temperature approaching that of melting ice? Annex III, 853/2004 8

11 Table 5 Landing and Unloading Checklist At landing and unloading of the products do you: Ensure that the equipment which comes into contact with the fishery products is constructed of material that is easy to clean and disinfect and well maintained and kept clean (e.g. winch cradles, hooks, ropes for fish boxes)? Annex III, 853/2004 Avoid contamination of the products by: Carrying out the process rapidly? Annex III, 853/2004 Placing the fishery products without delay in a protected environment at the required temperature? Annex III, 853/2004 Not using equipment and practises that cause unnecessary damage to the edible parts of the fishery products (e.g. hooks)? Annex III, 853/2004 Chill products as soon as possible after landing, and store them at a temperature of melting ice, if they have not been chilled onboard? Annex III, 853/2004 Cooperate with relevant Competent Authorities? Annex III, 853/2004 Ensure that you can identify who you have supplied the fish to? Article 18, 178/2002 Table 6 Document Checklist Do you keep records on: Who you supplied fish to? Article 18, 178/2002 Who supplied you with products (e.g. additives, packaging materials, cleaning materials)? Article 18, 178/2002 Induction training? Annex I, 852/2004 Any crews illnesses which are relevant to food safety? Annex I, 852/2004 Table 7 Inspection Checklist Are you aware that the SFPA can inspect your vessel to establish that: Fishery products are handled correctly? Annex III, 854/2004 Cleanliness of the vessels, their facilities, equipment and staff hygiene are adequate? Annex III, 854/2004 Correct storage and transport conditions are being adhered to? Annex III, 854/2004 9

12 Table 8 Approved Vessel Checklist Vessels seeking Approval (freezer and factory vessels) must meet the requirements in Checklist Table 8 Do you have: Do you: A hopper or pound, which is designed in such a way that: Each successive catch can be separated? Annex III, 853/2004 It is easy to clean? Annex III, 853/2004 It protects the catch from the sun, or the elements and from any other source of contamination? Annex III, 853/2004 A hygienic system to convey the fishery products from the receiving area to the work area (e.g. a conveyor from the hopper to the handling area)? Annex III, 853/2004 Areas that are easy to clean and disinfect? Annex III, 853/2004 Areas that are large enough for the hygienic preparation and handling of the fishery products? Annex III, 853/2004 Areas that are designed to prevent the contamination of the products (e.g. a specific handling area)? Annex III, 853/2004 Storage areas for the finished products that are large enough to hold the products? Annex III, 853/2004 Storage areas that are easy to clean? Annex III, 853/2004 A separate hold designated for the storage of waste from waste-processing units, if a unit operates onboard? Annex III, 853/2004 A designated area for storing packaging materials that is separate from the product preparation and handling areas? Annex III, 853/2004 Special equipment for disposing waste or fishery products that are unfit for human consumption directly into the sea, or into a watertight tank reserved for that purpose? If waste is stored and processed onboard for subsequent use or disposal, separate areas must be allocated for that purpose. Annex III, 853/2004 A water intake situated in a position that avoids contamination of the water supply? Annex III, 853/2004 Hand-washing equipment for crew who handle exposed fishery products with taps designed to prevent the spread of contamination (e.g. elbow or knee operated taps)? Annex III, 853/2004 Keep the vessel clean and maintained in good repair and condition? Annex II, 852/2004 Have suitable temperature controlled handling and storage conditions which are large enough to maintain the fishery products at appropriate temperatures and allow for these temperatures to be monitored and, in the case of frozen storage, recorded? Annex II, 852/2004 Store cleaning agents and disinfectants in a separate area to where the food is handled? Annex II, 852/2004 Use chemical additives to prevent corrosion of equipment and containers according to good practice? Annex II, 852/2004 Handle waste appropriately? Annex II, 852/

13 Does the layout, design, construction and size of the vessel allow: Adequate maintenance? Annex II, 852/2004 Adequate cleaning and/or disinfection? Annex II, 852/2004 Avoidance or minimisation of air-borne contamination (e.g. diesel fumes)? Annex II, 852/2004 Adequate working space for the hygienic performance of all operations? Annex II, 852/2004 For protection against the accumulation of dirt, contact with toxic materials, the shedding of particles into food and the formation of condensation or undesirable mould on surfaces? Annex II, 852/2004 Good food hygiene practices, including protection against contamination and, in particular, pest control? Annex II, 852/2004 Does your vessel have adequate: Flush lavatories which do not open directly into rooms where the fish are handled? Annex II, 852/2004 Washbasins which are suitably located and designated for cleaning hands, with hot and cold running water, material for cleaning the hands and for hygienic drying? Annex II, 852/2004 Natural or mechanical ventilation? Annex II, 852/2004 Natural and/or artificial light? Annex II, 852/2004 Drainage facilities which are designed and constructed to avoid the risk of contamination? Annex II, 852/2004 Changing facilities? Annex II, 852/2004 Facilities, where necessary, for the cleaning, disinfecting and storage of working utensils and equipment? These facilities are to be constructed of corrosion resistant materials, be easy to clean and have an adequate supply of hot and cold water. Annex II, 852/2004 Facilities to wash the fishery products with clean sea water? Annex II, 852/2004 Does your handling area: Have a design and layout that permits good hygiene practices, including protection against contamination between and during operations? Annex II, 852/2004 Have floor surfaces that are: Maintained in a sound condition? Annex II, 852/2004 Easy to clean and, where necessary, to disinfect? Annex II, 852/2004 Made from impervious, non-absorbent, washable and non-toxic materials? Annex II, 852/2004 Drained adequately where appropriate? Annex II, 852/

14 Does your handling area: Have wall surfaces that are: Maintained in a sound condition? Annex II, 852/2004 Easy to clean and, where necessary, to disinfect? Annex II, 852/2004 Made from impervious, non-absorbent, washable and non-toxic materials? Annex II, 852/2004 Smooth up to a height appropriate for the operations? Annex II, 852/2004 Have ceilings and overhead fixtures that are constructed and finished so that they prevent the accumulation of dirt and reduce condensation, the growth of undesirable mould and the shedding of particles? Annex II, 852/2004 Have windows and other openings which are constructed to prevent the accumulation of dirt? Annex II, 852/2004 Have doors that are: Easy to clean and, where necessary, to disinfect? Annex II, 852/2004 Constructed from smooth and non-absorbent surfaces? Annex II, 852/2004 Have surfaces (including surfaces of equipment) and in particular those in contact with food: Which are maintained in a sound condition? Annex II, 852/2004 Easy to clean and, where necessary, to disinfect? Annex II, 852/2004 Which are constructed from smooth, washable corrosion-resistant and non-toxic materials (e.g. stainless steel, food grade plastic)? Annex II, 852/2004 Are all the articles, fittings and equipment which come into contact with the fish: Effectively cleaned and, where necessary, disinfected? Cleaning and disinfection are to take place at a frequency sufficient to avoid any risk of contamination. Annex II, 852/2004 Constructed of materials and kept in good repair and condition so that contamination is minimised (e.g. food grade plastic that is regularly shaved or replaced)? Annex II, 852/2004 Are constructed from material and kept in good order, repair and condition to that they can be kept clean and, where necessary, disinfected (with the exception of non-returnable containers and packaging) (e.g. table where added value activities take place should be made from stainless steel or food grade plastic and well maintained and cleaned after every haul)? Annex II, 852/2004 Installed so that adequate cleaning of the equipment and surrounding area is allowed? Annex II, 852/2004 If you have a freezer vessel do you have: Freezing equipment which lowers the core temperature of the fish to 18ºC rapidly? Annex III, 853/2004 Equipment to maintain the fish products in the holds at 18ºC? Annex III, 853/2004 A temperature recorder fitted in the holds that can be read easily? Annex III, 853/2004 A temperature sensor situated in an area where the temperature would be highest (e.g. a temperature logger that can be downloaded at the end of every trip)? Annex III, 853/

15 Table 9 Crew Checklist Approved vessels must make sure their crew adhere to the requirements in the Checklist Table 9 Do your crew know: Are your crew: That they have to maintain a high degree of personal cleanliness in the food handling area? Annex II, 852/2004 That they have to wear suitable, clean and, where necessary, protective clothing in the food handling area (e.g. aprons when carrying out added value activities, arm protectors when using blast freezer)? Annex II, 852/2004 That they must not handle the fish or fish products if they have: Infected wounds? Annex II, 852/2004 Skin infections? Annex II, 852/2004 Sores? Annex II, 852/2004 Diarrhoea? Annex II, 852/2004 That they must inform the skipper if they have any of the above conditions? Annex II, 852/2004 Trained in food hygiene? Annex II, 852/2004 (see Section 4 for information on food hygiene training) Supervised, if required? Annex II, 852/2004 Trained in the application of Hazard Analysis Critical Control Point (HACCP) principles, if required? Annex II, 852/2004 (see Section 4 for information on HACCP training requirements) 13

16 Table 10 Do you: Do you: Fishery Products Checklist Approved vessels must make sure they handle the fishery products set out tin the requirements in Checklist Tables Ensure that operations such as filleting and cutting are carried out so that contamination of the fish fillets and slices is avoided? Annex III, 853/2004 Ensure that operations such as filleting and cutting are carried out so that spoilage of the fish fillets and slices is avoided? Annex III, 853/2004 Ensure that the fish fillets and slices do not remain on the worktables beyond the time necessary for their preparation? Annex III, 853/2004 Ensure that the fish fillets and slices are wrapped and, where necessary, packaged? Annex III, 853/2004 Ensure that fillets and slices are chilled as quickly as possible after their preparation? Annex III, 853/2004 Use ice that is made of potable water or clean seawater? Ice is to be made, handled and stored under conditions that protect it from contamination. Annex II, 852/2004 Have an adequate supply of potable water or clean seawater, if this is used for glazing the fishery products? Annex II, 852/2004 Have an adequate supply of clean seawater for washing the whole fishery products? Annex II, 852/2004 Carry out a freshness assessment on the fish you use for human consumption? Annex III, 853/2004 (see Section 3, page 29 for information on the sensory assessment of fishery products) Ensure that the fish have levels of histamine which are within the acceptable limits? Annex III, 853/2004 Ensure that the fishery products are not placed on the market if chemical tests reveal that the acceptable limits of TVBN and TMA-N have been exceeded? Annex III, 853/2004 (TVBN or TMA-N tests should be carried out if there is any doubt over the freshness of the fishery products Annex III, 854/2004) Ensure that the fishery products have been examined for the presence of visible parasites before being placed on the market? Annex III, 853/2004 (see Section 3, page 29 for information on the assessment of fishery products for the detection of parasites) Have an appropriate sampling plan to demonstrate compliance with microbiological criteria? Article 14, 178/

17 Table 11 Wrapping and Packaging Checklist Do you: Use material for wrapping and packaging that is not a source of contamination? Annex II, 852/2004, Store the wrapping and packaging material so that it is not exposed to contamination? Annex II, 852/2004 Wrap and pack the fishery products in a way that does not expose them to contamination? Annex II, 852/2004 Have wrapping and packaging material that is easy to clean and, where necessary to disinfect, if it is to be re-used? Annex II, 852/2004 Ensure that frozen blocks, prepared onboard the vessel are adequately wrapped before landing? Annex III, 853/2004 Maintain frozen fishery products at a temperature of not more than -18ºC in all parts of the product? Annex III, 853/2004 Table 12 Hazard Analysis and Critical Control Points Checklist Vessels seeking Approval must implement HACCP procedures as set out in Checklist Table 12 Do you: Have Hazard Analysis Critical Control Point (HACCP) procedures in place? Article 5, 852/2004 Know that if a product, or operation is altered, the HACCP based procedures must be reviewed? Article 5, 852/2004 Have evidence of implementation and maintenance of the HACCP based procedures that will satisfy the competent authority? Article 5, 852/2004 Know that documents and records must be kept up-to-date and retained for inspection for an appropriate period? Article 5, 852/2004 Carry out microbiological checks on the fishery products as a way to validate and verify the HACCP procedures? Article 3, 2073/

18 Section 3: Your Food Safety Management System The Four Step Approval Process for a Freezer and Factory Vessel Step 1: Hygiene, HACCP and Training. Step 2: Contact the SFPA to Arrange an Official Inspection. Step 3: Conditional Approval. Step 4: Approval and Ongoing Inspections. The first step is to check that the layout, fixtures and fittings, and hygiene of your vessel complies with the relevant legislation (Section 2). You must carry out a risk analysis of the added value activities onboard and establish pre-requisite programmes and associated record keeping requirements. A Food Safety Management System (FSMS) based on HACCP principles, specific to your vessel must be developed (Section 3). Crew should be trained to a recognised standard as food handlers and at least two crew should be designated as the HACCP team leaders and trained in HACCP principles (Section 4). BIM can provide advice on this and will carry out a preinspection of your vessel and crew to assist you prepare for the official inspection by the Sea Fisheries Protection Authority (SFPA). An application form for Approval can be obtained by contacting the SFPA (Tel. no ) or your local Sea Fisheries Protection Officer. On receipt of the completed application form, the SFPA will contact you to arrange an Approval inspection. Structural, hygiene and operational standards of the vessel will be audited; documentation reviewed and the crew s training assessed to determine compliance with the legislative requirements. If all relevant legislative requirements are met, full Approval will be granted and an Approval Number assigned to the vessel. If structural and equipment requirements are met and there are no serious deficiencies in terms of product safety, a Conditional Approval Number may be granted for a period of 3 months, during which time non-compliances must be addressed. A follow up inspection will be carried out at the end of this period; if clear progress has been made but full requirements are still not being met, the Conditional Approval can be extended for a further 3 months. The maximum period for which a Conditional Approval can be extended for a vessel is 12 months. As part of official controls, ongoing inspections will be carried out by the SFPA; a vessel s Approval can be suspended for a specified period of time, or revoked if at any time the legislative requirements are not being maintained. 16

19 Your Food Safety Management System (FSMS) As the food safety risks are higher when adding value onboard, you are required (Article 5, (EC) No. 852/2004) to prove due diligence through appropriate documentation. A robust Food Safety Management System based on Hazard Analysis Critical Control Point (HACCP) principles helps you achieve this. Although this sounds complicated, developing such a System is relatively straightforward for most vessels, as filleting, washing, blast freezing and storing are not classed as high risk activities. HACCP is a preventative System, which allows you identify the nature and location of potential food hazards in each of your operational steps, and importantly, puts measures in place to eliminate or reduce them to acceptable levels. For serious hazards, Critical Control Point (CCP) measures must be put in place. However for most basic onboard added value activities, the hazards encountered can be controlled by Pre-Requisite Programmes (PRPs). These ensure adequate vessel structural and operational hygiene requirements; personal hygiene practices and facilities; fundamental hygiene, training and handling standards are in place. This Section provides an overview of how you develop an appropriate FSMS for your vessel starting with developing a pre-requisite programme plan through to developing policies and procedures. Although most hazards can be controlled by pre-requisite programmes, including temperature, to cater for high risk activities such as cooking, the steps on how you develop Critical Control Points (CCPs) are explained (page 25). It is recommended that you develop your FSMS with appropriate technical support. BIM provide a course on Risk Based HACCP for Seafood which designated crew must complete as part of the Approval process (see Section 4). This course will help participating crew, to develop an appropriate FSMS for their vessels, using this guide as course content. 17

20 Developing a Pre-Requisite Programme Plan Developing a pre-requisite programme plan helps to ensure that the hygiene requirements outlined in Checklist Tables 2-12 are implemented onboard. The pre-requisite programmes will be specific to each vessel and require monitoring and verification to ensure that they are effective. The potential hazards, control measures, monitoring plan, corrective actions, and associated documents have to be outlined for each hygiene requirement. Four examples of pre-requisite programmes are provided in the plan below. Pre-requisite programme plan PRP No. Hazard (source) Control Measure Critical Limits Monitoring Procedure By Frequency Corrective Action Document Reference Verification Personal Hygiene 1 Pathogen contamination Training of staff Appropriate staff facilities Compliance to training programme (Seafood Hygiene Management) Visual supervision Authorised personal Each trip Re-train Training portfolio Review knowledge Competency Waste Management Pest Control 2 Pathogen contamination Waste management Training of staff System segregation Compliance to training programme and FSMS On site training Skipper Each trip Segregate Training portfolio Pest and waste control check sheet Monthly inspection (refer to completed Pest & Waste control check sheet) Cleaning & Sanitation 3 Pathogen contamination Cleaning programme Compliance to training programme and FSMS Visual Individual crew member Journey ashore Re-clean Cleaning schedule Hygiene swabs Maintenance & Calibration 4 Chemical and physical contamination Maintenance plan Adhere to FSMS schedule As per schedule Engineer As per schedule Re-calibrate Carry out correct maintenance Maintenance log or diary Maintenance records Use outside qualified contractors In addition to the examples above, the pre-requisite programmes should also include sections on: Appropriate design and construction of the vessel, (see vessel Checklists in Section 2), Services (to include purchasing of wrapping and packaging material, additives, processing aids and the supply of water), Quality and Food Safety Assessment, Storage, Distribution and Transport, Segregation, Maintenance of the Cold Chain, Freezing Temperatures, Traceability, Use of Sodium Metabisulphite and Training. 18

21 Steps to Developing your HACCP Based FSMS Once you have a robust pre-requisite programme in place, you can develop a HACCP-based, FSMS. CODEX 1 details the twelve steps that are involved and these are outlined in the diagram below. Each of the 12 steps must be addressed when developing a FSMS. For illustration purposes only, the tailing and freezing of monkfish has been used in the examples of the procedures involved. Step 1 Step 2 Step 3 Step 4 Step 5 Step 6 Step 7 Step 8 Step 9 Step 10 Step 11 Step 12 Assemble the HACCP team Describe the product Identify the intended use Construct a flow diagram Confirm the flow diagram on-site List all the potential hazards Construct a hazard analysis Consider control measures Determine the Critical Control Points (CCPs) Establish the critical limits for each CCP Establish a monitoring system for each CCP Establish corrective actions Establish verification procedures Establish documentation and record keeping Step 1: Assemble the HACCP Team The team should be made up of a number of people with expertise in the following areas: Handling of fishery products; Hygiene and operation of the vessel; Knowledge of HACCP. External assistance can be sought. The scope of the HACCP plan should be identified. The scope describes which segment of the food chain is involved, which process of the business and the general classes of hazard to be addressed (Biological, Chemical and Physical)

22 Steps 2 & 3 Describe the Product and its Intended Use Describing the product and the way it is stored will allow you to identify any relevant food safety information such as the use of additives and temperature requirements, which must be provided to the customer. Outlining the expected use of the product allows you to include any safety information which is relevant to vulnerable groups, for example mercury levels in tuna for pregnant women. Product Description Form Product: Monk Tail Author: Date: Step 2: A full description of the product is required. Product Name Sales Description Preservation Factors Type of Packaging Labelling Requirements Relating to Food Safety Storage Conditions Monk tails Frozen monk tails Blast freezing (min -18ºC) Onboard freezer (min -18ºC) Cardboard cartons Plastic sheets Common and scientific name Batch code Approval Number Best before date Storage instructions Blast frozen cartons (min -18ºC) Stored in onboard freezer (min -18ºC) Product Shelf Life Distribution Requirements Customer Use Customer Abuse 12 months from production date Distributed to wholesalers in frozen condition (-18ºC) Wholesale/Retail/Catering and further processing Thawing and refreezing Break in chill-chain management Step 3: The normal or expected use of the customer should be defined, as well as any allergen advice required. 20

23 Step 4 Construct a Flow Diagram All steps from receiving the raw materials to placing the end product on the market should be presented in a detailed flow diagram. Sufficient technical data should also be included so that anyone reviewing the information will understand the way the fish are handled onboard. Operation Description 1: Shooting the net 2: Boarding 3: Sorting The net is shot and towed for a maximum duration of 5 hours. The net containing the fish is emptied into a hopper until the net is redeployed and the crew are ready to handle the catch. The fish are released in batches from the hopper, by means of a trap door, onto a conveyor and transported to the work area. Non-marketable and small fish are discarded, by means of a chute leading to the open sea. Step 4: Construct a flow diagram and describe briefly each step in the operation. 4: Gutting The crew gut the fish; the guts are discarded via a discard chute. 5: Washing The fish are washed by hand, in the case of large whole fish, and in a washing machine for smaller fish. Particular attention is paid to sand deposits in the gill area. Where insufficient monk are available to make up a full batch, the monk taken in the haul are retained, gutted, in the chilled hold, to be tailed later. 6: Tailing The monk is tailed. 7: Grading The monk tails are graded into size categories determined by market specifications. 8: Blast freezing of tails 9: Shattering, dipping, boxing, weighing and labelling 10: Frozen storage and transport The monk tails are placed in freezer trays with food grade plastic underneath and on top and are placed into the blast freezer, for approximately 5 hours, until a core temperature of -18ºC is achieved. The blast-frozen tails are taken out of the blast freezer, shattered, dipped in potable water and placed in suitable packaging. The boxes are then weighed, labelled and placed in frozen storage. The labelled cartons of monk tails are placed in the onboard freezer (a core temperature of -18ºC must be achieved). On landing, the monk tails are removed from the onboard freezer and are transported by lorry, at min -18ºC, to their final destination. 21

24 Step 5 Construct a Process Flow Diagram A birds eye view of the handling area, showing the process flow is required to show how the fish are handled at the various stages within the handling area onboard. Walk through the handling area with your operation description and make sure that everything has been included. Step 5: Draw the handling area layout of your vessel and show the process flow movement from intake to finished product. Process flow raw product Process flow frozen product 22

25 Step 6 Construct a Hazard Analysis All potential Biological, Chemical or Physical Hazards that could occur at each operational step (see Step 4) must be listed. This is to show that all hazards that have the potential to affect the production of safe food have been identified for each step. Work out the Level of Risk for each Hazard by following the risk assessment instructions on the following page. Describe what actions and activities (Control Measures) you are going to use to prevent, eliminate or reduce each hazard. List the procedures or specifications to ensure the control measures are effectively implemented under the Comments section. Hazard Analysis Step 1: Shooting the net Author: BIM Date: 05:07 Hazard Source Level of Risk Control Measures CCP Y/N Comments BIOLOGICAL HAZARDS: Contamination, Growth, Survival Pathogen contamination Old meshed fish in the nets Low PRP (Pre-requisite programmes) No Adhere to cleaning schedule CHEMICAL HAZARDS: Contact, residual, Contaminants Chemical contamination Net contaminated with oil on deck from repairs onboard Net deployed in waters that are not clean e.g. an oil slick Medium PRP (Pre-requisite programmes) No Adhere to cleaning schedule Fish in clean waters PHYSICAL HAZARDS: People, Plants, Packaging, Pests Presence of foreign bodies Environmental, pollution e.g. rubbish hauled up Low to Medium Training No Be vigilant Visually inspect the haul 23

26 Risk Assessment Tables To establish the level of risk associated with each potential hazard in your operation description (page 21), look at the Likelihood and Hazard Severity of potential risks at each step. To assess risk you need to consider Likelihood (Table 12), which is the degree of probability that the impact will occur and Hazard Severity (Table 13), which is the amount/level of change, usually negative, that will be caused by an impact if it does occur. Use the final tables (Table 14 & 15) to establish the Level of Risk. The following is a worked example, which is highlighted in each of the following tables below. Finding old fish meshed in a net when shooting is a Frequent Event however the Hazard Severity would be Marginal giving a risk assessment of 5, which is a Low Level of Risk. Use this approach for each hazard identified in step 6. Table 12 Likelihood Score Example Improbable 1 May occur only in the most exceptional circumstances. Remote Possibility 2 Could happen very occasionally. Occasional Event 3 Might occur at some time. Probable Event 4 Will probably occur in most circumstances. Frequent Event 5 Is expected to occur in most circumstances. Table 14 Hazard Severity Likelihood 0 Negligible 1 Marginal 2 Considerable 3 Major 4 Critical 1 Improbable Remote Possibility Occasional Event Probable Event Frequent Event Table 13 Hazard Severity Score Example Negligible 0 The hazard has no impact or is not detectable. Marginal Considerable Major The hazard impacts on the customer requirements or expectations (customer complaints). The hazard impacts on product specifications / critical limits; significant. The hazard impacts on legal requirements, consumer illness. Critical 4 The hazard impacts on public health, consumer death. Table 15 Risk Rank Level of Risk 0 Very low 1-5 Low 6-10 Medium High Extreme 24

27 Steps 7, 8, 9, 10 & 11 Establish your Hazard Control Plan Critical Control Points (CCPs) are hazards in the operational steps where failure to effectively control them may create unacceptable risks. The time and temperature specified for cooking prawns is an example of a Critical Control Point, and the control at this point should never fail. Critical Control Points must be under constant control by the crew or machines, and the performance of the control steps must be monitored and documented. HAZARD CONTROL PLAN SCOPE: Cooking Prawns VESSEL: AUTHOR: DATE: PAGE: 1 of 1 Step CCP No. Hazard (source) Control Measure Critical Limits Monitoring Procedure By Frequency Corrective Action Document Reference Verification Cooking of prawns Pathogen Growth (Incorrect cooking temperature, incorrect cooking time) Step 7: Determine the Critical Control Points (CCPs) for any hazard which requires a control measure in order to ensure the safe production of food. 1 Water is vigorously boiling 6:1 ratio of water to prawns used Ensure prawns are well graded Stir the prawns while cooking Place cooked prawns in chilled clean sea water to stop cooking Only use utensils identified for handling cooked prawns Cooked prawns are not to be handled by crew who handle raw prawns Bring water back to boil (60 seconds) Time the cook from second boil using count down timer: Small prawns 30 seconds 1 Large prawns 60 seconds 2 Step 8: Establish the upper and lower limits to control the hazard. Temperature monitoring Visual (bubbles in water) Time monitoring Visual (cooked prawns will be curled up and meat will be separated from shell along back) Designated crew member Step 9: Have a monitoring schedule for the critical limits. 1,2 Cooking times presented are for explanatory purposes only. Specific controlled tests must be carried out to establish appropriate cooking times. Every time prawns are cooked If undercooked add to cooker for further cooking If overcooked discard Retrain crew Step 10: Corrective actions must be established so that the crew know what to do if a critical limit is exceeded. Cooking policy and procedure Temperature print out Training records Cleaning schedule Zoning of cooked operations away from raw handling area Core temperature of product checked using a temperature probe once a month Sample of prawns are sent off for microbiological analysis every month Utensils for handling cooked prawns swabbed at end of every trip Step 11: Specify what methods and procedures you use to verify if the HACCP is working correctly. 25

28 Step 12 Establish a Documentation and Record Keeping Routine Your documentation contains all the relevant information generated when developing your FSMS, e.g. your PRP plan, your hazard analysis etc. Records provide the evidence that you are adhering to your System and it is working appropriately. The HACCP based procedures must be reviewed annually or if the added value activities or crew involved change. All the records generated and a record of the HACCP review must be maintained for auditing. For more information on auditing, see Section 5. Step 12: Accurate, organised records must be kept to support and demonstrate that your FSMS is working effectively at controlling the identified hazards. The documents must include: hazard analysis and CCP determination, and CCP record sheets to show you are monitoring and verifying each CCP. The designated crew member responsible for the FSMS upkeep (see Section 4 on training requirements) must sign all the records generated by the crew. 26

29 Managing your Food Safety Management System Once you have developed and implemented you HACCP based procedures, it is important that the information is arranged carefully in a folder, that is left on the vessel, so that it can be accessed: by your crew to update records and by the SFPA for audit purposes. In addition to records, a number of policies and statements, outlined in the FSMS folder below, must be readily accessible for audit purposes. Careful management of all documentation is essential, as it shows your commitment to producing safe food products. Your FSMS folder Information on your vessel. A statement on your commitment to food safety. A list of fishery products you are adding value to and the vessel classification reasoning. A list of all the current crew and an outline of the skipper and crew responsibilities. A list of pre-requisite programmes as outlined on page 18. Completed cleaning and monitoring records need to be retained. Policies and procedures for each of the pre-requisite programmes. The HACCP principles as outlined in the twelve steps on page Sensory and parasite assessment on random samples of fish. See example B. A list of the relevant legislation. See Section 6. To further assist in the development of an effective FSMS, a summary of policies and procedures, fish quality assessment, labelling and product recall are also presented (examples A-D). 27

30 Example A: Policies and Procedures A policy can be described as a statement of intent outlining the company s commitment to food safety or quality. In the case of Approved vessels, the policies outline the skipper and/or owner s commitment to food safety or quality. A procedure gives more details on how the company achieves the stated policy and can use headings such as Who, When, How and Related Records. Policy: Policy: Statement outlining the commitment to training. Policy: Statement outlining the commitment to hygiene. Procedure: Procedure: Information on how the skipper/owner ensures that all the crew are adequately trained, instructed and supervised. Information on personal hygiene, the use of protective clothing, the maintenance of the vessel s cleanliness and the cleanliness methods during the capture and handling of fish must be outlined. Records: Records of training for new and existing crew must be kept. 28 Records: The crew must sign a record to show that they have read and understood the policy. Policy: Policy: Policy: Statement outlining the commitment to food safety by having a policy with regard to visitors. Procedure: Information on the requirements of any visitors to the handling area must be outlined. Statement outlining the commitment to maintenance. Procedure: Information on how maintenance contractors carry out procedures in fish handling areas. Records: A record of maintenance must be kept. Statement outlining the commitment to calibration. Statement outlining the commitment to pest and waste control. Procedure: Procedure: Information on the requirements for calibration contractors and the frequency of calibration. Information on waste and pest procedures as well as the areas where inspections will be carried out and the frequency. Policy: Records: Records of calibration must be kept. Records: Records of checks on the pest and waste management must be kept. Statement outlining the commitment to traceability. Procedure: Information on how products can be traced must be outlined as well as an explanation of the vessel s batch code. Records: Information on batch codes must be retained for potential product recall. Contact information for the customers and transport firms must be kept. Policy: Statement outlining the commitment to product recall. Procedure: Information on how to carry out a product recall must be outlined. Records: Contact information for the regulatory authorities and the recall team and an example of a product recall notice must be kept. An example of a product recall flow diagram is shown in example C. An example of a label must be kept to show that you are providing the required information. See example D.

31 Example B: Fish Quality and Food Safety Assessment Freshness Ratings To ensure the fish you are handling are fresh, it is important that a sensory check is carried out. Five random samples of fish must be assessed for freshness during the gutting stage after each haul and the results entered into a table like the one below. The attributes to be examined and grades allocated are described in Regulation (EC) No. 2406/96. The attributes that are to be examined ASSESSMENT TO BE MADE ON FIVE FISH AND AVERAGE TAKEN [E, A, B, Na (Not admitted)] The grades to be applied to the fish Freshness Attributes Haul Parasite Analysis A random sample of five fish from each batch must be examined for visible parasites during the gutting stage after every haul. Any fish that are obviously contaminated with parasites must not be placed on the market for human consumption. Checking fish for parasites is a legislative requirement as outlined in Regulation (EC) No. 853/2004, (EC) No. 854/2004 and (EC) No. 2074/2005. Date Skin E E E E E A E E E E MG Skin mucus E A E E E E E E E E Eye E E E E A E E E E E Gills E E E E E The E Eaverage E A E result from five random fish must be Peritoneum (in gutted fish) E E E E E recorded after every haul Smell of gills & abdominal cavity A A E E E Signed The crew member who carries out the assessment must sign the record Presence or absence of parasites Fill in yes or no for five fish for each haul Haul Date Signed N N N N N N N N N N The crew member who MG carries out the assessment must sign the record Microbiological Tests A sampling plan for microbiological tests such as TVBN should be established to show that the pre-requisite programmes and HACCP procedures are effective in producing safe fish products. The testing frequencies can be reduced over time as you will have records of TVBN levels to show that your pre-requisite programmes are effective. 29

32 Example C: A Product Recall Flow Diagram In the event of a product recall, the vessel skipper and/or owner will ensure that: The buyer is notified of the Product Recall either by fax or phone call from the vessel and via national media (in event of a threat or potential threat to human life or health). Notification includes the following: Nature of recall, Description - Batch number - Instructions (Quarantine/Recall/Disposal/Method of Credit). Buyers verify if the product is stocked. Product in stock remove the goods immediately. The vessel will advise on the appropriate action to be taken, whether to dispose of the product or quarantine the consignment and await collection from the supplier. Product not stocked no further action required. Source: FSAI For more information please refer to Code of Practise No. 5 Food Incidents and Food Alerts on the Food Safety Authority of Irelands website ( Buyers claim credit from the vessel within 5 working days. 30

33 Example D: An Example of a Label Species common name Market specific information The batch code Species scientific name Weight in kg Production method and FAO area Best before date (12 months after production for frozen products) Approval Number Any additives, such as Sodium Metabisulphite, must also be listed Storage instructions and temperature requirements 31

34 Section 4: Your Crew s Training Needs Traditional Whitefish Vessel Training All crew on any fishing vessel should be trained in basic hygiene and handling to ensure the production of safe seafood. This basic training, known as induction training can be provided by experienced crew members and/or the skipper. Details on induction training are provided on the Food Safety Authority of Irelands website ( There are however, additional requirements for freezer and factory vessels which are outlined below. Training for Approved Vessels All crew members on freezer and factory vessels should be trained in Seafood Hygiene Management. The HACCP team leaders must be trained in Risk Based HACCP for Seafood, during which instructions are given on how to develop a specific FSMS for your vessel using this guide as the core course content. Please be aware that a HACCP team leader must be onboard Approved vessels for all trips where the Approval Number will be used on the fishery products and therefore it is advisable to have more than one crew member be trained to this level. The designated crew members will then be responsible for the daily management of your FSMS. 32

35 Course Details BIM runs a 2-day FETAC approved course: Seafood Hygiene Management. This course covers: The role of hygiene in food safety; Legal requirements for food safety; Prevention of cross contamination; Personal hygiene and employee health; Pest and waste management; Traceability and product recall. On completing this course the participant will: Understand the legal requirements; Understand the need for monitoring and recording their actions; Know the importance of Pre-Requisite Programmes (PRP); BIM also runs a 3-day FETAC approved course: Risk Based HACCP for Seafood. There are other private companies that can also provide training on HACCP. All the courses will cover: The reason behind HACCP principles for food production; Food borne illness; The seven HACCP principles; How to identify hazards and determine critical control points; How to determine critical limits, monitoring frequency and corrective actions; How to verify your System and maintain records. On completing this course the participant will: Understand the requirements of a FSMS; Know the requirements of relevant legislation; Know how to develop a FSMS; Understand the importance of updating their FSMS; Know how to change their FSMS if required; Be confident in their FSMS and the ability to prepare their vessel for an official inspection by the Sea Fisheries Protection Authority (SFPA). Details of these courses are available at: Or by contacting Marine Services Training Administrator, PO Box 12, Crofton Road, Dun Laoghaire, Co Dublin. Tel: Fax:

36 Section 5: Your Official Inspection The Sea Fisheries Protection Authority (SFPA) Official Inspection The official inspection conducted by the SFPA is an independent evaluation to determine: If the activities of the vessel comply with the legislation requirements; If the legislation requirements have been implemented effectively; If the implementation of the requirements will result in a safe fishery product. The table below shows the specific aspects that are examined during the official inspection. Procedures to be verified by the SFPA TrTraceability Traceability Traceabilityaceability Traceability Design and maintenance of the premises and equipment Hygiene throughout the chain Personal hygiene Training in hygiene and work procedures Pest control Water quality Temperature control Controls on food entering and leaving the premises Documentation The SFPA may seek to verify that the HACCP procedures and FSMS guarantees that the fishery products comply with microbiological, residue and contaminant criteria laid down in legislation (Article 4, Regulation (EC) No. 854/2004) by taking samples of the fishery products. A close out report and record will be provided by the SFPA to document the official inspection. Post-Inspection Procedures After the first official inspection by the SFPA, full Approval may be granted if all relevant legislative requirements have been met. A Conditional Approval Number may be granted if the vessel and the FSMS have met the majority of requirements that have been outlined in Sections 2, 3 and 4 of this guide. A follow up inspection will be carried out within three months and if clear progress has been made but the full list of requirements are still not being met; the Conditional Approval can be extended. Conditional Approval for vessels cannot exceed twelve months. 34

37 Ongoing Inspections The SFPA can carry out ongoing inspections at any time, while the vessel is at sea, or in any port. Such an inspection, will focus on the aspects which are outlined in the following table. What will be checked by the SFPA If the conditions of Approval are still being fulfilled (your FSMS folder and HACCP based procedures will be reviewed) If the fishery products are handled correctly If the hygiene and temperature requirements are being adhered to The cleanliness of the vessels The cleanliness of the facilities and equipment Staff hygiene If the storage and transport conditions are being adhered to Where necessary, microbiological checks will be carried out, as well as random checks for parasites and freshness The SFPA will carry out ongoing inspections to check that the vessel maintains appropriate standards. The auditing intensity and frequency will depend on: The level of risk; The type and amount of added value activities; The skipper and/or owner s past performance in compliance with the food law (Article 4, Regulation (EC) No. 854/2004). Can Approval be Withdrawn? Yes. If the SFPA identifies serious deficiencies, has to stop production repeatedly or has not obtained adequate guarantees from the skipper and/or owner regarding future production, they will initiate procedures to withdraw the vessel s Approval. If the skipper and/or owner can guarantee that deficiencies will be rapidly resolved within a reasonable time period, the withdrawal may be temporary. 35

38 Section 6: Reference Material Relevant Legislation Hygiene package Regulation (EC) No 852/2004 of the European Parliament and of the Council of 29th April 2004 on the hygiene of foodstuffs. Regulation (EC) No 853/2004 of the European Parliament and of the Council of the 29th April 2004 laying down specific hygiene rules for food of animal origin. Regulation (EC) No 854/2004 of the European Parliament and of the Council of the 29th April 2004 laying down specific rules for the organisation of official controls on products of animal origin intended for human consumption. Council Directive 2002/99/EC of 16 December 2002 laying down the animal health rules governing the production, processing, distribution and introduction of products of animal origin for human consumption. Directive 2004/41/EC of the European Parliament and of the council of 21st April 2004 repealing certain directives concerning food hygiene and health conditions for the production and placing on the market of certain products of animal origin intended for human consumption and amending Council Directives 89/662/EEC and 92/118/EEC and Council Decision 95/408/EC. Marketing of fishery products Council Regulation (EC) No 104/2000 of 17th December 1999 on the common organisation of the markets in fishery and aquaculture products. Commission Regulation (EC) No 2065/2001 of 22nd October 2001 laying down detailed rules for the application of Council Regulation (EC) No 104/2000 as regards informing consumers about fishery and aquaculture products. Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28th January 2002 laying down the general principle and requirements of food law, establishing the European Food Safety Authority and laying down procedures in matters of food safety. Directive 2000/13/EC of the European Parliament and of the Council of 20th March 2000 on the approximation of the laws of the Member States relating to the labelling, presentation and advertising of foodstuffs. Quality and safety checks Commission Regulation (EC) No 2406/96 of 26 November 1996 laying down common marketing standards for certain fishery products. Commission Regulation (EC) No 2073/2005 of 15 November 2005 on microbiological criteria for foodstuffs. Commission Regulation (EC) No 2074/2005 of 5 December 2005 laying down implementing measures for certain products under Regulation (EC) No 853/2004 of the European Parliament and of the Council and for the organisation of official controls under Regulation (EC) No 854/2004 of the European Parliament and of thecouncil and Regulation (EC) No 882/2004 of the European Parliament and of the Council, derogating from Regulation (EC) No 852/2004 of the European Parliament and of the Council and amending Regulations (EC) No 853/2004 and (EC) No 854/

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