30) The Committee recalled that the last session had decided that the codes which had not been considered so far would be revised and integrated into the single code, in order to cover all fish and fishery products. A Working Group including the lead countries and other interested countries had met in London in 1999, in order to complete the integration of all relevant sections into the revised document. The Delegation of the United Kingdom introduced the Proposed Draft and outlined the main changes made to the earlier version. The “ How to Use this Code” section was expanded in order to make the Code more “user-friendly” and the document became more pragmatic in its approach. Some sections were rearranged: e.g. the Prerequisite Section was expanded to identify those GHP technical guidelines that were specific to fish and shellfish. Section 3 was redrafted to reflect the essential elements required prior to initiating hazard and defect analyses, with some items removed from the previous Section 5. Section 4 has become the new Section on the application of HACCP and DAP; Section 5 was rewritten and the “control boxes” were removed from processing sections as there was general agreement to avoid unnecessary prescriptive guidance in the Code.
31) The Committee expressed its appreciation to the United Kingdom, the Drafting Group and the lead countries for their considerable work and recognized that the revised text was now much closer to finalization. The Chairman indicated that for practical reasons it would not be possible to examine the entire Code in detail at the present session and proposed to concentrate on those sections which had been developed more thoroughly, and which had not called for extensive substantial comments. The Committee agreed to consider the general sections (1 to 5) and Section 6 Fresh Frozen and Minced Fish in detail as a first stage, and proceed with Section 13 Canned Fish and Section 14 Frozen Surimi if time allowed.
General aspects
32) The Delegation of Spain, referring to its written comments, stressed the need to separate clearly the aspects related to health protection and those concerning quality, and proposed to divide the code into two parts for this purpose. It was also pointed out that the relationship between the technical guidance provided in the processing sections and the General Principles of Food Hygiene, including the HACCP system should be clarified.
33) The Delegation of Thailand expressed its concerns about the emphasis on the use of HACCP principles to control defects, although this was optional. Defects could be interpreted differently and result in excessive demands for control and documentation where it was not necessary. This would lead to a demand for a HACCP based control programme, not only for product safety but also for quality and economic fraud. Therefore the Delegation suggested that steps for developing DAP should be removed from the main text and presented as an Annex to the Code. The Committee agreed that the current format should be retained and that clarification should be provided where necessary to avoid confusion. The Committee also agreed that a clearer separation between sections related to pre-harvest operations and processing would be appropriate to improve clarity and user-friendliness.
Section 1. Scope
34) The Delegation of Vietnam pointed out that 'production' was not clearly defined and that the code should cover all stages up to the final consumer, especially transportation and retail. The Committee agreed to retain production, which was applied especially to fish farming, and to add processing, transportation and retail in the scope to make it more complete.
Section 2. Definitions
2.1 General Definitions
2.2 Fresh Frozen and Minced Fish
2.9 Canned Fish
35) The Committee agreed that the definition of Clean Sea Water should be expanded to include all types of water (seawater, brackish and freshwater) and that the term “clean water” should cover “water from any source where microbiological contamination, harmful substances and/or toxic plankton are not present in such quantities as may affect the health quality of fishery products”. Consequential amendments were made to all relevant sections by replacing “sea water” with “water”.
36) The Committee agreed that the definitions of Cleaning, Contamination and Disinfection should correspond to those used in the General Principles of Food Hygiene. The definition of Control measures was amended to include the prevention of hazards, in addition to their elimination. The definitions of Decomposition and Defect Action Point (DAP) were reworded for clarification purposes. The Committee agreed to refer to “Biotoxins” in general instead of “Marine Biotoxins”. The definition of Hazard Analysis was added with the wording included in the General Principles of Food Hygiene. In the definition of shelf life a reference to chemical safety was added to microbiological contamination in order to cover all types of hazards.
37) As regards the definition of Fresh Fish, the Committee discussed the need to add provisions concerning shelf life; it was however recognized that the definition did not describe the quality of the product but should only reflect that no treatment other than chilling had been applied. It was also agreed to use the general term “fish and fishery products” for consistency with the rest of the text.
38) In the definition of Frozen Fish, the Committee had an exchange of views on the need to specify the temperature required for frozen fish. A temperature of - 18°C was proposed but it was noted that for brine frozen fish this value was not relevant. As it was recalled that the Standard for Quick Frozen Finfish, Eviscerated and Uneviscerated addressed the question of the temperatures of frozen fish, the Committee agreed to refer to the relevant standard in the definition.
39) As regards the definitions for Canned Fish, it was noted that only the definitions relevant to the current Code and used in section 13 were included in section 2.9
Section 3. Pre-Requisite Programme
40) The Committee agreed to refer to “food safety” instead of safety in this section and wherever applicable throughout the text. A reference to the fact that HACCP principles could be applied to defect action points was added at the end of the introductory section.
41) In section 3.1.2 it was agreed that hand washing and toilet facilities, isolated from the fish handling area, should be available on the vessels “where possible”, taking into account that is was not practical for small vessels.
42) The Delegation of South Africa indicated that containers with a fitted lid could be required for offal and waste which did not originate from fish; however this was not practical in the case of fish waste which was continuously disposed off and a distinction should be made between the types of containers used. The Committee had an exchange of views on this question and agreed that this requirement applied “where appropriate” and would depend on the type of waste.
43) The first sentence of section 3.1.4 was amended to clarify that the section applied only to the transport of live fish from aquaculture to processing facilities, when harvested with seines or nets. It was also noted that transport of dead fish would be covered in the relevant processing section.
44) While discussing section 3.2, the Representative of WHO pointed out that the use of the term “facilities” in the text differed from the General Principles of Food Hygiene, which referred to the “Establishment: Design and Facilities”. The Secretariat recalled that the Committee on Food Hygiene had recommended to follow the layout of the GPFH and ensure consistency with their provisions. The Representative of FAO indicated that the surroundings of the processing facility should also be taken into account in order to prevent contamination.
45) In section 3.2.2, as regards ventilation, a reference to cross-contamination by aerosols was added. At the end of the section, an additional provision was included to the effect that “water supply should be fitted with a back flow device where appropriate”.
46) The introductory paragraph of Section 3.3 concerning equipment and utensils was amended for clarification purposes. The provisions on the implementation of schedules (section 3.4.2) was transferred to the introductory paragraph of section 3.4 Hygiene Control Programme. An additional step to “check the efficiency” of cleaning was added in section 3.4.1. Section 3.5.2 Personnel Hygiene was partially reordered to separate the specific provisions on hand-washing.
47) In section 3.6 Transportation, the Committee noted some proposals for amendment but recalled that the section described only the design and construction of the vehicle, not the conditions of transportation, which would be addressed in Section 17. It was agreed that the reference to protection from contamination and exposure to extreme temperatures adequately covered relevant hazards.
48) In section 3.7 Traceability and Recall Procedures, the Observer from the EC, supported by some delegations, proposed to require the indication of the country of origin on containers and packages in order to ensure the traceability. Other delegations indicated that, for the purposes of inspection, official authorities referred to the information provided in the certificate but that the indication of country of origin would create several practical difficulties. In addition the determination of the country of origin or production was subject to different interpretations according to national legislation. The Committee also recalled that the GPFH required the identification of the producer and the lot for the purposes of identification and recall, and referred to the General Standard for the Labelling of Prepackaged Foods as regards labelling, but did not require the declaration of origin.
49) After an exchange of views the Committee agreed on the following marking requirements, in order to ensure traceability: “each container intended for the final consumer or for further processing should be clearly marked to ensure the traceability of the producer and the lot”.
50) The Committee discussed the proposal of the Delegation of New Zealand to replace the current Section 3.8 Training with the corresponding section of the General Principles of Food Hygiene. It was noted that the current section included requirements on the training on HACCP, which did not appear in the GPFH. The Committee however agreed to retain the section as currently drafted.
Section 4. General Considerations for the Handling of Fish and Fishery Products
51) The Committee agreed with the proposal of the Chairman to reorder the sections for clarification purposes including all biotoxins under Biological Hazards, since some of them were included under Chemical Hazards, and the section was renumbered accordingly.
52) In the introductory section, the Committee agreed with the proposal of New Zealand that fish and shellfish which were found unfit for human consumption could be either reworked or disposed of. In section 4.1.1.1 Parasites, it was agreed that brining would reduce the parasite hazard if the product is kept in brine long enough, but that it may not eliminate it.
53) In section 4.1.1.2 Bacteria, reference was made to bacteria that are 'normally or incidentally' present in the aquatic environment since this was the case in particular for Listeria monocytogenes. In section 4.1.1.4 (now section 4.1.1.3), the Committee agreed that viral contamination was not limited to the harvesting area and that other sources of contamination should be controlled during processing.
54) In the section on Chemical Hazards, it was agreed to include the hazards related to organochlorine compounds (e.g. dioxins and PCBs), veterinary drugs (instead of antibiotics) and contamination by detergents and residues of disinfectants when incorrectly eliminated.
55) In the section on Phycotoxins, the Committee included a reference to Amnesic Shellfish Poisoning (ASP) and Neurotoxin Shellfish Poisoning (NSP), and a separate section on Tetradotoxin in Tetraodontidae (puffer fish).
56) As regards Ciguatoxin, the Representative of FAO pointed out that the ban in trading of such fishery products was not the only effective control measure. Other criteria should be taken into account like seasonal and species variability, geographical location and the size of fish. The Committee agreed that ban in trading was 'one of the control measures'. Other editorial or limited changes were made to the sections for the purposes of clarification.
Section 5. HACCP and DAP Analysis
57) In section 5.1, the Committee agreed that the seven HACCP principles should be included in their entirety in view of their importance and since the Code was a stand-alone document. The Delegation of New Zealand proposed to delete the additional Step 13 concerning the Review of the HACCP Plan since it was part of Step 11 Establish Verification Procedure in the basic HACCP plan. The Delegation of the United Kingdom pointed out that an external review of the entire plan was required in practice, and this was different from the regular review of the different steps within the logical sequence. The Committee noted that the addition of a new step would entail a reconsideration of the current HACCP sequence in the General Principles of Food Hygiene, and such a change would require detailed consideration in the Committee on Food Hygiene.
58) After an exchange of views, the Committee agreed that a new section (5.3.11) would clarify that upon completion of all the steps a full review of HACCP and DAP plans should be conducted to verify that these plans achieved their expected objectives; this would also be reflected in the diagram, but not as a separate step.
59) In section 5.3, the Delegation of Finland indicated that in the case of aquaculture it would be preferable to refer to good aquaculture practice than to HACCP. The Committee noted that the question of pre-harvest conditions would be further considered and that hazard analysis could be conducted in the case of aquaculture.
60) As regards the identification of hazards, the Committee agreed that individual establishments should gather scientific and technical data 'where practical and feasible' and list all relevant potential hazards, as proposed by the Delegation of Thailand.
61) The Committee agreed that Table 5.2 referred to examples of hazards and the title was amended accordingly. Biological toxins were included in biological hazards, as previously agreed, and other amendments were made for clarification purposes. As regards pathogenic bacteria, the reference to the strain of E.coli was deleted and the other examples were retained.
62) In Table 5.4, it was noted that the second column should describe the nature of the hazard involved, and the presence of foreign material was included as a physical hazard in raw material.
63) Section 5.3.4 Significance of Hazards and Defects was reworded as proposed by the Delegation of the United States to determine the significance of hazards in relation to the severity of the adverse health effect and its probability and decide accordingly whether the application of HACCP was warranted.
64) Table 5.6 was amended to describe the hazard (Clostridium botulinum: viable spores), to specify that the product should be commercially sterile and that the control measures was 'to ensure adequate heat applied for proper time at retort'. A similar amendment was made to Table 5.8. Table 5.7 (example of defect) was reworded to indicate as a Justification that the product does not meet quality or customer requirements. In Table 5.9 some control measures were deleted since they were already covered in the pre-requisite programme.
65) In section 5.3.6 it was agreed that the effectiveness of critical limits related to controlling the hazard or defect 'to the determined level'. Section 5.3.9 was amended to clarify that verification activities should be carried out by competent personnel, and to include relevant examples. A reference to documentation was added to the title of section 5.3.10 on record keeping procedures.
66) In table 5.10, the checks of sterilization schedule were transferred to the Verification column (instead of Monitoring Procedure), and the 'Corrective Action' column was corrected to describe the personnel involved and its action. The Conclusion was amended, as proposed by the Delegation of New Zealand to reflect that the process, the objectives of the process, its environment and agreed outcomes should be assessed; and that the example illustrated how to apply the principles in terms of an agreed outcome.
Section 6. Processing of Fresh, Frozen and Minced Fish
Section 6.1 Finfish Preparation
67) In section 6.1.1 information about the harvesting area was added as one of the relevant characteristics in the 'technical guidance'. As regards Sensory Evaluation (6.1.1.1) a reference to the Guidelines for the Sensory Evaluation of Fish in Laboratories was included and it was agreed to replace 'evaluation charts' with 'evaluation criteria' used to evaluate the acceptability of fish. In Section 6.1.2 Chilled Storage, it was agreed that fish should be stored with ice or with a mixture of ice and water.
68) In section 6.3.1 the provisions concerning rejection of fish (7th bullet point) were deleted since this should have occurred before reaching this stage, and a similar amendment was made to section 6.3.2
69) Some additional amendments were made to section 6.4 Processing of Minced Fish (defects description) and to Section 6.5 Packaging Labels and Ingredients, for clarification purposes.
Section 13. Processing of Canned Fish and Shellfish
70) In section 13.1 Addition to the pre-Requisite Programme, the provisions concerning the devices used for handling containers (bullets one and three) were combined into a single paragraph, and 'retort controls' was replaced with 'steam controller valves'.
71) The section on Hazards was reorganized under biological hazards, chemical hazards and physical hazards. As regards Clostridium botulinum, inadequate container integrity was added to inadequate heat processing as one of the hazards to be considered. The physical hazards were identified as metal or glass fragments found in the containers.
72) In section 13.3.5.1 Fish Preparation, Clostridium botulinum was deleted from the list of hazards since it was not relevant at that stage and microbiological contamination and histamine were retained.
73) In section 13.4 Pre-Cooking and other treatments, it was specified that temperature abuse of scombrotoxic species should be avoided (at the end of 13.4.6.1). A reference to the Codex standards for fats and oils was included in square brackets in relation to the control of quality of Pre-Cooking Oils.
74) In section 13.4.7.1.Filling, its was agreed that 'a representative number of containers' should be inspected before filling, to clarify that such inspection was not systematic for all containers. Further requirements were added to section 13.4.3 Coding in order to prevent damage to the container in the coding operation.
75) In section 13.4.8 Handling of Containers after closure, the reference to a specific temperature was deleted and replaced with 'temperature conditions that minimize microbial growth'. In section 13.4.9.2 Heat Processing Operation, it was agreed that the process should be sufficient to provide commercial sterility to different sizes of cans, when they were processed together.
76) In section 13.4.10 Cooling, provisions for the prevention of contamination for heat processed canned fish and shellfish were transferred from section 13.4.12 (now 13.4.11) As regards monitoring the application of stability tests was left as optional.
General Conclusion
77) The Committee noted that due to time constraints it had not been possible to consider the section on Frozen Surimi, although it was also in an advanced stage. It was noted that some sections which had been added to the code more recently would need further elaboration and that the sections on Aquaculture and Molluscan Shellfish, which included pre-harvest requirements had not been discussed in detail so far.
78) The Committee expressed its appreciation for the considerable carried out by the Working Group and co-ordinating countries in the redrafting of the code since the last session, which had allowed for substantial progress at the session. In view of the progress made and the consensus reached on the sections considered, the Committee agreed that Sections 1, 2 (2.1, 2.2 and 2.9), 3 to 6 and 13 should be forwarded to the Commission for adoption at Step 5.
79) As regards the other sections, the Committee agreed that the Working Group composed of the co-ordinating countries would proceed with their revision, as follows: Netherlands (Molluscan Shellfish), Japan/USA (Frozen Surimi), Norway (Salted Fish), Denmark (Smoked Fish), Mexico (Shrimps and prawns), Brazil (Lobsters and Crabs), New Zealand (Cephalopods), Germany/USA (Frozen Coated products, FAO/WHO (Aquaculture).
80) In addition, the Delegations of France and the United States agreed to develop respectively the sections on Transportation and Retail, which required further elaboration. The Delegation of the United States asked for assistance from other countries, especially on activities such as auctioning and wholesaling. The Delegations of Thailand, Netherlands, Norway, Ireland offered to participate in the work on aquaculture, and the Delegations of Morocco and South Africa in the work on transportation. The lead countries, FAO and WHO invited all interested countries to provide their contribution to their respective work on the code.
81) The Committee agreed that the overall coordination would be ensured by the United Kingdom, France and Canada, as a Drafting Group that would consolidate the submissions from the co-ordinating countries and revise the remaining sections as required for consideration by the next session of the Committee.
Status of the Proposed Draft Code of Practice for Fish and Fishery Products
82) The Committee agreed to forward the Proposed Draft Code, sections 1, 2 (2.1, 2.2 and 2.9), 3 to 6 and 13 to the 24th Session of the Commission for adoption at Step 5 (see Appendix V), with the understanding that it would be forwarded to the Committee on Food Hygiene for endorsement. The other sections were returned to Step 3 for redrafting and further consideration by the next session.
