A.

INTRODUCTION
HACCP (Hazard Analysis Critical Control Point) is the systematic preventative approach to food safety.It addresses physical, chemical, and biological hazards as a means of prevention rather than finished product inspection.This approach has significant benefits to organisations operating within the food supply chain as it enables them to determine key controls over processes and concentrate resources on activities that are critical to ensuring safe food. The information, tables, and other materials in this generic HACCP plan for Hot Smoked Fish represent only one possible way to write a HACCP plan. It should be used only for illustrative purposes. Each processor is obligated by law to write a flow diagram specific to their own facility and conduct a hazard analysis for their own processes and products. The primary purpose of this generic plan is to illustrate how a firm might simplify record keeping by writing a single plan, which could include several similar smoked fish products having different brining and smoking procedures. According to law, certain HACCP functions must be performed by someone who has completed training equivalent to the HACCP Training Curriculum developed by The National Seafood HACCP Alliance for Training and Education. These functions include developing the plan, changing the plan, and conducting record review. This training may be obtained through classroom instruction or by equivalent on-the-job training. This generic HACCP plan for hot smoked fish is based on the principles detailed in that manual and in guidance contained in the FDA's Fish & Fisheries Products Hazards & Controls Guide, First Edition, September 1996. Seafood processors also should be aware that FDA's HACCP regulation (Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products; Final Rule, December 18, 1995) requires that they monitor and keep records on their sanitation procedures. This is best done by writing and implementing an SSOP (Sanitation Standard Operating Procedure).

B.PREREQUISITE PROGRAMS
1. PRELIMINARY STUDIES
1.1Sanitation Issues As with any food product, proper worker hygiene, raw ingredient handling and storage procedures, and the final product handling and storage procedures are essential to control product contamination by organisms that are harmful to humans. Raw ingredients are typically inspected prior to entering the hot smoking fish production facility/area. However, the manufacturer should not assume that these ingredients are free of pathogenic organisms. The manufacturer must ensure that raw ingredients are properly stored in refrigerated areas to minimize the opportunities for growth of pathogens. Workers handling these raw materials must not also handle completed hot smoking fish products, since cross contamination can occur. Equipment and facilities should be designed to prevent cross contamination between raw and cooked products. And, of course, hot smoking fish production workers should follow the standard hygienic procedures that are required for all food production workers. Hot smoking fish production equipments must be maintained in a clean and sanitary condition, under conditions that minimize the potential for growth of pathogens. And finally, the final products must be handled and stored according to acceptable standards to minimize the opportunities for cross contamination and spoilage. The same key sanitation principles outlined in the Seafood HACCP requirement can be utilized for retail hot smoking fish production: 1.2.Safety of water Water must be potable. Private wells or sources must be certified. 1.3.Condition and cleanliness of food contact surfaces The portions of this area that should be monitored daily are cleaning and sanitizing of equipment, utensils, gloves, and outer garments that come in contact with food, and the condition of gloves and outer garments.

1.4.Prevention of cross-contamination The issues in the area of cross-contamination that should be monitored are employee practices and physical separation of raw and cooked products. 1.5.Maintenance of hand-washing, hand-sanitizing, and toilet facilities The issues that should be monitored are the concentration of hand-sanitizing solutions and that the toilet facilities are in good repair. 1.6.Protection from adulterants and toxic compounds Food must be protected from contaminants such as condensation, floor splash, glass, and toxic chemicals. 1.7.Employee health conditions Employee health conditions must be monitored daily. 1.8.Pest control Pests must be excluded from food handling areas. 1.9.Proper Labelling,Use,and Storage of Potentially Hazardous Chemicals
Potentially hazardous chemicals used in factory include pesticides, cleaners, sanitizers, disinfectants, fuels, coolants, paints, and solvents. All chemicals must be labeled, used according to the manufacturers instructions, and stored in a safe manner so that chemical contamination of hot smoking fish is prevented. All relevant government regulations relating to the application, use, or holding of these products should be carefully followed.

1.10.Tracebility and Recall Processing

If a food borne disease outbreak occurs, traceability procedures are useful for determining the source and distribution of suspected products. A trace-back and recall program can, therefore, protect individual growers and the seafood industry by limiting an investigation to a specific region, packing facility.

2.PRODUCT CHRACTERISTICS
Table 1. Product Description and intended use
Product Specifications Name of product Description Product Hot smoking fish Refrigerated, vacuumpackaged, cooked ready-to-eat smoked fish (no mercurycontaining species used ) Smoked fish are bright and glossy. There is no dried blood or mold on the product. Stored and transported under refrigeration Packaged smoked fish storage for years without refrigeration and when package is opened it is stored in fridge Ready to eat by general public without further cooking Vacuum packaging, MAP packaging and skin packaging Public, food industry 0.89-0.99 4.1-8.4 Lot number, weight, name of receiver, name of seller, date number Salt (0.1-6.8g salt/100g product) Label Sample

Customer Specifications Conditions of storage Shelf life Intended use Packaging Target consumer Water activity pH Label information Additives

3.HACCP TEAM AND RESPONSIBILITIES

Table 2. HACCP Team
Team Member . . Department Hazard Analysis & CCP Analysis Hygiene & Sanitation Responsibilities Hazard analyses of processing and determine the critical control points. Control hygiene and sanitation of plant and personnel. Controlling the process and corrective results. Verification & Documentation Preparing all the documents according to the monito

Monitoring

ed results.

4. PROCESSING
RECEIVING

FROZEN FISH STORAGE

THAWING

THAWED FISH STORAGE BUTCHERING RINSING( BRINE MAKEUP)

BRINING

RINSING

SMOKING/DRYING/ COOKING/COOLING (INTEGRATED STEPS) COOLING (FINAL)

PACKAGING/LABEL ING

STORAGE SHIPPING

Receiving (non-scombroid fish) Fish headed, gutted, frozen and glazed in 50 lb. Boxes.Salt on wood pallets into dry storage. Frozen fish storage On pallets in -10F cold store until needed. Thawing Partially thawed in mobile tubs with fresh flowing water at less than 70F the day proceeding smoking operations. Thawed fish storage In raw product cold room at 40F or less in mobile tubs. Fish must be still partially frozen at time of butchering. Butchering Remove sides manually leaving skin on. Cut into pieces for brining. Processing takes place in an air-conditioned area. Rinsing (brine makeup) Fish rinsed in fresh water at less than 70F to remove debris.Brine makeup in cold water and stored in raw product cold room (less than 40F) until needed. Brining In a specified strength of salt brine for a specified time. These are relatively strong brines and short times. This hazard analysis assumes short brining times in strong salt solutions. If long brining times in weak solutions are used, the hazard analysis should consider the possibility of a biological hazard (pathogen growth and/or histamine formation), resulting in a critical control point at this brining step. Rinsing In fresh water at less than 70F to remove surface brine. Smoking/Drying/Cooking/Cooling (integrated steps) To surface dry, apply smoke, dehydrate, cook, and cool enough to remove excess heat prior to final cooling. Product goes into cooler immediately upon removing from cooker. Cooling (final) In a special unpackaged final product cooler at 38F or less which is isolated from other raw or processed products.

Packaging/labeling In vacuum packages then into 20 lb. master cartons Storage In cartons on pallets in finished product cooler at 38F or less. Shipping In refrigerated vans at 38F or less (commercial carrier).

5.PLANT LAYOUT

Shipping

P R O D U C T Packaging Cooling

S T O R A G E
R A W M A T E R I A L S T O R A G E

Smoking

Rinsing

Brining

Rinsing Quality Butchering Frozen Fish Storage Lab.

Thawing

Thawed fish storage

O t o p a r k

Administer

Fitting room Security WC

Main entrance

Electricity supplier Infirmary

Mainta nance holl Natural gas station

C.HACCP STUDY
Table 3. Hazard analysis for hot smoking fish production
Cause analysis* Process name/step Process descriptions Potential Hazards Pathogen inclusion, mercury, parasites, metal None Pathogen growth and adulteration Pathogen growth Pathogen growth Pathogen growth None pathogen growth during smoking and in final product None pathogen growth on surface during smoking/drying/ cooking pathogen growth in final product pathogen growth in final product pathogen growth during cooling, cross contamination pathogen growth in temperature abused product Causes (Sources and reasons) R,E Hazard Analysis (Y/N)*** Significant Hazard

Prerequisite Q1 Q2 Q3 Q4 Q5 programs**

Fish (nonscombrotoxin) Salt Storage Thawing Thawed fish storage Butchering Rinsing

Receiving nonscombrotoxin forming fish Receiving salt Frozen fish storage Partly thawed in cool water Thawed fish is storage Removal of fish bone Washed with water Prepared salt concentration Washed with water Smoking is applied

P;6,7

Y -

R E E,M,R R P,M M

P;6 P;7,8 P;5,6 P;5,6,7,8 P;10 P;5,6

Y Y

Y Y Y -

Y Y Y -

N N N N N N

Y Y Y N Y Y Y N -

Y Y

Brining

R,M

P;5,6

Rinsing

P;5,6

Smoking /initial

P;5,6,7

Y N

Smoking/ drying

Smoking and drying operations are done Smoking and cooking operations are done Cooling treatment is applied Packaging of hot smoking fish

P;5,7

Y Y

Smoking/ cooking

P;5,6

Y Y

Cooling Packaging/ labeling

P;5,7,8

Y Y

M,P,E

P;5,7,8

Y Y

Storage Shipping

Hot smoked fish are stored Final products are shipped

pathogen growth pathogen growth

R,E E

P;7,8 P;5,7

Y Y Y N

Y -

N -

Y N

* Cause and effect analyses (Figure 1.)

** Prerequisite programs (Table 1.)

*** Hazard analysis (Figure 2.)

Table 4. Risk assesment and CCPs in the processing of hot smoking fish
Process name/step Significant Hazard
Pathogen growth during smoking and in final product Pathogen growth in final product

Risk analysis* Severity

C

Probability
3

Risk class
3

CCP analysis (Y/N)** Preventive actions/control measures Q Q Q Q CCP 1. 2. 3. 4. no:

minimum brine strength and times as per process schedule minimum smoke-house cycle time as per process schedule Y Y 1

Brining

Smoking/ drying

Y Y -

Smoking/ cooking

Pathogen growth in final product

minimum final cook time/center temp as per process schedule

Y Y -

Cooling

Pathogen growth during cooling

maximum cooler temperature

Y N YN

Packacaging/la beling

pathogen growth in temperature abused product

all products labeled "keep at 38F or less"

Y N Y N

Storage of finished product

Pathogen growth

38F or less

Y N Y N

* Risk analysis (Table 9)

** CCP analysis (Figure 3.)

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Table 5. HACCP plan for the processing of hot smoking fish

Monitoring CC P No: Process name/step Significant hazard Pathogen growth during smoking and in final product Pathogen growth in final product Pathogen growth in final product Pathogen growth during cooling Pathogen growth in temperature abused product Pathogen growth Critical limits Record Method Frequency Responsible production log Corrective action

Brining

Enumeration

Each brining batch (lot)

Safety control manager

Rebrine or hold for evaluation Reprocess or hold for evaluation

Smoking/dr ying

Enumeration

Each batch

Safety control manager

production log and recorder charts production log and recorder charts production log and temp recorder charts

Smoking/co oking

Enumeration

Each batch

Safety control manager

Reprocess or hold for evaluation Hold for evaluation/ adjust cooler temp

Cooling

Enumeration

Continuous

Safety control manager

Packaging/l abeling

Enumeration

Each lot

Safety control manager

production log production logs/ recorder charts

Relabel Hold for evaluation/ adjust cold room temp

Storage of finished product

Enumeration

Continuous

Safety control manager

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D.DISCUSSION
The overall purpose of this report is to evaluate the published and unpublished data concerning likely hazards of public health concern derived from the consumption of hotsmoked fish. The application of the Hazard Analysis and Critical Control Point (HACCP) principles to the processing of domestically produced and imported fishery products. Although HACCP, with its focus on science, holds great promise for minimizing the risk of foodborne disease, the application of HACCP principles to foods and food processes such as hot-smoked fish is challenging. Specifically, to provide an in-depth review of pathogens that might be found in hot-smoked fish products, to identify processing parameters that may contribute to pathogen growth, and to review options available to eliminate or inhibit foodborne pathogens in smoked fish products. A review of the safety of current fish harvesting and handling practices as well as an evaluation of packaging options and their influence on survival or growth of the organisms of concern.To address these issues, the report begins by describing the situation with regard to the safety of consuming cold-smoked fish. Focusing attention on cold-smoked finfish, the panel reviewed the most significant and likely to occur hazards in cold-smoked product Listeria monocytogenes, Clostridium botulinum, human parasites, and biogenic amines. For each hazard, the report evaluates the effectiveness of methods for eliminating or preventing contamination in the processing environment, identifies possible control points for each step in the process, and, where there is scientific evidence, offers processing parameters that would control the hazard. Based on these findings, the panel offers information for reducing the risk of hazard in hot-smoked fish products. The report also identifies research needs for further investigating control methods for the hazards reviewed in this report. The microbiological hazards exist at various points, but measures can be taken to control these hazards. The anticipation of hazards and the identification of control points are therefore key elements in HACCP. The system offers a rational and logical approach to control (microbiological) food hazards and avoid the many weaknesses inherent in the inspectional approach. Once established, the main effort of the quality assurance will be directed towards the Critical Control Points (CCPs) and away from endless final product testing. This will assure a much higher degree of safety at less cost.

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REFERENCES en.wikipedia.org/wiki/Smoked_fish www.fao.org/wairdocs/tan/.../x5953e01.ht http://www.mexican-barbecue-recipes.com/smoked-fish.html http://www.fishingmag.co.nz/smoker.htm http://bbq.about.com/cs/fish/a/aa030400a.htm

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APPENDICES Tabel 7. Prerequisite programs

Prerequisite programmes 1-construction and lay-out of buildings and associated utilities 2-lay-out of premises, including workspace and employee facilities 3-supplies of air, water, energy and other utilities 4-supporting services, including waste and sewage disposal 5-the suitability of equipment and its accessibility for cleaning, maintenance and preventative maintenance 6-management of purchased materials (e.g. raw materials, ingredients, chemicals and packaging), and supplies 7-measures for the prevention of cross contamination 8-cleaning and sanitizing 9-pest control 10-personnel hygiene

Table 8. Five-class hazard scoring matrix Risk Classes Catastro Death or lasting damage phic Many concerned people and lasting or Critical continuous damages Serious Many concerned people, no lasting damages Single case, no lasting damages or minimal Low concentration Hazard to be discovered prior to consumption Ignorable or minimal indisposition Control measures 1. No measure necessary. 2. Periodic measures are measures which often cover a one-time activity. 3. General control measures, such as proper hygiene facilities, procedures for cleaning and disinfection personal hygiene instructions and maintenance, vermin control, maintenance and calibration, purchasing procedures and raw material specifications, complaint handling and recall procedures, etc. (of course, many of them are prerequisite programs) 4. Specific control measures are specifically developed and used to control the risk. E D C B A 3 3 2 2 1 I (< per 1 years)Unlikely 4 3 3 2 2 II 4 4 3 3 2 III (per semester)Occasional 4 4 4 3 3 IV 4 4 4 4 3 V (per week)Very frequent 14

Severity

Probability

(per month)Frequent

(per year)Rare

Risk classes

Figure 1. Cause and effect analysis (Fish bone diagram).

(ILSI, 2004) (*Not a hazard to be controlled at this step, **Reduction step thus becomes a CCP) Figure 2. Hazard determination

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Figure 3. Critical control point decision tree.

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