Section 4 — General Food Safety Operational Requirements 4.1 Hygiene and Sanitation

Reference Manual Section 4 — General Food Safety Operational Requirements 4.1 Hygiene and Sanitation

Introduction

Why is sanitation important? In one study reported by the FDA, sanitation deficiency data from 715 inspection reports (involving 561 facilities) was assessed between 1988–90. The facilities were deficient in the following areas [1]: ►► 23% of the receiving area facilities were not clean/orderly or in good repair ►► 26% of the facilities lacked effective insect and rodent control measures in the receiving area ►► 16% failed to handle ice in a sanitary manner and to protect it properly ►► 35% did not adequately clean or sanitize ►► 21% had processing equipment that was not constructed so that it was easily cleaned and sanitized ►► 18% of the processing equipment was not made from suitable materials ►► 15% had hand sanitizers that were not kept at proper concentrations ►► 18% failed to have hand sanitizers in the processing area ►► 33% had processing areas that were not maintained in a clean and sanitary manner ►► 42% had processing areas with exterior openings that were not sealed/covered properly to prevent the entrance of pests or insects ►► 16% had waste materials not being collected/covered in suitable containers or not being disposed of properly ►► 23% handled finished product in a manner that did not preclude contamination ►► 22% documented employees were not taking necessary precautions to avoid food contamination. Following this survey, the FDA mandated that the facilities focus on eight key areas as part of their sanitation and overall HACCP program [1], and most of these are directly linked to sanitation. 1. Water 2. Food contact surfaces 3. Cross-contamination 4. Hand washing and sanitizing and toilet facilities 5. Protection from adulteration 6. Labelling and storage of toxicants 7. Employee health 8. Exclusion of pests Overall, a written sanitation program should be present in the processing facility and according to the CFIA needs to include the following information [2]: 1. Procedures for equipment sanitation which specify step-by-step instructions for equipment to be cleaned and sanitized, including: • person(s) or position(s) responsible;

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-111 Provincial Fish Inspection • identification of equipment and utensils; • disassemble/reassemble instructions when required for cleaning, disinfecting, lubrication, and inspection; • methods of cleaning, disinfecting, and rinsing; • chemicals and concentrations used; • time and temperature requirements for cleaning and disinfecting; • lubricants used where applicable; and • frequencies for cleaning and sanitizing. 2. Procedures for establishment sanitation which specify step-by-step instructions for premises, processing, and storage areas to be cleaned and sanitized, including: • person(s) or position(s) responsible; • identification of premises, processing, and storage areas; • methods of cleaning, disinfecting, and rinsing; • chemicals and concentrations used; • time and temperature requirements for cleaning and disinfecting; • frequencies for cleaning and sanitizing; and • methods to prevent the contamination of food or packaging materials during, or subsequent to, cleaning and sanitizing. 3. The identification of acceptable cleaning and sanitizing equipment and its intended use. 4. The identification of acceptable cleaning chemicals and/or compounds, their intended use,and instructions for proper application.

Cleaning After Processing Cleaning should occur daily in a fish processing plant, after the hours of operation. Essentially cleaning is a 5-step procedure: 1. Remove debris (excess organic materials) 2. Wash with detergent 3. Rinse with clean water 4. Sanitize 5. Rinse with clean water

Basic steps 1. All large debris is removed with a brush or a scraper [3] 2. The whole area, including food contact surfaces and utensils, should be washed with clean water and the appropriate detergent. 3. Rinse with clean water of adequate pressure (minimum 20lb/in2) 4. Sanitize the surface. 5. Rinse with clean water of adequate pressure (minimum 20lb/in2)

2nd Edition: January 2012 Food Protection Services 4-112 Environmental Health Services Reference Manual Table 7 — Types of detergents, their respective applications and disadvantages [3]

Detergent Type Application Disadvantages • Removing scale • Extremely corrosive (PPE Acidic • Removing dirt required) • Removing oil • Foams in high pressure Neutral • Removing grease equipment • Removing fats Alkaline • Dissolving proteins • Avoid prolonged contact with skin • Softening water • Removing stubborn fats Caustic • Removing dried protein • Extremely corrosive • Removing tar • Do not use on soft surfaces such • Scouring hardened residues Abrasive as plastics

For a listing of cleaning and disinfecting products that are acceptable (by CFIA) for use in food processing establishments, refer to the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products database [4]. http://www.inspection.gc.ca/english/fssa/reference/refere. shtml

Sanitizers Sanitizers function as agents that can significantly reduce the level of harmful bacteria. An ideal sanitizer would be: ►► non-toxic ►► quick acting ►► broad spectrum ►► non-corrosive ►► easy to use ►► affordable ►► approved / authorized with a registered DIN number ►► on the list of approved non-food chemical products CFIA site Generally, the premise operator should be using a sanitizer appropriate to kill Staphylococcus aureus, Salmonella spp., Listeria monocytogenes and E.coli (coliforms). The label claims of the sanitizer usually state what organisms they are effective against. The premise operator should be using the recommended concentration and contact time for the sanitizer in use on the premise. When choosing which type of sanitizer to use the following considerations must be made: • Where is the product going to be used • How is the product going to be applied • What surfaces will the product be applied to • What agents are you trying to control • Economic issues • Volume to be used • Special requirements/limitations

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-113 Provincial Fish Inspection Table 8 — Types of sanitizers

Sanitizer Advantages Disadvantages • Most common • Can be corrosive • Fast acting • Can be hazardous Chlorine Compounds • Broad Spectrum • Affected by organic matter • Inexpensive • Affected by pH • Does not foam • By-products • Expensive • Non-corrosive • Not as effective against certain Quaternary Ammonium • Broad spectrum spoilage organisms (Quats) • Not as affected by organic matter • Foams • Can be expensive • Less corrosive than chlorine • Can foam • Broad spectrum • Stains Iodine • Not as affected by organic matter • Affected by pH • acidified • Affected by temperature • Non-corrosive • Can be expensive • Broad spectrum • Needs to be activated Chlorine Dioxide • Fast acting • Odor • Not as affected by organic matter • Requires mixing equipment • Does not foam • Can be affected by temperature • Can be expensive • Not effective against certain types • Broad spectrum of mold and yeast • Not as affected by organic matter Peroxyacetic Acid • Corrosive • Does not foam • Odor • Can be difficult to titrate • Broad spectrum • Limited effectiveness Acid Sanitizers • Not as affected by organic matter • Can foam • Inexpensive • Affected by pH and temperature

Operators must have a sanitation plan that includes monitoring and measuring the concentration of the sanitizer in use to ensure that enough sanitizer is being used to eliminate microbiological hazards from food contact (and non-food contact) surfaces [5] [6] [7]. Sanitation plans (also known as SSOPs —sanitation standard operating procedures) should always includes checklists, monitoring and verification to ensure sanitation is being followed [7].

Cleaning and Hygiene during Processing During fish processing, there should be sanitary measures in place to ensure fish do notbecome contaminated. For example, the flow of traffic, both human and equipment, needs to be from ready to eat food products to raw food products. Color coding of clothing, maintenance, and other equipment should also be present to distinguish between raw and finished products [5] [6]. Iodine foot baths near the door-ways and entrances of new rooms should also be present to remove dirt and debris from shoes. Soap foam on the floors of entrance ways should also be present to remove debris from the wheels of carts, fork lifts, and other equipment. All staff need to be appropriately dressed when working in the processing plant. Hair should be tied back, away from the face, and hair nets should be worn. Lab coats (coveralls preferred) should also be worn by both staff and visitors when inside the plant. Shoes need to be covered with clean and sanitized shoe-covers or rubber boots designated for plant use only (NOT worn outside). If gloves are being used they must be clean and sanitary. Finally, no tobacco, gum, food or jewelry should be present in places handling or processing fish.

2nd Edition: January 2012 Food Protection Services 4-114 Environmental Health Services Reference Manual A hand-washing unit should be present at the entrance of every processing area in a factory. The sink needs to have hot running water and pedal operated taps or motion sensing taps. Furthermore, liquid or foam soap should be present alongside hot air hand driers or single use paper towels. If paper towels are used a garbage bin needs to be available. Finally, automatic hand sanitizer dispensers should also be present.

Clean Water for Fish Processing As outlined in the earlier sections, it is essential during the processing and handling of fish to have an adequate supply of clean/fresh water. Over 90% of the bacteria residing on the surface of fish can be removed through proper washing with clean water. All water should be filtered and chlorinated to prevent pathogenic bacteria from being introduced to the flesh. The water that is in direct contact with the flesh should have the same quality and intensity of chlorination as drinking water (0.1-0.3ppm up to a maximum of 5ppm residual chlorine), and be from an approved source preferably in accordance with the BC Drinking Water Protection Regulation BC Reg 200/2003 [8] or meet the BC Fish Inspection Regulations Schedule A.0.1 [9] (total coliform count of not more than 2 per 100 millilitres).

Clean Water for Sanitation Water that is used for general washing of the premise may have a higher residual chlorine level of 20- 30ppm. Furthermore, for best results the water temperature for washing the premise should be between 48-66°C (120-150°F) [10].

Personal Hygiene In addition, the personal hygiene of employees is also an important factor in maintaining cleanliness [5] [6]. Overall, the personal hygiene of staff needs to be mandatory with adequate washing facilities present including hot water, soap, brushes, and paper towels. Proper hand-washing techniques should be followed: ►► Before starting work ►► After handling contaminated materials ►► After using the lavatory Additional requirements that must be followed include: • no staff should be working in the fish processing area if they are suffering from gastro-intestinal illnesses that can easily be transmitted through food • employees with open cuts, boils, and lesions that can carry pathogenic staphylococci, and other microoganisms, should be wearing the appropriate water-proof dressings and rubber gloves • fingernails should always be kept short and clean • to reduce contamination, outdoor clothing should not be worn within the processing area. All staff should be provided with clean overalls, hats/hair-nets, boots, and rubber gloves • correct number of toilet facilities present: According to Table 3.7.2.2.C. of the British Columbia Building Code (see Appendix 4.1A) [11], there are minimum requirements for the number of water closets in an industrial occupancy for each sex. It is important to note that these values are the minimum requirements and additional conditions may be added by either the building inspector or by the health authorities. The Fish Inspection Regulation Schedule A Part 1 and Schedule B also outlines general requirements for the toilet facilities [9].

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-115 Provincial Fish Inspection

Number of Number of Toilets People at Work 1-10 1 11-25 2 26-50 3 51-75 4 76-100 5 6 plus 1 for each additional increment of 30 Over 100 persons of each sex in excess of 100

Furthermore, the BC Building Code 3.7.2.3 states that at least one lavatory shall be provided in a room containing one or 2 water closets or urinals, and at least one additional lavatory shall be provided for each additional 2 water closets or urinals.

Handling The type of handling the fish are exposed to during preparation stages will also effect the quality of the final product. Overall, fish should be kept in boxes or small containers and not be piled on floor, thrown on the ground, or walked over. To avoid physical damage, bruised flesh, the fish need to be handled with care and kept clean. Direct sunlight should be avoided and fish should be stored at chill temperatures. Cut fish have an increased likelihood of post contamination, through dirty tools/equipment, compared to whole fish and therefore need to be handled with extra care.

Storage Food storage facilities need to be designed to allow for: ►► No pest access and harborage ►► Easy cleaning and maintenance ►► Protection against contamination of food ►► Minimal deterioration of food Furthermore, separate storage areas are made for raw and processed products and for chemicals. All items in a storage facility need to be properly labeled.

Pest Control Insects, birds, and vermin should be absent from the premise, especially the processing room. No trees, gardens, cultivated areas etc. should be present near the fish facility as they provide shelter and habitats. Domestic animals should also be excluded from the processing area and the site.

Note the legislative requirements for information provided in this section is outlined in the Fish Inspection Regulation Schedule A and B. For a detailed breakdown please consult Appendix 2.4A

2nd Edition: January 2012 Food Protection Services 4-116 Environmental Health Services Reference Manual Appendix 4.1A — Building Code

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-117 Provincial Fish Inspection

2nd Edition: January 2012 Food Protection Services 4-118 Environmental Health Services Reference Manual 4.2 Labelling and Packaging Labelling of domestic and imported fish and fish products

Labeling of domestic and imported fish and fish products is regulated by: • Food and Drugs Act/Food and Drug Regulations [12] [13]. • Consumer Packaging and Labeling Act/Consumer Packaging and Labeling Regulations [14] [15]. • Fish Inspection Act/Fish Inspection Regulations (federal and provincial) [1] [16] [17] [18]

What is the minimum information needed under the BC Fish Inspection Act/Regulation for processed fish products? The basic requirements are the same as the federal regulations. Product Label must contain • Name of product • Weight of product • Name and address of person (business) either doing the processing, or for whom the product was processed or who is distributing the product • Ingredients (if any) • “Keep Frozen Prior to Use” – in the same font size as the Name of the Product • Lot or batch number • Recommend a “Best Before” or “Use By” date A useful guide to give to operators is located on the BCCDC web-site called “Guideline for labeling and packaging requirements for smoked fish with reference to Federal regulations and Provincial regulations” [19]. According to the Fish Inspection Regulations (FIR) all labels need to be appropriately describing the product without relaying false, misleading, or deceptive information to the consumer. The specific labelling requirements are dependent on the type of fish product.

In summary: I. If fish was packaged to exclude air and was smoked, liquid smoked, or had liquid smoke flavor concentrate added and • contains less than 9% salt • has not been heat processed after sealing for a time and temperature to destroy all spores of Clostridium botulinum • is not cooked prior to use

The package needs the statement “Keep frozen prior to use” added onto the label in a letter size equal to the letters used in the common name.

This does not apply to oxygen permeable packaging.

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-119 Provincial Fish Inspection II. If seafood is pre-packaged fresh or previously frozen at retail and with a life of 90 days or less then it should be labeled with the following: • the “packaged on” date • the durable life of the food on a poster next to the food or on the label of the product OR a “best before date” • instructions for storing the food if the food has storage requirements that are different from normal room temperature III. If seafood products were previously frozen and are now thawed then they need to labeled “previously frozen.” This labeling should be: • near the name of the product in a letter size equivalent to that used for the common name • or in letters that are 6.4mm (1/4inch) high and anywhere on the label • or in a legible display sign Fish products that have some heat treatment and are still not RTE but may be perceived to be by consumers need to have the following information provided on their labels: • the product is not ready-to-eat • cooking instructions and the statement that the product needs to be cooked prior to serving • for frozen products, the cooking instructions should show proper heat treatment from the frozen stage • statements for proper storage conditions and the durable life The Food and Drugs Act [12], has made nutritional labeling mandatory for most prepackaged foods since December 12, 2007 [20] [21]. However, raw, single ingredient marine or freshwater animal products (such as fish, crustaceans, etc.) are exempt from a nutritional facts table (B.01.401(2)). According to (B.01.101(3)), this exemption is lost and a Nutritional Facts label is required if: • a vitamin or mineral nutrient is added to the product • a vitamin or mineral nutrient is declared as a component of an ingredient (other than flour) • aspartame, sucralose, or acesulfame-potassium is added to the product • the label or advertisement contains one or more of the following: o a nutritional reference or nutrient content claim o a biological role claim o a health claim o a health-related name, statement, logo, symbol, seal of approval or other proprietary mark of a third party; or o the phrase “nutritional facts’, “valeur nutritive” or “valeurs nutritives” Fish that are manufactured to resemble other seafood, kamaboko products, need to be correctly labeled. In other words, a kamaboko product that resembles shrimp cannot be labeled as “shrimp.” The common name of kamaboko products need to be descriptive. For example, “Imitation Shrimp” is an effective label. Finally, if a kamaboko product is used as an ingredient for a food product then the final food product must state this usage [22].

2nd Edition: January 2012 Food Protection Services 4-120 Environmental Health Services Reference Manual Section 28.1 of the FIR states for canned fish that 28 (1) In the case of canned fish, every can of fish or the wrapper or label thereon shall be correctly and legibly marked in English or French, in addition to any other language, to indicate (a) the common name of the fish, (b) in the case of fish other than shellfish and crustaceans, the net weight of the contents, (c) in the case of shellfish and crustaceans, the drained weight of the contents, (d) the name and address of the person by whom or for whom the fish is processed or by whom it is distributed, and (e) the ingredients in each can, where there is more than one ingredient therein, (i) by listing them in descending order of their proportion in the can, or (ii) by stating the proportion of each ingredient in the can. (2) The information required pursuant to subsection (1) shall be shown in such a manner that (a) the common name of the fish and the stated weight thereof appear on the main body or face of the can or on the main panel of the label thereon, (b) the common name of the fish is shown in letters of equal height and prominence and indicates whether the product has been prepared (i) by mincing, flaking or other special process, (ii) from selected parts of fish, or (iii) for dietetic use, and (c) the printing used to indicate the weight of fish is not less than 1/8 inch in height. (3) Where descriptive terms are used in addition to the wording required by subsection (1), such terms shall be printed in letters not less than 1/2 the height of the letters used for the common name of the fish. For non-canned fish, however, the requirements are different as stated by section 29 of theFIR. Specifically, this section states:

29 (1) In the case of fish, other than canned fish, every container or the label thereon shall be correctly and legibly marked in English or French, in addition to any other language, to indicate (a) the common name of the fish, (b) the net weight of the fish, unless (i) in the case of oyster and clam meats that are not frozen, the container or label is marked with a statement of net contents in terms of fluid measure or by count, (ii) in the case of oysters that are marketed in the shell, the container or label is marked with a statement of the contents in terms of bushels or pecks or by count, or (iii) in any case not referred to in subparagraph (i) or (ii), the container or label states that the contents are to be weighed at the time of retail sale, (c) the grade, size, class, count and moisture content (i) in the case of pickled fish, with the grade, class and size of the fish, (ii) in the case of boneless or semiboneless salted fish, with the grade of the fish, (iii) in the case of bloaters, with the grade and count of the fish, (iv) in the case of bloater fillets, with the grade of the fish, and (v) in the case of salted fish, other than boneless or semiboneless salted fish, with the grade and class of the fish, the size or count of the fish and the designation for moisture content,

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-121 Provincial Fish Inspection (d) the name and address of the person by whom or for whom the fish is processed or by whom it is distributed, and (e) the ingredients in each container, where there is more than one ingredient therein, (i) by listing them in descending order of their proportion in the container, or (ii) by stating the proportion of each ingredient in the container. (2) In the case of oysters and clams that are marketed shucked or in the shell, each container shall meet the requirements of subsection (1) (d) and (e) and section 52. (3) The markings referred to in subsection (1) (a) to (e) shall be shown on the main panel of every container of fish and shall be not less than 1/8 inch in height. (4) Cartons and cases are exempt from subsection (1) (b) to (e) where they contain containers of fish that are marked in accordance with subsections (1), (2) and (3).

Fisheries and Oceans Requirements for Labeling, Packaging and Transporting Catch There are specific requirements for personal catch transport of fish and shellfish. This is in part to protect against personal catch fisheries illegally entering the retail market. The regulation covering this is federal Fishery (General) Regulations [23] Section 36. It provides guidelines on how to cut fish, and label packages (including sport-caught fish) for transport before it reaches the residence of the fisherman[33] . For further details consult the DFO web-site.

Canadian Regulations for Packaging Smoked Fish Oxygen Permeable Packaging Oxygen permeable packaging is packaging that allows oxygen to penetrate the type of packaging used (e.g. 1.5ml thick polyethylene), at a rate acceptable for fishery products. The packaging should allow enough oxygen to enter to allow aerobic spoilage organisms to grow before C.botulinum toxin can be produced [27]. Canadian parameters for oxygen permeable packaging are shown in Table 9. See Section 3.7 Appendix D.5 for details on regulations as it relates to smoked product. The regulations include Food and Drugs Act Regulation B21.025 for packaging smoked fish and the Packaging Industry Bulletin, 1993 [12] [24] (http://www.inspection.gc.ca/english/fssa/labeti/retdet/bulletins/smofume.shtml) summarized in the table below.

Table 9 — Smoked Fish Packaging Requirements

Parameter Requirement 2,000 cc/m2/24 hours at 24°C and Oxygen permeability 1 atmosphere Temperature 4°C (40°F) or less Shelf-life Maximum 14 days

Modified Atmospheric Packaging (MAP) Modified atmospheric packaging, MAP, is a commonly used packing technique that involves modifying the composition of the internal atmosphere of a food package. Typically, the modification process replaces some of the oxygen present inside the package with carbon dioxide and nitrogen. The proportion of each component gas is fixed initially when the mixture is introduced, but no further control is done during storage, and consequently, the composition of the mixture may slowly change over time.

2nd Edition: January 2012 Food Protection Services 4-122 Environmental Health Services Reference Manual Modified atmospheric packaging is often incorrectly referred to as controlled atmospheric packaging, CAP [25] . CAP is packing of product in an atmosphere with a composition that is continuously controlled throughout storage. This type of packing is common in large storage units but not in small packs [25] [26].

Gas Mixture Carbon dioxide slows down bacterial spoilage of fish and is used to replace most of the oxygen present inside a package during MAP. However, too high a proportion of carbon dioxide may induce pack collapse, excessive drip and an acidic flavor [25] [26]. Oxygen is still present in the package and prevents color changes and bleaching from taking place in the product. Nitrogen, an inert gas, is used to dilute the mixture. Depending on the species of fish, the following mixtures are recommended [3] [25]:

Table 10 — Modified Atmosphere Packing Gas Mixture Recommendations

Species of Fish Carbon Dioxide Nitrogen Oxygen white fish, shrimp, scampi, 40% 30% 30% scallops salmon , trout, herring, mackerel, 60% 40% 0% smoked fish products

Smoked salmon that is packed in this mixture can show green discoloration during storage. The amount of greening is dependent on the strength of the smoke cure. The mixture recommended for white fish should be used where greening is likely to occur .

Equipment and Materials It is important to use only those packaging films that have low gas permeability to avoid having the original composition of the package change. Polyethylene gives a poor oxygen barrier while a mixture of polyester and polythene or nylon and polythene provides a better barrier. Using a polyvinylidene chloride coating can greatly enhance the ability of the barrier [3]. The gases can be obtained pre-mixed or need to be placed into the machines individually and are mixed by the equipment at later stages. If the gases are mixed by the equipment there needs to be regular monitoring of the gas composition in the packs. Measurements of the gas composition should take place at the beginning of a run and continue throughout the day especially when changes are made to the gas mixture. There are three main types of MAP systems [26]. One is a snorkel-type system where a tube/pipe is extended into the package to draw a vacuum inside the package. The tube will then inject the appropriate composition of gases into the package and then retract for the package to be sealed. The second type of MAP system is a chamber-type machine. In this system, the whole package is put into the chamber and a vacuum is created. To break the vacuum the gas mixture is used. Finally, the package is sealed before being removed from the chamber. The final MAP system creates a vacuum that is later filled with gas by heat sealing two plastic film webs around the product [26].

Advantages of Modified Atmospheric Packaging [25] There are several advantages associated with MAP: • Reduces growth of spoilage causing microorganisms increasing shelf life • Reduces occurrence of oxidative reactions, increasing shelf life • Odorless • Easy to label and convenient to handle • Leak-proof and Robust

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-123 Provincial Fish Inspection Disadvantages of Modified Atmospheric Packaging [25] • Walls of package may collapse when the enclosed atmosphere contains a high proportion of carbon dioxide which is highly soluble in fish tissue. When the carbon dioxide dissolves, a partial vacuum is created and the pack may collapse onto the product. A correct mixture of gasses will prevent this from occurring. • Drip may form inside the pack when a high proportion of carbon dioxide is used. Choosing the right gas mixture and using an absorbent paper pad under the fish can reduce this problem. • Chilled storage is still required with MAP. The packaging must be kept close to 0°C (32°F) throughout distribution and storage if the full benefits of MAP are to be maintained. • Storage of MAP products at temperatures above 4°C (40°F) can result in potential Clostridium botulinum hazards.

Clostridium botulinum Modified atmospheric packaging of fish involves the removal of oxygen and its replacement by carbon dioxide and nitrogen resulting in anaerobic conditions. This anaerobic environment may allow for the growth of Clostridium botulinum. Furthermore, C. botulinum can grow at temperatures below 3°C (37°F) and does not significantly alter the sensory properties of the fish. There is also concern thatcarbon dioxide promotes the germination of C. botulinum spores. These factors increase the potential of food poisoning that can lead to fatalities [27].

In reduced oxygen packaged products in which the spores of C. botulinum are partially inhibited or destroyed by a heating process (e.g. in smoked fish, pasteurized crabmeat, pasteurized surimi), normal refrigeration temperatures of 4°C (40°F) are appropriate because they will limit the growth of C. botulinum and other pathogens that may be present [27] [28].

In reduced oxygen packaged products in which refrigeration is the sole barrier to outgrowth of C. botulinum and the spores have not been destroyed (e.g. vacuum packaged raw fish, unpasteurized crayfish meat), the temperature must be maintained at 3.3°C (38°F) or below from packing to consumption [27] [28].

Fish Quality To see a significant increase in shelf life, the fish used for modified atmospheric packaging need to be of high quality [25]. Fish that are of poor quality will not experience the same increase in shelf life. As a result, fish undergoing MAP should be visually examined and free from bruises and parasites.

Packaging the Fish Fish need to be kept chilled from time of harvest/capture to when they are packed. Whole fish and fillets need to be kept in ice while they await packaging while smoked products need to be kept in a chill room set at 0°C (32°F). Table 11 — Effect of packaging on the shelf life of chilled fish and meat products[29]

Storage Shelf life (weeks) Type of product temp. Air VPa MAPb Meat (beef, pork, poultry) 1.0 - 4.4°C 1 - 3 1 - 12 3 - 21 Lean fish (cod, pollock, rockfish, trevally) 0.0 - 4.0°C 1 - 2 1 - 2 1 - 3 Fatty fish (herring, salmon, trout) 0.0 - 4.0°C 1 - 2 1 - 2 1 - 3 Shellfish (crabs, scampi, scallops) 0.0 - 4.0°C ½ - 2 - ½ - 3 Warmwater fish (sheepshead, swordfish, tilapia) 2.0 - 4.0°C ½ - 2 - 2 - 4 a VP: Vacuum packed b MAP: Modified atmosphere packed (High CO2 concentrations (25 - 100%)

2nd Edition: January 2012 Food Protection Services 4-124 Environmental Health Services Reference Manual Products should not be layered in a package because it will expose certain layers more to the gas mixture than other layers. As a result, not all products within the package will gain the full benefits of MAP. An absorbent paper should be placed inside the package under wet fish products that are likely to release drip [25]. Packages that are not properly sealed can be detected by pressing down on the pack. Faulty packs will collapse [25].

Fish also need to be handled hygienically throughout processing. Handlers should try not to bruise, cut, or puncture the fish. Handlers should also be practicing good hand washing techniques to prevent any unnecessary contamination from occurring [25].

Storage Life of MAP How long a fish product packaged with modified atmospheric packaging will last is dependent on: • species of fish used • initial quality and fat content of the fish • nature of the finished product • gas mixture used during MAP • storage temperature Temperature All modified atmospheric packages should be stored at a temperature near 0°C (32°F). The storage temperatures should never exceed 5°C (41°F). As the temperature rises from 5°C (41°F) the advantages associated with modified atmospheric packaging decrease. However, the storage life of mackerel, salmon, herring, trout and smoked fish products does not increase with a modified atmosphere at 0°C (32°F).

Vacuum Packaging Vacuum packaging, like MAP, extends the shelf life of the product. Vacuum packaging involves the removal of air from a package by using high gas barrier packaging films like polyester or polyvinylidene chloride [3]. The increase in shelf life is due to the removal of oxygen. The three main benefits from removing oxygen include: • reductions in aerobic bacterial spoilage • reduction in fat oxidation • reductions in rancidity Similar to MAP, due to the creation of an anaerobic environment, the growth of Clostridium botulinum is of concern in vacuum packaged foods. The growth of C. botulinum is more likely to occur if the package is exposed to temperatures above 3°C (37.4°F). Consequently, temperature regulations are important in controlling this pathogen. Proper handling and hygiene practices while preparing vacuum packaged foods is another control measure for preventing C. botulinum outbreaks [27]. Cryovac Cryovac packaging is a form of vacuum packaging that is taken up the fish industry. This packaging is based on drawing out air from the pack so that spoilage reactions can be reduced and the shelf life of the product can be enhanced. This type of packaging can also involve heat shrinking the wrapping around the product. Either way, anaerobic conditions are created to slow the rate of spoilage and increase the shelf life of the product. Following packaging the products need to be stored frozen.

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-125 Provincial Fish Inspection Comparing Modified Atmospheric Packaging and Vacuum Packaging Although both modified atmospheric packaging and vacuum packaging are effective at enhancing the shelf life of products, MAP is shown to be a better packaging technique as detailed in the results below:

Table 12 — Days to sensory spoilage and onset of toxicity in fresh salmon fillets inoculated with C. botulinum type E (100 spores/g of fish), packaged under selected atmospheres, and stored at various temperatures. [27] Storage Sensory Spoilage Toxin Detection Atmospheres Temp. (ºC) (days) (days) 100% air 4 4 16 Modified 5-6 4 Vacuum 3 3 100% air 13-17 17 8 Modified 20-24 24 Vacuum >6, <10 10 100% air 24-27 >66 4 Modified 55-62 >80 Vacuum 34-38 >66

Freezing Frozen fish will undergo dehydration resulting in undesirable freezer burn and a reduction in the shelf life of the product. Proper packaging material, with the correct water vapor barrier protection, will prevent freezer burn from occurring. The water vapor barrier is an impermeable membrane that blocks air flow and ultimately the water vapor that is in the air. By allowing water vapor to remain inside the package, moisture is not lost to the environment, and freezer burn does not occur. As a result, having the appropriate packaging material is important for products that are to be stored frozen. Packaging types can be divided into two broad categories [30]: 1. single-layer films 2. multiple-layer films (laminate) where the films are bonded together Polyethylene film or copolymer of ethylene and vinyl acetate plastic polymers are often used for packing of frozen products [30]. The FDA guidelines for fish processing parameters are sorted by packaging type. This perspective is given in Appendix 4.2A [27].

2nd Edition: January 2012 Food Protection Services 4-126 Environmental Health Services Reference Manual Appendix 4.2A — FDA Guidelines [28]

Refrigerated, reduced oxygen packaged smoked and smoke-flavored fish: • For cold-smoked fish, the smoker temperature must not exceed 90°F (32.2°C). • For hot-smoked fish, the internal temperature of the fish must be maintained at or above145°F (62.8°C) throughout the fish for at least 30 minutes. • Smoked fish must have not less than 3.5 percent water phase salt, or, where permitted, the combination of 3.0 percent water phase salt and not less than 100 ppm nitrite.

Nitrite is not allowed in Canada

• Strict refrigeration control (i.e., at or below 40°F [4.4°C]) during storage and distribution must be maintained to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F and other pathogens that may be present.

Refrigerated, reduced oxygen packaged, pasteurized fishery products, which are pasteurized in the final container: • Strict refrigeration control (i.e., at or below 40°F [4.4°C]) must be maintained during storage and distribution to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F, and because of the potential survival through the pasteurization process and recovery of spores of nonproteolytic C. botulinum aided by naturally occurring substances, such as lysozyme.

Refrigerated, reduced oxygen packaged, pasteurized fishery products, which are hot filled into the final container: • Product temperature must be 185°F (85°C) or higher as the product enters the final container. • Containers must be sealed according to the container or sealing machine manufacturer’s seal guidelines. • There must be a measurable residual of chlorine, or other approved water treatment chemical, at the discharge point of the container cooling tank; or the processor must follow the equipment manufacturer’s UV light intensity and flow rate guidelines. • Strict refrigeration control (i.e., at or below 40°F [4.4°C]) must be maintained during storage and distribution to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F, and because of the potential survival through the pasteurization process and recovery of spores of nonproteolytic C. botulinum aided by naturally occurring substances, such as lysozyme.

Refrigerated, reduced oxygen packaged “pickled” fish, caviar, and similar products: • Growth and toxin formation by C. botulinum type E and nonproteolytic types B and F must be controlled by either: o Adding sufficient salt to produce a water phase salt level of at least 5 percent; o Adding sufficient acid to reduce the acidity (pH) to 5.0 or below; o Reducing the amount of moisture that is available for growth (water activity) to below 0.97; or o Making a combination of salt, pH, and/or water activity adjustments that, when combined, prevent the growth of C. botulinum type E and nonproteolytic types B and F.

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-127 Provincial Fish Inspection • Processors should ordinarily restrict brining and pickling loads to single species and to fish portions of approximately uniform size. This minimizes the complexity of controlling the operation. • Strict refrigeration control (i.e., at or below 40°F [4.4°C]) must be maintained during storage and distribution to prevent growth and toxin formation by C. botulinum type A and proteolytic types B and F.

Refrigerated, reduced oxygen packaged raw, unpreserved fish and unpasteurized, cooked fishery products: • For refrigerated, reduced oxygen packaged raw, unpreserved fish (e.g. vacuum packaged fresh fish fillets) and unpasteurized, cooked fishery products (e.g. vacuum packaged, unpasteurized crabmeat, lobster meat, or crayfish meat), the sole barrier to toxin formation by C. botulinum type E and nonproteolytic types B and F during finished product storage and distribution is refrigeration. These types of C. botulinum will grow at temperatures as low as 38°F (3.3C). As was previously stated, maintenance of temperatures at or below 38°F (3.3°C) after the product leaves the processor’s control cannot normally be ensured. Time temperature integrators on each consumer package may be an appropriate means of providing such control.

Frozen, reduced oxygen packaged fishery products: • If your product is immediately frozen after processing, maintained frozen throughout distribution, and labeled to be held frozen and to be thawed under refrigeration immediately before use (e.g. “Important, keep frozen until used, thaw under refrigeration immediately before use”), then formation of C. botulinum toxin may not be a significant hazard.

Unrefrigerated (shelf-stable), reduced oxygen packaged fishery products: • Spores of Clostridium botulinum types A, B, E and F must be destroyed after the product is placed in the finished product container or a barrier, or combination of barriers, must be in place that will prevent growth and toxin formation by Clostridium botulinum types A, B, E and F, and other pathogens that may be present in the product. Suitable barriers include: o Sufficient salt is added to produce a water phase salt level (the concentration of salt in the water-portion of the fish flesh) of at least 20 percent (Note: this value is based on the maximum salt level for growth of S. aureus.) o Sufficient salt is added to reduce the water activity to 0.85 or below; o Sufficient acid is added to reduce the pH to 4.6 or below; The product is dried sufficiently to reduce the water activity to 0.85 or below (Note: this value is based on the minimum water activity for growth and toxin formation of S. aureus).

2nd Edition: January 2012 Food Protection Services 4-128 Environmental Health Services Reference Manual 4.3 Process Controls and Sampling Verification The process controls used in the prepartion of fish products will vary depending on the type of RTE fish being produced, on the products’ inherent and final (post-processing) food attributes (such as the pH,

Aw, WPS) and on the packaging and storage conditions chosen for retail to the consumer. Pathogen hazards must be controlled by the process, including the storage temperature of the RTE product, the type of packaging and how the product is cooked, pasteurized, salted, pickled, dried or left raw before consumption, as illustrated (for reduced oxygen packaging) in the table below [28].

Table 13 — Summary of Fish Product Process Requirements in Reduced Oxygen Packaging Fish WPS pH A Storage Temperature Cooking product w pasteurized at 85°C (185°F) for Surimi 2.4% <4°C at least 15 minutes pasteurized at 90°C (194°F) for Surimi <4°C at least 10 minutes Cooked (hot-smoke) > 63°C Smoked Fish 3.5% <4°C (145°F) for at least 30 minutes Smoked Fish 3.5% <3.3°C smoking temp usually <37°C (cold) Pickled Fish 5.0% <5.0 <0.97 <4°C Pickled or 20.0% <4.6 <0.85 Room temperature Salted Fish Raw Fisha <4°C Raw Fisha <-18°C a ie. unpasteurized crab, fish etc.

An overview of CFIA’s process controls are show in Table 14 [31]. They divide up minimal requirements for processing based on the type of process applied to the food. One of the guidelines are copied in part below, for further details visit the web-site [32]:

Information Expected to be Included in the Process Control Documents for Ready-to-eat Cooked Foods: 1. A description of the steps prior to cooking. 2. A description of the cooking step, which must include: ○○ the type of cooking equipment ○○ the time and temperature of the heating medium if the cold spot temperature is not measured directly ○○ the time and temperature process reached at the cold spot of the product; this may be expressed as an F value with the stated target organism, reference temperature and z value. The minimum cooking process must result in a 5 log reduction of Listeria monocytogenes where: D value at 65°C = 1.18 minutes and z value = 6.7°C ○○ reduce the chance of product contamination (eg sanitary practices during filling; chlorinated cooling water). ○○ prevent spore growth during cooling (eg cooled quickly; cooled under critical limits for time and temperature)

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-129 Provincial Fish Inspection 3. A description of storage. Note: there are critical limits to prevent the growth of spore and non-spore forming pathogenic microorganisms during product shelf life. The critical limits for different product types are as follows: A.1 The product is frozen and labelled "Keep Frozen" A.2 The product is refrigerated with a short shelf life: ○○ it is labelled with a shelf life of 14 days or less and ○○ labelled "Keep Refrigerated" and if the Fish is Smoked ○○ the oxygen permeability of the packaging is equal to or greater than 2000 cc/m2/24 hrs at 24°C and 1 atmosphere A.3 The product is refrigerated, with a long shelf life: ○○ it is labelled "Keep Refrigerated" and ○○ the critical limits of the safety parameters to prevent the growth of Listeria monocytogenes and are maintained to the end of the product's stated shelf life as follows:

»» Aw < 0.92, regardless of pH or

»» pH < 5.0 regardless of Aw plus prevent yeast and mold growth or »» pH 5.0 to 5.5 and Aw < 0.95 plus prevent yeast and mold growth ○○ If pH is used as a safety parameter, measures are described to ensure the pH does not rise during the shelf life of the product due to yeast and mold growth. Options: »» hot fill at 85°C (Reference: from Chapter 18 of the USFDA's Fish and Fisheries Products Hazards and Controls Guidance or »» preservatives with supporting scientific information

Sampling Verification during Inspection During inspection sampling verification might include any of the following activities: ○○ checking bivalves or crabs to assess if they are alive in live tank holding systems ○○ checking sanitizer concentration with test strip ○○ measuring the specific gravity of the salt brine solution ○○ checking temperature of the coolers and brining solutions ○○ testing the final food product for indicators (ie. E. coli) or for pathogens (ie. Listeria) ○○ testing environmental swabs for for indicators (ie. E. coli) or for pathogens (ie. Listeria) These activities are recommended to provide objective evidence and as a means of assessment of problems and verification of process controls in the plant.

2nd Edition: January 2012 Food Protection Services 4-130 Environmental Health Services Reference Manual Table 14 — CFIA Process Control and Testing Requirements

2nd Edition: January 2012 Food Protection Services Environmental Health Services 4-131 Provincial Fish Inspection References

[1] Ward, D., HACCP in the fisheries industry, in Safety and Quality Issues in Fish Processing. 2009, CRC Press.

[2] Canadian Food Inspection Agency. Guidelines for the development of a sanitation program. 2002 [cited 2009 April 24]; Available from: http://www.inspection.gc.ca/english/fssa/fispoi/man/fimmii/chap3_4_be.shtml.

[3] Clucas, I. and A. Ward, Post-Harvest Fisheries Development: A Guide to Handling, Preservation, Processing and Quality. 1996, Kent ME4 4TB, UK: Natural Resources Institute, Chatham Maritime.

[4] Canadian Food Inspection Agency. Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products. 2009 [cited 2010 March 10]; Available from: http://www.inspection.gc.ca/english/fssa/reference/refere.shtml.

[5] Codex Alimentarius. Recommended International Code of Practice for Smoked Fish. CAC/RCP 25- 1979 [cited 2009 April 19]; Available from: www.codexalimentarius.net/download/standards/123/CXP_025e.pdf.

[6] Food and Agriculture Organization of the United Nations, Guidelines for risk-based fish inspection. FAO Food and Nutrition Paper 90. 2009, Rome: FAO.

[7] Food and Drug Administration, Fish & Fisheries Products Hazards & Controls Guides. 1998, US Food and Drug Administration: Rockville, MD.

[8] Government of British Columbia. Drinking Water Protection Regulation B.C. Reg. 200/2003. Available from: http://www.bclaws.ca/EPLibraries/bclaws_new/document/ID/freeside/10_200_2003.

[9] Government of British Columbia. Fish Inspection Act FISH INSPECTION REGULATIONS (B.C. Reg. 12/78). Available from: http://www.qp.gov.bc.ca/statreg/reg/F/FishInsp/12_78.htm.

[10] Canadian Food Inspection Agency, Fish School. 2007.

[11] Ministry of Forests and Range and Minister Responsible for Housing, British Columbia Building Code 2006. 2006.

[12] Department of Justice Canada. Food and Drugs Act (R.S., 1985, c. F-27). Available from: http://laws.justice.gc.ca/en/F-27.

[13] Department of Justice Canada. Food and Drugs Regulation (C.R.C., c. 870). Available from: http://laws.justice.gc.ca/en/F-27/C.R.C.-c.870/.

[14] Department of Justice Canada. Consumer Packaging and Labelling Act (R.S., 1985, c. C-38). Available from: http://laws.justice.gc.ca/eng/C-38/index.html.

[15] Department of Justice Canada. Consumer Packaging and Labelling Regulations (C.R.C., c. 417). Available from: http://laws.justice.gc.ca/eng/C.R.C.-c.417/index.html.

[16] Department of Justice Canada. Fish Inspection Act (R.S., 1985, c. F-12). Available from: http://laws.justice.gc.ca/eng/F-12/index.html.

[17] Department of Justice Canada. Fish Inspection Regulations (C.R.C., c. 802). Available from: http://laws.justice.gc.ca/eng/C.R.C.-c.802/index.html.

2nd Edition: January 2012 Food Protection Services 4-132 Environmental Health Services Reference Manual

[18] Government of British Columbia. Fish Inspection Act [RSBC 1996] CHAPTER 148. Available from: http://www.qp.gov.bc.ca/statreg/stat/F/96148_01.htm.

[19] BC Centre for Disease Control, Guideline for labeling and packaging requirements for smoked fish with reference to Federal regulations and Provincial regulations, Food Protection Services, Editor. 2009: Vancouver, BC.

[20] Canadian Food Inspection Agency. Guide to Food Labelling and Advertising. Chapter 5: Nutritional Labelling. 2008 [cited 2009 May 7]; Available from: http://www.inspection.gc.ca/english/fssa/labeti/guide/ch5e.shtml.

[21] Canadian Food Inspection Agency. Guide to Food Labelling and Advertising. Chapter 15: Fish and Fish Products. 2008 [cited 2009 May 7]; Available from: http://www.inspection.gc.ca/english/fssa/labeti/guide/ch15e.shtml.

[22] Canadian Food Inspection Agency. Retail Food Information Bulletin. Seafood Labelling. 2006 [cited 2009 May 7]; Available from: http://www.inspection.gc.ca/english/fssa/labeti/retdet/bulletins/seamere.shtml.

[23] Department of Justice Canada. Fishery (General) Regulations (SOR/93-53). Available from: http://laws.justice.gc.ca/eng/SOR-93-53/index.html.

[24] Canadian Food Inspection Agency. Smoked Fish Storage Conditions. Industry Bulletin. 1993 [cited 2010 March 10]; Available from: http://www.inspection.gc.ca/english/fssa/labeti/retdet/bulletins/smofume.shtml.

[25] Cann, D.C. Packing Fish in a Modified Atmosphere. TORRY ADVISORY NOTE No. 88 [cited 2009 May 6]; Available from: http://www.fao.org/wairdocs/tan/x5956e/x5956e00.HTM.

[26] Wheaton, F.W. and T.B. Lawson, Processing Aquatic Food Products. 1985, New York: John Wiley & Sons.

[27] Seafood Network Information Center: Sea Grant Extension Program. Chapter 8: Vacuum and Modified Atmosphere Packaged Fish and Fishery Products. 2007 [cited 2009 May 6]; Available from: http://seafood.ucdavis.edu/haccp/compendium/chapt08.htm#Vacuum%20packaging%20processes.

[28] Food and Drug Administration. Fish and Fisheries Products Hazards and Controls Guidance. 2001 [cited 2010 March 10]; 3rd ed:[Available from: http://www.fda.gov/Food/GuidanceComplianceRegulatoryInformation/GuidanceDocuments/ Seafood/FishandFisheriesProductsHazardsandControlsGuide/default.htm.

[29] Huss, H.H., FAO FISHERIES TECHNICAL PAPER - 348. Quality and quality changes in fresh fish. 1995.

[30] Bykowski, P. and D. Dutkiewicz. Freshwater Fish Processing and Equipment in Small Plants. FAO Fisheries Circular No. 905 FIIU/C905 1996 [cited 2009 May 6]; Available from: http://www.fao.org/wairdocs/tan/x5956e/x5956e00.HTM.

[31] Canadian Food Inspection Agency. Process control and product testing requirements by product safety categories. 2009 [cited 2010 May 21]; Available from: http://www.inspection.gc.ca/english/fssa/fispoi/import/pol/image433e.jpg.

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[32] Canadian Food Inspection Agency. Appendix D - Examples of the Process Control Document Requirements for Different Product /Process Combinations. 2009 [cited 2010 May 21]; Available from: http://www.inspection.gc.ca/english/fssa/fispoi/import/pol/conte.shtml#appd.

[33] Fisheries and Oceans Canada. Packaging and Transporting Your Catch. 2009 [cited 2009 May 6]; Available from: http://www.pac.dfo-mpo.gc.ca/fm-gp/rec/points/packaging-emballage-eng.htm.

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