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7 PREREQUISITES TO HACCP (Hans Henrik Huss/John Ryder)

Hygiene standards and procedures usually described as Good Hygienic Practices (GHP) or Good Manufacturing Practices (GMP), have been in place for many years and constituted an essential tool in traditional food control. These concepts are still essential in a modern food control system by providing the basic environmental and operating conditions for production of safe food and thus being a requisite or foundation for HACCP in an overall food safety management programme (Figure 7.1). What is new is the concept of formalising the prerequisite programme alongside HACCP and the legal requirement in some countries (USA) of documented monitoring of certain sanitation areas.

Figure 7.1 Food Safety and quality, an integrated approach (from Jouve, 1998).

In the Code of Federal Regulation (FDA, 2001) it is outlined what is covered by current GMP regulations. These include basically all procedures and practices necessary to produce safe foods.

Good Manufacturing Practices (GMP)

Those procedures for a particular manufacturing operation which practitioners of, and experts in, that operation consider to be the best available using current knowledge

There is no clear definition of the term Good Hygienic Practices (GHP). However, "food hygiene" has been defined by Codex (CAC, 2001) as "all conditions and measures necessary to ensure the safety and suitability of food at all stages of the food chain" and GHP can therefore be regarded as:

Good Hygienic Practices (GHP)

all practices regarding the conditions and measures necessary to ensure the safety and suitability of food at all stages of the food chain

The terms GMP and GHP therefore basically cover the same ground and for the purpose of this book, the term GHP will mainly be used.

Various definitions of GHP or prerequisite programmes have been proposed by national and international organizations as shown:

Prerequisite programme = Good Hygienic Practices (GHP)

Prior to the application of HACCP to any sector of the food chain that sector should be operating according to the Codex General Principles of Food Hygiene, the appropriate Codex Codes of Practices, and appropriate food safety legislation (CAC, 2001)

Practices and conditions needed prior to and during the implementation of HACCP and which are essential for food safety (WHO, 1999)

Procedures, including GMP that address operational conditions providing the foundation for the HACCP system (NACMCF, 1998)

According to the Draft Revision of the Recommended International Code of Practice for Fish and Fishery Products (CAC, 2000), the following aspects should be included in the prerequisite programme:

An example of the common prerequisite programme is given in an appendix to the publication by NACMCF (1998). Additional to the points listed by Codex it includes: Supplier control, specifications for all ingredients, chemical control and conditions for receiving, storage and shipping of raw materials and products. In the present publication some of these additional points, i.e. supplier control and specifications of ingredients, will be included in the HACCP plan and not in the prerequisite programme.

According to the US-FDA's seafood HACCP regulation (FDA, 1995), processors are required to have key sanitary conditions written into Sanitation Standard Operating Procedures (SSOPs). As outlined, SSOP are equivalent to GHP.

SSOP - Sanitation Standard Operating Procedures

the documented GMP for hygiene and sanitation required to meet the regulatory requirements for food control in the USA

They are also required to monitor these conditions and practices, correct unsanitary conditions and practices in a timely manner and maintain sanitation control records. Thus the sanitation control procedures are an integrated part of the seafood HACCP regulations, but not of the HACCP-programme. The SSOP should address at least the following conditions and practices:

The written SSOP plan should explain the sanitation concerns, controls, in-plant procedures and monitoring requirements. This will demonstrate commitment to buyers and inspectors and also ensure that everyone from management to production workers understands the basics of sanitation.

In the European Union (EU, the prerequisite requirements are included in both 'horizontal' legislation such as the Hygiene Directive (EC, 1993) and 'vertical' or commodity-specific legislation such as the Directive specifying the requirement for fish processing (EC, 1991).

Many activities can be considered part of a prerequisite programme depending on the product and the actual processing conditions. For this reason, it is unlikely that two processing facilities have identical prerequisite programmes.

Although definitions of prerequisites and/or SSOPs refer mostly to operational conditions, there are also basic requirements to the processing plant and the processing environment. Thus the SSOPs are specifying the quality of the water, maintenance of hygiene facilities etc., but it is equally important that the plant has access to enough water and hygiene facilities (quantitative aspects). Below is a list of key points and activities that need to be addressed in any prerequisite programme:

The Processing Plant:

Operational conditions and procedures (GHP):

A proper and well designed prerequisite programme allows the HACCP team to focus and concentrate on the hazards directly applicable to the product and the processing procedures without undue considerations and repetition of protection from hazards from the surrounding environment. It is important to point out that the prerequisite programme certainly relates to safety and therefore is an essential part of the total quality assurance programme. Thus part of the prerequisite programme (e.g. sanitation controls) must lend itself to all aspects of a Critical Control Point (CCP) such as establishing critical limits, monitoring, corrective actions, record keeping and verification procedures. However, occasional deviation from a prerequisite programme requirement would not by itself be expected to create a food safety hazard of concern. Therefore deviations from compliance in a prerequisite programme usually do not result in reaction against the product. This is in contrast to a CCP, where any deviation from the established critical limits always leads to reaction against the product.

The prerequisite programme is a good starting point for companies who have a long way to go to implement a HACCP system. Practical experience has shown that if the general issues related to the prerequisite programme are dealt with first, the HACCP study will be much more straightforward and the resulting HACCP plan easier to manage. All issues related to GMP, hygiene and the environment will be dealt with in the prerequisite programme and only truly 'critical' control points, essential to safety of the product will be included in the HACCP plan.

7.1 The processing plant

7.1.1 Plant location, physical environment and infrastructure

Early considerations in building a new plant are the identification of a suitable location. A number of factors should be considered such as physical and geographical factors and infrastructure available.

Some of the physical needs for a plant location is a plot of adequate size (for present needs and future developments), with easy access by road, rail or water. An adequate supply of potable water and energy must be available throughout the year at a reasonable cost. Special considerations must be given to waste disposal. The plant should have proper sanitary sewers. Seafood processing plants usually contain significant amounts of organic matter which must be removed before waste water is discharged into rivers or the sea. Also solid waste handling needs careful planning, and suitable space - away from the plant - must be allocated or be available.

Assessment of pollution risk from adjacent areas must also be considered. Contaminants such as smoke, dust, ash, foul odours (e.g. neighbouring fish meal plant using poor raw material) are obvious, but even bacteria may have to be considered as airborne contaminants (e.g. proximity of a poultry rearing plant upwind may be a source of Salmonella spp).

The immediate physical surroundings of a seafood factory should be landscaped and present attractive appearance to the visitor (or potential buyer of products). However, this should be done in a way that rodents and birds are not attracted. Shrubbery should be at least 10 m away from buildings and a grass free strip covered with a layer of gravel or concrete should follow the outer wall of buildings. This allows for thorough inspection of walls and control of rodents. Ground immediately in front of doors and entrances should be paved to minimize dust. All areas around the plant and facilities should be well drained to prevent any standing water, where flies and microorganisms could breed and develop.

Figure 7.2
Surroundings of seafood processing plants should be clean and well kept (courtesy of Royal Greenland).


7.1.2 Buildings, construction and layout

A food processing plant shall provide (quoted from Troller, 1993):

External walls, roofs, doors and windows should be water-, insect- and rodent-proof. Internal walls, on the other hand, should be smooth, flat, resistant to wear and corrosion, impervious, easily cleanable and white or light coloured. Also the floors should ideally be impervious to spillage of product, water and disinfectants, durable to impact, resistant to disinfectants and chemicals used, slip resistant, non-toxic, non-tainting and of good appearance and easy repairable. Floors should be provided with a slope to drains to prevent formation of puddles. All openings (doors, windows, skylights, ventilators) must be adequately screened or otherwise constructed and fitted so as to prevent the entrance of any pests (flies or rodents).

Lighting should be adequate to carry out plant operations and protected so that broken glass will not be a potential hazard.

Proper ventilation is basic to good food plant sanitation. This will control condensation and help to eliminate any mould growth. Intake air should be filtered and positive air pressure maintained in the finished product area. The technical requirements, choice of materials, costs, etc. to obtain these goals may be found in a number of publications such as Shapton and Shapton (1991), Imholte (1984), Troller (1993).

The general layout and arrangement of rooms within a processing establishment is important in order to minimise the risk of contamination of the final product. A large number of bacteria (pathogens and spoilage bacteria) enter with the raw material. To avoid cross contamination it is therefore essential that raw material is received in a separate area and stored in a separate chill room. From here the sequence of processing operations should be as direct as possible - and a "straight line" process flow is regarded as most efficient (Hayes, 1992). This layout minimises the risk of recontamination of a semi-processed product.

Clear physical (e.g. a wall) segregation between "clean" and "unclean" areas is of prime importance. "Unclean" areas are those where raw material is handled and often a cleaning operation (wash) or for example a heat treatment (cooking of shrimp) is marking the point, where the process flow goes from "unclean" to "clean" areas. Thus a "clean" area is defined:

Clean area

An area where any contaminant added to the product will carry over to the final product (ICMSF, 1988)

i.e. there is no subsequent processing step that will reduce or destroy contaminating microbes.

Also cooled rooms must be separated from hot rooms where cooking, smoking, retorting etc. are taking place. Dry rooms must be separated from wet rooms and separate rooms must be provided for waste material, chemicals (cleaning and disinfection compounds, insecticides, all toxic materials), packaging materials and wood (for smoking).

The separation between the clean and unclean areas must be complete. There should be no human traffic between these areas, and equipment and utensils used in the unclean areas should never be used in the clean area. This means that there should also be separate wash and hygiene facilities for equipment and personnel in these areas. For easy identification the personnel should wear different coloured protective clothing for different operations (e.g. white in the clean and blue in the unclean).

Equally important in layout and design of food factories is to ensure that there are no interruptions and no "dead ends" in the product flow, where semiprocessed material can accumulate and remain for a long time at ambient temperature. Time/temperature conditions for products during processing are extremely important critical control points (CCPs) in order to prevent bacterial growth. This means that a steady and uninterrupted flow of all products is necessary in order to have full control of this critical factor. If any delays in product flow are necessary, the products should be kept chilled.

In addition, to facilitate product flow the factory layout and practices should ensure that:

Some of the principal requirements to an ideal establishment are outlined in Figure 7.3.

7.1.3 Facilities

Essential facilities in a seafood processing plant are:

Necessary hand-washing facilities must be located at the entrance to the processing areas and in all processing areas where GHP require employees to wash and disinfect their hands. They must be equipped with hand-cleaning and effective disinfection preparations and single use towels or other suitable hand-drying devices. Adequate and readily accessible toilet facilities must be available, properly located (no direct access to processing areas) and maintained in a hygienic condition and good repair.

Figure 7.3. Example of a simplified factory layout (drawing by V. Popescu).

7.1.4 Utensils and equipment

A great variety of utensils and equipment is used in the fish industry. There is an abundance of advice and regulations available concerning the requirements for equipment. All of them agree that the food equipment should be non-contaminating and easy to clean. In particular, all food contact surfaces (utensils, knives, tables, cutting boards, boxes and containers, conveyer belts, gloves, aprons etc.) must be designed and of such material as to be easily cleanable. Such surfaces shall be constructed of non-toxic, non-absorbent material that is resistant to the environment, the food, cleaning and disinfecting agents. Food contact materials that should be avoided are: wood, ferrous metals, brass and galvanised metals. However, the degree of stringency in hygienic requirements must be related to the product being processed. Raw fish, for example, do not require the same standard of hygiene as cooked and peeled shrimp. Criteria for hygienic design are particularly important for equipment used in the later stages of processing and particularly after a bacteria-eliminating processing step. There are seven basic principles for hygienic design agreed upon by a working party appointed by the Food Manufacturers Federation (FMF) and Food Machinery Association FMA (FMF/FMA, 1967) as quoted by Hayes (1992):

In the design and construction of equipment it is important to avoid dead areas where food can be trapped and bacterial growth takes place. Also dead ends (e.g. thermometer pockets, unused pipe work, T-pieces) must be avoided, and any piece of equipment must be designed so that the product flow is always following the "first in first out" principle

Cleanability of equipment involves a number of factors such as construction materials, accessibility and design. The most common design faults which cause poor cleanability are (Shapton and Shapton, 1991):

One general problem of food processing involves the extremes of temperature, abundant use of water, development of condensations and contamination of food from overhead pipes and surfaces. Equipment design must consider this and include proper protection.

Equipment design is one of the major problems in modern food hygiene. A great number of new machines and equipment are designed and constructed without proper attention to the fact that these tools have to be cleaned and sanitised. The EC (1992) addresses machinery safety and hygiene regulations. Some of the highlights are:

The directive also sets out a certification system where machinery is checked for compliance and tagged with an EC mark if found to be satisfactory. Certification is not retrospective and manufacturers have two years to bring new machinery into compliance.

Apart from literature already cited, additional useful material and information on hygienic design are found in Milledge (1981) and Gould (1994).

A great variability exists in the size, of and extent of handling in, fish processing establishments. Accordingly, the hygienic requirements in, and the design of, fish handling areas may vary considerably. Quite obviously the requirements that a small establishment which is only repacking fish in ice and catering for a local market, must meet are different from the hygienic requirements of a large establishment that is processing a variety of sophisticated products including heat treated and composite products and exporting to countries all over the world. Also the requirements commonly listed in legislation and codes of practice are not equally important. The more important factors include: facilities for water supply, waste disposal and cooling and cold storage facilities and -capacity. Of less importance are buildings, ventilation, factory location, clothes changing facilities, lightning and roadways (ICMSF, 1988).

The forms shown in Appendix 1 have been utilized in assessing fish factories using the HACCP principles. Only the most important factors are evaluated and given a rating from A to C, where A and B are expressions of degrees of excellence and niceties, while a rating of C is given to a condition which is unacceptable and needs immediate correction before further operations can take place. Thus it is an attempt to "distinguish between the nice and the necessary" which is the same approach as applied in the HACCP principles.

7.2 Operational conditions including GHP

A range of operational conditions must be in place prior to the implementation of HACCP in order to control the risks or safety concerns related to the environment and the personnel. The existence and the performance of such a programme must be well documented with written procedures, assigned responsibilities, measurable acceptance criteria, defined record keeping activities and procedures to be followed when acceptance criteria are not met. A written standard format as shown below using 5 of the 7 HACCP principles is useful as a guideline or checklist and to ensure that all essential points have been considered.

Standard format

· Criteria
what is required
· Monitoring
what, how, when and who
· Corrective actions
if something goes wrong
· Records
physical evidence
· Verification
check that it works

Figure 7.4 Standard format in assessing the prerequisite programme.

7.2.1 Safety of water and ice

Criteria for potable water

Water is used in food processing both as an ingredient and for cleaning and sanitation. Thus the quality of the water is of great importance. WHO (1993) and EC (1998) have published extensive guidelines on drinking water quality where standards for more than 60 parameters have been elaborated. The microbiological criteria suggested are shown in Tables 7.1 and 7.2.

Very often water needs to go through some form of treatment and disinfection before being suitable for use in food processing.

Water treatment

Water treatments vary from region to region depending on the water sources available. While groundwater from sedimentary aquifers has undergone extensive filtration the water from hard rock aquifers or surface water sources should be filtered as part of the water treatment in order to decrease the content of particulates, microorganisms, organic and inorganic matter.

Table 7.1 Bacteriological quality of drinking water (WHO, 1996)1.


Guideline value

All water intended for drinking

E. coli or thermotolerant coliform bacteria2,3

Not detectable in any 100-ml sample

Treated water entering the distribution system

E. coli or thermotolerant coliform bacteria2

Not detectable in any 100-ml sample

Total coliform bacteria

Not detectable in any 100-ml sample

Treated water in the distribution system

E. coli or thermotolerant coliform bacteria2

Not detectable in any 100-ml sample

Total coliform bacteria

Not detectable in any 100-ml sample. In the case of large supplies, where sufficient samples are examined: Not detectable in 95% of samples taken during any 12-months period

1. Immediate investigative action must be taken if either E. coli or total coliform bacteria are detected. The minimum action in the case of total coliform bacteria is repeat sampling; if these bacteria are detected in the repeat sample, the cause must be determined by immediate further investigation.

2. Although E. coli is the more precise indicator of faecal pollution, the count of thermotolerant coliform bacteria is an acceptable alternative. If necessary, proper confirmatory tests must be carried out. Total coliform bacteria are not acceptable indicators of the sanitary quality of rural water supplies, particularly in tropical areas where many bacteria of no sanitary significance occur in almost all untreated supplies.

3. It is recognized that, in the great majority of rural water supplies in developing countries, faecal contamination is widespread. Under these conditions, the national surveillance agency should set medium-term targets for the progressive improvement of water supplies, as recommended in Volume 3 of Guidelines for drinking-water quality.

Table 7.2 Microbiological criteria for drinking water (EC, 1998).


Parametric value

Method of examination

E. coli

0/100 ml

ISO, 9308-1


0/100 ml

ISO, 7899-2


Colony count, 22°C

[No abnormal change]1

Pr EN ISO 6222

Coliform bacteria

0/100 ml

ISO, 9308-1

1. Former directive 80/778/EC (EC 1980) used 100 cfu/ml as guidelines.

Parasites are removed to a large extent by filtration. The levels of bacteria and virus also decrease markedly and the removal mechanisms are both filtration and adsorption. The cation concentration influences adsorption, i.e. increasing concentrations give rise to increased adsorption. Ca2+ and Mg2+ seem to be especially efficient. These small cations will decrease the repulsive forces between the soil particles and the microorganisms. Iron oxides also have a high affinity for viruses as well as bacteria. Ferric hydroxide impregnated lignite has even been suggested as a local filtration/adsorption media (Prasad and Chaudhuri, 1989).

The disinfection efficiency is greatly affected by

The "hardness" of the water may indirectly influence disinfection since deposits may harbour microorganisms and protect them from cleaning agents and disinfectants.

By far the most widespread disinfectant is chlorine but also chloramines, chlorine dioxide, ozone and UV are being used in some instances. Chlorine is cheap and available in most places and monitoring the free residual levels is simple. For disinfection WHO (1996) is recommending 5 mg chlorine/litre and for effective disinfection there should be a residual concentration of free chlorine of ³0.5 mg/l after at least 30 minutes contact time at pH <8.0. For disinfection of clean equipment up to 200 mg/l is used. To avoid corrosion a lower concentration of 50-100 mg/l and longer contact times (10-20 minutes) are often used. Current guidelines are shown in Table 7.3.

Table 7.3 Concentrations of chlorine used in fish processing.

Type of water

Residual levels

Recommendation by

Drinking water

0.5 mg/l

WHO 1996

Water for clean-up

100 mg/l

Reilly 2000

Water in contact with fish

10 mg/l

Reilly 2000

Seawater for cooking of shrimp

20 mg/l

Watson and Prout 1996

Chloramines are more stable but less microbiocidal and much less efficient in killing parasites and virus than chlorine. Chlorine dioxide is, if anything, more microbiocidal than chlorine, especially at high pH, but there is concern with regards to the by-products. In the case of ozone and UV there is no residual matter to monitor. Ozone seems to be very efficient in killing protozoa. The efficiency of UV disinfection decreases markedly if there is any turbidity or dispersed organic matter and problems are often encountered due to a lack of lamp maintenance. The resistance of the various microbiological organisms varies a lot. In the case of most disinfectants the order of sensitivity in decreasing order is:

vegetative bacteria > viruses > bacterial spores, acid-fast bacteria and protozoan cysts.

The sensitivity varies within groups and even within species. Indicator bacteria are unfortunately among the more sensitive microorganisms and the presence of, for example, faecal coliforms in treated, disinfected water is therefore a very clear indication that the water contains potentially pathogenic microorganisms while the absence of such indicator bacteria does not guarantee pathogen-free water.

Bacteria from nutrient-poor media as well as otherwise stressed bacteria may also exhibit greatly increased resistance. Some of the effects mentioned on the efficiency of free chlorine are illustrated in Table 7.4.

Table 7.4 Inactivation of microorganisms by free chlorine.



Cl2 residues mg/l

Temp. °C


Time, min.

Reduction %


E. coli








E. coli








E. coli + GAC5








L. pneumophila
(water grown)








L. pneumophila
(media grown)








Mycobacterium chelonei









Hepatitis A








Hepatitis A









G. lamblia








G. lamblia








G. lamblia








1. C·t product of disinfectant concentration (C) in mg/l and contact time (t) in minutes for 99% inactivation (modified after Sobsey (1989))

2. BDF = buffered demand free

3. ND = no data

4. CDF = chlorine demand free

5. GAC = granular activated carbon

If microbes are associated with granular material or other surfaces the effect of a disinfectant such as chlorine decreases drastically. Attachment of Klebsiella pneumonia to glass surfaces may, for example, increase the resistance to free chlorine by 150-fold (Sobsey, 1989).

Organic matter may react and "consume" disinfectants such as chlorine and ozone and the presence will also interfere with UV light. The chloramines are less susceptible to organic matter.

pH is important in disinfection with chlorine and chlorine dioxide. There is greater inactivation of microorganisms at low pH in the case of chlorine and greater inactivation at high pH in the case of chlorine dioxide (Sobsey, 1989). In general, higher temperatures result in increased inactivation rates.

Use of non-potable water

The use of non-potable water may be necessary for water conservation purposes or desirable because of cost. Non-potable water may, for example, be surface water, sea water or chlorinated water from can cooling. Relatively clean water such as chlorinated water from can cooling operations may be used for washing cans after closing and before heat treatment, for transporting raw materials before processing (after the water has cooled off), for initial washing of boxes, for cooling of compressors, for use in fire protection lines in non-food areas and for fluming of waste material.

Separation of potable and non-potable water

It is absolutely necessary that potable and non-potable water should be in separate distribution systems which should be clearly identifiable

If potable water is used to supplement a non-potable supply the potable source must be protected against valve leakage, or back-pressure, for example, by adequate air-gaps. Back-flow, due to sudden pressure differentials or blockage of pipes, has unfortunately occurred in many systems.

Potentially contaminated water such as coastal water or surface water, should not be used at the production premises but may, if aesthetically acceptable, be used for removing waste material in places where no contact to food is possible.

Monitoring water quality

The responsible person should have continuously updated reference drawings of the pipe system and the authority to remove dead-ends. Especially in cases where a plant has undergone many changes, the piperuns, may become more and more complicated over the years. The person should also be in contact with the local waterworks and the authorities in order to be informed of special events (repairs, pollution accidents or other changes).

Water may be contaminated due to bad location of source (close to septic tanks, agriculture drainage systems), cracked or improperly sealed off piping systems or even floods and heavy rains. In the plant, contamination of the water may be due to cross-connections or backflow (back pressure or back siphonage). Where necessary, backflow should be controlled by air-gaps, vacuum breakers or check valves.

A quality monitoring scheme could consist of a plan of all the sampling points and a checklist describing what to examine and why, the frequency, who takes the sample, who does the analysis, what is the limit (value, tolerance) and what to do in case of deviation (Poretti 1990). If the water is obviously polluted there is of course no reason to wait for analytical results. The sampling frequency and the range of parameters will vary with the circumstances and a special monitoring program may be needed after repairs, or when using new water supplies, for example. A minimum monitoring program for water quality could be:

The technical procedures describing the analyses for the common indicator organisms are given in standard textbooks. The EC Directive (EC, 1998) specifies some methods and equipment to be used. The values used by the company should refer to the specific method employed and the recommendations should include how to sample (tap flow, volume, sampling vessel, labelling, etc.) and how to handle and examine the sample. Even though the commonly used methods for detecting, for example, faecal coliforms are standard analyses, faulty handling of the samples often occurs. Samples should be processed within 24 hours or less, be kept cool but not frozen (preferably below 5°C), and be kept in the dark. The impact of sunlight can be very dramatic, causing false negative results (Knøchel, 1990).

Model prerequisite programme: Safety of water and ice


Water that comes into contact with food or food contact surfaces or is used in the manufacturing of ice is from a safe and sanitary source or is treated to make it safe


Water must pass potability standards
(e.g. to E. coli, Enterococci, Coliform 0/100 mL
Aerobic Plate Count (22°C) 102 cfu/ml (guide level) residual free chlorine 0.2-0.5 mg/l in water distribution system max 10 mg chlorine/l in water, that comes in contact with fish products


When public water supply is used, the official records from the water works suffice. Water from own water supply:
Check for residual chlorine: daily
Check for microbiological contamination:
A water sampling schedule must be worked out. Sampling must follow standard microbiological procedures.
Responsible person is: chief, Q.A.

Corrective action:

Actions to be taken when criteria is exceeded must be outlined, e.g. adjusting water treatment, stop of production if water is contaminated, search for source of contamination


Records of all sampling, testing and actions must be kept for two years.
Daily hygiene record form (chlorine)


Once every year, water samples are tested by certified laboratory

If chlorination is used for disinfection monitoring of the free chlorine level is the simplest way of checking the water treatment and should be performed most often (e.g. on a daily basis). Simple laboratory methods and commercial dip-sticks are now available for on-the-spot measurements (e.g. Merchoquant Chlor 100 from Merck). The microbiological indicator parameters may be checked less frequently. If disinfection systems that leave no residuals are being used, then checking of equipment should be done regularly. The performance of the systems may be monitored at weekly intervals using indicator bacteria measurements. Above is a model of a control programme for this particular requirement.

7.2.2 Cleanliness of food contact surfaces

All food contact surfaces should be adequately and routinely cleaned and disinfected. Cleaning and disinfection belong to the most important operations in today's food industries. In the US, the term sanitation is sometimes used to describe the disinfection process. In some cases, sanitation may refer to the whole cleaning and disinfection process.

Food contact surfaces are

· Those surfaces that contact human food and those surfaces from which drainage onto the food or onto surfaces that contact the food ordinarily occurs during the normal course of operations

· Typical food contact surfaces include utensils, knives, tables, cutting boards, fish boxes, conveyor belts, ice makers, ice storage bins, gloves, aprons, etc.

The cleaning and disinfection process can be divided into clearly distinct operations. However, these are linked firmly together in that the final result will not be acceptable unless all processes are carried out correctly.


means adequately treating food contact surfaces by a process that is effective in destroying vegetative cells of microorganisms of public health significance, and substantially reducing numbers of other undesirable microorganisms, but without adversely affecting the product or its safety for the consumer (FDA, 2001)

The various steps included in a complete cycle are outlined below.


In the preparatory phase, the processing area is cleared of remaining products, spills, containers and other loose items. Machines, conveyors, etc. are dismantled so that all locations where microorganisms can accumulate become accessible for cleaning and disinfection. Electrical installations and other sensitive systems should be protected against water and the chemicals used.

AVOID starting the cleaning operation by splashing water (using the pressure hose) on floors and machinery before all food products are removed.

Before use of the cleaning agent, a gross food debris removal procedure should be carried out by brushing, scraping or similar action. All surfaces should be further prepared for the use of cleaning agents by a pre-rinse activity, preferably with cold water so as not to coagulate the proteins. Hot water may be used to remove fat or sugars in cases where protein is not present in significant amounts.

Completion of the preparatory work should be checked and recorded, as with any other process to ensure the quality of the complete cycle of cleaning and disinfection.

Cleaning is undertaken to remove all undesirable materials (food residues, microorganisms, scales, grease, etc.) from the surfaces of the plant and the process equipment, leaving surfaces clean, as determined by sight and touch and with no residues from cleaning agents.

Microorganisms present will either be incorporated in the various materials or attached to the surfaces as biofilms. The latter will not be removed completely by cleaning, but experience has shown that a majority of the microorganisms will be removed. However, there will still be some left to be inactivated during the disinfection. Bacteria in biofilm can be up to 1,000 times more resistant to common disinfectants compared to when in the free state.

The effectiveness of a cleaning procedure in general depends upon:

Some surfaces, e.g. corroded steel and aluminium galvanised metal can not be cleaned easily which means that disinfection also becomes very inefficient. The same applies to other surfaces, e.g. wood, rubber, etc. The preferred material is high quality stainless steel.

The types of residues to be removed in food plants, will mainly be the following:

Most cleaning agents work faster and more effectively at higher temperatures, so it can be profitable to clean at a high temperature. Cleaning is often carried out at 60-80°C in areas where it pays, energy-wise, to use such high temperatures.

Water is used as a solvent for all cleaning and sterilising agents and also for intermediate rinses and the final rinse of equipment. The chemical and microbiological quality of the water is important for the efficiency of the cleaning procedures as already described in a previous section of this Chapter. In principle, water used for cleaning must be potable.

Hard water contains a large amount of calcium and magnesium ions. When the water is heated, any calcium and magnesium salts will precipitate as insoluble salts. Also, some cleaning agents, especially alkalis, can precipitate calcium and magnesium salts.

Apart from reducing the effectiveness of detergents hard water leads to the formation of deposits or scales. Scales are not only unsightly but objectionable for several reasons:

The formation of scales can be reduced by addition of chelating and sequestering agents, which bind calcium and magnesium in insoluble complexes. However, it is advisable to prevent precipitations by softening the water before it is used for cleaning. Softening can be effectively achieved by ion exchange, in which the calcium and magnesium ions are replaced by sodium ions, the salts of which are soluble. A modern, and more costly, method of softening water is by means of reverse osmosis.

To be effective, a suitable detergent or cleaning agent must be applied. The ideal detergent would be characterized by the following properties:

A detergent with all these characteristics does not exist. So one must, for each individual cleaning operation, select a compromise by choosing a usable cleaning agent and water treatment additives so that the combined detergent has the properties that are most important for the procedure concerned.

All cleaning methods, including foams and soaks, require sufficient contact time to fully loosen and suspend soils. A moderately alkaline detergent, which is normally used in plants processing high protein foods such as fish, will typically require 10-15 minutes to fully loosen most processing soils.


Traditionally, the terms "disinfection" and "disinfectants" are used to describe procedures and agents used in food industries to ensure a microbiologically acceptable standard of hygiene. It is realised that the procedures and agents described will rarely introduce "sterility" i.e. total absence of viable microorganisms.

Disinfection can be effected by physical treatments such as heat, U.V. irradiation, or by means of chemical compounds.

Use of heat in the form of steam or hot water is a very safe method and a widely used method of disinfection. The most commonly used chemicals for disinfection are shown in Table 7.5.

With the use of chemical disinfectants, the death rate for microorganisms depends, among other things, upon the agent's microbiocidal properties, concentration, temperature and pH as well as the degree of contact between disinfectant and microorganisms. Good contact is obtained by stirring, turbulence, smooth surfaces and low surface tension. As with heat disinfection, different microorganisms show different resistance to chemical sterilants. Contamination by inorganic or organic matter can reduce the death rate considerably.

Cleaning precedes disinfection

An effective disinfection can only be obtained after an effective cleaning

The desirable plant disinfectant would be characterized by the following properties:

It will often be necessary to combine disinfectants with additives in order to obtain the required properties. The following are among the most widely used disinfectants and shall be described briefly.

Chlorine is one of the most effective and widely used disinfectants. It is available in several forms, for instance sodium hypochlorite solutions, chloramines and other chlorine containing organic compounds. Gaseous chlorine and chlorine dioxide are also used. Chlorinated disinfectants at a concentration of 200 ppm free chlorine are very active and have a cleaning effect. The disinfectant effect is considerably decreased when organic residues are present. The compounds dissolved in water will produce hypochlorous acid, HOCl, which is the active disinfecting agent, acting by oxidation. In solution it is very unstable, particularly in acid solution where toxic chlorine gas will be liberated. Furthermore, solutions are more corrosive at low pH.

Unfortunately, the germicidal activity is considerably better in acid than in alkaline solution, thus the working pH should be chosen as a compromise between efficiency and stability. Organic chlorinated disinfectants are generally more stable but require longer contact times. When used in the proper range of values (200 ppm free chlorine), chlorinated disinfectants in solutions at ambient temperatures are non-corrosive to high quality stainless steel, but they are corrosive to other less resistant materials.

Table 7.5 Types of disinfectants (based on anon. 2000).






Hypochlorites Chlorine gas Organic chorine, e.g., chloramines

- Kills most types of microorganisms
- Less affected by hard water than some
- Does not form films
- Effective at low temperatures
- Relatively inexpensive
- Concentration easily determined by test strips

- May corrode metals and weaken rubber
- Irritating to skin, eyes and throat
- Unstable, dissipates quickly
- Liquid chlorine loses strength in storage pH sensitive


Iodine dissolved in surfactant and acid

- Kills most types of microorganisms
- Less affected by organic matter than some
- Less pH sensitive than chlorine
- Concentration determined by test strips
- Solution colour indicates active sanitiser

- May stain plastics and porous materials
- Inactivated above 50°C
- Reduced effectiveness at alkaline pH
- More expensive than hypochlorites
- May be unsuitable for CIP1 due to foaming

Quaternary Ammonium Compounds

Benzalkonium chloride and related compounds, sometimes called quats or QACs

- Non corrosive
- Less affected by organic matter than some
- Residual antimicrobial activity if not rinsed
- Can be applied as foam for visual control
- Effective against Listeria monocytogenes
- Effective for odour control
- Concentration determined by test strips

- Inactivated by most detergents
- May be ineffective against certain organisms
- May be inactivated by hard water
- Effectiveness varies with formulation
- Not as effective at low temp. as some
- May be unsuitable for CIP due to foaming


Combination of certain surfactants and acids

- Sanitize and acid rinse in one step
- Very stable
- Less affected by organic matter than some
- Can be applied at high temperature
- Not affected by hard water

- Effectiveness varies with microorganism
- More expensive than some pH sensitive (use below pH 3.0)
- Corrode some metals
- May be unsuitable for CIP due to foaming

Peroxy Compounds

Acetic acid and hydrogen peroxide combined to form peroxyacetic acid

- Best against bacteria in biofilms
- Kills most types of microorganisms
- Relatively stable in use
- Effective at low temperatures
- Meets most discharge requirements
- Low foaming; suitable for CIP

- More expensive than some
- Inactivated by some metals/organics
- May corrode some metals
- Not as effective as some against yeasts and moulds

Carboxylic Acid

Fatty acids combined with other acids; sometimes called fatty acid sanitizers

- Kills most types of bacteria
- Sanitize and acid rinse in one step
- Low foaming, suitable for CIP
- Stable in presence of organic matter
- Less affected by hard water than some

- Inactivated by some detergents pH sensitive (use below pH 3.5)
- Less effective than chlorine at low temp.
- May damage non-stainless steel materials
- Less effective against yeasts and moulds than some

Chlorine Dioxide

A gas formed onsite and dissolved in solution or by acidification of chlorite and chlorate salts

- Kills most type of microorganisms
- Stronger oxidiser (sanitizer) than chlorine
- Less affected by organic matter than some
- Less corrosive than chlorine
- Less pH sensitive than some

- Unstable and cannot be stored
- Potentially explosive and toxic
- Relatively high initial equipment cost


A gas formed onsite and dissolved in solution

- Kills most type of microorganisms
- Stronger oxidiser (sanitizer) than chlorine and chlorine dioxide

- Unstable and cannot be stored
- May corrode metals and weaken rubber
- Potentially toxic
- Inactivated by organic matter (similar to chlorine)

Hot Water/Heated Solutions

Water at 77-88°C

- Kills most types of microorganisms
- Penetrates irregular surfaces
- Suitable for CIP
- Relatively inexpensive

- May form films or scale on equipment
- Burn hazard
- Contact time sensitive

1. CIP = cleaning in place

Iodophors contain iodine, bound to a carrier, usually a non-ionic compound, from which the iodine is released for sterilisation. Normally the pH is brought down to 2-4 by means of phosphoric acid. Iodine has its maximum effect at this pH range.

Iodophors are active disinfectants with a broad antimicrobial spectrum like chlorine. They are inactivated by organic material. Concentrations corresponding to approximately 25 ppm free iodine will be effective.

Commercial formulations are often acidic making them able to dissolve scales. They can be corrosive depending on the formulation and they should not be used above 45°C as free iodine may be liberated. If residues of product and caustic cleaning agents are left in dead ends and similar places, this may, in combination with iodophores, cause very unpleasant "phenolic" off-flavours.

Hydrogen peroxide and peracetic acid are effective disinfectants acting by oxidation and with a broad antimicrobial spectrum. Diluted solutions may be used alone or in combination for disinfection of clean surfaces. They lose their activity more readily than other disinfectants in the presence of organic substances and they rapidly lose their activity with time. They should be used in concentration of 200-300 ppm.

Quaternary ammonium compounds are cationic surfactants. They are effective fungicides and bactericides but are often less effective against Gram negative bacteria. To avoid development of resistant strains of microorganisms, these compounds should only be used by alternating with the use of other types of disinfectants.

Due to their low surface tension, they have good penetrating properties and for the same reason, they can be difficult to rinse off. If quaternary ammonium compounds come into contact with anion-active detergents, they will precipitate and become inactivated. Mixing or successive use of these two types of chemicals must therefore be avoided. They can be used in concentrations of 200 ppm on food contact surfaces. Table 7.6 summarizes the concentrations of commonly used disinfectants.

Table 7.6 Disinfectant concentrations commonly used in food plants (anon., 2000).

Concentrations of disinfectants commonly used in food plants


Food contact surface

Non-food contact surfaces

Plant water


100-2001 ppm

400 ppm

3-10 ppm


251 ppm

25 ppm


2001 ppm

400-800 ppm

Chlorine dioxide

100-2001,2 ppm

100-2002 ppm

1-32 ppm

Peroxyacetic acid

200-3151 ppm

200-315 ppm

1. The higher end of the listed range indicates the maximum concentration permitted without a required rinse (surfaces must drain)

2. Includes mix of oxychloro compounds

3. Monitoring of cleaning and disinfection

Effective cleaning is a prerequisite for an efficient disinfection. This indicates the importance of controlling cleaning. The most important control is sensory (visual, touch, smell) inspection to demonstrate:

Further, the concentrations and pH-values of cleaning agents, the temperatures, if hot cleaning is used, and the contact times should be monitored and registered. pH measurements, or similar testing, of rinse water may be used to ensure that the cleaning agent is removed so that it will not interfere with the disinfectant. These controls are all rapid and allow immediate decisions to be made as to whether cleaning should be repeated, partly or completely, or to proceed to the process of disinfection. All actions shall be registered as part of the Quality System. At this stage, microbiological control serves no real purpose. Firstly biofilms and surviving microorganisms are likely to be present and secondly, reliable rapid methods are not available.

Control of disinfection will be the final control of the complete cycle of cleaning and disinfection. Provided cleaning has been controlled effectively as described above, control of disinfection will be effective when the following conditions are met:

The above controls should be documented and the observations reported and registered as required in standard Quality Systems.

Microbiological testing and control serve the purpose of verification. Various techniques are available, but none are ideal and they are not "real time" methods. "Real time" methods are highly desirable for control of cleaning and disinfection. Methods (bacterial counting) that require overnight incubation are too late to correct critical situations. However, if conducted at regular intervals and planned to cover all critical points, useful information from microbiological control can be accumulated with time. Various methods are used and shall be mentioned briefly.

Regardless of the technique used, it is valuable to know from the verification analyses that the system was working when it was established. There is also a value in knowing trends as expressed in the verification results recorded. The objective of studying trends and conducting the microbiological control of cleaning and disinfection will be to take corrective action before loss of control of products or processes occur.

Model prerequisite programme: Cleanliness of food contact surfaces


A permanent cleaning and disinfection schedule must be drawn up specifying the frequency of cleaning and disinfection at each location. Food contact surfaces are most important, but non-food contact surface must also be kept clean. In addition, good housekeeping of all areas including employee restrooms and locker rooms is necessary. The following procedure should be followed in cleaning and disinfection procedures:

- pre-cleaning, preparation of area for cleaning.
- pre-rinse or soak in tanks.
- cleaning - with appropriate detergent (type of detergent, concentration, contact time must be specified).
- rinse
- disinfection - application of approved chemical (name disinfectant, concentration, contact time).
- post rinse.

A full cleaning schedule must be applied at the end of a working day on all locations, but part of the schedule can be omitted in a "clean as you go" policy.


What: Cleanliness of food contact surfaces, concentrations of cleaning and disinfection agents, cleaning operation, contact time for sanitation chemicals.

How: Visual inspection, smelling for offensive odours, feeling for greasy surfaces.

Check labels.

When: Daily.

Who: Foreman.

Corrective action:

Repeat operation


All observations and actions. Daily sanitation control records.


Microbiological testing of food contact surfaces, review of records and procedures.

7.2.3 Prevention of cross-contamination

A key element in any hygiene programme is the prevention of cross-contamination, i.e. contamination of final product with any hazards originating in the raw material or the processing environment. This is of particular concern if the final product is a ready-to-eat product that is not usually cooked before being eaten. There are many possible routes of contamination of the final product as shown in Figure 7.5. It is not always possible to identify the most important routes and all of them must be included in a preventive programme.

Figure 7.5 Routes of contamination in a seafood processing plant.

The main preventive measures to avoid cross-contamination are:

Personnel can contaminate the final product directly with pathogens from their skin or hands, digestive system or respiratory tract. They can also function as an intermediary vector carrying bacteria, virus, etc. from raw material or the environment to the product. For this reason, employee hygiene and food handling practices are very important - particularly when ready-to-eat products are handled. Below some points on personal hygiene to consider in this part of the prerequisite programme:

Model prerequisite programme: Prevention of cross-contamination


Cooked, ready-to-eat products must be physically separated from raw materials during processing and storage
Waste must be removed by the most direct route or at least downstream out of the processing-area. Care must be taken to avoid any possible contact with food products
No traffic of employees, products or utensils between clean and less clean areas is permitted
Food handling and processing areas must be clean and orderly at start-up
Description of dress-code
Description of hand-washing requirements


Adequate separation of raw and cooked or ready-to-eat products and processing activities
Cleanliness of food handling areas
Employee hygiene, handling practices and traffic in the plant
The monitoring should be carried out continuously by all supervisors in their areas of responsibility

Corrective action:

Stop all activities until areas or utensils are cleaned and disinfected or faulty procedures are corrected
Further training of personnel
If contamination of cooked or ready-to-eat products is likely to have happened, these products must be identified and segregated until a decision is made on their safety


Daily sanitation records - including specified time for checks on cleaning and disinfection procedures
All observations and actions

7.2.4 Maintenance of facilities for personal hygiene

According to the US Federal Seafood HACCP regulations (FDA, 1995) the condition of the personal hygiene facilities should be monitored separately.

The number and location of toilets and hand-washing facilities needs consideration. An adequate number of readily accessible toilet facilities must be available and maintained in a hygienic condition and good repair. Hand-washing facilities must be strategically and conveniently located near toilets and at entrances to the processing areas. Wash basin taps must not be hand-operated.

Hand-washing facilities should be dedicated to hand-washing only and never be used for washing dishes, utensils or equipment. Similarly, hand-washing should never take place in sinks or tanks used for food preparation. Hand-washing facilities should include:

Typically hand disinfectants are composed of chlorine compounds (100-200 ppm chlorine) or iodine compounds (20-25 ppm iodine).

Model prerequisite programme: Maintenance of facilities for personal hygiene


Toilets and hygiene areas kept cleaned and in good repair
Hand-washing and disinfection facilities must be located at toilets and at the entrance to all processing areas and maintained in a good condition
The facilities must be equipped with liquid soap, disposable towels and effective disinfectant dips


Daily check of facilities for cleanliness and good repair. More than one daily check for concentration of disinfectant dip
One person (e.g. the Q.A. supervisor) should be designated to carry out this monitoring

Corrective action:

Immediate repair if facilities are broken down or not functioning properly
Replenishing of supplies if lacking or concentration is inadequate


The daily Hygiene Record form should include all observations made and actions carried out

7.2.5 Protection of food from adulterants

Food, food contact surfaces and food packaging material must be protected from adulteration with filth, lubricants, fuel, pesticides, cleaning compounds, disinfection agents, condensates, floor splash and other chemical, physical and biological agents. Thus it is clear, that this part of the programme goes beyond safety aspects addressing also contamination with filth.

Model prerequisite programme: Protection of foods from adulteration


Food, food contact surfaces and food packaging material must be protected from adulteration with lubricants fuel, pesticides, cleaning compounds, disinfection agents, condensate and other chemical, physical and biological contaminants.
Specify chemicals to be used in the facility and the requirements to handling and storage (refer to section 7.2.6)


Daily check at start-up and every four hours during work hours by supervisor to observe on conditions

Corrective action:

Any unsatisfactory activity must be corrected. Possible correction could be to erect a screen to protect a product, correct air flow and ventilation to prevent condensation on the food or to reinforce training of employee


Must be kept on all actions. A daily hygiene record is kept

Processors need to be aware of all avenues that could cause the food to be adulterated. The maintenance department needs to establish a regular maintenance programme for the facility's ventilation system to avoid formation of condensation. Also floors must be maintained in good order to avoid formation of pools of water and supervisors must ensure that no floor splash occurs during processing or when food is exposed.

Only food grade lubricants should be used on all moving machinery parts that come into direct contact with food. Only approved chemicals for cleaning, disinfection, pesticides and rodenticides should be uses in the processing plant.

7.2.6 Proper labelling, safe storage and use of toxic compounds

All food processing plants use chemicals such as cleaning agents, disinfectants, rodenticides, insecticides, machine lubricants and various additives. These chemicals must always be used according to the manufacturer's instructions, have proper labelling and be stored in a safe manner that protects against contamination of food or food contact surfaces. Original containers (stock solutions) must be kept in a separate room for this purpose only. Working solutions of cleaning and/or disinfection compounds should be in the processing area only when in use - and when no food products are handled.

Model prerequisite programme: Safe storage and use of toxic compounds


List all chemicals used in the plant, manufacturer's instruction must be followed when used. Specify storage conditions (separate room with limited access)


Check labels
Storage conditions and check if manufacturer's instructions are followed. Monitoring daily and visual by supervisor

Corrective action:

Toxic compounds without proper identification or documentation are discarded (or returned to supplier)
Improperly placed or stored toxic compounds are removed to correct area
Retraining of employee in case of misuse of toxic compounds


Daily hygiene control records

7.2.7 Control of employee health conditions

It is well known that poor personal hygiene has been implicated in a number of food-borne disease outbreaks. Even apparently healthy persons may carry pathogens, which can spread and contaminate food. However, persons showing symptoms such as: diarrhoea, vomiting, open skin sores, boils, fever, jaundice or discharge from ear, eye or nose, are likely to be infected with pathogens that can be transmitted to food. A food worker displaying any of these symptoms should therefore be excluded or restricted from food handling areas.

Model prerequisite programme: Control of employee health conditions


No person suffering from any communicable disease should be engaged in handling of fish or fish products
Before starting to work at the factory, for the first time, the employee should produce a medical certificate
The new employee should be trained on GHP


Supervisors check daily for infected lesions or signs of any communicable disease

Corrective action:

Workers who represent a potential risk are re-assigned to non-food contact jobs


Daily hygiene control records

7.2.8 Pest control

This programme relates to pests such as rodents, birds and insects as well as dogs and cats. These pests can carry a variety of human disease agents, which can be introduced into the processing environment. For this reason, the presence of pests in a processing plant is unacceptable.

A pest control programme should be based on three principles:

Model prerequisite programme: Pest control


Presence of rodents, insects and other animals on the premises is not allowed in any area of the processing plant
An effective plan for pest control will be in place and includes:

- elimination of harbourage and attractant areas (Rapid removal of waste see section 7.2.9)
- exclusion. All openings (doors, windows, ventilators) must be filled with fly protection
- extermination. Company XX is hired for extermination of rodents


What: Inspection of plant for presence or trace of pests (droppings), attractant areas, exclusion arrangements (screening of openings, windows etc.) and of rodent traps

How: Visual

When: Daily

Who: Q.A. manager

Corrective action:

Immediate repair of defect screenings, removal of attractant areas


All actions and observations

7.2.9 Waste management

All offals and other waste materials must be removed from the processing area and premises on a regular basis. Separate facilities for containment of offal and waste material must be provided for this purpose only and those facilities should be properly maintained. A hygienic waste water disposal system must be in operation. Sewage disposal shall be made into an adequate sewerage system or disposed of through other adequate means.

Model prerequisite programme: Waste management


Offal, waste and sewerage will be contained in closed containers, separate rooms or connected directly to a public septic system and be removed from the premises on a regular basis
Any container, room etc. used for waste will be marked accordingly


What: Inspection of waste management utensils and procedures

How: Visual

When: Daily

Who: Processing manager

Corrective action:

Repair of system


Daily hygiene report

7.2.10 Storage and transportation

The conditions for storage and transportation must be as such to minimise contamination and damage of the fish. Storage areas and vehicles used for the transportation of fish and fish products must be clean. They must provide the fish with protection against contamination from dust and exposure to higher temperatures. Where appropriate, vehicles must be fitted with refrigeration and equipment to maintain fish at 0°C (chilling) or £-18°C (freezing). Below is an example of this part in a prerequisite programme.

Model prerequisite programme: Storage and transportation


Storage rooms must be kept clean and orderly and equipped to maintain products at chilled (<+5°C) or frozen temperature (<-18°C) Vehicles for transportation of fish and fish products should be designed and constructed so the fish is protected against contamination and exposure to higher temperatures. Where appropriate vehicles must be equipped to maintain chilled (£5°C) or freezer temperature (£-18°C)


What: Inspection of rooms and vehicles, recording of temperature

How: Visual

When: Daily (store-rooms) and all shipments

Who: Loading foreman

Corrective action:

Correct room temperatures or remove products
Replacement of vehicle


All actions and observations
Documented cleaning and disinfection procedures

7.2.11 Traceability and recall procedures

A system for tracing all raw materials and finished products is a necessary component in a prerequisite programme. No process is fail-safe and traceability that includes lot identification is essential to an effective recall procedure. A crisis response plan should be in place to handle any incidents.

Appropriate records of processing, production and distribution should be kept and retained for a period that exceeds the shelf life of the product. Where there is a health hazard, products produced under similar conditions may be withdrawn. The need for public warning should be considered. Once retrieved, products must be held under supervision until the manner of product disposition e.g. rework or destruction has been determined.

Model prerequisite programme: Traceability and recall procedures


Each container of fish and fish product will be clearly marked to identify producer/processor and lot. Written procedures for recall of products and possible information to the public are laid down


What: Inspection of packaging material and identification labels

How: Visual

When: Daily

Who: Processing supervisor

Corrective action:

When there is a health hazard, products produced under similar conditions may be withdrawn. The need for public warnings should be considered. Recalled products to be held under supervision until decision on further action (destroyed, processed, used for other purposes)


Records of processing and production must be kept and retained for a period that exceeds the shelf life of the products
All other actions and observations must be recorded


Checks of final products in storage for proper labelling

7.2.12 Training

All employees should receive documented training on personal hygiene, GHP, cleaning and disinfection procedures, product handling and protection, the HACCP-system and process control. Periodic refresher training should be part of the overall training programme. Training in basic food hygiene is fundamentally important. All personnel should be aware of their roles and responsibilities in protecting fish and the fish products from contamination and deterioration.

An example of a checklist to be used in assessing the prerequisite programme is shown in Appendix 1.

Model prerequisite programme: Training


All fish handlers must have participated in a training course in personal hygiene, GHP, cleaning and disinfection procedures before starting to work in the plant
Those who handle strong chemicals must be instructed in safe handling techniques
Appropriate training in application of HACCP-system and process control to key personnel
Periodic training of all employees so they understand the principles in the HACCP-system


What: Skill, knowledge and code of conduct of employees

How: Visual observation, occasional interviews

When: Continuously

Who: Supervisors

Corrective action:



Number and type of training sessions/courses for personnel
Interviews with personnel


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