1.2 Outline of official arrangements
2.1 Needs assessment and collection of existing legislation
2.3 Preparation of HACCP plans
2.4 Regional workshop on the implementation of quality assurance
3.1 Needs assessment and collection of existing legislation
3.3 Preparation of HACCP plans
3.4 Regional workshop on the implementation of quality assurance
In response to a recommendation made by the 26th Regional Technical Meeting on Fisheries held in Noumea in August 1996, the South Pacific Commission (SPC) requested FAO to provide technical assistance to help the South Pacific Region meet the new fish import requirements of major importing markets, based on the Hazard Analysis and Critical Control Point (HACCP) theory of food safety production. This assistance was required as a matter of urgency to ensure that trade in seafood products between the Pacific islands and the United States and Europe would continue without interruption. The USA, for instance, required seafood exporters to comply with new Mandatory HACCP Regulations for ensuring product safety by 18 December 1997. Similarly, the European Union (EU) enacted HACCP-based legislation that affected domestic and overseas seafood processors. The request from the SPC was formally endorsed by five Pacific island Governments (Cook Islands, Fiji, Samoa, Solomon Islands and Tonga), which sought assistance to undertake four sequential activities: needs assessment and data collection (legislative, technical, export data); drafting of appropriate food safety legislation; drafting of generic HACCP plans for products commonly exported from the region; and finally, a regional workshop on the implementation of HACCP, aimed at regulators and exporters.
This assistance was approved by FAO in March 1997 under the Technical Cooperation Programme project TCP/RAS/6713, Assistance to the South Pacific Region to Meet New Fish Import Regulations, for a total cost of $US 165 000. The South Pacific Commission was designated the agency responsible for project execution. The project was estimated to begin in April 1997 and end in December 1997; although it began a month later than planned, it succeeded in completing the programme of activities three months ahead of schedule.
The project's objective was to assist the authorities of the states and territories of the South Pacific to have model food control laws and quality control plans to ensure compliance with the new requirements for fish imports by the European Union and the USA. Three studies were to be undertaken by three international consultants for a period of one man-month each and a terminal regional workshop was to be held, during which the consultants' findings would be shared and discussed with member states. The project was carried out in collaboration with the Coastal Fisheries Programme of the South Pacific Commission.
The four major activities under this project were carried out as planned, with the full cooperation and support of the countries visited by the international consultants, and staff from FAO and SPC. The countries visited by the consultants included the Federated States of Micronesia, Fiji, Papua New Guinea, Samoa, Solomon Islands, Tonga and Vanuatu. Complete references for the reports produced by the consultants are given in the Appendix.
The preliminary study was designed to collect data and evaluate the food safety regulations of as many Pacific island countries as possible. The task was completed through visits by the consultant to a selected number of countries with significant seafood exports. In each country visited, the consultant compiled information and data on the status of the seafood export industry; quality assurance and export procedures; legislation; and information on major seafood exporting companies.
The consultant found that, with the exception of the canneries in Fiji and Solomon Islands, the USA market was the major HACCP-related challenge for the region. He therefore suggested that the remainder of the project be oriented towards meeting the requirements of the US Food and Drug Administration (FDA) regulations. The study also demonstrated how unprepared countries were to meet changing overseas market requirements. This situation, again with the exception of the canneries, was true for both exporters and national regulators. The consultant therefore recommended that regional fishery organizations establish a dialogue with the FDA to collect and then disseminate appropriate information to the countries. He expressed the need to focus on activities, such as training and technical advice, that would help exporters meet the US Mandatory HACCP Regulations before they came into force in December 1997.
After collecting and evaluating the diverse food safety related legislations and regulations from the majority of Pacific island countries and territories, it quickly became apparent that drafting a single model law would be extremely difficult and would probably be of little value to the region. The legal consultant's study therefore provided an overview of HACCP; reviewed the seafood HACCP regulations of the major importing countries of fish products from the Pacific Region (the US Seafood HACCP Regulation and the EU Seafood Directive, plus a brief description of the FAO/WHO Codex Alimentarius); reviewed the legislation covering food safety from sixteen Pacific island countries and territories; and discussed the regulatory strategies available to individual states as well as on a regional basis.
The US Seafood HACCP Regulation and the EU Seafood Directive were said to create options for the governments of seafood exporters. In the report these were called the Strategic Regulatory Options, which were: (i) no action; (ii) equivalency; or (iii) action short of equivalency designed to facilitate seafood exports. The merits of each option in terms of costs and ease of access to markets were discussed and evaluated in detail.
The HACCP technical consultancy reviewed the operations of specific plants, and offered advice and assistance on the implementation of HACCP to processors and government fisheries officers in Fiji, Solomon Islands and Tonga. Through visits to typical fish processing facilities in the three Pacific island countries, the consultant drafted five generic HACCP plans based on the production of the most common exported seafood commodities from the Pacific (with the exception of canned tuna - the reason being that the canneries have had HACCP in place for many years). The products were i) air-freighted chilled tuna and billfish; ii) air-freighted chilled bottom fish; iii) hot smoked, frozen fish sticks; iv) cold smoked, frozen, sliced fish loins; and v) dried flavoured tuna (jerky). The report also detailed Standard Sanitation Operating Procedures (SSOPs) and reviewed the constraints to implementation in the South Pacific Region.
The final activity of the project involved a Regional Workshop on the Implementation of HACCP-based Quality Assurance for Seafood held in Pacific Harbour, Fiji, from 30 September to 3 October 1997. The workshop provided a grounding in the legal and technical aspects of HACCP implementation by the USA and in the identification of strategic options that governments could pursue in meeting the US requirements. In addition to representatives from government departments of thirteen Pacific island countries and territories who were sponsored by the project, self-financing representatives of several seafood exporting companies, HACCP consultants and participants from other regional organizations attended the workshop.
The consultant recommended that the project and regional fishery organizations continue efforts to establish a dialogue with the US FDA and closely monitor any articulation by the agency of the requirements. The Pacific island exporters should be informed immediately and directly of any developments. The immediate priority for enforcement will be the requirement for exporters to have written, functional HACCP plans and SSOP plans. Given the FDA requirement for the plans to be formulated by a qualified individual, and the near-absence of such trained individuals in the Pacific islands, training should be immediately provided to private-sector exporters to enable them to have the required qualifications.
The consultant recommended that the Governments consider options for their own regulatory approach to HACCP regulations imposed by importing countries, based on the Strategic Regulatory Options that were described and evaluated in detail.
He also suggested that a list of Regulatory Components of a seafood safety regulatory regime be included in any national legislation, as follows:
- All seafood processing facilities require a licence.
- Licences shall only be issued for processing facilities that meet standards regarding the premises, equipment, sanitation, workers and handling that ensure cleanliness and eliminate possible contamination.
- Licences shall only be issued following inspection by qualified inspectors who will have access to all aspects of the processor's premises and operations.
- Licences can be revoked or suspended if facilities do not meet the appropriate standards.
- Penalties should exist for processors who do not meet the appropriate standards.
- The standards to be met should be from a recognized international body such as the FAO/WHO Codex Alimentarius.
- Appropriate definitions of seafood processing facilities should be adopted.
- All seafood exporters require a licence.
- Seafood export licences shall only be issued to processors who can demonstrate that they can consistently meet the appropriate standards regarding microbial and natural toxin contamination, chemical contamination and physical contamination.
- Inspectors shall carry out regular sampling and testing of products and shall have wide authority to conduct necessary inspections and to prevent unsafe seafood from reaching consumers.
- Seafood export licences may be revoked or suspended if uncertainty arises on the seafood product's ability to meet the appropriate standards.
- Penalties should exist for failure to comply with food safety standards.
- The standards to be met should be those of a recognized international body such as the FAO/WHO Codex Alimentarius.
- No seafood export licence shall be issued unless a processor has in place an effective HACCP system.
- To meet US requirements, it may be necessary to require HACCP plans to be prepared and monitored by persons appropriately trained in HACCP.
- Inspectors shall carry out regular monitoring of a processor's HACCP system to ensure that it is being implemented effectively.
- Documentation accompanying seafood exports must accurately reflect the conditions and activities related to the product, for example:
- the product was produced by a processor who has and implements a HACCP plan; and/or
- the product was inspected visually and found to be wholesome; and/or
- the product was produced by a processor possessing a seafood export licence, which means the product of this processor is regularly inspected for chemical, physical and microbial contamination.
The consultant recommended that:
factory quality assurance staff be trained in HACCP food safety principles and practical implementation, utilizing the curriculum of the US Seafood HACCP Alliance for Training and Education for most seafood exporting establishments, and more advanced training for more technically demanding operations such as fish smoking;
- factory production workers be trained in basic hygiene, HACCP and SSOP; and that
- exporters be provided with up-to-date information on the implementation of HACCP by seafood importing countries, suggesting that this should be done through regional government or industry bodies or the South Pacific Commission.
The following recommendations were agreed upon during the meeting:
- The organization of training activities, a number of which were either under way or planned, and the provision of HACCP specialists to assist regulators and exporters, was considered an important and valuable area of support to the exporters and regulators alike and should be continued.
- An evaluation of the way the US FDA HACCP Regulations are being applied following implementation in December 1997, should be made in six months to assess whether new responses and activities are required from the regional organizations, exporters and regulators.
- The South Pacific Commission should take the lead role in HACCP programming in the region and be responsible for keeping the countries and territories informed of changes and new developments in the US FDA's position on HACCP. In addition, it was requested that HACCP assistance become a priority area for the SPC Post-harvest Section's work programme.
- Sample letters, drafted during the meeting, that could be used by regulatory authorities in the Pacific for the purpose of notifying importers and US FDA of actions taken to help meet US HACCP requirements were considered to be sufficiently useful to be included as an annex in the workshop report.
The final activity of the project, the Regional Workshop on the Implementation of Quality Assurance, was held at the beginning of October 1997, well in advance of the introduction of the new regulations by the USA. This workshop successfully brought to the attention of the governments and industry the new standards that would be required, and prepared the way for change. As a result of the project, and other activities that it catalyzed, there is a high level of confidence in the region that the new higher standards can be achieved. Immediately following the project, and directly resulting from it, in-country training workshops on the development of HACCP plans were organized for the industry, including relevant government departments, in Samoa (13-17 October) and Fiji (22-24 Oct), with inputs sourced from the FAO Sub-regional Office in Apia, the FAO Regional Office in Bangkok, the South Pacific Project Facility and the Government of Fiji. A further workshop for Tonga was to be held before the end of November. The SPC was also able to obtain funds from UNDP to employ a consultant to visit processing plants in Fiji, Samoa and Tonga in order to finalize and verify their HACCP plans.
However, this successful conclusion should not give rise to complacency among the governments, as a great deal remains to be done in order to support quality assurance at a national and regional level. Governments will have to provide trained staff and assistance to industry as well as rapidly ensure that arrangements for HACCP verification and third party audit are in place.
DOCUMENTS PREPARED DURING THE PROJECT
Hazard Analysis and Critical Control Point (HACCP) for Seafood Exports: The Situation in Selected Pacific Island Countries. Technical Report 1. R. Gillett, 1997. 55 pp., plus appendices.
Hazard Analysis and Critical Control Point (HACCP) for Seafood Exports: South Pacific Region. Generic HACCP Plans. Sanitation Standard Operating Procedures. Technical Report 2. D. Graham, 1997. 92 pp.
Seafood Safety Standards (with special reference to HACCP): Review of the Import Regulations of the US and EU and the Relevant Laws of the South Pacific Region. Technical Report 3. T.L. McDorman, 1997. 98 pp., plus annexes.
Workshop Report: FAO/SPC Regional Workshop on the Implementation of HACCP-based Quality Assurance for Seafood, Pacific Harbour, Fiji, 30 September to 3 October 1997. Technical Report 4. S. Roberts, J.L. Sumner and D.G. James.
