Fish and Fish Products – Processing Including Pre-Processing
Receiving of Incoming Material:
There should be written specifications/quality standards for all incoming materials – fish and shellfish, ingredients and packaging materials.
Aqua Inputs used in aquaculture farms should be on CAA approved list and Aqua Feed from BIS.
For e.g. In case of Shrimps: to be procured from farmers registered under:
Marine Products Export Development Authority (MPEDA),
Coastal Aquaculture Authority (CAA) or
State Fisheries Department.
There should be written specifications/quality standards for all incoming materials –ingredients and packaging materials.
Suppliers of raw materials and ingredients should be evaluated regularly and must be FSSAI registered/Licensed.
Materials on receipt shall be inspected and those complying with the specifications should be accepted into the processing facility and non-conforming materials should be rejected and proper records should be maintained thereof.
Immediately on receipt, Fish/Shell Fish shall be washed or cleaned to remove soil or other contaminants using potable water.
Recommended that temperature of fish at the time of delivery should be in the range of 0°C to +4.0°C in case of chilled and -18°C or below in case of frozen.
All packaged raw materials shall be checked for ‘expiry date’/’best before’/’use by date’.
The incoming vehicles that bring the raw material should be checked for cleanliness and hygiene i.e. the trucks are clean, with no pests or dirt, with no strong odour and does not contain materials other than the raw material.
To prevent cross contamination, the raw material receiving station shall be separate with adequate space to receive and store raw material in chilled conditions.
Storage of Raw and Packaging Material:
Fish/ Shellfish should be stored such that damage from over stacking or overfilling of boxes will be prevented and should be kept in shallow layers surrounded by sufficient finely divided ice or with a mixture of ice and water before processing.
The temperature of the fish should be maintained between 0°C and +4°C in case of chilled and -18°C or below in case of frozen.
Ingredients and packaging materials should also be stored appropriately in terms of temperature and humidity and protected and segregated to prevent cross contamination.
A fish processing establishment shall store raw material and packaging materials in appropriate dry and ventilated areas for effective protection from dust, condensation, drains, waste and other sources of contamination during storage.
Packaging material storage room should be closed from all sides to restrict entry of flies, rodents, birds, insects/pests etc.
Storage of raw material/ ingredient, /packaging material shall be done as per FIFO (First in First Out) / FEFO (First Expire First Out) stock rotation system, as applicable.
The food materials/ ingredient/ packaging material shall be stored on racks/ pallets such that they are stored off the floor on pallets and off the walls to ensure easy and adequate cleaning and prevent harboring of any insects, pests or rodents.
The storage of raw, processed, semi processed, rejected, recalled or returned materials or products, shall be made separately and properly segregated. These areas shall be marked for identification and shall be secured.
All raw materials/food additives and ingredients shall be stored separately from printed packaging materials, sanitary, hardware and cleaning materials/chemicals
Allergen Management:
Major Allergens are –
Cereals containing gluten; i.e., wheat, rye, barley, oats, spelt or their hybridized strains and products of these;
Crustacean and products of these;
Eggs and egg products;
Fish and fish products;
Soybeans and products of these;
Milk and milk products (lactose included);
Peanut, tree nuts and nut products; and
Sulphite in concentrations of 10 mg/kg or more.”
Paste list of allergens at the relevant places in the processing areas for awareness among all the employees.
The allergens may include:
All that are used intentionally
Unintentionally (staff food, via contractors, transport, neighbours (air borne, etc.)
Allergen Control and Management
Supplier monitoring
COAs should be obtained for all allergens from the approved suppliers.
When reviewing specifications, the responsible person should look for formulations of the listed ingredients of the raw material.
Plant traffic flow
Maintain all ingredient flow during the manufacturing from non-allergen using areas to allergen using areas. This will help prevent cross-contamination.
Raw material storage
All raw materials that are allergens should be labelled with a tag that states “allergen.” The label can be made Bold and with Bright colour for quick identification.
Store all allergic foods or ingredients to a designated and separate area. For partially used allergic packets, the production staff should ensure the partially used packet should be stored separately and completely sealed and identified with label.
Color-coding charts can also be placed throughout the production area, especially above all wall-mounted equipment and near storage areas for easy identification by plant personnel
Colour coding system for allergen specific utensils
Dedicated scoops and utensils shall be used for specific allergens.
Bright colours and words can be used for easy identification of different allergens.
Production scheduling and Cleaning
Thorough cleaning should be there between allergic containing product manufacture and non-allergic containing product manufacture.
Process should be there to ensure any allergen residues on the production line.
Preferably products containing non-allergen ingredients should run before the product containing allergic ingredients.
When production scheduling and cleaning operations are not performed between allergen containing production runs, allergen testing must be performed. For. E.g. ELIZA test kits are used to verify.
Packaging of Fish and Fish Products and Warehousing:
Fish and Fish Products Packaging
The packaging design and materials shall provide protection for products in order to prevent contamination, damage and accommodate required labelling as laid down under the FSS Act & the Regulations there under.
Only Food grade packaging materials as specified by FSSR regulation shall be used. Usually, food grade polythene film is used in all the different procedures of packing.
Packing material should confirm FSSAI regulation i.e. Food Safety and Standards (Packaging and Labelling) Regulations, 2011 and regulation made there under. Packing should be covered and secured to prevent spoilage and contamination during transit and storage.
Packaging section to be considered high care zone & access restricted & controlled via changing facility
Clean protective clothing & footwear to be worn before entry
Daily internal Calibration & recording of packaging equipment like weighing scales.
Packaging Process steps to be performed without any delay to avoid contamination
Non-toxic PM or gases to be used to not pose threat to the safety and suitability of processed product
Labelling –
Product labelling must confirm the requirement laid down by Food Safety and Standards (Packaging and Labelling) Regulations, 2011 and and regulation made there under.
Product Label minimum should contains below information as required by FSSAI
The Name of Food
List of Ingredients
Food Category number & Name
Nutritional information
Declaration regarding Veg or Non veg
Declaration regarding Food Additives
Name and complete address of the manufacturer with FSSAI Numbers
Net quantity in terms of Weight, Number or litres
Lot/Code/Batch identification
Date of manufacture or packing
Best Before and Use By Date
Country of origin for imported food
Instructions for use etc.
Rework and control of Non-Conforming Products:
Rework management
Rework shall be stored, handled and used in such a way that product safety, quality, traceability and regulatory compliance is maintained.
Rework shall be clearly identified and/or labelled to allow traceability. Traceability records for rework shall be maintained (e.g product name, production date, shift, line of origin, shelf life etc.).
When rework activities involve removing a product from filled or wrapped packages, controls shall be put in place to ensure the removal and segregation of packaging material and to avoid contamination of the product with extraneous matter.
Stored rework materials shall be protected from exposure to microbiological. Chemical or extraneous matter contamination.
If rework is incorporated into a product as an ‘in process step’, the acceptable quantity, the process step, method of addition, type and conditions of rework, including any necessary pre-processing stages, shall be defined.
Non-conformance handling
A non-conformance could be identified through-
customer complaints, o internal audits,
external audits,
incoming material inspection
or simply during normal testing and inspection activities.
All non- conformance incidents should be recorded and assessed.
There should be a defined storage area and handling procedure for non- confirming raw material, packing material and finished goods.
Transportation and distribution of Fish and Fish Products:
All the transportation systems are expected to maintain the temperature of the fish and fish products within close limits to ensure its optimum safety and recommended shelf life. It is important that the fish and fish products is at the correct temperature before loading since the refrigeration systems used in most transport containers are not designed to extract heat from the product but to maintain the temperature of the product. In large containers used for long distance transportation, food temperature can be kept within recommended frozen temperature (at or below minus 18 degrees Celsius for frozen and at or below 4 degrees Celsius for chilled products). Transportation systems should be properly calibrated as well as licensed under FSS Act’2006.
The dispatches of finished goods must follow FIFO or FEFO (First Expiry First Out) system.
Vehicle inspection shall be in place.
Conveyances and/or containers or tankers used for transporting Fish and Fish products shall be kept clean, hygienic and maintained in good repair condition. Where direct contact with Fish can occur such as during bulk transportation, the materials used in carrier construction should be suitable for food contact.
Appropriate measures should be applied to minimize damage to products and to ensure packaging integrity.
Facilities for recording temperature or data logger should be present.
Ensure loading and unloading methods does not contaminate the product. The containers have to be clean and disinfected before loading.
While loading in the refrigerated containers, the temperature in the container has to be brought to – 12°C (Precooling) so that there is no thawing of the frozen product cartons while they are loaded. However, in case of chilled products, pre-cooling temperature shall be at or below 4°
Avoid thawing of frozen fish and fish products cartons during loading
After loading, the packaged fish and fish products shall be transported under hygienic conditions and at appropriate temperature that can be monitored at frequent intervals (Frozen at or below -18°C and chilled/fresh product at or below 4°C at all times).
Effective cleaning and sanitation of containers between loads when used for transporting non-food items.
Where conveyances and/or containers are used for transportation anything other than foodstuffs or for transporting different foods, there shall be effective cleaning between loads to avoid risk of contamination.
The transport vehicle should be examined for possible cross-contamination of ready-to-eat fish and fish products by raw fish and fish products
