Strategies for food safety and quality

Hazard analysis and critical control point (HACCP)

By the end of the 1980s, developed countries arrived at the conclusion that classic food inspections, based on the analysis of samples of the final product and on generic hygiene measures, were not enough to provide the necessary level of protection to consumers.

Inspection needed to address all the relevant hazards in food production and therefore had to be incorporated into the harvesting, processing and distribution of fish products. The system that was eventually developed was called “Hazard Analysis and Critical Control Point” (HACCP). In the HACCP system, each substance, micro-organism, pest, or condition which can contaminate the food is identified and called a “hazard”. By the beginning of the 1990s, developed countries were already applying HACCP on a voluntary basis. In 1997, it was incorporated into the WHO/FAO Codex Alimentarius in the form of a general guideline; subsequently, the system was officially adopted, and governments started to change their regulations accordingly (FAO 2000).
The plethora of regulations, agreements and guidelines concerning the safety of aquaculture products around the world has become a rather complex matter, as there are many international and national texts. The relevant internationally agreed texts are the GATT Agreement on the Application of Sanitary and Phytosanitary Measures (GATT 1994) and the basic Codex Alimentarius Commission (CAC) texts on food (including fish) safety. There are also FAO and WHO texts of particular relevance to farmed fish, such as the FAO aquaculture guidelines (FAO 1997b) and the food safety issues discussed in a paper by FAO/NACA/WHO (1999). A specific section for aquaculture will be adopted in the Code of Practice for Fish and Fishery Products of the Codex Alimentarius (http://www.codexalimentarius.net).

At the national level, many countries have now adopted specific HACCP-based regulations regarding the safety of fish and fish products, including the products from aquaculture. Approximately 65% of the total international fish trade is now carried out under HACCP-based regulations. Regional regulations also exist. For example, there are a series of directives in the European Union that enforce the use of HACCP systems. Directive 91/493/EEC of July 1991 lays down the hygienic conditions for the production and placement of fishery products on the market; 93/43/EEC (14 June 1993) is also applicable to fishery products; and the Commission Decision 94/356/EEC (20 May 1994) sets detailed rules for the 1991 directive, with regard to hygiene checks on fishery products, to ensure that producers follow and adhere to the requirements of the EU.
Regulations are changing very quickly; further changes and new regulations are likely in the next few years. Moreover, the HACCP-based regulations of different countries are not fully equivalent from the point of view of the analysis of regulatory texts. Future regulations will tend to include either direct quantitative risk analysis of the relevant hazards associated with a given product, or some indirect measurement of those risks (Lupin 2000).

The application of the HACCP system to capture-based aquaculture

While the implementation of HACCP-based food safety assurance programmes is well advanced in the fish processing sector, their application to fish farming generally (including capture-based aquaculture) is still in an early phase. The lack of scientific data regarding the effectiveness of the on-farm control of pathogenic micro-organisms is one of the problems that cause the insufficient application of HACCP in capture-based aquaculture.
A prerequisite for implementing an HACCP system in any fish farming operation is compliance with the principles of good aquaculture practice, sometimes known as best management practices (BMP). Good aquaculture practices can be defined as those practices necessary to produce high-quality products conforming to food laws and regulations of the intended marketing country. Governments should strive to promote the use of such practices through the education of farmers and the promotion of food safety procedures.
The successful application of HACCP requires the full commitment of the owner of the fish farm, together with its workforce and expert team (Figure 150). It is necessary to examine carefully the nature and extent of any hazards associated with products from aquaculture, and their methods of production. The first step is to assemble an HACCP team that should include experts in all the activities related to fish farming. This multidisciplinary team should consist of experts in aquaculture, fish farm management, fisheries extension, public health, parasitology, and fish inspection and quality control. The second step involves a description of the product and its intended use by the purchaser. The intended use may include processing as value-added products or consumption after cooking. The third step involves designing a flow diagram. The fourth step involves the on-site confirmation of the flow diagram approach. Finally, the fifth step consists of the application of the seven principles of the HACCP system (FAO/NACA/WHO 1999), adapted to production from capture-based aquaculture.

Figure 150. Harvesting of Japanese amberjack in Japan; in future, capture-based aquaculture will apply the HACCP system (Photo: M. Nakada)

There is an excellent text available from EUROFISH, in conjunction with SIPPO (the Swiss Import Promotion Programme) called “Guide to Hygiene within the Fish Industry” (J. Dallimore, pers. comm. 2002) that details all of the requirements for HACCP accreditation, and is full of illustrations showing the requirements in action.
An effective HACCP system must control the production and delivery of products from the first day that the fish are held in captivity until they are delivered to the consumer. The documentation must allow full traceability. The systematic procedure for setting up an HACCP system is as follows:
? analyse the complete production process and estimate the probability of a hazard occurring, and the risks involved. In capture-based aquaculture there are six main areas of concern: collection, on-growing, harvesting, packing and processing, delivery, and point of sale;
? determine the Critical Control Points (CCPs) that may be present in the system. These may include the quality of the trash fish used as feed, harvesting operations, hygiene in the packing area, temperature control levels, etc.;
? specify the limits which, when adhered to, will guarantee that the CCPs are under control (e.g. fresh fish always to be kept below 5°C after harvest);
? establish protocols and documentation for monitoring the CCPs;
? develop and specify corrective actions when monitoring reveals that a CCP is no longer under control;
? establish procedures for modification that include supplementary tests and procedures to confirm that the HACCP system is working effectively;
? develop a complete documentation system that records all of the stages necessary to the system.
It must be noted that to establish and maintain an HACCP system is a complex and time consuming operation, but one that must not be ignored. It is suggested that all companies employ a consultant experienced in HACCP systems to evaluate the CCPs needed, and to provide training to management and staff to ensure that the criteria in the system are met.

Environmental certification and its application to capture-based aquaculture

Environmental certification of aquaculture is increasingly seen by many as a multipurpose instrument. It represents a means for aquaculturists to produce value-added farmed organisms and a means for environmentalists to increase the level of environmental awareness and protection in the industry. An environmentally certified product gives consumers assurance on quality and some sensitivity to the way that the product is produced. Consumers can then make informed purchases; this can constitute a method for minimizing the risk faced by retailers of being accused or found guilty of supplying products that are produced in an environmentally unsustainable way (Mallows 1999). Such considerations should be also applied to the products of capture-based aquaculture.
Currently, the driving force behind eco-label initiatives derives mainly from Agenda 21 of the UN Conference on Environment and Development held in Rio de Janeiro, Brazil in 1992 (www.un.org/esa/sustdev/agenda21.htm), which were reinforced by the fisheries agreements that were achieved during the 2002 Summit in Johannesburg (www.johannesburgsummit.org). Many NGOs have taken up this topic; some of their views are extreme; others are more balanced. For example, a report on aquaculture for a US-based NGO, the Environmental Defense Fund (EDF) presents recommendations for the private sector of aquaculture, such as “Organic certification and potentially other eco-certification programmes should be established that empower consumers to choose aquaculture products grown in an environmentally sound manner…” (www.edf.org).
The labelling of a product as “environmentally certified” is based on an assessment of its entire cycle, extrapolated both upstream and downstream, and is dependent on a systems approach, e.g. Environmental Management System (EMS) to production, distribution and marketing. There are two main standard systems specifications for implementing an EMS: the ISO (International
Organization for Standardization) 14000 series and the EU-accredited Eco-Management and Audit Scheme (EMAS). Neither is legally binding. The ISO series is still being developed, and its components include standards for Environmental Auditing (ISO 14010-14013), Environmental Site Assessments (ISO 14015), and Eco-labelling and Self-declaration Environmental Claims
(ISO 14020-14024). The main certification criteria involve the development of an EMS. The required components for ISO certification are included in ISO 14001. For initial design, development and implementation, an EMS ISO 14004 can be used, as it consists of a set of guidelines rather than a full auditable certification criterion (Mallows 1999).
Eco-labelling is currently gaining acceptance in USA and EU markets. The Marine Stewardship Council (MSC), an organization supported by commercial interests that promotes the sustainable exploitation of the sea, has considered extending its eco-labelling system for capture fisheries to aquaculture (M. New, pers. comm. 2003). A certification system designed specifically for aquaculture has been developed by the Aquaculture Certification Council (ACC), but is currently confined to marine shrimp and prawns (ACC 2003); this initiative has its origins in a producers organization, the Global Aquaculture Alliance (GAA) and may therefore be subject to scepticism about its independence.
Recently, ecolabelling has become a major issue in the USA where the public is informed in restaurants and information points (such as university aquariums) under the Seafood Watch Program. Products are graded as “best choices”, “proceed with caution” and “avoid”, and in restaurants the consumer is also advised if a fish product is “environmentally sustainable”. Capture-based aquaculture will need to address these issues where products are sold in these sensitive main markets (www.intrafish.com/articlea.php?articleID=25219).
In response to growing public concerns about food quality, two of Japan’s biggest supermarkets, Aeon Co. (formerly Jusco) and Ito-Yokado Co., plan to improve the information provided on fish labels. The labels will include information on the origin of the fish, including “production histories” covering data on the farming area, the farming company and the feedstuffs used. Aeon Co. began this programme by labelling eel products in May 2002. By 2003, it planned to include other farmed fish such as yellowtails. It will also provide details of its own management of the fish farming process, and display information on whether its fish have been given anti-infective drugs (www.asahi.com/english/business/K2002032700610.html).
In 1995 the Food and Agriculture Organization of the United Nations (FAO) adopted a Code of Conduct for Responsible Fisheries (FAO 1995). The CCRF sets out principles and international standards of behaviour for responsible practices, with a view to ensuring the effective conservation, management and development of living aquatic resources, with due respect for ecosystem and biodiversity. The Code recognises the nutritional, economic, social, environmental and cultural importance of fisheries (including aquaculture practices), and the interests of all those concerned with the fisheries sector. The CCRF takes into account the biological characteristics of the resources and their environment, and the interests of consumers and other users. The Code is not legally binding, but FAO Member States and all those involved in fisheries are encouraged by FAO to apply it.
The feasibility of implementing a certification scheme in an aquaculture operation can be compared to other similar situations. Quality assurance, together with safety assurance such as HACCP, can be integrated quite simply with certification criteria; it is easier to incorporate existing quality and safety schemes into something new, such as a certification system, than to try to add a certification process to an existing assurance scheme. The inclusion of documentation on traceability is also essential for insurance purposes. The problem that must be addressed is performance monitoring (use of resources, waste discharge, etc.). By using a
separate organization to verify certain aspects of aquaculture production, the farm and the certifiers must both ascertain whether performance targets are being achieved and maintained. The operator, the regulating body or the certification organization can undertake this monitoring activity, though it would be better if all parties shared the responsibility.

Conclusions

The expanding trade in capture-based farmed species of various ages and life stages for the seafood industry without appropriate health considerations may increase the risk of spreading pathogens that are associated with human illnesses. Little is known about the impact of contaminated food on human health and its epidemiology.

Food safety concerns associated with capture-based aquaculture affect all levels of this activity. Illness caused by the consumption of contaminated food not only has socio-economic consequences (e.g. production losses) but also causes public health concerns. Such problems may seriously affect small-scale farmers, who represent the backbone of many rural communities in Asian aquaculture. Their livelihoods may be threatened through reduction in food availability and loss of income and employment.
The level of hygiene during the production and consumption of seafood in Europe keeps bacterial risks at a low level (Feldhusen 2000). Food-borne sicknesses associated with capture based farmed products could be largely prevented and controlled through appropriate food safety measures. Responsibility for food safety associated with the products from aquaculture is shared between governments, fish farmers, the processing industries, and consumers.
Reducing the number of seafood-related sickness outbreaks worldwide requires continued and coordinated efforts by many different agencies, including those involved with water quality, disease surveillance, consumer education, and seafood harvesting, processing, and marketing (Feldhusen 2000). Where appropriate, the aquaculture sector should institute farm management programmes based on the principles of the HACCP system, which should be applied at all stages from production, collection and transport, to the consumption of food. This would allow a systematic approach to the identification and assessment of the hazards and risks associated with the production, distribution and use of aquatic food. The application of HACCP-based food safety assurance programmes in fish farming is in its early phases (FAO/NACA/WHO 1999). Strategies for food safety guarantees and education must be enhanced among communities where eating raw or inadequately cooked fish is a cultural habit.
Capture-based aquaculture provides opportunities to reduce the risks associated with food safety. For example, in the culture of species where ciguatera is problematic, capture-based farmed species could be “certified” ciguatera-free, so that they would be regarded as a safe source of fish for human consumption (Cesar et al. 2000); this could assist profitable marketing.
The development of certification systems that assure quality and good practices should be advantageous for capture-based aquaculture operations, providing such schemes are manifestly independent and accepted as valid by consumers. Research is also necessary to reduce the risks associated with the feed consumed by capture-based farmed species.