|Fish Handling, Preservation and Processing in the Tropics: Part 2 (NRI)|
Food laws deal primarily with two areas of food quality:
1. SAFETY of food: the law protects the consumer's health, e.g., by ensuring that reasonable standards of hygiene are practised and that food additives and contaminants are controlled.
2. COMPOSITION of foods: the law protects the consumer against fraud, e.g., by preventing:
(a) the sale of adulterated, impure or low quality foods,
(b) the sale of food which is of short weight, and
(c) extravagant claims being made on labels or in advertisements.
The main concern of the law maker is, therefore, to produce laws for the safety, identification, compositional quality, labelling and advertising of foods, both to inform and protect the consumer and to sustain a fair basis for honest trading.
In addition to statutory food laws which are legally binding in the countries in which they are passed, various national and international standards and codes of practice exist which are predominantly voluntary or recommended.
An exporting company, therefore, needs to be aware of:
(a) The relevant national legislation of the consumer country to which the product is being exported.
(b) Any recommended international standards or codes of practice which may be applicable.
It must be emphasised that legislation is not usually simple and may vary significantly from one country to another. Legislation is never static: it is constantly being revised and updated in all countries of the world. It is, therefore, essential to obtain up-to-date information on any changes likely to affect product standards.
The objective of the following information is to be illustrative rather than comprehensive. Detailed regulations may be obtained from national Ministries and summaries are often compiled by relevant Food Research Associations.
Regarding international standards and codes of practice, most countries have a Codex Alimentarius Contact Point where information should be available.
The Codex Alimentarius Commission
The main international food standards organisation is the Codex Alimentarius Commission which was set up in 1962, under joint auspices of the two United Nations bodies:
(i) The Food and Agriculture Organization (FAO) and
(ii) The World Health Organization (WHO).
Membership of Codex is open to all countries who are members of either FAO or WHO but, in practice, only about 40 - 50 countries are regularly represented at the Codex annual meetings.
Purpose of Codex
Its purpose is to develop international food standards which can be agreed and adopted on a world-wide, regional or group-of-countries basis. These food standards aim at protecting consumers' health and ensuring fair practices in the food trade. Their publication is intended to guide and promote the elaboration and establishment of definitions and requirements for foods, to assist in harmonisation of standards between countries and, in so doing, to facilitate international trade by removing technical barriers.
Scope of Codex
Ultimately, it is hoped to produce standards for all the principal foods, whether processed, semi-processed or raw. Codex documents also include provisions in respect of food hygiene, food additives, pesticide residues, contaminants, labelling and presentation, and methods of analysis and sampling.
The Commission has established various specialist committees to deal with separate areas. These are of two types:
1 Commodity committees
Fish and fish products (Norway)
Fats and oils (United Kingdom)
Meat and meat products (West Germany)
Poultry and poultry meat (USA)
2 General subject committees
Pesticide residues (Netherlands)
Analysis and sampling (Hungary)
General Principles (France)
The responsibility for running each committee and for piloting standards through the various stages is taken by the member government responsible for that particular committee (given in brackets above).
Currently, many countries are collaborating in the drafting of comprehensive minimum standards for a wide range of fishery products. Almost all are for products meant for direct sale to the consumer. In order for a 'Recommended International Standard' to be agreed it must pass through a complicated 10-step procedure. Following various draft stages the final standard is eventually submitted to governments for their formal acceptance (step 9). The 'recommended standard' is then published as a Codex standard when the Commission determines that this is appropriate, in the light of the acceptances received (step 10). The assumption is that standards acceptable on a world-wide basis and published as Codex Alimentarius standards will be legally binding in those countries operating them. It has been possible to reach agreement on such matters as hygiene, contaminants and specifications for defects. However, there is still considerable disagreement on numerical methods for measuring staleness, chemical deterioration or microbiological contamination. Thus, for example, there are still no internationally agreed microbiological standards for fishery products.
Codex Recommended International Standards for Fishery Products
Recommended International Standards have been produced for,
Canned shrimps or prawns
Canned Pacific salmon
Quick frozen gutted Pacific salmon
Quick frozen fillets of Ocean perch
A typical standard document will include the following:
1. Name of standard
Should be clear and concise, and should normally be the common name by which the commodity is known.
Should contain a clear statement as to the food or foods to which the standard is applicable.
Should contain a definition of the product, with an indication of the raw materials, processing, types and styles, and form of pack.
4. Essential composition and quality factors
Should give detailed quality specifications of all controllable quality factors, with tolerances where appropriate, e.g., odour, flavour, texture, size designation etc.
5. Food additives
Should give names of additives permitted and, where appropriate, maximum amounts permitted.
May highlight special problems. Should refer to WHO limits for contaminants.
The product should be prepared in accordance with the appropriate sections of the General Principles of Food Hygiene as recommended by the Codex Committee on Food Hygiene.
8. Weights and Measures
Should give minimum total fill and minimum drained weight.
Should be in accordance with the 'Recommenced International General Standard for the Labelling of Prepackaged Foods'.
10. Methods of analysis and sampling
All methods should be endorsed by the Codex Committee on Analyses and Sampling.
Sampling is usually in accordance with the document 'The Sampling Plans for Prepackaged Foods (1969)'.
FAO Codes of Practice
In addition to the Codex Alimentarius Recommended International Standards for fishery products, a comprehensive and widely used set of Codes of Practice has been compiled by the Fisheries Products and Marketing branch of the FAO Department of Fisheries, advised by an ad hoc Consultation of international experts.
These voluntary codes are meant to provide technical guidance to manufacturers wishing to make products which meet Codex Alimentarius Standards.
Codes have been prepared for:
(i) Fresh fish (FAO Fisheries Circular 318)
(ii) Frozen fish (FAO Fisheries Circular 145)
(iii) Smoked fish (FAO Fisheries Circular 321)
(iv) Canned fishery products (FAO Fisheries Circular 315)
(v) Salted fish (FAO Fisheries Circular 336)
A typical code-of-practice document contains sections on:
(iii) raw material and ingredient requirements
(iv) handling and processing requirements at sea and on shore
(v) end-product specifications.
Governments of all countries recognise that they must assume ultimate responsibility for health. Thus, public health problems arising from the consumption of fish products are embraced by the national or local food laws; these are usually enforced by a team of official inspectors whose responsibilities, in addition to hygiene surveillance, may include ensuring absence of parasites, certain chemicals or pathogens in fish products.
Most governments also assume responsibility for ensuring the operation of fair trading practices which affect the fish industry, e.g., correct descriptions, labelling, weights and measures, etc.
There is still disagreement on use of certain additives in fish products, e.g.
- Traditional preservatives such as salt, vinegar and smoke compounds are usually permitted, but antibiotics such as tetracyclines may be banned.
- Colouring matters (from a permitted list) are often not permitted in raw or unprocessed fish but may be allowed in certain processed fish products. Different countries have different permitted lists.
- Use of polyphosphates is controlled by many countries and maximum limits are set.
- Use of permitted antioxidants in fatty fish may be allowed.
Canada probably has the most highly developed and extensive system of official inspection for fish products of any nation. On arrival at port, all types of fresh fish are graded into three freshness grades. A somewhat similar compulsory system is in operation for the canned salmon industry using a relevant grading scheme. Canada also has a comprehensive set of mandatory standards for most commercial fish products. These are very detailed, usually with two acceptable grades, and are drawn up by the Fisheries and Marine Service (Department of the Environment).
The Food and Drug Administration (FDA) is engaged in the formulation of processing standards, in the inspection of imported products and in the public health surveillance of processing establishments. USA product 'grade standards', using a three-grade system, have been drawn up for most of the 15 or so major frozen products sold by the National Marine Fisheries Service in conjunction with industry and other interested parties.
Mandatory inspection of chilled and frozen fish landed at Japanese ports from fishing vessels is carried out by highly trained officials employed by the Food Inspection Service. The aspects included are:
(i) checking for spoilage or contamination;
(ii) bacterial testing of raw shellfish;
(iii) ensuring that edible fish containing poisonous organs are identified and segregated;
(iv) ensuring that adequate sanitary conditions prevail.
Detailed mandatory standards issued by the Ministry of Agriculture are also in force in conjunction with compulsory inspection of exported canned and frozen products. The canned product standards are two-grade, while those for frozen products are minimum standards. Similar standards are used for products within the country.
Various regulations lay down the exact way in which the fish should be gutted, bled, washed, iced, stowed, dried, salted, frozen, cold stored and transported. In addition, compulsory standards of construction of vessels and premises, and of cleanliness, hygiene and sanitation are prescribed.
Detailed two-grade mandatory standards have been drawn up for approximately 15 canned products. They are used as the basis for inspection by the Quality Control Institute for Canned Fish Products.
European Community (EC) countries
The arrangements for inspecting fish and fish products in the nine EC countries are very varied. Denmark probably has the most highly developed system of official inspection.
Inspection of chilled fish invariably occurs during laying out for auction at the main port markets. Inspection, carried out by public health or veterinary officials, is of three kinds:
(i) To ensure that fish unfit for human consumption is identified and discarded.
(ii) To ensure good general standards of preservation and sorting on fishing vessels and at point of first sale.
(iii) To supervise and control grading into defined categories of size and freshness.
A mandatory regulation controls the grading system at first sale of chilled fish. The fish must be sorted into three freshness grades and, depending on species, into several size grades. However, this scheme has still not been fully adopted at all ports and landing places.
Inspection for public health aspects of chilled, frozen or processed fish may also be carried out at ports of entry, in factories, at inland markets or at retail outlets.
The general aim of the Community is to harmonise legislation
throughout the nine countries, so that legal barriers to the free movement of
goods within the Community can be effectively removed. However, progress towards
this ideal remains slow.
(b) United Kingdom
In the UK, the White Fish Authority and the Herring Industry Board have jointly published detailed minimum standards for a range of chilled and frozen products.
Various codes of practice have also been published jointly by the Ministry of Agriculture, Fisheries and Food and the Department of Health and Social Security relating to hygiene in the retail industry and in transport and handling of fish. These are complemented by the British Standards Institution's 'Recommendations on cleaning in the fish industry' (BS 4259/1968). The UK Association of Frozen Food Producers have also published a code giving recommendations for the handling, production, distribution and retailing of frozen food, much of which is relevant to the frozen fish industry.
UK legislation also covers minimum compositional standards for fish pastes, spreads and fish cake products, and controls the addition of colouring matters, preservatives and antioxidants.
The labelling of food regulations clearly define which species of fish can be used for a particular 'appropriate designation'.
Finally, the general provisions of the Food and Drugs Act offer general protection to the consumer concerning safety and composition of fish products while weights and measures is also thoroughly covered by legislation.
The increasing number of standards for fish products reflects a growing interest in, and movement towards, the standardisation of foods generally. If a company is to compete successfully in world markets it must increasingly be aware of national and international quality requirements.
1. CONNELL, J. J. (1975) Control of fish quality. West By fleet, Surrey: Fishing News (Books) Ltd., 179 pp.
2. BRITISH FOOD MANUFACTURING RESEARCH ASSOCIATION. Overseas Food Legislation Manual. Leatherhead, England: British Food Manufacturing Research Association.
3. KREUZER, R. (Ed.) (1971) Fish inspection and quality control. Published by arrangement with the Food and Agriculture Organization of the United Nations, Rome. (FAO). West By fleet, Surrey: Fishing News (Books) Ltd.
4. SHEWAN, J. M. (1974) Microbiological standards for frozen fish - a help or a hindrance. In: Symposium on freezing, Institute of Food Science and Technology, London.
5. EUROPEAN ECONOMIC COMMUNITY. (1973) Secondary legislation of the European communities. Volume 24: Fisheries.
Food Hygiene (General) Regulations 1970.
Code of Practice - Hygiene in the retail fish trade.
Code of Practice - Hygienic transport and handling of fish.
Food and Drugs Act 1955.
Weights and Measures Act 1963.
Fish and Meat Spreadable Products Regulations 1968.
Food Standards (Fish Cakes) order 1950.
Labelling of Food Regulations 1970.
Colouring Matters in Food Regulations 1973 and amendments.
Preservative in Food Regulations 1975.
Antioxidant in Food Regulations 1974.