35. The Committee recalled that its last session had agreed that the combined Code for Fresh Fish, Frozen Fish and Minced Fish would be used as a template for the revision of the other codes, and that the countries responsible for individual codes would meet between sessions to coordinate the revision and ensure a common approach. Two Working Groups had been held since the last session, in 1996 in Ottawa, Canada, and in 1997 in Bergen, Norway for this purpose.
36. The Delegation of the United Kingdom presented the revised text, which had been drafted as a result of the decision of the second Working Group to combine all codes into a single document, as it had been recognized that many common elements existed in the codes and that duplication should be avoided. The combined Code included the codes under consideration at the last session: Fresh Fish, Frozen Fish, Minced Fish, Canned Fish, Surimi, Smoked Fish, Salted Fish and it had also been decided in principle to include the codes which had not yet been specifically discussed: Cephalopods, Crustaceans, as well as the Molluscan Shellfish and Aquaculture Codes. In this respect, some delegations suggested that there might be a need for two codes, one for pre-harvest operations and one for processing, and the Committee noted that this might be considered in the future. The Delegation of the United Kingdom pointed out that the purpose of the revision was to make the codes more understandable and easily applicable, as they were intended to facilitate compliance with the relevant Codex standards. The revised text included pre-requisite programmes which were required for the implementation of HACCP principles and of a similar system for quality aspects. The Delegation of Norway asked for a clarification of the status of the Codes of Practice in relation to the WTO SPS Agreement. The Secretariat recalled that the SPS Agreement applied only to measures related to food safety and referred to the letter from the Chairman of the SPS Committee, which clarified that the Agreement did not establish distinctions between Codex standards, guidelines and other texts in this respect.
37. The Committe had a general exchange of views and agreed to the overall approach taken to the revision of the code, and especially the following principles: the incorporation of all current codes into a single text; the use of the code as a stand-alone document without referring to other codes (such as the General Principles of Food Hygiene for general requirements); the use of a system similar to HACCP for non-safety provisions, with the application of Defect Action Points (DAPs). The Committee considered the proposed draft code section by section and made the following amendments.
Introduction - How to use this code
38. The Committee agreed to delete the reference to “HACCP-based principles” throughout the text and to replace it with “a similar approach” to HACCP as the reference to HACCP principles when the HACCP system as such was not applied could be misleading.
Section 1. Scope
39. The exception relating to processing of fish sticks or portions was deleted as it was intended that such products would also be covered by the code.
Section 2. Definitions
40. A reference to a definition for aquaculture was inserted in the general definition, as the relevant code was integrated into the general text. The Committee agreed to use the general Codex definiton of «contaminant» rather than the definition specific to food hygiene, as other types of contamination should be covered.
41. The Committee agreed to refer to “approximately 0ºC” in the definition of “chilled sea water”, in view of the practical difficulties to reach this temperature, and also clarified the definition of “chilling”. The definition of “Disinfection” was amended for consistency with the General Principles of Food Hygiene. The Committee agreed to a definition of “fish” which did not include shellfish. The definition of “Processing facility” was clarified by a reference to “processing vessels”. The Committee agreed that “Validation” should be defined as it was required in the application of the HACCP system.
42. In the section on Fresh, Frozen and Minced Fish, it was agreed that candling applied to «fish or part of fish» according to the size of the fish. In the section on Salted Fish, it was agreed that maturation should be added to the list in square brackets, for further definition. The Committee agreed to put in square brackets the current limit of 2% fat for fatty fish, as it did not seem to correspond to current practice. In the section on Smoked Fish, it was agreed that liquid smoke was also used and its definition should be included in the future. The Committee noted that the definitions relating to Canned Fish should be checked for consistency with the Code of Practice on Low-Acid Canned Foods.
Section 3. Pre-Requisite Programme
43. The Delegation of New Zealand pointed out that some aspects were missing, such as waste disposal and transportation, and that reference should be made to the General Principles of Food Hygiene. The Committee recognized that as a rule the Principles should be followed closely. The Delegation of the United Kingdom indicated that this section had been drafted when the code incorporated only fresh, frozen and minced fish and that further consideration should be given to other relevant aspects of the programme, since the code was intended to apply to all fish and fishery products.
44. The Delegation of Norway expressed the view that the implementation of the programme should be adequately documented; it was noted that this question should be further considered. The Committee agreeed that section 3 would be redrafted along the lines proposed.
Section 4. Principles and Development of HACCP-based Systems
45. The Delegation of the United States proposed to amend the current text to make it clear that the HACCP system and principles as such applied only to safety, while other systems using a similar approach may be used for other aspects. Other delegations supported this position, stressing the importance of safety concerns, and the need to establish a difference with requirements applying to non-safety criteria. In reply to a question, the Secretariat recalled that the first principle of HACCP was to conduct a hazard analysis, which could not apply when the objective was not safety-related. The Committee agreed to refer to the application of HACCP and to «a similar approach involving many of its principles» for a broader application in the Preamble.
Section 4.3 Application
46. The Committee had an exchange of views on the opportunity of requiring the application of a similar approach to HACCP to aspects other than safety, as some delegations felt that this would ensure compliance with quality requirements. The Committee recognized that recommendations could be made in this sense but that definite requirements should apply only to food safety. It was therefore agreed to indicate that «..each facility should implement a food safety management system based on HACCPprinciples, and should at least consider a similar approach to defects, both of which are described in this Code», and other amendments were made to the text in the same perspective.
47. The Committee agreed to retain the flow diagram, as required in the HACCP Guidelines, while noting that it was not mandatory in the legislation of some countries. The Delegation of Thailand pointed out that the inclusion of the DAPs in the same diagram as HACCP may give the impression that they were also required; as it was not practical to split the diagram, a footnote was included to clarify that «a similar approach can also be applied to DAPs». The mention «if required» was added to point 12 on record-keeping for the DAPs.
48. The Delegations of South Africa and Marocco pointed out that the examples might create confusion as the industry sometimes used them as they were; the need to establish specific flow diagrams adapted to the process should be emphasized.
49. In the section on Nematodes, it was proposed to change the temperature from 55ºC to 60ºC, as required in EC legislation and this figure was put in square brackets, as well as the requirement for freezing at -20ºC for 24 hours in the fish core. The Observer from the EC informed the Committee that, according to a report of the Scientific Committee for Foods on nematodes, the presence of Anisakis was not rare but may be misdiagnosed and create allergic reactions. The Committe noted that a combination of salt and acetic acid could also kill nematodes. The Delegation of China pointed out that the intended use of the fish (i.e. cooked or raw) should also be made clear to the consumer. In Table 2, The Committee agreed with the proposal of Japan to list ciguatoxin with chemical hazards and that physical hazards included the presence of metal fragments.
50. As regards the general approach to the revision of section 4, the Committee agreed to:
The Committee also agreed that the titles of specific sections (5 to 13) would not refer to «Application of HACCP to Processing of...» but to «Processing of..» as the application of HACCP was addressed in Section 4.
Section 5. Processing of Fresh, Frozen and Minced Fish
51. The Delegation of the United States pointed out that many elements covered by this section and other similar sections in the Code did not actually relate to HACCP but rather to Good Manufacturing Practice and would be more relevant in section 3, and stressed the need to separate clearly quality from safety aspects.
52. The Delegation of Israel proposed that heavy metals should be considered in the list of hazards. In Section 5.2, the Delegations of South Africa and Thailand expressed their concern with the requirements for a temperature as close as possible to 0ºC, in view of the difficulties to achieve this in tropical conditions. In section 5.3.5, the Committee agreed to indicate that raw materials should be segregated «as appropriate» as different species could be processed together in the production of minced fish.
53. The Committee noted that there were differences in the identification of hazards across the sections, and the degree of precision and detail as to corrective action. The Committee had an exchange of views on the best approach to be followed to list hazards, as some delegations felt that the sections should not be too prescriptive while other delegations stressed that the CCPs should be identified clearly. In order to harmonize presentation, it was decided that the control boxes would be deleted and the flow diagrams would include the relevant reference to hazards. The Committee also recognized that some parts of Section 5 should be transferred to Section 3, as they related to the pre-requisite programme. In relation to section 5 and subsequent sections, the Committee generally agreed to delete the various CCP and DAP boxes; to revise the text parts of the sections and include only GMP requirements in section 3; for the remaining text, to identify those parts relating to safety and those relating to non-safety aspects.
Section 6. Molluscan Shellfish
54. The Delegation of New Zealand pointed out that there were too many CCPs and that they did not always actually correspond to hazards, or did not identify them clearly. The Committee noted that following its decision to delete the CCP boxes, the examples should be reviewed and the various hazards would be identified in the flow diagram.
Section 7. Crustaceans and Section 8. Cephalopods
55. The Delegation of Brazil agreed to undertake the drafting of a section on lobsters and the Delegation of Mexico agreed to continue its work on a section on shrimps and prawns, for inclusion on the general section on Crustaceans. The Delegation of New Zealand agreed to undertake the drafting of a section on Cephalopods, in the light of the decisions of the Committee concerning other sections.
Section 9. Salted Fish
56. In reply to a question on section 9.4.4., the Committee recalled that the general requirement for salted fish was set out in the first indent, whereby maturing time depended on fish, temperature and the amount of salt absorbed, while curing at a temperature of 0 to 50ºC applied only to Clupeidae and Scombridae in order to control the presence of histamine.
Section 10. Smoked Fish
57. The Delegation of Denmark indicated that the corresponding standard would focus on the cold-smoked products as they were the object of significant trade, and the Committee noted that in addition to salmonids, smoked hakes were also concerned. The Representative of WHO however pointed out that there was significant trade in some species of hot-smoked fish exported from South-East Asia and these should also be taken into consideration. The Delegation of Norway pointed out that other hot-smoked products such as mackerel, sprat and herring were found on the market. The Committee confirmed that in any case the code should apply to smoked fish in general, whether hot-smoked or cold-smoked. The Delegation of New Zealand noted that there were inconsistencies between CCPs in the flow diagram and in the control boxes and suggested that this should be revised.
Section 11. Canned Fish
58. The Committee noted that in this section the reference to "canned fish" also included canned shellfish. The Delegation of Japan pointed out the specific hazard related to cooling with water when the cans were not well sealed. The Delegation of France indicated that in the flow diagram this hazard had been taken into account in the CCP on "heat processing", but that it would be identified separately if required as "cooling".
Section 12. Frozen Surimi
59. The Committee noted that the detailed CCP boxes would be deleted and that the flow diagram would have to identify the hazards and CCPs.
Section 13. Aquaculture
60. The Committee confirmed that the definition of aquaculture should cover fish, crustaceans and molluscan shellfish, and agreed that the general FAO definition used in the Introduction was too broad and should be revised as it did not correspond exactly to the scope of the text. The Representative of WHO recalled that the code applied to intensive aquaculture, which was understood as high density farming, with regular stocking from hatcheries, the use of formulated feed and medication, and that the extensive farming systems prevailing in many developing countries was not covered.
61. The Committee recalled that the section on veterinary drugs had been drafted by the Committee on Residues of Veterinary Drugs in Foods. The Delegation of Norway indicated that its national legislation did not allow any detectable residue in fish. The Delegations of Norway and Japan considered that the withdrawal period should be long enough to ensure zero residue levels and that pre-slaughter control was an additional way to ensure compliance. The Observer from the EC pointed out that EC legislation requested a strict control on the use of veterinary drugs, with prescription under veterinary supervision and specific MRLs but no pre-slaughter control.
62. The Delegation of Thailand pointed out that even in the case of intensive aquaculture, record-keeping would not be practical for small farms, and it was noted that the introduction provided for the adaptation of the requirements to local conditions. The Committee noted the proposal of the Delegation of Germany concerning a reference to animal welfare in this section, and that Guidelines had been prepared by the Council of Europe in this area.
Optional Requirements
63. The Committee agreed that the reference to “critical bone” should be deleted, and that the use of merit points for surimi should be clarified.
General Conclusion
64. The Committee expressed its appreciation for the extensive work carried out by the Working Group, the lead countries, FAO and WHO, and recalled that these would proceed with the revision of the code, with the participation of all interested countries, as follows:
|
United Kingdom/Canada |
Frozen, Fresh and Minced Fish |
|
France |
Canned Fish |
|
Netherlands |
Molluscan Shellfish |
|
Japan/USA |
Frozen Surimi |
|
Norway |
Salted Fish |
|
Denmark |
Smoked Fish |
|
Mexico |
Shrimps and Prawns |
|
Brazil |
Lobsters and Crabs |
|
New Zealand |
Cephalopods |
|
Germany/USA |
Frozen Coated Products |
|
FAO/WHO |
Aquaculture |
65. The Committee agreed that the proposed draft, as amended during the present session, would be returned to Step 3 for further comments, especially on the aspects which had been highlighted in the above discussion (see Appendix VI). The comments would be forwarded to the countries responsible for each specific section, who would continue their revision work in the meantime. It was agreed that another meeting of the Working Group would be necessary to coordinate the revision, under the leadership of the United Kingdom, Canada and France, and to prepare a revised draft for circulation well ahead of the next session. The revised draft in Appendix VI should be read in conjunction with the present report, bearing in mind that many sections still need to be extensively reviewed.
