FT 4101 Fish Inspection and Legislation

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FT 4101 Fish Inspection and Legislation

1. a. Why fish is  Good source of animal protein, vitamin and minerals


considered as a high  Good source of omega-3 fatty acids helps in reducing cholesterol and triglyceride
quality food?  Fish peptides acts as functional foods such as reduces the blood pressure, diabetics, cancer and repair skins (beautification),
and maintain good health of the sportsman;
 Tasty and easily digestible

b. Write in brief major  Food poisoning by pathogenic bacteria (Salmonella spp., pathogenic Escherichia coli, Bacillus cereus, Staphylococcus aureus
food borne disease (Staphylococcal enterotoxin (E)), Shigella, Clostridium botulinum Clostridium perfringens.
outbreak occurs after  Ciguatoxin, Paralytic Shellfish Poison (saxitoxin), Neurotoxic Shellfish Poison (brevetoxin), Azaspiracid Shellfish Poisoning
consumption of (AZP) toxins, scombrotoxin (histamine),
contaminated fish  Norovirus, Hepatitis A Virus from clams and oysters

c. Differentiate Infection: A foodborne disease is when a person eats food containing harmful microorganisms, which then grow in the intestinal tract
between food infection and cause illness. Some bacteria, all viruses, and all parasites cause foodborne illness via infection. The foodborne bacteria that cause
and food intoxication infection are: Salmonella spp., Listeria monocytogenes, Campylobacter jejuni, Vibrio parahaemolyticus, Vibrio vulnificus, and
with examples Yersinia enterocolitica.
Intoxication: An intoxication results when a person eats food containing toxins that cause illness. Toxins are produced by harmful
microorganisms, the result of a chemical contamination, or are naturally part of a plant or seafood. Some bacteria cause an
intoxication. Viruses and parasites do not cause foodborne intoxication. The foodborne bacteria that cause intoxication are:
Clostridium botulinum, Staphylococcus aureus, Clostridium perfringens, and Bacillus cereus. Chemicals that can cause an intoxication
include cleaning products, sanitizers, pesticides and metals (lead, copper, brass, zinc, antimony, and cadmium). Seafood toxins include
ciguatera toxin, scombroid toxin, shellfish toxins, and systemic fish toxins. Plants and mushrooms can also cause an intoxication

2. a) List down the Sporeforming bacteria


spore forming and – Clostridium botulinum
non-spore forming – Bacillus cereus
bacteria – Clostridium perfringens
Non-Sporeforming bacteria
– Listeria monocytogenes
– Salmonella spp. (e.g., S. typhimurium, S. enteriditis)
– Shigella spp. (e.g., S. dysenteriae)
– Pathogenic Staphylococcus aureus
– Vibrio spp. (e.g., V. cholerae, V. parahaemolyticus,

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V. vulnificus)
– Others (Campylobacter jejuni, Yersina enterocolitica,
Shigella spp. and Escherichia coli)

b) Write down the Some controls for Clostridium botulinum in seafood:


control measures  Destroy spores during processing (e.g., thermal processing [canning] or proper cooking to destroy the spores).
of pathogenic  Prevent potential growth by proper salting, drying, or pickling (acidification).
bacteria.  Proper refrigeration, particularly for raw, non-frozen seafood packaged in anaerobic conditions (limited oxygen).
 Packaging refrigerated fishery products in permeable film that allows enough oxygen exposure to prevent anaerobic growth.
Some controls for Bacillus cereus, Listeria monocytogenes, Salmonella spp, Staphylococcus aureus, Vibrio cholerae, Vibrio
parahaemolyticus and Vibrio vulnificus

• Proper sanitation to prevent product contamination (product source, process facilities, and personnel)
• Proper refrigeration to prevent growth
• Proper cooking
• Prevent cross-contamination after cooking;
• Product harvested from approved sources;
3. a) List down the Shellfish Biotoxins
naturally • Amnesic Shellfish Poisoning (ASP; domoic acid)
occurring biotoxins • Diarrhetic Shellfish Poisoning (DSP; okadaic acid)
• Neurotoxic Shellfish Poisoning (NSP)
• Paralytic Shellfish Poisoning (PSP; saxitoxins)
• Ciguatera Fish Poisoning (CFP)
• Tetrodotoxins (puffer fish poisoning)
• Scombrotoxins (fish histamine poisoning)

b) List down the Intentionally Added Chemicals:


intentionally or Directly added ingredients (allowable limits under GMPs)
unintentionally  Preservatives (e.g. nitrite and sulfiting agents)
added  Nutritional additives (e.g. niacin)
chemicals/veterina  Color additives
ry drugs in Aquaculture Drugs
fish/shrimp farms, Animal drugs may be used in the raising of aquatic species to:
hatchery and feeds. 1) treat or prevent disease,
2) control parasites,

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3) affect reproduction, and
4) tranquilize.
Illegal residues of drugs may occur in aquaculture species because of the use of unapproved drugs, use of drugs not in accordance with
the approved labeling directions, failure to follow approved withdrawal times, or use of general purpose chemicals not labeled or
approved for drug use. There are only a few approved drugs for aquatic species.
Unintentionally or Incidentally Added Chemicals:
 Agricultural chemicals (e.g. pesticides, herbicides, fungicides, antibiotics, growth hormones) can be acutely toxic if present in
the food at high levels and may cause health risks with long-term exposure.
 Cleaning chemicals (e.g. sanitizers, chlorine, acids, caustics) can cause chemical bums if present in the food at high levels.
 Maintenance chemicals (e.g. lubricants, paints) that are not approved for food use and may be toxic
 Prohibited substances and toxic elements (e.g. lead, zinc, arsenic, mercury, cyanide)
 Polychlorinated Biphenyls (PCBs)

c) Write in brief the Control for shellfish biotoxins in seafood:


control measures • Only harvest approved shellfish products from approved waters
of naturally • Control for ciguatera in seafood: Do not process certain fish harvested from waters that have been designated as potentially
occurring biotoxins ciguatoxic
and unintentional • Control for tetrodotoxin in seafood: Do not process certain fish (puffer fish) that have been designated as potentially
or incidental tetrodotoxic
chemical • Control for potential scombrotoxin in seafood: Temperature controls from the moment of harvest through processing, storage,
contamination of and product distribution
seafood. Control measures of intentionally Added Chemicals
• Directly added ingredients (allowable limits under GMPs)
o Preservatives (e.g., nitrite and sulfiting agents)
o Nutritional additives (e.g., niacin)
o Color additive
o Use proper type and amount of chemicals.
o Label product to inform consumers (e.g., sulfites)
Some controls for use of aquaculture drugs:
• Only use approved chemicals in approved manner.
• When necessary, only use certain controlled drugs in the manner prescribed by a recognized veterinary expert.
• Test for any excessive residuals in final products
Some controls for unintentional or incidental chemical contamination of seafood:
• Proper use of cleaning and maintenance chemicals in the processing areas
• Proper location and monitoring of aquaculture farming operations relative to potential land runoffs and spraying of hazardous

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chemicals.
• Do not harvest from polluted or non-approved waters
• Product screening relative to source
4. a) Write a flowchart
of shrimp supply Farmer
chain
Auction
Faria Auction

Depot
Auction

Commission Agent

Industry

b) What are the  The major problem identified is the collection of raw material through a number of channels: primary, secondary, higher secondary
quality changes of and final stages of delivery to the industry.
shrimp occur at  The post-harvest quality occurs at different stages of handling and transportation, which are as follows:
farms, depot and  At firm
industries?
 farm to depot and
 depot to processing plants/ industries
At Firm:
The major quality loss occurred due to:
 often not washed with clean water;
 longer duration of harvesting;
 exposure of shrimp at high ambient temperature for a long time
 contamination;
 piled up on a dirty floor;
 general lack of hygiene; and
 soaking shrimp in water to increase weight gain.

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At Depot:
The major quality loss occurred due to:
 delayed icing (2-6 hours);
 inadequate ice;
 rough handling and peeled;
 lack of personal hygiene;
 packed under pressure in the bamboo basket;
 contamination;
 not iced until it reaches to collection center;
At processing plants/ industries
The major quality loss occurred due to>
 no fly screen;
 utensil and water are dirty;
 shrimp piled on a dirty floor;
 personal hygiene nonexistent;
 packed under pressure in bamboo basket;
 covered with dirty jute cloths;
 inadequate ice;
 quality defect of incoming shrimp;
 problem in grading;
 incorrect dress of workers and non-use of protective clothing in some plants;
 lack of hand washing facilities and poor toilets in some depot and
 piling up of non-iced shrimp directly on the floor.

c) Write down the  black spot


major causes of  broken
rejection of  soft shell and peeled/rotten
shrimps.  discolor
 molted shrimp
 filth
 dehydration
 foreign material such as push and pieces of iron material
 kerosene
 drip loss due to pressure

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5. Write in brief different Farms: Independent aquaculture producers or part of a company producing chain, which are part to the refereed export destined value
types of establishments chain (under DoF controls).
of Bangladesh dealing
Vessels: Vessels providing to operators that are part of the referred export destined value chain are divided in three groups:
with fish and fishery
products which needs Coastal: Fishing vessels that maintain raw materials in storage for less than 24 hours and preserve catch on Ice.
listing/registration for High seas: Fishing vessels that maintain raw materials on storage for more than 24 hours and preserve catch on Ice, RSW1, or
official control Brine.
Reefers: Vessels providing the service of storing and transporting frozen materials for vessels, and/or processing establishments,
that are part the referred export destined value chain.
Depots, Landing Centres, Auction Centres and Packing Centres
Establishments where aquacultured shrimp and fish are landed or collected or sold for further distribution to the local market or
processing industry;
Packing Centres comprehend the collection of finfish directly from suppliers and middlemen where they pack fish (including live
form) for exporting mostly to regional countries.
Cold / Frozen storage
Independent establishment or part of the company chain of establishment that provide the service of storing or consolidating frozen
materials for vessels and/or processing establishments for direct exporting.
Ice Factories
Independent providers of ice (in any shape or form) to farms, depots, landing centres, auction and packing centres, vessels, and
processing establishments, that are part of the referred export destined value chain.
Transport vehicles
Independent providers or part of the company chain of transport for fisheries products or ice/ or as transportation mean for that are
part of the referred export destined value chain.

6. Write down briefly Submission of application and documents needed for listing and getting approval of a newly established processing industry.
what kind of Fish establishments operating a registered licence or newly established, wishing to be included on the list shall, in the first instance,
documents are complete the application form for Producer / Exporter Registration need approval from CA and will be submitted together with a set
required for listing/ of documentation integrating the following:
licensing and getting  Business Pre-requirements:
approval of a newly  Tax Identification Number (TIN) registration and Value Added Tax (VAT) registration certificate.
established processing  No objection certification from the department of Environment.
establishment by the  Article of Memorandum from the processing establishment.
competent authority  No objection certificate from the department of Industry.

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 Chamber of Commerce Certificate.
 Export Registration Certificate (ERC) and Import Registration Certificate (IRC).
 General description of the company: facilities (construction plants, layout), products and process, number of employees (by section,
task, or processing line and shift, production capacity by product or processing line and the storage capacity.
 The description of operations followed (SOP).
 The documented prerequisite programmes (SSOP), including water/ice quality program (with test report from the Third party)
and also waste water disposal system.
 The HACCP plan (whenever necessary).
 The system to provide guarantees for the product traceability.
 The documented and formalized withdrawal and recall procedures.
 Brand registration certificate
After receiving such documents the CA will carry out a desk audit to detect any missing element or requesting for revising or
completion of the necessary documentation.
Where the CA is satisfied with the documentation received, a full regulatory visit - Full Verification Audit- will take place for
approval of the establishment.
Full Verification Audit
Takes place when is in full operation. It includes an in depth full verification / audit of physical settings, operational conditions and
control strategies, concerning the entire production process, following the Procedure of Regulatory Verification and specific
application of the respective verification / audit forms.
Documentation received previously will be confirmed on-site. Verification / Audit will include checking and evaluation of all pre-
requisite programmes, including:
• The general hygiene requirements and conditions of infrastructure (building and surroundings) and equipment.
• Water supply and water quality management system, detailing the internal distribution net, treatment if any, quality monitoring
plan and related data filing.
• Ice production, internal distribution and quality monitoring The absence of cross contamination / air currents risks / separation
between dirty-clean areas or wet-dry areas (lay-out considerations).
• Personnel health and hygiene control (including training).
• Sanitary filtering of personnel arrangements, toilets and dressing facilities.
• Facilities and equipment cleaning and sanitation plans (methods, schedules, chemicals used and approvals).
• Raw materials acceptance criteria and controls (freshness, temperature, transport, lots identification).
• Cold chain assurance.
• Toxic materials handling and storing.
• Protection of product from adulteration.
• Specifications for other entrants as ingredients, additives or packaging.

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• Waste disposal system.
• Labelling system and lots codes, providing effective traceability.
• Pests control plan. Insects, rodents and other undesirable presences control.
• Equipment and facilities preventive maintenance plan.
• Storage and transport of finished products.
• Testing Facilities/ Laboratory Service.
7. Write in brief the
Different types of audits are as follows:
different types of
audits conducted in the 1. Documentary Check
fish/shrimp processing A first documental verification is undertaken by the Audit Team after an establishment submits an initial request for official approval
industry by FIQC for with the purpose of producing and/or exporting fishery products. The verification will comprise of a check on the documents
official control submitted as part of the initial application for approval and will include:
 General description of the company: facilities (construction plants, layout), products and process, number of employees (by section,
task, or processing line and shift, production capacity by product or processing line and the storage capacity.
 The description of operations followed (SOP).
 The documented prerequisite programmes (SSOP), including water/ice quality program (with test report from the Third party)
and also waste water disposal system.
 The HACCP plan (whenever necessary).
 The system to provide guarantees for the product traceability.
 The documented and formalized withdrawal and recall procedures.
 Brand registration certificate
Further to approval of the establishment, any change of the documentation should be sent to the CA.
2. Full Verification / Evaluation Audit
Full verification by the Audit Team takes place when the factory is in operation, including different shifts and activities in
between shifts. It includes an in depth full verification of physical settings, operational conditions and control strategies,
concerning the entire production process, which will be verified against all written procedures / manuals / documents of the
establishment (received for the documentary checks).
The verification team should evaluate the application of all pre-requisite programmes, including:
 The general hygiene conditions of building and surroundings.
 Water supply and water quality management system, detailing the internal distribution net, treatment if any, quality
monitoring plan and related data filing.
 Ice production, internal distribution and quality monitoring

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The absence of cross contamination / separation between dirty-clean (wet-dry) areas / air currents risks (lay-out
considerations).
 Personnel health and hygiene control (including training).
 Sanitary filtering of personnel arrangements, toilets and dressing facilities.
 Facilities and equipment cleaning and sanitation plans (methods, schedules, chemicals used and approvals).
 Raw materials acceptance criteria and controls (freshness, temperature, transport, lots identification) .
 Specifications for other entrants as ingredients, additives or packaging
 Waste disposal system.
 Labelling system and lots codes, providing effective traceability.
 Pests control plan. Insects, rodents and other undesirable presences control.
 Equipment and facilities preventive maintenance plan.
 Testing facilities
3. Routine verification / inspection
The CA performs a routine general reassessment of the system following a predetermined inspection frequency based on
identified non compliances during the Full Verification for Approval or renewal. Routine verification is based on the same
content as a full verification. However, it may consist of a full audit or just partial audit. This will be identified in the checklist
and report and justified accordingly. The routine verification / inspection may (or should) be undertaken without notice.
4. Follow up verification / inspection
Such visits are specifically prepared for follow up of corrective actions requested during a previous verification / inspection
activity. Follow up verification are used to verify the correction of a previously noted defect / non conformity within an
established deadline date.
Verification of the effective correction of defects / non conformities subject of the CAR, will be registered in the respective
Follow up of corrective action request form, with the objective to close the CAR (which is kept open until verification of
compliance).
5. Partial verification / inspection
 The verification / inspection will consist on focusing the audit in only one or a group of the elements under assessment
of compliance. Therefore the verification will be only object of a partial verification/assessment inspection.
 Such visits are often used to follow up on items noted during a previous in depth verification. They can also be used to
verify the condition of previously noted observations.
 A section of a general checklist can be used for this purpose, or a specific worksheet may be created which is added to

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the original verification form on which the observations were noted.
 Subsequently, the verifier should observe and record deviation or non-conformities as they are found and/or obtain
product samples as required.
 Partial verification/inspection maybe (should be) undertaken without notice and may have the objective to assess/check
that conditions during normal operations are equivalent to those during formal verification/audit.
6. Random Spot checks inspection
Consists of a partial verification and depending on the logistical capacity and utilization of precautionary principles, has the
purpose of organizing additional non-programmed verifications. Therefore, it will serve as a parallel verification to check
compliance of operators and give feedback on how the system is performing.
It is also a response of the system when a particular change in the risk environment may indicate the need for additional checks:
 at certain periods
 in certain areas
 types of process
 raw materials
 other reasons
Spot check verifications/inspections are always undertaken without notice.

Pre-shipment inspection (for all exports)


Such visits are specifically prepared for a go-ahead of consignments shipment. The CA, prior to establishments notification
request, will inspect specifically the respective consignments file to be shipped (exported), against the required documentation,
information and own-checks results.

Pre-shipment controls and testing will be carried out for all importing countries. This includes sampling for testing (however,
chemical testing is only carried out for EU or on demand of other importing countries).

Pre-shipment verification is used to detect and prevent the existence of any abnormality / hazard or lack of traceability, and to evaluate
the respective risk of any possible food safety hazard. If this is the case the shipment of the consignment(s) will not be authorised.

8. a) Write down briefly Tasks of the Inspector


the task and duties Fish inspectors tasks are as follows:
of
inspectors/auditors  Undertake regular routine and on-the-spot inspection of establishments, farms, fishing vessels, distribution centres, depots,

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landing sites, ice plants, chill and cold stores, and means of transport.
 Undertake pre-shipment controls of consignment documentation, traceability records and respective own-checks controls and
sample testing as demanded.
 To prepare and submit reports to the Director regarding the status of sanitary conditions within the different entities controlled
in accordance with the outcome result system applied through the regulatory verification procedure.
 Monitor and control the implementation of the recommendations made as a result of the regular routine system, including
verifying that corrective measures demanded are realised in an efficient and effective manner.
 Ensure the appropriate certification of fishery products through the use of the different inspection forms and health
certification processes, and ensure the withdrawal or condemnation of non-compliant products.
 Participate in the development of inspection methods and the training of operators in the production chain.
 To take samples and deliver them for analysis at an approved laboratory, to receive and interpret results and act accordingly.
 Undertake the collection and synthesis of statistical data at each inspection point
Responsibilities of the Inspector
Always remember that the inspector is an official representative of the Competent Authority and must exhibit a professional image
when dealing with establishment officials. This includes:

 respect for establishment policies when undertaking inspection / audits


 maintaining a professional bearing
 keeping strictly confidential information obtained from a company
 maintaining a good level of personal cleanliness and tidiness
 guarding against corrupt practices and conflicts of interest
Examples of corrupt practices are:

 receiving payments (in cash or kind) for approval of establishments, irrespective of compliance with the conditions
 fraudulent issue of export health certificates
 “sampling” of products for personal use or gain
Examples of conflicts of interest

 entering into a business relationship with a fishery business operators (e.g. consultancy/training contracts)
 investing in fishery sector activities
 requiring tests to be carried out in a laboratory in which there is a financial interest
Inspectors should follow the following basic rules:

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 No gifts should be accepted from any person
 Do not accept offers of external employment unless approved by the Competent Authority
 Declare any relevant interests (including related activities of family members)

b) Write in brief what The preparation of the inspection / audit should cover at least the following aspects:
kinds of
preparations are a) Nomination of inspector / auditor or inspection / audit team
needed for the b) Definition of the objective
auditors/inspectors c) Familiarisation with the establishment’s file, including description of company, the premises / vessel, the process, the product
before arriving in specifications, markets of destination. The outcomes of last verification activities. This documentation should be reviewed
the industry for before the inspection / audit
audit/ verification. d) Preparation of necessary checklists for verification of essential aspects
e) Arrangements for transport of inspection / audit team and transfer of any samples to testing laboratory
f) Arrange equipment material (such as thermometers, rapid tests, clip boards, worksheet, flash light, cameras, sampling
equipment etc) and check that it is working
g) Confirmation with establishment (except for spot check inspection / audits or routine inspection)
h) Inform the laboratory to be ready to receive samples
9. a) Write briefly how Arrival at Establishment
the inspectors/
auditors execute Prior to announcing their arrival at the establishment, it is recommended that the inspection / audit team verifies that they are ready for
the inspections the job and well equipped.
after arriving in
the industry.  The team leader, demonstrating courtesy and professionalism, should:
a) Ask for the establishment manager or person in charge
b) Present identification card or business card and introduce the team members
c) Explain what the team will do and agree on an inspection / audit time frame
d) Inform management that the results will be discussed once the inspection / audit has been completed and arrange for a tentative
time to meet and discuss the results
e) Invite an establishment representative to accompany the inspection / audit team, preferably the Quality Assurance Manager.
 The inspection / audit team must determine what the establishment working schedule will be during the course of inspection /
audit (i.e. shift-work, hours of work, etc.).
 To facilitate the best order of inspection / audit, the inspection / audit team and establishment management should formulate an
inspection / audit schedule. All effort must be made to assess the items in an operational or working condition.

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Establishment Representative

 The establishment manager should be invited to accompany the team or nominate a foreman or quality assurance person to do
so. This is because:
a) questions can be asked on the spot
b) serious infractions can be pointed out for immediate action to be undertaken
c) help may be needed to assist in reviewing data records and data systems
d) help may be needed to gain access to certain areas
 However, inspectors / auditors must not allow accompanying plant personnel to lead or rush the inspection / audit, or distract
them away from infractions or defective circumstances.
 Inspectors / auditors are entitled to demand access to any part of the establishment and to request that they be accompanied by
a company representative to witness their actions at all times.
Avoidance of cross contamination

 Every effort should be made by the inspection / audit / team to minimize cross contamination risks. The inspection / audit team
should wear clean boots, hats and protective clothing. Jewellery and watches should be removed.
 The inspector / auditor should know and observe the hygiene rules of the establishment being inspected. The inspector should
not chew gum, smoke, eat or drink during the inspection / audit.
 The inspectors / auditors must utilize hand washing/sanitizing facilities as frequently as possible, and at least at the point of
entry to production areas.
Depending on the purpose, the sequence can be structured as follows:

a) begin with the critical processing steps (e.g. cooking area for establishments processing cooked shrimp)
b) review areas of major problems revealed during the last inspection / audit(s)
However in general, the inspection / audit should commence in the microbiologically cleanest areas (e.g. starting at the packaging and
ending in the raw receiving or establishment exterior). If not possible due to for example, necessary priority start in raw receiving area,
when recommencing visit to remaining areas undergo another cleaning process and/or change protective clothing and boots, especially
if activities held at the receiving area have potentially contaminated clothing and boots.

b) Write in brief General Inspection /audit Considerations


general inspection
The inspection / audit should be conducted as far as possible taking into account the following rules:
and audit
a. All team members should write up their own worksheet and findings and compare them after the inspection / audit.
considerations
b. Ask establishment management questions rather than the workers. An exception may be when you might want to determine

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need follow for the if a worker understands what he/she is doing or what procedures he/she has been directed to follow during regular production
auditors during or when there is a problem or deviation.
inspection/audit of c. Do not make observations or give instructions to any staff other than the nominated representatives.
a processing d. Set a good example to workers (e.g. when a wash basin is present in the inspection / audit area, wash your hands).
industry. e. The inspection / audit team must observe a major clean-up before start-up (pre¬operation) or after shut-down (post-
operation).
f. If more than one shift is operating plan inspection / audit so that each shift is observed (even if necessary to go in different
days).
g. If more than one shift is operating try to observe the changeover conditions between shifts. Changing shifts is usually object
of application of different standard conditions, where non compliances can easily happen. Inspectors / Auditors should
monitor the changeover routine between as many shifts as possible.
h. In the storage, mixing and blending areas, take note of all ingredients, additives, and processing aids, so that they can be
verified for compliance with existing regulations.
i. In the labeling area(s), obtain a sample label of the product currently being processed and packed. Review the required label
declarations while in the establishment. Attach the label to a worksheet so it can be reviewed more closely back at the office.
j. When in the boiler rooms make a note of the boiler additives being used, especially if live steam is being used on any
product in the establishment.
k. Remember to check special areas including: storage of cleaning chemicals, storage of pesticides, storage of ingredients,
toilets and locker rooms.
During or after an in-depth or directed inspection / audit, samples may be obtained. Always notify establishment management of
exactly what samples are required and the purpose of sampling. Draw the samples randomly, and according to the sampling plans.
Wherever possible, the types of checks or analysis carried out on those samples should be a reflection of the infractions observed in the
establishment

10. a) Briefly write down Outcomes, reporting and follow up


about the Inspection / audit Team Review
outcomes, When the inspection / audit are finished the team should meet in a private room to discuss the inspection / audit results. A suitable
reporting and location is necessary to protect the confidentiality of the information.
follow up actions The inspection / audit team should:
need to take after a. review each deficiency using a risk based assessment
auditing/ b. identify in writing all deviations that require corrective action
verification of the c. assign an overall rating
industry. d. decide on recommendations
e. decide on a date for a follow up visit

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Results and Reporting
It is important that operators understand the inspection / audit findings and the reason why certain items are unsatisfactory and require
correction or improvement. The Team should prepare an Inspection / audit report for presentation to the operator.
The Inspection / audit Report should:
a. Provide an overall rating resulting from the inspection / audit according to rating criteria and classification.
b. Describe the deficiencies found during the on site inspection / audit.
c. Distinguish the deficiencies which are considered to be related to the physical settings (facilities), to the hygienic
operation and process control, and to the follow up of HACCP plan application (operational management).
d. Be signed and dated by the representative of the Competent Authority, and the manager of the establishment or the
captain of the vessel.
A copy of the finalized report form/notifications should be presented to the management of the establishment or captain of the vessel at
the final management meeting.
Final Management Meeting / Corrective Actions
After the inspection / audit, the team must meet with the appropriate member(s) of the establishment management to:
a. review the inspection / audit process
b. identify the main findings (positive and negative)
c. present a draft report with results
d. highlight the unsatisfactory conditions
e. discuss and decide on a time period or a date for the correction of unsatisfactory conditions; However a final decision
on the timeframe will be subject to analysis of the Heads / Director of the CA.
Corrective action should always include planning with front-line management so that the problem will not recur. Urgency of corrective
actions must always be measured by the degree of existing hazard related to health and safety issues.
Final Report and Covering Letter
A printed copy of the finalised inspection / audit report should be forwarded to the management as soon as possible. The report must
be accompanied by a covering letter. This should contain the following contents:
a. Main findings
b. Specific non compliances noted
c. Corrective actions required
d. Request for a written action plan by a certain date.
e. Any formal changes as up-grading or down-grading export status of the establishment
f. Any other kind of sanctions to be applied
The copy of the report and letter should be registered and placed in the company file, along with a copy of any completed inspection /
audit forms and other documents presented. The report will be the basis for further verification activities.
The generic format for audit / inspection report for Full and Partial Verification (Audit /Inspection) activities should contain the
following data and be structured as follows:

15
 Establishment registration number and name
 Date of audit/inspection
 Scope
 Auditor/inspectors
 Establishment representatives
 Reference document used
 Audit findings
 CARs reports attached
 Conclusion
The Company’s Written Action Plan
 The written action plan submitted by the company must address all of the non compliances reported in the inspection / audit
report i.e. long term and short term.
 An incomplete action plan is not acceptable and should be returned to the company for correction.
 If the action plan is not submitted within the appropriate time frame, the CA inspector/ auditor should contact the company as
a reminder.
 Non-response may be grounds for the suspension of the products certification by the Competent Authority. Further action,
should be taken if the establishment management is uncooperative.
b) What are the Specific actions in case of Critical Non-Compliance
actions for critical  A critical non-compliance is one which might result in imminent risk to the health of consumers.
non-compliance  In this case the inspector / auditor should refer to standing procedures and national legislation for guidance on emergency
need to take after measures to be applied.
auditing/  If potentially contaminated product has been distributed, the Competent Authority and the Company should consider whether
verification of the withdrawal or recall is necessary.
industry. 1. If a General description of the company, facilities, products and process, production and storage capacity, and number
of staff (by task, section and shift).
2. The description of operations followed (SOPs) and process parameters.
3. The documented prerequisite programmes (SSOPs), including waste water disposal system.
4. The HACCP plan (whenever necessary) and respective HACCP mandatory and preparatory requirements fully
documented.
5. The system to provide guarantees for the product traceability.
The documented and formalized withdrawal and recall proceduresproduct recall is to be initiated, the inspector should immediately
contact the officer responsible for the rapid alert system in place at national level, with the relevant details.

16
11. a) Write down The inspection will focus on the external quality of processed fish and fishery products, labelling and net weight inspection. Samples
sample collection are to be collected through random selection, for the purpose of examination (according to approved check list) of the external quality,
procedure from a labelling, net weight and other harmless qualities, using an acceptable quality level of 6.5% (AQL = 6.5% of Codex Alimentarius),.
pre-shipment The mentioned AQL = 6.5% plan is described in Table-1 below:
consignment Table 1 : Codex alimentarius sampling plan of pre-packed products (AQL = 6.5%)

1. Weight of inner packet <100 kg


number of inner packet in each consignment (N) Total number of Higher number of acceptable faulty
sample (n) sample (C)
N = 4800 or less n=6 C=1
4801 - 24000 13 2
24001 - 48000 21 3
48001 - 84000 29 4
84001 - 144000 48 6
144001 - 240000 84 9
> 240000 126 13
2. Weight of inner packet 1.00 kg to 4.5
N = 2400 or less n=6 C=1
2401 - 15000 13 2
15001 - 24000 21 3
24001 - 42000 29 4
42001 - 72000 48 6
72001 - 120000 84 9
> 120000 126 13
3. Weight of inner packet >4.5 kg
N =600 or less n=6 C=1
601 -2000 13 2
2001 - 7200 21 3
15001 - 24000 48 6
24001 - 42000 84 9
>24000 126 13

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b) Write in brief Table:Sampling plan and microbiological limit for fish and fish products (ICMSF-1986)
sampling plan and Type of product Microorganism No. of sample c Limit per g
microbiological (n)
limit for fish and m M
fish products Fresh and frozen Aerobic Plate Count 5 3 510 5 10 7
(ICMSF- 1986). fish (APC)
Escherichia coli 5 3 11 500
Salmonella 5 0 0 -
Vibrio parahaemolyticus 5 2 100 1,000
Staphylococcus aureus 5 2 1,000 10,000
Precooked Aerobic Plate Count 5 2 510 5 10 7
breaded fishery (APC)
products Escherichia coli 5 2 11 500
Staphylococcus aureus 5 1 1,000 10,000
6
Frozen Aerobic Plate Count 5 3 10 10 7
crustacea(Raw) (APC)
Escherichia coli 5 3 11 500
Staphylococcus aureus 5 2 1,000 10,000
Salmonella 5 0 0 -
Vibrio parahaemolyticus 5 1 100 1,000
Frozen cooked Aerobic Plate Count 5 2 510 5 10 7
shrimp (APC)
Escherichia coli 5 1 11 500
Staphylococcus aureus 5 0 1,000 -
Salmonella 10 0 0 -
Vibrio parahaemolyticus 5 1 100 1,000
Cooked crab meat Aerobic Plate Count 5 2 10 5 10 6
(APC)
Thermal Tolerant Coliform 5 2 500 5000
Escherichiaa coli 5 1 11 500
Staphylococcus aureus 5 0 1,000 -
Listeria monocytogenes 5 0 0 -
Salmonella 30 0 0 -
Vibrio parahaemolyticus 10 1 100 1,000

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n= No. of representative sample; c = No. of highest acceptable sample which is higher than organism of m; m = No.
of such organism which distinguishes between good quality and marginally acceptable quality; M= Unacceptable
no. of organism.
12. a) Write down the Sample collection for the purpose of chemical testing
sample plan a. Chemical substance: From every consignment through random sampling, composite samples weighing about 1 (one) kg
criteria for each weighing 200 g shall be collected from 12 (twelve) master cartons.
chemical analysis b. Food additives and proximate analysis: From each consignment 5 (five) samples each weighing 200 g shall be collected
through random sampling.
c. Drugs (VMP) residues: From each consignment about 1 (one) kg composite sample is to be collected from 12(twelve)
master carton through random sampling each weighing 200 g.
d. Chemical contaminants: About 1 (one) kg composite sample is to collected through random sampling at the rate of 200 g
from each of 12(twelve) master cartons.
e. Analysis of other chemical elements: For the purpose of other chemical or biochemical tests, 5 (five) samples of 200 g
each are to be collected from each consignment.
b) Write in brief Procedure for the collection of samples
sample collection
process for the The procedure for collection of sample of a fixed group of commodity is somewhat different. The general issues are mentioned here:
purpose of
a. Wherever possible without opening the container ( inner packet), intact container (inner packet) is to be procured;
microbiological
b. When the container or carton is of big size, in that case through using sterile equipment, sample is to be collected and kept
testing in fish and inside the container or poly bag by breaking in aseptic condition. In such case about 70% alcohol is to be used for washing or
fishery products. sponging the outer surface for the case of paper carton. The outer portion is to be separated through cutting the surface of the
carton. Thereafter, with the help of sterile cutting equipment, the mouth of the container or poly bag shall be cut; and
If the commodity inside the container is large and if it is not possible to mix the sample well, then samples shall be drawn
from different portions.
2. Labeling

a. At the time of collecting of sample, if it is not possible to do so instantaneously, then marking and tags shall be attached; and
b. If refrigeration is required, that shall be mentioned on the label.

2. Transport of sample

a. The collected sample shall be sent to the laboratory as quick as possible;


b. Non-perishable and non-frozen substances shall be chilled between 0ºC to 5ºC, and shall be kept inside an insulated

19
container with sufficient ice at temperature between 0ºC to 5ºC and until the substance reaches the laboratory, the same
temperature shall be maintained. The sample can be chilled in refrigerator or by keeping in ice room to quickly lower the
temperature and the product shall be transported in such a manner that water from the ice can flow outside;
c. Frozen samples may be kept in frozen condition until examination. Non-frozen samples soon after collection shall be kept
inside the freeze and after the temperature comes down to 0ºC, the cargo shall be carried to the laboratory through insulated
container; and
d. The sampling report shall be preserved and it shall be sent along with the sample.

13. Write in brief FDA FDA Eight Key Sanitation Areas


eight key sanitation FDA’s seafood HACCP regulation focuses on eight key areas of sanitation . These eight areas of sanitation are derived from the
conditions applicable GMPs. FDA’s seafood HACCP requires that these eight key areas of sanitation be monitored and that the results be recorded along
for the processing with any corrections for
industry deficiencies
Eight key areas of sanitation:
1)..Safety of water
2)..Condition and cleanliness of.food contact surfaces
3)..Prevention of cross contamination
4)..Maintenance of hand washing, hand sanitizing and toilet facilities
5)..Protection from adulterants
6)..Labeling, storage and use of toxic compounds
7)..Employee health
8)..Exclusion of pests

Safety of water:
 Water (and ice) that contacts food or food-contact surfaces shall be of safe and of sanitary quality (Potable Water).
 Source of water, and the plumbing system that conveys it to the building must provide a safe supply.
 For companies using a municipal water source for processing and making ice, the water treatment authority is responsible for
safety of source and conveyance to the building.
 Documents must include annual water quality tests from the water authority.
 Companies using private water systems (e.g. wells), are directly responsible for adequate monitoring and documentation of the
safety of the water source. Municipalities can provide guidance.
 Protection of water used for food and food manufacturing must prevent contamination from potential cross connections and
backflow. To ensure water is safe, cross-connections must be prevented.
 There must be no cross connection or backflow potential between the water supply and piping for wastewater or sewage.

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Condition and cleanliness of food contact surfaces:
 Food contact surfaces shall be of a proper design and maintained in a clean and sanitary manner to prevent food contamination.
 Food contact surfaces must be designed, fabricated, maintained, and installed so that they are easy to clean and able to withstand
the environment in which they are used.
 Equipment must have smoothly bonded seams and be made of impervious materials that can be easily cleaned and sanitized.
 Food contact surfaces must also be maintained in suitable condition. For example, poorly bonded joints, corroded parts, exposed
bolts, screw heads, or even pitted surfaces that could trap water or soils should not be used.
 Adequate cleaning and sanitizing procedures and frequencies must be established for all food contact surfaces, including
equipment, utensils, food containers, gloves, and outer garments. Suggested frequencies for cleaning and sanitizing include:
before use, after processing interruptions, and a necessary.
 Cleaning is accomplished using detergent and water at a suitable temperature. Sanitizing is accomplished using approved
sanitizing agents such as chlorine, quaternary ammonium or iodine-based compounds.

Prevention of cross contamination:


 Employee hygiene, personnel practices and the design of the facility must prevent cross contamination. Employees shall maintain
adequate personal cleanliness and conform to adequate hygienic practices to prevent product contamination.
 Workers must wear clean and appropriate dress/apron and must wash and sanitize their hands at appropriate intervals.
 Gloves must be used appropriately and are not a substitute for hand washing and sanitizing.
 Employees must understand that their actions can contribute to product contamination. Employees’ hands or gloves, along with
equipment and utensils must be washed and sanitized (when necessary) after being contaminated. For example, employees
working in the raw product area should not work with the finished product without washing and sanitizing their hands, gloves,
equipment, or utensils to avoid cross-contamination.
 Plant design must prevent potential contamination of food, food contact surfaces, and packaging material.
 Operations must be adequately separated where contamination is likely to occur.
 Raw product and unpackaged cooked ready-to-eat product must be separated to avoid contamination.
 Food contact surfaces must be cleaned and sanitized when contaminated.
 Packaging materials must be stored and handled properly so they do not become a source of contamination

Maintenance of hand washing, hand sanitizing and toilet facilities:


 Sanitary facilities must be accessible, properly maintained, and adequately supplied. An adequate sewage disposal system must be
in place.
 Hand washing and, where appropriate, hand sanitizing facilities should be at each location where good sanitary practice requires
their use. Effective hand washing and sanitizing supplies must be available.
 Water at suitable temperature and sanitary towel service or suitable drying devices must be available and designed to prevent

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recontamination.
 An adequate sewage disposal system is required.
 Adequate and readily accessible toilet facilities with self-closing doors to protect food from airborne contamination must be
maintained in sanitary condition.
 All toilet facilities must be adequate, in good repair (e.g. not leaking), and properly supplied with paper towels, soap, etc.
Protection from adulterants:
 Food, food contact surfaces, and food packaging material must be protected from microbiological, chemical and physical
contaminants.
 Potential contamination sources could include: water splashing from the floor, condensate from air conditioners, refrigerator
condensers, pipes, light fixtures and ceilings, toxic substances (e.g., pesticides, fuel, cleaning compounds, and sanitizing agents),
filth, and physical contaminants (e.g., glass, metal fragments, dirt or corrosion from fans and other fixtures).
Labeling, storage and use of toxic compounds:
 Prevent contamination from toxic compounds. Toxic cleaning compounds, sanitizing agents and pesticides must be properly
labeled, used and stored in a manner that protects food, food contact surfaces and packaging material from contamination.
 Toxic compounds must be stored in a secured area with limited access separated from food processing and areas where food and
packaging materials are stored.
Employee health:
 Food handlers with an apparent illness, wound, or open lesions could be a source of microbiological contamination.
 Policies must be in place that exclude or restrict employees who exhibit or are diagnosed with symptoms of an illness, wounds or
other afflictions that could be a source of microbial contamination of food, food contact surfaces, and food packaging material.
Exclusion of pests:
 Pests, such as rodents, birds, domestic animals and insects are not allowed in any area of a food processing and/or storage
facility . Even if pest control is contracted to an outside company, the processor is responsible to assure there are no pests in the
facility

14. a) What do you mean  Articles 29 and 30 of Council Directive 96/23/EC- outlines residue monitoring requirements for countries wishing to export
by NRCP? Write food of animal origin to the EU (heavy metals, contaminants, residues of pesticides and veterinary drugs)
down the objects of Objectives of NRCP
NRCP.  To assess compliance with the tolerance limits ( for contaminants), maximum residue limits (MRLs for permitted substances)
 To reveal the illegal use of banned or unauthorized substances
 To determine the origin of residue contamination.
 Ultimate objective: To protect consumer health

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b) What types of The substance groups that are monitored in NRCP
chemical residues Following substance groups are monitored under the NRCP program:
are monitored
under NRCP in
Bangladesh?

c) Write down the


names of lab and
tasted parameters
of NRCP in
Bangladesh.

23
d) Write down of Sampling strategy
sampling strategy a. For Shrimp/Prawn, sample numbers are calculated based on one sample per 100 MT of National Production (Fisheries
NRCP in Resource Survey Statistics).
Bangladesh. b. Samples numbers are distributed to three Regional Competent Authorities (Dhaka, Chittagong, and Khulna) on the basis of
production in the region, risks and their previous year’s export quantities.
c. Sampling strategy is risk based- sampling officer applies certain risk criteria when choosing farms for sampling, such as
high volume and use of commercial feeds, increase the chance of identifying unauthorized use of medicines
d. Shrimp/Prawn samples collection spots are selected on the basis of non-compliance and production (Risk- based).
e. For Finfish, sample numbers are calculated based on one sample per 100 MT of National Fish Export from farms
(Fisheries Resource Survey Statistics).
f. Sample collection spots of Finfish are selected on the main areas from where fish are collected by the exporter.
g. RCA is responsible for selecting appropriate sample collection sites with the coordination of local Upazila Fisheries
officials.
h. RCA sends monthly progress report to CCA.
i. Total activities of NRCP are monitored by CCA.
15. a) Write down the Objectives of food laws are:
objectives of food  to protect the consumer against any food that might cause acute or chronic illness on consumption;
laws.  to ensure that foods are made from sound materials and will not be offensive to the consumer;
 to ensure that only permitted additives have been used in the preparation of the food;

 to ensure that the product is labeled correctly so as not to deceive or mislead the consumer
(a) Safety of Fishery Products:
 Food borne illness by bacterial food infection and food poisoning
 Scombrotoxin mainly from Scombroid family and clupeids.
 The toxin is associated with high level of histamin ;
 Tetradotoxin in pufferfish and related species
 Ciguatera toxin in a number of tropical fish
 Toxin of paralytic Shellfish Poisoning (PSP)
 Parasites from fish
 Pollutants (pesticides, organochlorines, heavy metals)
(b) Fitness for consumption:
It covers food not being spoiled or not being prepared from spoiled raw materials, not being from diseased animals and not
contaminated with foreign matter. Excessive infestation by parasites leads to unfit for consumption.
(c)Additives

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List of additives which are considered safe and which may be used in any foodstuff. Two additives are used: polyphosphates added to
frozen fish and sulphite to prevent shrimp discolouration
(d) Labeling
Labeling regulation for products for retail can be quite detailed and extensive in importing countries and quite strictly enforced. The
following information should be available: The name of the product and its form, a list of ingredients and additives, the quantity, and
the name of the manufacturer.
b) Write down briefly Nationa Legal Framework:
some legal • The Fish and Fish Product (Inspection and Quality Control) Ordinance, 1983
regulatory national • The Marine Fisheries Ordinance, 1983
and international • The Marine Fisheries Rules, 1983
legislation for • The Fish and Fish Product (Inspection and quality control) Rules, 1997
official control of • The Fish and Fish Product (Inspection and quality control) Rules, 1997 (amended in 2008)
fishery products • The Fish and Animal Feed Act, 2010 and rules 2011
• The Fish Hatchery Act, 2010 and rules 2011
• The Fish and Fish Product (Inspection and quality control) Rules, 1997 (amended in 2014).
In addition to the regulations, the following policies and guidelines are also in place for official control of FP-
• National Fisheries Policy-1998
• National Residue Control Plan Policy Guidelines, 2011 (amended in 2012)
• National Shrimp Policy, 2014
• Fish and Fishery Products Official Control Protocols, 2015
• Guidelines for the Control of Aquaculture Medicinal Products-AMPs, 2015
• Manual on Good Aquaculture Practice- Trainer Guide
• Compliance Guidelines for Fish Feed Production, Import & Marketing
• Guidebook on Waste Management in Fish and Fishery Industries
• Good Aquaculture Practice – A Farmer’s Guide
• Compliance Guidelines for Shrimp Hatchery
• ISO/IEC 17025:2005 General Requirements for Competence of testing Laboratories.

16. Write down the CONDITIONS OF NECESSARY FACILITIES FOR FISH PROCESSING PLANT
conditions of necessary 1. Floor of the processing plant shall be smooth, water-proof and the same be so slopping for easy drainage of liquid
facilities for fish substances in the drain.
processing plant as 2. In order to drainage the waste of liquid substances of the plant, there shall be hygienic drainage system and the outlet of
outlined in the FIQC drain shall be made such a way so that insect or other animal could not enter into the drain.
rules in Schedule-1 3. Interior walls shall be smooth., water-proof, light colored and it would be at least 1.8 meters height from floor of the
interior walls and it shall be made such a way for easy washing.

25
4. The height of roof shall be such a high so that under the roof easy movement can be possible and junction points of the
floor to wall, wall to wall and wall to roof shall be parabolic.
5. Windows and other openings shall be constructed in such a way so that dirt and particles could not enter into the plant and
those be covered with insect proof net.
6. Doors shall be smooth, non-absorbent, self-closing and be covered with insect proof net.
7. All entrances to the processing area shall have foot-operated taps with basin for washing hands and appropriate cleaning
and disinfectant materials there to.
8. There shall be an arrangement of liquid disinfectant substance in the way of entrances to processing area so that the bottom
of the shoes of the persons who enter, could get wet.
9. There shall be adequate number of hygienic rest-room for the use of the workers nearby the processing plant or under the
same roof of the processing plant.
10. All entrances to the rest-room shall have foot-operated taps with basin for washing hands and appropriate cleaning and
disinfectant materials thereto.
11. There shall be sufficient area and facilities to the entrances of the processing plant or nearby it so as to the workers could
change their dress and the said area shall be separated from the processing area.
12. For the purpose of using in the processing plant:-
(a) there shall be an arrangement for supplying potable water;
(b) there shall be covered, hygienic and cleaned sufficient water storage tanks; and
(c) there shall be supply of adequate hot water in appropriate place.
13. In processing plant:-
(a) there shall be sufficient lighting in the working areas for easy identification of fish & other materials; and
(b) the electric fitting shall be water-proof and bulbs be fitted with covers.
14. Plant building and other places thereto shall be designed and constructed in such a way as to minimize any chance of cross-
contamination of fish and the activities apprehended to contaminate fish, the place of said activities shall be separated by
partition or other means.
15. Crabs, tortoise and turtles shall be processed in an area completely separated by partition or other means.
16. Fish or fish products which would nto be used as human food or the processing area of other goods shall be kept
completely separated from fish processing area of other goods shall be kept completely separated from fish processing area.
17. Machinery and other tools used for the purpose of processing shall be kept clean and free from contamination.
18. In processing plant-
(a) equipments, fixtures and furniture for the purpose of fish processing shall be made by stainless steel or non-corrodible
materials;
(b) no wooden furniture and fixtures can be used in places where it can come into touch of fish; and
(c) the furniture and fixtures which are likely come into touch of fish shall be non-absorbent.
19. In order to remove waste materials from processing plant there shall be hygienic foot-operated, covered utensils and

26
arrangement for destroying the waste materials in hygienic condition.
20. So that the waste-materials of processing plant cannot pollute it surroundings, there shall be sufficient facilities to ensure
the same.
21. Conveyor-belts which are likely come close contact of fish be made so that they can be easily cleaned and disinfected.
22. There shall be arrangement for non-corrodible equipments for separating fish meat and they shall be easily cleanable and
disinfectant able.

Equipments for cutting grinders and other processing equipments shall be standard quality.
23.
The boxes, trolleys and other containers used for storage of fish (save and except lively fish) shall be made so that water
24.
can be easily drained away.
25. No utensil made by wire-net can be used for processing other fish and except shall fish and crustacean.
26. Enameled or galvanized utensils shall not be used in fish processing
27. In processing plant-
(a) each frozen storage shall be fitted with an auto temperature recording thermometer and the said thermometer be located
in conspicuous part of the store for easy visibility.
(b) frozen storage shall maintain a constant temperature of -180C to -250C or below;
(c) cold storage (chill-room) shall have the facilities maintaining temperature of 00c to 50c, and
(d) the temperature of ice-storage shall be below the range of 00c
28. For using adequate pressure and heat in processing canned fish, there shall be arrangement for adequate steam or vapour or
other means.
29. In canning plant-
(a) there shall be adequate sealing machines; and
(b) there shall be retort with thermometer, pressure gauge steam spreader and venting valve.
30. In processing plant there shall be an arrangement for producing value added product as per international requirement.
17. Describe the conditions CONDITIONS APPLICABLE FOR CONVEYANCES USED FOR TRANSPORTING FISH.
applicable for 1. Vehicles used for transporting fish shall have facilities for protecting the fish from the sun, rain and other contaminations. .
transport for carrying 2. All walls of fish holder shall be water-proof and temperature non-absorbent.
fish as outlined in the 3. Fish-holds, pen-boards and shelf-boards shall be smooth and impervious and capable of being properly cleaned.
FIQC rules in 4. Fish shall be stored in transport in such a way as to prevent damage or crushing.
Schedule-5 5. Fish shall transport in covered vessel shall be fully protected from the sun, rain, dust, dirt, insects and any other form of
contamination.
6. Decks, holds, pen-boards and shelf-boards shall be thoroughly cleaned and disinfected as soon as fish have been discharged
in the transport.
7. Fresh Live fish shall be transported covering with ice and shall keep in under 50c.
8. Fresh Live fish while transport under refrigerated carriers shall be kept under 50c.

27
9. Frozen Live fish while under the control of carrier shall be kept well refrigerated at all times and maintain a temperature of
-180c with fluctuation of not more than 20c.
10. Exportable or processed or fish under processing shall be protected from the sun and rain and contamination during loading
and unloading.

18. Write down the CONDITIONS OF NECESSARY FACILITIES FOR FISH LANDING CENTRE, SERVICE CENTRE AND VENDING
conditions of necessary CENTRE.
facilities for landing Fish landing centre, service centre and vending centre shall be constructed with building materials and for transport the
center, service center arrangement of pucca roads and amongst other following facilities, namely:-
and arot or depot as 1. there shall have high table made by non-corrodible steel for fish grading.
outlined in the FIQC 2. it shall be surrounded by wall and easily can be cleaned;
rules in Schedule-6 3. floor shall be smooth and water-proof which can be easily cleaned and for drainage of water, there shall be hygienic
arrangement;
4. their shall be drain for drainage of water hygienically;
5. the height of roof shall be at least 3.5 meter height;
6. there shall be an arrangement of sufficient natural and artificial air and electric fittings shall be water-proof and bulbs be
covered with;
7. arrangement shall be made for supplying potable water;
8. arrangement shall be made for supplying ice in potable water;
9. machines for breaking ice, lift machines and other articles shall be made of such material which are non-corrodible and
rust free;
10. there shall be sufficient toilets for use of the workers and arrangement be made to clean the same hygienically; and
11. there shall be specific room for Authorized Officer.

19. a) Write in brief (a) there shall have high table made by non-corrodible steel for fish grading.
compliance of (b) it shall be surrounded by wall and easily can be cleaned;
landing center (c) floor shall be smooth and water-proof which can be easily cleaned and for drainage of water, there shall be hygienic arrangement;
(d) their shall be drain for drainage of water hygienically;
(e) the height of roof shall be at least 3.5 meter height;
(f) there shall be an arrangement of sufficient natural and artificial air and electric fittings shall be water-proof and bulbs be covered
with;
(g) arrangement shall be made for supplying potable water;
(h) arrangement shall be made for supplying ice in potable water;
(i) machines for breaking ice, lift machines and other articles shall be made of such material which are non-corrodible and rust free;

28
(j) there shall be sufficient toilets for use of the workers and arrangement be made to clean the same hygienically; and
(h) there shall be specific room for Authorized Officer.

b) Compliance of FBO will undertake control of hazards in primary production and associated operations, including the necessary measures:
the primary  to control contamination arising from the air, soil, water, feed, veterinary medicinal products, and the storage,
production handling and disposal of waste;
 to keep clean and, where necessary after cleaning, to disinfect in an appropriate manner:
 any facilities used in connection with primary production and associated operations, including facilities used to store
and handle feed, equipment, containers, crates, vehicles and vessels;
 to ensure the cleanliness of aquaculture animals, as far as possible, during and post-harvest and slaughter;
 to use potable water, or clean water, whenever necessary to prevent contamination;
 to ensure that staff handling fish products are in good health and undergo training on health risks;
 to prevent animals and pests from causing contamination, as far as possible;
 to store and handle waste and hazardous substances so as to prevent contamination;
 to prevent the introduction and spread of contagious diseases transmissible to humans through Fish and Fishery
Products;
 to take account of the results of any relevant analyses carried out on samples taken from aquatic animals or other
samples that have importance to human health;
 to use feed additives and veterinary medicinal products correctly, as required by the relevant legislation and item
instructions.
 Fish business operators are to take appropriate remedial action when informed of problems identified during official
controls.
II RECORD KEEPING
 Fish business operators are to keep and retain records relating to measures put in place to control hazards in an
appropriate manner and for an appropriate period, commensurate with the nature and size of the business.
 Fish business operators are to make available to the Competent Authority relevant information contained in these
records on request.
 the nature and origin of feed fed to the aquatic animals, including batch number if applicable;
 veterinary medicinal products or other treatments administered to the aquatic animals, dates of administration and

29
withdrawal periods;
 the occurrence of diseases that may affect the safety of products;
 the results of any analyses carried out on samples taken from aquatic animals or other samples taken for diagnostic
purposes, that have importance for human health;
 any relevant reports on checks carried out on products.
 Records should be kept within a traceability system.
The fish business operators may be assisted with the keeping of record
20. Write down the major  Fresh Fishery Products
compliances need to Chilled, unpackaged products, which are not distributed, dispatched, prepared or processed immediately after reaching an
undertake for fishery establishment on land, must be stored under ice in appropriate facilities. Re-icing must be carried out as often as necessary. Packaged
products. fresh fishery products must be chilled to a temperature approaching that of melting ice. Heading and gutting operations must be carried
out hygienically. Where gutting is possible from a technical and commercial viewpoint, it must be carried out as quickly as possible
after the products have been caught or landed.
Beheaded and gutted products must be washed thoroughly with potable water or, on board vessels, with clean water immediately
after these operations. Filleting and cutting operations must be carried out so as to avoid contamination or spoilage of fillets and slices.
Fillets and slices must not remain on the worktables beyond the time necessary for their preparation. Fillets and slices must be
wrapped and, where necessary, packaged and must be chilled as quickly as possible after their preparation. Containers used for the
dispatch or storage of unpackaged prepared fresh fishery products stored under ice must ensure that melt water does not remain in
contact with the products. Whole and gutted fresh fishery products may be transported and stored in cooled water on board vessels.
May also continue to be transported in cooled water after landing, and be transported from aquaculture establishments, until they arrive
at the first establishment on land carrying out any activity other than transport or sorting.
 Frozen fishery products
Land establishments must have freezing equipment with sufficient capacity to lower the temperature rapidly so as to achieve a core
temperature of not more than -18 °C; refrigeration equipment with sufficient capacity to maintain fishery products in cold storage at
not more than -18 °C. Cold storage facilities must be equipped with a temperature-recording device in a place where it can be easily
read. The temperature sensor of the reader must be situated in the area where the temperature in the room is the highest;
All raw materials must be free from guts. The manufacturing process must satisfy the following requirements: Mechanical separation
must take place without undue delay after filleting. If whole fish are used, they must be gutted and washed beforehand. After
production, mechanically separated fishery products must be frozen as quickly as possible or incorporated in a product intended for
freezing or a stabilising treatment.

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 Processed fishery products: cooking crustaceans and molluscs
Rapid cooling must follow cooking. Cooling water must be potable water or, on board vessels, clean water. If no other method of
preservation is used, cooling must continue until a temperature approaching that of melting ice is reached. Shelling or shucking must
be carried out hygienically, avoiding contamination of the product. Where such operations are done by hand, workers must pay
particular attention to washing their hands. After shelling or shucking, cooked products must be frozen immediately (at temperature not
more than -18 °C), or be chilled as soon as possible to temperature approaching that of melting ice.

21. a) Write down the Organization of Fish Inspection and Quality Control (FIQC)
organogram of FIQC. The Ministry of Fisheries and Livestock of the Government of Bangladesh (GOB) has established FIQC wing under the
Department of Fisheries in 1975-76 to provide statutory support to processing plants and its value chain and to fulfil the
international requirement and achieve international recognition regarding fishery products. It got its legal backing in 1983, when
govt. enacted a comprehensive legislation entitled “The Fish & Fish Product (Inspection & Quality Control) Ordinance, 1983. The
formal organization of the Competent Authority is shown in the following organogram (Fig. 1):

Fig. 1: Organogram of Competent Authority of Bangladesh

b) What are the 1. The CA has a defined strategic objective of setting up of the necessary regulatory framework, to permit and maintain the export
purposes/ objectives status of Fish and Fishery Products to international and domestic markets for those establishments which ensure that all stages of
of establishing FIQC production, processing and distribution of fishery products under their control satisfy the relevant hygiene requirements.
in Bangladesh? 2. The fundamental objective is the pursuit of a high level of protection of human life and health and therefore the Bangladesh
regulatory framework has as its principal purpose to ensure a high level of consumer protection with regard to food safety respecting
the international specific hygiene rules.
22. Write in brief the major Major Inspection Activities:
inspection activities of
FIQC Inspection of compliance(Routine) according to the directions mentioned in the Fish & fish product(Inspection & Quality Control)
Rules, 1997

o Hygiene & sanitation of the establishment concerned


o Personal hygiene of workers concerned
o Stock verification of the declared lot/lots
o Evaluation of product quality (Physical, organoleptic, etc.)
o Collection of samples (Processed & raw) for lab. Analysis

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o Verification of establishment's own check system
o Verification of HACCP documents( particular attention is given to the CCP records)
o Supervisory inspection(Periodic& sudden) to verify the activities performed by the inspectors and to investigate major non-
compliance by the processing plants
o Annual inspection of the processing plant for issuing License. Inspection is conducted by a “National Team” formed by the
CCA). Particular attention is given on the compliance to EU Regulations/directives/decisions
23. Major activities of FIQC 1. Inspection of the processing plants, ice plants, landing centers, Depots, fish feed millers & traders
2. Collection of samples from the above mentioned establishments for laboratory analysis
3. Collection of samples for detection of residues(According to the “National Residue Control Plan (NRCP)”
4. Samples for residue monitoring are sent to the FlQC, Dhaka lab. for detection of Nitrofurans & Chloramphenicol, to the BAEC
for the detection of Heavy metal and to the BARI for the detection of pesticides, etc.
5. Lab. Analysis of collected samples((Microbiological, Chemical & filth)
6. Inter lab. tests of the samples
7. Issuing pre-shipment health/salubrity certificate for export
8. Satisfactory compliance inspection
9. Issuing License for the processing plants, ice plants, landing centers, Depots
10. Conducting training programs for all stake holders
11. Conducting awareness programs regarding emerging problems like Nitrofurans, Chloramphenicol, etc.
12. Implementation of traceability in fish and shrimp supply chain.
1. down briefly
Write Tasks of the Inspector
24. the task and duties of Fish inspectors tasks are as follows:
inspectors/auditors.
 Undertake regular routine and on-the-spot inspection of establishments, farms, fishing vessels, distribution centres, depots,
landing sites, ice plants, chill and cold stores, and means of transport.
 Undertake pre-shipment controls of consignment documentation, traceability records and respective own-checks controls and
sample testing as demanded.
 To prepare and submit reports to the Director regarding the status of sanitary conditions within the different entities controlled
in accordance with the outcome result system applied through the regulatory verification procedure.
 Monitor and control the implementation of the recommendations made as a result of the regular routine system, including
verifying that corrective measures demanded are realised in an efficient and effective manner.
 Ensure the appropriate certification of fishery products through the use of the different inspection forms and health

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certification processes, and ensure the withdrawal or condemnation of non-compliant products.
 Participate in the development of inspection methods and the training of operators in the production chain.
 To take samples and deliver them for analysis at an approved laboratory, to receive and interpret results and act accordingly.
 Undertake the collection and synthesis of statistical data at each inspection point

Responsibilities of the Inspector


Always remember that the inspector is an official representative of the Competent Authority and must exhibit a professional image
when dealing with establishment officials. This includes:

 respect for establishment policies when undertaking inspection / audits


 maintaining a professional bearing
 keeping strictly confidential information obtained from a company
 maintaining a good level of personal cleanliness and tidiness
 guarding against corrupt practices and conflicts of interest
Examples of corrupt practices are:

 receiving payments (in cash or kind) for approval of establishments, irrespective of compliance with the conditions
 fraudulent issue of export health certificates
 “sampling” of products for personal use or gain
Examples of conflicts of interest

 entering into a business relationship with a fishery business operators (e.g. consultancy/training contracts)
 investing in fishery sector activities
 requiring tests to be carried out in a laboratory in which there is a financial interest
Inspectors should follow the following basic rules:

 No gifts should be accepted from any person


 Do not accept offers of external employment unless approved by the Competent Authority
 Declare any relevant interests (including related activities of family members)

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Fig. 1: Organogram of Competent Authority of Bangladesh

Ministry of Fisheries and Livestock

CENTRAL COMPETENT AUTHORITY (CCA)


DoF - Director General (DG)

DoF - Principal Scientific Officer Director Inland Fisheries

REGIONSL CA LOCAL CA

FIQC FIQC FIQC Divisional


Khulna Dhaka Chittagong Deputy Director
Deputy Director Deputy Director Deputy Director (7)

LABORATORY
INSPECTION LABORATORY INSPECTION LABORATORY INSPECTION
Q. Manager
District
FIQC Q. Manager FIQC Q. Manager FIQC
Officers Technologists Officers Technologists Officers Technologists Fisheries Officer
Biochemist Biochemist Inspectors Biochemist
Inspectors Inspectors
Microbiologists Microbiologists (64)
Microbiologists
Tech. Assist. Tech. Assist. Tech. Assist.

Sub-units:
Satkhira Sub-units:
Inspectors Cox-Bazar Upazilla Fisheries
Benapole Inspectors Qfficer/Senior Upazilla
Inspectors Fisheries 34
Officer
(485)

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