Commercial Processing Example: Pickled Herring

Commercial Processing Example: Pickled Herring National Seafood HACCP Alliance for Training and Education Example: For Illustrative Purposes Only. Models are based in current guidance contained in FDA s Fish and Fishery Products Hazards and Control Guidance. Keep in mind that this model does not apply to all situations. Preliminary Steps Information Company Market Name Source of Fishery Product Describe the Food Method of Receiving, Storage and Distribution Finished Packaging Type Intended Use and Consumer ABC Pickled Fish Company, Anywhere, USA Herring or Sea Herring (Clupea spp.) Wild caught, purchased from primary processors Pickled (marinated) herring packed in plastic jars Herring is received packed in ice, then stored frozen. Frozen herring is thawed and processed and the finished product is packed in plastic jars that are stored and distributed refrigerated at 40 F/4.4 C or less. Plastic sealed jars (reduced oxygen environment). Pickled ready to eat product, to be consumed by general public. Description of Process Receive herring Wild caught whole herring are received fresh from packing houses (primary processors) in boxes packed with ice in a refrigerated truck. Maximum transit time from different primary processors is 6 hours. All incoming herring are evaluated according to company procedures including checking for adequacy of ice. De Ice and rinse Herring are de iced, rinsed and packed into containers for freezing. This is 30 minutes or less. Freeze Containers of herring are blast frozen at 31 F/ 35 C until solid and then moved into a storage freezer at 4 F/ 20 C for a minimum of 24 hours to kill parasites. Thaw Frozen herring are thawed as needed in tanks of continuously flowing water for 1 to 2 hours. Product temperature does not exceed 50 F/10 C during the thawing process. Head, gut and fillet Thaw tanks are drained and herring are moved to the processing area where they are headed, gutted and filleted by hand with knives. This takes no longer than 30 minutes. Dry salt Herring fillets are placed on racks, completely covered with salt and stored under refrigeration at 40 F/4.4 C for at least 24 hours. Rinse The racks are removed from the cooler and the herring fillets are rinsed with potable water to remove excess salt on the surface. This is continuous and doesn t take more than 30 minutes. Cure Rinsed herring fillets are placed into barrels to be cured. The curing occurs in brine using a ratio of 1.5 Kilograms of fish to 1.0 Kilogram of curing solution for at least 30 days at 40 F/4.4 C. Drain Cured product is then removed from the curing solution. This takes less than 30 minutes. Pack and label Pickled herring is packed in pre labeled plastic jars with screw lids and fresh pickling solution (vinegar and spices). This is a reduced oxygen package. This takes up to 30 minutes. Finished product refrigerated storage Plastic jars of pickled herring are stored under refrigeration at 40 F/4.4 C until needed to fill customer orders. Seafood HACCP Models: Pickled Herring Page 1 of 14

Seafood HACCP Models: Pickled Herring Page 2 of 14 ABC Pickled Herring Company Process Flow Chart Pickled Herring

Firm Name ABC Pickled Fish Company (1) Processing Step (2) List all potential biological, chemical, and physical food safety hazards that could be associated with this product and process. Hazard Analysis Worksheet Product Description: Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution (reduced oxygen package) Method of Storage & Distribution: Stored and distributed refrigerated at 40 o F Intended Use & Consumer: Ready to eat product, to be consumed by general public. (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this? ( or ) (4) Justify the decision that you made in column 3 (5) What control measure(s) can be applied to prevent this significant hazard? (6) Is this a Critical Control Point? ( or ) Sea herring are likely to have parasites Freezing at a later will kill parasites Receive growth temperature C. botulinum toxin Food additives is likely to form if herring are temperature d Pathogens are likely to grow if temperature d in transit Raw herring are not in reduced oxygen package at this food additives are used Herring must be completely surrounded with ice on delivery Fish must be completely surrounded with ice on delivery Food allergens Metal contamination Herring is a food allergen t likely to occur at this pack/label will identify fish Sea herring are likely to have parasites Freezing at a later will kill parasites De-Ice and Rinse growth- temperature C. botulinum toxin not likely because of short time at this processing Pathogen growth not likely because of short time at this processing Raw herring are not in reduced oxygen package at this Food additives food additives are used Food allergens Herring is a food allergen Metal contamination t likely to occur at this pack/label will identify fish Seafood HACCP Models: Pickled Herring Page 3 of 14

(1) Processing Step (2) List all potential biological, chemical, and physical food safety hazards that could be associated with this product and process. (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this? ( or ) (4) Justify the decision that you made in column 3 (5) What control measure(s) can be applied to prevent this significant hazard? (6) Is this a Critical Control Point? ( or ) Sea herring are likely to have parasites Fish will be frozen for the proper time and temperature to kill parasites at this Freeze growth- temperature C. botulinum toxin unlikely to form at freezer temperatures Pathogens unlikely to grow at freezer temperatures Raw herring are not in reduced oxygen package at this Food additives food additives are used Food allergens Herring is a food allergen pack/label will identify fish Metal contamination t likely to occur at this Thaw growth- temperature C. botulinum toxin were controlled at freeze not likely because of short time at this processing Pathogen growth not likely because of short time at this processing Raw herring are not in reduced oxygen package at this Food additives food additives are used Food allergens Herring is a food allergen pack/label will identify fish Metal contamination t likely to occur at this Head, gut and fillet growth- temperature C. botulinum toxin were controlled at freeze not likely because of short time at this processing Pathogen growth not likely because of short time at this processing Raw herring are not in reduced oxygen package at this Food additives food additives are used Food allergens Herring is a food allergen Metal contamination Knives are not likely to chip and contaminate product with metal pack/label will identify fish Seafood HACCP Models: Pickled Herring Page 4 of 14

(1) Processing Step Dry salt (2) List all potential biological, chemical, and physical food safety hazards that could be associated with this product and process. growth temperature (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this? ( or ) C. botulinum toxin (4) Justify the decision that you made in column 3 were controlled at freeze is likely to form if fish are temperature d S. aureus toxin and other pathogens are likely to grow if temperature d A salt level of 5% is a necessary barrier to growth in final reduced oxygen packaged product (5) What control measure(s) can be applied to prevent this significant hazard? Enough salt must be added at this to achieve 5% water phase salt in the finished product (6) Is this a Critical Control Point? ( or ) Food additives food additives are used Rinse Food allergens Herring is a food allergen Metal contamination growth temperature C. botulinum toxin t likely to occur to occur at this were controlled at freeze not likely because of short time at this processing Pathogen growth not likely because of short time at this processing Raw herring are not in reduced oxygen package at this pack/label will identify fish Food additives food additives are used Cure Food allergens Herring is a food allergen Metal contamination t likely to occur at this growth temperature C. botulinum toxin were controlled at freeze is likely to form if fish are temperature d S. aureus and other pathogens are likely to grow if temperature d Limited oxygen environment could occur during storage pack/label will identify fish Food additives food additives are used Food allergens Herring is a food allergen Metal contamination t likely to occur at this pack/label will identify fish Seafood HACCP Models: Pickled Herring Page 5 of 14

(1) Processing Step Drain (2) List all potential biological, chemical, and physical food safety hazards that could be associated with this product and process. growth temperature (3) Is the potential food safety hazard significant (introduced, enhanced or eliminated) at this? ( or ) C. botulinum toxin (4) Justify the decision that you made in column 3 were controlled at freeze not likely to form because of short time at this processing Pathogens not likely to grow because of short time at this processing Raw herring are not in reduced oxygen environment at this (5) What control measure(s) can be applied to prevent this significant hazard? (6) Is this a Critical Control Point? ( or ) Pack and Label Finished Product refrigerated storage Food additives food additives are used Food allergens Herring is a food allergen Metal contamination t likely to occur at this Pathogen growth temperature C. botulinum toxin were controlled at freeze not likely to form because of short time at this processing Pathogens not likely to grow b/c of short time at this processing C. botulinum toxin not likely to form because of short time at this processing Food additives food additives are used Food allergens Herring is a food allergen Metal contamination t likely to occur at this growth temperature C. botulinum toxin were controlled at freeze is likely to form if fish are temperature d Pathogens are likely to grow if temperature d C. bot. could grow and produce toxin in reduced oxygen package if temperature d Food additives food additives are used Food allergens Allergens were controlled at pack and label Metal contamination t likely to occur at this pack/label will identify fish this will contain the word herring in the ingredient list Seafood HACCP Models: Pickled Herring Page 6 of 14

ABC Pickled Herring Company Process Flow Chart Pickled Herring Shaded s are Critical Control Points Seafood HACCP Models: Pickled Herring Page 7 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Receiving Significant Hazard(s) growth temperature Critical Limits for each Control Measure What All fish are completely surrounded with ice at the time of delivery Adequacy of ice surrounding fish at time of delivery Monitoring How Frequency Who Visual check of adequacy of ice in a representative number of containers Each delivery Receiving Manager Corrective Action Verification If: Ice is inadequate Then: Reject the product or chill and hold the product until time and temperature exposure above 40 F is determined or test a minimum of 60 fish for histamine. Discontinue use of supplier until transportation procedures are corrected. Weekly review of monitoring, and corrective action records. Records Receiving Log Signature: Date: Seafood HACCP Models: Pickled Herring Page 8 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Freeze Significant Hazard(s) Critical Limits for each Control Measure What Fish are blast frozen at -31 F until solid and then moved into a storage freezer at -4 F for a minimum of 24 hours Blast freezer temperature Fish is solidly frozen Time held at 4 F storage temp. Monitoring How Frequency Continuous temperature recorder Physical check of solid frozen condition Continuous time and temperature recorder Continuous with visual check once per day At end of blast freezing Continuous with visual checks at the beginning and end of each storage period per batch Who Freezer manager Corrective Action Verification Records If: Blast freezer temperature is too high Then: Lower temperature and re-start the freezing cycle. If: Time in blast is too short Then: Extend frozen storage time to -4 F for 7 days. Determine if blast freezer is malfunctioning and fix as necessary. Weekly review of monitoring and corrective action records. Check accuracy of temperature recorder prior to use or daily Calibrate thermometer once per year. Blast Freezer Log and Time-Temperature recorder printout Storage Freezer Log and Time-Temperature recorder printout Temperature recorder accuracy check and calibration log Signature: Date: Seafood HACCP Models: Pickled Herring Page 9 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Dry Salt Fillets Significant Hazard(s) growth temperature Critical Limits for each Control Measure What How Maintain cooler temperature at 40 F Cooler temperature Continuous time-temperature recorder Monitoring Frequency Who Continuous recording and visual check once per day Cooler manager Corrective Action Verification If cooler temperature is above 40 F, then move product to another cooler or ice and hold for evaluation. Evaluate product safety by determining cumulative exposure temperature and time above 40 F, and accept or destroy as necessary. Adjust or repair cooler as necessary. Weekly review of monitoring and corrective action records Check accuracy of temperature recorder prior to use and daily Calibrate recorder once per year. Records Weekly Cooler Log and time and temperature recording charts Thermometer accuracy check and calibration log Signature: Date: Seafood HACCP Models: Pickled Herring Page 10 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Dry Salt Fillets Significant Hazard(s) C. botulinum toxic (Type E and non-proteolytic Type B and F) Critical Limits for each Control Measure What All fish are completely covered with salt before they are placed in the cooler* Fish are salted for at least 24 hours* Fish are completely covered with salt Start and end time of salting Monitoring How Frequency Visual check of fish Clock Each batch Who Process supervisor Corrective Action Verification If fish are not completely covered with salt, Then apply more salt before placing in the cooler If time is less than 24 hours, Then extend time fish are salted. Determine why procedures were not followed and provide training if necessary. Quarterly lab testing for water phase salt content of finished product Weekly review of monitoring and corrective action records Records Dry Salt Log Dry Salting Validation Report Signature: Date: Seafood HACCP Models: Pickled Herring Page 11 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Curing Significant Hazard(s) growth temperature Maintain cooler temperature at 40 F C. botulinum toxin (Type A and proteolytic B and F) Critical Limits for each Control Measure Monitoring What How Frequency Who Corrective Action Verification Maintain cooler temperature at 40 F Cooler temperature Continuous time-temperature recorder Continuous recording and visual check once per day Cooler manager If cooler temperature is above 40 F, then move product to another cooler or ice and hold for evaluation. Adjust or repair cooler as necessary. Evaluate product safety by determining cumulative exposure temperature and time above 40 F. Destroy if necessary. Weekly review of monitoring and corrective action records Check accuracy of temperature recorder prior to use and daily and calibrate once per year. Records Weekly Cooler Log and time temperature recording chart Thermometer accuracy check and calibration log Signature: Date: Seafood HACCP Models: Pickled Herring Page 12 of 14

HACCP Plan Form Firm Name ABC Pickled Fish Company Product Description Pickled herring (also called marinated herring) packed in plastic jars with vinegar solution Method of Storage & Distribution Stored and distributed refrigerated at 40 o F in a reduced oxygen package Intended Use & Consumer Ready to eat product, to be consumed by the general public Critical Control Point (CCP) Finished product refrigerated storage Significant Hazard(s) Pathogen growth temperature C. botulinum toxin (Type A and proteolytic B and F) Critical Limits for each Control Measure Maintain cooler temperature at 40 F What Cooler temperature Monitoring How Frequency Continuous time-temperature recorder Continuous recording and visual check once per day Who Corrective Action Cooler Manager Move product to another cooler or ice. Adjust or repair cooler as necessary. Evaluate product safety by determining cumulative exposure temperature and time above 40 F. Destroy if necessary. Verification Weekly review of records Check accuracy of temperature recorder prior to use and daily Calibrate temperature recorder once per year. Records Weekly cooler log and time temperature recording chart Thermometer accuracy check and calibration log Signature: Date: Seafood HACCP Models: Pickled Herring Page 14 of 14