February 1993

SRAC Publication No. 490

SouthernRegionalAquacultureCenter

Developing a HACCP Program forthe Catfish Processing Industry

George A. Schuler and P.T. Tybor*

Hazard analysis of critical controlpoints (HACCP) is an inspectionconcept developed by the Na-tional Aeronautics and SpaceAdministration (NASA) and thePillsbury Company that combinesrisk assessment with critical con-trol points. These tools of qualitycontrol are being expanded to in-clude quality assurance from theproducer (harvester) to the con-sumer. The idea of HACCP is tolocate and control potential prob-lems before they become a reality.

Several agencies are now involvedin developing a HACCP program.These include the U.S. Departmentof Agriculture, Food and DrugAdministration and NationalMarine Fisheries Service. Most pro-grams utilize from six to tenpoints. This paper utilizes sevenpoints to develop a program.

What is HACCP?

HACCP locates specific points inthe food plant that must be con-trolled to produce a high qualityproduct under good sanitation, la-beled correctly and free of contami-nation. One might be reminded ofa particular problem that occurredlast week, or even yesterday. Someexamples include:

* University of Georgia

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the breakdown of a refrigera-tion unit, causing the tempera-ture to rise and product to thaw;

a pile of fish you saw lying onthe table during lunch;

fish that wasn’t tested for off-flavor;

a new employee who didn’t re-

■ a truck that breaks down andsits full of product, overnight.

These are just a few critical controlpoints (CCP) that could exist.Somehow, they must be trans-ferred to your employees withoutgiving them license to throw awayproduct indiscriminately and thusaffect your bottom line.

move all of the viscera, result-ing in customer complaints;

an old product pulled from theback of the freezer because you 1■ Commitmentneeded to fill an order (two of The scientific community and theyour customers complained, re- food industry are learning that mi-turned the product and are nowformer customers); or

croorganisms cannot be controlledby inspections of finished product.

Figure 1. A well-lighted, well-designed plant is conducive to better qualitycontrol.

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submission and approval by theappropriate regulating agency.

Figure 2. Early chilling of the product assures slower bacterial growth.

Prevention of contamination, Many processors as well as scien-whether microbial, physical or tists and governmental regulatorschemical, during processing is the believe that HACCP is the bestkey to longer and safer shelf-life of available voluntary program forany product. A dedicated HACCP achieving the objectives of foodprogram allows this to be done. quality and safety. Since the pro-

Seafood is an expanding part ofthe food industry. This industrymust demonstrate its own capabil-ity to produce consistently clean,wholesome and safe product. Aspounds per capita consumption ofseafood increases, the industry canexpect to have more attention

gram is voluntary at present, thefirst criteria for success is totalcommitment by the man-ager/owner of the food facility.Management must be willing todelegate responsibility and author-ity to the quality assurance man-ager or the HACCP team.

from the news media. The indus- Future regulation of the industrytry must portray an image of qual- may well require each processority, safety and wholesomeness to to develop a HACCP plan fortheir customers and consumers.

2 ■ Develop a HACCPteam

There are certain individualswithin a plant who are safetyand/or quality conscious. Theseindividuals should make up theteam. Care should be taken torepresent as many areas of theplant as possible since this iswhere the knowledge will origi-nate. Production, engineering andquality control are obvious, but donot overlook procurement, salesand one of the most important butmost often overlooked department– sanitation. Yes, individualscleaning your plant can informyou about product waste at theend of a shift, especially if you arerunning two shifts. They knowwhere the frayed belts, cloggeddrains and deferred maintenanceproblems are.

Your department managers mayalready meet on a regularly sched-uled basis but this team should bemade up of people who are in inti-mate contact with the product, i.e.,line leaders – the ones who arefirst on the job. Discuss with them

the program they are about to de-velop. Assure them of your com-mitment and cooperation. Per-haps invite an outside individualto discuss HACCP with them.

3 . Construct a flowdiagram

The first step may be to look atblueprints. Are they up to date?(See figure on pages 4 and 5.) Arehandwashing facilities locatedstrategically throughout the plant?Once inspection of seafoodprocessing becomes a reality, aplumbing plan such as this will berequired. A site plan to show theexact location of the official prem-ises and a floor plan that showsthe flow of product ensuring re-contamination does not occur willalso be required by the regulatoryagency.

Construct a good flow diagramutilizing the prints and knowledgeof team members. Include everyprocess the product encounters.(See Figure 5 on page 6.) Discusseach step until everyone on theteam has a clear picture of whathappens to the product at this par-ticular step. For instance, the 14thstep in Figure 5 is washing. Is thewater potable, chlorinated, and ifso, how many ppm?

4 ■ Determine criticalcontrol points

This portion of development re-quires the most thought. It issometimes difficult to separate anitem that should be controlled butis not critical to human health. Forexample, a 4-ounce fillet foundwithin a package supposedly con-taining 6-ounce fillets is mislabel-ing but is not an item critical tohuman health. However, inclu-sion of fecal material on the fillet,resulting from improper viscera re-moval and/or improper washing,would certainly be of concern.The HACCP team should deter-mine CCPs after constructing the

flow diagram with, perhaps, thehelp of a facilitator.

A critical control point is a point inoperations which, if not controlledproperly, could result in a humanhealth problem. In contrast, a con-trol point is a point in the opera-tion which, if not monitored, mayresult in a definite reduction inproduct quality or marketability.Allowing a 4-ounce fillet to bepackaged as a 6-ounce fillet doesnot endanger human health but itaffects marketability and may beconsidered economic fraud. Someplans now being developed in-clude economic fraud with humanhealth problems when consideringCCPS.

Individuals from the various areasof the plant should identify theCCPS, being careful to separatecontrol points from CCPS. Theremay be areas where there are noCCPS. As the program progresses,areas may be added or deleted asconditions in the plant change. Aplant may have four to six CCPSon which it should focus. In theplant in the centerfold there wouldbe:

1. sampling live fish

2. viscera removal

3. washing

4. filleting

5. trucks

6. customer storage.

5 ■ Set controlprocedures andcorrective actions

Now that CCPS have been deter-mined, what are you going to doabout it? Who will do it? Whenwill it be done? What happens tothe product involved? These ques-tions must be answered. The an-swers will test management’s com-mitment. Control proceduresoutlining exact parameters andcorrective actions to enforce CCPsmust be written.

Suppose the CCP at the filletingstation is “presence of bones in thefillet.” The control procedurewould be to inspect ten tubs of fil-lets from each lot for bone frag-ments and record the findings. Iffragments are found, corrective ac-tion may include informing the fil-leters and requiring rechecks of fil-lets for bones.

6 ■ Monitor, reportand act

Three major areas of concern to bemonitored include:

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Microbial – limiting the totalload which would lead to spoil-age as well as specific microor-ganisms; i.e., Clostridium, E. coli,Staphylococcus, Campylobacter,and Listeria, which could causefoodborne illness.

Chemical – hazards such as an-tibiotics, algaecides and otherchemicals introduced into theplant via the seafood. Caremust also be taken with in-plant chemicals such as clean-ers, sanitizers and lubricants.Strange as it seems, paint hasn’tbeen implicated in the contami-nation of food products.

Physical – concerns includemany items an employee mayinadvertently add to your pro-duct. Tissues have been foundin bread, cigarette filters incanned peas and bolts togetherwith teflon filters in tomato pro-ducts. These make for poor cus-tomer relations.

Very few of us like reports orforms but they are needed if theprogram is to be viable. Supposeyou have determined that one ofyour CCPS is the temperature ofyour product cooler. Since fishfreezes at 28°F and since we knowListeria can survive at 37°F, ourgoal maybe 33°F. We need toknow how well our refrigerationunit is functioning. Will it uni-formly maintain 33°F? A chartsimilar to the one shown in Figure8 could be used in which the

Figure 5. A simplified flow chart diagram for a processing plant.

employee assigned places an “X”at the proper temperature. Keeprecords simple and meaningful.An automatic recorder maybemore useful for something thiscritical. Information should betransmitted to management andmaintenance in the event of a mal-function. Should the temperaturerise above the limits set, qualitycontrol personnel must make a de-termination as to the fate of theproduct. This will depend on: (1)temperature of the product, (2)length of time the CCP was vio-lated and (3) corrective action pro-cedures spelled out in the HACCPplan.

7. Training

Employees need to be trained con-cerning the new system of qualitycontrol. They will make or breakthe program. The training pro-gram may consist of breaking intogroups and developing or revisingthe program. Remember this isNOT a static program – it willevolve as need for other CCPS be-comes evident.

SummaryFor a HACCP program to be vi-able, it must involve the commit-ment of management and the em-ployees. The seafood industry hasthe opportunity to implement aprogram to regulate itself beforegovernment regulators make thedecision for us. Identify CCPS, setparameters, create a procedure tomonitor the CCPS, determine safe-guards, set up a record system thatworks and continually verify thatthe system is working.

A HACCP system is not setupquickly and is not static, but, oncein place, you will feel you havecontrol of your operation.

AcknowledgmentThanks to George Low, draftsmanwith the Georgia Cooperative Ex-tension Service, for preparation offigures used in this publication.

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Figure 7. Prior to final packaging, fillets undergo quick freezing.

Figure 8. A simplified refrigeration record which charts acceptable and unacceptable temperatures.

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The work reported in this publication was supported in part by the Southern Regional Aquaculture Center through Grant No. 89-38500-4516 from the United StatesDepartment of Agriculture.

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