Michigan smoked fish processors need HACCP plans

State regulations require a HACCP with several critical control points.

The FDA requires that all seafood products must have a HACCP (Hazard Analysis and Critical Control Point) program to help the operator mitigate the risk of chemical, physical and biological hazards in food products. A working HACCP plan helps the regulator understand the food sanitation effort on a day-to-day basis, aids in traceability and in determining the cause of public health problems related to food products. All of the typical HACCP requirements apply, but the Michigan Administrative Code requires some extra requirements for commercial fish smoking.

Typical requirements in a HACCP plan would include:

  • Identification of the specific smoked fish product, or identification of the category of products.
  • Identification of potential physical, chemical or biological hazards, and establishment of critical limits for potential hazards
  • A flow diagram describing the entire process, including packaging and storage.
  • How, and by whom, the critical control points are to be monitored. This must also include the frequency of monitoring.
  • The method for verifying that monitoring is taking place in the manner described in the plan.
  • Actions taken when the critical limits are exceeded.
  • Record keeping to determine that the HACCP plan is being managed.

Two specific items needed for Michigan fish smoking operations:

  • The code requires a training plan to address food safety issues that may be of concern. Typically, training is addressed in prerequisites to the HACCP
  • The code also identifies and requires specific critical control points including, raw material thawing, brining or dry salting, smoking, cooling after smoking, and post-smoke processing.

Commercial fish smoking operations can refer to MDARD Food and Dairy Division Administrative Code.

Michigan State University Extension and Innovation Counselors at the Michigan State University Product Center assist food business operators in the establishment of good practices and in producing safe food products. For further information and assistance with employee communications please contact your local Michigan State University Extension office. 

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