MSU Extension

Michigan Sea Grant and Michigan State University Extension conducted a session called Freshwater Fish as a Raw Material for Processing at the Growing Power Urban and Small Farms Conference held in Milwaukee, Wisconsin in November.

Growing Power first hosted the event in 2010 where nearly 1,500 participants met at the Milwaukee State Fair to share ideas for building healthy and resilient community-based food systems. The conference included farmers, aspiring farmers, renewable energy experts, urban planners, corporate executives, politicians, academics, and chefs.

Participants came from nearly every state as well as from several countries. The mission at Growing Power is to support people from diverse backgrounds, and the environments in which they live, by helping to provide equal access to healthy high-quality, safe and affordable food for people in all communities.

There is a trend developing in the United State of growing more fish in an urban environment. Those growing fish in an urban environment must comply with the same fish handling methods as rural aquaculture and commercial fisheries. Fish farmers at this conference session learned that those who process their own fish are directly affected by the U.S. Food and Drug Administration (FDA) HACCP regulation. Those that sell fish to a processor are indirectly affected by the HACCP regulation. Processors of domestic, as well as, imported fishery products will take greater responsibility for incoming materials, which will directly affect aquaculture producers.

If the supplier, such as an aquaculture producer, does not provide satisfactory information about how the fish were handled, the HACCP plan will strengthen the processor’s position in refusing to accept shipment. The aquaculture producer, thus, will be responsible for providing specific information to fish processors who purchase their fish or allow these fish processors or their representative to visit their sites to collect information on their aquaculture practices. This information may include proper use of aquaculture drugs and prevention of product contamination with environmental chemical contaminants and agriculture chemicals. Fish farmers can expect to bear increased responsibility for documenting compliance with the HACCP regulations, as it is doubtful the FDA will permit direct sale of aquaculture products to end users without HACCP controls, even when fish production and harvesting, trucking, and retail are excluded from the regulation.

There are practices that are exempt from the FDA HACCP regulations, but the aquaculture producer will still need to comply with specific state and/or local regulations where applicable. For instance, an aquaculture producer would not be subject to the FDA HACCP regulations when he harvests and boxes his fish whole, on ice, for immediate transportation to a wholesaler or retailer within the state or outside the state. The aquaculture producer would not be subject to the HACCP regulation whether he sold his boxed, whole fish to a wholesaler at the farm site and the wholesaler transported the fish off-farm and to a retail market or if the producer did the transportation. But, if the aquaculture producer holds the product after harvesting and prior to distribution for 24 hours or more, that operation would be subject to the regulations. Holding is deemed processing as defined by the HACCP regulation. If the aquaculture producer performs any other activities as defined by the regulations such as heading, eviscerating and freezing, he would be subject to the regulations.

Other practices that are exempt from the FDA HACCP regulations include live fish hauling to various market outlets and custom processing the fish directly for a costumer who does not resell it. Fish may be taken to some location in the same state or may be taken to another state for consumption.

Aquaculture producers who do not process their own fish may not be directly affected by the FDA HACCP regulations, but may in many ways be affected indirectly. It is important that all aquaculture producers take it upon themselves to become aware of the HACCP regulations to circumvent any surprises when it comes time to market their fish.