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Seafood Processing Plants
Guidelines for BAP Standards
GUIDELINES — SEAFOOD PROCESSING PLANTS
The following guidelines provide perspective and clarification for the standards referenced in the Application/Audit Form.
The application and guidelines were designed to assist program applicants in assessing their facilities and developing man-
agement systems for compliance with the certification standards.
The word "shall" is used throughout these guidelines to indicate mandatory provisions. For further information, pleaserefer to the additional resources listed.
Standard 1 — Community
• business licenses Property Rights and Regulatory Compliance
• aquaculture licenses• land deeds or lease agreements Processing plants shall comply with local and national laws
• land use taxes and environmental regulations, including those related to
• construction permits product exportation, and provide current documentation
• water use permits that demonstrates legal rights for land use, water use, con-
• mangrove protection struction and operation.
• effluent permits• predator control permits Reasons for Standard
• well operation permits• landfill operation permits Certified processing plants shall comply with applicable busi- • waste treatment disposal permits.
ness-related laws and regulations for waste disposal, efflu-ents, pest control, etc. These regulations are needed to assure ACC evaluators cannot know all laws that apply to seafood that processing plants provide pertinent information to gov- proc essing in all nations. Processing plants have the respon- ernments and pay fees to support such programs. BAP requires sibility to obtain all necessary documentation for siting, compliance because it recognizes that not all governmental constructing and operating their facilities.
agencies have sufficient resources to effectively enforce laws.
Assistance in determining these necessary permits and licens- Processing plants can represent considerable sources of em - es can be sought from governmental agencies responsible for ployment and tax revenue for local communities and nation- environmental protection, water management and transpor- al governments. Certified facilities should demonstrate man- tation. ACC evaluators shall also become familiar with the agement commitment to both fiscal responsibility and com- legal requirements within the areas they service.
munity good. Facilities shall meet established export, sani-tation and food safety standards through compliance with During the ACC audit, the plant representative shall present all local and national regulations or importer review.
necessary documents to the evaluator. All documents shall becurrent, and processing plants shall be in compliance with the requirements stipulated by the documents. In some cases, Regulations regarding the operation and resource use of pro- governmental agencies may have waived one or more permits.
cessing plants vary significantly from place to place. Among Letters granting the waivers or other proof of waivers shall be other requirements, such laws can call for: Guidelines copyright 2008, Global Aquaculture Alliance. Do not reproduce without permission.
Global Aquaculture Alliance • 5661 Telegraph Rd., Suite 3A • St. Louis, MO 63129 USA • www.gaalliance.org Seafood Processing Plants Guidelines for BAP Standards
Standard 2 — Community
given to workers who operate cutting machines and other Worker Safety and Employee Relations
Processing plants shall comply with local and national labor
Workers should be trained in the first aid of electrical shock, laws to assure worker safety and adequate compensation.
profuse bleeding, and other possible medical emergencies.
They must also be informed of emergency evacuation proce- Reasons for Standard
dures in case of fire or release of toxic gases.
Processing work is potentially dangerous because of the types In some locations it is necessary for plants to provide meals of machinery needed and the use of potentially hazardous for workers. In such cases, food services should provide whole- materials, especially refrigerants. It is the responsibility of some meals for workers, with food storage and preparation processing plants to provide safe and healthy working condi- done in a responsible manner. Safe drinking water shall be tions and training on worker safety.
available at all times to employees working at the facility.
Most processing of aquaculture products for export to Europeand the United States is conducted in tropical nations where An adequate number of working toilets and hand-washing wage or other labor laws are not always consistently en - facilities shall be available. If living quarters are provided, forced. Since processing plants can be a major source of job they should be well ventilated and have adequate shower opportunities, they should maintain a good working relation- and toilet facilities. Trash and garbage should not accumu- ship with not only employees but the communities in which late in living, food preparation or dining areas. Health screen- ing with documented results by employee should be conductedat least every six months.
Implementation
To receive BAP certification, processing plant management
During the facility audit, the ACC evaluator will evaluate shall show both compliance with labor laws and a commit- whether conditions comply with labor laws. The evaluator ment to worker safety. Certified processing plants shall pro- will also interview a random sample of workers to obtain vide legal wages and a safe working environment, and efforts their opinions about wages and safety conditions.
should be made to exceed these minimum requirements. For Additional Information
Workers should be given adequate initial training, as well asregular refresher training, on safety in all areas of plant oper- Safety for Fish Farm Workers
ation. Safety equipment such as machine guards, safety gog- D. C. Minchew — 1999 gles and respirators, as well as training in their use, should be USDA/Cooperative State Research and Extension ServiceWashington, D.C., USA Standard 3 — Environment
Effluent Management
Processing plants shall dispose of process water and sew -
water shall comply with government regulations or the BAP
age in a responsible manner that does not create pollution,
criteria below, whichever are more strict. Plants shall con -
cause excessive odor or spread disease. Water quality meas-
tinue compliance with these criteria to maintain certifi-
urements of plant effluents that enter natural bodies of
BAP Water Quality Criteria — Processing Plants
Final Value
(After 5 years)
pH (standard units) Total suspended solids (mg/L) Soluble phosphorus (mg/L) Total ammonia nitrogen (mg/L) 5-day biochemical oxygen demand (mg/L) Oil and grease (mg/L) No water discharge No water discharge Water with less than 1 ppt salinity or specific con ductance below 1,500 μmhos/cm is considered fresh.
Seafood Processing Plants Guidelines for BAP Standards
Reasons for Standard
sewer systems, canals or other waterways shall not cause Processing plants discharge not only sewage from employee deterioration of ambient conditions. toilet facilities, but effluents from ice baths, cleaning and To eliminate the chance of disease transmission from efflu- sani tizing. Effluents from packing processes can include organ - ents discharged to natural waters, plants should screen out ic matter, offal/viscera from fish and shellfish, high residual solids and hold effluents in oxidation ponds or tanks before levels of chlorine, phosphorus deter gents and other nutrients.
release. Steps shall also be taken to control odors. These substances can contribute to eutrophication, sedimen-tation, high oxygen demand and pollution in receiving water.
Facilities shall verify that the quality of their discharge water They can also transmit diseases to wild aquatic animals. complies with all permitted standards. Plants that discharge Processing by-products and other plant waste can create a water directly into streams, rivers or estuaries shall have gov- significant odor when not disposed of properly. Such odors shall ernment permits authorizing the activity and test results thatdemonstrate they are in compliance with the standards. Sam - not be a nuisance for neighboring communities or businesses. ples should be taken during periods of processing, rather than inactive periods at the plant. Processing plants shall determine the levels of soluble phos- The BAP water quality criteria for processing plants are dif- phorus, ammonia nitrogen, suspended solids, BOD, pH and salin- ferent from those for other aquaculture facilities because ity of the source water used in processing. When sampling, of the plants' common pretreatment of effluents before re - plants should record the source water volume, influent (un - lease. In addition, although effluents from plants can be more treat ed process water) and effluent discharged after treatment. concentrated than those from other facilities, this is mitigat -ed by the much lower volumes released by the plants. Processing plants should implement best management prac-tices to treat wastes with a goal of meeting or exceeding in - For Additional Information
dustry standards in the countries in which they are located.
Plants shall not exceed permitted load levels when effluents Global Aquaculture Advocate
are discharged into public/municipal water treatment sys- Volume 3, Issue 5, 2000, pp. 61-66 tems or pollute receiving water into which they are discharg - "Effluent Composition and Water Quality Standards" ed. For plants that treat their own effluents and/or sew age C. E. Boyd and D. Gautier in set tling ponds or oxidation lagoons, water discharged into Standard 4 — Environment
icals and wastes collected after spills should be properly con- Storage and Disposal of Plant Supplies
fined, labeled and disposed of in a safe place to avoid environ-mental damage or danger to animals or humans.
Fuel, lubricants, plant chemicals and potentially toxic or dan-
gerous compounds shall be properly labeled, stored, used
Hazardous chemicals such as insecticides, chlorides and sodi- and disposed of in a safe and responsible manner.
um metabisulfite shall be stored in locked, well-ventilated,water-tight buildings. The buildings' concrete floors should Reasons for Standard
slope to a center basin for containing spills. Warning signs shall Processing plants regularly use a variety of chemicals and toxic be posted. Oxidants shall be stored in a safe area where they substances that can cause damage to products, workers or the will not come into contact with diesel or other oils to avoid explosion. Secondary containment for fuel storage is requir ed,and "flammable material" and "no smoking" signs shall be Gaseous ammonia and refrigerants can be dangerous to work- installed at fuel storage sites.
ers and contaminate the environment, while chemicals likesodium metabisulfite and chlorine, if not used at safe levels, Procedures should be developed for managing spills or leaks are a potential hazard to both the health of workers and the of oil, fuel, gases, chemicals and other products. The equip - safety of the plant's products. Fuel and oil spills, ammonia ment and supplies needed for managing and cleaning up these leaks and the improper use of pesticides and other chemicals spills shall be readily available and accessible. Workers should can result in water pollution and cause toxicity to aquatic be trained to properly use the equipment and handle the organisms and wildlife. contained waste. In particular, ammonia shall be properlystored and workers who use it trained to handle the gas if it escapes into the atmosphere. Potentially toxic compounds and chemicals shall be properlylabeled, stored and used according to instructions. All gov- For Additional Information
ernment regulations relating to the use or handling of theproducts shall be followed. Disposal of unwanted lubricants Sanitation Control Procedures for Processing
and outdated chemicals shall be carried out in a safe, respon- Fish and Fishery Products
sible manner to prevent environmental contamination.
National Seafood HACCP Alliance — 2000 Oil leaks and spills from equipment should be prevented through USDA NRCS AL Guide Sheet No. AL 701
good maintenance. Used oil and contaminated refrigerants Spill Prevention Control and Countermeasures should be removed and disposed of properly. Outdated chem- Seafood Processing Plants Guidelines for BAP Standards
Standard 5 — Environment
quently and disposed of properly. Some by-products can be used as animal feed or dried for use as feed ingredients. Ifsuch uses are not suitable, the by-products shall be boiled, Processing by-products, garbage, and paper and plastic
burned and/ or buried at least two feet deep. If required by refuse shall be disposed of in a sanitary, responsible and
local authorities, plants must be properly licensed to dispose bio secure manner.
of wastes. Solid wastes should be removed before they be -come part of the facility effluent. Reasons for Standard
Improper disposal of trash and garbage — especially process -
Trash and garbage may not be dumped on vacant land. Such ing by-products such as heads, scales, bones, shells, offal/ waste shall be burned, composted or put in a landfill in accor- viscera, etc. — can create ecological nuisances in surround- dance with local laws. Composting procedures shall not cre- ing areas and attract rats, insects and other pests. Poorly ate odor problems or attract wild animals.
handled processing by-products can also transmit diseases towild aquatic stocks.
The BAP program encourages recycling of paper and plasticwaste where it is possible. Effective management of these The smell of decomposition can become a serious nuisance wastes depends upon the availability of convenient waste for neighboring communities. Runoff from refuse piles can containers that are serviced at regular intervals. cause pollution and contaminate ground water. Empty plastic bags and other containers do not decompose For Additional Information
quickly. They can be a hazard to animals that become en - Environmental Engineering
tangled in them.
P. A. Vesilind, J. J. Peirce, R. F. Weiner — 1994 Butterworth-Heinemann Boston, Massachusetts, USA Processing by-products generally represent the largest chal-lenge in waste disposal for plants, so a rigorous program of by-product removal shall be in place. Processing by-products U.S. Enviromental Protection Agency shall be stored in covered containers or silos, removed fre- Standard 6 — Food Safety
SSOPs are based on good manufacturing practices (GMPs, Food Safety and Quality Assurance
called codes of practice by the EC/DG) and are considered"nonprocess" environmental controls that prevent adulter- Processing plants shall have a current HACCP plan and
ation of products during processing through rigorous clean- proc ess control program to control food hazards and ensure
ing, sanitizing, plant maintenance, exclusion of pests, con- product safety. Prod uction process controls that ensure
trol of wastes and employee hygiene. The key to maintain- product quality shall be documented.
ing the safety and cleanliness of the plant environment is incontrolling the movement of product, ingredients, packag- Reasons for Standard
ing and personnel into and out of processing areas. To comply with European Commission Health and ConsumerProtection Directorate General (EC/DG), United States Food Examples of food hazards addressed by HACCP and common and Drug Administration (USFDA) and Canadian Food Inspec - to most seafood processing facilities include: tion Agency (CFIA) regulations, food production processorsshall assure consumers that the food they produce is pure • physical hazards
and wholesome, safe to consume and produced under sani- • microbiological contamination
tary conditions. To better protect consumers and assure food • chemical contamination
safety, EC/DG, USFDA and CFIA legally mandated in 1999 that • pesticides and drug residues
the hazard analysis critical control point (HACCP) system be • natural toxins
implemented for processing all seafood products sold in the • decomposition in scombroid toxin-forming species
European Community, United States and Canada.
or any species where a food safety hazard such as histamine has been associated with decomposition HACCP and complementary standard sanitation operation pro- • hazards from mechanical processes (metal)
cedures (SSOPs) are designed to minimize the risk of food • parasites, where the processor has reason to know
safety hazards by controlling both the production process and that the parasite-containing fish or fishery product the environment in which that process takes place. A com- will be consumed without a process sufficient plete HACCP plan includes SSOPs to ensure that processing to kill the parasite plant environs are adequately cleaned and maintained. Al - • unapproved use of direct or indirect food and color
though HACCP focuses primarily on risk-prevention measures additives, or use of adulterated food additives implemented through the control of processes, in and of • possible allergens
itself, a HACCP plan is inadequate to guarantee food safety • contamination from nonfood-grade lubricants
without complementary SSOPs.
in processing equipment. Seafood Processing Plants Guidelines for BAP Standards
Sanitation Control Procedures
1. Ensure the safety of water and ice in contact 1. Organizational charts of all processing plant with food and food contact surfaces.
employees, including management personnel.
2. All surfaces and substances in contact with food or 2. Process flow chart showing all steps in the process in food production areas that might come in contact including the addition of ingredients and additives.
with product must be food grade and/or made of 3. Description of product and its presentation(s) that impermeable, easily cleaned and sanitized materials identify intended use(s) and method(s) or materials that will not shatter and adulterate of distribution.
product. (Glass is an example of a material that can 4. Hazard analyses must include at least those hazards shatter and create a food hazard.) outlined in the "Potential Species-Related & 3. Maintain and clean food contact surfaces, Process-Related Hazards" section of the USFDA/CFSAN equipment and clothing.
Fish and Fisheries Products Hazards and Controls 4. Prevent cross-contamination between raw and Guidance, and/or those outlined in the FAO/WHO cooked products and from unsanitary contact Codex Alimentarius Commission (Codex Standard surfaces, clothing and equipment.
092-1981, Rev. 1-1995), depending on importing 5. Maintain hand-washing and toilet facilities.
country and local regulations.
6. Protect food, packaging materials and food contact 5. Preventative measures for each identified hazard services from adulteration with chemical, biological at each critical control point. and physical contaminants.
6. Monitoring procedures for each identified hazard 7. Properly label, store and use chemical at each critical control point that include frequency, and toxic compounds.
assignment of task, monitoring method and record- 8. Control employee health conditions to avoid con- keeping method.
tamination of food, packaging or contact surfaces.
7. Corrective actions that will be implemented when 9. Exclude and control animal pests.
a critical level has been exceeded for any identified 10. Remove all spoiled, decomposed or adulterated hazard must be identified, implemented and products and materials.
11. Monitor cleaning and sanitizing activities that 8. Verification procedures for all monitoring, corrective directly contact food and food contact surfaces.
actions and preventative measures that demonstrate 12. Verify the efficacy of cleaning and sanitation safety of product by revision of HACCP procedures procedures, and food safety through product through product analysis at a frequency specified by analysis carried out at a frequency specified by the processor and showing to ACC satisfaction that the processor and showing to ACC satisfaction that control is sufficient to prevent adulteration. control is sufficient to prevent adulteration for Verification should include chemical testing of food those hazards the processor has identified as additives for purity to assure only food-grade controlled by SSOPs.
additives are used.
9. Recall procedures should be in place in case adulterated product leaves the processing plant.
Salmonella and other microbiological adulterants, as well asphysical adulteration with glass, insects and other filth, maybe controlled by SSOPs. Sanitation controls are as necessary as HACCP controls to assure the safety of all seafood products.
A current HACCP plan and SSOP manuals shall be available to Since product quality is essential to maintaining value and the evaluator. The HACCP plan shall identify critical control food safety, certain controls must be used to meet consumer points, preventative measures, monitoring and verification expectations and buyer specifications. Calibration of process- procedures, corrective actions, and product recall procedures.
control instruments used at critical control points and peri- It shall also include information on the process itself through odic end-product or in-process testing are the responsibility flow charts and organizational charts of management and of the processors. em ployee authority structure. Some important quality issues that often cause rejection by The SSOPs shall specify how the processor cleans, sanitizes and maintains the facility in the condition required to ensure food safety, as well as outline procedures for maximum em - • presence of extraneous materials and filth
ployee hygiene. "Adequate" SSOPs also include monitoring • product appearance, texture, taste and odor
procedures for cleaning and sanitizing activities. See the ta - • improper use and labeling of sulfites and moisture-
bles above for necessary sanitation control procedures and minimum required HACCP hazard controls. The frequency of • use of non-food grade or adulterated moisture-
cleaning and sanitizing actions, and types of records used to monitor the sanitation control measures shall be stipulated • mislabeling of product
in the processor's SSOP. • processing defects like short weight, off-count,
lack of uniformity, dehydration and the presence Processing facilities shall have a properly functioning metal of bone and/or skin in fish.
detector in place to check all finished product.
Seafood Processing Plants Guidelines for BAP Standards
Cross-contamination in seafood is one of the most common otics such as chloramphenicol and nitrofuran and its deriva- causes of foodborne illness. While being processed, product tives. BAP requires that processing plants consider antibiotics can be exposed to many potential sources of cross-contam- in their hazard analyses and show that adulteration with ination that can promote the growth of pathogens. these substances has been controlled and that the control hasbeen verified. Common routes of cross-contamination include product-to-product transfer of bacteria from contaminated raw prod- Processing plants shall also maintain copies of supplier cer- uct to cooked or ready-to-eat product; equipment-to-prod- tificates from farms regarding growout and production haz- uct transfer of bacteria from contaminated equipment, work ards that assure the processor that no banned chemicals or surfaces or utensils to food; and people-to-product transfer antibiotics were used during farm production and that other of bacteria from workers' bodies or clothes to product. chemical and antibiotic treatments were carried out in aresponsible fashion. BAP strongly recommends that partici- Cross-contamination can be prevented by effectively sepa- pating plants establish internal audit plans for verification rating raw materials or ingredients from cooked or ready- of this data through laboratory analysis of incoming product.
to-eat products during processing, handling and storage;and controlling the movement of goods and people within During the audit, the ACC evaluator will examine the phys- the factory. Additional measures include the implementation ical plant and review records to verify that the food safety of personal hygiene and contamination control training, pro- and quality controls outlined in the plant HACCP and SSOPs cedures and cleaning systems at the plant and assuring that are maintained, and that the controls meet the regulatory water and ice are free of pathogens. standards of USFDA, EC/DG and/or CFIA. The evaluator mayalso take finished product samples for laboratory analysis to Record keeping is the basic tool that an evaluator uses to verify standards compliance.
audit a facility. Hence, complete and accurate documenta-tion as outlined in the plant's HACCP/SSOPs is fundamental.
For Additional Information
For cer tification, plants shall make available updated recordsthat show all monitoring, verification and corrective actions Fish and Fisheries Products, Hazards
taken, and documentation for process and environmental/ and Controls Guidance
sanitation controls. These should be up dated and shall be Environmental Chemical Contaminant and Pesticide no less than 90% complete. Tolerances, Action Levels and Guidance Levels (Table 9-1) Third Edition, June 2001 Adequate HACCP and SSOP programs include verification ofsanitation and process controls through periodic testing for Current Good Manufacturing Practices in Manufacturing,
biological, microbiological and chemical contamination, mis- Packing or Holding Human Food
labeled products and levels of additives. A particular concern Codes of Federal Regulations 21 — Part 110, Food and Drugs of importing countries is adulteration with banned antibi- standards by third-party laboratories. Analyses include micro- biological testing for bacterial pathogens as well as analyt-ical testing for antibiotic residues.
Random samples of finished product shall be analyzed for
bacterial contamination and antibiotic residues by both
To reduce cost and improve efficiency, a two-tiered hierar- the processing plant and third-party laboratories to verify
chy of analytical testing is used. Most samples are analyzed that the control processes used by the plant are effective
locally using inexpensive "rapid screening" tests conducted and finished products are safe and wholesome.
by laboratories in each seafood-producing country. Less-fre-quent "confirmatory" tests using official methods are con- Reasons for Requirement
ducted by ISO-approved reference labs in each region. A list Particularly when dealing with ready-to-eat products, food of approved local and reference laboratories is currently processors must assure consumers that the food they pro- being compiled. Test frequency and procedures may be mod- duce is wholesome and safe. Programs established by the ified and tests added as needed, with notice given on the United Nations Food and Agriculture Organization, Europe - ACC website.
an Union, United States Food and Drug Administration, andother agencies require processors to implement plans and controls that maintain food safety. Verification is an ongo- Product analyses are carried out in three ways.
ing review process that ensures plants' food safety plansfunction effectively.
NEW APPLICANTS — Plants submit samples
As a prerequisite for certification, processing plants shall pro-
BAP verification requires that random samples of finished vide analyses of end product samples representing five lots product be collected and analyzed for compliance with BAP for every product form collected during the previous six Seafood Processing Plants Guidelines for BAP Standards
Required Tests — Raw Seafood
Required Tests — Cooked and Raw
Less than 20 CFU/g Less than 10 CFU/g Positive for staphylo- coccal enterotoxin or Enterotoxigenic E. coli S. aureus level equal (ETEC) — 1 x103 ETEC/g, LT or ST positive; generic E. coli less than Presence of organism Positive for staphylo- Detectable limit, coccal enterotoxin or S. aureus level equal Detectable limit Presence of organism metabolites, 1.0 pbb Detectable limit, Presence of organism Detectable limit Detectable limit, Ciprofloxacine Detectable Detectable limit, * Ridascreen quick test for initial screening and LC/MS/MS Detectable limit, for confirmation of positives.
CFU/g = Colony-forming units per gram sample Detectable limit, MPN = Most probable number BAM = Bacteriological Analytical ManualAOAC = Association of Official Analytical ChemistsFSIS = Food Safety and Inspection ServiceELISA = Enzyme-linked immunosorbent assay months. A lot is defined as a processed batch of shrimp or fish LC/MS/MS = Liquid chromatography/mass spectrometry harvested from a single pond or other culture system on a sin- LC/MSn = Liquid chromatography/mass spectrometry gle day. As defined in the tables above, tests required for raw, LC/VIS = Liquid chromatography/visual detection cooked and ready-to-eat products shall be conducted by HPLC= High-performance liquid chromatography third-party laboratories, and results shall be documented.
Plants are responsible for testing costs related to certification.
When composite testing is negative for six consecutive ANNUAL AUDITS — Evaluator collects samples
months, the frequency can be reduced to quarterly testing During the auditing of processing plants, ACC evaluators or for each product form and species. If composite testing is laboratory personnel authorized by ACC shall collect sam- negative for 12 months, testing frequency can be reduced ples of each finished product and forward them to ACC- to twice per year for each product form and species. If any approved laboratories for testing. Each type of product pro- test shows positive results, testing frequency reverts back duced shall have three samples, with one sample each from to monthly on the component that tested positive, and ACC three different lots. Analytical results will be documented in will require confirmation testing at third-party laboratories.
the certi fication records, and copies will be sent to facili-ties. Plants are responsible for testing costs.
Sample collection and compositing is only to be done by prop-erly trained individuals to prevent contamination of the prod- ONGOING IN-PLANT MONITORING
uct. If plants have a properly equipped laboratory and duly Once a plant is certified, ongoing in-plant testing is required trained personnel, monitoring can be done by the plants. Al ter- to insure compliance. As shown in the table on page 24, the natively, plants can submit samples to an independent lab. testing frequency is initially monthly, but reduces over timeif results are within acceptable tolerances.
Seafood Processing Plants Guidelines for BAP Standards
Required Monthly Sampling for Bacterial Contamination and Antibiotics
Product Form
Composite 15, 25-g samples into 1, 375-g unit Composite 30, 25-g samples into 2, 375-g units Composite 10, 25-g samples into 2, 125-g units Composite 10, 25-g samples into 2, 125-g units Composite 10, 25-g samples into 2, 125-g units Composite 10, 25-g samples into 2, 125-g units Malachite Green, Leucomalachite Green* Composite 10, 25-g samples into 2, 125-g units * Testing for chloramphenicol, nitrofurans, malachite green or leucomalachite green can be made from one 125-gram composite sample for either shrimp or fish.
Example process: Ready-to-eat shrimp
The detection of positive samples shall lead to immediate Aseptically collect 30 random samples of 25 grams each.
corrective action for the respective lots and a temporary Aseptically combine the samples into two 375-gram compos- in crease in sampling frequency. In such cases, the facility ite samples for testing. All samples must be properly marked shall document the source problem(s) and corrective actions according to the lot number and product type. taken, and make them available to ACC, if requested. The analytical regimes shall consist of quick tests in the The Aquaculture Certification Council reserves the right to plant or at local laboratories for microbiological contamina- rescind the certified status of plants at which verification tion and antibiotic residues. Confirmatory tests shall be results are out of acceptable ranges. For the period during conducted by ACC-approved regional reference laboratories which the plants undergo corrective actions for contaminat- using official protocols of the U.S. Environmental Protect - ed product, the plants will be considered on probation and ion Agen cy and Food and Drug Administration as specified in the BAP logo can not be used on packaging. guidance documents.
ACC will periodically review sampling frequencies, testing Analytical results shall be recorded and tracked with corre- re quirements and verification protocols to ensure product sponding lot numbers. Verification data shall be maintained safety. If necessary, changes will be made in procedures to and made available if requested by the Aquaculture Certi fi - address deficiencies cation Council. ACC reserves the right to conduct a surpriseaudit at its own cost. As lots of seafood from certified farms are sold or shipped to buyers, the processing plant shall record: • buyer name
To establish product traceability, the following information
• ACC buyer identification, if applicable
shall be recorded:
• lot quantity shipped
• farm name
• shipping date
• BAP-certified farm identification, if applicable
• invoice/transfer number.
• species
• farm lot number
The recipient of the product shall maintain all pertinent chain-of-custody records, including those related to shipment and • BAP-certified processing plant identification
• date and time of product reception at plant
• plant lot number
Reasons for Requirement
• finished lot weight
Product traceability is a crucial component of BAP aquacul- • product form and count.
ture facility certification. It interconnects links in the seafoodproduction chain and allows each proc essed lot to be traced Additionally, processing plants shall maintain documentation back to the culture system and inputs of origin. Results of records from producers that verify sources of postlarvae and food quality and safety analyses by accredited laboratories feed use, and report chemical treatments. Plants shall also can also be included. Traceability ultimately assures the pur - keep records of testing data for the presence of microbes, chaser that all steps in the production proc ess were in com- anti biotics and chemicals in raw seafood products. pliance with environmental, social and food safety standards.
Seafood Processing Plants Guidelines for BAP Standards
Sample Processing Plant Product Traceability Form
Received From: FARM
Reception Time/Date Postlarvae Source Statement Available? Feed Source Statement Available? Y N Chemical Treatments Statement Available? Antibiotics Testing Statement Available? Heavy Metals/Pesticides Testing Statement Available? Y N Product Form/Count 1 Product Form/Count 2 Product Form/Count 3 Product Form/Count 4 Total Finished Product Weight Plant Analysis Results for Microorganisms Results for Chemical/Antibiotic Residues Analysis Results for Finished Product Analysis Results for Cooked Shrimp Sold To: BUYER
Lot Quantity Shipped Container Company/Number Implementation
Participating processing plants can maintain paper records
Adequate record keeping is only meaningful when combined of the required data in notebooks or files using the sample with procedures that maintain lot separation. Incoming lots Proc essing Plant Product Traceability Form above. If possible, of product from BAP-certified farms shall not be stored, mixed the information should also be transferred to computer data- or processed with lots from noncertified farms. A produc- base files, with the original files kept to allow verifi cation of tion lot is defined as the product harvested from one pond the electronic data. The record-keeping process re quires time- or culture unit on a single day.
ly, organized, accurate entries ideally performed by a singleclerk responsible for collecting the data and trans ferring it Boxes and master cartons shall be accurately labeled, and pri- to the database.
mary box or bag packaging that is in direct contact with sea-food shall be clearly marked with a lot identification num- All BAP-certified facilities shall also add this data via the Internet ber. Monitoring records for microbial and chemical analysis to the ACC online database developed by TraceRegister, Inc.
shall be provided for production lots.
TraceRegister securely stores and exchanges the productinformation necessary to satisfy BAP traceability and chain-of-custody requirements.

Source: http://www.pacificblue-seafood.ch/dropbox/Guidelines_for_BAP_Standards.pdf