Dar seafood ppp standard

4.5.1.2 Cold-smoked finfish

Cold-smoked finfish (and other cold-smoked seafood products) were found to present a higher relative risk to public health for at-risk population sub-groups, due mainly to the severity of illness caused by contamination with Listeria monocytogenes. Listeriosis is a serious food-borne illness that affects susceptible populations and can lead to death. Because of its long incubation period (up to three months), it is often difficult to identify the food vehicle responsible for the illness.

Listeria is a ubiquitous organism in the environment and because the cold-smoking process does not contain a listericidal step, it is difficult to eliminate this pathogen from the product.

Instead, strict adherence to good hygienic practices and proper maintenance of the processing environment are essential for controlling this organism. The long storage periods of the products at low temperatures favour the growth of the pathogen. Typically the shelf-life for vacuum packed cold smoked fish is up to 4 weeks at 5C.

The Code sets a limit for L. monocytogenes in smoked fish and processors use this limit as one criterion for evaluating the safety of their products before release into the marketplace and in setting use-by-dates. Testing of products in the marketplace also contributes to recall of contaminated product. However, good hygienic practices and clean premises are essential tools in maintaining low levels of the pathogen in the product. These practices are already mandated for processing of this product in Chapter 3 of the Code.
In addition, FSANZ publishes and distributes information material to alert susceptible populations such as pregnant women to the high risk posed to them by this food. It must be concluded, however, that these current management strategies for Listeria in cold-smoked finfish leave a residual, albeit small, risk to public health.
One approach to manage the residual risks posed to public health by cold-smoked finfish would be to propose implementation of additional risk management systems. These could consist of a HACCP system or food safety program as described in the voluntary Standard 3.2.1 in the Code. It is clear that the risks lie mainly in the processing part of the food chain where the pathogen may be introduced, and also in the retail shop where Listeria growth may occur during the long shelf life of the product.
The implementation of HACCP or food safety programs would need to be justified by a positive benefit-cost ratio demonstrating that the burden would be clearly outweighed by the public health improvements. Such a benefit-cost study has not been done and until it is done, the proposal to mandate HACCP-based approach for this food would not meet with stakeholder agreement.
As the main sub-populations at risk are pregnant women and the elderly, improved education of these vulnerable populations may be the best approach, in the short-term, to manage the residual risk, combined with improved compliance and enforcement of the existing mandatory Standards in Chapters 1 and 3 of the Code. FSANZ has recently reviewed the Listeria pamphlet for pregnant women to broaden its audience to the main vulnerable population groups at risk.
In summary, at this point in the standard development process, no additional regulatory requirements are proposed for cold smoked finfish.