Joint Ministerial Decree
No ( 1909 ), Year 2001
Regarding Regulations and Procedures
Related to Fish and Marine Products Exports
To the European Union Countries
Deputy Prime Minister and Minister of Agriculture and Land Reclamation,
Minister of Economy and Foreign Trade,
After reviewing;
Law No 53, issued in 1966 for the issuance of Unified Law for Agriculture,
And
Law No 118, issued in 1975 concerning Import and Export, And
Law No 10, issued in1966 concerning Food Control and regulating its distribution
and its executive Ministerial decrees,
And
Presidential Decree No 187, issued in1984 for the Establishment of the General
Organization for Veterinary Services,
And
Presidential Decree No 106, issued in 2000 to facilitate the Control and Inspection
Procedures on Imported and Exported Commodities,
And
Minister of Health Decree No 880 issued in 1960 concerning the transport of
fresh fish,
And
Minister of Health Decree No 362 issued in 1984 concerning the transport of
Frozen Commodities,
And
Ministerial Decree No 275 issued in 1991 concerning the Executive Regulations of
Import and Export Law previously mentioned,
Decided
Article (1): The Catch, Storage, Preparation and Inspection of exported fish to the
European Union countries is performed according to the attached system
Article (2): The exporter is temporarily suspended in case of any violation of regulations
and procedures included in the attached system until proven not responsible
for such violation. The exporter is suspended for a year in case of committing
a second violation.
Article (3): The General Organization for Veterinary Services, Ministry of Agriculture
and Land Reclamation will supervise the implementation of this system, in
this respect it has the power to: One) Present any suggestions to amend
procedures included in the attached
system. Two) Prepare a list of Egyptian companies, which abide by the
sanitation
regulation and production charts.
Article (4): This decree is published in Al-Wakaaei Al-Massreya Newspaper and is
active as of date of its issuance.
Minister of Economy
And
Foreign Trade
Dr Youssef Botrous Ghaly
Deputy Prime Minister
And Minister of Agriculture
& Land Reclamation
Dr. Youssef Wally
Regulations and Procedures
Related to Fish and Marine Products Exports
To the European Union Countries
1. Definitions:
Fish:
Animals existing in waters and breathing through Gills whether in sweat or sea waters,
including fish eggs and excluding aquatic mammals and other aquatic animals.
Fresh Fish Products:
Fish or its parts prepared naturally without any interference by any processing operation
for preservation except cooling.
Preserved Fish Products:
Fish which have been preserved by adding preservative materials or by conducting a
physiological treatment such as heating or smoking or drying or freezing or canning.
Marine Products:
Include Mollusks, crustaceans and bivalve mollusk.
Fisheries:
Places where fish are bred whether naturally or have been established and\or outlined.
Competent Authority:
The agency that is responsible for, authorized to, has the right to perform control and
veterinary review to the preparation, processing and exports operations (General
Organization for Veterinary Services-Ministry of Agriculture).
"authorized officer" means any public officer designated by the GOVS to be an officer
authorized under Section 2 of this Decree.
"Establishment" means any premises where fishery products are prepared, processed,
chilled, frozen, packaged or stored, excluding auction and wholesale markets in which
fishery products are only displayed and sold by wholesale, but including any fish
processing establishment under the terms of the Fisheries Management and Development
Act 1996.
"Fishing vessel" means any vessel designed and equipped for the capture of fish and
operated for this purpose, but does not include vessels used exclusively for the transport of
fish or fishery products.
"Freezer vessel" means fishing vessel which is equipped for the preservation by freezing
of fish and fishery products, which may include packing, but does not include any of the
operations conducted by factory vessels.
"Factory vessel" means any vessel on which fishery products undergo one or more of
the following operations followed by packaging, filleting, slicing, skinning, mincing,
freezing, or processing, but excludes any fishing vessels on which only freezing of fish
(whole or with gills or guts removed) and shrimp (head- on or head-off) is carried out.
"fishery product" means any cold blooded aquatic animal, or part or product derived
therefrom, intended for food for human consumption , and includes any fish, crustacean,
mollusc, echinoderm, holothurian, or aquatic reptile, but does not include live animals
(excluding shellfish).
"aquaculture" means managed production in artificial enclosures of fish species which
are used for human consumption, and includes the production of intermediate stages of
the life cycle including eggs and larval stages. It does not include the holding of live fish
for short periods for the purpose of collecting for market or for purification.
"compound feed" means a manufactured animal feedstuff used for feeding to fish,
which contains two or more ingredients blended by the feed producer
"extensive aquaculture" means aquaculture which takes place with limited or no inputs
in terms of feed, fertiliser and other interventions, relying mainly on natural productivity
for growth.
"diseased fish" means a fish on or in which pathological changes or other abnormalities
are apparent.
"disinfection" means the application of hygienically satisfactory physical and/or
chemical agents and processes to cleaned surfaces, with the intention of eliminating or
reducing the number of microorganisms to a level that will not lead to harmful
contamination of human food.
"veterinary drug means any substance applied or administered to any food producing
animal whether used for therapeutic, prophylactic or diagnostic purposes or for
modification of physiological functions or behaviour.
"withdrawal time" is the period of time between the administration of a veterinary drug
to fish, or exposure of fish to a chemical, and harvesting of the fish to ensure that the
concentration of the drug or chemical in the edible flesh of the fish complies with the
maximum permitted concentration of the drug or chemical in fish for human
consumption.
"Batch" of fishery products means an amount of harvested fish or molluscan shellfish of
the same species produced at the same location at the same time.
"Frog's legs" means the back part of the body divided by a transversal cut behind the
front limbs, eviscerated and skinned of members of the genus Rana spp. (family Ranidae)
presented fresh, frozen or processed.
"Fresh water fisheries" includes fisheries undertaken within the limits of coastal
lagoons and lakes
Provisions for control and inspection of health conditions of production
Approval of establishments and factory vessels exporting fishery products
•
2 Provision for control and inspection of health
conditions of production 2.1 Approval of establishments and
factory vessels exporting products
1. (1) No shore-based establishment may be used for the storage or
packaging of fishery products intended for export except under an
accordance with an approval granted under this Decree.
(2) No factory vessel may be used for the storage, processing of
fishery products intended for export except under and in
accordance with approval granted under this Decree.
(3) An approval granted in accordance with subsections (1) and in respect of
an establishment or factory vessel will authorise that establishment or
vessel to store, process or package fishery products intended for export for
a six months period and for such products and processes as may be
specified in the approval.
(4) Health certificates for export to the EU will only be awarded lvalve
mollusks which are consigned for export from an approved dispatch centre or
approved purification centre
2.2 Approval conditions
(1) Every establishment or factory vessel required under Decree to be
awarded an approval shall be subject to any general or specific operation and
management requirements which are described in this Decree:
2.3. Suspension and Cancellation of Approval
1 .Any approval granted in accordance with Section 1 of this Decree must be suspended
or cancelled at any time and without notice by the written order of the Board of the
GOVS:
(a) where an establishment or processing vessel has been used in contravention
of the this decree or any regulations made thereunder or in contravention of the
conditions of the approval
(b)where such action is deemed necessary or expedient for ensuring the safety of
exported fishery products
2.4 Fees
(1)
There shall be payable in respect of every application for an approval
granted under Section 1 an appropriate fee as may be prescribed by the GOVS.
(2)
The schedule of fees prescribed by the GOVS will be published from time
to time in the Gazette.
2.5 Provisions for Enforcement
2.5.1 Authorised officers
1(1) The GOVS may authorise any public officer to act as an authorised officer under
this Decree.
(2) The GOVS shall issue to every person authorised to act as an authorised officer a
certificate of his authority.
2.5.2 Powers of authorised officers
1. (1) An authorised officer may without a warrant (a) at any reasonable hour or whenever work is in progress in any establishment or
factory vessel in which fishery products are believed to be stored, processed or
packaged, enter and search that establishment or factory vessel for the purposes of
determining the existence, nature and extent of any trade or business in fishery products.
(b) examine any fishery product in any establishment or factory vessels to which he
believes this Decree applies, take samples thereof and examine anything which he
believes is used or capable of being used for the preparation of any fishery product
(c) stop search or detain any vehicle, vessel or aircraft in which he believes that any
fishery product to which this Decree applies is conveyed, examine the fishery product
and take samples of it;
(d) open and examine any receptacle or package which he believes contains any fishery
product to which this Decree applies, examine the article and take samples of it;
(e) call for any books, documents or other records which h? believes contain any
information relevant to the enforcement of this Decree with respect to any fishery
product, make copies thereof and take extracts from it;
(f) seize and detain for such time as may be necessary any fishery product by means of,
or in relation to which, he believes this Decree, or the conditions of an approval issued
under this Decree, have been contravened
(2) An authorised officer shall release any fishery product seized by him under
subsection (1) where he is satisfied that the provisions of this Decree in relation to the
fishery product have been complied with or where he is satisfied that product is not
destined for export.
(3) An authorised officer shall in the exercise of his powers under subsection (1) if
required by any person affected thereby, produce his certificate of authority issued to him
under Section 7(2).
(4) The owner or occupier or person in charge of any establishment or the master of any
factory vessel entered into by an authorised officer pursuant to subsection (1) or any
employee found therein or any person who when requested to give information or any
assistance to an authorised officer,
(a) fails to give the information or assistance reasonably requested or,
(b) knowingly makes any statement which he knows or believes to be false or
does not believe to be true
is guilty of an offence.
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I
(5) Any person who wilfully obstructs an authorised officer in the execution of his
functions under this Decree is guilty of an offence.
(6) Any person who without the written permission of an authorised officer, removes,
alters or interferes in any way with any fishery product seized under this Decree is guilty
of an offence.
2.6 Appeals
1. (l)Any person aggrieved by a decision of an inspector in relation to export approvals
or approvals, or in relation to certification of individual batches of fishery products may
appeal to the Chairman of the GO VS.
(2)The Chairman will investigate the appeal within 30 days and will provide a written
decision, with reasoned arguments for his decision.
3 HACCP and own checks
3.1 Staffing for food safety management
A person should be appointed with the responsibility of managing and implementing food
safety systems within the establishment.
This manager should be a person of suitable qualifications for the post, and should have a
broad experience in fish processing, quality control and quality evaluation techniques
The quality control manager will have the following responsibilities.
a)
to ensure compliance with the requirements of this Decree
b)
to communicate with senior management regarding the need for
any works or changes of practice which may be necessary to maintain or improve the
quality of the finished product.
c)
to accompany inspectors from state agencies when they visit the
plant, and to put into effect any recommendations which they make.
to implement a quality control program based on the analyses and tests specified in Section
9 of this Decree
Sufficient quality control staff should be employed to ensure the smooth running of the
quality control function.
3.2 Laboratory
A laboratory should be prided at each establishment, which should comprise of a room(s)
of sufficient size to undertake all the quality analyses specified.
The laboratory should be provided with sufficient work surfaces and tables to permit the
laboratory to function normally without crowding of staff or equipment.
The floor and walls of the quality control laboratory should be smooth, impermeable and
easy to clean.
The laboratory should possess suitable facilities for the storage of equipment and
reagents.
The laboratory should be provided with an adequate supply of hot and cold water.
The laboratory should be provided with a sink of sufficient size for the washing of
equipment. If
necessary, a separate sink should be provided for the defrosting of fish.
The laboratory should be well ventilated with a suitable forced extraction fan, in order to
prevent the accumulation of gases emanating from the chemical analysis offish.
The laboratory should be well illuminated with daylight and fluorescent strip lighting.
3.3 Laboratory Equipment and Materials
Suitable equipment and materials should be provided for the carrying out of the following
tests and analyses.
•
•
Temperature measurement
Weighing
•
•
free available chlorine content of water
Microbiological contamination (including faecal indicators) of the surfaces of
tables and equipment in the plant
• Sensory evaluation of raw material and final product
• Separation and identification of extraneous material
3.4 Hazard Analysis and Critical Control Points
All export establishments must introduce and implement a system of Hazard Analysis
and Critical Control Point (HACCP) for each product and each species subject to export
approval. The principles of the system to be applied are as follows:
•
•
•
•
•
•
•
Identification of hazards, analysis of risks and determination of control measures
Identification of critical points
Establishment of critical limits for each critical point
Establishment of monitoring and checking procedures
Establishment of corrective actions, and conditions in which they are to be applied
Establishment of verification and review procedures
Establishment of documentation concerning all procedures and records
The written HACCP plan(s) must be submitted to GO VS.
Written records of measurements made under the plan, and any corrective actions taken,
must be held on file by the establishment and be available for inspection by an authorised
officer.
3.5 Water Analysis
The quality of the water which is used in the plant should be tested on a daily basis.
Samples should be taken at the point of use and the following parameters analyzed for
compliance with the standards expressed in Section 9.
- organoleptic quality
- free chlorine and combined chlorine residuals
-PH
If water from different sources is used in the same plant, the tests should be repeated for
each source.
At least once every week, water samples from each source should be submitted for a
microbiological analysis, to ensure that there is no contamination of the water supply.
3.6 Raw Material
On arrival at the plant the internal temperature of each batch should be measured. The
average internal temperature of frozen raw material should be below 10(C.
On arrival at the plant samples offish should be selected from each batch for
organoleptic analysis of smell and appearance of raw fish, and the flavour of the cooked
flesh.
The quality control manager should indicate his approval of the batch, based on the
results of the above tests. He or she should sign an inspection form and assign a lot code to
the fish before the commencement of processing.
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3.7 Process Control
Quality control staff should regularly observe the processing of the fish in order to ensure
that the requirements of this code are complied with, particularly those of Section 8.
Quality control staff should ensure that fish does not remain exposed on the tables during
stoppages in the process.
Quality control staff should ensure that the correct lot code is applied to the finished
product.
3.8 Hygiene Control
Quality control staff should ensure that all persons entering the plant comply with the
relevant provisions of Section 8 of this Decree.
Quality control staff should ensure that the cleaning of the plant and equipment is carried
out in such a way, and as frequently as necessary, to maintain a high level of hygiene.
A cleaning and sanitizing program should be specifically written covering the
disassembly, cleaning and disinfection of all areas in which fish is handled and equipment,
tables, fish boxes, tools, and other materials with which fish comes into contact.
The plan should specify a suitable methodology and frequency of cleaning and identify the
individuals responsible for each component.
Check lists which reflect the plan should be maintained by the Quality Control Manager
to ensure that the cleaning schedule is met.
A copy of the program and completed check lists should be available to inspectors during
inspections of the plant.
Each week, or more frequently if necessary, a microbiological analysis (total plate count or
equivalent) should be made of work surfaces, fish boxes and equipment which comes into
contact with fish, in order to test the efficiency of the plant cleaning and disinfection
routine.
3.9 Data Storage
All the results of the analysis and tests mentioned in this section should be recorded on
specially designed forms.
All the completed forms containing data which applies to each production batch
code should be stored in a permanent filing system.
Data forms should be stored for at least three years after the date of production.
Forms should be available to inspectors from state agencies during their inspections of the
plant.
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4 Conditions For The Factory Ships:
1st) Design and Equipment Conditions:
1- Factory Ships should have the following:
Receive area on board ship to contain different kinds offish as soon as caught. The
area should be designed and divided into tanks with suitable spacing to allow the
separation apart of what's been caught. The receive area and its moving parts
should be easy to clean and designed in a way to protect fish from sun or dirt or
contamination or any other harmful substances.
•
Comply with the sanitary conditions when the different kinds of fish are
transported from the receive area to the operation area.
•
Sufficient spaces for work areas to perform preparation and processing of different
fish in suitable hygienic circumstances. It should be designed and equipped in a
way to prevent fish contamination.
•
Areas with sufficient spaces to store fish and can easily be cleaned. In case there is
a fish wastes processing unit on board, there should be a place to store these
residues (parts).
•
Separated storage areas for packing and packaging materials away from fish
preparation and processing areas.
•
Special equipment to pump fish residues unsuitable for human consumption.
•
Equipment to provide potable water supplies for human consumption or clean and
pressurized seawater. The outlet of seawater should be put in a special place where
the residues in the refrigeration engines water or the steam residues will not affect
the stored waters.
•
A suitable number of locker rooms and washing sinks and water supply units
should be available, provided that no direct opening to the areas where fish
preparation, processing and storage operations are taking place.
•
2- The Following Should Exist In the Preparation, Processing And Freezing Areas
Onboard Factory Ships:
•
Anti-Slippery easy-to-clean and disinfect floors, especially prepared to facilitate
water discharge. The openings and fixtures should be flexible and wide enough not
to be clogged by fish residues and to facilitate water drainage.
•
Easy to clean walls and ceilings especially in places where there are pipes,
connection rings and electrical cables.
•
Protected water system to provide oil leakage proof, in order to prevent fish
product contamination
•
Good ventilation outlets and powerful steam expulsion.
•
Adequate lighting.
»
Cleaning and disinfecting utilities for equipment, tools and installations.
•
Hands cleaning and sanitation utilities through automatic faucets and one time
usage towels .
3- Equipment and tools (Cutting tables - Containers - evisceration and filleting
machines...etc) should be anti-rust from seawater and easy to clean and disinfect
4- Factory ships which freeze different kinds offish should contain the following
•
High efficiency cooling area for product's fast cooling
•
High efficiency refrigeration area to store fish products at suitable temperatures
along with a temperature recording system to facilitate monitoring.
5 Sanitation Conditions To Be Applied On Fish Products Onboard
Fishing Vessels:
1- Sections or containers of fishing vessels designated for fish product storage shouldn't
contain substances or products that could transfer harmful residues or strange qualities
to the food substance. The design of these sections and containers should be done in a
way to allow easy cleaning and the assurance that excess water is no longer existing in
the fish products.
2- Ship sections prepared for the storage offish products should be cleaned as soon as
used. Contamination from ship's fuel or stagnant water accumulated in the ship's hold
should be eliminated.
3- The fish should be protected from contamination and sun effects or any source of heat
as soon as deployed onboard the ships. Water used to wash fish should be potable
water or clean seawater, in order not to affect their quality or general appearance.
4- Fish products are handled and stored in a way that does not cause any cuts or
scratches. It is permissible to use fork tools to move large size fish or fish that might
hurt the handling person, provided no damage occurs to the fish meat.
5- Fish products should be subjected to cold treatment operations directly after loading. If
fish products are on board ships where cooling operations represent a practical
problem, then these products shouldn't stay more than 8 hours on board those ships
except those kept alive.
6- The ice used for cooling operations should be made from clean water or clean
seawater. The waters should be kept before use in conditions to prevent
contamination
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7- The containers, equipment and ships' sections should be cleaned with potable water or
clean seawater after unloading fish products.
8- Fish heads, intestines and other parts which may represent some danger to public
health, should be separated and eviscerated Hygienically. It should be kept apart from
products directed towards human consumption, which should washed thoroughly with
clean seawater. The fish livers and eggs intended for human consumption should be
refrigerated and/or frozen.
9- Containers, equipment used to separate fish heads and remove its intestines and fins
and any other used tools should be made of smooth, easy to clean materials and
covered by water-resistant hard to wear materials. After use, they should be
thoroughly cleaned.
10- Workers designated to handle fish products should keep a high standard of
cleanliness and hygiene for themselves and their cloths.
6 Additional Hygienic Conditions Applicable To Fishing Vessels
Designed and Rigged to Preserve Fish Products Onboard Under
Suitable Conditions for More Than 24 Hours. (Except Vessels
Equipped to Preserve Live Fish, Shellfish, Crustaceans And
Mollusk):
1- Shipping vessels should be equipped with Cargo Decks, tanks and containers to store
refrigerated or frozen fish products according to the required temperatures. These
Cargo Decks should be separated from the vessel's machines and crew quarters by
separators to prevent the contamination of the stored fish products.
2- The inside surface of the Cargo Decks, tanks and containers should be water-resistant,
easy to wash and disinfect. The surface should be made from smooth materials or at
least painted by a smooth paint in a good condition to prevent transmitting harmful
materials to the fish products that may affect human health.
3- Cargo Decks should be designed in a way to prevent the retention of excess waters in
fish products.
4- Containers used to.store fish products should guarantee the preservation of these
products in adequate hygienic conditions and especially allow the drainage of excess
waters. They should be completely clean when used.
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5- Ship deck, equipment, cargo decks, tanks, containers are to be cleaned each time they
are used. Potable water or clean seawater is used to achieve this purpose. Disinfecting
and getting rid of insects and rats residues are done whenever necessary.
6- All detergents, disinfectants, insecticides and all materials that may be poisonous
should be stored in closed lockers or compartments.
7- When fish are frozen on board ship, it should be done according to the sanitation
regulations. If fish are frozen in a saline solution, there should be assurance that this
solution doesn't represent a source of contamination.
8- Fishing Vessels equipped to refrigerate fish products in cold seawaters are committed whether this is done through cooling by ice or by using mechanical means - to comply
with the following requirements:
One - Ship tanks should be supplied with an adequate quantity of sea water and water
discharge mechanisms. Gadgets should be integrated to realize unified temperature inside
all tanks.
Two - Tanks should contain temperature measurement equipment, connected to a
temperature device installed on the highest place inside the tank.
Three -The operating system of the tanks or containers should include cooling modifier
that mix fish with sea water under a temperature reaching 3 centigrade within a maximum
of six hours after loading and reaching zero centigrade within a maximum of sixteen
hours.
Four - Tanks and containers should be completely emptied after unloading and
thoroughly cleaned, every time, with potable water or clean seawater.
Five - The number and date of the tank should be written clearly in the temperature
registries and kept for use by the control authorities.
Six - The responsible authorities (the General Organization for Veterinary Services), to
fulfil the objectives of control, should keep an updated list of equipped vessels in
conformity with items 7 & 8. Vessels having containers that can be moved are excluded
since it doesn't perform routinely fish retention in cold seawater.
Seven - Vessels owners or their representatives should take all necessary arrangements to
prevent personnel who may contaminate fish products when handling such products from
working on board their ships, until it's completely proven that they don't represent any
hazard to fish products.
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7 Regulations to be followed before and after loading on board vessels:
1- Hauling and stacking equipment on board ships should be made of easy to clean and
disinfect materials.
2- Avoidance of any contamination during fish hauling and stacking operation, by
complying with the following:
•
•
•
Hauling and stacking should be done quickly.
Fish are put in a protected environment without any delay at the required
temperature according to the fish nature. If required it should be put in ice during
transport or storage whether in the establishment or at the markets.
No use of equipment or practices other than the authorized ones to avoid any
damage to the edible parts of different kinds offish.
3- The following should be observed at the wholesale market and auctions where the fish
products are displayed:
It should be covered and surrounded by easy to clean walls.
Floors should be water-resistant, easy to wash, disinfect and supplied with a
hygienic drainage system to get rid of drainage water.
Hygienic utilities, an adequate number of washing basins supplied by hand
cleaning detergents, one time use towels and clean lavatories, should be provided.
Good lighting system to facilitate fish samples examinations.
No vehicles that emit harmful exhausts, which might affect the fish products,
should be allowed to get into these markets. Unwanted animals are not also allowed
entrance.
Crates and boxes are cleaned regularly from inside and outside with potable waters
and clean seawaters, after every sales operation.
Posting signs of (no smoking, spitting, eating and drinking) in easy to notice
places.
Should have the utilities to provide needed water quantities and water tanks made
of anti rust materials.
A locker room that can be closed with all utilities needed for the examination
operations
Markets should contain large cooling rooms to store fish in a temperature reaching
the temperature of melting ice
4- Application of General Hygienic Conditions.
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8
Conditions for Construction of Buildings on Lands: 8.1
General Conditions connected with Buildings and Equipment:
1- Existence of working areas with adequate spaces to conduct work according to the
hygienic regulations and providing no contamination may occur to the product. There
should be separation between both the clean and contaminated parts of the building
2- In areas where the products will be handled, prepared and processed, the following
should be available:
• Water-resistant floors, easy to clean and disinfect and designed in a way to allow
water drainage, or equipped with necessary equipment to remove water.
• Smooth surface walls, easy to clean, durable and water-resistant.
• Easy to clean ceilings.
• Doors made of durable materials and easy to clean.
• Good ventilation outlets.
• Natural and artificial lighting.
• Utilities to clean and disinfect hands. Faucets in workrooms and lavatories
shouldn't operate manually. One time use towels should be provided.
• Utilities to clean processing equipment and other different tools.
3- Refrigeration rooms where the different types offish are stored should be provided by
the following:
• Water-resistant floors, easy to clean and disinfect and designed in a way to allow
water drainage, or equipped with necessary equipment to remove water.
• Smooth surfaced walls, easy to clean, durable and water-resistant
• Easy to clean ceilings.
• Doors made of durable materials and easy to clean.
• Natural and artificial lighting.
4- Provide necessary means to control pests, insects, rodents, birds ... etc.
5- Work tools and instruments (cutting tables - Containers - trays - knives) should be
made of rustproof materials, easy to clean and disinfect.
6- Provide special containers made of rustproof materials to hold water allocated for fish
products.
7- Provide means of supply for adequate quantities of potable water or clean seawater or
treated seawater with a suitable pressurized system in adequate quantities.
Exceptionally, it's allowed providing waters unsuitable for drinking for steaming and
anti fire operation, provided that the installed pipes for this reason will prevent the use
of these waters for other purposes
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8- A sanitary drainage system to discharge drainage water according to standard
specifications should be available.
9- Provide an adequate number of dressing rooms with smooth, water-resistant and
washable walls and floors washing basins supplied by hand cleaning detergents, one
time use towels, automatic faucets and lavatories provided they are not open directly
to the working rooms.
10- Availability of suitable equipped rooms that can be closed to conduct examination
operations.
11- Arrange for suitable utilities to clean and disinfect the means of transport.
12- Existence of constructions to store live mollusk (crustaceans and different kinds of
fish) equipped with suitable utilities to guarantee the best survival, in addition to high
quality water to prevent the transmittal of harmful materials and organisms to
Mollusk and Fish.
8.2 General Hygienic Conditions:
one )
General Hygienic Conditions for Utilities and Equipment:1- Floors, walls, separators, ceilings lined and unlined, equipment and tools
used in operations related to different types of fish products should be kept in
good condition and clean, in order not to represent any source of
contamination to the products.
2- Extermination of any rodents or insects or any other harmful creatures,
regularly and continuously. Pesticides or any poisonous materials should be
stored in buildings and storage areas that can be locked. This shouldn't
subject the fish products to any kind of contamination.
3- Working areas, equipment and working tools should be used solely in
operation related to different kinds offish products, However, it could be
used in other operation especially food products according to what's
authorized by the responsible authorities.
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4- Potable water and clean seawater should be used in all purposes. However, nonpotable waters can be used exceptionally for steaming, fire protection and cooling
equipment operation, providing that installed piping will prevent the use of these
waters for other purposes and they won't represent a source of contamination to the
products.
5- Responsible authorities should approve cleaning, disinfectant and similar materials
Furthermore these materials should be used in a way that does not affect machines,
equipment and products.
8.3 Work Team general Hygienic Conditions:-
1- it's required that the working team should be on the highest level of cleanness and
especially:
• Workers should wear clean cloths and a helmet to cover the whole hair.
• Workers who deal with different fish products preparation should at least wash
their hands every time they resume work. Wounds should be covered with
waterproof bandages.
• Smoking, spitting, eating and drinking are completely forbidden in work buildings
and storing areas of different fish products.
2- The owner's of establishments should take necessary arrangement to prevent
individuals whom may pollute fish products from working with or handling such
products. Those individuals are obliged to perform a regular checkup every six months
to ensure they are free from disease.
3- When an individual is appointed in operations related to fish products, he should
submit a medical certificate proving that he does not have any obstacle preventing him
from taking this job.
9 WATER SYSTEM
9.1 Water Supply
The plant should have a permanent supply of adequate quantities of water, suitable for
human consumption (ie. free of dangerous bacteria and toxic materials in concentrations
which represent a risk to health)
9.2Water Treatment
If necessary the water will be treated by filtration and chlorination in order to achieve the
standards summarized in Section .
If the water used in the plant receives additional treatment prior to use (eg. addition of
chlorine) this must be done in accordance with the instructions of the manufacturer of any
equipment or chemicals utilized.
The system for water treatment by chlorine must be designed in such a way as to ensure a
contact time of at least 30 minutes before water is used
Products intended for export shall be dipped, washed, glazed or treated with hyperchlorinated water. The water which comes into contact with fishery products should be
suitable for human consumption.
9.3Storage of Water
The plant should possess adequate water storage cisterns with sufficient capacity to
supply the requirements of the plant when operating at maximum capacity.
The cisterns should be well constructed and the internal surfaces should be smooth and
impermeable. A high quality cement finish in acceptable.
Each water cistern should be provided with an impermeable hatch which permits entry for
cleaning and inspection purposes. The design of the hatch should protect against the entry
of rainwater and any water which may flow out of the plant.
Each water cistern should be protected against the entry of insects, animals and dust by
adequate screening of any ventilation pipes.
The area surrounding each water cistern should be maintained clean and free of
accumulations of rubbish, dust, water and other materials which could contaminate the
water inside.
Water cisterns should be inspected at regular intervals with the objective of keeping them
clean and in good condition.
9.4 Hot Water
The plant should possess a means of heating water to a temperature of at least 80(C, in
quantities adequate for hand washing by personnel.
The installation of either a steam system or pressurised water for plant cleaning, is
recommended.
9.5 Seawater
The use of seawater is permitted for the following purposes:
a) as a chilling medium for raw material storage of whole fish
b) ice making
The use of seawater is not permitted for the following purposes:
a) handwashing
b) addition to the final product
c) hot water
19
9.6 Water System Within the Plant
All pipework in the water system should be impermeable, well constructed and in good
condition. Iron pipes should be painted externally in order to protect them against rusting.
The provision of water to the sanitary facilities (WCs and urinals) should be isolated from
the water system for the rest of the plant, and should be supplied from a separate cistern.
9.7 Plan of the water distribution
The management of the establishment must prepare a plan of water distribution within the
establishment which shows all pipes, tanks, cisterns and outlets within the establishment.
The outlets should be identified by consecutive numbering, so that they can be located on
the plan.
9.8 Water Analysis
All samples for analysis should be taken at the point of use.
If water from different sources is used in the same plant, the tests should be repeated for
each source.
The quality of the water which is used in the plant (including ice) should be tested on a
daily basis, from different locations, in rotation, for the following parameters:
organoleptic quality
free chlorine and combined chlorine residuals
pH
At least once every week, water samples from each source should be submitted for a
microbiological analysis, to ensure that there is no contamination of the water supply. If
numbers of microbes exceed the specifications, then action must be taken to identify the
source and stop the contamination.
At least once every year, a sample should be submitted for analysis of other parameters.
9.9 Standards for water quality
9.9.1 Organoleptic quality
Characteristic
Acceptable limit or range
Colour
Acceptable to consumers
Taste
Acceptable to consumers
Odor
Acceptable to consumers
Chloride
250 mg/1
PH
6.5 to 9.5
20
9.9.2 Chlorine content
There should be a detectable free chlorine residua! at the point of use.
9.9.3 Microbiological standards
Parameter
Value (number/1 00ml)
E.coli
Enterococci
0
0
9.9.4 Other parameters
Parameter
Value
Unit
Notes
Acrylamide
Antimony
0.1
5.0
μ§/1
Note 1
Arsenic
10
μβΛ
μ§/ι
1.0
Kg/I
Benzene
Benzopyrene
Boron
Bromate
Cadmium
Chromium
Copper
Cyanide
1,2 dichloroethane
0.010
1.0
25
5.0
50
2.0
50
3.0
Epichlorohydrin
Fluoride
Lead
Mercury
Nickle
0.10
Nitrate
Nitrite
Pesticides
50
0.5
Pesticides Total
Polycyclic aromatic hydrocarbons
Selenium
0.5
Tetracloroethene and Trichloroethene
Trihalomethanes - total
Vinyl chloride
1.5
15
1.0
20
0.10
0.10
10
10
150
0.5
μ§/ι
mg/l
μ§/ι
Note 2
Kgfl
κβϋ
mg/l
Note 3
μβ/ι
μ#ϊ
BS/!
Note 1
μβ/ι
μ&Ί
μ^
Notes 3, 4
mg/l
mg/l
μΕ/1
Note5
Note5
Notes 6, 7
№Λ
μ^
Notes 6, 8
Sum of concentration of specified compounds. See note 9
mg/l
Note 3,4
μ§Λ
μβ/1
Sum of concentration of specified parameters
μ§/ι
Sum of concentration of specified compounds. See note 10
Note 1
μ§/1
Note 1: The parametric value refers to the residual monomer concentration in the water
Note 2: Where possible lower values should be obtained
Note 3: The value applies to a sample of water obtained by an adequate sampling method
at the tap and so taken to be representative of the weekly average value ingested by
consumers.
Note 4: Lower levels should be obtained if possible
Note 5: the following condition must be met: [nitrate]/50 + [nitrite]/3 ? 1 where the
square brackets signify the concentrations in mg/l for nitrate (NO3) and nitrite (N02).
The nitrite level must be no greater than 0.10 mg/l ex-water treatment works.
21
Note 6: pesticides means
Organic insecticides
Organic Herbicides
Organic Fungicides
Organic Nematocides
Organic Acaricides
Organic AJgicides
Organic Rodenticides
Organic Slimicides
Related products (inter alia growth regulators)
Only those pesticides which are likely to be present in the water supply should be
monitired
Note 7: the parametric value applies t
to each individual pesticide. In the case of aldrin, dieldrin, heptachlor and heptachlor
epoxide the parametric value is 0.030 μg/l.
Note 8: pesticides - toatl means the sum of all individual pesticides detected and
quantified in the monitoring procedure
Note 9: The specified compounds are:
Benzo (b) fluoranthane
Benzo (k) fluoranthane
Benzo (ghi) perylene
Indeno (1,2,3-cd) pyrene
Note 10: Where possible lower levels should be obtained. The specified compounds are
chloroform, bromoform, dibromochloromethane, and bromocloromethane.
10 Specific Conditions Associated with Fish Product On-Shore:
10. 1 Conditions connected to Fresh Fish Products:
one ) Unpacked and refrigerated products should be stored in ices (made of potable water or
clean seawater) in the establishment's refrigeration rooms. The ice should be
reapplied whenever needed. Fresh products and the ones packed beforehand should be
cooled by ice or refrigerated by the mechanical refrigeration unit to stay on a fixed
temperature.
Two) Evisceration and heads separation should be done hygienically. Products should be
washed with potable water or clean seawater directly after performing the said
operations (If not done onboard ship).
Three) Filleting and cutting in a way not to damage the fillets and the cuts to
contamination or damage. These operations are done in areas other than the ones
where the Evisceration and heads separation were done. Fillets and cuts shouldn't
remain longer than necessary on the work tables after the preparation operation.
Fillets and parts to be sold fresh should be cooled as fast as possible after the
preparation process.
22
Four) Heads and other cut parts that represent a danger to public health should be
separated in another place than the one where products fit for human consumption
are kept.
Five) Containers used to transport or store different fresh fish should be designed in a
way to guarantee its safe keeping from pollution and preserve it under suitable
hygienic conditions. There should be especially a place devoted to discharge melted
ice waters.
Six) If there aren't any special utilities for the continuous dispensing with wastes then the
wastes will be put in easy to clean and disinfect, anti-leak covered containers. Wastes
and leftovers shouldn't accumulate in work areas .It should always be removed at the
end of each workday or when the containers are full.
10. 2 Conditions Related to Frozen Fish Products:
one) The Factory should have the following:
1 - High efficiency freezing equipment to realize the required drop in temperature.
2- High efficiency freezing equipment to preserve products in the storage rooms under
temperatures that do not exceed the temperatures indicated in the decree, regardless of the
surrounding temperatures.
• As for canned fish, higher temperatures are approved provided it does not exceed 9
degrees Celsius.
3- A temperature-recording device should be installed in the storage rooms provided it's
put in a place where it can be easily read. The temperature recording device sensor should
be installed away from the refrigeration source i.e. in the area where the temperature is
the highest.
•
Temperatures degrees charts should be available for inspection done by the General
Organization for Veterinary Services during the period where products are stored.
10. 3 Conditions Related to Melted (Defrosted) Fish Products:
•
Establishments that perform melting operations should comply with the following:
One) Different fish products should be melted according to hygienic conditions. The
products shouldn't also be subjected to any kind of contamination. Furthermore, there
should exist a suitable sewage system to drain waters resulting from melting. The
temperature of the different fish products shouldn't increase much during the melting
operation.
The preparation and processing should be done after melting without any delay. If the
products are placed on the markets immediately, then it should be done in a good way
23
10. 4 Conditions Related to Processed Fish Products:
one) The processing operations should be recognized in the current law, if the processing
operations contain the prevention of the growth of disease causing microorganisms,
or if these operations were a main factor to preserve the product
Two) The person in-charge of the establishment should keep a special record containing
all the conducted processing operations. Salt and water percentages and their
control according to the type of performed processing operation, heating time and
temperatures should also be recorded. In addition, records of the expected storage
duration for the products should be registered and offered to the General
Organization for Veterinary Services.
Three) Indicate suitable storage conditions on the package that's kept for a limited period
through some processing like salting, smoking, or drying.
Four) In case of caning different fish products that were subjected to a sterilization
processing in tightly sealed containers, the following conditions should be
observed:
•
Waters used in the preparation of the cans should be potable water.
•
The process followed for heat treatment should be appropriate, taking into
consideration the major criteria such as heating time, temperature, filling, size of
the container.. .etc, a special registry for these things should be kept. Processing
through heat treatment should be capable of destroying diseases causing organisms
and its spores. Heating equipment should contain the necessary tools to ensure
whether or not the container has passed the heat treatment process. Potable water
should be used in cooling the containers after the heat treatment process without the
disruption of the existence of any chemical additives used according to good
technological practices preventing the corrosion of equipment and containers.
•
The factory should perform more random tests to guarantee the application of the
right heat treatment to the processed products such as :
- Incubation tests (period between disease infection and the appearance of disease
symptoms). These tests should be performed in a temperate
' 'ng 37 degrees
Celsius for seven days or 35 Celsius for ten days or any other temperature relate to this
subject
- Biological tests for elements and containers in the establishment's laboratory or any
other laboratory agreed upon and approved by the General Organization for Veterinary
Services
24
- Production samples should be taken every day at fixed times to ensure the validity of
guarantee. Therefore, suitable tools for can samples inspection should be available.
- Inspection should be made to ensure that the containers are not damaged.
- All the heat-treated containers according to the applied practical conditions should be
given an identification mark by the General Organization for Veterinary Services.
10.5 The following should be observed during the smoking operation:
- Performing the smoking operation in separate locations or in a specially prepared
location for this purpose. If necessary, the location should be equipped with an air
ventilation system to prevent the effects of heat and smoke emitted from combustion
on buildings and/or other locations where different fish products are being prepared,
processed or stored.
- The materials used in fish smoking should be stored away from the smoking location;
moreover, it should be used in a manner not to pollute the products.
- Painted and glued wood or the wood that has been chemically treated to be smokeproducing substances by burning wood shouldn't be used.
- Cooling process should be done quickly after smoking to the required temperature to
protect the product before packaging.
10.6 The following should be complied with during the Salting operation:
•
Salting should be done in different buildings and it should moved away from
buildings where other operations are performed,
»
The salt used in the treatment of different fish products should be cleaned and
stored in way to prevent any contamination during the different salting processes
»
Clean areas where different salting operations before use.
10.7 Bivalve Mollusks and Crustaceans should be cooked as follows:
• A quick cooling should follow the cooking operation. Water used for this purpose
should be potable water or clean seawater. The cooling operation should continue
until the temperature would reach the melted ice temperature, if there weren't any
other protection scheme
25
•
The removal of the shells should be done according to hygienic conditions to avoid
products' contamination. If such operation is done by hand then the workers should
pay a special attention to continuously wash the hands and clean all what's used in
these operations. If machines were used in these operations, then they should be
cleaned on fixed intervals and disinfected at the end of every working day.
•
After different shells are removed, the cooked products should be freezed
immediately or refrigerated to reach a degree that would prevent the growth of
diseases causative. The storing should be done in suitable buildings.
•
Every factory should perform inspection operations on scheduled and fixed
periods.
10.8 Mechanical processing operation should be done according to the following
conditions:
•
Mechanical processing should be done to filleted fish that there intestine were
removed without any delay. If fish were used a whole then the intestine should be
eviscerated and the fish washed in advance.
•
The machines are cleaned on fixed intervals (at least every two hours).
After processing, fish meat should be freezed as soon as possible or integrated with
another product that will be freezed or equilibrium
10.9 Conditions relating to frogs' Legs
Frog's legs may only be exported to the European Union if they meet the conditions
described below.
The frogs must have been slaughtered, bled, prepared and where appropriate, chilled frozen
processed packaged and stored in establishments which meet the requirements of Sections
11 of this Decree.
Are approved by the GOVS in accordance with Section 13 of this Decree.
Are subject to monitoring and inspection in accordance with Section 12 of this Decree.
Are produced subject to a HACCP plan in conformity with Section 3 of this decree
26
In addition, a separate room must be set aside for the storage and washing of live frogs
awaiting slaughter, and for their slaughter and bleeding. The room must be physically
separate from any room in which frogs are cut, dressed , prepared, packed or processed
The death of frogs must only be carried out by slaughter in an approved establishment
Frogs which are found dead prior to slaughter must be not be used for human
consumption
Immediately after cutting frogs legs must be washed in water which complies with
section 9 of this Decree, followed by immediate chilling using ice or chilled air, to a
temperature of 0 degrees centigrade, or immediately frozen to a temperature of-18
degrees centigrade.
Where frogs legs are further processed, packed, stored and transported this must be
carried out in accordance with Sections 11 of this Decree.
The packaging containing frogs' legs must bear an indelible identification mark
containing the following particulars:
•
•
•
The name of exporting establishment
The country of origin
The approval number of the Establishment
11 General Conditions relating to operation of export establishments
11.1 Conditons relating to traceability of fishery products and molluscan shellfish
All producers (including fishers and aquaculture production units), traders and processors
who hold fish for the purpose of export to the EU must:
•
•
•
•
•
Apply a mark or label to every unit within every batch of fishery products, to
identify that batch and distinguish it from other batches
Keep batches separate
Maintain a written record of the origin of that batch, to include the supplier, date,
quantity and any other relevant characteristics
Maintain a record of the person to whom the batch or parts were sold
To keep records for minimum period of 3 months in the case of fresh fish, and two
years in the case of frozen fish.
11.2 Conditions related to Parasites:
one) Fish and its products should be subjected during the production period and before
offered for human consumption to visual inspection for the purpose of discovering any
visual parasites.
Fish or its parts that are infected by parasites although removed, shouldn't be placed on
the markets for human consumption.
Two) If fish is to consumed in raw form, including lightly salted, then it should be
subject to a freezing process such that all parts of the fish arruve at a temperature not
exceeding -20 Celsius degrees, for a period not less than 24 hours.
27
b- Fish processors should guarantee that fish and their products or fish used in its
crude form in their different processing operations have been subjected to the
previous mentioned treatments before being offered for consumption.
c-
Fish products indicated previously when placed on the markets
should be accompanied by a document from the factory referring to the types of
operations performed on them
11.3
Species and products prohibited for export
Fish of the following species are not permitted for export to the European Union:
Latin
English
Arabic
Scomberomerus spp.
Barred Spanish mackerel
Pomatomus saltator
Bluefish
Miass
Seriola dumerii
Amberjack
Insh
Trachurus trachurus
Horse mackerel
Self
Scomber scombrus
Mackerel
Scomber
Clupea sprattus
Sprat
Anchuga
Engraulis encrassicholu
Anchovy
Espadin
The following processed products may not be exported to the European Union:
Fermented fishery products produced from fish of the genus Mugil. This includes the
product feseikh.
This list of prohibited species and fishery products may be amended by order of the
Minister of Agriculture.
11.4 Packaging Conditions:
1- Packaging should be done according to suitable hygienic conditions to prevent
the occurrence of any kind of contamination to the different fish products.
2- Packaging materials and its products which will be used to pack different fish
products should conform with all hygienic regulations especially:
• Won't prevent the physical properties of different fish products.
• Won't transfer to different fish products any harmful substances to human health.
• Won't be strong enough to protect different fish products.
3- It's not permissible to re-use packaging materials except some containers made of
smooth, anti rust materials that won't be affected by water and radiation and easy
to clean and disinfect. These containers may be re-used after cleaning and
disinfecting. Packaging materials for Fresh fish products put in ice should provide
a good discharge system for melted ice waters.
28
4- Packaging materials that were not used should be stored in distant warehouse away
from production areas and should be protected from dust and pollution
11. 5 Identification Marks:
A label should be pasted containing all the producer's data or through these products'
documents. Therefore the following information should appear on the package or in the
products' special document:
1- Exporting country.
2- Establishment official and approved identification number.
11.6 Storage and Transport Conditions:
1- Fish products during storage and transport should be kept in temperatures according
to the following:
•
•
Fresh fish products or ice melted, the Bivalve Mollusk and crustaceans cooked and
refrigerated in a temperature degree reaching the melted ice temperature degree.
Frozen fish products except fish frozen in salt water and will be used in canned
food industry- in a temperature degree reaching -18 Celsius degree or less in all
parts of the product, allowing a minor increase that does not exceed 3 degrees
Celsius during the transportation of processed products The factory will determine
the degree if necessary.
2- Some of the storage and transport conditions may be disregarded. In the event of
transporting the frozen fish from a refrigeration storage unit to an establishment
(which has been approved by the General Organization for Veterinary Services) but
melted upon arrival for the purposes of preparation and processing or for both
purposes. Also when the distance to be covered is short (not exceeding 50 kilometer or
one hour drive).
3- Fish products shouldn't be stored or transported with other products that may
contaminate or affect its hygiene, unless when it's packed in a form to provide full
protection.
4- Vehicles used to transport fish products should be prepared in a manner to maintain
the necessary temperature all the transportation period Whenever ice is used to
refrigerate the products, a discharge system should be provided to guarantee that
melted ice water does come near the products. Moreover, the used transport vehicle
internal surfaces should be outfitted in a manner not to negatively affect fish products
and should be smooth surfaces, easy to clean and disinfect.
29
5- Fish products means of transport shouldn't be used to transport any other products that
would affect the fish products or contaminate it, unless it's guaranteed that fish
products will not be contaminated due to the continuous cleaning and disinfecting of
the said means of transport.
6- It's prohibited to transport fish products in vehicles or containers that aren't clean or
disinfected.
7- The transport conditions to place the live fish products in the markets shouldn't
negatively affect these products.
12 Provisions relating to aquaculture and freshwater fisheries
12.1 Freshwater capture fisheries
Fish from freshwater capture fisheries should meet the conditions specified in sections **
and ** of this section..
12.2 Site location and selection
Aquaculture and freshwater fisheries activity should be located in areas where the risk of
contamination with hazardous chemical effluents is minimal and where sources of
pollution can be controlled.
Aquaculture and freshwater fisheries activity should be sited at a safe distance from
potential sources of water contamination in order to ensure protection of products from
contamination.
The immediate vicinity of aquaculture and freshwater fisheries activity should be free of
potential sources of water contamination and in particular should not be located
downstream and close to:
•
•
•
•
•
Industry and mining
Intensive agriculture (especially animal husbandry)
Densely populated areas or urban areas
Hospitals
Major roads and railways
Before building a land-based aquaculture facility a survey of the soil should be conducted
in order to determine the concentration and extent of any parameters which are of
importance for the safety of end products, including heavy metals and pesticide residues
Such an analysis should be conducted as part of the licensing required for new
aquaculture activity.
Cages, pens or any other form of aquaculture enclosures or water intakes should be sited
away from routes of water-borne traffic, and preferably upstream of any water-borne
traffic;
Cages, pens or any other form of aquaculture enclosures or water intakes should be sited
away from, and preferably upstream of, any natural or man-made discharges of
contamination.
30
12.3 Aquaculture site facilities
All aquaculture enterprises must provide reasonably accessible sanitary facilities available
for the use of people working in the enterprise.
Earth closet facilities are acceptable.
The minimum of facilities depends on the number of staff at the site, according to the
following table:
Number of employees
(Counted following sex)
Minimum number of toilets
01 -09
01
10-24
02
25-49
03
50- 100
05
More than 100
for every 30 persons add more 01 toilet
Sanitary facilities should be located a sufficient distance away from where fish are held to
ensure that there is no risk of contamination offish ponds with human faeces.
12 .3. 1 Feed storage
If feed is stored at the aquaculture facility it should stored in a properly constructed wellventilated facility, and protected from the entry of insects, birds and rodents.
31
12.4 Pond conditioning, fertiliser and feeds
12.4.1 Pond preparation
Weeds, rubbish and debris should be removed before preparing aquaculture ponds for filling
with water.
Ponds should be conditioned with lime and left for a period of at least two weeks before filling
and stocking.
At least once each year the pond should be drained, allowed to dry out and re-conditioned
with lime.
12.4.2 Fertiliser
Materials not permitted to be used as fertiliser for fish ponds are as follows.
Human faeces
Animal manure unless it:
•
•
•
Is added with equal weight of lime during pond conditioning, or
Has been adequately composted to eliminate trematode eggs
Is derived from enclosed animals living adjacent to the pond as part of an
integrated culture system and those animals are treated regularly with
antihelminthic drug treatment
12.4.3 Feeds and feed materials
Slaughterhouse waste and offal from mammalian food animals may only be used as a food for
fish if it is first cooked.
Compound feed should not be used for feeding fish unless the user is informed of the
composition, including any supplements added by the manufacturer.
Compound feed treated with veterinary medical supplements (including hormones and
antobiotics) are considered to be veterinary medicines to which the following section applies.
12.5 Veterinary medicines and withdrawal periods
12.5.1 Registration and Distribution of Veterinary Drugs
No veterinary therapeutic products or medicinal premixes for inclusion in fish feeds, may be
applied to fish, apart from those listed below:
Tetracyclines
Quinolones (inlcudes oxolinic acid, flumaquin)
Sulphonamides
Formalin
32
The Minister of Agriculture may by order amend this list of permitted medicines.
12.5.2 Handling and Administration of Veterinary Drugs
Control with drugs offish diseases in aquaculture should be carried out only on the basis of
a diagnosis by a veterinarian or a qualified fish disease specialist.
Veterinary medicines for treatment offish diseases should only be applied under the
supervision and written prescription of a qualified veterinarian or fish disease specialist.
Prescriptions should specify dosage and frequency, method of administration, withdrawal
period. In all cases veterinary drugs should be used according to manufacturers instructions
and note should be taken of all warning statements and contraindications for use,
particularly in relation to withdrawal periods.
Each individual dose and administration of veterinary medicines (including compound
feeds containing veterinary supplements) should be recorded in a special book kept for that
purpose, specifying date and nature of treatment, identification offish and duration of
withdrawal period.
The entries in the register are to be signed by the veterinarian or fish disease specialist
responsible for administering the drug programme. The register should also record daily
water temperatures during administration of the drugs and for the duration of the
withdrawal period.
Fish which are diseased and which are being treated with veterinary medicine should be
kept separate from those which are not being treated, and be easy to identify as a separate
batch.
Veterinary products should be stored in labelled and locked cabinet which is used
exclusively for this purpose. The cabinet should be labelled with the name of the
responsible key holders.
12.5.3 Harvesting and Withdrawal Period
Drugs used for treatment as well as prophylaxis must not be given to fish during a certain
period of time (withdrawal period) before slaughtering.
Withdrawal periods under different conditions must be established by the supplier of the
drug, for the fish species and the drug in question, and recorded in the drug register held
by the farmer.
Fish must not be harvested before the end of the withdrawal period.
The amount of any veterinary drug residue in the edible part of the harvested fish must not
exceed the maximum residue limit specified below.
Substance
Maximum residue limit (MRL) micogram/kg
Tetracyclines
100
Quinolones (oxolinic acid, flumaquin)
300
Sulphonamides
100
if fish which are treated with a veterinary medicine are sold live for on-growing before he
end of the withdrawal period, then the buyer must be informed in writing.
12.5.4 Requirements for marketing
If the fish is sent for further processing, then the producer should certify to the processor
in writing that either.
•
No veterinary medicines have been applied
•
If they have been applied, that minimum withdrawal periods have been observed
for the named medicines
Processors receiving aquaculture products for processing must undertake their own
checks to ensure that:
•
•
•
They do not accept production batches in which undeclared drug treatments have
been administered
Where veterinary medicines have been applied, that minimum withdrawal periods
have been observed and maximum residue limits are not exceeded
No prohibited substances are present
12.6 Harvesting, equipment and materials
Harvesting areas and methods within the aquaculture facility should be designed and
constructed for easy, fast and hygienically acceptable operations.
All equipment used for harvesting, catching, sorting, grading, conveying and transporting
offish should be designed for rapid and efficient handling offish without causing
mechanical damage.
Equipment, containers and utensils coming into contact with fish should be designed and
constructed to ensure that they can be adequately cleaned, disinfected and maintained to
avoid contamination.
All surfaces of boxes, implements and other equipment which come into contact with fish
should be of corrosive resistant material which is smooth and easy to clean, or be
designed for a single use only.
If re-usable boxes are used to carry fish from the pond then a suitable means of cleaning
with water and detergent, and disinfection should be provided
12.7 Hygiene
12.7.1 Personal hygiene and behaviour
Any person working on an aquaculture facility shall maintain a reasonable standard of
personal hygiene and should take all necessary precautions to prevent the contamination
ofthe fish.
Any cut or wounds on hands and forearms shall immediately be covered by a suitable
water-proof dressi ng.
Persons suffering from infectious diseases, or from a helminthic parasitic infection, or
who have infected wounds, boils or other skin infections, or who are suffering from
diarrhoea are not permitted to work in an aquaculture operation.
Personnel who work in aquaculture shall, on their appointment and in one year intervals
thereafter undertake a health test to ensure that they do not suffer from any of the above
conditions. Health documents of every person shall be kept at the facility and shall be
available to the inspection authority on request.
Any person entering an aquaculture facility must refrain from spitting or eating food,
urinating or defecating, except in areas locations designated for these purposes, which
must be away from fish production areas.
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12.7.2 First aid box
Each aquaculture facility shall be provided with a first aid box, which should contain at
the minimum:
1. a sufficient quantity of impermeable dressings
2. antiseptic cream or disinfectant
3. cotton wool and adhesive tape
12.7.3 Exclusion of animals
Except in integrated aquaculture systems where food animals are deliberately introduced,
domestic animals should be excluded from aquaculture operations and areas adjacent to
ponds.
12.8 Cleaning, disinfection and pest control
12.8.1 General
Areas around the ponds should be kept clean and free from rubbish, waste fish and items
not associated with the aquaculture operation
12.8.2 Cleaning and Disinfection Schedule
A permanent written cleaning and disinfection schedule should be drawn up to ensure that
all parts of the fish farm facilities and equipment therein are cleaned appropriately and
regularly.
A named person should be responsible for implementation of the schedule.
The schedule should be available for inspectors at all times.
Fish farm personnel should be trained in the use of special cleaning tools, methods of
dismantling equipment for cleaning and should be knowledgeable in the significance of
contamination and the hazards involved.
12.8.3 Pest Control Systems
A permanent written pest control schedule should be drawn up to ensure that all parts of
the fish farm facilities and equipment remain free from infestations of inspect and rodent
pests.
A named person should be responsible for implementation of the schedule.
The schedule should be available for inspectors at all times.
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12.9 Record keeping and batch identification
Effective records should be kept of each batch offish grown in each pond, to include
veterinary drug regimes, feeding methods and quantities, pond fertilisers added and any
results of water quality parameters.
The records should be kept for a period of one year after harvest.
Each batch offish leaving the farm for market or for processing should be allocated a batch
number which relates it to the information records described in section 12.1
Each batch offish leaving the farm for market or for processing should be marked to include
the following information:
•
•
•
•
•
Approval number of the aquaculture enterprise
Name of the enterprise
Date of harvesting
Species
Batch Number
Managers should ensure effective procedures are in place to effect the complete
traceability and rapid recall of any lot offish from the market.
12.10 Minimum Monitoring (own-check) requirements
Monitoring programmes should be implemented to ensure that:
•
•
•
•
•
•
Waste and debris eg.dead or diseased fish does not build up and is disposed of in a
hygienic manner;
Personal hygiene and health standards are maintained
The pest control programme is implemented
Cleaning and disinfecting programmes are implemented
Quality of water and ice any supplies is maintained
At the time of harvest, residues of any veterinary medicinal products applied during
the life of the fish are below the MRLs (where specified).
The results of all monitoring actions, and of any corrective actions taken after monitoring must
be recorded
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13 Responsibilities of the General Organization for Veterinary
Services:
The GOVS is responsible for conducting all the checks and procedures necessary to
ensure that the requirements of this Decree are complied with.
Inspections and control activities will be conducted as frequently as is necessary to
ensure an adequate level of control.
Inspections of export establishments, factory vessels, freezer vessels and aquaculture
production facilities which supply product for export to the EU will be subject to an
inspection at least every 6 months.
Inspection and control activities will include:
a) Inspection of the supply chain for export establishments, including fishing vessel,
aquaculture production, landing sites, and transport conditions to ensure that the
conditions at all stages meet those specified in this decree.
b) Inspection of the conditions in export establishments, factory vessels, freezer vessels
and aquaculture production facilities during production to ensure that the requirements of
this Decree are complied with.
c) In particular to ensure that HACCP systems are implemented according to the written
plan approved by the GOVS, and to check that critical limits are not exceeded.
d) In relation to general monitoring, the collection and analysis of appropriate samples
from different stages of production, of both product and the environment in which
product is handled, to include checks and measurements on:
•
•
•
•
•
Hygiene conditions of production.
Presence of human pathogens, including parasites
Residues of veterinary medicines used in aquaculture
Residues of environmental contaminants (heavy metals, pesticide residues, other
contaminants)
Presence of any other hazards for which there is a risk (such as histamine,
ciguatera)
14 The Series of Steps to be Followed to Acquire an Establishment's
Permit for the Export of Fish and Their Products:
1- The exporter presents to the General Organization for Veterinary Services an
application and fills out a registration form for the registration of an establishment and
the type of activity (Export of fresh or frozen fish) "attached"
2- The establishment is inspected by specialized veterinarians to determine the extent of
its matching with the General Organization for Veterinary Services conditions
conforming to the European countries Union specifications. A report of suitability
should be written down
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3- Consequent to the committee's minutes and the establishment's suitability report, an
establishment permit is issued containing the code number of the establishment
(according to the attached prepared form).
4- All quarantine outlets are informed by the code numbers of establishments in an area
under their jurisdiction in order to perform a veterinary supervision on such
establishments in all the preparation stages and until export.
5- The veterinary health certificate for the exported consignment is issued from the
export outlet with the establishment's code number written on it.
6- A registry is created at the concerned department to record the data of every
establishment
15 Verification of the Establishment's Code Number:
From left side: Telephone code for every Governorate of the Arab Republic of Egypt.
- (F) : First letter of the word fish in English.
Establishment code number. Registered in Latin numbers
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