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Code of Practice for the Harvest, Transport, Processing, and Export of Seal Products Intended for Human Consumption
Appendix III: Harvest Vessel Processing/Construction/ Storage Requirements

1.0 Training

Controls must be established to ensure that all crew members involved in processing (pelting/evisceration) upon the harvest vessel are appropriately and adequately trained.

1.1 Each crew member who will be processing seals upon the vessel must be trained in the proper methods of pelting, evisceration, handling, storage, sanitation, personal hygiene, and effective measures to ensure that contamination of the meat and fat to be processed for human consumption does not occur. The training shall include appropriate sections of the Code of Practice.

1.2 Documentation of the delivery of adequate training must be maintained. Each harvester/harvest vessel must be able to verify to the competent authority, and to the registered processor of the seal products, that they have received adequate training which ensures they are capable of processing acceptable food products.

2.0 Holding/Processing Controls On the Harvest Vessel

Holding of harvested seals upon the vessel is conducted in a manner to prevent contamination.

2.1 On-deck holding areas for un-eviscerated bled seals must be designed so that any deck water/processing residues of blood etc. do not come into contact with the stored animals.

2.2 On-deck holding areas shall be adequately elevated above the deck, and drained to remove water/blood from this area on a continual basis. Cleaning of this area should be conducted as is required.

2.3 During holding, seals shall be placed so there is no excessive weight upon them which would result in leakage of the gut/anal contents. Care must be taken to minimize the exposure of the seals to contamination during on deck holding.

2.4 Processing tables upon which seals are placed for processing/evisceration must be of suitable construction, and designed for effective cleaning/sanitation. They should be free of cracks, depressions or any other feature which would prevent effective cleaning and sanitation. Wooden processing tables, or other processing equipment such as wooden chop blocks are not acceptable.

2.5 Processing equipment including knives/saws shall be of appropriate design and construction. Wooden handles are not acceptable. All processing equipment must be designed to be easily cleaned and sanitized.

2.6 During pelting/evisceration care shall be taken to minimize exposure of meat/fat to visceral contents. Processing tables and equipment (e.g. knives) onto which visceral contents may spill must be effectively cleaned and sanitized. Exposure of meat/fat to any such contamination should be prevented. The seal shall be eviscerated in a manner to prevent the spillage of gut material onto the processing table.

2.7 Cleaning and sanitizing chemicals needed for such cleanup of food contact surfaces in response to exposure of the surfaces to gut material, shall be readily available when needed. They shall be stored in a manner as to not spill onto meat/fat products.

2.8 During processing there must be a continual flow of clean sea water upon the deck to remove blood and other material resulting from evisceration and pelting activities.

2.9 Viscera removed must be immediately discarded to prevent contact with meat/fat product. If discarded into the sea, the visceral contents, and the deck wash water must not come into contact with the intake water supply or any seals or seal products which are in the sea being cooled, or awaiting processing.

2.10 Following evisceration and pelting (identified in sections 3.2.5-3.2.7 in Appendix I), the meat and the pelt must be immediately washed, and cooled. The meat must not come into contact with the pelt once pelting has been completed. Re-circulating wash water is not acceptable.

2.11 Following the washing of the meat and pelt, they must be cooled and stored to maintain a storage temperature of 4°C or colder.

2.12 Pelts and meat must be handled to protect them from all sources of contamination. Contact with the deck, or other non-food contact surfaces must be avoided.

3.0 Storage on the Vessel

Seal products and ice are protected from contamination during processing, handling, storage, and transportation, upon the harvest vessel. Vessels of any size (including vessels with below deck storage holds, and open vessels with mid-ship storage lockers) must be designed to meet these requirements.

3.1 Seal meat must be stored separately from pelts in order to prevent cross contamination. Storage areas (e.g. pounds of larger vessels, mid-ship rooms of smaller vessels) must provide physical separation of the meat and the pelts. Vessel holds/storage areas where required, shall be constructed to provide drainage and to ensure that melt water and bilge water does not come in contact with seal products and ice.

Vessels with chilled seawater or that use slush ice systems are exempt from this provision.

Melt water must not become a source of contamination. Excess water/effluent from the pelts must not have access to the pounds containing the meat. Excess water should be disposed of through proper drainage/bilge pumps.

3.2 Handling practices in placing the seal product into the storage areas must not result in cross contamination of the meat from the pelt. During storage care shall be taken to ensure that the storage areas are not contaminated. Personnel shall not tread in the pounds or upon stored pelts/meat.

3.3 Ice stored upon the vessel for use in refrigeration of meat/pelts must be stored in an approved container or compartment which protects it from sources of contamination until it is placed upon the product.

3.4 All containers/holds where seal products are stored must be outfitted with tight fitting covers. Vessels with holds, including mid ship storage rooms, will be required to have tight fitting preferably insulated, covers to aid in maintaining refrigeration of the fish. Vessels with below deck storage shall have colemans of an adequate height to ensure there is no leakage from the deck into the hold.

Unacceptable Covers

Canvas or polypropylene tarpaulins are unacceptable.

3.5 Seal products must be protected from the sun, weather, environment, and such contaminants as grease, oil, fuel, glass, or bilge oil. Equipment such as chain drives, drive shafts, and bearings, if present, must be enclosed to protect the product and the ice from contamination.

Bulkheads are required to be watertight to prevent any contamination of the seal product storage area with fuel, grease, and other contaminants.

Equipment, including fuel lines, fuelling ports, waste disposal lines and fuel storage tanks, shall not be located in a seal product storage area. If these cannot be relocated, they must be totally enclosed and watertight.

It will not be necessary to enclose below deck bilge pumps, solid hydraulic lines, and hydraulically operated fish pumps provided they are adequately maintained and coated with a suitable epoxy or paint.

Rubber hoses must not be painted as the flexing causes the paint flake off.

All lights must be of a shatterproof design or be adequately protected with a shield to prevent breakage.

Stored seal products must not be stored in any area where it is prone to contamination with rust or any other form of foreign matter.

Animals are not allowed onboard fishing vessels or in areas where seal products are unloaded from those vessels.

3.6 Seal products must not be contaminated with pieces of viscera, or visceral contents, as they are heavily laden with spoilage bacteria and digestive enzymes.

Seal offal and waste water must not be allowed to contaminate seal products during storage. Disposal of offal or refuse must not create obnoxious odours or unsanitary conditions upon the vessel.

4.0 Transport Conditions

Seal products must be transported in a manner to prevent decomposition or contamination of the product.

4.1 Areas/containers which have been previously used for transporting hazardous or unsanitary materials such as chemicals, pesticides, fertilizers, fish offal and other waste, shall not be used for transporting seal products.

Only approved containers (e.g. polyethylene tubs) may be used to transport seal products.

4.2 During transport, seal products must be maintained at a storage temperature of 4°C or colder, in order to maintain product safety and to ensure that decomposition does not occur. Refrigeration may be achieved through the use of ice or other acceptable means (e.g. slush ice, clean cold circulated sea water).

4.3 Ice used to chill seal products must be obtained from an approved source. Clean ice obtained from the harvest site is acceptable. When ice is used, sufficient ice shall be added to reduce and hold the temperature at 4°C or colder. Additional ice may be used to replace the ice as it melts in order to maintain the required holding temperature.

Previously used ice shall not be reused.

4.4 Chilling systems other than ice may be used to maintain adequate storage temperatures of seal products during transport. Such systems or other methods must be capable of cooling and maintaining the temperature of the seal products to 4°C or colder. Vessels using refrigerated seawater or chilled seawater systems must have a thermometer which continuously measures the temperature of the seawater.

Cool ambient temperatures, or refrigeration systems producing cool air have not been found to be suitable replacements for ice, as a means to refrigerate seal products.

4.5 During transport seal products must be stored in a manner so that they are protected from crushing. Where necessary, bulk storage pens shall be divided vertically to prevent crushing of the bottom levels of stored seal products from occurring. The requirement for fish is that storage pens be divided vertically at intervals of 90cm or less where it is necessary. Where the industry can verify that a storage height of greater than 90cm will not result in the crushing of stored seals products during transport, the CFIA may consider holding this regulatory requirement in abeyance.

4.6 Seal products must not be handled in any manner that causes physical damage. Forks, tools or other equipment and practices that tear, or otherwise damage or contaminate the seal product shall not be used.

Seal products must not be thrown or dropped into storage area but rather be allowed to slide down chutes, flumes and other devices designed to minimize physical damage to the seal product.

Seal products must not be trampled, walked upon, roughly handled or otherwise mis-handled at any time during processing, transportation or handling.

4.7 Frozen storage (if applicable). Seal meat which is frozen upon the vessel, must be held under conditions that maintains safety and quality. Storage areas in which frozen seal meat is held onboard a vessel shall be maintained at a temperature at -18°C or lower.

4.8 Frozen seal meat shall be protected from dehydration and oxidation. After freezing the seal meat shall be glazed or packed with a suitable impervious packaging material onboard the vessel to protect it from dehydration and oxidation.

4.9 Frozen storage temperatures must be monitored. Each cold storage room on the vessel which is used to hold frozen seal meat, must be equipped with an automatic temperature recording device. (Note: This does not apply to storage areas where seal meat/pelts are stored in ice.)

5.0 Construction, Equipment and Maintenance

All vessels engaged in the transport of seal products for human consumption must meet the requirements of Schedule III of the FIR. Responsible personnel should be familiar with the requirements of Schedule III.

Seal product storage and handling equipment are made with approved materials which are easy to clean and will not physically damage or contaminate the seal products.

5.1 Materials and Design. Seal product contact surfaces must be constructed of approved materials.

Seal product contact surfaces on equipment, holds, pens (shelving and dividers), boxes and chilled water tanks shall be constructed of non corrodible, smooth surfaced materials impervious to water. Examples include steel, sea water resistant aluminum alloys, high density plastic, polyurethane coated cement or fibreglass reinforced plastic. Surfaces shall be smooth and free of crevices to prevent physical damage of the seal products and to facilitate cleaning. Electrical wires, piping, or any other auxiliary structures must not interfere with the effective cleaning of storage areas.

Equipment with direct contact with seal products and ice shall be made of non absorbent, non corrodible materials, other than wood.

Containers into which seal products are placed shall be of smooth, non absorbent, non corrodible material other than wood, free from cracks and crevices, and constructed to provide drainage and protect the seal products from damage when the boxes are stacked.

Unacceptable Surfaces

It is not acceptable to coat wood or other surfaces made of materials that are not suitable for food contact with coatings that are prone to damage. Epoxy coated wooden boxes will not comply. Paints and other coatings such as some types of epoxy resins that are used on these surfaces that are prone to damage may result in direct contamination of the seal products and will make the surfaces difficult to clean.

Galvanized metal and wood are not permitted.

5.2 Equipment design facilitates cleaning. Equipment must be designed to be accessible during regular cleaning operation to prevent accumulation of debris. If necessary, equipment should be easily dismantled to facilitate cleaning of all parts.

5.3 Storage compartments are insulated from heat sources. The engine compartment and other heated areas must be separated from the ice and seal product storage area by water tight, insulated bulkheads and wall surfaces. Bulkheads and deck heads in frozen storage areas of a vessel shall be well insulated.

All insulating materials must be properly installed. Any ice melt water, blood, or slime seeping through the fish lining will reduce their efficiency of the insulation and this will in turn lead to an increase in the temperature of the seal products. All insulation must be properly covered with approved, impervious fish hold lining material. All joints must be watertight.

5.4 Refrigeration Equipment

If the vessel is equipped with refrigeration systems, those systems will reduce the temperature of the fish at a rate that maintains product safety and quality. Systems must provide adequate cooling rates and holding temperatures.

Materials used in these systems must be non-porous to reduce the risk of contamination. Appropriate materials include stainless steel, high density plastics, seawater resistant aluminium and copper based alloys.

The entire system must be designed to allow an easy introduction and effective circulation of the cleaning and disinfecting solutions ensuring all surfaces are kept clean.

5.5 Regular cleaning and maintenance is followed such that storage areas, equipment and other fish contact surfaces do not become a source of contamination.

Seal product handling equipment is maintained to prevent contamination of the seal product. Equipment must be kept clean and sound.

Surfaces of equipment are free of corrosion, peeling paint, or other defects that will contaminate the seal products or make cleaning difficult.

Any surfaces that contact seal products shall be maintained to be sound, smooth, and free from cracks and crevices. All seal product receiving areas, equipment, containers and utensils used to handle the seal in preparation for storage, must be cleaned with suitable water and disinfected at least once per day while the vessel is operating.

6.0 Sanitation

Each vessel must implement sanitation procedures to ensure that the vessel and all food contact surfaces are maintained in a clean and sanitary condition.

6.1 Sanitation procedures must be documented. Procedures should identify the area to be cleaned, the frequency of cleaning, the procedures to be followed, cleaning and sanitizing chemicals to be used and their method of preparation, and persons responsible for cleaning procedures.

6.2 Adequate cleaning requires that all equipment and processing surfaces, as well as other areas (e.g. where seals are handled) of the vessel, be rinsed, thoroughly cleaned (with cleaning chemicals), rinsed and sanitized.

6.3 All cleaning chemicals shall only be used following the manufactures recommendations.

6.4 Containers and equipment must be allowed to air dry prior to stacking or storing.

6.5 Following the discharge of seal products from a vessel, all equipment, utensils, storage areas, and containers shall be subject to cleaning procedures.

6.6 Cleaning must occur promptly after unloading at the end of each fishing trip. All seal product holding facilities, and other equipment and utensils that come in contact with the product shall be washed with suitable cold water (includes clean seawater under adequate pressure). Surfaces must be thoroughly scrubbed with a brush or high pressure cleaning equipment and an acceptable detergent and then rinsed. Clean surfaces should then be disinfected with hypochlorite solution or another suitable sanitizing agent and rinsed with cold water to then again remove the disinfectant.

In the case of boats equipped with chilled water systems, all pipes and heat exchangers must be flushed with suitable water and a cleaning solution to remove slime, blood, and viscera. These systems must be flushed again with suitable water to remove all traces of the cleaning solution. The use of a disinfectant is also strongly recommended providing the system is rinsed with water before the tanks are filled prior to fishing.

Cleaning and disinfecting as appropriate must be completed prior to taking on fresh ice for the next trip, and prior to the initiation of subsequent processing activities.

6.7 Cleaning Chemicals Are Acceptable For Food Contact Surfaces.

Cleaning chemicals must be suitable for food contact surfaces. If in doubt, please refer to the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products.

7.0 Water Source

Water used for cleaning must be obtained from an acceptable source and not be a source of contamination.

7.1 Water must be obtained from a suitable source. Harbour water, or water from alongside the dock where the vessel is tied up, must never be used for cleaning purposes as its safety cannot be verified. This is also true for water in close vicinity to towns, villages, industrial plants, fish plants and factory freezer ships.

Re-circulating cleaning water is not permitted.

8.0 Hand Washing and Toilet Facilities

Seal Products Must Not Be Contaminated by Human Waste.

8.1 There must be an adequate number and placement of toilet facilities. Hand washing and marine type toilet facilities shall be provided on vessels over 13.7 metres or more in overall length that have sleeping accommodations.

8.2 The owner of the vessel must be able to demonstrate that the location and number of flush toilets and wash basins is appropriate for the number of crew on board the vessel.

8.3 The hand wash facilities shall be located close to the seal product handling area to encourage frequent hand washing. The use of the galley sink for hand washing is considered acceptable.

8.4 As a general guide, one marine type flush toilet and one wash basin shall be provided for every ten crew members.

8.5 Toilets and washbasins must be properly equipped, clean, sanitary and must be maintained in a clean and sanitary condition.

8.6 Hand washing facilities shall be equipped with running water, (use of a reservoir piped to a sink is acceptable), liquid or powdered soap and single service towels.

8.7 In the absence of adequate hand washing facilities (smaller vessels) persons handling seal products must use proper hygienic practices (hand sanitizers).

8.8 Waste from toilets and washbasins must be properly handled. The waste discharge must drain overboard, be equipped with a check valve if necessary, and be situated on the opposite side of water intakes and further towards the stern in order to minimize the possibility of contamination when the vessel is in forward motion.

A washbasin draining into a pail is unacceptable.

9.0 Daily Catch Log

Harvesters must be able to identify the time and location where seals were harvested.

9.1 The vessel owner/operators must maintain an accurate log onboard the vessel, indicating the numbers of seals harvested and the harvest location. These records shall be maintained on a daily basis. These records must be made available to the competent authority upon request.

10.0 Training Records

Training procedures and records must be maintained to clearly document that harvesters are adequately trained in the proper processing, handling, storage and transportation of seal products.

10.1 Written procedures which document the requirements for the handling and storage of seal products upon the harvest vessel, and the procedures to monitor adherence to the construction requirements of harvest vessels must be maintained.

10.2 The vessel captain shall ensure that crew members that participate in the fishery are properly trained in the harvesting, handling, storage and transportation requirements.

10.3 A record of the training shall be kept on file by the harvester for a minimum of three years.

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