THE IMPLEMENTATION OF HAZARD ANALYSIS AND CRITICAL CONTROL POINT (HACCP) BY THE SEAFOOD INDUSTRY IN MALAYSIA

Zahaitun Mahani Zakariah 1.0 Introduction There is a worldwide trend towards higher customer expectations for food safety and quality as a result of awareness on foodborne diseases outbreaks. This impact has been particularly felt, among others, in the manufacturing of fish products and has led countries like United States and European Union to tighten up regulations and to introduce new control system on the import of fish products. One such measure for food safety assurance is called the Hazard Analysis and Critical Control Point (HACCP). The HACCP system is a science based and systematic method that identifies specific hazards and measures for ensuring food safety. The potential hazards might be originated from pathogens, mismanagement of chemicals and antibiotics used. Where fish products are concerned, the prerequisite programs for HACCP foundation consist of water quality, sanitation, packaging and labeling should be scrutinized. The history of HACCP could be traced back to the National Aeronautics and Space Administration (NASA)s request to Pillsbury, a major food company to provide astronauts with safe food products. In 1970s, the US Food and Drug Administration (FDA) adopted HACCP in order to ensure the safety and quality of food sold in the US market. In 1991, Codex Alimentarius, an agency of the United Nations adopted HACCP as a food safety standard. The original concern for food safety which initially focused on microbial contamination, was later broadened to include chemical and physical hazards. In international trade, the application of HAACP assures consumers of confidence in food safety and their protection. The World Trade Organization (WTO) members involved in food trade need to consider and adapt their national legislation to the Codex Alimentarius provisions through Agreement on the Application of Sanitary and Phytosanitary Measures and the Technical Barriers to Trade. The European Union (EU) initiated the requirement for HACCP for the import and export of fish and fish products to the EU countries in 1996. Although the United States made the kick-off earlier at the national level, it only implemented for the international requirement on the imported products to the country in 1997. Development in food safety requirements motivated exporting countries to consider the implementation of HACCP for their food products. Although the implementation of HACCP is on the voluntary basis, the future of Malaysian seafood products in the international trade is highly linked with our ability to comply with the food safety requirements imposed by the importing countries. As an exporting country, Malaysia must be able to meet the mandatory requirements of importing countries. In this light, this report discusses the Malaysias progress in implementing HACCP.

2.0 Malaysias Seafood Export Industry The 1998 Fisheries Statistic reported that total export of fisheries commodities of Malaysia was 144, 540 tonnes, equivalent to value of RM 1, 232 million. The fisheries export commodities for Malaysia consists of live fish (including fresh water, marine fish and eels), fish fry and ornamental fish, chilled and frozen fish, salted fish, fish in brine, smoked fish and processed fish products. Figure 1 reflected percentage of the fisheries commodities for export the traditional markets. In terms of quantity, Thailand (26,540 or 18.3 %) is the top importer, followed by other countries such as China (23, 548 or 16.3 %), Singapore (20, 390 or 14.1 %), Japan (18,313 or 12.7 %), Hong Kong (6,773 tonnes or 4.7 %), Indonesia (6,259 tonnes or 4.3 %), Italy (6,060 tonnes or 4.2 %), Netherland (5,324 tonnes or 3.7 %) and others in 1998. Export to countries like Thailand comprising of cheaper fishery commodities. Malaysia also exported to the non-traditional markets like Cameron, Croatia, Laos, Monaco, Nepal, New Caledonia, Romania, Senegal, Seychelles, Syria and Yemen. Figure 1: Percentage of Quantity of the Fisheries Commodities for Export to Various Countries, 1998
Thailand China Singapore Japan Hong Kong Indonesia Italy Netherland Others

In terms of values, Malaysia exported fishery commodities of higher values to countries like Japan, USA and European countries. The exports consist of shrimps, prawns, fresh and frozen fish, and canned crustaceans and mollusk. In that sense, Japan still remained the top importer as reported in 1998. Table 2 shows the values and percentage of high value fisheries commodities to various countries. In terms of quantity, Malaysia imports more of low value fishery commodities, especially from Thailand and Indonesia (Table 3). This is done to gain foreign exchange and domestic demands for cheaper protein resources.

Table 2: Export Value of Fishery Commodities to Various Countries, 1998 Country RM (million) Percent (%) Japan 280.4 22.7 Singapore 114.1 9.3 Italy 111.2 9.0 Netherlands 100.3 8.1 Hong Kong 91.5 7.4 China 78.5 6.4 USA 67.4 5.5 Australia 62.5 5.1 Others 326.4 26.5 TOTAL 1,232.3 100.0 Table 3: Quantity and Value for Import and Export of Fishery Commodities, 1998 Quantity (metric tonnes) Value (RM million) 250 908 Import 145 1,232 Export In Malaysia, the seafood processing industry is dominated by the small and medium scale enterprise (SMEs) with capital assets less than RM100, 000. The small operation factories which are located mainly in coastal areas produced salted-dried fish, fish crackers, shrimp paste, fish satay, frozen seafood and fish meal. Whereas, the factories that aimed for export produced canned, frozen and surimi-based seafood products. Until the year 2003, there are more than 30 seafood processing companies have implemented HACCP for their export products. 3.0 Illnesses from Seafood Products The food borne and water diseases outbreak in Malaysia consist of cases such as cholera, typhoid and paratyphoid, hepatitis, food poisoning and dysentry. The cases of these outbreaks in Malaysia are as stated in Table 4. Although the incidence of illnesses from food borne and water borne diseases are high, cases particularly causes by seafood in Malaysia were not documented. Most illnesses caused by raw seafood products are often implicated by the pathogens that naturally occurred in marine environments. However, recontamination and cross-contamination product by raw products also can affect the cooked seafood products due to improper processing and packaging operations. The sources for seafood illnesses and diseases outbreaks are originated from causative agents such as microbs (e.g. Salmonella sp, Vibrio parahaemolyticus, Vibrio cholerae diarrhetic, Bacillus cereus, and Clostridium bifermentans, Listeria moncytogenes and Staphylococcus sp), natural poisons (e.g. shellfish poisoning, paralytic shellfish poisoning, scombroid poisoning, ciguatera toxin and histamine), parasites and chemical substance. Bacteria contamination can cause food poisoning that leads to diarrhea and miscarriage. The cost of seafood illnesses is sometimes tremendous which could cause death (e.g. Vibrio vulnificus).

Table 4: Food and Water Borne Diseases in Malaysia from 1998-2002 Year Cases Cholera Typhoid Hepatitis Food & Poisoning Paratyphoid 1998 1304 782 240 6976 1999 491 811 319 8640 2000 124 765 497 8129 2001 557 557 453 7137 2002 365 853 295 7023 (Resource: Ministry of Health, Malaysia)

Dysentry 246 429 447 348 292

In Japan, where seafood is usually taken raw or under-cooked, food poisoning occupied 22 % of food-borne diseases and illnesses1. Food and Agriculture reported that European Union seafood borne diseases and illnesses outbreaks between 1983 and 1992 from fish and shellfish, ranged from 4.4 % (United Kingdom England/Wales) to 16.1 % (Finland) (Table 5)2. The same report also enlisted seafood exporting countries that the products have received an alert by European Union (Table 6) - where Malaysia was identified as one of the seafood products exporting country. Table 5: The Total Number of Food-Borne Illness Outbreaks Attributed to Fish and Shellfish in European Union, 1983 -1992. Country Outbreaks Percent of Total Percent of Total Food-Borne Food-Borne Outbreaks Outbreaks when Implicated Food Source Known 50 12.4 13.8 Denmark 45 11.9 16.1 Finland 125 7.4 10.2 France 23 4.2 7.1 Germany 103 5.9 7.8 Netherlands 283 4.1 5.9 Spain 20 8.4 10.5 Sweden 105 3.2 4.4 UK (England/Wales) UK (Scotland) 37 1.9 4.6

Naoki Takatori. Application of HACCP System in the Japanese Seafood Industry. Proceedings of the 1st Regional Workshop on the Application of HACCP in the Fish Processing Industry in Southeast Asia. 28 August 1 September 2000. Singapore. 2 Seafood Safety Economics of Hazard Analysis and Critical Control Point (HACCP). http://www.fao.org/DOCREP/003/x0465e/X0465E04.htm

Table 6: List of the Exporting Countries that Received Alert and Numbers of Cases Detected by EU Countries. Exporting country Number (s) of case (s) 1 India 7 2 China 6 3 Portugal 5 4 Thailand 5 5 Spain 4 6 United Kingdom 3 7 Senegal 3 8 Guinea 3 9 Peru 3 10 Kenya 3 11 Italy 3 12 France 2 13 Morocco 2 14 Uganda 2 15 Turkey 2 16 Ivory Coast 2 17 Nigeria 2 18 Vietnam 2 19 Mauritania 2 20 Albania 2 21 Belize 1 22 Greece 1 23 Shetland Isles 1 24 New Zealand 1 25 Sri Lanka 1 26 Oman 1 27 Malaysia 1 28 Denmark 1 29 Tunisia 1 30 Netherland 1 4.0 Background and History of HACCP Implementation in the seafood export industry in Malaysia The implementation of HACCP in Malaysia, for exported food products is more to cater for the international demand on the sanitation and safety of food. The seafood export industry in Malaysia began in the mid 1970s when a few small companies in Malaysia started to export cooked and peeled prawn to overseas market. During this time, the prawn peeling activities were set up in fishing villages with no proper processing facilities. In 1997, Malaysia faced the first challenge in international pressure for sanitation of its seafood products when our prawn was

rejected by the United Kingdom and Australia due to the discovery of Salmonella sp in the shipment. To address this problem, Malaysias Ministry of Health introduced the Code of Practice for cooked and peeled prawn as a measure to avoid microbial contamination in seafood products for export. The export of prawns dropped in the 1980s due to shortage of supply and some of the companies stopped operating. However, aquaculture for black tiger prawn in the late 1980s revived the seafood export from Malaysia. This marked the shift from export of captured prawns to prawns from farms. The shift also saw the start of Malaysias effort towards developing a national level HACCP program. Apparently, the seafood export industry in Malaysia led the initiative in implementing the HACCP program. MOH led the task with cooperation from the National HACCP Certification Scheme that was launched on 19 April 2001 and it is the sole government agency recognized by EU as a competent authority for seafood safety in Malaysia. As a measure to conform to the WTOs Agreement on the Application of Sanitary and Phytosanitary (SPS) measures, MOH and SIRIM prepared published documents that are related to HACCP implementation; 1. 2. 3. 4. 5. 6. MS 1480: 1999 Food Safety According to HACCP system.* MS 1541: 2001 General Principles of Food Hygiene. * MCS 1: Guidelines for HACCP Certification. ** MCS 2: Guidelines for HACCP Compliance Audit. ** MCS 3: Guidelines for HACCP Compliance Audit.** MCS 4: Guidelines for HACCP Surveillance Audit.**

Note: * published by SIRIM ** published by the Ministry of Health 4.1 Implementation of HACCP by government The Department of Fisheries (DOF) is the key agency in implementing HACCP plan at source for the seafood industry. Together with Standard and Industrial Research Institute of Malaysia (SIRIM), Malaysia Agriculture Research and Development Institute (MARDI), the universities and other relevant agencies, DOF developed a standardized HACCP scheme for seafood products in Malaysia. The departments responsibilities include monitoring and checking the best practice of HACCP for capture and aquaculture products, and also training of personals, aquaculturist and seafood producers. MARDI has been given mandate by MOH in auditing HACCP for fisheries products and training of personals. Besides MARDI, MOH is in process of appointing the registered independent auditors. In line to the requirement from WTO and the Agreement on Sanitary and Phytosanitary (SPS) Measures, DOF has introduced programs on Implementation of Sanitation on Captured Fisheries and Certification Scheme to Aquaculture Farms. The former program is to ensure the landed catch is safe from pollution and at acceptable sanitation level for human consumption. These programs were introduced with the cooperation by the State government, such as Sarawak, and the owners of seafood and aquaculture industries. In order to ensure hygienic regulations

being complied during farming, harvesting, landing and marketing, DOF issues Sanitation Certificate to the seafood producers and aquaculturists. In 1999, the Sanitary and Phytosanitary (SPS) plan for capture fisheries was introduced in Malaysia. This plan provides sampling program for analyzing fish and water samples in order to detect microbes, histamines, heavy metals, harmful plankton, pesticides, and also to estimate fish freshness index. Table 7 shows examples of requirements on SPS agreement by US and EU countries. Table 7: Requirements on Sanitary and Phytosanitary Agreement Analysis Required Standards Bacteriological analysis 1.Faecal coliform US (< 230 MPN/100 g) EU (< 300 MPN/100 g) 2.Eschericia coli EU (< 230 MPN/100g) 3. Salmonella (nil in 25 g sample) 4. Vibrio cholera and V. parahaemolyticus (nil in 25 g sample) Histamine Heavy metal US ( < 50 mg/100g) 1. Cadmium (<1.0 ppm) 2. Copper (< 30 ppm) 3. Lead (2.0 ppm) 4. Zinc (< 100 ppm) Phrodium sp. Gymnodium sp. Alexandrium sp. Dinophsis sp Microalgae 14 Organochloride pesticide in marine products tissues Eye, body surface, gill, texture

Plankton identification

Pesticide analysis Fish Freshness Index

The program on the Certification Scheme of Aquaculture Farms is to encourage responsible aquaculture farming through the Code of Practice for Aquaculture. The scheme requires the culturists to comply with the guidelines provided by DOF. The validation period for certification is for two years subject to renewal on expiry. This scheme observes the good practice applied during farming which includes site suitability, water and soil resources, fish feed, the use of drug, chemical and pesticides, and post harvest handling. Under the Extension Program, DOF provides training, seminars and talks such on HACCP, GMP and Good Hygiene Practices (GHP), personnel hygiene and Food Act 1983. MARDI and MOH have conducted the HACCP awareness program for both small and big scale fish processing industries since 1998. Through fish handling training program, fishermen were taught on good practices to maintain fish freshness. This training promoted better fish handling technology such as using refrigerated sea water. For the food processing sector, a training course aimed to achieve 7

HACCP competencies among the personnel involved in fish processing industry such as the quality supervisor and on-line workers. HACCP system can be integrated into other Quality Assurance (QA) system. Codex Alimentarius Commission, through the Codex Committee on Food Import and Export Certification Systems (CCFICS) is currently deliberate on a proposed draft guidelines for the utilization and promotion of QA systems such as ISO 9000 and Total Quality Management (TQM). In Malaysia, SIRIM has prepared the Integrated HACCP/ISO 9000 certification which was launched in February 2002. The ISO 9000 has distinctive criteria to be incorporated with HACCP because it sets out the methods that can be implemented to an organization to assure that the customers requirements are fully met. At the international level, the Western is an example of combining the ISO 9000 with HACCP plan that is known as SQF2000. 4.2 Application of HACCP by Seafood Industry Main players in seafood industries consist of fishermen, aquaculturists and seafood producers. Although, its implementation is at voluntary basis, it becomes mandatory for the seafood producers that have intention to export their products to countries that require for the HACCP regulation. Hence, the producers must adhere to HACCP implementation which begins from catching fish to processing and packaging seafood products. Sanitation certificate is issued to these owners of seafood industries and it is based on activities consist of (i) culturing/farming process, (ii) after harvesting/landing, and (iii) handling/ packaging process. The sanitary and phytosanitary measures should be taken into consideration starting from the capture and landing activities, where the fishermen or aquaculturist is expected to handle fish in appropriate manner to avoid contamination and maintain freshness. 5.0 Issues and Problems HACCP implementation in Malaysia requires a commitment from industry. In ASEAN countries like Malaysia, the small-scale seafood producers still practice traditional methods of food production. The implementation of HACCP is generally accepted by the industries as means of responding to international trade pressure and not as a measure for improving food quality and safety. Thus, small-scale seafood producers are not willing to conform to the HACCP plan especially if they do not have intention to export their products overseas. At present, only large companies in Malaysia comply with the HACCP implementation in order to fulfill the international trade requirements. To restate the food cleanliness issue, Good Manufacturing Practice (GMP)3 is a basic requirement in producing food in hygienic manner. However lack of GMP and sanitation is seen as an impediment for HACCP implementation, especially when the small-scale seafood producers are lacking in financial and technical resources.

Good Manufacturing Practices (GMP) or also known as quality system regulation is a requirement related to the methods used in, and the facilities and controls used for, designing, manufacturing, packaging, labeling, storing of manufactured products. This action is necessary to add pre-production design controls and to achieve consistency with quality system requirements worldwide.

According to an article in the Ecologist Report4, the new hygienic regulations are seen as contributing to the demise of small food producers, so their market can be taken over by big companies. In this light, Marine Fisheries Department (MFRD) in Singapore as one of the Southeast Asian Fisheries Development Center (SEAFDEC) has carried out research and training programs in improving the traditional fish products (dried shrimps and fermented seafood products) in this region. Canadian International Development (CIDA) and Japanese Trust Fund Project supported MFRD in the HACCP-related within ASEAN countries. To ensure the quality of the seafood products, monitoring measures should be applied from the harvesting stage to packaging process. In this light, DOF has been working to ensure the landed capture and cultured fish are safe from pollution through programs such as Implementation of Sanitation on Captured Fisheries and Accreditation to Aquaculture Farms. For example in the later program, water quality is the parameter to ascertain the level of pollution at the farming site. Unfortunately, DOF is powerless in this matter since the jurisdiction for monitoring water pollution is under the Department of Environment. On the same note, to adhere to the requirement for clean water in aquaculture, integrated farming is found not suitable because it is associated with poultry farming and animal husbandary that could introduce enterobacteria (e.g. E. coli) contamination to fish ponds. At present, the HACCP certification in Malaysia is based on the requirement of European Union and United States Food and Drug Administration (USFDA) which focuses only on food safety. Some other importing countries have other requirements besides of HACCP certification. For example, Canadas Quality Management Practice (QMP) includes food quality and Australian SQF2000 program combines HACCP and ISO 9000. These additional requirements would make compliance by the exporting countries more complicated. Because of the differing requirements and occasional change to meet new technology and more stringent demands, exporting countries would have to carefully scrutinize the HACCP systems for every importing country in order to avoid rejection and complication. 5.0 Emerging Issues and Challenges HACCP plan is prepared for monitoring food safety based on the microbial, chemical and physical hazards. However, it does not cover issues on genetically modified organism (GMO) which maybe against customers health condition (e.g. allergy) and as well as humane and religious values (e.g. vegetarianism, Halal food). In 1999, the US Department of Agriculture (USDA) permitted food produced from controversial methods such as genetic modification and nuclear irradiation in order to achieved high productivity. Eventually, the USDA withdrew this proposal due to tremendous public outcry in US. Perhaps HACCP should also include the issues on GMO and nuclear irradiated food products. The emergence of new foodborne disease and ailment needs more sensitive method for testing the contamination in food. The purchase of high-tech equipments for detecting new strain of microbes could be burden to developing countries not only have to upgrade the scientific equipment but also their human resource.
4

Teddy Goldsmith. Unhygienic or just small scale. The Ecologist report. June 2001.

6.0 Recommendations and Conclusion In order to fully comply with HACCP, the exporting countries must change the traditional business into an industrial scale. Thus small-scale seafood producers which intend to export their seafood products should merge in order to create big company through cooperation concept. The company can invest in better physical structure such as building and facilities. Incentives such as grants, loans and subsidies to the seafood producers from the government will help in elevating the financial burden and other pressure that related to GMP and sanitation issue. Since hygiene and the correct use of chemicals in aquaculture are the important elements in complying with the HACCP system, DOF must educate the small farmers on the best farming practice. Besides increasing the staff in auditing the farming activities, DOF also should consider expanding its human resource for education programs that specialize in educating the farmers on hygiene and correct use of chemicals in aquaculture practices. More stringent enforcement of the Environmental Quality Act 1974 and its regulations is needed to improve the water quality on land and in coastal areas. Perhaps a special regulation for pollution mitigation is needed in the coastal areas meant for intensive aquaculture sites. This regulation should also include the requirement for installing sewage treatment disposal in the coastal area to mitigate the land-based pollution. Despite of issues and challenges in implementing HACCP for exporting the seafood products in Malaysia, most of the problems are confined to the small-scale seafood producers. The industrial scale seafood producers who intend to export their products view the HACCP as a positive development. This could be seen through the industries strong commitment in complying with the HACCP requirements. The Malaysian government fully supports the industries in terms of improving facilities and infrastructure for fish and fish products. The Ministry of Health hopes to impose HACCP certification on all food products including the small-scale food producers within the next ten years5. In order to cater for the local consumption, first of all the consumers perception on hygiene and food safety needs a lot of improvement.

MARITIME INSTITUTE OF MALAYSIA (2003)

New Straits Times. 29 July 2001.

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