Food > Fish and Seafood > Product Inspection > Facilities Inspection Manual Chapter 3, Subject 4
QMP Reference Standard and Compliance Guidelines
Appendix A
Guidelines for the Development of a Product Description
The importance of the product description, including the intended use, distribution,
and consumer information should not be underestimated.
The product description has two major roles:
a) it contains sufficient information regarding the product which is essential to the
hazard analysis and the development of safety and regulatory controls in the QMP Plan;
b) to describe the scope of the QMP Plan, i.e., all of the documentation, controls,
reports, corrective actions, etc., in the QMP Plan that pertain specifically to the
product described in this section.
Information contained in the product description must be supportable. In particular,
physical characteristics, composition, packaging, and/or shelf-life attributes which
impact on the risk of a hazard or its likelihood of occurrence must be substantiated. This
data is usually found in association with the HACCP Plan.
The product description can be developed using the following 3-step approach:
Step 1 - Describing the product in consumer terms
The product should be described in consumer terms, including:
a) the product name
This should use the acceptable common name associated with the species, and the manner
of processing or intended preparation.
For example, fresh aquaculture raised Atlantic salmon, canned chinook salmon, salt cod,
etc.
The List of Canadian Acceptable Common
Names for Fish and Seafood, is available on the CFIA Internet.
b) the type of product packaging
This should describe the packaging of the final product and may include multiple types
of packaging.
Key issues associated with food safety are selective barrier films, vacuum packaging,
recycled packaging materials, the acceptability of food contact materials, and
identification of potential sources of physical contamination (i.e., product packed in
glass represents a potential source of contamination from broken glass).
Any characteristics of the packaging which may affect the multiplication of microbial
pathogens and/or the formation of toxins should be identified. For example, the potential
for growth and toxin production of Clostridium botulinum in products packaged in
selective barrier (i.e., oxygen permeable) films, and vacuum or modified atmospheric
packaging and the potential growth of Listeria monocytogenes in products packaged
for extended shelf-life.
Step 2 - Describe any factors which may result in the addition of ingredients
or other compounds to the product
Consider and identify any sources of intentional and/or unintentional additions to the
product which may affect product safety, including:
a) the source of incoming fish where it could affect product safety
Fish, whether migratory or non-migratory may be disposed to naturally occurring or
man-made contaminants or other compounds in the environment.
In general, Canadian products should be identified by the waters where the fish was
harvested or the location closest to it. However, where a known risk exists, it is
important to identify any source(s) that is not acceptable. For example, a fisheries
exclusion zone or area closed to harvesting as a food safety precautionary measure.
Bivalve molluscs must be identified by specific harvest area or areas.
Imported fish must be identified by the country of origin, and where geographic risks
apply, by more specific localities.
b) processing steps or processing aids which could affect product safety or regulatory
compliance
Any compounds that are added to the product, either directly or indirectly, such that
they are part of the product whether or not the component is listed on the label, must be
identified.
Fish culture, harvesting, processing, and/or transport operations should be considered.
For example, consider the following ingredients, processing aids, or residual compounds
that may be added to the product:
- aquaculture therapeutants
- sawdust used to naturally smoke fish
- ice used to pack fresh fish during transport, processing or in the final product
- boiler compounds in steam used to pre-cook fish
- water used to flume or wash fish
- traditional ingredients (salt, sugar, spices, vinegar, etc.) must also be listed.
c) the important characteristics of the final product which are intended to affect
product safety or influence the growth of disease-causing pathogens, such as additives,
salt concentration, water activity (aw), or pH.
Step 3 - Describe the conditions of distribution, intended use, and consumers
of the food
Consider and identify the factors which impact on product safety and regulatory
compliance, including:
a) the product market, i.e., within Canada or outside Canada;
b) special distribution controls or instructions for safe product distribution, e.g.,
"Keep Refrigerated" or "Keep Frozen";
c) labelling instructions that may be applicable for safe product storage and
preparation, e.g., "Keep Refrigerated";
d) the intended end product use which may effect the product safety.
For example, consider: Will the food be heated by the consumer? Will there likely be
leftovers? Is the food intended for the general public? Is the food intended for
consumption by a population with increased susceptibility to illness (e.g., infants, the
aged, the infirm, immuno-compromised individuals)? Is the food for institutional use or
for the home?
e) the product's shelf life.
For example, consider: the potential growth of Listeria monocytogenes in
extended shelf-life products; the potential effect of shelf life on the integrity of
sensitive packaging materials.
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