U. S. Food and Drug Administration
Center for Food Safety and Applied Nutrition
March 29, 2001

Appendix A: Summary of Cold-Smoked Process
Appendix B: On-Board and Aquaculture Post-Harvest Handling of Fish
Appendix C: Verification Procedures and Corrective Actions during Cold-Smoked Processing
Appendix D: Industry Survey

Appendix A

This appendix provides a brief summary of the cold-smoking process as a complement to Chapter VI, Control of Food Safety Hazards During Cold-Smoked Processing, which includes a more detailed description of the process and identifies potential hazards, control points, and processing parameters. Both Chapter VI and this summary address some recommendations by the Association of Food and Drug Officials (AFDO 1991). It bears repeating that although developed by experts and widely used, these recommendations have not necessarily been scientifically evaluated. The recommendations from the Fish & Fishery Products Hazards & Controls Guide (FDA 1998) are indicated for reference.

Cold-smoked fish processors receive fish that are either wild-caught or farm-raised. For both practices, scombrotoxin-susceptible fish should be received at an internal temperature of 40 °F (4.4 °C) or less. If fish are received directly from the harvest vessel, all lots should be accompanied by documentation certifying proper time and temperature handling of the fish. In addition to the time and temperature parameters, analytical testing for biogenic amines should be done periodically on samples of edible fish flesh (FDA guidance limits the histamine level to 50 ppm). Even though an experienced processor may be doing the evaluation, sensory analysis is a very subjective and not quantitative monitoring method; therefore, a more objective method (analytical method or temperature record) should be in place. Practically, most companies use a sensory evaluation of incoming scombrotoxin-susceptible species with a maximum receiving temperature for refrigerated raw material received. If sensory analysis points to a high biogenic amine level, analytical testing is performed.

If product is received frozen to control parasites, a number of time and temperature combinations have been recommended in the United States, such as holding the fish at -10 °F (-23 °C) for 60 h, or less than -4 °F (-20 °C) for 7 d, or -31 °F (-35 °C) internally for 15 h. For a more detailed explanation of freezing regimes, see Chapter V. Farm-raised fish fed a controlled diet such as processed feed pellets and reared in the proper environment are generally free of parasites.

Raw fish stored fresh should be kept in an appropriate refrigerated or iced condition to maintain an internal temperature of 40 °F (4.4 °C) or less, especially if scombrotoxin-susceptible fish are to be cold-smoked. The reader is referred to the Fish & Fishery Products Hazards & Controls Guide (FDA 1998) for recommendations on refrigeration time and temperature critical limits for scombrotoxin-susceptible fish.

Wild-caught fish intended for cold-smoked processing should be frozen at some step during the process. Generally, fish are frozen either before brining or slicing. For quality purposes, it is recommended that freezing be performed before the salting and smoking steps. Often, the freezing step before slicing is conducted to make the fish "hard" enough to cut. Regardless of the stage at which fish are frozen, a number of time and temperature combinations have been recommended for proper storage to control parasites, such as holding the fish at -10 °F (-23 °C) for 60 h, or less than -4 °F (-20 °C) for 7 d, or -31 °F (-35 °C) internally for 15 h.

Thawing, washing, and rinsing of the fish should be done under sanitary conditions and temperature control. AFDO guidelines offer the following recommendations for thawing temperatures. If the fish are thawed in water, the water should be continuously flowing or spraying, with the water temperature below 60 °F (15.5 °C). The internal temperature of the fish should remain below 45 °F (7.2 °C). After thawing, the fish should be washed and rinsed thoroughly with potable water.

Fish should be butchered separate from the rest of the processing area. Gutting should be performed with minimal disturbance of the intestinal tract contents. After butchering and evisceration, the fish should be washed and rinsed thoroughly, especially the body cavities, with continuously flowing or spraying water.

Brining is the process by which the fish is soaked in a solution consisting of water, salt, sugar, various spices and flavorings, phosphates, and, depending on the recipe and species of fish (sable, salmon, shad, chub, and tuna), additives such as sodium nitrite. Dry-salting involves placing fish for a certain period of time in a dry mixture of salt and other ingredients. Fish also may be brined by injecting the fish with a solution, either by hand or machine.

Salting should be as uniform as possible, with the correct amount of salt or brine solution absorbed into each piece of fish flesh.. To achieve uniformity, fish must be sorted by size and thickness; different species of fish should not be mixed in the same brining tank, and the weight-volume ratio, time, and temperature of the process should be controlled. It is extremely important that brining solutions not be reused or recycled unless treated in some way to maintain an acceptable microbiological profile. If the fish is washed after salting, washing and rinsing should be done with potable water.

Salting times may vary from < 1 h to 24 h. The time and size of the fish pieces are empirically determined. Brining is usually a cold process, but it also may be done at room temperature (50-60 °F, 10-15.5 °C). AFDO guidelines recommend that the temperature of the brine not exceed 60 °F (15.5 °C) at the beginning of brining. If the brining or soak time is longer than 4 h, the brining must be done under refrigerated conditions. Fish processed with a dry-cure mixture should be held under refrigerated conditions in the salt mixture. If brining is done by injection, a saturated salt solution is used up to a temperature of 65 °F (18.5 °C).

A number of cold-smoking procedures involve a drying stage with no smoke added to the product. The product is held at a certain temperature, often refrigeration temperature, for a certain amount of time before the smoke is introduced. The parameters of this initial drying component include the type or species of fish, its fat content, and humidity. During this time, a pellicle is formed on the outside surfaces of the fish pieces.

During the cold-smoking step, the fish must be arranged to allow for uniform smoke absorption, temperature exposure, and drying. The smoke can be "natural" (generated), liquid, or a combination of the two.

In Europe, cold-smoking temperatures are below 30 °C (86 °F), based on protein coagulation temperatures. AFDO guidelines recommend that cold-smoking temperatures should not exceed 90 °F (32.2 °C) for more than 20 h; 50 °F (10 °C) for more than 24 h; or 120 °F (48.8 °C) for more than 6 h for cold-smoked sablefish. In the United States, cold-smoking is seldom performed at temperatures above 100 °F. The duration is usually in the range 6-12 h.

7. Cooling

According to AFDO guidelines, after cold-smoking the fish should be cooled to 50 °F (10 °C) within 3 h and to 38 °F (3.3 °C) within 12 h. These recommendations, however, are under reviewed.

8. Slicing and cutting

After cooling, cold-smoked fish are often sliced and cut. A processor must have well-designed and comprehensive Sanitation Standard Operating Procedures (SSOPs) and must follow Good Manufacturing Practices (GMPs) during slicing and cutting.

9. Packaging

Cold-smoked fish is packaged using film with variable oxygen transmission rates (OTRs). Gas permeability is an important parameter and should be taken into account when doing research and making decisions on food safety issues. Specifications for gas permeability, however, are product- and use-specific and are usually established at ambient temperatures under moderate humidity conditions (for example, 23 °C and 50% R.H.) using a variety of testing and verification methods. Consequently, it is difficult to extrapolate the OTR of a package to a specific combination of package, product, and conditions.

The Fish & Fishery Products Hazards & Controls Guide (FDA 1998) recommends at least a 2.5% WPS in the loin muscle of the finished product in air-packaged fish. For vacuum-packaged or modified atmosphere-packaged fish, a salt concentration of at least 3.5% WPS in the loin muscle of the finished product or a combination of 3.0% WPS in the loin muscle and at least 100 ppm but not more than 200 ppm of sodium nitrite is recommended (allowed in the United states for sable, salmon, shad and shub).

The final product should be kept under refrigeration. If the product has the appropriate salt content, scientific data support that the storage temperature should be maintained at a maximum of 40 °F (4.4 °C) for 4 wk for safety. The product should be labeled as to the required refrigeration temperature and storage time.

10. Storage and distribution

Cold-smoked fish products can be stored refrigerated or frozen. In any case, finished product must be maintained at or below 40 °F (4.4 °C) at all times throughout storage and distribution.

[AFDO] Association of Food and Drug Officials. 1991 June. Cured, salted, and smoked fish establishments good manufacturing practices [model code]. [York (PA)]: Association of Food and Drug Officials. 7 p.

[FDA] Food and Drug Administration. 1998. Fish & Fisheries Products Hazards & Controls Guide. 2nd ed. Washington, D.C.: FDA, Office of Seafood. 276 p.

Minimizing the microbial load on seafood products begins prior to the harvest of the product. Raw materials for cold-smoked fish products include both wild and aquaculture species. In either case, the microbial flora present will be determined by that present in the waters from which the fish are harvested and the feed materials consumed by the fish. In general, fish harvested from the open ocean will be relatively free of human pathogens (with the exception of certain parasites) while those harvested from near-shore saltwater, fresh water, and aquaculture sources are at greater risk for contamination. Sources of the microorganisms include general pollution resulting from human, animal, and agriculture waste.

Regardless of the source of the raw material, a good sanitation regimen is critical to minimize the growth of the existing microbial load and even more important to minimize the risk of introducing additional organisms. Good Manufacturing Practices (GMPs), including holding, transporting, and processing at appropriate low temperatures, are also requisite.

On a harvest vessel, a good sanitation program includes regular cleaning and sanitizing of nets, brailers, equipment (harvest and processing), holds, totes, baskets, boxes, and bins. It is also critical that water, refrigeration and freezing media, such as refrigerated seawater and brines, and ice are as free of microorganisms as possible. Thus, appropriately treated water should be used in processing, ice production, contact surface cleaning and rinsing, and in other applications whereby contamination is possible. Several publications prescribe excellent on-board procedures for both harvest and transporting vessels (Crapo and others 1986; Crapo and Elliot 1987; Crapo and Paust 1987; Rasco and others 2001).

The microbiological flora present on farmed fish is affected by water quality and feed composition. The quality of water can vary dramatically. Specific harvest and post-harvest treatment, therefore, must be related to the specific level of risk associated with the water source. In general, good sanitation procedures should be applied throughout the harvest, transport, storage, and post-harvest handling of the aquacultured fish.

Transportation of the fish from initial harvest or processing is another area of concern. Basic sanitation practices need to be applied to the transportation vehicles and containers, and temperature abuse should be minimized. It is recommended that temperature recording or indicating devises be used when transporting or even holding such products, particularly when the product is frozen and the period of transportation or holding is used to satisfy requirements directed toward controlling parasites.

Direct treatment of finfish for reduction of microbial load is practical after harvest and before processing. Again, a simple technique involves a chlorine solution rinse, preferably applied as a spray, to the round fish followed by a rinse with potable water. At one time it was prescribed that the fish be dipped in a chlorine solution (Eklund and others 1993); however, this is no longer recommended as the solution quickly became an innoculating broth unless intensively managed. Although it has been suggested that rinsing of the fish is important to reduce numbers of pathogenic microorganisms, no data on the effect of this procedure could be found in the scientific literature. The feasibility of using ozone and ultraviolet light to control microorganisms in water is also being evaluated.

In summary, efforts directed at reducing or minimizing the microbial load on fish destined for cold-smoking must be initiated as early in the production cycle as practical. GMPs and appropriate sanitation procedures should be applied throughout the process. The fish should be cooled as soon after harvest as practical and maintained at a temperature less than 40 °F (4.4 °C) until processed. The use of temperature recording or indicating devices is highly recommended. The old adage, "keep it cold, keep it clean, and keep it moving," is quite appropriate.

Crapo CA, Elliot E. 1987. Salmon quality: the effect of elevated refrigerated seawater chilling temperature. Fairbanks (AK): University of Alaska, SeaGrant College Program.

Crapo CA, Kramer DE, Doyle JP. 1986. Salmon quality: the effect of delayed chilling. Fairbanks (AK): University of Alaska, SeaGrant College Program.

Crapo CA, Paust B. 1987. Air shipment of fresh fish: a primer for shippers and cargo handlers. Fairbanks (AK): University of Alaska, SeaGrant College Program.

Eklund M, Pelroy G, Poysky F, Paranjpye R, Lashbrook L, Peterson M. 1993 July. Summary of interim guidelines for reduction and control of Listeria monocytogenes in or on smoked fish [internal report]. Seattle: Northwest Fisheries Science Center. July 1993. 14 p.

Rasco BA, Girard WA, Bledsoe GE. 2001. Frozen aquatic food products [chapter 22]. In: Smith JS, editor. Introduction to food chemistry. West Sacramento (CA): Science Technology Systems.

For scombrotoxin-susceptible fish, if internal receiving temperatures are too high or sensory evaluations indicate a problem, the product can be rejected. Records of temperature monitoring, sensory evaluations, supplier certifications, and testing results should be available for every lot. If time and temperature documentation is unavailable, the product should be rejected, appropriate documentation must be requested from the supplier, or samples must be sent to a laboratory for histamine testing. To confirm the accept-or-reject decision, samples can be collected and sent to a laboratory for quantitative analysis of histamine levels. Sensory evaluation of the product may also be conducted.

Fish for cold-smoking need to be frozen at the proper temperature for the proper length of time at some point during the process to control parasites in the final product. If the product is received frozen, this may be a control point for parasites. Records of temperature monitoring or supplier certifications should be available for every lot. If no time and temperature documentation exist, the processor should either reject the product, request documents, or certification from the supplier, or freeze product for the required time and temperature. Detailed examination of periodic samples of product at each step will assist in insuring that the control methods are effective.

3. Sorting, sizing, and salting

This is a control point to prevent Clostridium botulinum toxin formation on the final product. During brining the following parameters should be monitored appropriately to assure that the final product has sufficient salt levels to inhibit C. botulinum toxin formation (that is, 3.5% water phase salt [WPS] in thickest portion of loin if vacuum-packaged):

• The salt concentration in the brine must be adequate (a minimum brine strength or concentration is necessary). The salt concentration should be measured at the beginning of each batch prior to the addition of sugar or other substances. An alternative procedure is to establish limits for the weight of each ingredient and keep records.
• The weight or volume of fish must be within the brining capacity of the brining solution (a maximum volume or weight of fish or fish portions). The volume or weight of the brine should be measured at the beginning of each batch.
• The fish or fish portions must not exceed a pre-determined thickness (a maximum size is set).
• The maximum temperature of the brine solution must be set (brining solution is kept below a maximum temperature during the brining step).

Corrective actions should be introduced as appropriate. For example, if the brine concentration is too dilute, more salt should be added. If there is not enough brine solution for proper brining, more of the brine or brining solution should be added. If there is too much fish for the brine, some of the fish or fish portions should be removed.

All parameters should be appropriately recorded and records reviewed. Periodic calibration of scales and thermometers is needed. Additionally, periodic review of monitoring, corrective action, and calibration records is necessary.

4. Labeling

This step is not considered a control point, since it is not possible to label safety into a product. Nevertheless, label information identifying appropriate storage temperatures and time for safety is critical to control biogenic amine formation in scombrotoxin-susceptible species and C. botulinum growth, and toxin formation in cold-smoked products, especially if packaged in a reduced-oxygen environment. This label information is also important in reducing the growth rate of Listeria monocytogenes, although temperature will not prevent its growth. Visual checks of labels should be performed. Packages without proper labels specifying proper handling and storage conditions should be rejected and packages should be replaced with the proper labels.

Temperature during storage, distribution, retail, and consumer is a control point to prevent C. botulinum toxin formation, growth rate of L. monocytogenes, and biogenic amine formation in scombrotoxin-susceptible species. Temperature of the cooler should be monitored. If the product temperature exceeds 40 °F (4.4 °C), the temperature of the product should be reduced immediately and the product evaluated for safety.

The panel developed a questionnaire and sent it to over 30 companies and processing facilities producing smoked-fish products. The questionnaire was adapted from a smoked-fish survey questionnaire originally developed by Dr. Roy Martin of the National Fisheries Institute. Six completed survey forms have been returned. Based on this response, it is proper to think of this as a sampling of procedures and techniques used by the Cold-Smoked Processing Industry.

A collation of the sampling follows. The responses were as expected. The types of fish used for cold-smoking as well as the many variations in technique, brines, and smoke, are exemplified in this sampling. All of the companies responding indicated that their cold-smoked product either is or could be frozen for storage and distribution. Four of the companies had the capability to freeze their maximum daily production.

Company 1 - Herring, Mackerel, Cod, Haddock, and Pollack.

Company 2 - Salmon (Atlantic, dry brine), and Tuna

Company 3 - Salmon, Sablefish, and Tuna

Company 4 - Salmon and Sablefish

Company 5 - Salmon, Sablefish, and Halibut

Company 6 - Salmon

Company 1 - liquid Brine

Company 2 - No response

Company 3 - Dry Salt and Liquid Brine

Company 4 - Liquid Brine

Company 5 - Dry Salt and Liquid Brine

Company 6 - Dry Salt and Liquid Brine

Company 1 - Salt content of 2%

Company 2 - 50 lbs product to 10 gallons brine for wet brine.

Company 3 - 1.8 gallons of brine to lbs of fish

Company 4 - 2 to 1

Company 5 - 1 to 1 (some types of fish we do dry curing others wet curing); 2 to 1

Company 6 - 2 to 1

Company 1 - No

Company 2 - Yes

Company 3 - No

Company 4 - No

Company 5 - Yes (for cold smoke depending on specie)

Company 6 - No

5. If the answer to question #3 is yes, then please describe further.

Company 1 - No response

Company 2 - Salmon (Nova (dry brined) and Kippered,)

Company 3 -

Company 4 -

Company 5 - Salmon 1:1, Sablefish 2:1, and Halibut N/A

Company 6 - No response

Company 1 - 35-40°F

Company 2 - 55-60°F

Company 3 - 35-38°F

Company 4 - 35-40°F

Company 5 - 35-40°F Tap water temperature and Room temperature

Company 6 - Under 35°F

First 5 Companies said NO

Company 6 - Yes, it slows the osmosis process down a little bit

Company 1 - No

Companies 2, 3, 4, 5 and 6 - Yes

Companies 2, 3, 4, 5 and 6 all said Manually, such as a paddle

Company 1 - After each 4 brinings

Companies 2, 3, 4, 5 and 6 - With each batch

Company 1 - No

Company 2

Company 3

Company 4 -

Company 5 - Needles are cleaned and sanitized before and after use

Company 6 - Does not inject our Nova Products. Only our Kippered and Non-perishable products.

Companies 1, 2, 3, 4, 5 and 6 - With a Salometer

Company 2 - By adding more salt

Company 6 - By weight ratio, WPS testing on the finished product.

Brining time (hours)

Company 1 - Brine for 10-15 min depending on fish

Company 2 - 8-10, 10-12 (Salmon N) depending on size of fillets, (Tuna) 2 hrs to 2 hrs and 15 min,

Company 3 - 4-7 days in liquid brine (Salmon, Sablefish, and Tuna)

Company 4 - 24-48 (Sable) and over 48 (Salmon)

Company 5 - 14-16 (Sablefish, Salmon, and Halibut)

Company 6 - Salmon, Dry cure is 8 hours to 48 hours depending on species. Liquid cure is 18 to 24 hours.

Hanging/Drying time (hours)

Company 1 - 2-4

Company 2 - No response

Company 3 - 0-2 (Salmon, Sablefish, Tuna)

Company 4 - 0-2 (Salmon and Sablefish)

Company 5 - 8-10

Company 6 - 0-2 hours

Company 1 - Stainless Steel

Company 2 - Stainless Steel

Company 3 - Plastic

Company 4 - Stainless Steel

Company 5 - Stainless Steel

Company 6 - Plastic, 1,000 # magnum totes

Company 1 - 30-40° Salometer

Company 2 - 55° Salometer

Company 3 - 30-40° Salometer

Company 4 - 50-60° Salometer

Company 5 - 30-40° Salometer

Company 6 - 60-70° Salometer

Company 1 - All the same 30-40°

Company 2 - 55° (Tuna)

Company 3 - 30° (Salmon), 25° (Sablefish), Company 40° (Tuna)

Company 4 - 50-60° (Salmon)

Company 5 - 30-35% Salmon (and dry), 35% Sablefish, and Halibut (dry)

Company 6 - 60° Salmon

17. Please describe how you prepare your brine.

Company 1 - Mix in a tank and add fish fillets

Company 2 - Brine sinks (wet brine) water run to desired temp range - stoppered predetes volume salt added to filling sink - filled to desired level - agitated to mix salt to solution-decked with salometer - adjust if necessary.

Company 3 - Clean and sanitize plastic tub or stainless tank; add 48 gallons water; add salt to product 30° salometer brine; add sugar to produce 35° salometer brine; add NO (for salmon and sable)

Company 4 - No response

Company 5 - A saturated brine solution is mixed with water until the desired amount/conc. Of salt is achieved (measured with a salometer).

Company 6 - Take a clean plastic totes put it on a plate form scale weight out the amount of water and ingredients that are needed. After the proper amounts have been added and mixed we then check the salinity of the brine.

Company 1 - Yes (Air Temperature)

Company 2 - Yes (Air Temp. Cooler <35°F and Room 60-70°F)

Company 3 - Yes (Running Water (Temperature is usually under 60°F)

Company 4 - Yes (Water Temp. fill tank w/tap then refrigerate) and Running Water Fish not over 38°F.)

Company 5 - Yes (Water 39-40°F)

Company 6 - Yes, (Running Water: 40-60°)

Company 1 - 12-18 hours

Company 2 - Cooler air <38°F and Room temperature 60-70°F

Company 3 - Running Water: Depends upon time of year, but generally overnight (12-15 hours).

Company 4 - In water 24 hours in refrigerator then 4-6 hours in running water

Company 5 - In water, approximately 18 hours

Company 6 - In Running Water: 40°F takes 8 hours. 60° takes 4 hours (500# to 600# per tote)

Company 1 - Yes, Chlorinated water

Company 2 - Yes, Potable rinse

Company 3 - Yes, in running 50 ppm chlorinated water

Company 4 - Yes, Chlorine Dip then rinse

Company 5 - No

Company 6 - Yes, We do not wash the fish. We use only as kippered or non-perishable product.

Company 1 - Yes, Government of Canada C.F.I.A. - Q.M. P.R.

Company 2 - NO

Company 3 - Yes, New York State Code of Rules and Regulations Part 262 Fish Processing and Smoking Establishments (this is the same rule FDA has copied almost word for word).

Company 4 - NO

Company 5 - NO

Company 6 - NO

Company 1 - NO

Company 2 - Receiving specs for temperature must be = or less than 40° F. Thawing when product reaches 38°F, return to cooler.

Company 3 - Processing: Chlorinated rinse water; chlorinated hand and knife dips; dips gloves and aprons are mandatory; process schedules which specify time/temp maximums. Cleaning & Sanitizing: All equipment is cleaned and sanitized in between uses; monthly sanitizer rotation program with weekly titration monitoring; twice-weekly environmental swabbing for Listeria spp.

Company 4 - Chlorine for processing, Quarternary Ammonia for Sanitizing

Company 5 - Time /Temperature controls

Verifications of analytical results with incoming raw product

Washed/Sanitized tanks before use

Knives are place in a bucket with sanitizer

Proper use of gloves and uniform

Limit of employee traffic through departments

Wash/Sanitize room: drains, utensils, tables, walls, product contact surface areas, personal aprons.

Company 6 - We make sure there is absolutely no cross contamination from one department to another specific to utensils and equipment and employees. We also make sure there is no cross contamination from one product to another. Each department has its own color code.

Company 1 - No

Company 2 - No

Company 3 - No

Company 4 - Yes, 3

Company 5 - No

Company 6 - No response

Company 1 - No

Company 2 - No

Company 3 - Yes, 3 (1x3 cage/2x24 cage)

Company 4 - No

Company 5 - Yes, 6

Company 6 - Yes, 4 each, 1 electronic oven with microprocessor control

25. Do you attempt to control humidity in the Cold Smoking operation? Please describe how you control the humidity?

Company 1 - Yes, Dampers

Company 2 - No

Company 3 - Yes, Dampers, Blowers/Air circulation, Wet Bulb, and with moist sawdust

Company 4 - Blowers/Air Circulation, and with moist sawdust

Company 5 - No

Company 6 - Yes, Dampers, Wet Bulb, Use of Steam

Company 1 - With a regular thermometer

Company 2 - With a thermocouple & recording device

Company 3 - With a thermocouple & recording device

Company 4 - With a regular thermometer

Company 5 - With a regular thermometer and a thermocouple & recording device

Company 6 - With a regular thermometer and thermocouple & recording device.

Company 1 - No

Company 2 - Yes, Refrigeration for drying air

Company 3 - Yes, Cooling Coils

Company 4 - No

Company 5 - Yes, Automatic Oven Cooking System

Company 6 - Yes, Stainless steel tubes

Company 1 - 15 minutes

Company 2 - Within 30 minutes of loading

Company 3 - Minutes

Company 4 - Cold smoking takes 10-12 minutes

Company 5 - 2-3 minutes (76-78 degrees Fahrenheit)

Company 6 - No response

Company 1 - Sawdust Burning

Company 2 - Natural hardwood and fruit wood smoke

Company 3 - Kiln-dried commercial grade hardwood blend of maple, beech , and birch.

Company 4 - Real hardwood smoke

Company 5 - Wood Chips (hard wood, cube cut)

Company 6 - Alder and Oak

Company 1 - Temperature 20-25°C

Company 2 - We don't target internal temp for cold smoked products

Company 3 - Salmon, max time 22 hours at max temp 86°F; Sablefish, max time 6 hours at max temp 120°F (only to Sable and Seabass.); Tuna, max time 22 hours at 86°F.

Company 4 - Salmon, no target- not to exceed 90°F and Sablefish, not to exceed 120°F

Company 5 - Salmon 78°F, 7-14 hours, Sablefish 78°F, 7-11 hours, and Halibut 78°F 8-10 hours.

Company 6 - Salmon 4 hours at 60°F

31. What temperature in the Smoking chamber of the Smokehouse (external to the fish) gives you the above targeted internal temperature?

Company 1 - Temperature 20-25°C

Company 2 - < 90°F for cold smoke product (kiln temp)

Company 3 - When processing in a modern microprocessor-controlled convection oven, one need only monitor ambient air temperature inside the oven since the internal temperature of the fish cannot exceed the ambient oven temperature. This applies all species.

Company 4 - Salmon, Ambient temp with smoldering wood fire, and Sablefish, oven temp slowly increased from 100° to 140° over several hours.

Company 5 - Salmon 80°F, Sablefish 120°F, and Halibut 115°F

Company 6 - Salmon, 4 hours at 70°F

Company 1 - No

Company 2 - Yes

Company 3 - Yes

Company 4 - Yes

Company 5 - Yes

Company 6 - No

Company 1 - Chill Room at 0-2°C for 12-14 hours

Company 6 - Nova products go immediately from the smoker into our finished product cooler, which is held below 38°F.

Company 1 - Were not aware of /Do not follow either

Company 2 - New York Guidelines

Company 3 - State of New York

Company 4 - AFDO

Company 5 - AFDA

Company 6 - Were not aware/Do not follow either

35. Do you use in-plant chlorination of your water? If yes, please briefly describe where and how you use the in-plant chlorination.

Company 1 - Yes, we chlorinate well to 5 ppm

Company 2 - Yes, we chlorinate a pre-brine bath for raw fillets. Use an injection pump mixing chamber -10 ppm.

Company 3 - Yes, Microprocessor-controlled metering system that injects desired ppm liquid chlorine into water used in thawing frozen whole fish.

Company 4 - No

Company 5 - No

Company 6 - Yes, In our thawing totes for thawing frozen fish and in the wet or raw processing area of the plant as running water over cutting boards and on belts, etc.

Company 1 - No

Company 2 - Yes

Company 3 - Yes

Company 4 - Yes

Company 5 - Yes

Company 6 - Yes

Company 1 - Yes, all of our products are frozen

Company 2 - Yes

Company 3 - No, freeze to 25%

Company 4 - Yes

Company 5 - Yes

Company 6 - Yes

Company 1 - No

Company 2 - No

Company 3 - Yes, Granular NO2 is dispersed in water and added to 48 gallons of brine prior to addition of fillets. Amount added depends upon time of year: during cold months 8 oz granular NO2 is added: warm months 4 oz granular NO 2 is added.

Company 4 - Yes, Dissolved into Brine

Company 5 - Yes, Necessary amount to achieve 170 ppm in finished product 11 oz. In 850 lbs fish/850 lbs brine.

Company 6 - Yes, on some products we use wet brine with sodium nitrite.

Company 1 - No

Company 2 - No

Company 3 - Yes

Company 4 - No

Company 5 - Yes

Company 6 - Yes

Company 1 - Salt/Salometer, Sensory/Organoleptic

Company 2 - Salt/Salometer, Sensory/Organoleptic, Moisture, Water-phase salt, and Microbiology (send out to lab)

Company 3 - Salt/Salometer, Sensory/Organoleptic

Company 4 - Salt/Salometer, Sensory/Organoleptic

Company 5 - Salt/Salometer, Sensory/Organoleptic

Company 6 - Salt/Salometer, Sensory/Organoleptic, Moisture, Water-phase Salt and Microbiology.

Company 1 - Every 3 months

Company 2 - Raw product - monthly (salmon), and Environmentals - weekly

Company 3 - Minimum of twice weekly we test cold-smoked product for total aerobic plate count, coliform count, Listeria monocytogenes, water phase salt content. Minimum of 4 times yearly we test finished cold-smoked product (that contains nitrate) for ppm NO2.

Company 4 - Approximately once per quarter, Salt, Nitrate, Water phase salt, Listeria, Salmonella.

Company 5 - Once a year for each type of fish or more as needed --> wps % nitrate, histamine, TPC, C. botulinum, L. monocytogenes, mold, and yeast.

Company 6 - We are required to test, in our finished products, for WPS and residual nitrite levels 4 times a year. Any raw material that is going to be processed into a finished Nova product we do full micro screens. Also, we do full microscreens on 100% of our finished nova products and once a year on our kippered and non-perishable products.

All 6 Companies said Yes

Company 1 - No

Company 2 - No response

Company 3 - Yes, at end of the production day equipment is first cleaned with soap and scurb brushes and then washed down with hot water. Then a 150-250 ppm chlorine solutions is sprayed onto all surfaces and allowed to sit for 5 minutes. Then a 200 ppm quat solution is foamed onto the equipment and allowed to air-dry overnight. Prior to start-up the following morning, all surfaces are briefly washed down with water to reactivate the quat. A monthly rotation program is in place including an acid-based quat. Strength of quat is determined and monitored by in-house titration.

Company 4 - Yes, Machines are taken apart and cleaned and sanitized daily.

Company 5 - Yes, Scheduled cleaning and sanitizing before and after use and between species of fish. Slicing is conducted in a temperature controlled room. Proper use of uniforms and good manufacturing practices.

Company 6 - Yes. No, just our regular cleaning and sanitizing schedules before we start work and at employee breaks and lunch time. This is including any cleaning the equipment receives by the sanitation crew.

All 6 Companies said Yes

Companies 1, 2, 3, 5 and 6 said Yes

Company 4 said No

Company 1 - No

Company 2 - No response

Company 3 - Yes (see item #43 and stop asking the same questions)

Company 4 - Yes, cleaning and sanitizing

Company 5 - Yes, Equipment is inspected for proper sanitation and cleaning before use.

Company 6 - Yes, (No)

Company 1 - Yes, Shrink-Wrap

Company 3 - Pouch, Skin-Pack, and Shrink-Wrap

Companies 1 & 6 - Oxygen Impermeable

Company 2 - Oxygen Permeable, our bag manufacturer has given us an oxygen permeability rating of approximately 605 cc/m, 2-24 at 20°C, 0%.

Company 3 - Oxygen Permeable

Company 4 - No response

Company 5 - Oxygen Permeable, 3.9cc/100, S.I./24 hrs., Thickness 3+/-0.3 Mics.

Company 1 - Frozen at a temper of 18°C Cooler

Company 2 - Refrigerated trailers <38°F, Coolers < 38°F.

Company 3 - The product is distributed both frozen and refrigerated. When refrigerated the maximum storage temperature is 38°F. We ship via our own trucks, common carrier, and air.

Company 4 - Frozen

Company 5 - Refrigerated<38°F, Frozen ~0°F for extended shelf life.

Company 6 - Frozen at - 10°F

Company 1 - Yes, 100% Frozen

Company 2 - Yes, Portions of all cold-smoked product may be frozen

Company 3 - Yes (see item #49)

Company 4 - Yes

Company 5 - Yes, for distributors, retailers, etc with the appropriate thawing procedures.

Company 6 - Yes, All of our products, once vacuum sealed, are blast frozen at -40°F. Then they are labeled, boxed and then held in our finished product freezer at 0°F until they are shipped to a cold storage and held at -10°F for final distribution on a frozen carrier.

Company 1 - No response

Company 2 - Small percentage of whole fillets is paper wrapped. All product is shipped-waxed, cardboard boxes.

Company 3 - Whole sides are air-packed in bulk. Sliced product in retail sized unites are overwrapped (air-packed) styrofoam boats.

Company 4 - Poly bags inside corrugated cartons

Company 6 - Our products are labeled both on the back and front of the package along with all master cases.

Company 1 - No

Company 2 - Yes

Company 3 -Yes

Company 4 - Yes, Smoking and storing are separate. Some packing is done in the same room as processing, but not at the same time due to spare restraints.

Company 5 - Yes

Company 6 - Yes

Company 1 - Start at 18°C or colder. Product has to be "COOKED BEFORE EATING" on label.

Company 2 - Sell by dates: 21 days

Company 3 - Sell by dates

Company 4 - "Sell By" dates- Are used at customer request otherwise product is sold frozen with no date.

Company 5 - "Sell By" dates

Company 6 - "Sell by" dates, All of our products have either a small white sticker or a stamp located on the back left hand side of the package that indicates the shelf life of the product. Either saying (Use By Date) or (Sell By Date).

Company 1 - All product 18 months

Company 2 - No response

Company 3 - Salmon: Vacuum-packed 35 days at max 38°F/ air-packed 10-14 days max 38°F. Sablefish: vacuum packed 5-7 days at max 38°F/ air-packed at max 38°F/ Tuna: vacuum-packed 35 days at max 38°F/air-packed 10-14 days at max 38°F.

Company 4 - Salmon: 4 weeks, Sablefish: 2 weeks

Company 5 - 90 days (Salmon, Sablefish, and Tuna) vacuum packed

Company 6 - Salmon, 21 days no preservatives and 60 days with preservatives

Company 1 - No response

Company 2 - 21 days from thaw date.

Company 3 - Salmon: vacuum-packed 60 days; Tuna: vacuum-packed 60 days

Company 4 - Salmon: 4 weeks, Sablefish: 2 weeks

Company 5 - 90 days after thawed at retail. If distributed frozen 120 days

Company 6 - Same as above

Company 1 - 50-100,000 lbs

Company 2 - No response

Company 3 - Over 500,000 lbs.

Company 4 - 50-100,000 lbs (Salmon 80,000 lbs raw product, and Sable 1,000 lbs raw product).

Companies 5 & 6 - Over 500,000 lbs

[AFDO] Association of Food and Drug Officials. 1991 June. Cured, salted, and smoked fish establishments good manufacturing practices [model code]. [York (PA)]: Association of Food and Drug Officials. 7 p.

Corby JJ. 1991. Circular 102 Rules and regulations relating to fish processing and smoking establishments pursuant to Article 17 of the Agriculture and Markets Law. Albany, NY: New York State Department of Agriculture and Markets, Division of Food Inspection Services. Part 262 of Title 1 of the Official Compiliation of Codes, Rules, and Regulations of the state of New York.

Hypertext updated by ear 2001-MAY-18