Processing Fish for Food

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General Info

Processing fish or a fishery product for human consumption has product specific hazards and increased food safety concerns. Therefore, fish and fishery product producers have to additionally comply with 21 CFR 123. The information below has information for all processors as well as information for specific products. Links to the resources mentioned are to the right. ​

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Definitions

Fish means fresh or saltwater finfish, crustaceans, other forms of aquatic animal life (including, but not limited to, alligator, frog, aquatic turtle, jellyfish, sea cucumber, and sea urchin and the roe of such animals) other than birds or mammals, and all mollusks, where such animal life is intended for human consumption.

Fishery product means any human food product in which fish is a characterizing ingredient.

Molluscan shellfish means any edible species of fresh or frozen oysters, clams, mussels, cockle, or scallops, or edible portions of such species, except when the product consists entirely of the shucked adductor muscle.

Processing means, with respect to fish or fishery products: Handling, storing, preparing, heading, eviscerating, shucking, freezing, changing into different market forms, manufacturing, preserving, packing, labeling, dockside unloading, or holding.

Aquaculture

At minimum, raising fish requires farm registration. If processing occurs, as defined above, then a license is needed. 

Processing does not include:

  • Icing fish on the whole or packing for transport
  • Raising fish for stocking or non-food purposes

Hazard Analysis and Critical Control Point (HACCP) for Seafood

Wholesale activity involving fish and fishery products must be done in compliance with regulations such as those requiring a HACCP system to be in place.

Among those regulations is federal code provision 21 CFR 123. Training required under 21 CFR 123.10,  available via the national Association of Food and Drug Officials (AFDO), is periodically available directly from Wisconsin Department of Agriculture, Trade and Consumer Protection (DATCP) staff.

 In addition, the federal Food and Drug Administration (FDA) has developed guidance on how to develop HACCP plans. Applicable templates are also available at the Florida SeaGrant website.

Shellfish Certification

When shipping RAW molluscan Shellfish intrastate, certification in compliance with the Shellfish Model Ordinance is required.  This still includes a HACCP plan, as well as some additional requirements.  If not shipping out of Wisconsin, 21 CFR123 would apply instead.​

Catfish

Siluriform species are regulated by USDA and not covered under Seafood HACCP or 21CFR123.


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