A Conference:

May 1 6 - 1 8 , 1993

Newport, Oregon

Edited by Gilbert Sylvia,

Ann L. Shriver,

& Michael T. Morrissey

Oregon Sea Grant, Oregon State University,Administrative Services A402, Corvallis, Oregon 97331-2134

© 1994 by Oregon State University. All rights reserved.

ISBN l-881826-08-2

-

Support viPreface viiAcknowledgments ixAbbreviations xContributors xi

Report from the Office of Seafood: an Issues Update 1Thomas J. Billy

NATIONAL AND INTERNATIONAL PERSPECTIVES ON SEAFOODQUALITY

Trends In Seafood Quality Assurance 9Liz Brown and Gilbert Sylvia

Import Standards and Regulations for Seafood Sold in the EEC, andIn-Plant Quality Assurance 15

Peter Howgate

Internal Marketing of Quality and Marketing Orientation at theNational Level: Cooperation Between the Norwegian Governmentand the Industry 21

Terje E. Martinussen

Evolving International Inspection Standards and Impacts on U.S.Seafood Trade 31

Thomas J. Moreau

The Canadian Quality Management Program 35Ian Devlin

FDA Inspection Programs for Seafood 39Roger Lowell

The Use of Total Quality Product and Total Quality ManagementPrograms in Meeting New EEC Regulations 47

Christian Felter

Quality at General Mills Restaurants 62Robert Joseph

The Need for Developing Uniform Surimi Standards 64Jae Park and Michael T. Morrissey

Implementing an IS0 9000 Quality System in a European SeafoodCompany Operating Internationally 72

Sigurdur Bogason

IS0 9000-The Sealord Experience (Past Lessons and FutureVisions) 80

Robert deBeer

Quality Assurance Standards to Improve Market Opportunities forIQF Fillets and H&G Whiting 88

Ron Williams

Integrating Quality Assurance into an Industry AssociationPanel/Audience Discussion 90

Panel members: Sigurdur Bogason, Ian Devlin, Tom Libby,Terje Martinussen, Jim Ostergard, and Jay Rasmussen

SEAFOOD QUALITY ASSURANCE PROGRAMS: DESIGNIMPLEMENTATION AND MANAGERIAL STRATEGIES

Using TQM Principles to Implement HACCP 97Donald A. Corlett, Jr.

Establishing Programs to Measure Quality Assurance 104John Clemence

Quality Assurance: Internal and External OrganizationalRequirements 109

Carmine Gorga

MEASURING AND CONTROLLING SEAFOOD QUALITYHow Arctic Alaska Measures and Maintains Whiting/SeafoodQuality 117

Allen Kimball

Sensory Analysis Application to Harmonize Expert Assessors ofFish Products 120

Terriann I. Rielly and Roberta K. York

Measuring and Controlling Seafood Quality in Japan 125Etsuo Watanabe

Measuring the Quality of Seafood Products: Using Microcomputersand Statistical Process Control in the Seafood Industry 133

Gregg J. Small

Making Quality Pay: Strategies for Improving Seafood Quality onFishing Vessels 140

Jim Ostergard

QUALITY ASSURANCE: CONCEPTS IN MARKETINGMANAGEMENT

Development of Quality in the Norwegian Fish-Farming Industry-From Quality Inspection to Quality Management 145

Terje E. Martinussen

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Demand for Seafood Quality Standards and Grades: The Case ofPacific Whiting Fillets 152

Gilbert Sylvia, Michael Murphy, and Sherry Larkin

Quality Assurance: Internal and External Financing Opportunities158

Carmine Gorga

Tillamook: the Quality Tradition 164Harold Schild

The Quest for Quality: New Frontiers in Seafood Marketing 166Pat Shanahan

A number of agencies and individuals have supported research inPacific whiting fisheries aver the years. Among them are the following

USDA/CSRS--Special Research Grant Agreement 92-34 276-7140Oregon State University Agricultural Experiment StationOregon Sea GrantNational Marine Fisheries ServiceCenter for Applied Agricultural ResearchOregon Trawl CommissionOregon Department af AgricultureCaptain Barry Fisher

This book is funded by the National Oceanicand Atmospheric Administration, throughOregon Sea Grant (grant number NA89AA-D-SG108). The views expressed herein are thoseof the authors and do not necessarily reflectthe views of NOAA or any of its subagencies.

PUBLICATION CREDITSTechnical Editor: Sandy RidlingtonCover: Amy Charron

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Controlling and improving seafood quality isone of the foremost challenges confronting theworld' s seafood industries. Seafoods can beconsidered delicate and highly perishable"commodities" like other foods, but many - -plex quality issues result from conditionsunique to this industry. For example, mostseafoods aren’t raised under controlled condi-tions from a few cultivated breeds, but arehunted and captured from thousands of pub-licly managed wild stocks and species. Theseconditions complicate efforts to standardizeproduct quality, particularly in comparison t oCompeting industries that use animal hus-bandry techniques (including aquaculture).Commercially harvested seafoods are also cap-tured at long distances from processing anddistribution centers. Variability in supply andquality due to natural variation in these wildcreatures, and problems arising from publicmanagement of the resource, complicate qual-ity problems. The risk and uncertainty associ-ated with this variability often make itunprofitable to invest in the capital and hu-man resources necessary to improve productquality. Providing products that consistentlysatisfy consumer demand and enhance marketopportunities is therefore a difficult and daunting task for many sectors of the industry.

Many of the firms that process productsfrom the assemblage of codlike fish known ashakes and whitings are particularly vulnerableto these problems. Although these species arespread across every major ocean and have di-verse life histories, they share two intrinsiccharacteristics that significantly affect finalproduct quality: a relatively soft flesh and in-festation of parasites, including myxosporideanparasites. These parasites are not only un-sightly, but are often associated with high lev-els of protease enzymes. These enzymes canresult in a soft texture and contribute tobruised or mushy flesh, rapid rancidity, andreduced shelf life.

Among all species of hakes and whitings,none may be characterized by a greater combi-nation of preharvest product quality problemsthan Pacific whiting (Merluccius productus),found off the west coast of the United Statesand Canada. Until recently, poor final productquality resulted, and market prices were toolow to generate profits. Prior to 1991, the vast

majority of the stock was harvested by foreignand joint-venture vessels delivering to process-ing ships from Europe and Asia. Domestic useof whiting grew from 20,000 metric tons (mt)in 1990 to over 200,000 mt in 1991 because ofincreased prices for various product forms andan expanding west coast fishing and proces-ing fleet. Pacific whiting, with potential allow-able biological harvests of 200,000 to 500,000mt, is now considered “fully utilized.” The 1992season showed a dramatic increase in shore-based investment in processing facilities; it isestimated that 75,000 to 100,000 mt of Pacificwhiting will be processed shoreside in 1994(the remaining 140,000 mt will be processed aat sea).

This rapid transformation to domestic pro-cessing has compounded difficulties in under-standing and controlling the quality attributesthat critically affect the value of whiting prod-ucts. A better understanding of the inherentcharacteristics of Pacific whiting and how theyaffect final product quality and market devel-opment is crucial for the development of a sus-tainable, profitable industry.

Given the size of the resource and its prod-uct quality problems, a considerable amount ofprivate and public effort has been expended tounderstand biological, technical, and market-ing problems. Conferences on Pacific whitingwere held in Astoria, Oregon, in 1990 andagain in Newport in 1992. In late 1992, Oregonfishers and seafood processors joined togetherto form the Pacific Northwest Seafood Associa-tion (PNSA). One of the primary objectives ofthe association was to establish guidelines forcontrolling and improving Pacific whiting qual-ity. Association members recognized that therewere a number of organizations, seafood mar-keting associations, and government agenciesthat had established seafood quality stan-dards. They also understood that “official” pro-grams such as HACCP, IS0 9000, and TQMwere being proposed for implementation at gional, national, and international levels. Theassociation believed that it would be beneficialto learn from the individuals, firms, industrygroups, and regional or national governmentsthat had spent years wrestling with the prob-lem of managing seafood quality. The PNSAtherefore asked the organizers to plan a confer-ence that would gather U.S. and international

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experts to share their experiences and knowl-edge, in order to guide the Pacific whiting in-dustry in developing its own successful qualityassurance programs.

The conference was designed to cover arange of topics and to highlight the relation-ships between production, marketing, andquality management strategies. Topics coveredwere (1) the status and evolution of nationaland international seafood quality standards,(2) the “buyer’s” perspective on quality assur-ance, (3) seafood associations and the role ofquality standards, (4) measuring and control-ling seafood quality, (5) designing and manag-ing quality assurance programs, and (6)quality assurance as a tool in marketing man-agement programs.

As conference organizers, we were ex-tremely pleased by the quality of the speakersand their active participation in round tablediscussions as well as question and answersessions. We were also gratified to see the com-mitment to seafood quality demonstrated bymany of our colleagues, including fishers, pro-cessors, marketers, and researchers. We feltfortunate to have so many experts from re-gional, national, and international arenas whocould provide us with insights from their expe-rience and research.

One of the missions of both Oregon StateUniversity’s Coastal Oregon Experiment Sta-tion and the International Institute of Fisheries Economics and Trade is to transferinformation on managing marine resourcesand marine resource-based industries to thepublic and private sectors where it can beused. We feel that this conference and its pro-ceedings serve this purpose and provide theindustry with some unique insights into quality control and quality assurance programs forseafood.

Gilbert SylviaMarine Resource EconomistCoastal Oregon Marine Experiment StationOregon State University

Ann L. ShriverExecutive DirectorInternational Institute for Fisheries Economicand TradeOregon State University

Michael T. MorrisseyDirector of the Astoria Seafood LaboratoryCoastal Oregon Marine Experiment StationOregon State University

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Several organizations, government agencies,and individuals made significant contributionsto the success of the conference and the publi-cation of the proceedings. The Pacific North-west Seafood Association and the OregonEconomic Development Department (as part ofits Key Industries Program) were the primaryconference sponsors. We would like to thankthe other contributors, which included the In-ternational Institute of Fisheries Economicsand Trade, the National Security Bank, theOregon Coastal Zone Management Associa-tion, the Oregon Department of Agriculture,the Oregon Sea Grant Program, Oregon StateUniversity's Coastal Oregon Marine Experi-ment Station, the Oregon State UniversitySeafood Laboratory, the Oregon Trawl Com-mission, Pacificorp, and the U.S. Departmentof Agriculture.

We would especially like to thank those in-dividuals who contributed significant amountsof time and effort in support of the conference.They include Jay Rasmussen (Oregon CoastalZone Management Association), Tom Libbey(Pt. Adams Packing Co.), Mark Cooper(Midwater Trawlers Cooperative), BarryFisher (Yankee Fisheries), and Joe Easley

(Oregon Trawl Commission). A special thanksto Susan Mills and Maureen Collson (CoastalOregon Marine Experiment Station), NancyChamberlain (OSU Seafood Laboratory), andGeorgia York (Oregon Coastal Zone Manage-ment Association) for helping in conference or-ganization and overseeing the myriad detailsthat collectively make the difference betweensuccess and failure. Graduate studentsMichael Murphy, Maurice McCarthy, LizBrown, Finley Anderson, Greg Peters, andSherry Larkin did yeomen’s work transportingspeakers and editing various conference ses-sions. A round of applause from the editorsgoes out to Sandy Ridlington who edited themanuscripts and who took on the responsibil-ity of getting the proceedings to print. We alsothank Bob Malouf, Director of Oregon SeaGrant, for financial support for the publication.Finally, a heartfelt thanks to Lavern Weber,who, as Director of the Coastal Oregon MarineExperiment Station, has engendered amonghis researchers a strong sense of responsibilityfor communicating and working with thecoastal community to effectively addresscoastal concerns.

AFAQ-Association Francaise pourl’Assurance Qualite (the French QualityAssurance Association)

ANSI-American National Standards Insti-tute

AOC-Appellation d’Origine Controlee (speci-fied origin label, France)

ASMI-Alaska Seafood Marketing InstituteASP-amnesic shellfish poisonASQC-American Society for Quality ControlATP-adenosine triphosphateCAC-Codex Alimentarius CommissionCCP-critical control pointCFR-Code of Federal RegulationsCP-control pointDFO-Department of Fisheries and Oceans

(Canada)DSP-Division of Seafood Programs (OS)EC-European CommunityEEC-European Economic CommunityESOP--employee stock ownership planFAO-Food and Agriculture Organization

(UN)FD&C-Food Drug and Cosmetic Act of 1938

(U.S.)FDA-Food and Drug Administration (U.S.-

HHS)FSIS-Food Safety and Inspection Services

(USDA)FTA-Free Trade Agreement (U.S.-Canada)FWS-Fish and Wildlife Service (U.S.)GATT--General Agreement on Tariffs and

TradeGMP-good manufacturing practiceHACCP-hazard analysis and critical control

pointsHHS-Department of Health and Human

Services (U.S.)IQF-individually quick frozenISO-International Standards OrganizationMF-Ministry of Fisheries (Norway)

MOU-memorandum of understandingMSSP-Model Seafood Surveillance Program

(NOAA)NACMCF-National Advisory Committee

Microbiological Criteria for FoodsNAS-National Academy of Science (U.S.)NFFSO-Norwegian Fish Farmers’ Sales

OrganizationNFI-National Fisheries Institute (U.S.)NMFS-National Marine Fisheries Service

(U.S.)NOAA-National Oceanic and Atmospheric

Administration (U.S.)NSIP-National Seafood Inspection Program

(U.S.)OIE-Office of Epizootics-health and sani-

tary requirements for the import andexport of animals (U.S.)

OS-Office of Seafood (U.S.-FDA)PC-production capacityPO-producer organizationsPSP-paralytic shellfish poisonPUFI-packed under federal inspectionP-productionQA-quality assuranceQMP-Quality Management Program

(Canada)RAB-Registrar Accreditation BoardRNE-Reseau National d’Essais (National

Testing Network, France)SIFE-Sanitarily Inspected Fish Establish-

mentSPC-statistical process controlSTP-sodium tripolyphosphateTQM-total quality managementTRQ-Tariff Rate QuotaUN-United NationsUSDA-U.S. Department of AgricultureUSDC-U.S. Department of CommerceWHO-World Health Organization

Thomas J. BillyDirector, Office of SeafoodFood and Drug Administration1110 Vermont Avenue, N.W.Washington, D.C. 20005USA

Sigurdur BogasonDevelopment & Quality ManagerIcelandic Freezing Plant Corp.Adalstraeti 6101 ReykjavikICELAND

Liz BrownCollege of Oceanic and Atmospheric SciencesOregon State UniversityOcn. Admin. Bld., Rm 104Corvallis, OR 97331-5503USA

John ClemenceSeafood SpecialistPharmaceutical & Food Specialities10604 Forest Ave.Seattle, WA 98178USA

Donald A. Corlett, Jr.Corlett Food Consulting Service5745 Amaranth PlaceConcord, CA 94521USA

Robert deBeerQuality Systems ManagerSealord ProductsPO Box 11NelsonNEW ZEALAND

Ian DevlinChief of Facilities & Offshore InspectorDept. of Fisheries and Oceans2250 S. Boundary Rd.Burnaby British Columbia V9M 4L9CANADA

Christian FelterConsulting Agricultural and Food Engineer58 rue DroitNice FRANCE

Carmine GorgaPresident, Polisetics87 Middle StreetGloucester, MA 01930USA

Peter HowgateSeafood Processing Consultant3 Kirk Brae, CultsAberdeen AB1 98RScotland

Robert JosephDirector, Seafood ProcurementRed LobsterGeneral Mills RestaurantsPO Box 59330Orlando, FL 32859-3330USA

Alan KimballOperations DirectorArctic AlaskaPier 91, Bldg 392Box C119Seattle, WA 98119USA

Sherry LarkinDepartment of Agricultural and REsourceEconomicsOregon State UniversityBallard Hall, Rm. 322Corvallis, OR 97331-3601USA

Roger LowellDistrict DirectorUSFDAPO Box 3012Bothel, WA 98041USA

Terje E. MartinussenSenior ResearcherFiskeriforskningPO Box 2511N-9002 TromsoNORWAY

Thomas J. MoreauDirector, Inspection Services Div.National Marine Fisheries Service1 Blackburn DriveNMFS-GloucesterGloucester, MA 01930USA

Michael T. MorrisseyDirector, Astoria Seafood Lab250 36th StreetAstoria, OR 97103USA

Michael MurphyCollege of Oceanic and Atmospheric SciencesOregon State UniversityOcn. Admin . Bld. , Rm 104Corvallis, OR 97331-5503USA

Ji m OstergardPeregrinator Marine ServicesNew England Fisheries Dev.309 World Trade CenterBoston, MA 02210USA

Jae ParkFood TechnologistAstoria Seafood Lab250 36th StreetAstoria, OR 97103USA

Terriann I. ReillyFood Technologist1 Blackburn DriveNMFS-GloucesterGloucester, MA 01930USA

Pat ShanahanVice PresidentMcKnight and Company, Inc.1507 Western Ave. Suite 507Seattle, WA 98109USA

Gregg J. SmallDirector of Technical ServicesGolden Age Fisheries18 Mercer Street Suite 400Seattle, WA 98119USA

Gilbert SylviaAssistant ProfessorHatfield Marine Science CenterNewport, OR 97365USA

Etsuo WatanabeProfessorDept. of Food Science & TechnologyTokyo Univ. of FisheriesA-5-7, Kohnan, Minato-kuTokyo 108JAPAN

Ron WilliamsShore Trading Co., Inc.145 Norcross StreetRoswell, GA 30075USA

Roberta K YorkDepartment of Fisheries and OceansCentral and Arctic RegionFreshwater Institute501 University CrescentWinnipeg, Manitoba R3T 2N6CANADA

Harold SchildGeneral ManagerTillamook County Creamery Assoc.PO Box 913Tillamook, OR 97141USA

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Thomas J. BillyOffice of Seafood, Center for Food Safety and Applied Nutrition,U.S. Food and Drug Administration

GLOBAL PIC

In the United States, consumers eat about1,000 commercial species and spend about $30 billion annually on seafood. Every year theU.S. exports approximately $3 billion of itsharvest and imports approximately 200,000seafood entries from 135 countries, worthabout $5 billion.

Nutritionally, seafood contributes to ahealthful diet as a source of high-quality pro-tein, certain vitamins and minerals, and essen-tial fatty acids. Consumers have come todepend on seafood as a protein source in theirquest for low-fat, low-cholesterol diets: con-sumption has increased in the last decade toalmost 15 pounds a person. It is evident, then,that seafood is an important commodity in theU.S. diet and a significant contributor to theGNP and world trade.

OFFICE OF SEAFOODThe Food and Drug Administration’s (FDA)

Office of Seafood is a little over two years oldand in that brief period has accomplishedmuch that will serve as the springboard to im-proving and assuring the safety of seafood.

In remarks at the March 22,1993 NationalFood Policy Conference, David Kessler, Com-missioner of Food and Drugs, said that if wefood regulators are going to ensure the safetyand wholesomeness of the U.S. food supply, wecan ’t do the job the same way we were doing it25 - or- even 10 - years ago. We cannot affordto march in place.

We need to recognize that the food industryand consumption patterns have changed dra-matically. The Pacific whiting surimi industryis a good example.

FDA SEAFOOD PROGRAMIn the face of these changes in the produc-

tion and consumption of food, consumers con-tinue to ask the same two simple andlegitimate questions: “Is the food safe to eat?”and “What are you doing to make it safe?”

It is not that the public expects assurancethat food is absolutely safe. But it does expectthat a system is in place to ensure that food isas safe as we can possibly make it-a systemthat is responsive to today’s realities, today’srisks, and today’s consumer expectations.

Seafood, like many other foods, poses a widearray of potential health problems, most ofwhich never occur. Data indicate that the rateof illness from seafood is extremely low and , ona per pound consumed basis, is declining.

Some problems, however, do arise becauseof pathogenic bacteria and viruses: natural tox-ins, like domoic acid along the Oregon coast;chemical contaminants; parasites; decomposi-tion; and drug residues.

The changing conditions and increasingtechnological advances in the seafood industryare typified by the areas of aquaculture , engi-neered seafood (surimi) , and vacuum andmodified atmospheric packaging. Thesechanges and resultant demands are not uniqueto the seafood industry. The fundamental waysin how we produce, distribute, and consumefood have changed since the basic elements oftoday ’s food safety system were put in place.The Office of Seafood is in the forefrontt of FDAefforts to respond to these new issues and chal-lenges , which it sees not as obstacles, but asopportunities.

STRATEGIC PLAN FY 93-98The Office of Seafood has recognized that

conducting inspections, gathering samples,and running laboratory analyses and researchwere not sufficientt to protect the consumerfrom all potential hazards. This recognitionhas resulted in a different perspective on sea-food safety. The new perspective is reflected ina draft strategic plan that is in its final forma-tive stages and that will reflect suggestionsfrom the industry, state and local agencies, , sci-entists , and consumers. Our intention withthis plan is to create complete consumer confi-dence in all seafood.

The strategic plan set s four strategic g o a l sThey are to ensure the following:

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that seafood products are safethat seafood is wholesome and properlylabeledthat the FDA, industry, and consumershave accurate information concerningseafoodthat the infrastructure exists to accom-plish 1,2, and 3 above

We are achieving these goals, as I willshow, through specific activities and new ini-tiatives in the seafood arena.

ECONOMIC FRAUDEconomic fraud is of sufficient complexity

that it can occur even among members of theseafood industry who are most knowledgeableabout the products and trade practices. Thisproblem has been targeted as a major concernby Commissioner Kessler, who has been ap-plauded by the industry for his efforts. First,the FDA’s budget for work in this area hasbeen doubled. Second, over 1,000 letters havebeen sent to the industry warning againstoverglazing. Third, a number of actions havebeen taken against species substitution, in-cluding Pacific rockfish substituted for redsnapper, pollock for cod, oreo dory for orangeroughy, and some freshwater species for salt-water species. The FDA has been much moreactive in this area over the past two years, andit intends to continue to vigorously pursue ac-tion against these and other types of economicfraud.

SCALLOPS AND PHOSPHATESFresh sea scallops are 75 to 79 percent wa-

ter. They may lose considerable moisture aftershucking; however, this loss may be preventedby treatment with sodium tripolyphosphate(STP). There is even some indication that STPmay help preserve desirable eating charac-teristics.

However, it turns out that prolonged soak-ing of scallops in STP solutions results in thescallops' taking up excess water. And unfortu-nately, some scallop processors have been tak-ing advantage of this to enhance productweight and their profits. Selling this excesswater at the price of scallops constitutes eco-nomic fraud.

LABELING POLICYAfter some people in industry expressed

their frustration and concern to the FDA, we

responded by setting an interim labeling policyfor scallops based on water content. This policywas designed to ensure fair play within theindustry and a fair product for the consumer,

Specifically, the policy is that scallops thathave been treated with STP and have pickedup water must be labeled with the identitystatement, “X percent of water-added scallopproduct.” This labeling must be used with anyscallop with 80 to 84 percent water. In addi-tion, the statement “Processed with SodiumTripolyphosphate” or any other phosphatethat might be used must appear on the label;and the phosphate(s) and added water must bein the ingredients statement. No scallops con-taining greater than 84 percent water will beallowed on the market.

In other words, untreated scallops with 79percent water or less are to be labeled “scal-lops.” Any product with 80 to 84 percent mois-ture should be labeled as scallop product, andanything over 84 percent moisture cannot bemarketed.

This policy will remain in effect until theagency completes an evaluation of the addi-tional data recently provided by industry. Thedata concern the relationship between the nor-mal moisture content of freshly shucked scal-lops and their treatment, as well as thepossible loss of key nutrients.

PROBLEMS WITH CRAB

Blue CrabIt has been FDA policy for decades that

product labeled “crab meat,” with no qualifica-tions, must be derived from the blue crab.There have been some complaints from theblue crab industry, however, that imported,less valuable crab meat from other species isbeing substituted for blue crab and labeled as“crab meat,” with no regard for our policy andrequirements. In addition, some companiesare ignoring the U.S. Customs Service’s label-ing requirement for country of origin. We areworking closely with the U.S. Customs Serviceand other agencies on this problem. One firmhas already been prosecuted for this illegalpractice in the State of Maryland.

Dungeness CrabThe west coast has certainly had more than

its share of problems in the last few years withdomoic acid and the saxitoxins, associatedwith amnesic shellfish poison (ASP) and para-lytic shellfish poison (PSP), found in the vis-

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cera of Dungeness crab. Again, the FDA hasestablished a policy and is taking actionagainst crabs found to have 30 or more partsper million (ppm) domoic acid in the viscera; or80 or more micrograms per 100 grams saxi-toxin in the viscera. This 30 ppm is a recentrevision upward from a previous level of 20ppm, based upon new data provided to ourHealth Hazards Evaluation Board. These tox-ins also have affected the harvest of west coastrazor clams. PSP in razor clams must be below80 micrograms per 100 grams; domoic acidmust be below 20 ppm, or the beds are closedto harvest.

CONTAMINANTS

Chemical ContaminantsThe presence of chemical contaminants in

seafood-both marine and freshwater spe-cies - is often a regional issue. The FDA’s roleis to determine allowable levels for productsentering interstate commerce. Because we rec-ognize that regional concerns may not be effec-tively addressed by national controls, we havebeen working on guidance documents that lo-cal health authorities can use to issue adviso-ries or close areas to both commercial andrecreational fisheries.

Contaminant Limits for ShellfishFour of these guidance documents have

been issued for contaminants of shellfish (in-cluding molluscan and crustacean shellfish).The contaminants are arsenic, nickel, chro-mium, and cadmium. Documents for other con-taminants are under development and,following review by a subcommittee of the As-sociation of Food and Drug Officials, will beissued.

National ConferenceIn April 1993, the FDA hosted a two-day

conference in Washington, D.C., on chemicalcontaminants in seafood. The purpose was todraw together state regulatory agencies, indus-try, scientists, other federal agencies, and in-terested consumer groups to share informationon current and planned efforts to assess therisk of chemical contaminants in seafood. Par-ticipants also discussed how to manage theserisks and how to go about communicating tothe world what the risks really are. Our meet-ing was hailed as a new paradigm in risk com-munication. This meeting will go a long way inhelping us in FDA to focus our resources.

Color AdditivesWhen canthaxanthin was approved for col-

oring food directly and through chicken feed, itwas not the agency’s intent to permit its use asan additive to fish feed, although we did notexplicitly prohibit it. This ambiguity has led tosome confusion in the aquaculture industryand in the agency.

Petitions for the use of canthaxanthin andastaxanthin are in varying stages of submis-sion and review, These and other color addi-tives may be present in fish products, andregardless of whether they are added directlyor through the fish feed, or whether they are ofnatural or synthetic origins, they are artificialcolors and any labeling must state that colorhas been added.

The problem with Listeria in seafood re-mains difficult Our current policy is that if wedetect it, we take action. The focus here is withready-to-eat products such as smoked fish andsurimi that will not be cooked sufficiently bythe consumer.

As a follow-up to limited inspections of vir-tually the entire domestic seafood processingindustry completed over a year ago, we haveconducted more in-depth inspections of produc-ers of

1)2)

3)

4)

ready-to-eat productsproducts in modified atmospherepackagingproducts from scombrotoxic species,such as tuna, mahi mahi, and amber-jacksome specialty products likely to havehigh microbial loads

These inspection surveys have been a greathelp in providing us with an overview and un-derstanding of the latest industry practicesand in targeting for future activities.

Firms processing these types of products,often referred to as “high-risk” products, arenow inspected on an annual basis.

HACCP INITIATIVEI mentioned earlier that both the food indus-

try and consumption patterns have changeddrastically in the last decade. The Americanconsumer relies now on foods produced in high-tech, centralized processing facilities, shipped

over long distances, and packaged and storedin new ways. For a number of reasons, the op-portunities for food-borne illness have in-creased. The consumption of prepared foodssold ready-to-eat at retail outlets is expandingrapidly. There are more steps between the har-vest site and the kitchen table, more steps inprocessing, and greater distances of transport.As a result, there is more opportunity for foodto be contaminated. Furthermore, new patho-gens have appeared, there has been an in-crease in the incidence of industrial chemicalsand environmental contaminants, and certainhuman subpopulations are now at higher riskthan others.

Unfortunately, the FDA’s current system ofmonitoring the food supply has not kept upwith the technology. As Commissioner Kesslerhas said, our current system of food safetyregulation is piecemeal and reactive. What weneed now is a system built on preventing prob-lems. That system is HACCP.

HACCP stands for hazard analysis criticalcontrol points. It was adopted for mandatoryfederal control over the processing of low-acidcanned foods over 20 years ago and has beenan unqualified success in an industry sectorthat was fraught with problems. HACCP hasbeen endorsed by the World Health Organiza-tion, the Food and Agriculture Organization’sCodex Alimentarius, and the National Acad-emy of Sciences (NAS). The 1991 NAS report,Seafood Safety, recommended that HACCP beapplied to the seafood industry.

HACCP DEFINITIONHACCP is a system of preventive controls

by which food processors and handlers evalu-ate the kinds of hazards that could affect theirproducts, institute controls to prevent thosehazards, monitor the performance of these con-trols, and maintain records of this monitoringof routine practice. It puts industry squarelyinto the driver’s seat of preventing publichealth hazards.

Government’s role, of course, is one of verifi-cation-through inspection, examination ofrecords, sampling and analysis, if necessary-to make sure industry has done its part.

The FDA has developed a draft regulationrequiring that industry apply the kinds of con-trols that will enhance consumer confidence inseafood. The draft is currently under review byour general counsel. We hope to publish soon.

FDA/NOAA VOLUNTARY SEAFOODPROGRAM

In cooperation with the National MarineFisheries Service of the National Oceanic andAtmospheric Administration (NOAA), we havedesigned a voluntary, fee-for-service inspectionprogram, based on HACCP concepts. It mayserve as an adjunct to our already existing in-spection programs, both of which are beingtransformed to a HACCP-based approach. Wehave conducted pilots for domestic seafood processors, foreign processors, and retailers. Weare currently piloting one for food service facili -ties. Publication of the proposed regulation onthis program has been delayed pendingcompletion of my agency’s mandatory HACCPinitiative. In the meantime, NOAA is shiftingits program for processors to a HACCP-basedapproach as well.

IMPORTSWe have recently adopted a new strategy for

dealing with imported seafood. This strategyincludes

1) much closer cooperation with stateand local authorities to identifyimports that reach the retail market

2) the initiation of civil and criminalactions against consistent and fla-grant violators

3) short-term inspection surveys target-ing specific products categories

4) education of importers, brokers, andforeign processors

At the same time, we think that importersmust do a better job, they must be more re-sponsible to make sure the products they im-port meet our requirements.

Another aspect of the new import strategythat holds great promise is to give priority tothe establishment of memoranda of under-standing (MOUs) with countries that, becauseof their own inspection systems, consistentlyship acceptable products to the U.S. This phi-losophy will facilitate the entry of productsfrom countries that export safe, wholesome,properly labeled products and will permit us todirect our resources to the inspection of prod-ucts of concern from other countries.

IRRADIATION Irradiation of seafood to reduce microorgan-

isms is approved for use in 35 countries. If

4

properly used, it can give the consumer ahigher quality, as well as a safer, product. TheFDA is reviewing petitions to permit applica-tion of this technology to U.S. seafood products.

We are already receiving inquiries about thetechnology from consumers. Clearly, there is aneed for greater consumer education to achieveacceptance and understanding. Industry andgovernment must work together to preventmisuse of the technology and to promote publicunderstanding. We believe the petition processis the key.

DECOMPOSITIONDecomposition is a leading cause of com-

plaints about seafood. Besides its aesthetic ef-fects, decomposition may also be a directhealth threat; scombrotoxins are a prime ex-ample. We have been putting much effort intothis area. Analyses for decomposition in sea-food-fresh, frozen, and canned products, do-mestic and imported-have been increasedsignificantly. We’re trying to improve the con-sistency of detection of decomposition, throughboth microbiological and chemical indicators.To date, the microbiological indicators have notpanned out as well as the chemical indicators.

We are putting together a plan to set a de-fect action level for histamine in all scombroidfish, and a 1 ppm cadaverine action level formahi mahi, tuna, and other fishery products.We are also looking at the implementation of apass-fail system rather than the current three-class system for organoleptic assessment of de-composition,

RESEARCHI can’t describe the activities of the Office of

Safety without talking about our research pro-gram. The FDA’s seafood research is directedtoward understanding the nature and severityof risks in seafood and finding the means tocontrol those risks. We believe we need a solidscientific base from which to make sound regu-latory decisions, address new problems, andperform inspection activities.

Our scientists develop or evaluate the testsor methods used to determine if seafood hasbeen prepared, packed, or held underunsanitary conditions and to ensure that it isnot contaminated with filth or rendered injuri-ous to health. The scientists design these testsnot only to determine the presence of biological

and chemical contaminants in seafood, but alsoto assess what effects chemical contaminantsand toxins have on biological systems, howspecific pathogens cause disease, and whethereconomic fraud has occurred.

A recently completed inventory indicatesthat there are over 180 ongoing seafood re-search projects directly related to safety. Theyfall into three general areas:

1) biological hazards, including the naturaltoxins--algal toxins and toxins arisingfrom decomposition

2) microbiological hazards-bacteria,viruses, and parasites

3) chemical hazardsResearch is also being done in the areas of

economic fraud, exposure, consumption pat-terns, and occurrence of illness.

The FDA wants to lead the nation in coordi-nating seafood research, it also intends to workhand-in-hand with industry, other federalagencies, state and local authorities, privategroups, and the international community toensure and promote seafood safety.

The FDA is in the hazards managementbusiness. We conduct research in hazardanalysis, risk assessment, and the develop-ment of risk management strategies. All aredesigned to provide sound, up-to-date informa-tion to the industry, to educate the consumer,and to develop regulations and standards.

SEAFOOD HOTLINELast, as part of our comprehensive educa-

tional program on seafood safety, we have es-tablished a 24-hour seafood hotline to provideinformation to consumers and industry. Thehotline number is l-800-FDA-4010. In theWashington, D.C., area, the number is (202)205-4341.

Our hotline allows callers to request FDAseafood publications, listen to pre-recorded sea-food safety messages, and access other infor-mation. Between 12 noon and 4 p.m. EST,Monday through Friday, FDA consumer affairsspecialists are available to answer calls di-rectly and to return earlier calls that need per-sonal attention. Information can even be flashfaxed using this system.

In its first six months, the hotline receivedalmost 10,000 calls. Inquiries have rangedfrom purchasing, storing, and handling, tosafety, labeling, and preparation.

5

GET HOOKED ON SEAFOOD SAFETY that together we can face the challenges and

There is a lot on our plate at the Office of develop new ways of thinking, new ap-

Seafood, but with the help and cooperation of proaches, and a new dedication to food safety.

groups such as this, we have every confidence

ernationalSeafood

Liz BrownMarine Resource Management Program, Oregon State University

Gilbert Sy lv iaCoastal Oregon Marine Experiment Station

INTRODUCTIONThe issue of seafood quality is becoming in-creasingly complex. Consumers want morethan safe and wholesome food-they want con-sistent and high quality. Fishers and proces-sors must meet these changing demands andrealize that harvesting and processing usingtraditional practices or simple “rules of thumb”are inadequate to meet evolving internationalstandards for seafood quality. Every countryincorporates minimum safety standards intoimport regulations, which processors routinelymeet and generally exceed. The problem lies inknowing the level of quality beyond simple“safety” that must be met to improve profitsand create new market opportunities. Contem-porary consumers demand a level of qualitythat is costly to produce. However, dependingon the market, “excess” quality will increasecosts and decrease profits. Both exceeding andnot meeting optimal quality will lead to lowerprofits.

Seafood producers are familiar with thetechnical aspects of quality control and are ac-customed to adapting to technical problems asthey arise. Today, however, quality assurancemeans more than identifying belly burn andtearing down seams. To succeed in the highlycompetitive food protein market, the seafoodindustry must address a wide range of issuesrelated to public regulations, consumer behav-ior, and product quality. Adaptability is a nec-essary element of good management. Theobjectives of this paper are to summarize thelatest trends and issues in seafood safety andquality in the United States and internation-ally. The first sections of the paper describeU.S. programs and agency responsibilities. Theremaining sections outline international pro-grams, particularly those being developed bythe European Community (EC). The paperconcludes with a discussion of implications forthe U.S. industry.

SEAFOOD INSPECTIONAmerican seafood producers are routinely

inspected by the government for food safetyissues. Plants are also regularly visited byvarious buyers, each with individual needs andspecifications.

A prominent topic in the seafood industry iswhether inspections will become “mandatory.”This is somewhat misleading because the U.S.Food and Drug Administration (FDA) has hada mandatory inspection program for manyyears. Where confusion lies is that the inspec-tions for seafood are periodic, unlike those forbeef and poultry, which require the continuouspresence of a U.S. Department of Agriculture(USDA) inspector in the plant.

The newest plan of the FDA is to continueits periodic inspection with modifications, in-cluding the incorporation of the hazard analy-sis and critical control points (HACCP)program, as discussed below. The broad out-line for this plan was announced March 22,1993 by FDA Commissioner David Kessler.The periodic plant inspection has always in-cluded certain records and will now add aHACCP plan. HACCP training workshops areavailable through the National Marine Fisher-ies Service (NMFS) and various industrygroups. These workshops should provide ad-equate training for designing a HACCP plan,but each plan will be individually reviewed bythe FDA. The FDA plan has been drafted andis under review by the Department of Healthand Human Services (HHS). After leavingHHS, the plan will be reviewed by the Office ofManagement and Budget, then published forpublic comment. A publication date of late1993 is predicted. There will be a substantialperiod of up to a year for implementing theFDA-mandated HACCP program (Billy 1993;Lowell, personal communication).

9

HACCPHazard analysis and critical control points

is a method of proactive and preventative in-spection. The traditional system of inspectingonly the final product can be extremely waste-ful of both materials and labor. In contrast, theHACCP system is designed to identify criticalareas in the plant and monitor those pointsduring processing, which allows the qualityassurance personnel to find problems whereand when they occur. This technique has beenused successfully in many industries, notablylow-acid canning of seafood. The function of theHACCP program primarily is safety ratherthan quality (Pierson 1992).

Producing a HACCP program requires fa-miliarity with the workings of the plant andthen tailoring a plan on the basis of that infor-mation. Many agencies have their own ver-sions of HACCP checklists. For example, theUSDA uses the checklist of the National Advi-sory Committee on Microbiological Criteria forFood, and the Codex Commission has its ownlist. With slight variations, each list consists of

1. the personnel to be involved with theprocedure

2. construction of a product flow diagramfor the plant

3. the control points, potential preventa-tive measures, and establishment oftarget levels and tolerances at eachcritical control point (“critical” referringto possible consumer health hazardsresulting from loss of control at thispoint)

4. the monitoring system, documentationsystems and procedures to addressprocess deviation

5. the review systemThe FDA and the National Oceanic and At-

mospheric Administration (NOAA) have beencollaborating on developing regulations and amanual for a HACCP-based inspection pro-gram targeting (1) food safety, (2) food hygiene,and (3) economic fraud. According to Lu Canoof the FDA, this was to be accomplished by theend of 1993, but as of August the project hadbeen halted to reconsider its necessity as anaddition to the other programs (Cano, personalcommunication).

NOAA began operating a HACCP-based in-spection system in July 1992, which is a fee-for-service program. NOAA administers threetypes of inspection programs: heavy inspection,occasional inspection, and HACCP-based self-inspection. The three vary in cost. The NOAA

programs result in inspection certificationwhich, according to Thomas Moreau of NMFSTechnical Services, will be adequate for exportof product to the EC. The certificates will beavailable in nine languages to expedite expor-tation procedures (Moreau 1993).

Over the years many mandatory seafood in-spection bills have been introduced in Con-gress but have not been passed. The 1992Congress examined two bills, neither of whichmade it out of committee. No new seafood in-spection bills have been submitted to the 1993Congress., although there is a shellfish waterbill-HR1412-sponsored by Jolene Unsoeld, aDemocrat from Washington. The interest increating seafood inspection legislation hasbeen decreasing because of difficulties in devel-oping congressional consensus on (1) the choiceof agency to administer the new law, (2) pro-tection of whistle blowers, (3) a new definitionof “adulteration” in the federal Food, Drug, andCosmetic Act of 1938, and (4) the origin of thefunding.

The FDA predicts that their HACCP-basedinspection will be a sufficient program formeeting safety and export needs. The FDA be-lieves that the program will require minimaladditional effort from industry and incur noextra cost to the FDA.

UNITED STATES AGENCIESThere are three U.S. Executive Branch cabi-

net posts directly responsible for dealing withcontaminants in seafood: the Department ofHealth and Human Services, which houses theFDA, the Department of Commerce, withinwhich NOAA administers NMFS; and the De-partment of the Interior, which contains theFish and Wildlife Service.

FDA-Office of SeafoodThe U.S. FDA administers the Food, Drug,

and Cosmetic Act through the use of randominspections.

In February 1991, David Kessler createdthe first product-specific office in the FDA: theOffice of Seafood (OS), contained in the FDA’sCenter for Food Safety and Applied Nutrition.The OS attempts to address the most seriousproblems associated with seafood consumption,which it defines as water quality, exports, im-ports, retail, and consumer concerns. The OScomprises two divisions:

1. The Division of Seafood Research, whichplans and conducts research on (a) seafoodharvesting and processing and (b) storage and

distribution of wild and farmed sources thatmay be affected by chemical and biological con-tamination.

2. The Division of Seafood Programs, whichis responsible for agency policies, planning andcoordinating all seafood inspection, and en-forcement. The Division of Seafood Protectionis further broken down into (a) policy guidance,(b) program and enforcement, and (c) shellfishsanitation.

The current strategy of the FDA is to be-come more effective by aiming for prevention.However, there are two problems with thismore aggressive strategy: the difficulty of iden-tifying future problems and the tendency toundertake a wider scope of responsibility thanwas originally intended - for example, themonitoring for ocean contaminants that couldaffect seafood safety. The FDA justifies thisbroadening of responsibility as necessary forthe protection of consumers against the pro-duction and trade of adulterated goods. TheFDA uses several methods of protection:

1.2.

3.4.

5.

6.

creating minimum tolerance levelsmonitoring water quality in shellfishharvest areasdeveloping simple field tests for toxinscompiling data from other organiza-tions on chemical contaminantsanalyzing species susceptibility topesticides and chemicalsrequiring the incorporation of aHACCP program for seafood processingplants

NOAA-NMFSThe National Oceanic and Atmospheric Ad-

ministration is a branch of the U.S. Depart-ment of Commerce. The National MarineFisheries Service, under the directorship ofNOAA, offers several fee-for-service inspectionprograms. These inspections may be used tosupplement the FDA-required inspection ei-ther when buyers require an independentgrading system or when an inspection isneeded sooner than the regularly scheduledFDA inspection.

There are several different auditing fre-quencies that lead to different approval marks.“U.S. grade A,,” required by some buyers, isachieved through a heavy inspection system.“Packed Under Federal Inspection” (PUFI) isthe general NOAA inspection mark. “Sani-tarily Inspected Fish Establishment” (SIFE)

inspection focuses only on plant sanitation andincludes no product qualifications. “Lot In-spected” is an inspection of samples of entirelots.

NMFS has written Model Seafood Surveil-lance Programs (MSSP) for various seafoodbusinesses. MSSP is a guideline for building aHACCP program. MSSP subjects covered areaquaculture, breaded and specialty items, foodservice/consumers, imported products, plan ofoperations, raw fish, retail, smoked and curedproducts, and wholesale distributors.

In July 1992 the U.S. Department of Com-merce announced the incorporation of HACCPinto its inspection program. Completing aHACCP workshop is mandatory by at least oneemployee in a company wishing to use theNMFS inspection service. Training is providedthrough NOAA workshops and several indus-try groups. Along with the inspection services,NMFS is working on joint training betweenthe FDA and the Department of Fisheries andOceans of Canada, in a move to harmonizetrade between Canada and the U.S.

U.S. Department of Agriculture - FSISThe USDA oversees other protein foods be-

sides seafood through the Food Safety and In-spection Service (FSIS), which uses acomprehensive continuous inspection programin all meat and poultry plants.

The National Fisheries Institute (NFI) pref-erence for administrator of a continuous sea-food inspection is the FSIS (Richard Gutting,personal communication). At the suggestion ofthe National Academy of Science, the currentcontinuous inspection in the meat and poultryindustries would be changed to a HACCP ran-dom inspection program that would free upsome of the program’s labor to include seafood.The reason the NFI prefers the USDA is thatthe cooperative international inspections arealready in place for meat and poultry importa-tion. However, this preference may be recon-sidered in light of the recent E. coli outbreaksin the Western United States.

The United States, along with Guam,Puerto Rico, and the Virgin Islands, falls underthe jurisdiction of the Code of Federal Regula-tions Part 21 when dealing with the transpor-tation and inspection of seafood and CFR 50when dealing with fishery products. Manystates have additional regulations, tailored toregional production, that are slightly more re-strictive than the Federal regulations.

11

With increasing international trade in sea-food and other goods, the need for uniformityamong quality systems has also increased.This need has been addressed by the Interna-tional Organization for Standardization (ISO),Geneva, with the creation of the IS0 9000 se-ries of standards. The object of IS0 is to "pro-mote the development of standardization andrelated world activities with a view to facilitat-ing international exchange of goods and ser-vices and to developing cooperation in thesphere of intellectual, scientific, technologicaland economic activity” (ANSI/ASQC, 1990).

In the United States, certification isachieved through an audit by a third party ap-proved by the Registrar Accreditation Board(RAB). RAB is an affiliate of the American SO-ciety for Quality Control, and the registrar pro-gram is part of the American NationalStandards Institute’s (ANSI) accreditation pro-gram. ANSI is the U.S. member to the ISO. Acurrent list of third-party auditors can be ob-tained from

Registrar Accreditation Board6 11 E. Wisconsin Ave.P.O. Box 3005Milwaukee, WI 53201-3005(414) 272-8575fax (414) 765-8661

The IS0 standards are not specific to anyone industry or process but are broadly definedto encompass all areas. The five standards are

9000: Selection of the right standard9001: Product development, production,

delivery, and follow-up9002: Production and delivery9003: Final inspections and testing9004: Guidelines

Seafood processing is covered under IS0 9002or 9001, depending on the function of the corn--pany If carried out as planned, the standard-ization should help international trade. Theresponsibility for guaranteeing quality isshifted from the buyer to the producer. How-ever, the certification process may be expen-sive and difficult to standardize (Chynowethand Mullin 1992).

ISO registration may prove unnecessary toAmerican seafood companies. If a company al-ready has a comfortable trade relationship, itsEuropean buyer may be willing to continue tosend over inspectors to be sure of the existenceof a competent program instead of requiringISO certification. Both the FDA and MFS

inspection programs result in certificates suit-able to existing EC needs. The consolidation ofthe EC and evolving standards may changefuture needs and requirements. If the stan-dards address only microbial safety, then theU.S. HACCP as it is now constituted will meetEC requirements. If, however, the EC require-ments extend to price and general quality,then U.S. HACCP programs may be inad-equate to meet European standards.

EUROPEAN COMMUNITYThe new, unified European Community has

shifted its inspection focus to the point of ori-gin, a strategy which reinforces the value ofprograms such as ISO 9000. The regulationsare published in the Official Journal of the Eu-ropean Communities, volume 34, September24, 1991. EC Directive 91/493 sets standardsfor both European and foreign producers. Thequality assurance requirements of the directiveare listed in article 6 and incorporate HACCPprinciples.

The purpose of the EC is to form an eco-nomically powerful union of its 12 membercountries: Belgium, Britain, Denmark, France,Germany, Greece, Ireland, Italy, Luxembourg,Netherlands, Portugal, and Spain. From a tar-iff perspective, the EC is also a customs union.A common tariff is applied on imports to theEC, and all products are free of duty within the12 member nations.

The following directives in the Official Jour-nal pertain to seafood:

91/67, of 28 January 1991, concerningthe animal health conditions governingthe placing on the market of aquacul-ture animals and products91/492, of 15 July 1991, laying downthe health conditions for the productionand the placing on the market of livebivalve mollusks91/493, of 22 July 1991, laying downthe health conditions for the productionand the placing on the market offishery products91/2587, of 26 July 1991, chapter 3,amending 87/2658 on the tariff andstatistical nomenclature and on theCommon Customs Tariff91/3865, of 16 December 1991, fixingthe reference prices for fishery productsfor the 1992 fishing year

Directive 91/493 concerns imports of seafoodinto the EC, but, as EC fisheries consultant,Peter Howgate puts it, “[It’s] no big deal for the

United States” in terms of microbiologicalsafety. The directive does not require any ac-tion that exceeds HACCP requirements. Thepurpose of the directive is to define how fisheryproducts will be regulated in the EC based onequivalency of quality standards and control.The directive places more emphasis on controlduring processing than on final inspections.Although HACCP is not specifically men-tioned, the four steps on which the directive isbased are consistent with HACCP concepts:identification and monitoring of critical points,keeping records, and sampling. The sampleanalysis must be performed by a competentauthority. (“Competent authority” is a nebu-lous term that will be more completely definedin the upcoming annexes [Howgate 1993]).

The EC is protective in its stance towardsits agricultural industry. “The U.S. proposedduring the Uruguay round of the GeneralAgreement on Tariffs and Trade (GATT) azero-for-zero measure where the U.S. wouldremove all tariffs on certain goods in exchangefor reciprocal action on the part of other na-tions. Seafood is included in this zero-for-zeroproposal. This rather strong proposal has beenmet with resistance on the part of many GATTmembers, particularly the EC, and prospectsfor its adoption appear slim. The outcome ofthe Uruguay round is unclear” (AIPCEE 1992).

CODEX ALIMENTARIUSInternational guidelines for seafood safety

essentially lie under the auspices of the UnitedNations, whose Codex Alimentarius (FoodCode) sets international standards for mini-mum safety. In practice, major importing coun-tries have their own standards, which exceedCodex standards.

The Codex Alimentarius is a joint project ofthe Food and Agriculture Organization (FAO)and the World Health Organization (WHO). Itis the compilation of all the standards, codes ofpractice, guidelines, and recommendations ofvarious world governments by the CodexAlimentarius Commission (CAC). The CAC isa subsidiary body of the FAO and WHO and isfunded by these two groups and open to all oftheir members.

The purpose of Codex is to facilitate theworld trade in food by means of internationalstandards incorporating the goals of fair tradeand consumer protection. Codex balances theremoval of trade barriers with an emphasis onthe ethical aspects of food supply. The stan-dards imposed by Codex address safety assur-ance and are generally exceeded by U.S.

products. The Codex Commission meets everytwo years to consider revision of standards.Some current concerns are codes of practice forsurimi, addition of sensory techniques to otherevaluation practices, and questions aboutaquaculture. NMFS represents the U.S.; theFDA is the alternate delegate.

CONCLUSION

The goal of the NFI is to increase U.S. sea-food consumption to 20 pounds per person bythe year 2000. To realize even a portion of thisobjective, the seafood industry will need to de-velop seafood programs that are part of greaterefforts to promote seafood consumption. It cur-rently appears that HACCP programs will bemandated for each U.S. processing plant aswell as some vessels. Although such programsare ostensibly designed for controlling micro-biological contamination of seafood, their de-velopment has much broader use andimplications: a program and managementstructure for controlling other aspects of sea-food safety and quality; an important promo-tional device for assuring the public of seafoodsafety; and a way to meet evolving interna-tional standards for seafood safety and quality.

While HACCP-based seafood programs havebeen traditionally designed to cost effectivelyreduce seafood contamination, the structure ofthe programs may be flexible enough to accom-modate future firm and industry needs. Evolv-ing European standards may require programsthat assure seafood quality and integrity be-yond microbiological contamination. It is rec-ommended that as the US. seafood industryadopts HACCP, it consider how this programwill fit within a longer-term commitment toseafood quality control. The general design ofHACCP may prove to be a flexible and eco-nomically effective structure for incorporatingother quality control objectives and programs.

REFERENCESAIPCEE (Association des Industries du

Poisson de la Ce). 1992. Whitefish study1992. EC Fish Processors Association.Brussels, September 1992.

ANSI/ASQC Committee on Quality Assurance.1990. Answers to the most frequently askedquestions about the ISO 9000 series. ASQCpamphlet.

Billy, Thomas J. 1993. Report from the office ofseafood proceedings. In Quality control andquality assurance for seafood. A conference:May 16-18,1993, Newport, Oregon, Gilbert

13

Sylvia, Ann L. Shriver, and Michael T.Morrissey, eds. Oregon Sea Grant,Corvallis, Oregon.

Cano, Lu. August 1993. Personal Communica-tion.

Chynoweth, Emma and Mullin, Rick. 1992.IS0 9000: Providing the basis for qualitychemical week, April 29, 1992, p 30-31

Gutting, Richard. November 1992. Personalcommunication.

Howgate, Peter. 1993. Import standards andregulations for seafood sold in the EEC, andin-plant quality assurance. In Qualitycontrol and quality assurance for seafood. Aconference: May 16-l8,1993, Newport,Oregon, Gilbert Sylvia, Ann L. Shriver and

Michael T. Morrissey, eds. Oregon SeaGrant, Corvallis, Oregon.

Lowell, Roger. May 1993. Personal communi-cation.

Moreau, Thomas. 1993. Evolving internationalinspection standards and impacts on U.S.Seafood trade. In Quality control andquality assurance for seafood. A conference:May 16 -18, 1993, Newport, Oregon, GilbertSylvia, Ann L. Shriver, and Michael T.Morrissey, eds. Oregon Sea Grant,Corvallis, Oregon.

Pierson, Merle D. 1992. HACCP: Principlesand applications. New York: Van NostrandReinhold.

14

Peter HowgateAberdeen, United Kingdom

INTRODUCTIONThe single European market came into effectJanuary 1, 1993. In preparation for this event,a wealth of legislation over many fields of ac-tivity had to be harmonized to become EC leg-islation. Food laws were included in thisharmonization program with the aim thatmember states could have confidence in thesafety of foods produced anywhere within theEC. In principle, and ultimately in practice,foods produced in any member state can betraded throughout the Community withoutany hygiene and safety checks at borders, al-though there will be a brief period while mem-ber states introduce national legislation whensome foods might still be subject to checks. Theharmonized regulations also impose a singleset of criteria for the entry of imported prod-ucts, and once a food product has entered acountry within the EC, it can be distributedwithout further checks at internal borders.

Broad classes of food commodities are thesubject of separate legislation, and two direc-tives apply to fishery products. They are thecouncil directive of 22 July 1991, laying downthe health conditions for producing and mar-keting fishery products (91/493/EEC), and thecouncil directive of 15 July 1991, laying downthe health conditions for producing and mar-keting live bivalve molluscs (91/492/EEC)(Council of the European Community 1991a &b). As only a very small amount of live bivalvemolluscs enters international trade, this articlewill not discuss the latter directive. Commu-nity law requires that member states enact na-tional legislation to put into effect therequirements of a council directive.

Harmonizing food laws within the Commu-nity has also formalized a shift in approachesto ensuring the safety and quality of foods.There will be less reliance on inspecting prod-ucts; rather, the basic principle is that thesafety of food should be assured by control andinspection primarily at the point of production.This is in accord with current thinking on

quality assurance and inspection of food prod-ucts. The directive also establishes in legisla-tion the principle of “equivalency” with regardto imported fishery products-products im-ported into the Community must be producedunder conditions equivalent to those applicablein the Community and subjected to equivalentcontrols. The directive, then, is worth studyingby anyone interested in quality assurance andinspection of fishery products because it laysdown a framework of principle and practice forregulating safety and quality of fishery prod-ucts.

PROVISIONS OF THE DIRECTIVE

GeneralQuotations in this paper are from the En-

glish edition, but versions are available in theother official languages of the Community.

The July 22, 199l directive consists of threeparts: a preamble of 2 pages, which states thereasons for the directive and its principles; 5pages of provisions of the directive, which de-fine the legislation; and 13 pages of a technicalannex laying down conditions for handling,processing, and storing fishery products.

Some DefinitionsArticle 2 of chapter I, General Provisions,

defines terms used in the directive. Some, like“chilling,” are general technological terms andhave no special meaning in the context of thedirective, but some terms are worth pickingout for their importance in the application ofthe directive.

Fishery products--all seawater or freshwa-ter animals or parts thereof, including theirroes, excluding aquatic mammals, frogs,and aquatic animals covered by otherCommunity acts.Competent authority-the central authorityof a member state competent to carry outveterinary checks, or any authority to which

it has delegated that competence. (Note: itis common in many European countries formeat foods and premises where meat foodsare handled and stored to be controlled bypersons with veterinary qualifications.Hence the reference to “veterinary” checks.)Establishment - any premises where fisheryproducts are prepared, processed, chilled,frozen, packaged, or stored. Auction andwholesale markets in which only displayand sale by wholesale takes place are notdeemed to be establishments.Placing on the market-holding or display-ing for sale, offering for sale, selling, deliv-ering, or any other form of placing on themarket in the Community, excluding retailsales and direct transfers on local marketsof small quantities by fishermen to retailersor customers, which must be subject to thehealth check laid down by national rules forchecking the retail trade.Factory vessel-any vessel on which fisheryproducts undergo one or more of the follow-ing operations followed by packaging:filleting, slicing, skinning, mincing, freez-ing, or processing. The following are notdeemed to be factory vessels:l fishing vessels in which only shrimps

and molluscs are cooked on boardl fishing vessels on board which only

freezing is carried out

The Competent AuthorityThe directive places certain responsibilities

on the “competent authority” defined above.This is in effect the inspection agency in thecountry, but how it is organized for fisheryproducts differs among member states. Onlyone country, Denmark, has a dedicated fishinspection service. In other states the require-ments of the directive will be enforced by thenational or local government body responsiblefor the safety of foods generally, or more spe-cifically, meat foods. In the United Kingdom,food laws are enforced by environmentalhealth officers employed by local government.

Approval of EstablishmentsA central requirement of the directive is

that fish placed on the market must have beenhandled, processed, packed, and stored in ap-proved establishments. An approved establish-ment must meet the technical requirementsfor construction, equipment, and operationspecified in the annex to the directive. An

approved establishment is given a registrationnumber, and the competent authority mustsubmit a list of approved establishments to thecommission. Only products from approved andregistered premises may be marketed.

The competent authority is also required to“register” auction and wholesale markets,which must comply with the appropriate stan-dards specified in the annex to the directive.

Monitoring by the CommissionThe directive allows for monitoring of appli-

cation of the directive by “experts” from thecommission. These experts will be employed bythe commission and will have the power tomake on-the-spot checks to verify that estab-lishments are complying with the provisions ofthe directive. For this purpose, the commissionwill recruit a small force of inspectors.

APPLICATION TO EXPORTINGCOUNTRIES

Though the primary objective of the direc-tive is to harmonize practices within the Com-munity, it is a principle of the directive that itsprovisions should apply equally to importsfrom "third countries" and that there should bea common import control system applied by allmember states of the Community. Article 10 ofthe directive is quite clear:

Provisions applied to imports of fisheryproducts from third countries shall beequivalent to those governing the placing onthe market of Community products.What this means is that the EC requires

fishery products intended for export to theCommunity to be processed under conditionsequivalent to those prevailing in the Commu-nity and to have been subjected to inspectionand control equivalent to that applied in theCommunity. This principle of equivalence isbeing applied to imports by other countries im-porting fishery products, particularly by au-thorities in the U.S. and Canada.

Before the introduction of the single market,each member state controlled the safety of im-ported fishery products according to the legis-lation in force in that state. Fishery productsimported into a country, or for that matter,produced in a country, could be further in-spected when they crossed a border. Controlwas exercised by sampling and inspecting asample from a consignment. The directive nowestablishes a completely different principle - control will be at the point of production, and

though inspectors at the ports of entry of im-ports still have the right to inspect consign-ments, such action is expected to be theexception. Clearly this approach will work onlyif there is effective control over the safety ofproducts during production and effective moni-toring by the competent authority.

In order to apply the principle of equiva-lency, the commission reserves the right tocarry out inspections of the situation concern-ing hygiene and inspection in the exportingcountry by experts from the commission andthe member states. Article 11, section 2 states

In order to allow the import conditions to befixed, and in order to verify the conditions ofproduction, storage and dispatch of fisheryproducts for consignment to the Commu-nity, inspections may be carried out on thespot by experts from the Commission andthe member states.

ter. Most of the fishery products, by weight,entering the Community come from countrieswith effective fish inspection services in place,and I do not imagine the change to the newsystem will present any problems in thesecases. However, the Community imports fish-ery products from around 140 countries, andsome, perhaps many, of these do not have atpresent fish inspection services that will meetthe standards required by the commission. Thedirective requires that establishments desiringto export to the Community must be approvedand registered by the competent authority andthe competent authority must submit a list ofapproved establishments to the commission.Consignments not bearing an approval num-ber, or a number not on the list submitted tothe commission, will not be permitted entryinto the Community. There is provision for di-rect approval of establishments in exportingcountries by commission experts if the commis-sion, on the basis of an inspection by its inspec-tors, is not satisfied with the effectiveness ofthe competent authority and its inspectionservices.

The commission’s own team of inspectors isexpected to be in place in mid-1993, but clearlyit will be some time before it can consider orsurvey the situation in all countries exportingto the Community. In the meantime it is up toeach member state to ensure the safety of fish-ery products entering that country.

The experts will be appointed by, and work-ing for, the commission, and the commissionwill bear all costs of the inspection.

Though the commission reserves the rightto carry out inspections in the exporting coun-try, this does not necessarily mean it will do so.Each country will be considered of itself, andspecific import conditions will be fixed, depend-ing on what the directive refers to as the hy-giene situation in that country. When fixingthese import conditions, the commission willtake into account the situation with regard tothe existence and competence of an inspectionservice and the hygiene standards prevailing

PRODUCT STANDARDS

in the industry. The thrust of the directive is control over

When fixing the import conditions of fisherythe safety of fishery products by control over

products referred to in paragraph 1, par-conditions for processing, storage, and distribu-

ticular account shall be taken of:tion, not by control of the quality of end prod-

(a) the legislation of the third country;ucts. The directive, though, does have some

(b) the organization of the competentrequirements for testing products.

authority of the third country and of itsinspection services, the powers of suchservices, and the supervision to whichthey are subject, as well as theirfacilities for effectively verifying theimplementation of their legislation inforce

Freshness

The annual per capita consumption of fishand fish products in the Community is around20 kg, live weight equivalents (FAO 1990),ranging from a low of 9 kg in the Netherlandsto a high of 50 kg in Portugal. As about halfthe fish products consumed within the Com-munity are imported, control over productionin exporting countries will not be a trivial mat-

Fitness for human consumption is tested bysensory evaluation for freshness There is aseparate council regulation, 103/76, which re-quires that fish must be inspected at first sale,essentially when landed, and classified intogrades of freshness and size (Howgate 1987).Three grades of freshness, E, A, and B, are de-fined by sensory attributes for fish consideredsuitable for human consumption, and fishwhich is not fresh enough to be classified intoone of these grades is deemed unfit for con-sumption. The directive under discussion hererefers back to this regulation and further al-lows for products to be checked at any point in

17

the processing, storage, and distribution chainfor compliance with the minimum freshnessstandards defined in the regulation.

The sensory evaluation for freshness may besupplemented by chemical or microbiologicaltests Total volatile basic nitrogen andtrimethylamine are included as tests for fresh-ness, though limits have not yet been set.

HistamineThe directive specifies a sampling scheme

and limits for histamine that can be applied tofish of the Scombridae or Clupeidae families. Asample of nine units are taken and analyzedindividually. The following criteria arespecified:

.

.

.

the mean value must not exceed 100ppmtwo samples may have a value of morethan 100 ppm but less than 200 ppmno sample may have a value exceeding200 ppm

ContaminantsThe directive requires that “fishery products

must not contain in their edible parts contami-nants, such as heavy metals and organochlo-rines, present in the aquatic environment atsuch a level that the calculated dietary intakeexceeds the acceptable daily or weekly intakefor humans.” This principle has still to betranslated into concentration limits.

Microbiological CriteriaThe commission may lay down microbiologi-

cal criteria for products, including samplingplans and methods of analysis, where there isa need to protect public health. One set of cri-teria, for cooked crustaceans and molluscs, hasbeen issued (Commission of the EuropeanCommunities 1992).

THE ANNEXThe annex contains the detailed conditions

and requirements for handling, processing,storing, and dispatching fishery products fromlanding at ports to packaging and transport.

The separate chapters and sections includethe following:

Conditions applicable to factory vesselsRequirements during and after landingGeneral conditions for establishments onland

General conditions relating to premisesand equipmentGeneral conditions of hygiene

Premises and equipmentStaff

Special conditions for handling fisheryproducts on shore

Conditions for fresh productsConditions for frozen productsConditions for thawing productsConditions for processed products

CanningSmokingSaltingCooked crustacean and molluscanshellfish productsMechanically recovered fish flesh

Conditions concerning parasitesHealth control and monitoring of productionconditionsPackagingIdentification marksStorage and transportThe various chapters are written as brief

codes of practice for the operation under con-sideration, and any factory vessel, market, orestablishment that is already operating to goodmanufacturing practices will meet the require-ments of the annex.

IN-PLANT QUALITY ASSURANCE ANDHACCP

An approved establishment must meet therequirements specified in the general provi-sions of the directive which, in article 6, explic-itly lays a responsibility on “personsresponsible for establishments” to have effec-tive quality assurance systems in place in theplant.

Member states shall ensure that personsresponsible for establishments take all neces-sary measures, so that, at all stages of the pro-duction of fishery products, the specificationsof this directive are complied with.

To that end, the said persons responsiblemust carry out their own checks based on thefollowing principles:

.

.

.

identification of critical points in theirestablishment on the basis of themanufacturing processes used;establishment and implementation ofmethods for monitoring and checkingsuch critical points;taking samples for analysis in a

laboratory approved by the competent

authority for the purpose of checkingcleaning and disinfection methods andfor the purpose of checking compliancewith the standards established by thedirective;

0 keeping a written record or a recordregistered in an indelible fashion of thepreceding points with a view to submit-ting them to the competent authority.The results of the different checks andtests will in particular be kept for aperiod of at least two years.

All this reads very much like the principlesof hazard analysis and critical control points(HACCP) (ICMSF 1988), but HACCP is notreferred to as such in the directive.

Throughout the food industry in general inEurope, including the fish processing industry,there is an increasing use of the HACCP ap-proach for controlling microbiological hazardsof foods. Generally seafoods are not commonsources of food poisoning, and where they areimplicated, most outbreaks are associated withbacteria, viruses, or toxins present in the foodwhen caught or harvested. Examples are vari-ous forms of food poisoning from bivalve shell-fish throughout the world and ciguaterapoisoning in some countries (Ahmed 1991;Bryan 1987; Gibson 1992). The EEC directiveon marketing of live bivalves controls the in-trinsic safety of bivalve mollusc, and the direc-tive on fish products forbids the marketing offish from specified families (Tetraodontidae,Molidae, Diodontidae, Canthigasteridae),which are associated with intrinsic toxins, andproducts containing ciguatera toxin. Food poi-soning resulting from contamination of fishproducts during processing or from poor han-dling and storage practices are quite rare, themost common being scombrotoxin poisoning.Criteria for histamine content referred to ear-lier are intended to control this hazard.

There have been considerable changes inthe marketing of fish in Britain over the lastcouple of decades, changes which have had amajor impact on quality assurance practices inthe processing industry. The number of fish-monger shops and similar specialist outlets forfish has declined over this period, and morefish is being sold through multiple retail out-lets-supermarkets and similar stores. Theseoutlets are now responsible for about two-thirds of retails sales of frozen fish and aboutone-third of retail sales of “wet” fish in Britain.Of the wet fish, about half are sold at fishcounters and half as prepacked products. Salesof ready-to-eat fish products and of “recipe”

dishes, that is, complete meals incorporatingfish, are increasing markedly. Multiple retail-ers set high standards for both the safety andthe consumer acceptability of the products theymarket, and as they have considerable buyingpower and consequently an ability to dictateconditions, they have had a significant impacton improving quality assurance practices inthe fish-processing industry. In addition, tradeassociations, like the Sea Fish Industry Asso-ciation, the Scottish Salmon Growers Associa-tion, and the Shetland Seafood QualityCompany, set standards for products or guide-lines for the manufacture of products marketedby their members.

There is a general worldwide shortage offish. Natural stocks throughout the world arefully exploited, if not overexploited, and thoughfarmed products are making an increasing con-tribution to supplies, they are still only a smallproportion of the total. At the same time de-mand for seafood is increasing. Fish is recog-nized as being a nutritious food, and, if of goodquality, very pleasant to eat. As a result of re-stricted supplies and increasing demand, theprice of fish has increased over the years morethan that of other meat foods. Some species offish, particularly shellfish, have long been con-sidered luxury foods, but there is a tendencynow for almost all varieties of fish to be consid-ered expensive foodstuffs. Naturally, the con-sumer is expecting high quality for ahigh-priced product.

Regulatory authorities have been tighteningup their control over the safety of foods, includ-ing fish products. I think it has to be acceptedthat fish processing has not led the field instandards of hygiene and sanitation, but thetightened regulations of the last few years areimproving the situation. Certainly the EC di-rective on hygiene in fish processing has mark-edly changed attitudes in the fish processingindustry in Britain. It might not be possible toget an exact figure for Britain or the EC, but inAberdeen alone some tens of millions of poundshas been spent on new or refurbished process-ing plants to meet the requirements of the di-rective.

These pressures, from the marketers of fishproducts, from consumers, and from regulatoryauthorities, have resulted in a marked im-provement in the quality of fish available tothe consumer at all types of outlets and in amarked improvement in quality assurancepractices in the industry. Control over hygieneand safety is accepted as a basic and essentialrequirement in fish processing, but consumer

19

satisfaction and at least maintenance of, if notincreasing, market share in a competitive envi-ronment are seen as important objectives ofquality assurance. Fish processors, certainlythose selling under their own brand names orsupplying the multiple retailers, view the pro-visions of the EC directive for hygiene, sanita-tion, and product quality as minimumrequirements and in practice will work tohigher standards. For example, the minimumfreshness standard required in the directive,equivalent to around 15 days in ice for typicaldemersal species like cod, would not be accept-able to a processor with any pretensions to-wards supplying good quality products. Thespecifications for freshness typically imposedby multiples or by secondary processors for ei-ther prepacked wet fish or frozen products areequivalent to about five days in ice. Prepackedwet fish of this quality, in air, MAP, or vacuumpack, would be date stamped with a three-daystorage life from the time of packing.

HACCP methodology is adopted as part of atotal quality management (TQM) system(Shaw 1992) in a company. TQM is seen as themeans of achieving consumer satisfactionthrough consistently high quality and safety.TQM can be seen as an extended HACCP ap-proach. The same principles of defining haz-ards and identifying and monitoring criticalpoints are adopted, but a hazard is any circum-stance that could affect any aspect of the qual-ity of the product, induding safety.

Many food-processing companies in Britain,including those manufacturing fish products,use BS 5750, part 2 (British Standards Institu-tion 1987, identical to ISO 9002-1987 and EN29002-1987), as a model for their quality as-surance systems, even if they do not seekaccreditation as complying. It must be remem-bored that meeting the provisions of ISO 9002is no guarantee that the product is of goodquality, only that the quality assurance sys-tems will consistently achieve the standards ofquality, good or bad, set by the company.

REFERENCESAhmed, F.E. (ed.). 1991. Seafood Safety.

Committee on Evaluation of the Safety ofFishery Products. Washington, D.C.:National Academy Press.

British Standards Institution. 1987. BS5750:Part 2:1987. British Standard Quality

Systems. Part 2. Specifications for produc-tion and installation. London: BSI.

Bryan, F.L. 1987. Seafood-transmitted infec-tions and intoxications in recent years.Pages 319-337 in Seafood Quality Determi-nation, D.E. Kramer and J. Liston, eds.Amsterdam, Elsevier.

Commission of the European Community.1992. Commission decision of 15 December1992 on the microbiological criteria appli-cable to the production of cooked crusta-ceans and molluscan shellfish. (93/51/EEC).Official Journal of the European Communi-ties, L 13: 11-12.

Council of the European Community. 1991a.Council Directive of 22 July 1991 layingdown the health conditions for the produc-tion and the placing on the market of fisheryproducts (91/493/EEC). Official Journal ofthe European Communities, L 268: 15-34.

Council of the European Community. 1991b.Council Directive of 15 July 1991 layingdown the health conditions for the produc-tion and the placing on the market of livebivalve molluscs (91/492/EEC). OfficialJournal of the European Communities,L 268: 15-34.

FAO. 1990. Fishery Statistics: Commodities.Vo1 71. Table I, Provisional food balancesheets. Rome, Italy: Food and AgricultureOrganization of the United Nations.

Gibson, D.M. 1992. Pathogenic microorgan-isms of importance in seafood. Pages 197-209 in Quality Assurance in the FishIndustry, H.H. Huss et al., eds, Amsterdam:Elsevier.

Howgate, P. 1987. Fish inspection and qualitycontrol in Europe. Pages 605-613 in SeafoodQuality Determination, D.E. Kramer and J.Liston, eds. Amsterdam, Elsevier.

ICMSF. 1988. Microorganisms in Foods. 4.Application of the hazard analysis criticalcontrol point (HACCP) system to ensuremicrobiological safety and quality. Interna-tional Commission on MicrobiologicalSpecifications for Foods (ICMSF) of theInternational Union of MicrobiologicalSocieties. Oxford: Blackwell ScientificPublications.

Shaw, S. 1992. Total quality management.Pages 365-378 in Chilled Foods: A Compre-hensive Guide. C. Dennis and M. Stringer,eds. New York: Ellis Horwood.

20

Terje E. MartinussenNorwegian Institute of Fisheries and Aquaculture

During the 1980s, various internal and exter-nal factors had an important impact on the at-titudes towards quality in the fishery sector inNorway.

The fishery industry entered into a period ofreduced quotas and subsequently reduced sup-ply to the fish-processing industry. At the sametime, competition in the market became stron-ger and more difficult and thus made it clearthat there had to be strategies other than in-creased volume through which profit could bemade.

Norway’s main competitors in the seafoodmarket, like Canada and Iceland, have beenimproving the quality of seafood through vari-ous means, and Norway’s status as the num-ber one quality seafood producer has thereforein some markets been challenged. Althoughmarkets for less expensive products can befound, it is more and more obvious that an in-creasing number of companies and sectors arecompeting on quality and with brand products.In this situation it is important to be in themarket to sell to the best paying, quality-con-scious customers, who demand safe productsand specified quality at the correct price.

Furthermore, the Norwegian system of sub-sidizing the fisheries sector has changed dra-matically, from a system of a general incomeguarantee to a general improvement of theframework of the fisheries sector. This latterpolicy, it is believed, results in an industryfounded on a sound economic basis, an indus-try that has more efficient units of production.The most important factor in the increasinglysignificant role of quality is the process of es-tablishing a single market within the Euro-pean Economic Community (EEC). TheNorwegian industry also heeded U.S. talkabout a mandatory fish inspection program onall imports.

The Single MarketEurope is Norway’s most important market,

importing some 60 percent of our total exportof fishery products. In Europe efforts havebeen underway for many years to establish theEEC as one single market as of 1 January1993. The single market will be a communitywherein goods, money, and people can movefreely. Existing technical obstacles to intra-Community trade will be removed and re-placed by common rules affecting marketing ofgoods and standardization of production.

Whereas an EEC council directive (directive91/493/EEC, of July 1991) lays down thehealth conditions for the production and thegeneral admission of fish to the market, theEEC council requests the different entrepre-neurs in the market to strive for higher stan-dards and thereby increase competition andefficiency within the community. As a result ofthis policy, there is a growing tendency for cus-tomers to ask Norwegian exporters to producecertificates of quality assurance according toprinciples in the International Standard’s IS09000 and ISO 45000 series.1 In March 1993,the company NORFRA became the first ex-porter in Norway to receive the ISO 9002 cer-tificate.

National RegulationsSo that Norway’s regulations will be consis-

tent with those of the EEC, the Governmenthas proposed an amendment to our nationalregulations. Because the technical and hy-gienic standards are very high in Norway, thenew EEC regulations will have only limited

1 1 International Standard ISO 9000 and ISO 45 000 havebeen adopted as European Standard EN 29 000 and EN45 000 and as Norwegian Standard NS-ISO 9000 andNS-ISO 45 000.

impact as far as investments are concerned.The seafood industry in other countries, in-cluding member countries, is facing massiveinvestments in order to comply with the newtechnical standards set forward by the council.The major change in Norway will be the ques-tion of a compulsory monitoring system for allestablishments to ensure that the productionof fishery products complies with the directive.Such a monitoring system will be based on theprinciples of hazard analysis and critical con-trol points (HACCP).

FROM A NATIONAL SEAFOODINSPECTION SYSTEM TOWARDS ANINDIVIDUAL QUALITY ASSURANCESYSTEM

tors is to undertake quality inspection2 of fishas they are landed, processed, and stored. Issu-ing different certificates (health, grading, andso on) on consignments of seafood ready for ex-port to certain countries occupies a significantpart of their time. It is also the duty of the fishinspectors to control the hygienic standard ofall fishing vessels and processing units tomonitor conformity with the specified require-ments. During the 1980s the department wasalso involved in the national resource control.

The quality inspection of fish and otherfoodstuff at the point of retailing is, however,monitored by the Norwegian Food Control Au-thority.

Quality Inspection

The fisheries sector has previously been themost important sector of the Norwegianeconomy, The industry is fragmented, with nu-merous fishers and a large number of small-and medium-sized fish-processing companiesspread along the Norwegian coastline. Todaywe have a register of about 21,000 full-timeand part-time fishers, about 12,000 employedin the processing industry, and 6,000-7,000employed in the fish farming industry. Recur-ring problems in such a fragmented structureare to assure a consistently high quality ofgoods from the many suppliers and to coordi-nate efforts to maintain and achieve the highquality of the products.

The focus of the fish inspection authoritiesin Norway has been on quality inspection.Those who are not following the rules will get afine, get an improvement order, or even losetheir license. However, more serious fraudcases are taken to court.

It is well known that the existence of a largegroup with a common interest (high quality)does not automatically give rise to collectiveaction. There must be an individual incentiveto join in, or there must be compulsion (Olsen1977).

Because of the way the fish inspection sys-tem has been operating, with emphases oncontrolling quality, issuing certificates, andmonitoring resources, there has been less timeleft for giving advice to the industry on qualitymatters. Therefore, to a large extent, fish in-spectors have been recognized as “quality po-lice.” At the same time there have been fewincentives for the industry to produce a higherquality than that required by the regulations;as a result, the national standard has becomea maximum standard.

National Seafood Inspection SystemIn Norway there has always been strong

governmental involvement in the fisheries sec-tor to secure the national economic interest.The first governmental intervention occurredin 1444, with regard to the inspection ofstockfish. The first national act on “qualitycontrol of fish handling and processing” wasimplemented in 1937. The act has since beenmended, in 1958, and reviewed, in 1986. It isstill a major instrument in national efforts tosecure a high standard of quality within thesector.

However, through this national system formandatory fish inspection, the government hasbeen able to “guarantee” the quality of consign-ments of fishery products. Producers in othercountries have thus recognized our nationalinspection system as a significant competitiveforce in the market .

Quality Assurance SystemsThrough the ongoing process of establishing

a general market standard in the EEC, wehave faced a process in which the responsibil-ity for monitoring and assuring a certain pro-duction standard gradually is beingtransferred from the governmental to the pri-vate sphere. The greater responsibility put on

The law, which lies under the jurisdiction ofthe Directorate of Fisheries, is implementedthrough a system of regional fish inspectorsand laboratories. The main task of the inspec-

2Testing the freshness of the fish through sensory andbiochemical tests. The tests are carried out by random

sampling

the processors to ensure the health and safetyof the consumers implies that safeguardingquality, including monitoring internal quality,has to be an integrated part of the processingactivities of any successful company.

We therefore believe that in the near future,Norway will have a system where the nationalfish inspection system will continue to play avital role as a system for securing a “minimum(high) quality standard” through inspectionand monitoring of processing establishments.In addition, the National Seafood InspectionSystem will possibly be accredited as a compe-tent body for issuing health certificates forfishery products to be exported. It is urgentthat we strengthen the advisory part of theservice to facilitate improved systems for qual-ity assurance in the industry.

Above this “minimum level,” the fishers andprocessors who have a policy of supplying sea-food to quality-conscious buyers paying thehighest prices will have to introduce systemsthrough which quality control and quality as-surance can be ensured within the company.Such quality systems will most likely be basedon the principles of quality assurance ratherthan on those of quality inspection. To someextent such systems have to be approvedthrough ISO certificates or through certifiedlaboratory tests by an independent third party(the global approach).

DlFFERENT LEVELS OF STANDARDAs a consequence of the new marketing

trends that have been discussed, a certainminimum standard has to be adopted in theindustry before a processor can obtain an offi-cial registration number and be allowed to en-ter the market. The next step will be that somecustomers will ask the industry to certify thatit is able to manufacture goods according to anISO standard for quality assurance. These cer-tificates are issued by certain private enter-prises that are accredited in one of the EECmember countries. Those who think an ISOcertificate will be the ultimate solution willhave to reconsider their opinion. The mostquality-conscious customers, like brand ownersand supermarket chains, will, however, ask fora quality certificate before any processor is in-vited to negotiate a contract. In addition, pro-cessors will have to demonstrate their abilityto manufacture a certain product on the basisof strict guidelines and process specificationsfrom the customer.

3 According to NS ISO 8402 the definition is ‘The totalityof features and characteristics of a product or service thatbear on its ability to satisfy stated or implied needs.”

NATIONAL CAMPAIGN FOR IMPROVEDQUALITY

The Ministry of Fisheries (MF) is fullyaware of these challenging market trendsamong quality-conscious consumers and hastaken the initiative to maintain andstrengthen our position as the leading qualityseafood producer. The Government designated1990 “the Quality and Marketing Year” in thefisheries sector. To accomplish this, the Gov-ernment approved and launched a nationalcampaign for improved quality on all seafood.The campaign continued the following yearsbut was due to be terminated by the end of1993.

OrganizationThe campaign-called "Kvalitetsbølgen"

(the " Wave of Quality”)-_has been plannedand implemented as a joint program betweenthe MF and major fisheries and the aquacul-ture organizations. The Norwegian Institutefor Fisheries and Aquaculture was given thesecretarial functions for the coordination of theprogram. A professional public relation agencyis assisting in the preparation and presenta-tion of the necessary material and brochures.The different activities have been agreed uponby the Steering Committee and executed eitherby the Norwegian Institute of Fisheries andAquaculture or by one of the organizations in-volved.

The campaign has thus become a collabora-tion among three main parties:

1. the Government2. the producers and the processors3. research and development institutions

Objective“Quality”3 means different things to differ-

ent people. The main objective of the firstphase of the campaign was to motivate and in-fluence the fishers’ and industry workers’awareness of and attitude to quality in all Nor-wegian seafood. An objective of the campaignwas to teach people to recognize ‘quality” asmeaning that a product has characteristicsthat correspond “to specifications from identi-fied customers.”

A further objective of the campaign Was toincrease the total market value of the fisheryproducts and the profitability in the Norwe-gian seafood industry. Finally, for nutritionaland health reasons, it was an objective to in-crease the domestic consumption of seafood inNorway.

Target GroupsThe target groups of this campaign are the

fishing industry, the fish-processing industry,and all involved in marine aquaculture. Butpeople engaged in related activities in the fish-ery sector, such as research, education, andadministration, also have been included.

The First Phase-Awareness and AttitudeDuring the first phase, the campaign fo-

cused on awareness, attitude, and knowledge.In this connection, different kinds of informa-tional material were developed; some materialwas made specific to a particular group, andsome was made general for the entire targetpopulation.

SeminarsInitially a press conference was held to brief

invited journalists about the campaign soon tohe launched. As a result, many articles focus-ing on quality in the fisheries were printed.

At the beginning of the campaign, anotherseminar was held at which various topics re-lated to quality were discussed. A concludingseminar is planned by the end of this year toreview the achievements during the campaignperiod.

Seminars focusing on quality and qualityassurance were held in 12 of the main fishingmunicipalities. Much local initiative has beennoticed in the wake of these seminars, andsubsequently, many companies are now imple-menting quality assurance programs.

BrochuresThe Norwegian Institute of Fisheries and

Aquaculture wrote the text for each publica-tion, which was then reformulated by the pub-lic relations agency. The text and drawingswere reviewed by all members of the SteeringCommittee before the brochures were pub-lished. These publications highlight a numberof activities:

l The importance of having support fromhighly motivated and dedicated manag-

24

ers who need to understand and partici-pate in all quality matters. A pamphletwas distributed to about 8,000 manag-ers, skippers, boat owners, and fishfarmers.The importance of informing everybodyinvolved in fish production and process-ing about the need for improved qualityand to discuss quality not only as“freshness” but also in terms of “just intime” and “according to specifications.”A brochure on this topic was distributedto 45,000 persons.The importance of identifying improve-ment areas and to learn what people inthe sector understand by quality. TheNorwegian Institute of Fisheries andAquaculture (Olsen 1991) conducted asurvey, asking fishers and those whowork in the processing industry theiropinion of the present quality standardsin the handling and processing opera-tions. Everybody seems to be aware ofmajor shortcomings in relation toquality, but nobody is willing or able totake the responsibility for the situation.These are the main conclusions we wereable to draw:l Support from top management is

necessary.l Quality can be improved at many

stages of the processing line.. The supplier and the customer,

external and internal, shouldestablish a good relationship toachieve a higher quality end product.

We determined which activities tohighlight in the second brochure byasking the people involved ratherthan referring to the commonliterature on quality assurancesystems.

l The importance of identifying theneeds of our main customers. Howdo consumers in our major marketsrecognize the quality of Norwegianseafood, and how does this informa-tion correspond with our ownopinion?

On the basis of a survey conducted by theNorwegian Institute of Fisheries and Aquacul-ture in the U.S. (Olsen 1991), along with con-clusions from various marketing reports, athird brochure was distributed. These are themain conclusion that could be drawn:

0 Norwegian exporters are considered to educate the fish inspectors in the principlesbe reliable and professional. and the implementation of quality assurance

0 Norwegian brands are hardly recognized systems. In this regard, five different pilotat all.

* The quality of Norway’s salmon isconsidered to be on top, whereas thequality of its cod is considered to beinferior to products from Iceland andCanada.

AdvertisementsDuring the campaign we took out nine dif-

ferent advertisements in main fisheries news-papers and magazines. Our intention was togive facts and announcements of importantmessages in the brochures.

projects have been implemented in cooperationwith different fish-processing plants, one foreach control district covered by the Directorateof Fisheries. These projects are carried out incooperation with different institutes as profes-sional resources. Special emphasis was put onthe question of implementing and monitoringthe HACCP system since it will be compulsoryas a minimum monitoring system for the in-dustry.

Guidelines for Implementing HACCP

NewslettersWe printed monthly newsletters in the two

main fisheries newspapers, intending to giveinformation about people who had respondedto the campaign and had started implementingdifferent “quality projects.” The newsletterswere also open to questions from the readers.However, we stopped the activity after oneyear, as it was rather demanding to follow upgiven the resources available and given thefact that the industry did not inform us aboutongoing activities.

The Directorate of Fisheries, in cooperationwith the Norwegian Institute of Fisheries andAquaculture and producers associations, hasbeen carrying out a project to establish generalguidelines for implementing the HACCP sys-tem in different companies like the prawn fac-tories, the filleting industry, and theprocessing industry in the aquaculture sector.The progress of this project has not been satis-factory because the Directorate has not givennecessary priority to the project.

Guidelines for Handling of Fresh Fish

Also we printed a series of six posters anddistributed them to the processing industry.

Scholarship for JournalistsAs a follow up to the newsletters, we intro-

duced five traveling scholarships for journal-ists. By giving these fellowships, we managedto get a lot of articles on quality printed in fish-ing newspapers and locally based newspapers.Various articles covered the Norwegian posi-tion in the Spanish market for salted fish aswell as the position in the German wet fishmarket. Other articles are still to be printed.We believe this has been a worthwhile strategyto get journalists aware of the quality issue.

Another activity carried out by the Norwe-gian Institute of Fisheries and Aquaculture isthe preparation of guidelines and instructionson handling and grading fresh fish (ground-fish), The guidelines are not revolutionary, butrather a comprehensive and systematic pre-sentation of the somewhat boring rules andregulations given in “the blue book.”

Other Activities

The Second Phase-Learning by DoingIn the second phase of the campaign, the

strategy was to continue the efforts for chang-ing attitudes and to support various ongoingactivities and initiatives in the industry.

Because information and motivation areconsidered important parts of the campaign,different projects within these areas have beensupported. In this regard, activities carried outby the fish industry associations have beengiven some financial support. The secretariathas also been giving advice to the industry onimplementing quality systems.

The Role of the Norwegian Institute ofFisheries and Aquaculture

Quality Assurance ProgramOne major project has been a training pro-

gram within the Directorate of Fisheries to

The Norwegian Institute of Fisheries andAquaculture was designated in 1973 as an in-dependent research institute under the Norwe-gian Fisheries Research Council and wasreorganized in 1992. The institute has the fol-lowing obligations:

2 5

” to promote and carry out research anddevelopment work for the fisheries andaquaculture sector and thus contributeto a better utilization and managementof the biological resources of the sea

* to promote fisheries and aquaculture byinformation

* to give advice to the Norwegian authori-ties and to the fisheries and aquaculturesector

The Norwegian Institute of Fisheries andAquaculture was designated to be the secre-tariat of this campaign because our institutealready had taken several initiatives to getmore emphasis on quality aspects. We had re-sponsibility for writing all background infor-mation for the brochures. Two of the brochureswere based on results from ongoing researchprojects in the Center of Economics and Mar-keting. We have also been responsible for car-rying out the different activities under theprogram.

In addition, the institute has played a majorrole in designing and implementing quality as-surance programs in the industry, and we havetested different approaches. There has been aspecial need for extrapolating the require-ments in the ISO standard to practical proce-dures in the industry. The nature of this workhas been partly research and partly basic con-sulting. With regard to consulting, our workhas been taken further than our policy intends,but it was necessary at an early stage beforethe traditional consultants had obtained thenecessary training and experience. In the nextstage, we will undertake training, monitor theprogram, and assist in the certification of newcompanies. We shall not be practically involvedin any enterprise.

The Norwegian Institute of Fisheries andAquaculture has been highly involved in theplanning and execution of an education pro-gram under the University of Tromsoe. TheFisheries Research Council has stressed qual-ity in its research program, and the NorwegianInstitute of Fisheries and Aquaculture has car-ried out research on subjects like methods forsorting fish alive, processing of prerigor fish,methods for measuring the fat content infarmed salmon, and important quality at-tributes for the processing of salted fish.

We have also been involved in different com-mittees to formulate strategies for differentdevelopment programs (financed 50-50) andestablish priorities among applications fromthe industry.

During the campaign, quality has been puton the agenda in fisheries as never before, andthere has been an increased focus on the needfor quality assurance and quality improve-ments. Several projects are being imple-mented, with the associations in a key role.These efforts have also identified the need forbetter education and training of the employees.

Quality PrizesThe Norwegian Fishermen’s Association

and the Directorate of Fisheries have intro-duced quality prizes for the fishing fleet andthe processing industry, respectively. Thoughthese prizes are not based on the principles ofthe more famous prizes, like the Demingerprize or the Malcolm Baldrige Award, theyconstitute important rewards for those whohave shown an above-average interest in qual-ity.

Quality Assurance SystemsAt the beginning of this campaign, the Nor-

wegian Institute of Fisheries and Aquaculture,in cooperation with some consultants, planneda program for implementing a quality manage-ment system in 10 companies in northern Nor-way. The Federation of Norwegian FishingIndustry has responsibility for implementingand coordinating the program, whereas theNorwegian Institute of Fisheries and Aquacul-ture has been giving professional support. Thisprogram will terminate in July; by that timemost of the companies will be at the level of NSISO 9002. The program is considered to bevery successful, and another group of 26 com-panies have already joined a two-year programat a total cost of about U.S. $7 million. Anotherimportant quality program has been imple-mented in the Lofoten and Vesteraalen area.The Norwegian Institute of Fisheries andAquaculture, in cooperation with trainedteachers, has been responsible for the profes-sional support.

This program was implemented in two sepa-rate phases. The first phase covered all 26companies, with emphasis on motivation andeducation of shop floor people in order to orga-nize and generate improvement activities. Inthe second phase, 19 of the factories continuedand worked out system documentation.

A third program in which the NorwegianInstitute of Fisheries and Aquaculture hasbeen involved is a quality program for five

26

shrimp factories. The shrimp processing indus-try in Norway has a high level of quality and isfamiliar with strict requirements from custom-ers like Marks & Spencer and the legal au-thorities. Therefore, there is a market-driven" quality culture” in the shrimp industry andconsequently less need for motivation than inthe fish-processing industry.

The marine aquaculture sector had been fo-cusing on quality long before the campaignwas launched and had, at the time we started,already made a plan--“Quality Fish Project”("Prosjekt God Fisk")" - for implementingquality assurance in the whole sector.

Through this program, they have workedsystematically towards awareness of qualityand practical information on the handling andprocessing of farmed salmon to maintain thehighest degree of freshness and quality. Theyplanned a second phase to prepare the compa-nies for the process of being certified accordingto international standards of quality. For twoto three years it was expected that most com-panies in the aquaculture sector should intro-duce quality management. However, thebankruptcy of the Norwegian Fish Farmers’Sales Organization was a setback to this plan.(Unlike the fishing industry, the aquaculturesector planned to implement a strict qualityassurance program giving priority not so muchto education and training, but to establishing aquality system documentation).

EducationFish processing remains a relatively labor

intensive industry. One of the keys to improv-ing performances in this industry is to findways of helping employees do a better job. Aswe have implemented quality systems, wehave identified the need for improved educa-tion and training of managers and employees.

This need for education cannot possibly bemet by the sector alone, and so some financialand professional support is given by the Gov-ernment. The training and education of work-ers is basically given as (1) training program4

for specialized workers or (2) “internal train-ing,” thus using both public and private fundsfor education. The Directorate of Labor has

made funds5 available for companies that wantto offer the employees internal training pro-grams as an alternative to unemployment andexpenditures on unemployment pensions. As afund of this nature has been made available, amore comprehensive effort for implementing“quality” in the fish-processing industry inNorway could be made possible.

Several projects of this nature are beingimplemented, something that seems propitiousfor the future of the fisheries sector in Norway.A weak point, however, is that the fishing in-dustry is not given the same training opportu-nities as the processing industry. Because thefishing industry is an important part of an in-terdependent production chain, its trainingneeds should be given a higher priority.

At university level, a training program inquality management has been introduced. Inconnection with “the Lofoten and Vesteraalenprogram,” the Finnmark Regional College hasstarted an integrated one-year program on“education and development” of teachers andof key personnel in the factories.

Research and DevelopmentThe research institutes and the universities

have also focused on quality, which has beengiven priority through special research pro-grams administered under the Fisheries Re-search Council. Quality (in the handling ofmarine resources) has also been emphasized indevelopment programs in connection with theannual agreement between the MF and theNorwegian Fishermen’s Association.

Grading System for CodfishAnother important decision related to im-

proving quality in the fisheries sector in Nor-way was the introduction of new principles fordetermining the minimum prices of raw fish bythe Norwegian Fishermen’s Sales Organiza-tion in May 1989.

Prices were previously determined on thebasis of the various product categories; the newsystem determines prices on the basis of spe-cific criteria of quality. The new system gradesthe fish into Extra, A (ordinary), and Rejection.Grade A6 is based on the standard described in

4The training program for the processing industry andthe marine aquaculture industry was approved in 1989;a similar program for the fishing fleet is still to beapproved by the Government.

5The Government covers 50 percent of the labor cost ifpeople are given internal training programs as analternative to unemployment.6 In the case of nonconformity with the standard, the

price can be reduced up to 30% on the basic price for the

A grade.

the guidelines of the quality regulation,whereas Extra requires careful and profes-sional handling similar to that for the gradeSuperior salmon. The price of grade E is about10 percent above grade A.

The effect of this change in price regime isevident. During the first two years of the newsystem, the quality of the landed fish increasedsignificantly and the rejection rate due to poorquality of raw fish was reduced. However,when practicing the new system, it has beendifficult to distinguish between matters suchas the objective quality of the fish and thequestion of fixing a reasonable price for thefish.

CONCLUDING REMARKSThe underlying message of this campaign

has been that people are the most importantfactor when we want to achieve higher quality.Internal marketing has thus become the keystrategy of this campaign. In this context wehave emphasized identifying internal custom-ers through the processing line of any com-pany. Do the products we supply to the nextcustomer comply with expectations or specifi-cations? Have the employees received the nec-

essary training and qualifications for the jobthey are going to perform? And finally, who isresponsible for the quality level in an estab-lishment?

The final goal should not be to establish asystem only to ensure quality assurance, butalso to encourage quality improvement activi-ties in line with the Total Quality Manage-ment concept.

Today, we feel that the wave of quality thatwas introduced by the Ministry of Fisheriesand the organizations of the sector waslaunched at the right moment, as the cam-paign for improved quality supports ongoingand planned efforts. We certainly believe thatsuch a massive quality effort in the comingyears will increase the total value of Norwe-gian fish resources.

REFERENCESJensen, P.F. 1992. EEC standards for fish and

fish products. Pages 547-559 in Qualityassurance in the fishing industry. H.H.Huss et al., eds. Amsterdam: Elsevier.

Olsen, S.O. 1991. Fiskernes oppfatninger ogholdninger til kvalitet og kvalitetsstyring.Rapport 4/1991, Fiskeriforskning, Tromsø.

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INTRODUCTION NEvolvi ng in ter nat iona l standards will likelyhave an impact on seafood trade for the UnitedStates in both exports and imports. The U.S.was the number one exporting nation in theworld in 1990, with over $3 billion in seafoodexports, and the number two importing nationin the world, with over $5.5 billion in seafoodimports (Fisheries of the United States 1991).

The international requirements will evolvefrom activities that are in progress in theCodex Alimentarius, negotiations under theU.S./Canada Free Trade Agreement, the NorthAmerican Free Trade Agreement, and negotia-tions with the European Community (EC).

It is in the best interests of the UnitedStates to continue to actively participate inthese activities.

CODEX ALIMENTARIUSSThe Codex Alimentarius Commission is a

subsidiary body of the Food and AgricultureOrganization of the United Nations (FAO) andthe World Health Organization (WHO). TheLatin words codex alimentarius mean “foodcode.” In the present context it is the compila-tion of all the standards, codes of practice,guidelines, and recommendations of the CodexAlimentarius Commission.

The Codex Alimentarius Commission wasestablished in 1962. The Codex system was setup because of a widely perceived need to facili-tate world trade in foods, and internationallyaccepted standards were seen as the means. Atthe same time it was realized that if such in-ternationally acceptable standards could bedeveloped, then these standards must be basedon added protection for consumers’ health.Such standards would also promote fair prac-tices in the food trade. The objectives of freertrade and better consumer protection are mu-tually dependent and mutually supportive.

Membership in the Codex AlimentariusCommission is open to all member nations andassociate members of FAO and WHO; some137 countries were codex members by the endof 1989.

Codex work is divided between committeesdealing with “vertical” measures and those

with "horizontal” measures, that is, commit-tees on commodities and those dealing withgeneral subjects such as food labeling. Eachstandard is considered in both kinds of com-mittee as necessary.

A Codex standard sets out the requiredqualities of the food commodity, as sold, inobjective terms. The elaboration of Codexstandards follows eight different steps tocompletion, Degrees of acceptance by membercountries are "full acceptance,” “targetacceptance,” and “acceptance with specifieddeviations.”

Codex also develops recommended interna-tional codes of hygienic practice for variouscommodities. Their purpose is to provide guid-ance for good manufacturing practices, andthey are advisory in nature. The Codex contactpoint in the United States is the Executive Of-ficer for Codex, Food Safety and InspectionService, U.S. Department of Agriculture,Washington, D.C.

The Codex Committee on Fish and FisheryProducts is responsible for the elaboration ofworldwide standards for fishery products. TheUnited States delegate is from the NationalMarine Fisheries Service (NMFS). The delega-tion consists of technical advisors from govern-ment - that is, NMFS and the Food and DrugAdministration (FDA) - and industry.

The host government for this committee isNorway. The committee, which had its firstsession in 1966, now meets every two years.

There are currently 15 Codex standardsthat are approved or in draft form for frozen,canned, dried, and salted fishery products. Allstandards are in the process of being revised.The purpose of the revision process is to iden-tify baseline acceptability criteria, which, if notmet, would result in governments’ taking ac-tion against the product.

The aesthetic characteristics would be re-tained and placed in appropriate documents asadvisories to be used by buyers and sellers inestablishing trading specifications.

There are currently 17 recommended inter- national codes of practice for fish and fisheryproducts either approved or under elaboration.

The committee has been requested to consider a review of the codes of practice for possible

31

revision and to consider incorporating hazardanalysis and critical control points (HACCP)principles into the documents.

The National Standards and SpecificationsBranch, Technical Services Unit, InspectionServices Division, NMFS, is responsible for co-ordinating all work to be done to establish U.S.positions that are presented to the committeeat each session. This work includes developingprotocols, field testing data collection sheets,analyzing data, and soliciting comments on ap-propriate documents for consideration by theU.S. delegation.

It is extremely important that governmentand industry work in harmony to provide accu-rate and precise information to the U.S. del-egation in order to protect the U.S. interestsfor trading fishery products.

CANADA - U.S. FREE TRADE AGREEMENTA Bilateral Technical Working Group on

Fish and Fishery Product Inspection was orga-nized and the first meeting held in January1990 in Ottawa, Canada. The objective of theworking group is to harmonize inspection sys-tems by eliminating technical trade barriersbetween both countries. Meetings take placeapproximately every six months and alternatebetween the United States and Canada.

The Technical Working Group consists of aU.S. cochair from the FDA, a cochair from theNMFS for trade matters and those matterswhere NMFS assumes responsibility, and tech-nical representatives from the FDA, NMFSand the U.S. Fish and Wildlife Service(USFWS). The Canadian representatives in-clude a cochair from the Department of Fisher-ies and Oceans (DFO), Inspection andEnforcement Directorate; and technical repre-sentatives from the Directorate, InternationalDirectorate, and from the National Health andWelfare, Canada Health Protection Branch.

There are eight subworking groups underthe direction of the Technical Working Groupto deal with specific areas and issues:

1. Comparison of Regulatory Measures2. Training and Education3. Notification and Information Sharing4. Essential Composition and Quality5. Facilities/Imports and Exports Inspection6. Molluscan Shellfish7. Aquaculture8. Reciprocal/International ActivitiesEach subworking group is under the direc-

tion of a U.S. and Canadian cochair.

32

The major activity in harmonizing inspec-tion systems is taking place in sensory evalua-tion, analytical procedures and requirements,and evaluation of the equivalency of inspectionsystems.

Recent sensory harmonization workshopswere conducted using the latest criteria frominternationally recognized sensory scientists.Expert analysts from the FDA, NMFS, and theDFO Inspection Directorate participated. Anin-depth analysis of the workshops clearly in-dicated that use of the appropriate sensoryanalysis applications resulted in expert asses-sor harmonization. These workshops will leadto diminished technical trade barriers and en-hance the trading of fish and fishery products.

Analytical procedures and requirements formicroorganisms, biotoxins, and food additivesare being evaluated by both countries to har-monize procedures, requirements, and actionlevels. Of particular interest are Listeria incooked, ready-to-eat fishery products, domoicacid levels, paralytic shellfish poisoning,methyl mercury, and polyphosphates. A proto-col for a collaborative study on the use of ca-daverine and putrescine as spoilage indicatorshas been submitted to the Association of Offi-cial Analytical Chemists for approval. Thestudy will include collaborators from the FDA,NMFS, and the DFO.

In regard to the examination for equiva-lency of existing inspection systems in theUnited States and Canada, NMFS has submitted its voluntary HACCP-based inspection pro-gram to Canada for review. This program wasdeveloped using the Canadian Quality Man-agement Program (QMP) as a model. The pro-gram was published in the Federal Register ofJuly 29,1992 for use. It is expected that a del-egation from Canada will perform an on-sitevisit to the United States to evaluate the pro-gram for equivalency in the near future. TheUnited States has visited Canada to observeand review the Quality Management Program.

Other activities include arrangements forjoint training, the development of a cooperativestudy on fish parasites by both governmentsand industry, and close coordination of all theactivities in Codex Alimentarius.

NORTH AMERICAN FREE TRADEAGREEMENT

There is currently little activity concerningprogress under the North American FreeTrade Agreement (NAFTA) as it relates to fishand fishery products. Based on the most recent

meetings, it appears that evolving interna-tional standards will be used as a basis fortrade. There is a committee on sanitary andphytosanitary measures that directs its atten-tion to those areas that protect human, animal,and plant life or health. There are no subcom-mittees or working groups. Joint Canadian-U.S. working groups continue to coordinatewith the NAFTA Sanitary/Phytosanitary Com-mittee.

There is also a committee on standards-re-lated measures to consider quality, nomencla-ture, packaging, and labeling issues.

EUROPEAN COMMUNITY (EC)NMFS is aware that the EC directives re-

garding the inspection and certification re-quirements to be implemented July 1,1993 area matter of concern to exporters of fisheryproducts.

Our meetings with industry across the coun-try during the past several months attemptedto provide the industry with as much advancenotice of the EC’s intentions as possible so thatplans could be made to meet these new re-quirements. It is important to note that the EChas adopted import requirements. Once therequirements are fully implemented, all coun-tries must comply with them if their productsare to be accepted into the EC.

Officials from NMFS, the FDA, and theUSFWS have met with representatives of theEC to discuss the impending directives, ex-plain the various controls and programs in theU.S., and seek clarification on a number ofitems described in the respective directives.These and other efforts have been undertakento assure that there will be minimal disruptionto U.S. export trade in seafood with the EC.

As an official U.S. Government agency re-sponsible for inspecting and certifying fisheryproducts, NMFS cannot ignore the EC importrequirements. It must assure that products itcertifies for export to the EC comply with ap-propriate requirements. In the event that a re-quirement is not being uniformly applied, tothe detriment of the U.S., it will be viewed as anontariff trade barrier and the U.S. Govern-ment will take appropriate trade actions.

Three EC directives have a major impact onfishery products:

1. Council directive 91/493, “laying downthe health conditions for the productionand the placing on the market of fisheryproducts.”

2. Council directive 91/492, “laying downthe health conditions for the production

3.

and the placing on the market of livebivalve molluscs.”Council directive 91/67, “concerning theanimal health conditions governing theplacing on the market of aquacultureanimals and products.”

Council directive 91/493 requires that thirdcountries (for example, the United States) havea system at least equivalent to the system de-scribed in the directive. The general provisionsof the system are delineated under Article 6with additional requirements that would beapplicable in the annex of the directive inchapters 2-7, which covers sanitation of thefacility, handling and storage practices, andproduct requirements.

Article 6 outlines the principles of theHACCP-based system. The value of such a sys-tem has been widely acknowledged by foodcontrol authorities internationally (for ex-ample., Codex Alimentarius) as well as in theUnited States (for example, various reports is-sued by the National Academy of Sciences re-garding meat, poultry, and seafood products).The United States, in particular, has recog-nized the advantages of adopting a HACCPbased inspection system.

EC representatives have acknowledged thattraditional NMFS in-plant inspection tech-niques (such as continuous inspection) wouldalso be considered equivalent to the HACCP-based inspection system. They have acknowl-edged that a lot inspection without knowledgeof the handling and processing conditionswould not be considered adequate.

The forthcoming system under the EC direc-tives contains significant changes from previ-ous experiences:

1.

2.

3.

4.

The establishment must be approved bya competent authority of the thirdcountry for compliance with require-ments equivalent to those laid down indirective 91/493.The establishment must be on a list ofofficially approved establishments thatis submitted to the EC by the competentauthority.The product must bear a mark contain-ing the approval number of the estab-lishment.The shipment must be accompanied bya health certificate.

The United States has identified N M F S theFDA, and the FWS as competent authoritiesfor the inspection and certification of fishery products and has submitted all the required

material pertaining to laws, regulations, proce-dures, and so on, to the EC for evaluation. TheUnited States has been informed that the ECwill perform on-site visits between July 15 andOctober 1993.

Commission decision 93/185/EEC, “layingdown certain transitional measures concerningthe certification of fishery products from thirdcountries in order to facilitate the switchoverto the arrangements laid down in council direc-tive 91/493/EEC,” is to be implemented July 1,1993. We have been informed that these tran-sitional measures for certification have beentaken to provide the EC with sufficient time toconduct site evaluations of the inspection sys-tems of third countries exporting products tothe EC. The decision will apply from July 1,1993 to December 31,1994. NMFS is in theprocess of translating the model certificate intothe nine official languages of the EC. All cer-tificates will be bilingual.

Council directive 91/492, requirements forlive bivalve molluscs, is being discussed by theFDA and the EC.

The major difference between the U.S. andthe EC systems is the method of control. TheEC relies on testing of the meats whereas theU.S. FDA system relies on testing the watersin the growing areas for control purposes. TheUnited States continues to pursue EC approvalfor equivalency of our system.

Council directive 91/67, deals with aquacul-ture animals and products. The USFWS is dis-cussing its programs with the EC to determineequivalency. The measures in this directiveaddress matters pertaining to health and dis-ease control.

The United States will continue to pursueclarification of language and areas in all of theEC directive that are unclear or left to inter-pretation. The industry will be kept informedof the status of the ongoing negotiations.

OTHER ISSUESNMFS has received inquiries from several

countries - Canada, Iceland, Chile, Indonesiaand Ecuador - expressing interest in the devel-opment of memorandums of understanding torecognize each others’ inspection systems forequivalency.

Initial meetings to discuss protocol for thedevelopment of a memorandum of under-standing have taken place with officials fromIceland.

Any development of a memorandum of un-derstanding will be discussed and coordinated

34

with the FDA for mutual agreement before ap-proval.

INTERNATIONAL N M F SThe FAO, Rome, Italy, has requested that

NMFS provide training assistance at work-shops and seminars conducted in South andCentral America over the past 18 months. Therequests have originated from the Food andAgriculture Organization of the United Na-tions, Rome. The training has focused on qual-ity assurance and HACCP inspection systems.All of these seminars and workshops havebeen conducted in Spanish, and U.S. participa-tion has been from the National TrainingBranch of NMFS. The host countries havebeen Chile, Panama, Costa Rica, El Salvador,Honduras, Brazil, and Guatemala.

There were 790 participants in the variousworkshops and seminars, from 40 differentcountries.

NEW NMFS HACCP-BASEDINSPECTION SERVICE

On July 29,1992, NMFS published in theFederal Register the new NMFS inspection ser-vice based on HACCP principles. This inspec-tion service is in addition to the existingtraditional NMFS inspection services availableto industry. As is the case with the traditionalinspection services, participation is voluntary,on a fee-for-service basis, the scope beingsafety, wholesomeness, and economic integrity.The service is available to all interested par-ties.

As of May 14,1992, three firms at four loca-tions have been participating in the NMFSHACCP-based inspection program. NMFS hasreceived twelve HACCP plans for review.There continues to be interest from the retailsector.

NMFS provides HACCP certification by ad-ministering a test. Interested parties can ar-range for a test to be given at a NMFS facility,following an NMFS training workshop, or fol-lowing an industry training workshop. Thiscertification is recognized by the FDA.

REFERENCESFisheries of the United States 1991. U.S.

Department of Commerce, NOAA, NMFSPublication.

Ian DevlinDepartment of Fisheries and Oceans, British Columbia

ODUCTIONDuring the past five years, the Department ofFisheries and Oceans and the Canadian fish-processing industry have worked together todevelop the Quality Management Program(QMP). On February 1,1992 it became manda-tory and is now a condition of federal registra-tion for fish-processing plants.

In this paper I explain the rationale for de-veloping the QMP by providing you with somebackground information on the Canadian fishinspection program and identifying the chal-lenges that we were facing in delivering ourinspection program and that prompted the re-examination of the way industry was beingregulated. I then briefly explain the basic prin-ciples of our new QMP and clarify theGovernment’s and industry’s roles under theQMP.

THE CANADIAN FISH INSPECTIONPROGRAM

The Inspection Services DirectorateMandate

The Inspection Services Branch of the De-partment of Fisheries and Oceans is mandatedthrough federal legislation to inspect all fishand fish products intended for export fromCanada or for interprovincial trade, and allfish and fish products imported into Canada.Through this mandate, we assure that bothdomestic production and imported productsmeet Canadian and foreign standards forgrade, handling, identity, process, quality, andsafety. In simpler terms, the Canadian FishInspection Program ensures that fish productsproduced in Canada or imported and sold inCanada are safe and wholesome and are fairlytraded.

For fish and fish products produced inCanada, we have a dual concern: the healthand safety of Canadian consumers and theoveraIl quality of Canadian fish and fish prod-ucts and their acceptability in internationalmarkets. Eighty-four percent of the fish caughtand processed in Canada is exported. The In-spection Services Branch plays an importantrole in facilitating the trade of these Canadian

fishery products through its product inspectionand certification programs.

To achieve its mandate, the Inspection Ser-vices Branch has developed over the years amultifaceted national fish inspection programthat focuses on the strategic steps of the fish-processing industry to ensure safe and accept-able fish products. This program involves avariety of inspection activities that include theinspection of

domestically produced fish products todetermine the acceptability of theseproducts for sale in Canada or on foreignmarketsdomestic fish-processing establishmentsto determine the degree of compliancewith regulatory requirements forconstruction, equipment, and operationdomestic fishing vessels, unloadingsites, and transport vehicles to deter-mine compliance with the applicableconstruction and operating require-mentsimported product and the offshoreprocessing operations to determine theacceptability of these products for sale inCanada and the monitoring of shellfish-growing waters through the CanadianShellfish Sanitation Program.

Traditionally, many of the decisions madeunder the Fish Inspection Program relied onfinal product analysis and the results of singleindependent inspections of fish-processingplants. Implementing the QMP will expandthe sources of information used in making de-cisions. A new decision-making process basedon interrelated inspection data, gathered overtime by both government inspectors and theprocessor, will be established.

Future ChallengesBefore I focus on the specifics of our new ap-

proach, I would like to comment briefly on thechanging nature of the commercial environ-ment of the 199Os, which is making innovative

.

public media. Because of the increase in con-taminants, pollution, and threats to the envi-ronment, there has been an increase in mediaand public concern regarding the safety of thefood supply in general and fish products in par-ticular. International trends lead us to believethat there will be no letup in media attentionin the next decade. Today’s consumers are bet-ter educated, better informed, and concernedabout the safety of the food they eat. In allprobability the workload of all food inspectionagencies will continue to

The rapid pace of changing technologies pre-sents an additional challenge to industry andfood inspection agencies. As the Canadian fish-processing industry develops new products andprocesses, the Fish Inspection Program mustadapt its inspection methods to continue tomeet its mandate.

Another major challenge for the 1990s willbe responding to trade issues. The movementtowards HACCP in the United States and thedevelopments in the European Community arealready indicating additional demands on theCanadian fish processors and the Fish Inspec-tion Program. These countries and others arerequiring more assurances from the CanadianGovernment that standards are being met.

The factors I have mentioned are all exter-nal factors that will affect both the InspectionServices Branch and the Canadian fish-pro-cessing industry; but there is another key fac-tor internal to government that will have animpact on all of the Canadian food inspectionagencies. That is the question of resources.

The Canadian Government, as well as otherwestern governments, is under constant pres-sure to limit spending and inspection programssuch as the Department of Fisheries andOceans and the Department of Agriculture.Canada cannot expect to have ever increasingresources to meet the challenges of the future.We must find smarter and more cost-effectiveways to carry out our mandate.

The challenges of the 1990s make it neces-sary for government and the food processingindustries to find, develop, and implement in-novative and cost-effective approaches to foodinspection. These new approaches must beflexible and sensitive to the needs of the indus-try and permit industry to adapt and remaincompetitive in the changing markets.

The Department of Fisheries and Oceans’QMP is a key component of our strategy forresponding to the demands of QP fut;ure mar-ketplace and addressing both industry concerns. The QMP has been devel-

oped jointly by the Canadian fish-processingindustry and the Department of Fisheries andOceans. The QMP that the Canadian fish-pro-cessing industry will be required to establishin their plants is based on the HACCP philoso-phy. The QMP is, like HACCP, a system de-signed to prevent instances of public healthsignificance. However, the QMP has been de-signed to also prevent instances of unaccept-able quality and economic fraud.

The development of an individual QMP for afish-processing operation incorporates all ofthe basic steps involved in developing aHACCP system for a specific food product. Ahazard assessment of the process operation isperformed. Critical control points are identi-fied. Defect definitions and tolerances, moni-toring procedures, record-keeping criteria,corrective action systems, and company verifi-cation measures are established for each criti-cal control point.

The QMP is not however purely a HACCPsystem. It could be better described as a regu-latory compliance program as it is closelylinked to the Canadian Fish Inspection Re gu -lations. During the initial stages of the devel-opment of the QMP, the industry-governmentworking group decided that the QMP would bebased on existing regulations, which are de-signed to ensure that fish and fish products aresafe, wholesome, of acceptable quality, andfairly traded.

The QMP is designed for the fish-processingindustry to control their processing operationswithin the compliance boundaries of the regu-lations governing the production of fish prod-ucts. By implementing the QMP, thefish-processing industry will be able to demon-strate that it is operating on a day-to-day basiswith controls that ensure compliance with theregulations.

Let’s look a little closer at our QMP and howit fits into increasing industry’s responsibilityand accountability.

As of February 1, 1992, each fish-processing ingplant is required to have in place and be oper-ating under a QMP specific to its fish-process-ing operations. The department has developedthe QMP Submission Guide sist the in- t --dustry in developing their programs. The guidehelps the processor identify the critical controlpoints in the process and the associated haz-ards and sets out for the fish-processing indus-try the minimum requirements for a plant’sQMP.

The QMP of a fish-processing plant will berequired to address each of the 12 critical con-

36

trol points that are applicable to their opera-tion. Potential hazards should be preventedthrough the monitoring of these 12 points:

1.2.3.4.5.

6.7.8.9.

10.11.12.

incoming fishother ingredientspackaging materiallabelingchemicals (cleaning agents,sanitizers, lubricants, and pesticides)construction and equipmentoperation and sanitationprocess controlstoragefinal productrecall proceduresemployee qualifications

‘Critical control point” is defined as a pointin time or a physical location in the process atwhich failure of preventative measures willexpose the customer to unacceptable risks re-lated to tainted, decomposed, or unwholesomefish or to economic fraud.

At each critical control point the fish plantmust

* identify the standard that is beingapplied to ensure compliance withregulatory requirements

* identify the monitoring procedures andinspection frequencies that will befollowed to ensure that the standard isbeing met during production

. identify the reporting mechanism thatwill be used at each critical control pointto document the results of the inspec-tions. The fish plant will be required todevelop contingency plans or correctiveaction plans that will be followed if andwhen the monitoring procedures iden-tify an instance where the standard isnot being met.

The fish-processing plant will be required tohave available for inspection their documentedQMP that provides a written description of theprogram being implemented in the processingplant. The fish-processing plant will also berequired to retain records of all inspectionsperformed as part of their QMP for threeyears. These records must be made availablewhen requested to inspectors from the Depart-ment of Fisheries and Oceans.

In summary, a fish-processing plant’s re-sponsibilities under QMP will be

l to develop its own in-plant QMP specificto its operation

* to implement the in-plant QMP0 to maintain the QMP records of the

QMP inspectionso to correct all problems identified during

the QMP inspections.

M P INSPECTIONThe Department of Fisheries and Oceans

will inspect the fish-processing plant againstthe QMP requirements.

Individual inspectors will perform QMP in-spections that will entail the following:

verification of the written QMP to ensurethat the documented standards, monitor-ing procedures, record-keeping systems,and guidelines for corrective action meetthe minimum requirements as set by theDepartment of Fisheries and Oceansconfirmation that the written QMP isbeing followed in the plant. This willrequire the inspector to observe theprocessor’s QMP activities at eachcritical control point in the plantverification that the processor’s recordsare accurate. This will require theinspector to withdraw and inspectparallel samples of the processor’sproducts and compare the results withthose of the company.

The completion of the QMP inspection willresult in the process operation’s being rated“excellent,” “good,” “satisfactory,” or “fail.”These QMP ratings represent the degree ofconfidence the Department of Fisheries andOceans has in the company’s ability to operatewithin compliance of the regulations and willdetermine the inspection coverage to be di-rected at the operation in subsequent weeks.

Fail-rated plants will be asked to voluntar-ily correct the deficiencies and improve theirrating to at least a “satisfactory.” Refusal todeal with the problems voluntarily will jeopar-dize the federal certificate of registration andtherefore the ability of the processing plant toexport its products. Plants which receive a“satisfactory” rating will be inspected on a fre-quent basis until they gain greater control overtheir process and obtain a higher rating.

Processing operations that are successful inmeeting all but a few of the QMP requirementswill receive an “excellent” or “good” rating.These plants will be qualified to apply for theuse of the “CANADA INSPECTED” logo ontheir product labels. Also the product certifica-tion process will be streamlined and provided

37

without delay, and the company will havemore autonomy in its day-to-day processingoperation.

The Q,MP will provide added assurancesthat problems are identified early in the pro-cess before value is added to the product andbefore the product reaches the market. TheQMP will also allow the department to mea-sure the level of compliance of the industry ina uniform manner and direct its resources tothose areas where problems have beenidentified.

The Quality Management Program-Industry’s Role

The major change for industry under theQMP is that it must accept more responsibilityand accountability in monitoring its perfor-mance. The processing plants will be requiredto perform inspections of the plant and prod-ucts and initiate corrective actions when theyidentify a problem. And records of all theseQ M P activities must be maintained so thatthey are able to demonstrate that they consis-tently operate in compliance with the regula-tions.

The Role of Government in RegulatingUnder QMP

The implementation of the QMP will meana change in the relationship between the fish-processing industry and the department. Un-der the QMP, the Department of Fisheries andOceans’ role will shift from solely an inspectionfunction to include an auditing function.

The inspector will continue to perform ran-dom inspections of the process operation andproducts, but the focus will not be on indi-vidual lots of product or on a day of plant op-eration, as now is the case, but rather on theoverall QMP system. The inspector’s decisionswill be based upon a compilation of interre-lated inspection results gathered over time byboth the inspector and the processor.

CONCLUSION

We feel the QMP will provide the Canadianfish-processing industry and the Departmentof Fisheries and Oceans with an effectivemechanism to ensure the protection and assur-ance needed in today’s demanding markets.The price of this assurance is change.

We will have to change. Industry will haveto change. But this approach should realizemore impact from each inspection. The numberof inspections we do may be somewhat reducedfor some plants, but each inspection will countfor more. We will be able to focus our effort onareas of higher risk and apply our resources ina more cost-effective manner.

In summary, the Department of Fisheriesand Oceans’ new approach to quality manage-ment is a joint industry-government systemthat is aimed at preventing problems beforethey occur. Working together through theQMP, the Canadian fish-processing industryand the Federal Government will be able toprovide Canadian and international customerseven better assurance than in the past so thatthe high standards Canadian fish productshave been known for will be met in the future.

Roger LowellU.S. Food and Drug Administration

Sometimes the impression from the media isthat the Food and Drug Administration (FDA)doesn’t have a mandatory seafood inspectionprogram in this country or that we have noseafood inspection program at all. I take issuewith this position, and in this paper, I’ll showsome statistics for the inspectional work that isdone. I’ll also give some insight into what a dis-trict office looks like and how it works.

The main FDA office for the Pacific region isin Seattle (figure l), which also houses the

as shown in table 1. It can be frustrating todeal with the Washington office because of theinfluence that the east coast industry has onFDA decisions. The west coast, and in particu-lar the Pacific Northwest, accounts for over 50percent of the domestic seafood production andnearly the same amount of exports in thiscountry. Yet, I don’t believe our voice is wellheard. If you look at dollar values of landingson the various ports for the United States, yousee that the west coast dominates the list.

Field Legalsurveillance - action prep.investigations industry

Inspections - EducationFOI

Samplecollectionsresident posts

Processing imports

JohnIIWiskerchenDSB

- Labsupport

- Analyticalservices

Research

seafood products research laboratory for FDA’sfield organization. Seattle has an investiga-tions branch and a compliance branch. Most ofthe people that you see are from the inspectionbranch of the FDA, where Jim Davis is chiefinspector. If you have questions about what isgoing on in your plant and I am not available,Jim Davis is the person to contact. Under thechief inspector, there are eight supervisors,each responsible for various programs. ChrisRezendes is a seafood monitor for the wholePacific region. He is the most knowledgeableperson in the district when it comes to seafoodissues.

The Pacific Northwest should have a greatdeal of power in terms of the seafood industry,

Marleen-1WekellDSPRC

- Seafoodresearch

Methodsdevelopment

KrisThiesA0

Personnel- services

accounting

- Procurement

- Mail/Files

- Data processing

Figure 1.Pacific RegionSeattleDistrict.

When it comes to seafood regulations, our voiceneeds to be heard along with the voices of pub-lic opinion, the bureaucracy, and the law.

State No.Firms

Table 1.Pacificregion

America Samoa 2Alaska 332Arizona 19California 279

seafoodindustry:number offirms ineach state.

Hawaii 20Idaho 46Montana 5Nevada 2Oregon 92Washington 595

The Pacific Region, Seattle district, has1,070 of the 1,392 firms that are registeredwith the FDA The official Establishment In-ventory lists firm names by a central file num-ber. The Seattle district has a great deal to sayabout what happens in seafood in the FDA.

Seafood firms are listed by state, withWashington leading and Alaska and Californiafollowing. We can break down seafood use intoestablishment types as shown in table 2: (1)manufacturers (people who do something withthe seafood); (2) repackers (people who takesomething that someone else has put together,break it into smaller entities, and repack it for

Table 2. Pacificregion seafoodindustryestablishmenttypes.

Establishment N O.Growers 103Manufacturers 830Repackers 583Shell Ship 279Other 44Warehouses 78

retail); (3) shellfish shippers; and (4) growers(who include people in aquaculture). To put thePacific Region Seattle district into nationalperspective, we can talk about the number of

actions that have been made and the per-of the national total accounted for out of

this region. We account for a good share ofwhat happens in seafood out of this region. TheFDA has six regions; we are simply one ofthem. Our region accounts for 27 percent of thenation’s inspections, 26 percent of the hoursspent making those inspections, and 40 per-cent of the samples collected from both importstatus and domestic status. We do wharf ex-ams for imports, which are just short of sam-pling that product. The exam is usually forlabeling, but it could also be for seams on cansor other characteristics that an investigatorcan look at right on the dock without bringinga sample back to our laboratory.

Inspection classifications are assigned tofirms we have inspected (figure 2). NAI means“No Action Indicated,” which doesn’t meanthat you don’t have some problem; it simplymeans that we are not going to take legal ac-tion against your firm. VAI-2 stands for “Vol-untary Action Indicated.” It indicates to usthat there were more serious problems, but weanticipate that you are going to fix them.VAI-3, or “Voluntary Action Indicated,” andOAI, which is “Official Action Indicated,” entailreceiving official written notice from us thatyou have a problem and that we’re going totake action if you don’t remedy the situation.First, we give you a warning letter describingactions you must take and requiring a re-sponse in 10 or 15 days telling us what you’ve

Figure 2. Pacific Region inspection classification

40

FDA@a STATEm REGIONm NATION

done. If we don’t get an adequate response, weare prepared to take FDA legal actions, suchas seizing product, or injunctive action againstmoving your product in interstate commerce,or our last resort, to prosecute. We don’t havemany firms in that last category, but we dohave some.

Sample classifications are listed as classes1, 2, and 3. Classes 1 and 2 are what we con-sider mostly in compliance. Class 3 samplesare considered out of compliance. These are notsurveillance samples: they do not indicate thecondition of the industry. Frequently, the me-dia and other people will pick up on our sampleresults and claim that 20 percent of what theFDA looks at in the seafood industry is con-taminated. Where the misinformation occurs isin not understanding that these samples aretargeted. We do not have enough resources todo a strict surveillance-based sampling pro-gram to show the amount of compliance in theindustry. Our samples, both domestic and im-ported, are focused where we think there areproblems. Therefore, when people look at oursample results, they can get a false image ofwhat seafood looks like in the country.

We have a higher level of samples that weconsider violative in imports. I must empha-size that these are targeted samples. We targetour samples with nationwide alerts. If asample hits New York from a particular coun-try with something wrong, when that sameproduct from the same country hits Seattle, Isample it. That also includes automatic deten-tion, where a country has a reputation of giv-ing us bad products.

Because there is often confusion over whatthe FDA does, I’ll describe the steps of an FDAinspection. First, inspectors show up in yourplant and make an inspection. At the end ofthe inspection, they give you the 483 form,which is a list of observations. The law man-dates that we give you this list before we leave.Next, the inspector writes a report, which isreviewed by a supervisor, so it is not theinspector’s opinion that is going to affect you.There are several further steps before you getin trouble. The report is given to the supervi-sor, and the chief inspector, Jim Davis, takes itto the compliance branch. Our compliance of-ficers review it with national policy to see ifthere is a case. The compliance branch directorreviews it and then I, as district director, re-view any action. Only the OAI violations leaveour district and go to headquarters for the Of-fice of Enforcement review, in Washington,D.C. The general counsel are not Food andDrug employees, but employees of the Depart-

ment of Health and Human Services. The nextstep is to the U.S. Attorney. The FDA does nothave police powers; we can’t lock your doors.The FDA goes through the Justice Departmentto the federal courts before any actions aretaken. There are many steps and reviews be-fore FDA takes action against a firm.

The prohibited acts section of the Food andDrug Law is what applies to your products andthe acts are mandatory. You don’t have achoice in complying with these rules. The lawtalks about the introduction, adulteration, re-ceipt, and interstate commerce of adulteratedproducts. Good manufacturing practices(GMPs) are always going to be here becausethey are a part of the law. The hazard analysisand critical control points program (HACCP) issimply an augment to those GMPs to makethem tighter. I agree that we tend to focus onHACCP, but you can’t forget about GMPs.They are a part of the Food and Drug regula-tions. They are not being replaced by HACCP,they are simply being added.

The seafood complaints that the Seattle dis-trict gets today are the same complaints Iheard 20 years ago. We still see poor employeepractices, especially in moving raw materialthrough finished product areas; that can con-tribute to cross contamination. Employeesmove from one area to another without chang-ing clothes or sanitizing themselves beforeswitching from handling raw product to han-dling finished product. This is especially im-portant when you deal with ready-to-eatproducts where there is potentially Listeria orother pathogens.

Listeria is still a problem, especially in coldsmoked fish. The east coast is enmeshed inListeria from smoked fish. The district directorin New York is preparing many injunctionsagainst firms back there. Dr. Ecklund of theNational Marine Fisheries is on the east coastworking with the east coast industry. Listeriais not going to go away. People keep asking ifwe are going to abolish the zero tolerance level.As Tom Billy said, I do not see our changingthe tolerance on Listeria at all.

Two years ago, we started with the incidentof domoic acid in razor clams. The season wasessentially closed for the entire year. Now ev-eryone is out happily harvesting the largestrazor clams they’ve ever seen, so maybe therewas a good side to that. The next incident wasfinding domoic acid in crab viscera. We neverdid find any crab in interstate commerce fromWashington and Oregon that exceeded the tol-erance of 20 parts per million. We got close andhad some problems especially with exports to

The result of that was a meeting in Sanon domoic acid. This region hired a re-coordinator for domoic acid, actually for

all marine toxins, to try to coordinate what thestates were doing. We awarded state contractsto California, Washington, and Oregon to setup a more intricate monitoring system fordomoic acid, but it didn’t show up this year.Our hope for these systems is that we can closethe season if domoic acid shows up rather thanharvest the resource, or delay the opening o fthe season until the toxic levels go down.Through the work of the states and our seafoodcoordinator, we raised the tolerance for domoicacid in Dungeness crab viscera from 20 to 30parts per million. That same request is beingmade for paralytic shellfish poisoning in crabviscera.

Paralytic shellfish poisoning is the next is-sue. Alaska had a great deal of trouble withparalytic shellfish poisoning in Dungeness crabvicera again this year. We had product thathad to be eviscerated and sold as sectionsrather than as whole crab because of the toxinlevels in the viscera. Alaska has drafted amonitoring program whose goal is to monitorthat area and open and close the crab harvest-ing season to prevent crab with problems fromeven being harvested.

Last, I’d like to discuss the European Com-munity (EC). The FDA intends to issue certifi-cates to firms wishing to export to the EC. Theprotocol is being written and will be reviewedand distributed to industry and others for com-ments. You will apply to us to be placed on alist for exports to the EC. We will then reviewyour firm’s inspection records and, if appli-able, the records of your state agency or of theNational Marine Fisheries Service (NMFS). Ifnecessary, we may have to reinspect your plantto update our information. If you pass thesesteps, other than the VAI-3 or OAI category,we will put you on a list.

When You deal with the EC, you’ve got tohave a firm number, which you have alwayshad from the FDA, called a central file num-ber. We can give that list of numbers to theEC If you are on that list, you can submitfilled-out certificates to us. You are going tohave to give me an English version so that Ican understand what I am signing. After I sign,the certificate is returned to you to accompanythat shipment. I will not inspect those lots. Iwill sign that certificate based on the fact thatyou are on our list as an acceptable firm. Ifyour buyer wants additional quality attributesor you need to have additional inspections, you

are going to have to arrange for them in thesame way you always have, typically, by goingto NMFS and getting their lot certification forthe value added part. If you fail to make ourlist, your choice is probably to go to NMFS,sign up for their program, and pay for the ser-vice. Once you get upgraded, you can alwayscome back to us and ask to be reinstated.

This FDA program has to be resource neu-tral. I have no additional resources to run theprogram. If the inspection of your firm is notroutinely scheduled for six to eight monthsfrom now, then I will not visit your firm until I have it regularly scheduled. If you want to geton to EC, you are going to have to have someother authority come to me and show me thatyour firm is in compliance. That could be theAlaska Department of Environmental Conser-vation, the Oregon State Department of Agri-culture, the Washington State Department ofAgriculture, or NOAA, but if I have to make aninspection to get you on the list, it will be doneonly when I’m on my routine inspection.

You need to provide specific information.You should be able to describe the HACCP pro-gram for your firm. You must be site specific. Ifyou’re a company that has five firms, I have tohave a letter for each one of your sites becausethat is the way your firms appear in our filesright now. You also have to be product specific.You must provide a contact person for eachprogram. If you have five different plants, youcan give me one contact person, but that con-tact person should be knowledgeable aboutthose five sites. I also need to know what othergovernment agencies are inspecting you, likeyour state’s Department of Agriculture orNOAA, and when those inspections are madeand who is doing that in your plant. I don’tneed to know about the Occupational Safetyand Health Administration or the EPA. I sim-ply need to know about those that would begermane to shipping to the EC. I need permis-sion to look at those other records. This espe-cially applies to NMFS. When NMFS does aninspection in your plant, that is a contract be-tween you and them. Those records are be-tween you and them. They are not available tome unless you tell NMFS that I can look atthem.

Canned salmon has had the “canned salmoncontrol plan” for over 70 years. This is anagreement between industry, the FDA, theAlaska Department of Environmental Conser-vat ion and the National Food Processors Asso-ciation with their lab in Seattle. Everythingthat has been done under that plan is a

42

HACCP program, and we will sign certificates long as you’re in good standing under thatfor shipments of firms in good standing under plan, your canned salmon will get a certificatethat plan right now. That includes the past from the FDA.year’s production and current production. As

43

Christian FelterConsulting Agricultural Engineer, Nice, France

In this paper I discuss the current status ofquality certification in the French and Euro-pean markets. I focus on the organization ofFrench markets, using examples from the sea-food industry.

BACKGROUND

The French Market in EuropeThe French market has a dominant position

in Europe for all food products, whether des-tined for at-home or away-from-home con-sumption, for three main reasons:

1. French cuisine sets the internationalstandard for food preparation andpresentation.

2. France has developed a high level oftechnical knowledge of both innovationand tradition in human nutrition, ofwhich the invention of vacuum cookingby a student of the famous chefTroisgros is the best illustration.

3. The German market strongly prefers“French quality,” and Germany, in allmatters concerning the organization ofEuropean markets for food products, isvery receptive to French proposals.

Treaties, Directives, and RegulationsThe European Common Market is organized

around three levels of agreements with verydistinct functions:

1. The Treaty of Rome. This provides theconstitution. All regulations must be in strictconformity with the Rome Treaty. As withother constitutions, the treaty text is unknownto most of those in the business world. Its realsignificance is revealed in the legal decisions ofthe European Law Court, which constantly re-fer to it.

2. Directives. Directives are the directions orpositions established by the European Com-mission. These directions are not optional;each member state must set its national legis-lation in conformity with them. But in practice,national laws demonstrate a strong passiveresistance to these directives. In addition, it is

very often the jurisprudence of the EuropeanLaw Court which must determine preciselywhich modifications will be required. For in-stance, a member state is not permitted to ad-vertise the national origin of its products; thus,France is not allowed to build an advertisingcampaign with and about “qualité France.”The passive resistance of national law, every-day practice, and the threats and sanctions ofthe EC Commission combine to provide thecontext within which the directives becomeregulations.

3. Regulations. These are laws. Memberstates are given only the time period set by theregulation itself in which to make their ownlaws conform to these regulations. For this rea-son regulations encounter much less passiveresistance from national law and practice thando directives.

The Use of StandardsThe primary function of a standard is to pro-

vide security to transactions made over a dis-tance. It is the industrial world that hascontributed the most to the definition andpropagation of the standards that support andguarantee contractual relationships betweenfirms placing orders and those that carry themout, or their subcontractors. Inherent in astandard is reference to a sale contract, that is,the given commercial practice at a given timeconcerning the exchange of merchandise. Themerchandise itself functions as a support forthe system which allows the individuals con-cerned with the exchange to make the neces-sary profits.

In regard to human nutrition, the develop-ment of standards is much more recent, for twomain reasons. First, the definition of what con-stitutes human food is complex, with a strongcultural component. The constant change thatcharacterizes technology and culture presentsan ongoing challenge to this definition. Second,tradition is efficient, which is to say thatexpectations of “fair and customary use” pro-vide the main guarantee, at the national level,of the success of food products sales.

47

I should emphasize that the safety of a food(the first priority of every regulation) is onlythe first step toward consumer satisfaction,which is the real driving force behind every ex-change involving food products. Safety is animplicit expectation of consumers. But con-sumer expectations are evolving and vary fromone country to another, as do the methods ofsatisfying them. Since each market can refer,in good faith, to its own tradition of “fair andcustomary use,” a preoccupation with legalprotections has arisen in the competition be-tween EC members. In the hope of improvingcredibility and protection, economic partnerswill demand more and more sophisticatedproof of facts that support the fairness of alle-gations and the safety of common food uses.

Fundamental to understanding the currentevolution of the EC regulations concerningquality certification are the specific require-ments of human nutrition. It is equally impor-tant to keep in mind the essential function of astandard, whatever this standard might be: toprovide security to an economic transactionfrom a distance.

The "New Approach" and the Cassis deDijon Case

The requirement of free circulation of goodsbetween member states of the EC affects everyproduct. When the unifying act was signed, itwas technically impossible to define a full setof regulations guaranteeing free trade within ashort period. This is why the “New Approach”directives were adopted. These directives arelimited to the essentials, leaving the workingout of technical details to the standardizationprocess (or, as we shall discuss further, the“professional approach”). The object of havingthese directives come into force simultaneouslyin each national legal system is to set up an“automatic” harmonization process amongthese systems. The application schedule ofthese New Approach directives is determinedby the goods’ complexity, to allow time for con-cerned firms to gather correct information andto adapt their production processes to EC stan-dards.

The directive of 22 July 1991 (see appendix),fixing the sanitation regulations for productionand trade of seafood products, is typical of the"New Approach.” To make it easier for readersto understand the following discussion, I ad-vise them to take a break for a careful readingof this directive, integrating the informationprovided above before going on. (This advice isin fact a directive, since the contents of the

July 22 1991 directive will be referred to belowwithout further citation than the article num-ber).

At the same time as the New Approach wasdefining a method of harmonizing varioustypes of “fair and customary uses,” the outcomeof the Cassis de Dijon case nipped in the budthe protectionist tendencies embodied withinvarious national legal interpretations of "fairand customary use.” This case merits furtherexamination in order to elucidate the essentialcommon rights it established.

In the 1970s a German importer was re-fused authorization to import Cassis de Dijoninto Germany. The reason: the alcoholic con-tent of Cassis de Dijon is 18%, and only alco-holic beverages with a minimum alcoholiccontent of 32% are allowed to be called "Cassis"for sale in Germany. This national law con-formed to what was considered “fair and cus-tomary use” in the German market. Germanauthorities took the position commonly held byall member states at that time in cases not cov-ered by EEC regulations: a national law thatforbids the trade of a product, whether pro-cessed locally or imported, concerns EC prod-ucts too, as there should be no discriminationbetween the treatment of domestic and com-munity goods. The European Law Court re-futed this position by affirming that anyproduct legally processed and traded in one ofthe member states, must, in principle, be al-lowed in trade in every other member state.

This case set a precedent confirming one ofthe fundamental principles of the RomeTreaty: free circulation of goods. It further in-troduced an equivalence between the “fair andcustomary uses” of different member states. Inso doing it established an initial practice thatis the basis of the lowest common denominatorof the food trade: the less demanding “usage”must be allowed in as far as the relevant au-thority allows it.

The New Approach and the Cassis de Dijoncase established also, as a corollary, a clear re-sponsibility on the part of the processor as aprerequisite to any transaction. It is the estab-lishment of the processor’s credibility which isthe goal of the development of quality certifica-tion systems.

Defining Concepts: Competent AuthorityThe dictionary offers two different meanings

for the term quality:

1. what it is that makes a thing what it is(with reference to final uses)

2. the excellence inherent in something(with reference to ethical consider-ations)

Food consumers’ expectations can be basedon one or both of these concepts. Food technolo-gists and industry concern themselves prima-rily with the first concept; consumers andtraders with the second. The fact that the EC’s“competent authority” should be composed ofveterinary technicians (article 2 directive 91/493) provides a clear indication of the kind ofcertification expected from a firm: it consistsessentially of its capacity to organize and guar-antee the processes within the competentauthority’s charge (article 6 directive 91/493).

We now turn to the general context of firmcertification, or a firm’s quality assurance sys-tems, as an implicit element of the New Ap-proach to the approval of firms (article 7directive 91/493). As I will discuss later, theoversight of this implicit trend of EuropeanCommunity regulation is managed in Francethrough applications initiated by AFAQ (Asso-ciation Française pour l'Assurance Qualité).However, as a preamble, I must emphasizethat this is a trend and not a legal obligation.

We have already mentioned the effect of theinertia of national laws on EC directives. Thisis even more important in cases of quality as-surance applications, In such cases, the inertiais strengthened by the perverse effects of theCassis de Dijon case, which concerns de factothe former French colonies in Africa (throughthe Lomé convention), thus allowing very low-quality goods into the EC. Some French pro-cessors actually seek trade in such goods or usethem as inputs in their production processes todiversify their sources of profit. Several ex-amples of such behavior are famous on thecanned fish market, including sardines in oil,anchovy fillets, and canned tuna A good part ofthe turnover of this sector comes from low-quality product imported by small French pro-cessors and sold under their own brand names.

At the opposite end of the scale, large pro-cessors such as SAUPIQUET anticipated theevolution of the regulations and have alreadycertified their own quality assurance systemsto ISO 9000 standards. In fact, there is cur-rently a clear split between two categories ofoperators in France:

l firms that anticipated regulatoryevolution and are involved in certifica-tion of their quality assurance processes

l firms that are unaware of this evolutionor wish to profit from current regulatory

distortions of free competition and freecirculation of goods

Limits of the Current System: an Exampleof Regulatory Distortion

It is generally accepted that it is the largefirms that will be most concerned with certify-ing their quality assurance systems. The fol-lowing example concerns a large distributionfirm with a quality assurance program thattrades seafood products under its own brandname, imported from Denmark as fresh prod-ucts with a nine-month shelf life. There is cur-rently a strong demand in France for allseafood sold fresh, especially in the saurisserie,or smoked foods, department: smoked fish,taramas, snack products, fish fritters, andso on.

For products or meals prepared in advanceand sold as fresh, French regulations allowFrench processors to indicate, following preciseprocedures, a shelf life date of 21 days forvacuum cooked products and 42 days for pas-teurized products. Processors are not allowedto claim a shelf life of over 42 days for fresh orprocessed seafood (article 2 directive 91/493),except for “semiconserves.” For these products,the minimum shelf life is over two weeks, dueto the use of conservation techniques indicatedon the label. Danish products imported andtraded under this distributor’s brand name areeffectively sold in the fresh department as“semiconserves,” with instructions to keepthem at 8 degrees Celsius. Last year they weresold as canned.

This example and others are very wellknown among French processors, and some ofthem are actually trying to define new lines of“fresh canned products” for sale under the cur-rent regulatory loophole.

TOTAL QUALITY MANAGEMENT

IS0 9000 StandardsCertification of quality assurance systems

originated mainly within thecustomer-supplier relationship. A customer,having certain specifications for a product,would seek out suppliers who could meet thesespecifications and purchase only from thosesuppliers. Certificates attesting to the suppli-ers’ ability to meet specifications could begranted either by an independent organization(third-party certification) or directly by thebuyer or distributor (second-party certifica-tion). Various terms of reference can be used in

49

these two cases. In the case of third-party cer-tification, ISO 9000 standards are usuallyused, for easier recognition both of the certify-ing body specializing in these standards andfor the certified firm’s use in communicatinginternationally known references.

The definition of quality assurance in ISO9000 standards is as follows, roughly trans-lated into English: “the combination of prees-tablished and systematic actions necessary togive appropriate confidence that a product orservice will satisfy requirements related toquality,” these requirements being “the combi-nation of properties and characteristics of aservice or product which confer upon it theability to satisfy expressed or implicit needs.”

It must be noted that the notion of quality isdefined here in its wider sense, including allthe expectations of the concerned public, with-out specifying a particular level of quality. Itmust be emphasized as well that it is the firmitself which selects the set of preestablishedprocesses that are to be verified, processes thatwill be established through its own technicalexpertise in quality management. Also, it canonly be a voluntary effort, indicative of boththe firm’s management expertise and of thequality of production due to this management.The voluntary nature of this approach pre-sumes a clarity of objectives within the firmnecessary to mobilize the staff to realize theseobjectives.

Third-party certification of quality assur-ance systems under ISO 9000 thus functionsas a management tool attesting to a highly ef-fective level of management. It is this tool andthis level that give the processor credibility,even from a distance. The function of ISO 9000standards, like that of every set of standards,is effectively to give security to a transactionfrom a distance.

The Relationship Between Distributorsand Processors: Competent Authority andCurrent Developments in France

At the moment, most distributors who wantto distribute goods under their own brandname accord limited importance to third-partycertification of their quality assurance sys-tems, preferring their own controls to those ofan independent organization. The current levelof development of trade standards embodied indirective 91/493 allows distributors to imposecommercial pressure in the guise of second-party certification “standards,” at very low costto themselves. However, the inevitable trend is

toward independently imposed standards origi-nating with an international certification bodythat will ensure the independence of themanufacturer from the distributor of themanufacturer’s product. French processorsknow very well that without third-party ISO-9000 certification, they risk being submitted toarbitrary audits on the part of their foreigncustomers, which in some cases could be an ill-disguised effort to create barriers to free trade.

The best ally of the French processor, andthose in the EC or other countries, is the com-petent authority in France that deals withcommunity regulations: the state veterinaryservices. The veterinary services in charge ofhygiene and food safety in France are powerfuland efficient. Their actions are founded, ac-cording to “fair and customary use,” on allow-ing processors to be progressively moreresponsible for setting up and verifying qual-ity-control processes. This means that overall,French authorities have responded positivelyto the increasing complexity of productiontechniques (for example, “4th range” andvacuum cooking) and the rising level of qualityassurance requirements. From the beginning,the French have accepted the challenge of com-bining voluntary efforts and the legal obliga-tions put upon them by France and the EC.

Indeed, everyone - firms, administrators,and experts-knows that at the beginning, theprocess of firm certification will be long anddifficult, but that quality certification, thoughit is not a miracle drug, is the single best wayto meet the managerial needs inextricablylinked to the long-term satisfaction of consum-ers in developed nations.

The French Quality AssuranceAssociation (AFAQ) and the NationalTesting Network (RNE

Many industrial applications of quality as-surance certification led to the creation, in1988, of AFAQ, constituted by three “collèges”:

collège A: AFNOR and professional salesorganizations

collège B: buyerscollège C: technical controllersAFAQ certification, like every standardiza-

tion process, requires an interdisciplinary pro-fessional approach. AFAQ certification is basedon international standard practices:

l standard 45012 for a firm’s own manage-ment

l IS0 9000 standards applied to firms

. ISO 10011 standards for selection ofexperts

The final objective of this professional ortho-doxy is to facilitate agreements between andpartnerships with firms certified by otheranalogous certification centers, to improve therelationship between customers and suppliers.This kind of partnership already exists be-tween German, Canadian, and Swiss bodies.Although AFAQ has no ambition to take con-trol of international certification, it is clearthat all significant firm certification programscurrently being tested in France are aimed to-ward achieving AFAQ certification.

Created in 1979, th Rèse a u Nationald’Essais (National Testing Network) managesaccreditation of laboratories to the EN 45001standard according to detailed requirementsfor accredited laboratories and candidates foraccreditation. Accreditation of a laboratory isthe formal recognition of its ability to under-take specified tests and to ensure the quality ofthese tests. The political purpose of the RNE isto set up a network of similar organizations inother countries to establish more consistentstandards between competent authorities.

Food SecurityIt is not by chance that the food security

theme accompanied the complete set of com-mon agricultural policy reforms. The entirepolicy was systematically linked to the estab-lishment of professional strategies in qualitycertification, in all sectors. It is not possible tolimit the free circulation of goods and services,but the increasing concern with health andsafety by consumers in developed countriesgoes hand in hand with the increasing chal-lenge to firms in developed countries to main-tain their market positions. Certification ofquality assurance systems is clearly the key tofuture access to EC markets for firms in devel-oped countries.

TOTAL QUALITY PRODUCT

Specialty FoodsCertification systems for quality assurance

mainly concern large industrial firms of theagro-food sector, producing goods for massconsumption. But many French producersfamous for the quality of their product are verysmall firms, often "artisan" sized. This isparticularly true for such products as wines,cheeses, poultry, red meat, pork specialties,

and regional specialties such as Cassoulet deCastelnaudary.

At the national level, these specialty proprod-ucts are subject to a double set of consumer- recognized certifications:

g a certificate of higher quality indicated bythe authorization to stamp the productLabel Rouge (Label Rouge is a nationalcollective brand name for higher qualityfoods; in French the word label connotesquality and not information requirements)

o a certificate of regional specialty attestedto by the indication Appellation d'OrigineContr ô lée (specified origin label or AOC).

Usually, certification by one of these meth-ods precludes certification by the other, andthus products given the Appellation d'OrigineContrôlée would not also be certified with theLabel Rouge. The Appellation d'OrigineContrôlée is reserved for products or processesgiving proof of a strong historic tradition andprecedence in setting a special or high-qualitystandard. The Appellation d'Origine Contrôléeconcerns mainly wines and cheeses. Qualityhere refers essentially to bioclimatic conditionsor traditional, often secret, technicalknowledge.

Label Rouge concerns any superior-qualityproduct. In order to be granted this label, aproducer must adhere to precise terms of refer-ence, explaining what differentiates it from ge-neric products and justifying its higher price.Proof must be offered that this product of su-perior quality is produced in significant quan-tity (this was the main issue of contention inproviding Scottish salmon with the LabelRouge).

The terms of reference for foods certifiedwith the Label Rouge are public. The registra-tion of these terms of reference is done by anindependent certification organization usingthe 45011 standard. So, for products certified“Label Rouge,” our general definition of qualityis met: the following of preestablished proce-dures, with verification.

As this was not necessarily the case for Ap-pellation d'Origineorigine Contrôlée there has for along time been a kind of philosophical opposi-tion between the approaches followed by theInstitut National des Appellations d'Origineorigine(which focuses on tradition and French art devivre) and the Commission Nationale des La-bels (which focuses on consumer expectations).Each of these organizations has been lobbyingBrussels for at least five years to publish

directives or rules allowing it to determine theprofessional methods for certifying the qualityof foods at the EEC level.

The Rule of 14 July 1992 on Agro-FoodSpecialties and the Rule of 14 July 1992on Protection of Geographic Indicationsand Origin Appellations of Food Products

Rather than choose between the methodsproposed by the two organizations, the EECCommission permitted both, with these twoclosely related rules. The rule about food spe-cialties is no more than the elevation to the EClevel of the French Label Rouge. However “spe-cialty,” in the rule, is not limited to superiorquality for this type of product. Further, theharmonizing of the EEC register of recognizedspecialties between member states and pro-ducer groups has been difficult and complex,although the register has been adapted tochanges in the terms of reference on whichspecialties are based. And, in order to main-tain superior-quality levels, these changes arestrictly necessary.

The rule about protected geographic indica-tions mentions terms of reference as well (ar-title 4 of the rule), explicitly the “description ofthe method of obtaining the agricultural orfood product, and where relevant the fair andcustomary practices.”

These two rules have two points in common:l the professional character of each

method, managed by concerned profes-sional groups

l the obligation of every member of theprofessional group to submit to thecontrol of an independent certificationbody using the 45011 standard, valid to1998 at the latest

Standard EN 45011 specifies criteria thatmust be met by a certification organization be-fore the certification of products, in order to berecognized at the EC level as competent andreliable to set up such a certification system,whatever the concerned sector might be. The1998 limit date on anything concerning the45011 standard of certifying organizations forfood specialties and origin appellations is con-nected with article 17 of directive 91/493

The Redeployment of ProfessionalOrganizations

These two rules will come into force nextJuly and will certainly allow a new deployment

of the largest French professional organiza-tions, which have been crippled for a long timebecause of the illegal origin of their income(national obligatory parafiscal taxes). Indeed,there are strong similarities between the objec-tives of professional organizations and those ofcertification organizations.

In France, the goals of agro-food trade orga-nizations are those which the individual firmcannot assume alone, including

0 collective research and development0 collective promotion and advertisinge procedures and controls

These are also the goals of certification orga-nizations dealing with producers who have al-ready achieved the 45011 standards as well asthose who have attained the “Label Rouge.”

The Challenge for “Peripheral”Agriculture

A few years ago, there was a clear distinc-tion between the “agro-industrial,” or profit-making agricultural sector (milk, corn, and soon), and agricultural products from the periph-eral regions, especially from the Mediterra-nean zone. At that time food security strategiesconcerned production only in these peripheralzones, while other producers had to compete ininternational markets around the world.

Recent developments show that this as-sumption was mistaken and that food securitystrategies concern the entire Europeanagro-industrial sector. In this context it wasimperative to immediately develop effectivetools (rules) which would allow differentialmarketing for products from peripheral zones.Putting these rules into practice will be just asimportant as putting into place the new regu-lations tied to the common agricultural policy.

Perspectives for Other CountriesIt is likely that the application of these two

rules will be extended to agro-food products ofnon-EC states that are able to guarantee qual-ity assurance practices equivalent to those inthe EC and in which the competent certifyingauthority meets 45011 standards. These regu-lations could provide an excellent and usefultool for third-country professional groups tomeet quality challenges, by furthering theirunderstanding of the current evolution of ECfood product quality management practices.

COUNCIL DIRETTIVE

of 22 July 1991

laying down the health conditions for the production and the placingon the market of fishery products

(91/493/EEC)

THE COUNCIL OF THE EUROPEAN COM-MUNITIES,

Having regard to the Treaty establishing theEuropean Economic Community, and inparticular Article 43 thereof,

Having regard to the proposals from theCommission (1),

Having regard to the opinions of the EuropeanParliament (2),

Having regard to the opinions of the Economicand Social Committee (3),

Whereas, with a view to achieving the internalmarket and more especially to ensuring thesmooth operation of the common organizationof the market in fishery products establishedby Regulation (EEC) No 3796/81 (4), as lastamended by Regulation (EEC) No 2886/89 (5),it is essential that the marketing of fish andfish products should no longer be hindered bydisparities existing in the Member States inrespect of health requirements; whereas thiswill enable production and placing on themarket to be better harmonized and bringabout competition on equal terms, whilstensuring quality products for the consumer;

Reprinted with permission of the EuropeanCommunities from the Official Journal of theEuropean Communities, L 268,24.9.91, p 15.

OJ No C 66 , 11.3. 1988, p. 2;OJ No C 282,8.11.1989 p. 7 and OJ No C 84,2.4. 1990, p. 56.OJ No C 96,17.4.1989, p. 29 and OJ No C183,15. 7. 1991.OJ No C 134,24.5.1988, p. 31 and OJ No C332,31. 12. 1990, p. 59.OJ No L 379, 31. 12. 1981, p. 1.OJ No L 282,2. 10. 1989, p. 1.

Whereas the European Parliament in itslegislative resolution of 17 March 1989 (6)requested the Commission to come forwardwith comprehensive proposals on the hygienicproduction and placing on the market offishery products, including solutions for theproblem of nematodes;

Whereas fishery products freshly caught are inprinciple free of contamination with micro-organisms; whereas however contaminationand subsequent decomposition may occurwhen handled and treated unhygienically;

Whereas therefore the essential requirementsshould be laid down for the correct hygienichandling of fresh and processed fishery prod-ucts at all stages of production and duringstorage and transport;

Whereas it is appropriate to apply by analogycertain marketing standards which are laiddown pursuant to Article 2 of Regulation(EEC) No 3796/81, in order to fix the healthquality of these products;

Whereas it is the responsibility primarily ofthe fisheries industry to ensure that fisheryproducts meet the health requirements laiddown in this Directive;

Whereas the competent authorities of theMember States must, by carrying out checksand inspections, ensure that producers andmanufacturers comply with the said require-ments;

Whereas Community control measures shouldbe introduced to guarantee the uniform

~__(6) OJ No C 96, 17.4. 1989, p. 199.

53

application in all Member States of the stan-dards laid down in this Directive;

Whereas, in order to ensure the smoothoperation of the internal market, the measuresshould apply in an identical manner to tradewithin the Member States and to trade be-tween the Member States;

Whereas in the context of intra-Communitytrade, the rules laid down in Council Directive89/662/EEC of 11 December 1989 concerningveterinary checks in intra-Community tradewith a view to the completion of the internalmarket (7) as amended by Directive 90/675/EEC (8) apply to fishery products;

Whereas fishery products from third countriesintended to be placed on the market of theCommunity must not qualify for morefavourable arrangements than those applied inthe Community; whereas provision shouldtherefore be made for a Community procedurefor the inspection in third countries of theconditions of production and placing on themarket in order to permit the application of acommon import system based on conditions ofequivalence;

Whereas the products in question are subjectto the rules concerning checks and to safe-guard measures covered by Council Directive90/675/EEC of 10 December 1990 laying downthe principles governing the organization ofveterinary checks on products entering theCommunity from third countries;

Whereas, so that account may be taken ofparticular circumstances, derogations shouldbe granted to some establishments alreadyoperating before 1 January 1993 so as to allowthem to adapt to all the requirements laiddown in this Directive;

Whereas the Commission should be entrustedwith the task of adopting certain measures forimplementing this Directive; whereas, to thatend, procedures should be laid down introduc-ing close and effective cooperation between theCommission and the Member States withinthe Standing Veterinary Committee;

(7) OJ No L395,30.12.1989,p.13.(8) OJ No L 373,31.12.1990,p.1.

Whereas the essential requirements laid downin this Directive may need further specifica-tion,

HAS ADOPTED THIS DIRECTIVE

CHAPTER 1

General provisions

Article 1

This Directive lays down the health conditionsfor the production and the placing on themarket of fishery products for human con-sumption.

Article 2

For the purposes of this Directive, the follow-ing definitions shall apply:

1.

2.

3.

4.

'fishery products’ means all seawater orfreshwater animals or parts thereof,including their roes, excluding aquaticmammals, frogs and aquatic animalscovered by other Community acts;

‘aquaculture products’ means all fisheryproducts born and raised in controlledconditions until placed on the market as afoodstuff However seawater or freshwa-ter fish or crustaceans caught in theirnatural environment when juvenile andkept until they reach the desired commer-cial size for human consumption are alsoconsidered to be aquaculture products.Fish and crustaceans of commercial sizecaught in their natural environment andkept alive to be sold at a later date are notconsidered to be aquaculture products ifthey are merely kept alive without anyattempt being made to increase their sizeor weight;

‘chilling’ means the process of coolingfishery products to a temperature ap-proaching that of melting ice;

“fresh products’ means any fishery productwhether whole or prepared, includingproducts packaged under vacuum or in amodified atmosphere, which have notundergone any treatment to ensurepreservation other than chilling;

5.

6.

7.

8.

9.

10.

11.

12.

13.

‘prepared products’ means any fisheryproduct which has undergone an opera-tion affecting its anatomical wholeness,such as gutting, heading, slicing, filleting,chopping, etc.;

‘processed products’ means any fisheryproduct which has undergone a chemicalor physical process such as the heating,smoking, salting, dehydration or marinat-ing, etc., of chilled or frozen products,whether or not associated with otherfoodstuffs, or a combination of thesevarious processes;

'preserve' means the process wherebyproducts are packaged in hermeticallysealed containers and subjected to heattreatment to the extent that any micro-organisms that might proliferate aredestroyed or inactivated, irrespective ofthe temperature at which the product isto be stored;

'frozen products’ means any fisheryproduct which has undergone a freezingprocess to reach a core temperature of -18°C or lower after temperature stabiliza-tion;

‘packaging’ means the procedure ofprotecting fishery products by a wrapper,a container or any other suitable device;

‘batch’ means the quantity of fisheryproducts obtained under practicallyidentical circumstances;

‘consignment’ means the quantity offishery products bound for one or morecustomers in the country of destinationand conveyed by one means of transportonly;

‘means of transport’ means those parts setaside for goods in automobile vehicles, railvehicles and aircraft, the holds of vessels,and containers for transport by land, seaor air;

‘competent authority’ means the centralauthority of a Member State competent tocarry out veterinary checks or any author-ity to which it has delegated that compe-tence;

14.

15.

16.

17.

18.

1.

‘establishment’ means any premiseswhere fishery products are prepared,processed, chilled, frozen, packaged orstored. Auction and wholesale markets inwhich only display and sale by wholesaletakes place are not deemed to be estab-lishments;

‘placing on the market’ means the holdingor displaying for sale, offering for sale,selling, delivering or any other form ofplacing on the market in the Community,excluding retail sales and direct transferson local markets of small quantities byfishermen to retailers or consumers,which must be subject to the healthchecks laid down by national rules forchecking the retail trade;

‘importation’ means the introduction intothe territory of the Community of fisheryproducts from third countries;

‘clean seawater’ means seawater or brinywater which is free from microbiologicalcontamination, harmful substances and/ortoxic marine plankton in such quantitiesas may affect the health quality of fisheryproducts and which is used under theconditions laid down in this Directive;

‘factory vessel’ means any vessel on whichfishery products undergo one or more ofthe following operations followed bypackaging: filleting, slicing, skinning,mincing, freezing or processing.

The following are not deemed to befactory vessels’:

- fishing vessels in which only shrimpsand molluscs are cooled on board,

- fishing vessels on board which onlyfreezing is carried out.

Article 3

The placing on the market of fisheryproducts caught in their natural environ-ment shall be subject to the followingconditions:

(a) they must have:

55

(i) been caught and whereappropriate handled forbleeding, heading, gutting andthe removal of fins, chilled orfrozen, on board vessels inaccordance with hygiene rulesto be established by theCouncil acting by a qualifiedmajority on a proposal fromthe Commission. The Commis-sion shall submit proposals tothat effect before 1 October1992;

(ii) where appropriate, beenhandled in factory vesselsapproved in accordance withArticle 7, and in accordancewith the requirements ofChapter I of the Annex.

The cooking of shrimps andmolluscs on board mustcomply with the provisions ofChapter III, section I(5), orChapter IV, section IV(7), ofthe Annex. Such vessels shallbe specifically registered bythe competent authorities;

(b) during and after landing they must (b) they must, in addition, comply withhave been handled in accordance the requirements laid down under 1with Chapter II of the Annex; (c) to (g).

(c) they must have been handled and,where appropriate, packaged,prepared, processed, frozen, de-frosted or stored hygienically inestablishments approved in accor-dance with Article 7, in compliancewith the requirements of ChaptersIII and IV of the Annex.

The competent authority may,notwithstanding Chapter II, section2 of the Annex, authorize the trans-fer of fishery products ex quay intocontainers for immediate delivery toan approved establishment orregistered auction or wholesalemarket to be checked there;

(d) they must have undergone a healthcheck in accordance with Chapter Vof the Annex;

56

(e)

(f)

(g)

they must have been appropriatelypackaged in accordance with Chap-ter VI of the Annex;

they must have been given anidentification mark in accordancewith Chapter VII of the Annex;

they must have been stored andtransported under satisfactoryconditions of hygiene, in accordancewith Chapter VIII of the Annex.

2. Where gutting is possible from a technicaland commercial viewpoint, it must becarried out as quickly as possible after theproducts have been caught or landed.

3. The placing on the market of aquacultureproducts shall be subject to the followingconditions:

(a) they must have been slaughteredunder appropriate conditions ofhygiene. They must not be soiledwith earth, slime of faeces. If notprocessed immediately after havingbeen slaughtered, they must be keptchilled;

4. (a) The placing on the market of livebivalve molluscs shall be subject to therequirements laid down in CouncilDirective 91/492/EEC of 15 July 1991laying down the health conditions for theproduction and the placing on the marketof live bivalve molluscs (1).

(b) When processed, bivalve molluscsmust, in addition to the requirements inpoint (a), satisfy those of paragraph 1 (c)to (g).

Article 4

Fishery products to be placed on the marketalive shall at all times be kept under the mostsuitable survival conditions.

(1) See page 1 of this Official Journal.

Article 5

The placing on the market of the followingproducts shall be forbidden:

- poisonous fish of the following families:Tetraodontidae, Molidae, Diodontidae,Canthigasteridae,

- fishery products containing biotoxins suchas ciguatera toxins or muscle-paralysingtoxins.

Detailed requirements concerning the speciescovered by this Article and concerning methodsof analysis shall be laid down in accordancewith the procedure prescribed in Article 15.

Article 6

1. Member States shall ensure that personsresponsible for establishment take all neces-sary measures, so that, at all stages of theproduction of fishery products, the specifica-tions of this Directive are complied with.

To that end, the said persons responsible mustcarry out their own checks based on thefollowing principles:

- identification of critical points in theirestablishment on the basis of the manufac-turing processes used;

- establishment and implementation ofmethods for monitoring and checking suchcritical points;

- taking samples for analysis in an approvedlaboratory by the competent authority forthe purpose of checking cleaning anddisinfection methods and for the purpose ofchecking compliance with the standardsestablished by this Directive;

- keeping a written record or a recordregistered in an indelible fashion of thepreceding points with a view to submittingthem to the competent authority. Theresults of the different checks and testswill in particular be kept for a period of atleast two years.

2. If the results of own checks or any infor-mation at the disposal of the persons respon-

sible referred to in paragraph 1 reveal the riskof a health risk or suggest one might exist andwithout prejudice to the measures laid down inthe fourth subparagraph of Article 3 (1) ofDirective 89/662/EEC, the appropriate mea-sures shall be taken, under official supervision.

3. Rules for the application of the secondsubparagraph of paragraph 1 shall be estab-lished in accordance with the procedure laiddown in Article 15.

Article 7

1. The competent authorities shall approveestablishments once they have verified thatthese establishments meet the requirements ofthis Directive, with regard to the nature of theactivities they carry out. The approval must berenewed if an establishment decides to carryout activities other than those for which it hasreceived approval.

The competent authorities shall take thenecessary measures if the requirements ceaseto be met. To this end, they shall take particu-lar account of the conclusions of any checkcarried out in accordance with Article 8.

The competent authority shall register thoseauction and wholesale markets which are notsubject to approval after verifying that suchinstallations comply with the provisions of thisDirective.

2. However, subject to the express conditionthat products coming from factory-vessels andestablishments, auction and wholesale mar-kets meet the hygiene standards set by thisDirective, Member States may, for the require-ments relating to equipment and structureslaid down in Chapters I to IV to the Annex,grant to factory-vessels and establishments,auction and wholesale markets a furtherperiod expiring on 31 December 1995 withinwhich to comply with the conditions of ap-proval set out in Chapter IX. Such derogationsmay be granted only to factory-vessels andestablishments, auction and wholesale mar-kets, already operating on 31 December 1991,which have, before 1 July 1992, submitted aduly justified application for derogation to thecompetent national authority. This applicationmust be accompanied by a work plan andprogramme indicating the period within which

57

it would be possible for them to comply withthe requirements in question. Where financialassistance is requested from the Community,only requests in respect of projects complyingwith the requirements of this Directive can beaccepted.

3. The competent authorities shall draw up alist of their approved establishments, each ofwhich shall have an official number.

Each Member State shall notify the Commis-sion of its list of approved establishments andof any subsequent amendment thereof. TheCommission shall forward this information tothe other Member States.

4. The inspection and monitoring of estab-lishments shall be carried out regularly underthe responsibility of the competent authority,which shall at all times have free access to allparts of establishments, in order to ensurecompliance with the requirements of thisDirective.

If such inspections and monitoring reveal thatthe requirements of this Directive are notbeing met, the competent authority shall takeappropriate action.

5. Paragraphs 1,3 and 4 shall also apply inrespect of factory vessels.

6. paragraphs 3 and 4 shall also apply towholesale and auction markets.

Article 8

1. Experts from the Commission may, incooperation with the competent authorities ofthe Member States, make on-the-spot checksinsofar as this is necessary to ensure theuniform application of this Directive. Theymay in particular verify whether establish-ments are in effect complying with the require-ments of this Directive. A Member State inwhose territory a check is being carried outshall give all necessary assistance to theexperts in carrying out their duties. Thecommission shall inform the Member States ofthe results of the investigations.

2. The arrangements for implementingparagraph 1 shall be adopted in accordancewith the procedure laid down in Article 15.

Article 9

1. The rules laid down in Directive 89/662/EEC, as regards fishery products intended forhuman consumption, shall apply, in particularas regard the organization of and the action tobe taken following the inspections to be carriedout by the Member States of destination, andthe protective measures to be implemented.

2. Directive 89/662/EEC shall be amended asfollows:

(a) in Annex A the following indent shallbe added:

'- Council Directive 91/493/EEC of22 July 1991 laying down thehealth conditions for the produc-tion and placing on the marketof fishery products (OJ No L 268,24.9. 1991, p. 15);

(b) in Annex B the following indent shallbe deleted:

'- fishery products intended forhuman consumption’.

CHAPTER II

Imports from third countries

Article 10

Provisions applied to imports of fishery prod-ucts from third countries shall be at leastequivalent to those governing the productionand placing on the market of Communityproducts.

Fishery products caught in their naturalenvironment by a fishing vessel flying the flagof a third country must undergo the checkslaid down in Article 18 (3) of Directive 90/675/EEC.

Article 11

1. For each third country or group of thirdcountries, fishery products must fulfil thespecific import conditions fixed in accordancewith the procedure laid down in Article 15,depending on the health situation in the thirdcountry concerned.

2. In order to allow the import conditions tobe fixed, and in order to verify the conditions ofproduction, storage and dispatch of fisheryproducts for consignment to the Community,inspections may be carried out on the spot byexperts from the Commission and the MemberStates.

The experts of the Member States who are tobe entrusted with these inspections shall beappointed by the Commission acting on aproposal from the Member States.

These inspections shall be made on behalf ofthe Community, which shall bear any expendi-ture incurred.

The frequency of and procedure for theseinspections shall be determined in accordancewith the procedure laid down in Article 15.

3. When fixing the import conditions offishery products referred to in paragraph 1,particular account shall be taken of:

(a) the legislation of the third country;

(b) the organization of the competent author-ity of the third country and of its inspectionservices, the powers of such services and thesupervision to which they are subject, as wellas their facilities for effectively verifying theimplementation of their legislation in force;

(c) the actual health conditions during theproduction, storage and dispatch of fisheryproducts intended for the Community;

(d) the assurances which a third country cangive on the compliance with the standards laiddown in Chapter V of the Annex.

4. The import conditions referred to inparagraph 1 shall include:

(a) the procedure for obtaining a healthcertificate which must accompany consign-ments when forwarded to the Community;

(b) the placing of a mark identifying thefishery products, in particular with the ap-proval number of the establishment of origin,except in the case of frozen fishery products,landed immediately for canning and bearingthe certificate provided for under (a);

(c) drawing up a list of approved establish-ments and auction or wholesale marketsregistered and approved by the Commission inaccordance with the procedure laid down inArticle 15;

For that purpose, one or more lists of suchestablishments shall draw up on the basis of acommunication from the competent authoritiesof the third country to the Commission. Anestablishment may not appear on a list unlessit is officially approved by the competentauthority of the third country exporting to theCommunity. Such approval shall be subject toobservance of the following requirements:

- compliance with requirements equivalentto those laid down in this Directive,

- monitoring by an official inspectionservice of the third country.

5. The conditions referred to in paragraph 4(a) and (b) may be modified in accordance withthe procedure laid down in Article 15.

The list referred to in paragraph 4 (c) may beamended by the Commission, in accordancewith the rules established by CommissionDecision 90/13/EEC (1).

6. To deal with specific situations and inaccordance with the procedure laid down inArticle 15, imports may be authorized directfrom an establishment or factory vessel of athird country where the latter is unable toprovide the guarantees laid down in paragraph3, provided that the establishment or factoryvessel in question has received special ap-proval following an inspection carried out inaccordance with paragraph (2). The authoriza-tion decision shall fix the specific importconditions to be followed for products comingfrom that establishment or factory vessel.

7. Pending the fixing of the import conditionsreferred to in paragraph 1, the Member Statesshall ensure that the conditions applied toimports of fishery products from third coun-tries shall be at least equivalent to thosegoverning the production and placing on themarket of Community products.

-_I(l) OJ No L 8,11. 1. 1990, p. 70.

59

Article 12

1. The rules and principles laid down byDirective 90/675/EEC shall apply, notably asregards the organization of and follow up tothe inspections to be carried out by the Mem-ber States.

2. Without prejudice to compliance with therules and principles referred to in paragraph 1of this Article and pending implementation ofthe decisions provided for in Article 8 (3) andArticle 30 of Directive 90/675/EEC, and inArticle 11 of this Directive the relevant na-tional rules for applying Article 8 (1) and (2) ofthe said Directive shall continue to apply.

CHAPTER III

Final Provisions

Article 13

The Annexes shall be amended by the Council,acting by a qualified majority on a proposalfrom the Commission.

Article 14

The Commission, after consulting the MemberStates, shall by 1 July 1992 submit a report tothe Council concerning the minimum struc-tural and equipment requirements to be metby small establishments which distribute onthe local market and are situated in regionssubject to particular supply constraints,together with any proposals, on which theCouncil, acting under the voting procedure laiddown in Article 43 of the Treaty, shall actbefore 31 December 1992.

Article 15

1. Where the procedure laid down in thisArticle is to be followed, the Chairman shallrefer the matter to the Standing VeterinaryCommittee set up by Decision 68/361/EEC (2)hereafter referred to as the Committee, eitheron his own initiative or at the request of aMember State.

2. The representative of the Commissionshall submit to the committee a draft of the

(2) OJ No L 255, 18. 10. 1968, p. 23.

measures to be taken. The committee shalldeliver its opinion on the draft within a timelimit which the chairman may lay downaccording to the urgency of the matter. Theopinion shall be delivered by the majority laiddown in Article 148 (2) of the Treaty in thecase of decisions which the Council is requiredto adopt on a proposal from the Commission.The votes of the representatives of the MemberStates within the committee shall be weightedin the manner set out in that Article. Thechairman shall not vote.

3. (a)

(b)

The Commission shall adopt themeasures envisaged if they are inaccordance with the opinion of thecommittee.

If the measures envisaged are not inaccordance with the opinion of thecommittee, or if no opinion is delivered, the Commission shall, withoutdelay, submit to the Council a proposal relating to the measures to betaken. The Council shall act by aqualified majority.

If, on the expiry of a period of threemonths from the date of referral tothe Council, the Council has notacted, the proposed measures shall beadopted by the Commission, savewhere the Council has decidedagainst the said measures by a simplemajority.

Article 16

In order to take into account the possiblefailure to take a decision on the detailed rulesfor applying this Directive by 1 January 1993,necessary transitional measures may beadopted in accordance with the procedure laiddown in Article 15 for a period of two years.

Article 17

The provisions of this Directive shall be re-examined before 1 January 1998 by theCouncil, acting on proposals from the Commis-sion, on the basis of experience gained.

Article 18

The Member States shall bring into force thelaws, regulations and administrative provi-sions necessary to comply with this Directivebefore 1 January 1993. They shall notify the

Commission thereof.

When Member States adopt these measures,they shall contain a reference to this Direc-tive or shall be accompanied by such refer-ence on the occasion of their official publica-tion. The methods of making such a referenceshall be laid down by the Member States.

Article 19

This Directive is addressed to the Memberstates.

Done at Brussels, 22 July 1991.

For the CouncilThe PresidentP. DANKERT

Robert JosephRed Lobster, Orlando, Florida

General Mills Restaurants Inc. is a division ofGeneral Mills. General Mills is the “Companyof Champions." Each division operates underthe company goal statement, "To be thenation’s best food company in terms of productquality and shareholder value.”

Consumer Foods makes up 67 percent ofcompany sales and earnings. Most of the majorbrands are common household items that youand your family use all the time.

The restaurant group makes up the other 33percent of sales and earnings. The Red Lobstername is General Mills’ largest brand.

With sales of over $1.5 billion this year, RedLobster will serve over 150 million guests. RedLobster is the largest dinnerhouse chain in theworld. The second largest is Olive Garden,with sales of over $900 million. The newestconcept is China Coast Restaurant, with fiveunits and ambitious goals to be as large as itssister companies. Asian food is the fastestgrowing segment of dining occasions in theU.S. By the year 2000, three out of the twenty-one meals you eat each week will be Asian.

Projected growth for all three chains is forover 50 units per concept in the next few years.General Mills believes that restaurants will bea critical part of its projected growth plans. Bythe year 2000, the goal is to have over 2000restaurants worldwide.

The restaurant industry is very competitive.Currently, there is over 55 percentovercapacity in seating. The hardest hit seg-ment is fine dining, but all segments are hav-ing trouble maintaining their market shareand traffic.

General Mills restaurants will use over 85million pounds of frozen seafood this year.Forty-two percent will be shrimp products, 18percent crab products, 17 percent fish fillets,10 percent lobster, and 13 percent other shell-fish and seafood products. We will also serveover 5 million pounds of fresh fish and 1.5 mil-lion pounds of live lobster. By the year 2000,our seafood needs will double to over 170 mil-lion pounds.

Not only are our seafood needs growing, butso are the needs of most dining segments.There has been a 4 percent increase in thenumber of restaurants serving seafood. This

shows that America still prefers to eat seafoodaway from home. But even as U.S. consump-tion has turned down, so has consumption atrestaurants. However, restaurants are usingseafood to offer healthy alternatives to theirguests. The American pallet has changed inrecent years. Variety sells, and people aremore wilIing to experiment with different typesof foods when dining out.

The history of the departments of Purchas-ing and Quality Control started at the sametime. The founders of the company realizedback in the early 1970s that the limiting factorto growing Red Lobster into a national chainthe size it is today would be the supply of high-quality, value-priced seafood. The founders be-lieved that these two traits, plus great servicein a clean, efficient restaurant, would be thekey to success.

In the early seventies we were buyingthrough brokers and distributors. The qualityof the products varied greatly. Supply was in-consistent and prices were unpredictable. Sothe decision was made to create a purchasingdepartment. Today the purchasing departmenttravels to over 40 countries a year. Our buyersspend over 50 percent of their time at the pro-ducing areas and production facilities whereour products are harvested and packaged. Buy-ers spend time training in their products sothat they can travel anywhere in the world andteach fishers, production workers, and plantquality control personnel how to produce RedLobster quality. Over 70 percent of our seafoodcomes from overseas. One hundred percent ofour shrimp now comes from aquaculture. Nomatter where the resource is, our buyers arewilling to go and learn about what this area ofthe world can offer our guests. We continue touse some brokers and importers who under-stand our needs and philosophy of quality,value, and service.

Marketing supplies Purchasing with chang-ing trends in dining patterns and guest expec-tations. Purchasing plays a large role indeveloping new products and species and intro-ducing value added products to save on back ofthe house labor. Today every item is made ateach restaurant daily to ensure that our food isfresh and that our guests receive only the

highest quality seafood they can buy. It is aconstantly changing environment, and whatwas good enough yesterday will not meet theneeds or standards of today. By having an in-ternal purchasing and quality control function,it has been easier to communicate neededchanges to industry so that we can maintainour competitive edge.

By having the buying team visit the world’sseafood-producing areas, we have been able toanticipate shortages, embargoes, and foreigncompetition that can drive price. Our menuand promotions are flexible, so we can worktogether with marketing to smooth out supplyor price problems. Years ago when McDonaldsput Pandalus shrimp on the menu and pricesreached over $5.00 a pound, we were forced toreduce our usage from 3 million pounds toabout 100,000 pounds. Now that the price hasreturned to a more stable level, our usage hasincreased to about 750,000 pounds. But itnever gained its place completely back becausethe product we substituted continues to occupythat space and popularity. This year we substi-tuted Dungeness crab for Opilio when supplyand price became issues. On every trip we lookfor new ideas, products, or items. People forgetthat it was Red Lobster that introducedAmerica to snow crab, popcorn shrimp, andorange roughy. This conference is an exampleof taking the opportunity to talk to industryabout our company and to explore with thisindustry mutual areas of interest and potentialbusiness.

All our specifications are developed by ourPurchasing Department with advice from in-dustry. Before they are written up, RestaurantOperations and Test Kitchen approve them tomake sure that our restaurants are receivingthe correct product, properly packaged, andwith maximum ease of use.

Once a specification is developed, productsare shipped to one of our primary freezer loca-tions (Atlanta, Los Angeles; Indianapolis;Trenton, Ontario). At each of these facilities,we have built quality control labs to inspectevery shipment of seafood and other products.These labs are set up to evaluate packagingand physical characteristics and to checkmicrolevels. No product ever is sent to one ofour restaurants before it is inspected. Countsand weights are checked to ensure we pay forwhat we ordered and they meet our specifica-tions.

Specifications address chemical additives,acceptable species, receiving temperatures,and other defects that could be seen with eachindividual product. Most of our specificationsare stricter and more detailed than currentgovernment standards. They have been devel-oped with industry so that what we inspect foris what industry can produce and package. Weown our own shrimp processing plant, whichenables us to understand that side of the busi-ness and teaches us what we should expectfrom other processing facilities. Our specifica-tions are available for anyone to use.

During the late 1980s there were a numberof seafood scares and bad publicity. To head offthe issue that seafood was not government in-spected, we worked with the U.S. Departmentof Commerce to have our inspection programcertified. Our Integrated Lot Inspection Pro-gram has been very successful in that it is onemore step to ensure that our guests receiveonly the best seafood. Red Lobster was one ofthe first companies to institute this programon a national level.

Training and continuing education pro-grams are a key step to ensuring that the qual-ity message is understood through all levels ofthe organization. Publications such as LobsterTales and Expert’s Guide To Seafood are usedto train our employees and keep them currenton all changes. Brochures in our restaurants’lobbies educate our guests to our quality pro-grams, the health advantages of seafood, andnutritional levels of all our products.

All these programs together ensure that wedeliver our goal: to provide a continuous supplyof top quality seafood for our guests.

This translates into a pleasurable, safe, andconfident dining experience for our guests ev-ery time they dine with us. If we do a poor jobone percent of the time, over 1.5 million guestswill have a bad experience. That is why wehave always joined forces with industry andgovernment to work together to create the bestseafood dining experience for our guests.

It takes a complete understanding of allthese areas to produce the quality story. forwithout a commitment to quality by all seg-ments of our industry, consumers will findother ways to spend their food dollars.

THE NEED FOR DEVELOPINGSTANDARDSJae Park and Michael T. MorrisseyOregon State University Seafood Laboratory

INTRODUCTIONSurimi is washed, minced, fish flesh to whichcryoprotectants have been added to maintainthe functional properties of the proteins duringfrozen storage. More than any other seafood, itis relatively homogeneous in composition andphysical attributes. Although there are a num-ber of processing techniques, the end product(if made from the same species) will have simi-lar characteristics whether it is made aboard afactory trawler or a shore-based surimi plant.

Japan has been the recognized leader in theglobal surimi industry. Surimi processing grewfrom a small traditional fisheries in Japan tolarge-scale operations during the 1950s. Theinitial phases of the industry depended onshore-based operations (Okada 1992). In 1965,the use of cryoprotectants allowed the produc-tion of surimi at sea, which greatly expandedthe resource base for Japan (Zenkama 1987).The Americanization of the Alaska pollockfishery that began in the 1980s and was fol-lowed by the Pacific whiting fishery in the1990s forced Japan to be more dependent onforeign harvests for their surimi Nonetheless,Japan has dominated the world’s surimi pro-cessing technology for on-shore and at-sea op-erations. The total production of surimi in theworld has fluctuated between 390,000 to530,000 metric tons over the last five years(Kano 1992).

More than 100 types of surimi-based sea-food products currently are produced in Japan.In the United States the majority of the surimiis processed into shellfish analogs, primarilyimitation crab. The nature of the final productis such that gel strength and color are the mostimportant attributes of surimi. Although anumber of analog products are made in Japanand other Asian countries, gel strength andcolor continue to be critical characteristics ofsurimi sold overseas.

Surimi is one of the few seafood commodi-ties that will receive a price differential basedon a grading system. Understanding and ma-nipulating the production to take advantage ofthis grading system is crucial in the marketingof surimi. For example, if company X makes

three different grades of surimi - A, B, and C-for which there is a 10 percent price differen-tial, it may be to the company’s advantage toproduce the higher-grade surimi, depending onthe market conditions. However, if the cost ofmaking the higher-grade surimi (lower yields,added production costs) are such that the pricedifferential is negated, it may be more eco-nomically beneficial to make grade B surimi.In either case, knowing how the grading sys-tem operates and how different factors can af-fect grading of surimi samples can meansubstantial increases to profit margins.

Factors Affecting the Grading SystemThe grading system for surimi is based on a

number of its characteristics, some more im-portant than others. These include

Gel strengthColorMoisture contentImpuritiesMicrobiological count

Other properties of surimi that can influ-ence the final grade are pH, protein content,fat content, cryoprotectants, and otheringredients such as protease inhibitors, gelenhancers, and whiteners. A number of factorswill have an effect on these surimi charac-teristics and are taken into account duringsurimi production.

Gel strength depends on the functionality ofthe myofibrillar protein and its ability to formheat-set gels (Matsumoto 1979). The gelstrength is affected by the species of fish, sea-sonality, and time and temperature factorsduring handling onboard the vessel as well asduring the processing steps. Compositional fac-tors will also affect the gel strength readings.Lower moisture content will improve gelstrength as well as starches and gel enhancers(Hamann and MacDonald 1992; Lee 1986).

Color largely depends on the species of fishthat are used for surimi products. The typicallow-fat white fish species such as Alaska pol-lock and whiting will give a color that isslightly off-white but will turn a creamy white

during analog processing. Pelagic species suchas sardine or mackerel will have a more gray-ish hue, while other species will take on theinherent color of the flesh. The degree of wash-ing will greatly affect the final color as well.The washing away of pigments or impuritieswill generally lighten the color of the surimi.

As mentioned previously, the moisture con-tent will affect gel strength: the lower themoisture, the higher the gel strength. How-ever, a lower moisture content in surimi re-sults in lower yields and decreased profitmargins. Since analog manufacturers add wa-ter to their formulations, they prefer the mois-ture to be lower than 75 percent. This is withinthe manufacturing tolerances of present surimiproducers.

Impurities are normal bits of skin or viscerathat have not been washed out during process-ing. They have little affect on the gel strengthof the surimi but do affect consumer accep-tance of the product, especially, if the finalproduct is a creamy white analog. Some spe-cies have a certain percentage of “black spot-ting” in the flesh. If these fish are not culled,they can cause a defect that appears like “pep-per on snow” and will cause a reduction in thegrade (Morrissey et al. 1992).

Microbiological levels of surimi are impor-tant for quality control and health standards.Standards may include total plate count andcoliform count as well as specific pathogenssuch as Listeria. The initial bacterial load onthe fish is the most important factor for finalbacterial count of the surimi (Lee 1992). Re-searchers have found that the washing stepsdid not appreciably reduce the microbial count(Himelbloom et al. 1991). With the increasinguse of HACCP in the surimi industry, therewill be increasing reliance on good microbio-logical controls in the plant.

The pH of the final surimi can greatly affectits gel strength and should be monitored dur-ing processing (Chung et al. 1993). Other addi-tives, such as calcium compounds, can affectgel strength while glycerides and hydroge-nated vegetable oil will have an effect on coloror the sheen of the final block. Protease inhibi-tors, such as beef plasma protein, used in Pa-cific whiting surimi, markedly improve gelstrength but may cause an increase in yellowcolor if used in too great. a concentration.

Surimi Characteristics: Measurementsand Additives

Uniform surimi standards require a uniformmethodology for testing surimi characteristics.

Unfortunately, at present, this is not the casefor surimi. There are a number of different in-struments as well as methods for evaluatingcharacteristics such as gel strength, color, andmoisture. While the principles for measuringthese characteristics may be similar among theinstruments, there are a number of differencesas well.

The measurement of gel strength is one ofthe more problematic. The traditional surimimethod is the fold test by which a 3-mm-thickslice of surimi is folded several times and in-spected for cracks resulting from the folding(Lee 1984). This procedure, although simple touse, can have a wide variation and is not verydiscriminatory among surimi samples with ahigh gel strength. Because of the subjectivenature of the evaluation, it is difficult to stan-dardize this type of test.

The punch test is currently the method ofchoice among surimi producers to measure gelstrength. Recently, an electronic rheometer(Rheo Tex) has been commonly used to deter-mine gel strength (NFI 1991). In this method,a plunger is driven at a constant speed into asurimi gel, and values are reported by mea-surements of force (force needed to penetratethe gel) and depth (the distance the plungertravels inside the gel). Gel strength (jellystrength) is expressed as the force (g) x depth(cm). While this method is more objective thanthe fold test, it still can give highly variableresults that could lead to discrepancies be-tween buyer and seller. Furthermore, there isno method to calibrate the instrument afterextended use. Nonetheless, even with theseshortcomings, the punch test is preferredbecause of its ease of use during at-seaprocessing.

A more accurate test of overall gel strengthis the torsion test developed at North CarolinaState University (Hamann and Lanier 1987).This procedure requires a standardizedmethod of preparing the gel for testing such asbringing the moisture content of samples to 78percent. The torsion test involves the twistingof an hourglass-shaped gel to failure. The re-sistance to the twisting is related to gelstrength and is reported as stress while thedegree of twisting that occurs before breakingis related to the elasticity of the gel and is re-ported as strain. The disadvantages of the in-strument are that the accuracy of the resultscan depend on the technical expertise of thelab technician and that the instrument wouldbe impractical on an at-sea factory trawler roll-ing in the Bering Sea.

65

Other researchers have used the compres-sion test (most commonly performed with theInstron) as well as other instruments for ana-lyzing texture. While these are good researchtools, they are usually impractical for the typi-cal surimi producer. The making of the cookedsurimi gel to be measured is as much an art asa science. There are a number of factors, suchas the type of sausage stuffer, and the use of avacuum chopper, that will influence the resultsof the gel test (Babbitt and Reppond 1988).

The surimi paste is often prepared for test-ing by various methods that can lead to differ-ences in the results. The surimi industry hasbeen using three different formulas to preparethe surimi paste. One method uses 97 percentsurimi and 3 percent salt, while anothermethod uses 100 parts of surimi and 3 parts ofsalt. A third method uses 94 percent surimi, 3percent salt, and 3 percent potato starch.There are only minor differences in the firsttwo methods, but by adding starch to measuresurimi gel strength (third method), we arelikely to observe increased gel-strength valuesdue to starch gelatinization. Park (1993) foundthat the addition of starch up to a 6 percentlevel raised the gel strength by 15 to 45 per-cent, depending on its kind and modification.An addition of 3 percent potato starch in thesurimi gel will upgrade the gel-strength of thesurimi.

The surimi industry currently uses threedifferent cooking methods for testing surimigels. They are (a) a 90 C cook for 30-40 min-utes, (b) 24-40 C preincubation for 2-6 hoursfollowed by a 90 C cook for 30-40 minutes, and(c) a 5 C preincubation for 18-24 hours followedby a 90 C for 30-40 minutes. Preincubation iscalled suwari in Japanese. This technique isused in the industry to facilitate molding andforming products for kamaboko or crab ana-logs. The effects of preincubation have beenstudied by a number of investigators(Numakura et al. 1985; Kim 1987; Kamath1990; Park et al. 1993). There is a minimumeffect on gel elasticity, but preincubation canaffect the gel stress (strength) by 15-60 per-cent, depending on the method and fish spe-cies. Because of these effects on gel strength,there is some confusion between buyers andsellers in surimi evaluation.

Surimi additives used in commercial pro-cessing are another important issue that weneed to look at for the standardization ofsurimi. Cryoprotectants have been used in theprocessing of surimi since Japanese scientistsfound the combination of sugar and phos-phates can extend the shelf life by inhibiting

freeze-induced protein denaturation (Okada1992). Different levels of sugar (4-5 percent),sorbitol(4-8 percent), phosphates (0.25-0.3 per-cent), and more recently glyceride (0.1-0.2 per-cent) for whiting surimi have been used bymanufacturers. Manufacturers believe theirrecipe is specially blended with a patentablepropriety.

With the processing of Pacific whiting forthe last three years on the Pacific coast, theuse of enzyme inhibitors is necessary to makequality surimi. In 1991-1992, several enzymeinhibitors such as beef plasma protein, eggwhite, and potato flour were evaluated bymanufacturers and research institutes. In1993, all manufacturers of Pacific whitingsurimi used beef plasma protein (1.0-1.5 per-cent) as an enzyme inhibitor. With continuingefforts to make whiting surimi comparable topollock surimi, calcium carriers (such as cal-cium lactate, calcium sulfate, and calcium ca-seinate), sodium bicarbonate, and canola oilhave been used as a gel enhancer or a color-improving agent. Again, all manufacturers usedifferent levels as well as different combina-tions in the name of proprietary blending.

There are some problems with the gradesand specifications of surimi from the viewpoint of consumers and analog manufacturers.First, each manufacturing company has itsown specification of grades and additives. Sec-ond, there are no uniform grades among com-panies. Third, there is no uniformity incompositional properties, because of the addi-tion of different levels and kinds of additives.Fourth, there is not a universally acceptedtesting methodology. In 1991, the TechnicalCommittee of Surimi and Surimi Seafoodsthrough the National Fisheries Institute estab-lished the U.S. standard of surimi measure-ments (NFI 1991). However, none of the surimimanufacturers have shown their willingness toadopt it.

Current Practices in Surimi IndustryTechnical systems for surimi processing

have been developed by the five most impor-tant fisheries in Japan (Taiyo, Nisui, Hoko,Nichiro, and Kyokuyo) based upon their owninterest and business involvement. These tech-nical systems have been further modified byKorea and the United States, again because oftheir own interests.

To demonstrate the different grades, wehave selected 11 major surimi manufacturersof Pacific whiting surimi (table 1). The gradingsystems vary from company to company, and

66

there are even differences between two factorytrawlers within the same company (I-l and I-2). The eleven companies use very similargrades and specifications for Alaska pollock.The only grade they all agree on is the SAgrade for their best surimi. Most of the compa-nies use the FA terminology for their secondbest grades. Four different grades are avail-able for their third best category. Five differentgrade names are offered for the low-gradesurimi. Interestingly, company K offers onlytwo grades, SA and FA.

<2 mm, while other companies give 1 point forlengths >2 mm, l/2 point for l-2 mm, and 0points for <l mm. There are two systems usedin the industry for determining the impurity ofsurimi. The most common method is to use de-fect counts, while the other method uses a 1 to10 scale purity point such as company B. Thenumbers shown in table 2 are extremely differ-ent among companies because of the samplesize and the counting method.

As previously mentioned, gel strength is oneof the most important factors in surimi quality

H SA FA A KA BI-1 SA A KA B KBI-2 SA FA A KA K BJ SA FA AA A RA

Specifications of each quality parameterhave been used as guidelines for grading. Fivemajor companies were selected to compare thedifferences in their specifications. The mois-ture level in surimi is important and is relatedto whether or not the surimi-based seafoodmanufacturers are buying water or fish pro-tein. There is about a 1 percent differenceamong companies for the top two grades. Mostof the companies set the same specifications forall grades; company A and company D are ex-ceptions. Four different heating elements maybe used to determine moisture. They are infra-red, microwave heat/auto scale, electric heat/auto scale, and oven methods. The first threecan give relatively good results within 10 to 15minutes, whereas the oven method needs 16 to20 hours. However, the oven method gives themost accurate results.

For the measurement of skin bits or defects,all manufacturers follow the guidelines of theJapanese Surimi Association with various de-grees of modification. Sample size may vary,being either 10 or 40 grams. The countingscale may also vary when counting skin bits ordefects. Some companies assign 1 point tolengths >2 mm and 1/3 of a point for lengths

Table 1. Grades ofcommercial Pacificwhiting surimi.

measurements. However, there is a large dif-ference among the companies. Gel strength(gm-cm) is calculated based on the force (gm)required to break or tear the gel and ondeformation (cm), which indicates the degree ofthe gel’s resistance to a penetration probe.Most of the companies use the gel strength asa force value multiplied by deformation, whilecompany H uses a force value only. The rangeamong the companies is between 850 and 1000for the SA grade and between 900 and 750 forFA grade. These differences may be due to thetype of gel preparation and whether starch isused when making the sample gels. Preincu-bating of the surimi will also affect the final gelstrength measurements (Kamath 1990). Thegreatest difference between the differentcompanies is in the lower grade surimi (AAand KA), where there is a 200-unit difference.

Color specifications for surimi are extremelydifferent among the companies, as shown intable 2. The surimi industry has been usingthree different brands of colorimeters: Minolta,HunterLab, and Nippon Denshoku Kogyo.Even though the principle of color measure-ment is identical, there is still a small but sig-nificant difference between the machines.

67

1 Moisture (± 0.3%) 3, Gel Strength(gram.cm) d*Force(Gram)Onlyl- r

Table 2. Specifications of commercial Pacific whiting surimi. Companies A, B, D, and H are selected from table 1.

A

SA

FA

KA

RA

RB

D G H

74.3 SA 74.5

74.3 FA 74.5

74.3 A 74.5

74.3 KA 74.5

B 74.5

B

74.5

74.5

74.5

74.5

77

77

SA

FA

A

B

SA 73.5

FA 73.5

P 74

K 74.5

B 75

SA 74.1

FA 74.1

A 74.1

KA 74.1

SA

FA

KA

RB

1000

900

800

700

300

<30C

SA

FA

A

KA

750

600

450

SA

FA

P

K

B

SA

FA

A

B

750

600

450

SA

FA

2,Skin and Defect Counts *PurityScore T-

4,Color (L*/b*) l- -rB* D GA

SA 15

FA 20

AA 20

KA 20

RA 15

RB 30

SA 8

FA 14

A 14

B 23

15

20

25

80

80

SA 47 SA 7614.5 SA 74/12 SA 75/4.5 SA 46

FA 46 FA 75/5.0 F A 73/14 FA 75/5.0 FA

AA 45 A 74/5.5 P 72/15 A 74/5..5 A

KA 72/8.5 K B 74/8.5 K A

B

71/l 5

70/17 B

RB

SA

FA

A

KA

B

SA 10

FA 10

P 10

K 25

B 35

SA 9

FA 8

A 7

KA 7

Companies A and H use a whiteness indexbased on an equation using X, Y, Z values; theother three use L* (lightness) and b* (yellow-ness). When L* and b* values are comparedbetween companies (B, D) using the sameequipment, a significant difference is observed,as shown on table 2.

Reasons for Establishing SurimiStandards

The setting of surimi grades has been a pro-cess that has evolved with each company overthe years. In the past, when surimi was asmall land-based industry concentrated in Ja-pan, the traditional fold test was adequate todetermine the gelling characteristics of theproduct made from the landed catch. As theindustry has become more global and the pro-duction has grown to approximately 1 billionpounds per year of product being producedfrom at-sea factory trawlers and shore-basedplants, these traditional methods are inad-equate to define the product. There are, nodoubt, advantages to individual companies inhaving their own grading system. If they arelarge producers, they can have a tighter con-trol of their product and thus their markets.Ideally, they could have a complete under-standing of their own surimi measurementsand know how these measurements relate toharvest variables, yield, and protein content.They can lock in customers using their gradingsystem and make it difficult for a customer tochange to other brands.

However, the setting of different gradingsystems and values within the industry leadsto high information costs. It becomes more dif-ficult for a surimi-based seafood producer tochange suppliers and fully know the character-istics of the surimi. How does a different grad-ing system affect his formulation and finalproduct quality? If there are differences, howdoes this affect consumer satisfaction? Does anFA grade of 900 gel strength from company Atranslate to the same protein quality of an FAgrade of 750 gel strength for company B, ifcompany A is using starch in its gel measure-ments?

These differences in measurements andgrading can cause confusion in the marketingof surimi. Larkin (1993) states that different“firm-specific grades are not an efficientmechanism for conveying the key surimi char-acteristics for the following reasons:

1) Surimi is not an homogeneous productdespite its appearance, i.e., laboratory

2)

3)

tests are needed to determine levels ofkey characteristics;External processors face unnecessarilyhigh costs of gathering informationabout alternative supplier grades, i.e.,search costs exist;External processors may develop adependency on a past supplier, i.e.,buyer loyalty exists that may ensureproduct consistency while allowingsuppliers to restrict substitutionpossibilities and monitor their potentialrivals in the final surimi-based seafoodmarket.”

Standards for any raw material help to de-fine that commodity and promote fair tradepractices. It is as important for buyers to knowexactly what they are receiving as it is for sell-ers to receive a fair price for their product.Standards are beneficial to the industry as awhole and will encourage growth and promotestable markets. At present, the United Statesis the largest producer of surimi and Japan isthe largest user. Any development of a surimistandard requires agreement between thesetwo countries. A unilateral agreement by ei-ther one of the countries could cause greaterconfusion and mistrust in the surimi industryand uncertainty in world markets. Both coun-tries need to fully agree on the standards andgrading system.

A standard grading system requires thestandardization of methodology and instru-mentation. Preparation of samples, reagents,and calibration of instruments need to be accu-rately defined and followed. A start in the rightdirection has been the publication of themanual for measuring surimi quality by theNational Fisheries Institute (NFI 1991). Al-though the manual does not establish a systemof grades, it explains which compositionalproperties are important for measuring surimiquality and describes the methodology for mea-suring these properties. These standardizedmethods are suggested for in-house measure-ments to ensure quality control and accurateproduct formulation. Accurate measurementsfor surimi depends, in part, on whether asimple methodology can be followed by techni-cians at shore-based plants, on factory ships atsea, and in various counties. Cooking times,sample size, and ingredients for forming thetest sample are important considerations. Thesalt concentration and moisture percentage areimportant variables that need to be held con-stant for a standardized testing regime. Asnoted previously, several companies add

69

starch. Since starch is an added variable in the Reduced costs related to information gatheringtesting and can exhibit its own gel-forming could be translated to decreased costs in finalproperties, it should be eliminated from the product form and to the consumer. This willtesting methods. These are some of the issues allow surimi to be cost competitive againstthat should be decided by a standardization other seafood and nonseafood items and ex-committee. pand its marketing opportunities.

The standardization of testing equipment isalso a necessary component of determiningstandards for surimi. The most commonly usedmethods for measuring gel strength are thepunch test and the torsion method. There arelimitations in correlating the punch test withthe torsion test in surimi (NFI 1991). Thesecorrelations are weak for measuring the elas-ticity of the gels or for lower grade surimi. Thiscould be especially true for some of the newspecies of fish that are being introduced intothe surimi marketplace. It will be beneficial tothe industry as a whole if only one type of in-strument is used and the methodology is welldescribed. This would require an accurate wayto calibrate the instruments so that they wouldmeasure the same functions throughout theseason. This should be true for the color mea-surement as well. The establishing of a colorstandard (or hitching tile) is necessary to accu-rately calibrate the instruments before takingcolor measurements.

REFERENCESBabbitt, J., and Reppond, K.D. 1988. Factors

affecting the gel properties of surimi. J.Food Sci. 53: 965-966.

Chung, Y.C., Richardson, L., and Morrissey,M.T. 1993. Effects of pH and NaCl on gelstrength in Pacific whiting surimi. Acceptedfor publication in J. Aquatic Food ProductTech.

Hamann, D.D. and Lanier, T.C. 1987. Instru-mental methods for predicting seafoodsensory texture quality. In Seafood QualityDetermination, D.E Kramer and J. Liston(Eds.), p. 123-136. Elsevier, New York.

Hamann, D.D. and MacDonald, G.A. 1992.Rheology and texture properties of surimiand surimi-based foods. Ch. 17 in SurimiTechnology, T.C. Lanier and C.M. Lee (Ed.),429-495. Marcel Dekker, New York.

Himelbloom, B.H., Brown, E.K., and Lee, J.S.1991. Microbiological evaluation of Alaskashore-based surimi production. J. Food Sci.56: 291-293,314.

The surimi industry has evolved rapidlyover the last half century. It has changed froma small, traditional, shore-based industry inJapan to a billion dollar industry involving anumber of countries and increasingly a num-ber of species of fish. The grading system hasevolved as well from a subjective analysis oftexture and color to a more sophisticated objec-tive system of analysis of gel strength, L value,moisture, and so on. Although there are sev-eral discrepancies in how these quality param-eters are currently measured, there is acommon goal for most companies to have a sys-tematic way to evaluate surimi blocks. Thereare differences, at present, in the grading ofthe surimi. However, there are also a numberof similarities, and the numbers almost beg fora committee to establish a standard gradingsystem for measuring surimi. Any committeeformed to establish standards and gradesneeds to include representatives from theJapanese and the U.S. surimi industry. Thesurimi industry should support the establish-ment of grading standards to help stabilize theindustry, A uniform grading system would im-prove the efficiency of the industry and in-crease competitiveness across all sectors.

Kamath, G.G. 1990. Investigation of physico-chemical basis for the unique “setting”phenomenon of Alaska pollack and Atlanticcroaker surimi, Ph.D. dissertation, NorthCarolina State University, Raleigh, NC.

Kano, I. 1992. The situation of global surimi,with special emphasis on the Japanesemarket. In Pacific Whiting: Harvesting,Processing Marketing and Quality Assur-ance, G. Sylvia and M.T. Morrissey (Eds.), p.73-79. Oregon Sea Grant, Corvallis, Oregon.

Kim, B.B. 1987. Rheological investigation ofgel structure formation by fish proteinsduring setting and heat processing. Ph.D.dissertation, North Carolina State Univer-sity, Raleigh, NC.

Larkin, S. 1993. Personal communication.Lee, C. 1984. Surimi process technology. Food

Technol. 38( 11): 69-80.Lee, C. 1986. Surimi manufacturing and

fabrication of surimi-based products. FoodTechnol. 40(3): 115-124.

Lee, J, 1992. Microbiological considerations insurimi manufacturing. In Surimi Technol-ogy, T.C. Lanier and C. Lee (Eds.), 113-121.Marcel Dekker, New York.

Matsumoto, J.J. 1979. Denaturation of muscleproteins during frozen storage. In Proteinsat Low Temperature, 0. Fenema (ed.) p.205-224. ACS Symposium Series 180, Amer.Chem. Soc., Washington, D.C.

Morrissey, M.T., Peters, G. and Sylvia, G.1992. Quality issues in the Pacific whitingfisheries. In Pacific Whiting: Harvesting,Processing, Marketing and Quality Assur-ance, G. Sylvia and M.T. Morrissey (Eds.), p.9-16. Oregon Sea Grant, Corvallis, Oregon.

NFI. 1991. A Manual of Standard Methods forMeasuring and Specifying the Properties ofSurimi. T. C. Lanier, K. Hart, and R.E.Martin (Ed.). National Fisheries Institute,Washington, D.C.

Numakura, T., Seki, N., Kimura, I., Toyota, K.,Fujita, T., and Arai, K. 1985. Crosslinkingreaction of myosin in fish paste duringsetting (suwari), Nippon Suisan Gakkaishi51:1559.

Park, J. W., Yongsawatigul, J., and Lin, T.M.1993. Rheological behavior and potentialbindings of Pacific whiting surimi gel asaffected by settings and chemicals. Unpub-lished manuscript.

Park, J.W. 1993. Starches and protein addi-tives. Presented at the 1st Annual OSUSurimi Technology School, Astoria, Oregon.March 29-3 1.

Okada, M. 1992. History of surimi technologyin Japan. In Surimi Technology, T.C. Lanierand C. Lee (Eds.), p. 3-21. Marcel Dekker,New York.

Zenkama. 1987. Outline of All JapanKamaboko Makers Association (Zenkama)and All Japan Surimi Users Committee. AllJapan Kamaboko Makers Association.Tokyo, Japan.

IMPLEMENTING AN ISEUROPEAN SEAFOOD

INTERNATIONALLY

Sigurdur BogasonIcelandic Freezing Plant Corporation

INTRODUCTIONIn this paper I will discuss the various aspectsof systematic quality management as pre-sented in the ISO standards. Where appropri-ate, I will try to refer to my personalexperience working with an ISO 9001-certifiedquality system. The focus of my discussion willbe the following points.

l What is meant by the terms qualityand quality assurance?

l What are the typical components of anISO 9000 quality system?

l Why should a seafood company chooseto work with a structured qualitysystem?

l What are the benefits?l How long does it take to integrate this

kind of a system into an organizationand how much might it cost?

I will discuss the general principles involvedand use some practical examples that relate tothe seafood industry.

The international business world seems tobe deeply concerned about quality. This con-cern may be only a new fad or the hope of sal-vation for every businessman and industry. Mypersonal experience is that nobody with anysincerity can afford to look at this only as afashionable idea. To compete successfully onthe global food market, an industry like theseafood industry needs to take quality manage-ment very seriously. This recent interest inquality seems to arise mainly from the factthat the Western world has come to under-stand that the basis of Japan’s industrial suc-cess in the last few decades is quality. Now weare all extremely busy trying to come to termswith this. Everybody wants to be saved byquality or at least use it somehow to achieve acompetitive edge in the future.

The next logical question becomes, what isquality? The term has many meanings, de-pending on culture and type of industry. It isimportant to define quality before going anyfurther. Many have said (Juran 1989; Surakand McAnelly 1992) that quality is the eco-nomical production of consistent products andservices that meet or exceed customer require-ments. We can add to this statement, and con-formance to regulations. Furthermore, it isobvious that customer requirements are morethan just meeting specifications.

To meet customer requirements, we needinformation from market research that lets usunderstand customers’ needs and problems.Then we need to develop a process for produc-ing goods and services that meet or exceedcustomer’s needs or desires. Finally, we needto sell the products or services at appropriateprices. When any of these criteria can’t be met,it is obvious that the product or services havenot met the definition for quality. For example,rework, waste, or loss during production or dis-tribution of seafood product means there is adecrease in quality. This is because the cus-tomer eventually will have to pay more for theproduct or the owners of the company will re-ceive less return from their investment. To il-lustrate further the true meaning of quality,we can compare two automobiles. A Rolls-Royce, which meets the specifications for aRolls-Royce, is a quality car. But it is equallytrue that a Russian-built Lada, which meetsthe specifications for a Lada, is a quality car.Quality is meeting the requirements.

Another term one comes across frequently(Surak and McAnelly 1992) is quality assur-ance, which is the planned and systematic ac-tions necessary to provide adequate confidencethat processes, products, and services satisfythe requirements of quality. This definitionbrings us back to the IS0 9000 standards sincethey are probably the best tool available to anyindustry for setting up a system to managequality and maintain quality assurance.

The following standards (published in 1987)are used as guidelines for quality managementsystems:

* IS0 9000 - quality management andquality assurance standards-guide-lines for selection and use

* IS0 9001-model for quality assurancein design/development, production,installation, and servicing

0 IS0 9002-model for quality assurancein production and installation

* IS0 9003-model for quality assurancein final inspection and testing

l IS0 9004-quality management andquality system elements-guidelines

For practical purposes most quality systemsthat I know about are based on either ISO9001 or 9002. Figure 1 shows the elementaldifference between the models. IS0 9001 is themost comprehensive one, and IS0 9003 is the

simplest, as it deals only with final inspectionand testing. To add to the confusion, the stan-dards have different reference names in Brit-ain and in the EEC. In the UK, 575O:part 1 isthe same as EN 29001 in the EEC; both areidentical to what internationally is called IS09001 (BSI Quality Insurance publication).Gudmundsson (1992) points out some of thekey reasons for using the IS0 standards: toprovide direction, generate ideas for change,design or redesign systems, implementchanges, measure results, and manage changethrough audits and reviews.

The IFPC Quality Assurance Manual de-scribes a typical ISO 9001 quality system. Fig-ure 2 lists the contents of the manual. Each ofthe 20 chapters in the manual deals with spe-cific activities.

Many people think of quality in the limitedsense of product quality and quality control.However, the standards address all the usualactivities taking place in an organization. Inthe food industry one can easily visualize many

IS0 9001EN 29001BS 575O:l

Source: Pira International

Relevant Quality System Standard

Statement of Quality Policy

Issue Log

CONTENTS

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

Management Responsibility

Quality System

Contract Review

Design Control

Document Control

Purchasing

Customer Supplied Product

Product identification and

Process Control

Inspection and Testing

Inspection, Measuring and Test Equipment

Inspection and Test Status

Control of Nonconforming Product

Corrective Action

Handling, Storage, Packaging and Delivery

Quality Records

Internal Quality Audits

Training

Servicing

Statistical TechniquesAppendices:

::List of Quality Plan and Quality Procedures - ReykjavikList of Quality Plan and Quality Procedures - Hamburg

Section: Contents Page: 1 Issue: 3

Figure 2. Contents page of IFPC’s Quality Assurance Manual.

of these activities also being addressed with aHACCP-based system. The main differencebetween the two systems is that HACCP con-centrates on process control and is one of thebest tools available for this. ISO 9000 systems,on the other hand, ensure the overall manage-ment of quality in all quality-sensitive aspectsof the organization.

The company I work for, Icelandic FreezingPlants Corporation, has a long history of usingthe term quality as a key part of its market ap-proach. The corporation celebrated its 50th an-niversary last year, and in March 1992 becamecertified towards ISO 9001. Commitment tothis work was made in the spring of 1991, andI was given the task of compiling the qualityassurance manual and quality procedures incooperation with other IFPC staff and consult-ants from a British company with extensiveexperience in this field. It took us at IFPCabout eight months to have the system writ-ten, implement it, do a number of internal au-dits, amend procedures, introduce somechanges to work routines, and finally pass theassessment of BSI quality assurance (Bogason1992).

The reason this was possible in such a shorttime was that there was total commitment andleadership from the top management of thecompany. Also almost all the personnel partici-pated in some aspect of the work.

There is no mystique involved in this pro-cess. Basically what you need is to start orga-nizing and documenting in a formal mannerthe actual work being carried out within thecompany. The only new aspect in the process isusing the ISO 9000 standard to guide you insetting up the controls required by the indi-vidual ISO standard you choose as the modelfor your quality system. The result is a for-mally written quality assurance manual andquality procedures that describe yourcompany’s tradition for doing the daily taskswhile adding the security of controls in spe-

the quality policy. In the next layers are thequality assurance manual, quality procedures,and work instructions. The foundation of thedocumentation is the records that prove we dowhat we say we will do. The description of thework routines is increasingly detailed towardthe base of the pyramid.

Examples of new tasks that most companieswould have to deal with are controlling the for-mal documents, assessing the supplier, andconducting internal quality audits. Figure 4shows a form that was introduced at IFPC todeal in part with the requirement of the ISO9001 standard: “Part 4.6.2 Assessment of sub-contractors - The supplier (company) shall se-lect sub-contractors on the basis of their abilityto meet sub-contract requirements, includingquality requirements. The supplier (company)shall maintain records of acceptable sub-con-tractors." Figure 5 shows a sample outline ofthe quality procedure that corresponds to thispart of the standard. Also, we maintain a list ofapproved suppliers for IFPC, and in manycases we visit the suppliers to perform qualityassessments. The reason for taking this as anexample from the standard is to point out theobvious. Certified companies will establish cri-teria for assessing their suppliers, and themain criterion will soon become that the sup-plier company also be certified. This will re-duce the amount of inspection required forgoods or services being purchased. Credibilityand confidence will be greater for certified sup-pliers. Al l competent companies will gradually

QUALITY POLICY

cific areas of work, many of which may benew to the company. The individualchapters in the typical quality assur-ance manual specify how the com-pany operates and ensures that therequirements of the ISO 9000standard are met. The qualityprocedures describe in moredetail how they are met.

The IFPC quality manage-

QUALITY PROCEDURES

WORK INSTRUCTIONS

QUALITY RECORDS

ment system documentationcould be viewed as a pyramid(figure 3). At the top we place Figure 3. Structure of the IFPC quality management system.

75

SÖLUMIDSTÖD HRADFAYSTIHÚSANNAICELANDIC FREEZING PLANTS CORP.

VENDOR ASSESSMENT QUESTIONNA!RE

Figure 4. Vendor assessment questionnaire.

76

ASSESSMENT OF SUPPLIERS

ObjectiveTo ensure that suppliers Of goods and services used within thequality system areselected on the basis of their ability and thattheir performance is monitored.

Procedure

1. Quality ManagerSuppliers of goods and services are assessed and theirperformance is monitored in consultation with the Purchasing,Quality Control, Shipping, xxxxx xxxxx xxxxxx xxxxx xxxxxxxxxxxxxx xxxxxxxxxxxxxxxxx.

2. Functional ManagersInformation about suppliers performance and complaintsresulting from their services or goods are relayed to theQuality Manager. Complaint xxx xxxx xxxxxxxxxxxxx xxxxxxxxxxxxxxx xxxxxx xxxxxxxx xxxxxxxxxx xx xxxx xxxxxxxxxxxxxxxxxxxxx xxx xxx xxxxxx xxx xxx xx . A. Manual.

3. Quality ManagerWherever possible suppliers registered as firms of assessedcapability to ISO 9000 or similar are selected. Othersuppliers are selected using one or more of the followingcriteria:-

- Supplier questionnaire form- Evaluation of sample products- On site assessment- Past history of performance.

xxxxxxxxx xxxxxx xxxxxxx xxx xxxxxxxxxxxx xxxxxxx xxxx xxxxxxxxxxxxx "Approved".

4. Quality Managerxxxxx xxxx xx x xxxxxxxx xxxxx xxxxx xxxxxxx xxxxxxxxx xxxxxxxx xxxxx xx x x xxxxxx xxxxxx xxxxxxx xxxxx xxxxxx xxxx xxxxxxx xxxxx xxxx xxxxxxxx xxxx xxxxx xxxxxx xxxxx xxx arerecorded and filed.

Figure 5. Sample outline of a quality procedure.

77

be pulled on this bandwagon, willing or not.Those who refuse to put their effort into qual-ity issues will lose market shares, just as thosewho pull their weight with enthusiasm willgain the competitive edge. Remember that atsome stage everybody is both a supplier and acustomer. The same thing is true within a com-pany as each department needs to be sure whoits customers are and what their requirementsare.

We found forms to be very useful in effi-ciently introducing the controls and record-keeping required. In many cases the staff com-plained about the forms, but that was beforethey realized that using forms didn’t take anylonger to relay information than scribbling theinformation or request on some piece of paper.Also everybody quickly saw that the securitygained was immensely important as informa-tion was not being lost and actions becamemore accurate. The number of failures to actupon an internal request was reduced and thestaff became more responsible for their actions.Doing it right the first time is extremely im-portant in all organizations because it reducesthe cost of redoing the work (Bogason 1992).

At IFPC a new computer system has beenset up. In designing its routines, we made aneffort to automatically log in as much as pos-sible of the record-keeping information re-quired by the quality system. Consequently,many of the forms introduced when the systemwas being implemented have now become su-perfluous. Always remember the kind of moti-vation needed for the people who have to carryout the routine tasks like working according toprocedures and using forms. You have to showthe staff why a routine is required and helpthem see for themselves the benefits comingfrom this approach. Training is a key elementin the effort, and the standard stipulates gen-eral requirements for training. Each companyhas to specify how its training needs willbe met.

WHAT ARE THE BENEFITS?There are four reasons the ISO standards

can be useful to a company. First, the stan-dards are internationally recognized. Second,they help organize the internal operations inan organization; in other words they can makeall work flow more easily and prevent mistakesfrom happening. The quality system shouldreduce the effort needed for internal inspectionand double checking within the company.

Third, a company receives public benefits fromISO standards. A company that has a certifiedquality system can tell its customers it hasbeen certified to the ISO standards. As custom-ers are informed about the third-party assess-ment involved, the company and the quality itstands for gain credibility for the customers.European firms are under increasing pressureto become certified, and more frequently it isbecoming a requirement for doing business.The fourth reason ISO standards can be usefulis that the standards help establish proof ofdue diligence on part of the organization inmaintaining the safety of processes, products,and services and in meeting legal require-ments. Due diligence is the term used when acompany has taken all possible steps and pre-ventive measures to ensure the safety of itsproduct.

APPROACH FOR SEAFOOD COMPANIESHow can a quality management system be

beneficial specifically to seafood companies?There are no simple answers. Let’s put it thisway: if a company chooses not to manage qual-ity in any formal manner, will it be competitiveor be able to maintain the necessary credibilityfor customers, consumers, and regulatory bod-ies? My approach is as follows (Bogason 1992).By setting up a quality management systemaccording to the ISO 9000 standards, any orga-nization has then invested time, effort, andmoney to develop an immensely powerful toolfor managing that organization. A carefullydesigned quality system is a general manage-ment tool for almost all operational activities.The finance department is usually excludedfrom the ISO 9000-based system. Although thestandards do not require the financial depart-ment to be a part of the quality managementsystem offered for certification, it can be orga-nized and controlled by the same methods andphilosophy.

How long will it take to become registered?If the company has a formal quality system-e.g., a HACCP system-in place, it could takeonly six months. However, this would be theexception; a company starting without a formalquality system should allow a year or two tobecome ready for assessment.

The ISO 9000 standards do not by them-selves specify or demand any specific level ofquality or service. Each company has to estab-lish its own standards of excellence or its ser-vice level. The standards basically require only

that the company meet customer require-ments, informing the customer about the prod-uct or service being offered. The standards alsorequire that legal aspects be considered andregulations be met. How a company does thesethings is not specified; for a food company therequirements are most commonly met by set-ting down product, process, or service specifica-tions. Typically, the cornerstones used by theseafood industry are finished product specifica-tions, packaging specifications and processmanuals containing procedures for hygienecontrol, and good manufacturing practices.These documents will be carefully controlledwithin an ISO 9000 quality management sys-tem. How, and what types of records are kept,is determined by the processes and the risksinvolved or the safety needed for the productsor process involved. By maintaining a viablequality system, the company should not havedifficulty proving that it is maintaining duediligence.

How much does it cost? The costs will varyfrom one company to another depending on thenature of the existing quality system. Holmes(1991) advises companies to budget a sumroughly equivalent to a middle manager’s an-nual salary to cover the implementation costs.This, he says, will cover the time spent on theproject by the management team in briefing,training, and external assistance. The chiefexecutive officer needs to allocate 2 to 3 per-cent of his or her time to ensure that theproject stays on track. The rest of the manage-ment team needs to allocate about 10 percentof their time to developing and introducing thesystem (Holmes 1991)

In Iceland the emphasis is now on applyingHACCP to the production flow within the pro-cessing plants and designing them in the man-ner that makes them applicable as parts orelements of IS0 9000-based quality systems.Through the certification of its ISO 9001 qual-ity system, IFPC has met many of the basicrequirements for the individual quality sys-tems being assimilated at the production levelin its member plants. In other words, futurequality systems will in many cases use the ISO9000 approach for the overall quality systemand will use HACCP techniques in the produc-tion to meet specific requirements.

TO conclude, I would like to present a model(Bogason 1992) of a quality management sys-tem for a seafood processing company. The pro-cessor would use the ISO 9002 or 9001standard as the guideline for the company’soveraIl system. From that the processor woulddraw the management and organizational ele-

Surak, J.G. and McAnelIy, J.K. 1992. Educa-tional programs in quality for the foodprocessing industry. Fd. Technol. 46 (6): 80-90.

ments and then use the HACCP approach toset up process controls for the processing lines.In this context, processing would be defined asstarting aboard the fishing vessels and extend-ing through to the delivery of the finishedproducts to the customer. Therefore qualitysystem documents relating to chapters 8 and 9and parts of chapter 12 in the standard wouldbe more or less written with the HACCP ap-proach in mind; they would analyze criticalpoints and put in place necessary controls andrecord keeping. Then the company would usethe total quality management (TQM) approachto set quality goals and improvement bench-marks for the company and personnel. Inter-nal audits and TQM work would then ensurethat the quality system is constantly being im-proved.

A simple but important statement is appro-priate here: quality cannot be inspected into aproduct, service, or task. The correct qualitycan be achieved only by manufacturing theproduct, providing the service, or performingthe task to the required standard. The qualityissues would then be served in the progressivemanner envisioned by the management, cus-tomers, consumers, and regulatory bodies. Thecertification, and the regular third-party as-sessment, is really only the first step in mak-ing quality the cutting edge for the future ofany seafood company.

REFERENCESAnonymous. BS 5750, ISO 9000, EN 29000?

An undated brochure published by BSIQuality Assurance, Milton Keynes, UK.

Bogason, S.G. 1992 Certification to ISO-9000standards is only the beginning in qualitymanagement. Reykjavik: Commett CourseProceedings from Quality Issues in theEuropean Fish Industry; European Co-operation (in press).

Gudmundsson, G.H. 1992 The quality system:implementation by involvement. ReykjavikCommett Course Proceedings from QualityIssues in the European Fish Industry;European Co-operation (in press).

Holmes, K. 1991. Implementing BS 5750.Leatherhead, UK: Pira International

Juran, J.M. 1989. Juran on Leadership forQuality. An executive handbook. New York:The Free Press.

IS0 9000--THE SEALORD EXPELESSONS AND FUTURE VISIO

Robert deBeerSealord Products Ltd., Nelson, New Zealand

In December 1992 the Nelson site of SealordProducts Limited gained certification to ISO9001. Although this was a significant achieve-ment, one of which Sealord is proud, the com-pany considered it the start of a process ofcontinuous improvement and not the end of aself-contained project.

Two questions have been repeatedly askedof Sealord since it achieved this milestone:What would you do differently if you had to doit again? and What do you plan to do now thatyou have been certified?

In this paper I will answer both of thesequestions.

SEALORD PRODUCTS LIMITEDSealord is the leading seafood company in

Australasia. It employs 1400 people, has anannual turnover of NZ $350 million, and pro-duces a range of retail and commodity prod-ucts. The company has grown rapidly over thepast decade, initially because of the success oforange roughy , then later because of the effortmade to become a genuinely customer-focusedcompany.

T H E HISTORY OF QUALITY ASSURANCEAT SEALORD

Like most food companies, Sealord had ele-ments of a quality system in place early in itsdevelopment, but the first attempt to pullthese elements together into a coherent bodytook place five years ago.

This initial effort was not a success, due inlarge part to the lack of a model on which tobase the system, but it did leave behind itsome elements of a quality system that couldbe used in the future.

In 1991 the drive to develop a quality sys-tem resurfaced. The impetus came from twosources. First, Sealord’s marketing strategyhad continued to move away from commoditytrading and toward added-value, customer-specific products. This move placed greater andgreater demands on production, logistics, prod-uct development, and marketing. Sealord rec-ognized that it would benefit greatly from a

more structured quality system, especiallysince things were hardly likely to get less com-plicated as the size of the company increased.Second, a number of key markets, particularlyin Europe, seemed likely to impose a manda-tory requirement for certification to an ISO9000 standard.

The move toward customer-specific productsmeant that Sealord wanted to focus on devel-oping a quality system that really worked. Fur-thermore, as a result of the pendingmandatory requirements, the company set atime frame and committed its entire organiza-tion to a concerted effort to work within thatframe. With the benefit of hindsight we seethat this is one of the keys to setting up a qual-ity system-momentum. It would be nice tofiddle around and build up a quality systemwithout any stress or fuss, but in the realworld such a quality system would be use-less - it would be out of date before it was setup. It would also be anonymous; one of the realadvantages of building a quality system atspeed is that it raises the prominence of qual-ity concepts within an organization and devel-ops a momentum that will ensure the systemcontinues to grow and evolve long after the ar-bitrary level of certification has been achieved.

To guide the certification process, a qualitysystems manager was appointed, and within12 months Sealord had been certified to IS09001.

As simple as that?Not quite. Sealord experienced a number of

problems along the way, some due to the na-ture of the food industry, some due to the na-ture of the fishing industry, and some due togood old human nature. With the benefit ofhindsight, some pitfalls are apparent.

SOME OF THE LESSONS LEARNED

CommitmentOne of the most common gripes of a quality

manager is that the company management arenot committed to quality. In reality it is morelikely that they are committed to quality per sebut require expenditure to be justified by

something a little more substantial than surely the most logical approach to start off"Juran and Deming say so.” This is very much with the most comprehensive standard, ISOthe case at Sealord. 9001, and go to ISO 9002 only if the sections on

Nick Grainger, at the New Zealand Organi- design control and servicing clearly do not ap-zation for Quality Conference in 1992, pointed ply. This advice has anecdotal support fromout that if, for some reason, the management Iceland, a country which seems to favor theof a company are not truly committed to qual- ISO 9001 standard for its fishing industryity, then it is the job of the designated quality (Scudder 1993).practitioner to get them committed (Grainger1992). There are plenty of convincing argu-ments and examples available to support the

Planning the Implementation

benefits of quality. As mentioned earlier, it is tempting, when

Commitment is “measured” in the IS0 9000 formalizing a quality system, to set vague ob-

standards under the heading of “Management jectives for certification. While companies tak-

Review,” where a company needs to measure ing this approach may still get there in the

its performance against its stated objectives. end, it is likely that they will take longer than

One of the external auditors of the Sealord necessary. A detailed plan will ensure that a

quality system has observed that a telltale sign level of momentum is established and main-

of a company that is not really committed to tained throughout the implementation process.

quality is an impressive sounding mission A simple technique for planning the imple-

statement with no way of measuring progress mentation is the use of matrix diagrams, suchagainst it. as that shown in figure 1. This matrix will en-

sure that all elements of the standard are ad-

Which Standard Should a Company Godressed in the documented quality system. For

For?each procedure identified through the matrix,responsibilities, scopes, and target dates can be

For any company that relies upon exportmarkets, then the ISO 9000 series of standards

set. The time spent on this phase repays itself

stand out as a good choice. They have beenmany-fold and this technique is being used inplanning the certification for the rest of the

adopted as a national standard by a large Sealord group.number of countries and despite some deficien-cies, they serve as a reasonably sound model touse.

Selection of a Certification Body

There are three standards in the ISO 9000 The organization chosen to certify a qualityseries: 9001, 9002, and 9003. There is a popu- system is going to be a partner of the companylar misconception in some countries that ISO for a long time to come. Although Sealord se-9002 is the most appropriate standard for a lected KPMG-QCI as its certification body

manufacturing company to go for. This stan- quite late in the play, Sealord realized that itdard covers the organization of the company, would have been far more desirable to have

contract review, purchasing, process control, developed a relationship with them earlier.inspection and testing, control of nonconform- The sooner a certification body is selected, theing product, internal auditing, and training- sooner specific requirements and interpreta-everything it takes to make a product tions can be dealt with.consistently. What ISO 9002 doesn’t cover isthe design and development of new productsand processes and the after sale servicing ofcustomers. ISO 9001 does cover these areas. ToSealord the decision was that simple - the ef-fect of product and process design was too criti-cal to the marketing strategy to be ignored inthe quality system

It is surprising, then, that so many food

Beware of DocumentationThe ISO 9001 standard uses the word “docu-

mentation” a lot. Unfortunately, this is ofteninterpreted as being synonymous with “writ-ten.” It is not. Documentation can be in theform of photographs, physical standards, dia-grams, computer screens, cartoons, videos, andpractically any other way of reliably communi-cating information. The written word should

companies choose to go for ISO 9002. Someeven choose to go for ISO 9003 first as a start-ing point. The ISO standards were not de-

be used only as a last resort, particularly in the

signed to be used in this way. Each standard isseafood industry. Is it really worthwhile writ-

a model for a company with a different require-ing a detailed manual on fish handling tech-

ment for its quality system (Standards Asso-niques for fishers or a tome containing everyconceivable way to trim a Hoki fillet?

ciation 1990). In selecting a standard, it is

NOTES/REFERENCES ON“RESPONSIBILITY,”

4.11m4.12

4.13

‘TIME FRAME,”AND “SCOPE,”WHERE THE HEADINGSRELATE TO EACH OTHER.

Figure 1.

planning matrix.

Staff TrainingTraining staff and monitoring their perfor-

mance are traditionally poorly done in qualitysystems. By emphasizing training methods, weeliminate much of the need for excessive writ-ten instruction. We need to recognize thatmany of the jobs in a seafood processing com-pany are skilled ones and a comprehensivescheme to assist people in acquiring thoseskills is required.

Sealord puts considerable resources intostaff training and development. It is importantto note, however, that it is not just the opportu-nity to undergo training, but the opportunity toapply the training that is important.

Ownership of the SystemIn trying to meet the time frame set for cer-

tification, it is very easy for a quality managerto "hijack" the quality system. Doing all thewriting, designing, and setting up is not work-ing hard - it is being extraordinarily lazy. Aperson who has experience in a given area ofan organization will know far more about thejob than a quality manager and will almostcertainly resent having a cumbersome system

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imposed without consultation or considerationto the realities of the job.

The role of the quality manager should bethat of a coordinator, trainer, adviser, and sup-porter. It is one of those unique jobs where aperson can be proud of having let someone elsedo all the work!

The focus of the quality manager should beon system design--coming up with a model forthe system. The ISO standards are a good startbut should not be followed blindly.

One of the big temptations that arises whensetting up a quality system is to compartmen-talize the procedures. In this approach, theonly department that has to worry about thedevelopment process is the R&D department,the only department that has to worry aboutplanning is the logistics department, and theonly department that has to worry about qual-ity is the quality systems department. The re-sult of such a system is shown in figure 2: acompany with no common strategic goals be-tween different departments.

The aim should be to involve all depart-ments in all of the areas of operation that af-fect them. The role of support and servicedepartments therefore becomes one of

FINANCIAL PLANNING

ISO OA SYSTEMVESSEL STRATEGY

PROOUCT DEVELOPMENT

PRODUCTION PLANNING

STAFF PLANNING

MARKETING STRATEGY

PROCESS OPTIMISATION

STRATEGICDIRECTION

P DEPARTMENT

FINANCIAL PLANNING

ISO Q.A. SYSTEMVESSEL STRATEGY

PRODUCT DEVELOPMENT

PRODUCTION PLANNING

STAFF PLANNING

MARKETING STRATEGY

PROCESS OPTIMISATION

coordinating activities throughout the orga- converted into processing requirementsnization. This means that the company is bet- through detailed process specifications andter able to focus all of its efforts on its strategic work instructions, which in turn spawn rawplan and runs a lower risk of departments’ material specifications.heading off on different tangents. After the raw materials are defined, process

Sealord evolved a very simple model for its specifications and work instructions for thequality system, a model that relies on cross- fleet come into play.functional management to make it work. This This process is controlled by the quality sys-model is summarized in figure 3. tem, which ensures that other factors such as

The process starts off with the product delivery requirements, pricing, and invoicingspecification as the definition of customer re- are incorporated into the production cycle.quirements. This product specification is

Figure 2.Organizationalmodels.

WORK INSTRUCTIONS

Figure 3. Simplifiedmodel of the Sealordquality system.

RAW MATERIAL PECIFICATIONS

VESSEL PROCESS SPECIFICATIONSAND WORK INSTRUCTIONS

Internal AuditingAlong with staff training and management

review, this is an area of quality system designthat is often not done justice to. Without plan-ning for an ongoing process of internal audit-ing, a quality system will inevitably start todeteriorate. Companies often tend to attackthe internal audit by conducting widely spacedmajor audits. In reality, this only pays lip ser-vice to the concept of internal auditing. Theaim of the exercise is to check on the function-ing of the quality system to find problems be-fore they start to cause failures in the qualitysystem. Sealord uses continuous audits tomonitor its systems. Each procedure is auditedseparately, products are audited, processes areaudited, and records are audited. All of theseaudits are planned out only as far as the nextaudit - the frequency is varied to suit the levelof confidence in the area being audited. Be-cause the audits are small, less trained staffcan be used, and this in turn reduces the nega-tive connotations of an internal audit (sincenow almost anyone can be used as an auditor).Periodically a full internal audit is carried outto ensure that the overall system still compliesto the standard.

Preparation for an External CertificationAudit

No matter how well motivated people are,an external audit by the certification body willstill be an intimidating experience. The pur-pose of the audit needs to be communicated toall staff. It will not be an interrogation; the jobof an auditor is to help identify failures in thesystem that lead to problems in consistentlysatisfying the requirements of the customer,

This of course leads back to selecting the rightcertification body in the first place, one thathas auditors compatible with the culture ofyour organization, one that has experience inyour industry, one that has a good reputationfor looking for genuine problems with qualitysystems and not nitpicking over trivia.

And Whatever You Do. . .Design a system that is easy to change and

that can evolve; despite the philosophy ofDeming, you’ll never get it right the first time.Between the specifications and procedures, thebackbone of the Sealord quality system con-tains several kilograms of paper. With the firstprint having taken place less than a year ago,Sealord is now up to the third revision of mostdocumentation because people are actively andenthusiastically using and criticizing the sys-tem. If it is difficult to change, then the mo-mentum will be dampened.

WHERE TO FROM HERE?

Recognition of CertificationAfter you have achieved certification, the

next trick is to explain to people what itmeans. It’s not bad news, and as a result me-dia coverage will always be a bit of a problem.

Any organizations that are not already cer-tified, or working towards it, will usually bepoorly versed in the niceties of quality systemcertification They will congratulate you onachieving the “2001 Quality Award,” ask youwhen you are going to upgrade your certifica-tion to ISO 9003, or ask you what ISO isanyway.

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In practice it comes down to educating cus-tomers and consumers about what certificationmeans. However, as more companies achievecertification, this will prove to be less of aproblem.

Getting people to recognize the agency thatcertified your company continues to be a prob-lem, and there don’t seem to be many solutionson the horizon. This relates largely to the ac-tivities of national accreditation authorities-the groups that accredit certificationbodies-such as RVC (Holland), RAB (UnitedStates), NACCB (United Kingdom), and JAS-ANZ (Australia and New Zealand)-which inmany cases cannot agree on common require-ments for certification bodies. If internationalrecognition is important to your organization’scertification, then it is a good idea to select acertification body that has a good reputationwith your customers.

The Sealord PlanAt present, Sealord’s certification covers the

Nelson site, including the majority of the pro-cessing facilities, plus the company marketingand support functions. The immediate plan isto extend the certification to cover the fishingfleet and the subsidiary operations.

At the same time, Sealord wants to morefully use techniques such as quality improve-ment, HACCP (hazard analysis and criticalcontrol points), and the present icon of thequality profession, total quality management.

This fits in well with the current direction ofthe New Zealand seafood industry, which islooking at more fully incorporating HACCPinto its fishing industry inspection and certifi-cation scheme.

Food SafetyOne of the major strengths of the ISO 9000

series of standards is also one of its majorweaknesses: it is not specific to any particulartype of organization. One of the main areas inwhich this causes problems is food safety.

While setting up its Approved SupplierProgramme, Sealord sent out surveys to all ofits major suppliers and contractors. Manydidn’t have certification to a quality systemstandard and although disappointing, this wasnot surprising. The surprise came when ques-tions were asked about food safety programs.Three questions were asked of ingredientsuppliers:

l “Do you have a food safety program?”Predictably enough, all respondents said

yes (they were hardly likely to say no,after all).“Do you use HACCP in your food safetyprogram?” Half of the suppliers indicatedthat they did; the other responses variedfrom “not applicable” to “what isHACCP?.”“Is your food safety program regularlyaudited?” The majority of suppliers said“no.”

Further correspondence with and audits ofsuppliers have indicated a generally poor un-derstanding of food safety. Similarly, HACCPis often seen as being a flowchart and a fewnotes about problem areas in the process.

Of course, HACCP is a far more potent toolthan that. It provides a systematic way toevaluate the entire manufacturing process anddevelop control points to prevent problems thatmight jeopardize the consumer. Coming out ofa thorough hazard analysis study is a planthat, if implemented through the quality sys-tem, will provide a high level of confidence inthe ability of a manufacturer to control thesafety of its products. The plan can be audited,both internally (essential if it is to be of anyuse at all) and externally, as the framework forregulatory control.

When implementing a quality system, it isbetter to start implementing HACCP soonerrather than later. HACCP will provide thelogic behind much of the quality system (suchas the control of purchased product, processcontrol, process and product design, inspectionand testing, product release, and producttraceability). In tandem with an approachbased on the marketing concept (ensuring afocus on contract review, production planning,product design, and distribution), a qualitysystem that really works for the company willbe far more certain.

Such an approach could also lead to morelogic in the regulatory control. A system thatencourages processors to assess the particularstrengths and weaknesses of their operationmust surely result in a more practical andworkable system than a “one size fits all”mechanism that forces cumbersome andsometimes inappropriate controls on foodcompanies. If HACCP does begin to form thebasis of regulatory control, which seems to bea strong possibility, then this may also lead tomandatory certification programs for ISOcertification. The important difference betweenHACCP and more traditional approaches issystem ownership: in this scenario theprocessor takes ownership of the system

and is more likely to find it to be of genuinepractical value.

HACCP will be one of the key components offood company quality systems in years to come.

Total Quality ManagementAt the 1991 Asia Pacific Quality Control Or-

ganization Conference, an Australian businessstudies lecturer, Thomas J. Fisher (1991), hadthe effrontery to suggest that quality manage-ment was not the only key ingredient to busi-ness success. Silence reigned as a hall full ofquality practitioners struggled to come to gripswith the possibility that marketing, account-ing, exchange rates, and the like could actuallyhave a significant impact on the viability of anorganization.

While it is true that in a genuine qualityculture, the ethic of not accepting, producing,or passing on defects will permeate all areas ofa company, there has been a tendency for qual-ity practitioners to poach the credit for busi-ness success in the name of qualitymanagement. That’s fair enough in someways - marketers, accountants, and econo-mists have been doing pretty much the samething for a lot longer - but it tends to confusethings rather than clarify them.

Sealord has a mission statement. It wantsthe philosophy of the statement to be adoptedin all areas of the organization, and it wants tocreate a genuine synergy throughout all de-partments. Is this quality management? Theanswer is that Sealord doesn’t care. It’s a sen-sible way to run a company no matter what it’scalled.

TQM is the latest in a long line of buzzwords. It is interesting that of the many com-panies that decline to formalize a quality sys-tem against a recognized standard, quite anumber make a vague claim to taking the “to-tal quality approach.” Few companies seemable to elaborate on exactly what that means.In many cases, TQM is used as a weasel wordby those organizations that are not really com-mitted to the marketing-quality concept. Nowonder Fisher had his doubts about the effec-tiveness of quality management programs.

One of the models that has been used atSealord to try to show how the different tech-niques relate to each other under the umbrellaof TQM is shown in figure 4. The concept isthat TQM consists of two components - a phi-losophy and a set of techniques that are se-lected from the many available to best suit acompany’s specific needs.

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Figure 4. Interrelationships of quality concepts.

Setting up a quality system is a good, nononsense start towards total quality. Initiallythe quality system will tend to be an add-on tothe-day to-day operation of a company, but astime goes by, it gets absorbed into the normaloperating methods. From there on it leads in-evitably towards quality management: the sys-tem provides a way to lock in the changes andimprovements that previously may have beenlost once the initiator moved on.

Total quality management is very much inthe plans of Sealord, but under a different ban-ner - that of the Sealord way, the marketingconcept, and sound business practice.

The Strategic Quality ChallengeThe challenge that faces the seafood indus-

try is one that is not uncommon in primaryprocessors - the clash between productiondrive and market focus. The marketing conceptin its purest form would dictate that a com-pany should seek out its customers, determineits product mix, and then catch fish to suit.However, this is unlikely to use up all of thepieces of the fish and all of the species broughtup in the nets. There will inevitably be a com-ponent of production drive behind the opera-tion of any fishing company. This is notunhealthy so long as companies can find theright place on the continuum between beingproduction driven and market led.

CONCLUSIONSThe single most important lesson learned by

Sealord from its certification process is the im-portance of a holistic approach in setting upsystems. Involve as many people as possible,avoid re-inventing systems where existing sys-tems are in place, and make sure that thefocus remains on building a quality systemthat works for the company rather than onethat conforms to the standard.

The resources department of Sealord Prod-ucts, responsible for the Sealord owned andchartered vessels, is currently in the process offormalizing its quality systems. This depart-ment is doing it because it can see clear ben-efits to Sealord in implementing such aprogram. The comments from the managers ofthe department have been along the lines of‘We’re not too worried about getting certifica-tion; we’re mainly doing it because we need agood quality system.” In Sealord the only per-son who worries about the ISO 9000 series ofstandards is the quality systems manager.Everyone else is concerned about creating a

workable quality system that nurtures innova-tion and harnesses the inherent enthusiasmpeople have for trying to make their jobs bet-ter.

Don’t make your company fit the standard;make the standard fit your company.

REFERENCESFisher, T.J. 1991. The Impact of Quality

Management on Productivity. Asia PacificQuality Control Organization 1991 Confer-ence Proceedings, Volume 2 (Quality theInternational Language).

Grainger, N. 1992. The New Zealand QualityPrize - One Year On in ICI Paints. NewZealand Organization for Quality Confer-ence Proceedings 1992 (Beyond 9000 Before2000).

Scudder, B. 1993. Quality Not Quantity.Seafood International, EMAP Heighway,April 1993.

Standards Association of New Zealand. NZS9000, Quality Systems-Guide to Selectionand Use. 1990.

AND H&GRon WilliamsShore Trading, Inc., Roswell, Georgia

It’s an opportune time to talk about the qualityassurance standard as it relates to the market-ing of, in this case, headed and gutted (H&G)whiting and individual quick-frozen (IQF)whiting fillets. I’m not sure we’ve establishedthe point where quality assurance standardsapply to any marketable seafood product, but Ifeel I can speak with some authority on prob-ably one of the most maligned seafood productson the west coast. When I started selling andmarketing seafood products from the westcoast about 15 years ago, the sum of a presen-tation was product, packaging, and price, andthen price, and then price, and then price. Itreally didn’t make any difference what theproduct packaging was; it was the price thatdid it. Price was, and continues to be to a greatextent, the runaway locomotive that’s pullingthe whole industry behind it. I’m one buyer ofseafood who is trying to put the brakes on thattrain, because if the industry’s not healthy, I’msure not going to be healthy. I’m not going tohave anything to sell. Today that same presen-tation, whether I make it in Jasper, Georgia, orat Kroeger’s headquarters in Cincinnati, or atA&P's headquarters in Montvale, New Jersey,covers fishing methods, improved processingmethods, test marketing, target customers,packaging, and so on, and the last part of thepresentation is about what it costs. If youhaven’t sold it by that time, it doesn’t makeany difference what it costs. You can’t give itaway, because space is too important and no-body is buying products strictly on price in thearea where you can make a profit. Commodityproducts, as long as you continue to establishyour products as commodity, are strictly pricedriven and market driven.

Last fall, at the end of the last whiting sea-son, we did a test market involving about400,000 pounds of IQF whiting fillets. I’ve beenmarketing whiting products for a long time,and what happened really surprised me. Wepackaged the fillets in 5- and 2-pound bags.The package was up-to-date on every specifica-tion from nutrition labeling to cooking instruc-tions. We created a good-looking master case.

We put together cases with a pack size thatwas acceptable to either a distributor out inthe country or a food chain. We were fortunateto get enough distribution, working as hard aswe could to ensure that the distributionworked out of the warehouse and into thestores so we’d get a good test. One huge dis-tributor we worked with was a test market inhimself because he distributed to large retailfood chains, A&P stores, Cub stores, Pacestores, and so on as well as to the little storesout in the rural areas of Georgia and up in themountains. Through him, we had a cross sec-tion of customers.

We found some things we should haveknown but didn’t know. Number one, our larg-est customer base is the food store that’s awayfrom the major chains. If you take simple sta-tistics, you know that 90 percent of the peoplein the United States are not wealthy. Notmany of them are going to buy $6.99- or $7.99-a pound merchandise, even though thosepeople go to the same doctors you do, have thesame physicals you do, and hear their doctorssay, “Eat more seafood; eat more poultry.”Well, they’re going to eat a lot of poultry be-cause who can afford the seafood?

That basically was part of the presentationfrom Kroeger in Cincinnati to IGA in Dothan,Alabama. It works; it is so logical. These storesdon’t have a seafood department, and so thesebags of IQF fillets became their seafood depart-ment. It was incredible to watch each week themovement go from 25 cases to 30 to 50 to 100to 150 to 200 and on and on and on. The buy-ers became the best friends we had. They saidthey just couldn’t believe this was happening. Itold them I’d take back the product if it didn’twork, but I thought it would work.

The 400,000 pounds I had for this test mar-ket went so well that by February I didn’t haveany more product. Now I had a bunch of veryangry people on my hands. So, I had the idea ofsubstituting product from Peru. Peru had thebusiness before. They produce 2- and 5-poundbags of IQF skinless, boneless fillets. They soldso incredibly cheap that you couldn’t compete

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with them. After February, these distributorswere at my throat. My salesmen were about torevolt because we didn’t have your west coastproduct. I said “Aha, I’ve got the answer." So Isold them a truckload of Peruvian 5-poundproduct and a truckload of Peruvian 2-poundproduct. The distributors’ customers revolted.They were sending the product back. All of asudden they had a quality standard, a westcoast product, and they would not take theproduct that they were taking before. Theysent it back. I picked it up - 489 cases of 2-pound product - and was never so glad to do itin my life because if anything had proved ourpoint, it was that. The incredible fact was thatthe Peruvian product was over 30 cents apound less than the west coast product. I wasblown away.

So when we’re talking about quality, weshould consider a circle divided into quadrantsrepresenting fishers, processors, marketers,and reorders. Now, the third quadrant is mar-keting. Quality is important. You’re sellingquality, and quality creates the continuity thatcompletes the circle: you haven’t done a thinguntil the end user buys your product again andagain and the reorders start to come back intothe plant. These four quadrants are like thebrains, heart, lungs, and kidneys. You take oneof them out and your business no longer hascontinuity. Quality is the continuity.

The west coast has beaten itself to death byselling price, strictly commodity products.There is no continuity to your business. Youcan sell to everybody this year, but next yearsomebody’s going to be cheaper, somebody’s gotto move product, And so, you get it this time,you don’t get it next time, and so on.

I think it’s time we changed the face of ourbusiness a bit. We take an H&G whiting andwe make fillets out of it, but we don’t makejust fillets, we make the best quality product

we can put in a bag. We’ve got a better gaugebag than the Peruvian product. There are notas many broken packages. Peruvian producthad a tendency to pop open because it’s a thin-ner gauge. Ours is tough. It costs more, but it'stough. We have a better fish inside. We freezeit better, we take care of the product better. It’slighter and whiter. It’s not dark like the Peru-vian. We integrated brokerage into it. We inte-grated promotional monies into the price sothat Kroeger, A&P, or anybody else can have“x” cents a pound that we accrue for advertis-ing, into allowances, and so on. It’s marketingdollars built into the price of product.

If we’ve done nothing else, we’ve paved theway in one respect - we’ve shown that youshouldn’t sell yourself cheap. You have an ex-cellent quality product. Years ago, the onlything we were told was that we had inferiorfish. You could sell it as H&G and that’s basi-cally it. As a matter of fact, it was only a coupleof years ago that I was wondering, if it’s thatbad will a whiting fillet hold together skinless?I was thinking it would just crumble and fallapart. If it’s fished and processed right, ofcourse it won’t fall apart; it’s an excellentproduct.

This test market confirmed exactly whatwe’re saying about quality being the locomo-tive that’s going to drive the train further andlonger than price will. You want somethingthat, number one, you can plan on. Now if Ihave customers with a brand name, they’re go-ing to buy it from me today, they’re going tobuy it from me tomorrow. So I can plan and mysuppliers can plan; they can pack against or-ders. It’s like Valhalla, but it works. The onlyway it works is for the whole circle to work to-gether, from the fishers to the processors to themarketers. And after marketing, we hope, thecustomer will reorder and we’ll go from there.

N

Session leader: Jay Rasmussen. Panel members: Sigurdur Bogason, Ian Devlin, Tom Libby,Terje Martinussen, Jim Ostergard

J. Rasmussen: I’m the director of an associa-tion of coastal governments, counties, cities,and ports along the Oregon coast. In thePacific Northwest we are trying not only tomaintain our traditional fisheries, but toenhance the role of fisheries in the economiclifeblood of the Oregon coast. This is the originof the Pacific Northwest Seafood Association.With all the collective wisdom gathered herefrom diverse backgrounds, we want to talkabout where quality control and qualityassurance could fit into this association.

T. Libby: The primary concept of our visionwas to develop an industry-wide, certifiable,quality standard program as a base to workfrom. Depending on the product and themarket you’re dealing in, you have customerswho demand certain standards or certainspecifications rather than product quality. Youpack to size range, glaze percentage, count perpound, and whatever else might pertain. Wewant standards that provide certification toour customers, whether they are European orJapanese or domestic or Canadian, that willtell them this product is packed under PacificNorthwest Seafood Association standards andtherefore is good. Few processors can providethe total volume that a single buyer mightwant. The association could be involved inmatching buyers who want large volumes withprocessors who can produce part of thatvolume. We need continuity of quality. Anotherpart of this effort is name recognition similarto that which Tillamook has established indairy products,

R. Williams: Quality assurance won’t work ifit’s not market driven. The people who marketthe product should be the people who set thequality standards. We need to specify whatquality standards will be. Do they need to beset by scientists or by people who are market-ing a product line to the public? What drivesthose standards is the customer.

J. Rasmussen: Is it possible to establishstandards with all the variety of product thatyou have coming in? There must be someminimum level standards. You aren’t going tosell Icelandic fillets that are far below whatpeople have typically bought, even though youmay be adjusting to your customers’ needs.

S. Bogason: Our group has specific stan-dards. We don’t sell fish below those stan-dards. Our minimum standard is actually alittle bit higher than the government standardbecause we have a marketing company. Ifyou’re selling a low-grade product, forget it.

G. Sylvia: One reason Pacific whiting hasbeen called a low-grade product is that it’shard to control the quality. The efforts in thelast few years have improved the product qual-ity. Some techniques used have been refriger-ated seawater systems, fishing short tows, andcatching and processing quickly. Now the ques-tion is, What are the minimum standards thatthe association wants to establish? Individu-ally, you may want to set higher standards oradjust to specific buyer needs. Those are thekinds of questions the industry has to dealwith.

C. Gorga: The issue is not simple. Theremust be a process. The entire industry has toget together and decide on the standards. Thefirst thing is to distinguish between qualitycontrol and quality assurance. Quality assur-ance keeps the consumer in mind, and qualitycontrol thinks of the next buyer. There aremany subtle differences between the two, butthat is the key. Next you must discover whatthe consumer will accept. Scientists can tellyou what is possible from a technological pointof view. Each market has certain sociologicalrequirements that must be taken into account.There was an example this morning of theAlaskan Natives wanting a certain type of fishthat is not accepted by the controllers. Quality

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assurance is an agreement between the con-trollers and the processors and the fishers.Quality assurance is a process, not somethingthat some dictator proclaims. What is essentialto this process is collecting market informationand developing some kind of a feedback loop sothe information can be used in forming qualityassurance programs.

R. Williams: The Pacific Northwest SeafoodAssociation will complete the circle by servingas a marketing association. Fishers andprocessors will have direction in standards andtrends. The image of Pacific whiting hasalready been changed. You and I are the oneswho should set the standards. In a controlledregional test market, we found that customersloved five-pound packages of skinless, bonelessfillets. The association will be able to keep thiskind of standard and not kill the market witheither too much product or inconsistentquality. We want to expand the market, notkill it.

P. Howgate: I wanted to give examples oftrade association types of quality assurancethat might have some lessons for you. One isthe Scottish Salmon Growers Association,which has a quality assurance scheme for thewhole industry; this scheme covers the finalsteps of harvesting and packing the salmon-confirmation of size, grade, blemishes on theskin, correct packaging, and residue informa-tion for exportation. The product can then getthe logo stamped on it, announcing approvalby the Scottish Salmon Growers Association.The Scottish Salmon Smokers Associationwanted a quality logo on their product too.They consulted the institute where I work andwe drew up a code of practice and instituted aninspection scheme. The first round of inspec-tion was pitiless; we even failed the presidentof the association because he did not conformto the standards the association set.

Another trade group is the Shetland FishProducers Association. The Shetland Islandsconsiders everything that goes from there asexported. The industry has set up a small qual-ity control unit with about three inspectors ina small technical laboratory. Their plants arewell operated in terms of hygiene and such.The plants are approved and given the Shet-land Quality Assurance Company logo, whichis assurance to the customer. These programshave to be marketed because there’s no value

in having these controls unless your customersknow what you mean.

More people are asking, “If I’m going topay this much, how do I know it’s going to begood?” This is the demand. When profits arehigh and fish has become a luxury food, thecustomers quite rightly want assurance thatthey’re not wasting their money. We know thatbig profits are fragile in terms of storage in iceor in a frozen state. Fish must be handled withmore care than other protein foods. Theindustry has not been giving this assurance tothe customer.

C. Gorga: I have three comments. First, theassurance has to be serious, which means hardand tough. There must be a pledge of giving arefund to an unsatisfied customer. You shouldnever reach that point, but it must be thatstrict. Second, the logo will be your way ofexcluding the processor or fisher who will notrespect your standards. You must control thatpower because it is the logo that will assurethe consumers. That logo has to be true; it hasto say, “Yes, this is really high quality.” Thisbecomes an enforcement of your qualitystandards because those who do not meetthose standards must be excluded from receiv-ing the logo. The third point is that we do havestandards. We have U.S. grade A quality fromNMFS.

T. Moreau: This is an excellent opportunityfor you as an association to work with myagency. You’ve got to be up front. We need todiscuss shelf life and performance because ifwe sell the military a bad item they’re notgoing to buy it again. The requirement ismeeting the grade A standard. The military isinterested in Pacific whiting because it is adeveloping fishery and because of the qualityimprovements.

You can grade in accordance with theNMFS system without having an inspectorcontinuously present during processing. Thereare costs, but they are only a fraction of a cent.What you have to consider is that even withthese rough estimates, the cost of quality wasabout 10¢ a pound. But you could sell thatsame pound of fish for a dollar more.

T. Libby: When it comes to the point when weare satisfied with quality standards and plantsagree to the standards, we should separateourselves by emphasizing the differences of

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Pacific whiting from the rest of the pack. If weput an identity on our fish and build consumertrust, we’re making our own market.

M. Morrissey: The Scottish Salmon Growers’quality assurance program is more in line withgood manufacturing practices than the endproduct evaluation, which has merit; but Ithink there’s more. With Pacific whiting, evenif you have good manufacturing practices allthe way through, you might have some inher-ent variation that could result in high proteaseactivity or other problems that lower qualityeven though it was produced under the seal ofapproval. Possibly what is needed is a combi-nation. You might have to include all handling:at sea, in the processing, and on down the line.

P. Knight: The Pacific whiting going tomarket now is better quality than a few yearsago when we used dry pumps. There have beena lot of advances in technology in harvestingand processing whiting. Another improvementis the emphasis on marketing.

T. Moreau: I’d like to go back to the questionof the quality requirements of the military,They buy quality products, and they know thatthey pay for costs that are incurred to get tothe quality level they want. They have donethat for years and will continue to. They’relooking for new species of fish. One of thethings they’re not looking at is value added.They want traditional fillets because theyalready have their recipes, and their recipesare almost sacred.

T. Libby: I’d like to ask those of you fromother countries if you think we’re headed inthe right direction. If not, which way shouldwe go?

T. Martinussen: You need to analyze thesituation and then improve step by step. Withstandards, people are paid according to qualitycriteria. What are those criteria that consum-ers are willing to pay for? All processors needto pay according to quality. Those who fallbelow the standard should be warned and toldwhat criteria they must meet. The policy of theassociation should be to give information abouthow to improve the processing and quality toget the best price out of a product. You need tocontrol all the factors. You need a system foridentifying the products and the producers, soyou know who is responsible. If there’s a

problem, you can go back to that processor andthe processor, not the association, will beresponsible,

G. Sylvia: One of the issues this association isgrappling with is enforceability. That’s wherethe largest cost is going to be. Members of theassociation could sit down with the work ofmarketers and other factors and start to lookat what the standards would be. We’re doingsome studies to look at what the costs will beto develop those standards. Can a programwork without enforceability? The concern isthat if we develop a common label across allplants, but one of those plants falls below thestandards, that would smear other producerswho did meet the standard and ultimatelylower the price. We want to make sure thatdoesn’t happen.

P. Howgate: The whole business of anassociation-type logo is buyer confidence. Theassociation’s reputation will back up yourquality, but you’ve got to advertise to makepublic what your standards are. Enforcementis crucial. Financing is crucial. The Shetlandassociation is financed by a levy on the value ofthe fish. I don’t have an exact amount, but Iagree with Tom Moreau that it’s really a smallamount of the total value. The Shetlandsystem has been in existence for some time, sothey must be able to recoup that levy by theadditional value they can get by saying thishas come from Shetland.

C. Gorga: It all depends on the rules andregulations governing the association. You setthem up through the process of getting all themajor players in the same room and develop-ing the standards. After the standards areaccepted, they must be enforced.

R. de Beer: What it mostly sounds like is theseafood association here really needs qualitymanagement systems itself to work with theprocessing companies. You need to developstandards and codes of practices and then havean auditing system from this organization.

Member of audience: As a bureaucrat in themidst of all the processors, one thing that didstrike me is that quality lost cannot be re-gained. The traditional fishing fleet needsparticular attention. The industry must beaware of the whole process, from when the fishfirst leave the water, through the boats on to

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the plants; all these factors need to be built down to this: the value of the seal is only asinto the standards. good as the weakest player. If you don’t weed

out people who aren’t going to conform, theMember of audience: There have been value of the seal and all that money can just besimilar discussions in Alaska for half a dozen blown out by the first guy who decides to takeyears on the use of a seal. It always comes shortcuts.

ce

trategies

Donald A. Corlett, Jr.Corlett Food Consulting Service, Concord, California

INTRODUCTIONThe recent emphasis on helping people do bet-ter in the business environment has resultedin a relatively new approach to group processcalled total quality management (TQM). TQMis a “people system” that provides the opportu-nity for individual employees to effectively con-tribute to planning, implementation,operation, and continuous improvement ofcompany operations.

The principles of TQM are most appropriatefor the effective development and implementa-tion of new company programs such as thehazard analysis and critical control points(HACCP) system. HACCP is a systematic ap-proach to food safety (Codex 1991; ICMSF1988; USNACMCF 1989; 1992). It is organizedfor use by teams but is primarily a technicalprocedure for the identification of potentialhazards for a food and development of themeans to prevent or control the hazards in thefood manufacturing and marketing system.

This paper contains a short discussion ofTQM, quality assurance, and the use of TQMprinciples for HACCP implementation. TQMgroup process techniques will be illustrated forpreparing the HACCP plan and for implement-ing the HACCP system for the ingredient pro-curement, production, distribution, and retailsequences for bringing a reliably safe foodproduct to the consumer.

TOTAL QUALITY MANAGEMENTPRINCIPLES

Total quality management is defined as “aphilosophy, a set of concepts and a collection ofmethods for continuously improving organiza-tions” (Golomski 1992). An organization thatuses TQM in its operations would create anOperating environment for all company em-ployees based on the following principles:

* Customer-driven quality - a strategicconcept

Leadership--sustained support bysenior management

l Continuous improvement - applied to alloperations

0 Full participation - committed andempowered work force

e Fast response-reduced project-cycletime

o Design quality and prevention - prob-lems prevented by building in quality

* Long-range outlook - goals, plans, andapplication of resources

Management by fact-decisions basedon reliable data and analysis

Partnership development - everyoneworks together

l Public responsibility-corporate respon-sibility

These 10 principles are the core concepts ofthe Malcolm Baldrige National Quality AwardCriteria (Surack 1992).

TQM provides the ground rules to encour-age an effective group process for people in acompany to plan, develop, implement, and op-erate systems or programs such as HACCP. Inparticular, TQM emphasizes the establishmentof goals, leadership, an environment of preven-tion and continuous improvement, and the op-portunity for everyone to work together ingroups and teams to accomplish common goalsand objectives.

THE COMPANY QUALITY ASSURANCEPROGRAM

The company quality assurance program,sometimes referred to as the “umbrella” forproduct safety, regulatory compliance, andproduct quality systems, is illustrated in table1. The table indicates that product safety is amandatory program, where HACCP is the op-erating system and the type of monitoring isfor critical control points (CCP). A CCP is de-fined as “a point, step, or procedure at whichcontrol can be applied and a food safety hazardcan be prevented, eliminated, or reduced to ac-ceptable levels” (USNACMCF 1992).

The other activities that fit in the umbrellaquality assurance program are regulatory com-pliance and the product quality system. Notethat these systems are required or voluntaryand do not always require a critical controlpoint for monitoring. Product quality monitor-ing usually requires monitoring by controlpoints (CP), defined as “any point, step, or

Table 1. Types of ractivities clusteredunder the umbrellacompany qualityassurance program.

Importance

System

Type of ControlPoint Required

Product Regulatory ProductSafety Compliance uality

Mandatory Required by Law Voluntary

HACCP Regulations Quality Control

Critical Control Critical Control Control PointPoint (CCP) Point (CCP)* or CP)

Control Point (CP)

* A CCP would fall under regulatory compliance when it would involveproduct safety. It would be both in the HACCP and Legal Compliancesystems. An example would be the legal requirement for a pH of 4.6 or lessfor the safety of an acidified canned food. Control points (CP) would be usedfor legal requirements that do not involve product safety.

procedure at which biological, physical, orchemical factors can be controlled”(USNACMCF 1992).

There are other programs that are consid-ered parts of the umbrella quality assurancesystem and are related to product safety andregulatory compliance. They include applica-tion of the good manufacturing practices(GMPs), environmental controls, control oftoxic substances, labeling, and analyticaltesting.

INTEGRATING HACCP INTO THE TOTALQUALITY ENVIRONMENT

HACCP is a preventive approach to foodsafety assurance that requires the education ofpersons using the system, analysis and plan-ning, coordination of different departments ina company, and above all, an attitude of dy-namic improvement and action. This modernapproach to food safety is greatly facilitated bythe total quality management environment.

Table 2 lists the complete sequence oforganizational events and actions necessary forimplementing the HACCP system in a foodfacility. Note that although managementbegins the process, subsequent developmentand responsibility is delegated to the HACCPcoordinator and the core HACCP team, toproduct-specific HACCP implementationteams, and ultimately, to the line operators.

The actual integration of HACCP into theexisting TQM environment begins with sus-tained support from top management. Man-agement must be involved to set the example

because HACCP-TQM is motivational. Ifpeople are not motivated to keep food safe,technical development of the safety system isseldom successful. Management must initiatethe TQM process by clearly stating food safetypolicy and goals, which may appear as follows:

Food SafetyPolicy: “All company food products

will be safe for consumption.”Food SafetyObjectives: l.“The company will plan

and implement a HACCPsystem for product safety.”2. “The HACCP system willbe operational by "(a stated future date).

The next step is for management to appointthe core HACCP team, which initiates the ac-tual development of the HACCP system. Thecore team may be appointed at the corporate ormanufacturing facility levels. It oversees thedevelopment of HACCP plans, training, trans-lation of the plans into manufacturing prac-tices, start-up, and continuous operation andimprovement of the HACCP system in thecompany.

The team is composed of 7 to 10 people rep-resenting a cross section of the manufacturinggroup. The HACCP team coordinator is usu-ally the quality control manager for the com-pany or plant. The team may consist of two orthree manufacturing supervisors and opera-tors and quality control, purchasing, mainte-nance, sanitation, and distribution personnel.Other persons from outside a facility may be

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Organizational

Management

HACCP coordinator and core HACCP

Management and core HACCP team

Actions

* Policyl Objectives* Appoint HACCP coordinator* Train coordinator and team

e Develop HACCP project plan* Develop initial HACCP plan* Appoint product teams. Conduct training for teams* Assist product teams

* Develop product HACCP plans* Develop operator proceduresl Plan operator training* Conduct trial test runs* Help line operators start HACCP

. Monitor individual CCP* Take corrective action* Do most record keepingl Help improve system

l Verificationl Update and revise HACCP plan

Table 2. Sequenceof organizationalevents and actionsnecessary forimplementation ofthe HACCP systemin a food facility.

product development and quality assurance.on the team, such as members of corporate

This core team uses the TQM process ofmeeting and operating as a group. In somecompanies, the team has a leader and a facili-tator. All persons are given the opportunity toparticipate in the planning, discussion, andactions of the group. The core HACCP teammay appoint other teams to develop HACCPplans and systems for specific products pro-duced at the company or in the manufacturingfacility. Sometimes members of the coreHACCP team serve as the team leaders for thesatellite groups. These groups are sometimescalled manufacturing teams.

2. Describe the food and its distribution.3. Identify the intended use and consumer

1. Assemble the HACCP team.

of the food.4. Develop the flow diagram.5. Verify the flow diagram.Following these steps, the team develops

the hazard analysis (also termed the risk as-sessment), HACCP principle 1, consisting ofthe review of multiple risk factors for each stepin a food process (USNACMCF 1992, AppendixA).

An important point to be made concerningthe hazard analysis is that the teams will needthe assistance of technical experts for in-depthinformation on microbiological, chemical, andphysical hazards. Expert information supple-ments the team’s “real world” expertise withthe actual production system and processingtechnology. The hazard analysis helps theteam to examine each step in the process toidentify potential hazards and to develop themeans to prevent the hazards.

MANUFACTURING TEAM DEVELOPMENTOF THE HACCP PLAN

A. Description of HACCPThe definition and seven principles of the

HACCP system are given in table 3. TheHACCP system sets forth a systematic proce-dure for development and documentation ofthe food safety controls for a specific food.

Five preliminary steps are necessary beforeapplication of the HACCP principles(USNACMCF 1992). These steps guide theteam in developing the information needed toapply the seven principles. They are as follows:

As noted in table 2, development of theHACCP plan is a first priority. The HACCPplan is defined as “the written document whichis based upon the principles of HACCP andwhich delineates the procedures to be followedto assure the controI of a specific process orprocedure" (USNACMCF 1992).

9 9

HACCP is a systematic approach to food safety consisting of seven principles:

Table 3. HACCP system 1. Conduct a hazard analysis. Prepare a list of steps in the process where signifi-cant hazards occur and describe the preventive measures.definition and principles.

2. Identify the critical control points (CCP) in the process.3. Establish critical limits for preventive measures associated with each identified

CCP.4. Establish CCP monitoring requirements. Establish procedures for using the

results of monitoring to adjust the process and maintain control.5. Establish corrective actions to be taken when monitoring indicates that there is

a deviation from an established critical limit.6. Establish effective record-keeping procedures that document the HACCP

system.7. Establish procedures for verification that the HACCP system is working cor-

rectly.

Source: USNACMCF, 1992

B. Example HACCP Plan for Fish Fillets Parts of the HACCP plan not shown areI’m using selected parts of a model HACCP record keeping and verification. Record keep-

plan for refrigerated fish fillets to illustrate the ing is fairly straightforward, its objective toresults of the HACCP team’s work. The hazard make sure that the HACCP system, and par-analysis has already been completed by the ticularly monitoring and correction actions (re-team. The next six figures illustrate the action- quiring deviation control), are documented,oriented parts of the HACCP plan that are signed off by the operator and management,used for the product-specific HACCP system. and kept in a secure but accessible location inFigure 1 gives examples of the results of the the facility. Verification is also planned and ishazard analysis for fish fillet production. This based on review of the HACCP plan, records,shows five selected production steps, potential observation of the operation of CCP, and if de-food hazards identified at the specific step, and sired, analytical testing to verify that CCPs arepreventive measures. under control.

Figure 2 illustrates the types of CCP thatwere developed from the preventive measuresthat include the description of the critical con-

CONVERTING THE HACCP PLAN INTO

trol point, its critical limits, the monitoring ac-PRODUCTION PROCEDURES

tivity, and corrective action. Converting the HACCP plan into the proce-This figure illustrates the parts of the dures needed on the production floor is accom-

HACCP system that are used on the produc- plished by the more conventional TQMtion line to monitor the application of food procedures used to establish new programssafety controls and to apply corrective action if and to achieve the benefits of continuous dailymonitoring indicates that a CCP is out of con- improvement. Central to the establishment oftrol. Note that the core HACCP team has made HACCP is a project plan that lays out the se-these action parts of the HACCP plan, such as quence of events leading up to start-up of the"stop the line” and “immediately place the food HACCP system (as given in table 2).on hold” - very specific and straightforward. By far the most important phase of estab-This clarity is necessary for people who must lishing HACCP in the production system istake corrective action when action is required. translating the HACCP plan critical controlAlso, note that the HACCP plan (in the ex- point information (i.e., critical limits, monitor-ample) is extended to the refrigerated trucks ing, and corrective action) into procedures forused in distribution and to the retail refriger- people to use on the production floor. TQM isated display cases. most effective when the teams develop the

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ProductionStep

Raw fish

Inspection

Cooking

Trucking(distribution)

Figure 1. Examples*of the results of ahazard analysis forfish fillet production.

Retail display

Identifiedazard(s)

Potential:microbiologicalchemical, andphysical hazardsMetalcontaminationSurvival ofhazardousmicroorganisms

Temperatureabuse andgrowth ofhazardousmicroorganismsTemperatureabuse andgrowth ofhazardousmicroorganisms

PreventiveMeasure(s)

Establish andenforce specificationsfor receipt of raw fish

Metal detector

Correct cookingprocedure (such astime and temperatureof the cook)Chill truck to < 35° Fbefore loading;monitor compartmenttemperature

Maintain product inrefrigerated food caseat < 40° F; do notexceed shelf life.

* Preventive measures for other steps and identifiedhazards could include refrigeration; sanitation; protectionfrom cross-contamination from raw materials or sources ofmicrobiological, chemical, or physical contamination;correct employee hygiene; and other means to prevent foodhazards.

CCP Number

No. 1: Adherence topurchase specifications

No. 5: Metal detector

No 11: Cook time andtemperature for food (oneminute @ XXX° F)*

No. 21: Precool refrigeratedtrucks to 4.4° C beforeloading product

No. 22: Retail producttemperature 4.4° C andshelf life

Monitoring

Comply: each lot

Continuous

Continuous: time andtemperature recorder

Before each load

Each week

Corrective Action

If not in compliance:reject lot

If metal detected:l Stop line and correct cause.l Hold food and dispose of safely.

If low time or temperature:l Stop cook and correct cause.l Immediately recook or hold and

dispose of safely.

If truck temperature is above 4.4°C: Do not load truck until it iscooled to 4.4° C.

If temperature exceeds 4.4° C or ifshelf life is exceeded:l Work with store to lower

temperature.l Remove product.

*Temperature to be determined experimentally for size of portion and type of cookingsystem (that is, deep fat frying, oven cook, grill, and so on).

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l HOW IS THE MONITORING INSPECTIONCONDUCTED?

l MUST EQUIPMENT BE DISMANTLED?

l WHAT IS LOOKED FOR?

l HOW WILL THE INSPECTION PERSONDETERMINE IF T H E CRITICAL LIMIT ISIN SPECIFICATION?

l HOW WOULD YOU TELL A PERSON TOMONITOR THE CRITICAL CONTROLPOINT?

Figure 3. Guide for preparing operator proceduresfor monitoring for one critical control point.

wording for operators to use in monitoring andcorrective action. The teams are encouraged toinvolve the hourly workers in testing andworking out the bugs in the new procedures forthe CCPs. Figure 3 provides a guide for the de-velopment of monitoring procedures, and fig-ure 4 is a guide for corrective actionprocedures.

Completion of “floor” procedures makes itpossible to begin the trial runs that are used asa shakedown of the new system. They may beinitially started on one line. The core HACCPand the product teams monitor the trial runsand may need to go back to the drawing boardson occasion to make procedures more explicit.Sometimes the teams discover that a criticalcontrol point cannot be monitored because noone realized that the equipment could not beopened or disassembled for inspection. It maytake several months to work all the bugs out ofthe new HACCP system, and it is not unusualto discover many potential safety problemsthat were not noticed before the use ofHACCP. The use of TQM provides for continu-ous review and refinement of the HACCP pro-cedures used by food processing personnel.

ADVANTAGES 0F USING TQMPRINCIPLES TO IMPLEMENT HACCP

TQM makes the scientifically provenHACCP system available to company employ-ees. Because employees prepare the HACCPplan, they are knowledgeable about transform-ing the plan into food safety action procedures.Increased awareness is created when a largenumber of people are involved in developingthe HACCP system. This involvement appears

. IMMEDIATE CORRECTIVE ACTION FOR THEMANUFACTURING LINE?

* WHO DOES THE PERSON NOTIFY AND WHEN?

. IMMEDIATE ACTION TO PLACE PRODUCT ONSECURE HOLD.

* WHO DOES THE PERSON NOTIFY THAT PRODUCTIS ON-HOLD AND WHEN IS NOTIFICATION DONE?

Figure 4. Guide for preparing operator proceduresfor corrective action when monitoring indicates thatthe CCP is out of control and a safety hazard mayexist.

to gradually establish new behavior towardscontinuous product safety assurance.

The HACCP-TQM approach is particularlyeffective in helping to prevent catastrophicpublic safety exposures and product recalls.These episodes are rare and sporadic, but theymay be extremely serious, causing injury anddeath. Prevention is the key, and experiencehas demonstrated that maintaining productsafety requires a carefully planned food safetyprogram and active participation of every com-pany employee. Combined TQM-HACCP tech-niques are applicable to large and smallcompanies alike. Industry associations can as-sist smaller companies by helping to establishmodel HACCP system plans that streamlineimplementation.

REFERENCESCodex. 1991. General Definitions of HACCP

and Procedures. Codex Committee On FoodHygiene, Codex Alimentarius Commission,25th Session. Borne: FAO.

Golomski, W.A. 1992. Keynote talk givenduring a preconference workshop on "TotalQuality Management,” Program for the1992 IFT Short Course, IFT Annual Confer-ence, New Orleans, LA, June 19,1992.

International Commission on MicrobiologicalSpecifications for Foods (ICMSF). 1988.HACCP in Microbiological Safety AndQuality. Blackwell Scientific, Oxford,England.

Surak, J.G. 1992. Using the Malcolm BaldrigeNational Quality Award Criteria to Drivethe Total Quality Management Process.Food Technology, June, p. 70.

U.S. National Advisory Committee on Micro-biological Criteria for Foods (USNACMCF).

1989. HACCP Principles For Food Produc- U.S. National Advisory Committee on Micro-tion. Ad Hoc HACCP Working Group, biological Criteria for Foods (USNACMCF).chaired by D. A. Corlett. Pamphlet available Revision of the 1989 HACCP Guide. 1992.from USDA-FSIS Information Office, Room International J. of Food Microbiology 16:1-1160, South Building, Washington, D.C. 23.20250, U.S.A.

ESTABLISHING SASSURANCE

John ClemencePharmaceutical and Food Specialties, San Jose, California

WHAT DO WE MEAN WHEN WE TALKQUALITY?America is noted for creating ‘buzz words” andhot concepts without taking time to under-stand them. For the last half of the 1980s, oneof these magic words was quality. Look at anyseafood publication and you will notice thatevery company advertising in it claims to pro-duce quality products. However, if you sur-veyed the average person on the street, youwould hear a lot of horror stories about sea-food. I think we all agree there is room for im-provement. The question is, how do we makethat improvement? We do it by having a qual-ity assurance program, or as I like to think ofit, a quality improvement system.

Quality is really about customers: how acompany gets them, how they are treated, andhow they are kept satisfied. Ultimately, thecompany’s success with customers determineswhether it succeeds or fails. There is an oldsaying, “If it isn’t broke don’t fix it.” At facevalue this seems to make sense, but what itreally says is don’t worry until things totallybreak down. That’s not a very good way tokeep customers happy. I’m going to talk aboutways not only to make sure things don’t breakbut to improve them.

SOME BASIC TRUTHS OF QUALITYThere are some basic truths that relate to

quality assurance programs, whether they arein the seafood, automobile, or electronicindustry.

First and foremost, a quality assurance pro-gram works only when top management iscommitted to it and drives it. If the company’sCEO does not push the program, it will neverbe truly effective. The employees will quicklyfigure out the true priorities and act accord-ingly.

Second, the process will not succeed withoutthe involvement of the company’s employees.Wherever quality improvement programs havebeen successful it was because the programsinvolved the employees. People respond in kindto the way they are treated: if management’s

approach is to treat the workers as mindlessrobots that can be trusted to do only what theyare told, it isn’t surprising that the employeesdon’t show any initiative or come up with inno-vative ideas. On the other hand, if they aretold what the goals of the company are andwhy things are done a certain way, they aremuch more likely to notice what is happeningand let supervisors know when problems arise.They are also much more likely to suggest im-provements to the equipment or procedures.

Seafood processors have more difficultythan other industries in instituting this part ofa total quality program; they employ manyseasonal and short-term workers, and therealso are often language problems. Even short-term employees, however, work better if theyfeel their thoughts are valued and they under-stand why things are done the way they are.Don’t dismiss them as worthless because theyare temporary. Other important sources arethe longer-term employees, such as mainte-nance engineers, mechanics, office personnel,and production line leads. Whatever your situ-ation, remember, the ideas are there; you justmay have to look harder.

Third, you cannot inspect quality into aproduct. The people who check samples at vari-ous stages of production are only telling youhow you are doing; they are not improving thequality of that product. The only way to im-prove the product quality is to have a formalquality assurance program.

Fourth, quality does not cost money. To es-tablish a quality assurance program or inten-sify the one you already have may increasecosts briefly, but time and time again it hasbeen shown that the payback more than ex-ceeds the costs. The key to getting thispayback is to use the information gathered.This is the critical step often not taken in theseafood industry.

Fifth, quality control is not quality assur-ance. Having a system of technicians perform-ing tests and making records does notconstitute a complete quality assurance pro-gram. Without a system to incorporate the in-formation gathered into an overall master

104

plan, there will not be much progress. As a cor-ollary, this conference includes several discus-sions about HACCP. HACCP is an excellentconcept. However, when it is designed solely toachieve regulatory compliance, it is not a qual-ity assurance program.

UALITY ASSURANCE?

Quality assurance is a systematic approachto organizing your thoughts when reviewing aproduction process. Its purpose is to enable acompany to produce products better andcheaper. It is also designed to allow the plantto maximize its financial revenues from theproducts it produces.

It basically involves four steps:1.

2.

3.

4.

Planning. Determine where you want togo and what you are going to do to getthere.Testing. Implement the plan. This isoften done on a trial basis. Keep com-plete records of the tests.Reviewing. Review what you did usingthe information you gathered.Modifying. Plan any changes that youfind are needed based on your review.During this step, keep in mind the goalyou established earlier.

The last step returns to the first step andthe process repeats itself.

WHAT IS THE DIFFERENCE BETWEENQUALITY ASSURANCE AND QUALITYCONTROL?

There is often confusion about the differencebetween quality control and quality assurance.A quality control program is only one part of acomplete quality assurance program. Qualitycontrol is the system of checks and tests thatare conducted throughout the plant to deter-mine the status of the fish and related prod-ucts during the processing.

Quality assurance, on the other hand, is thesystematic process that was followed to de-velop and define the quality control program.It is also the system that is used to monitor theeffectiveness of the quality control program. Itis the way information from external sourcessuch as customers, ingredient suppliers, com-parative cuttings, and regulatory agencies isgathered, analyzed, and turned into the qual-ity improvement program. Quality control tellsyou where you are. Quality assurance lets youdetermine where you want to go and how far

you have to go and sets up a road map to getthere.

Quality assurance also includes a procedureto audit the quality control program. This iscombined with the feedback described previ-ously and used to evaluate the effectiveness ofthe overall program. In addition it is critical toobtain feedback from the plant personnel actu-ally living with the program. Can the techni-cians performing the testing think of someimportant areas that are being overlooked? Doproduction managers have suggestions forminimizing the testing’s impact on production?What do the plant engineering and mainte-nance staff think about the identified areas ofconcern?

A quality assurance program is dynamic. Toachieve maximum effectiveness, it needs toevolve. That evolution must be reflected indocumentation. Feedback from the customermust be actively sought. That informationmust be quantified and compared to the origi-nal goals and premises used to develop thequality assurance program.

For the seafood industry that feedbackcomes not only from the customer; the plantmust also be aware of the concerns of the vari-ous regulatory agencies.

In the early days of the seafood processingindustry, the whole decision-making processwas much easier. The company president dis-cussed production and quality problems withthe vice-president over dinner and then ex-plained any changes to the workers when theytucked them into bed at night. Today the sys-tem is much more complex.

COMPONENTS OF A SEAFOOD QUALITYASSURANCE PROGRAM

The goals and objectives of the companymust be understood. Usually the most basicgoal is to stay in business. For seafood thismeans selling the product for more than it costto produce it. It means repeat sales to repeatcustomers and getting the maximum value forall products. The quality assurance plan beginswith this basic understanding.

The first step is to determine the customer’sneeds for the products you produce. There areseveral aspects to this. What are the qualitylevels the customer wants, and more impor-tant, what attributes does the customer con-sider in determining quality? For example,how important are things like scale loss, meatcolor, oil content, and the fat layer on white-fish? What product size classification does the

customer want? How is the product to be pre-pared? What about processing style? Considerpacking style and container size. Warehousestores such as Costco and Pace have created ademand for container sizes that were not usedin the past, and those companies that adjustedtheir production fastest have secured a vastnew market.

ESTABLISHING THE QUALITY CONTROLPORTION OF A QUALITY ASSURANCE

The first step is to outline the entire process,just as you would if you were setting up aHACCP plan. Then assign risks following thesame procedure you would use for that pro-gram, but when you think of the “risks or haz-ards" associated with each point, don’t limityourself to questions of public health. Expandyour analysis to consider whether the step canaffect the customer’s satisfaction with theproduct. A step may have little or no healthconsequences but may significantly affect theprice you get for your finished product. An ex-ample of this is mishandling salmon - grab-bing and lifting them by the tail. This causesbruising, which has no public health signifi-cance but which destroys the value of the fishfor sale to a smoker who is going to split thefish.

When you have finished outlining the steps,assign them risks, using whatever value sys-tem you prefer. Common choices are numeric,meaning 1, 2, 3, 4, and 5, and descriptive, us-ing terms such as aesthetic, minor, major, seri-ous, and critical. Decide the risk levels you willmaintain records for and give thought to thepracticality of the records you plan to use.Records wilI not prevent something from goingwrong. The quality control checks and plantoperating procedures serve that function. Thereasons for keeping records are to minimizethe impact of any difficulty that may developand to learn from it. The records should becomplete enough that you can use them to de-termine what went wrong and when and howmuch product is affected. They should showwhen and how a problem was corrected. Theyallow analysis of the scope and nature of thedifficulty so corrective action can be targeted tothe appropriate area.

Balanced against the need for records to becomplete and comprehensive is the problem ofoverkill. It is very easy to make so manyrecords that the number of technicians re-

quired to fill them out increases the plant’soverhead to the point at which it is no longercompetitive and the purpose of keeping therecords in the first place is defeated because noone looks at them or understands what theyrepresent.

A final comment on quality control checks.To have maximum value, all tests must have avalid statistical basis. This means the samplesize must be large enough to be statisticallyvalid and the lot sampled must have commoncharacteristics. A sampling manual such asMilitary Standard 105E is a must.

SOME SIMPLE QUALITY CONTROLCHECK POINTS

To give you an idea of how a quality controlprogram can be developed for seafood, I’m go-ing to list some check points to consider. I’msure that with some thought you can identifyothers not mentioned. When reviewing yourprocess, remember the basics of maintaininggood quality seafood:

Keep it cool.Keep it clean.Keep it moving.Handle it carefully.By using these guidelines, you can tailor a

quality control program to a particular plant.

INCOMING PRODUCT QUALITYFor seafood, this is the most critical area. It

is not possible to improve the quality of a fishabove the level it was at when received. Thebest you can do is minimize the rate of decline.The concerns at this point may not be relatedto public health. For example farmed catfishare brought to the plant live, so there is no con-cern about decomposition. They are sampledextensively, however, for quality because fishin some ponds may develop strong, muddyodors that make them far less valuable. An-other example of a quality problem that doesnot concern public health but that should bedetected at receiving is chalky black cod. Thecritical criteria for your raw product should beoutlined and the test procedures designed tocheck for those criteria.

Any incoming materials used in the process-ing should also be inspected. Are the packingcartons being used what you specified? Whatabout the liners?

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SEAFOOD IS

In situations where the fish are not held forlong before processing, such as factory trawl-ers, trollers freezing on board, aquacultureplants, and processing plants that are able tohandle the fish without storing, it is not neces-sary to check the fish a second time. There areother situations, however, where the fish maybe stored at the plant for a day or more beforeit is processed. In those cases, it is important tocheck the fish a second time, to make sure ofthe quality and suitability when it is actuallybeing worked.

IN-LINE PROCESSIN GCheck the effectiveness of the butchering

and dressing steps. Include a feedback proce-dure to let the workers know how they are do-ing. If the head cuts are too long, let themknow. If there are 10 butchers and you find ev-ery 10th fish has viscera remaining, it is prob-able that one of them was not given completeinstructions on how to clean the fish.

MONITOR THE GRADING STEPThis is one of the most critical steps in the

process in terms of maintaining customer sat-isfaction. A good quality assurance programincludes a program of statistically based sam-pling of the graded product. Nothing makes acustomer madder than receiving a grade 2product and being charged for grade 1. If theplant packs for several different buyers, eachhaving slightly different product criteria, youhave a problem waiting to happen. An ap-proach I have seen effective at this point is aseries of wall charts that list the grading crite-ria for each buyer or pack style. If the gradingis not checked, you don’t really know what isbeing shipped to your customer.

FINISHED PACKAGE CHECKSJust as it is critical to monitor the effective-

ness of your grading, it is vital to check thecondition of your product as it leaves yourplant. You need to know that the product ispacked the way it is supposed to be, the con-tainers are correctly marked, they contain theproper amount of product, and the packagingis correctly done. If you use preprinted cartonswith sections to be checked to show producttype, make sure they are sized and located so

the workers can mark them properly. If not,this can cause serious problems farther alongin the distribution chain. Are the liners prop-erly folded? Another packaging problem is im-properly sized packages. Boxes that are toosmall usually lead to product damage whenthe workers try to put five pounds of fish in afour-pound box. On the other hand, too large acontainer allows product to shift and break.

AUDIT YOUR QUALITY CONTROLPROGRAM

When the quality control program is in op-eration, it is critical to conduct routine audits.They tell you if the checks are appropriate forthe attributes you want to monitor. Don’t heafraid to drop a check or move it to a differentpoint in the process if it is not productive.

The most difficult part of making a qualityassurance program work is the human ele-ment. Be aware of it at all times. Wheneveryou conduct an audit, it is important to avoidan atmosphere of blame. Talk about problemsand solutions, not individuals. Concentrate onpreventing problems, not assigning responsi-bility for past faults.

QUALITY ASSURANCE IS AN ONGOING,EVOLVING PROCESS

Sometimes it seems that the only constantin business is change. We are in an era of glo-bal markets and global suppliers. In the past,your competition was the plant across theriver. Now it is just as likely to be the plantacross the ocean. This is especially true forvalue-added products. The Pacific Northwestand Alaska are uniquely situated in the centerof vast fisheries resources. The three states ofWashington, Oregon, and Alaska account forwell over one-half of all the fishery productsharvested in the United States. Unfortunately,this abundance has lead to our complacency.We have assumed we could always pass on thecosts of our operation to the consumer. If theydidn’t like it they could try to find it elsewhereor cheaper. That is exactly what has happened.Salmon is farmed in Norway, Scotland, theUnited States, Canada, and Chile. Ring crab,canned salmon, halibut, and whitefish arecoming from Russia.

We are no longer the only game in town,and to be honest, when compared to farmedfish, we also are not the best game in town.The only thing left open for us is to be the

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smartest game in town. Farmed fish may bethe Mercedes of the industry, but remember,not everyone can afford or even wants aMercedes. The Japanese built their automobileindustry making economy cars. However, theymade the most dependable, the most consis-tent, the best economy cars around.

The point of all this is that you have the re-sources; now you must maximize your returnfrom them. Do this by communicating withyour customers continuously: find out whatthey need and how they need it. Ask whatother processors are doing. Keep a formalrecord of any complaints you receive, act onthem, and let the customer know what you aredoing. Don’t be afraid to let the customer talkdirectly to the plant quality control and pro-duction managers. Communication rarely im-proves when it’s filtered through severaldifferent individuals.

Ask the users if there are any changes orvariations in product form, pack style, packagesize, or package construction that would bemore useful to them. Work with them to de-velop the new products.

A trap that members of the seafood industryoften fall into is surveying the converted. Toooften we ask the wrong people what we shoulddo. Don’t talk only to seafood traders. Whenyou travel, step at a fish market or the seafoodsection of a supermarket. Listen to what theshoppers are saying; talk to the clerks behindthe counter. Find out what the actual con-sumer really thinks.

When you have talked to the buyers, thecustomers, and the people on the street andhave developed records of customer com-plaints, incorporate that information into yourquality assurance plan. Compare the problemsyou are checking for against the problems thebuyers are finding, and then change your pro-cessing procedures to prevent the problems.Where necessary change the quality controlchecks to monitor your performance in thesenew areas. Quality problems may involveitems such as billing errors and shipping er-rors. They must be addressed, they can’t be ig-nored simply because they don’t happen on theprocessing floor. A series of these types of er-rors can cost you customers as quickly as badproduct. The quality assurance system allowsthe plant to identify problems of this kind.

KNOW YOUR COMPETlTORS

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kets, talk to your brokers, and get samples. Docomparison cuttings. Note competitors’ strongpoints; don’t just look for areas where they aresubstandard. You’ll learn a lot more that way.

REGULATORY AGENCIESThe best way to avoid problems with regula-

tory agencies is to consider them customers,with specific requirements. If you try to under-stand their goals and design your quality as-surance program to include their concernsalong with those of your paying customers, youshould not have any serious problems. Keepcurrent with their activities through yourtrade associations, university extension ser-vices, and trade publications. Be aware thatscientific tests are becoming more sophisti-cated all the time and people are becomingaware of problems they could not identify inthe past. For example when I studied microbi-ology, E. coli was an indicator organism. Itwasn’t anything to worry about in itself, butbecause it indicated potential fecal contamina-tion, you tried to minimize the counts. That isnot the way E. coli is treated today, as Jack-in-the-Box well knows.

A new requirement instituted by a regula-tory agency should be treated in the mannerdescribed above and the quality assurance pro-gram reviewed to see if it should be modified toaddress the new concerns.

SUMMARYTo summarize, a good quality assurance

program allows you to maximize your profitsby producing the best quality product for theleast cost.

I have spent over 20 years in the seafoodindustry developing and implementing seafoodquality assurance programs. I have facedmany challenging problems, including twobotulism recalls, Listeria concerns, and acanned tuna recall, and I have worked success-fully to find the solutions that would satisfythe regulators, the customers, and the com-pany management.

As independent consultants, PhF Specialistscan offer you insider’s knowledge with anoutsider’s objectivity. A company such as oursan assist you in matters ranging from estab-ishing a HACCP program to optimizing your

quality assurance program economically.

Successful industries continually checksamples of their competitors. Check the mar-

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Carmine GorgaPolis l tics Incorporated, Gloucester, Massachusetts

At the last Salon International De L’Alimen-tation (SIAL), visitors were treated to thisdelicacy: Arctic char fillets. And how were theyprepared? They had been marinated in honey,with chestnut topping-all bathed in cognac.Who is the consumer to resist such apresentation?

Of course, some will object to the alcohol forreligious or health reasons. And some will ob-ject to the sauces. But that is not the point.These are some of the reasons entrepreneurssearch for market niches. No one can be every-thing to anyone. The point is, each entrepre-neur must define quality.

THE DEFINITION OF QUALITYEach entrepreneur must define quality.

This is not an abstract operation. It is a veryconcrete one. Many factors must be taken intoaccount: the market, the competition, the tech-nical requirements, the human possibilities,the financial limitations. In our experimentalwork, Louis Ronsivalli and I took the U.S.grade A as the standard that the seafood in-dustry ought to achieve.

That is the first strategic decision that theentrepreneur must take. This decision will de-termine all the others. Once the standard ofquality is determined-and the standard oughtto be determined as objectively as possible - allother decisions will logically follow. The stan-dard of quality to be attained is the goal to bereached. Nothing less than that can be ac-cepted. Nothing less than that will determinethe success of the enterprise. Below or beyondthat there is only failure. All resources must bemarshaled to achieve that goal.

THE STRATEGIC PLAN: INTERNALORGANIZATIONAL REQUIREMENTS

It takes a strategic plan to organize re-sources. The plan ought to be all encompass-ing.. It must list all resources and direct themto the desired end. The resources comprise thephysical, technical, financial, and human re-sources at one’s disposal.

The Physical ResourcesNo physical resources, no marketable prod-

uct. This axiom appears to be especially rel-evant in the seafood industry these days. Andof course, there is a defeatist school of thoughtthat accepts the “reality” as is. One cannotfight Mother Nature, it is said. If the resourcesare not there, nothing can be done.

Another school of thought, however, looks atthe resources objectively - not as cod, flounder,or whiting, but as seafood protein. The old say-ing applies: All is in the eyes of the beholder.This is not a psychological trick. The search forproper definitions can be elevated to the rankof scientific investigation. The result of thesedifferent definitions is astounding. If onesearches for cod, one is met with scarcity. Ifone searches for seafood protein, one is metwith superabundance.

Where is the difference?The best way to describe the difference, per-

haps, is to keep in mind the difference betweenthe part and the whole. Cod is the part, bio-mass is the whole.

When one considers the biomass of the lakesand the oceans, scarcity is no longer a factor.Defeatism disappears. Entrepreneurshipthrives again. The issue then becomes this:what can be done with the biomass? Oneschool of thought approaches the solution fromthe point of view of changing the market in thelong run. Another school of thought ap-proaches the solution from the point of view ofworking with the existing market. The goal isthe same; the means are different.

The first school of thought designs strate-gies around the marketability of mackerel andherring through school lunch programs andthe Army. The other school of thought designsstrategies around the transformation of thebiomass into readily acceptable products: itwants to transform the underutilized portion ofthe biomass, from krill to mackerel and her-ring, into food pellets for salmon grown in fishfarms, for instance, and wants to bring salmonto the market.

The strategies of these two schools ofthought are not mutually exclusive. the size of

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the biomass is such that both goals can bepursued at once. And if they are both success-fully pursued, they will both reap an addedbenefit. The clarification of this issue startswith the question, Who does the overfishing oftraditional seafood species? One school ofthought says that it is fishers-and latelysportsfishers-who do the overfishing. Anotherschool of thought, marshaling scientific theo-ries as well as statistical evidence to supportits viewpoint, says that overfishing is done bythe natural predators of the traditionalspecies.

Since the predators are, among others, themackerel and the herring, catching them andsending them to market whether through aschool lunch program or via salmon, would re-duce the pressure on the traditional speciesthat is applied both by fishers and predators.

The Technical ResourcesAssisted by the technologist, one should let

one’s imagination run wild. It seems absurd,but that is what technologists do. They lettheir imagination run wild - in a controlledand systematic fashion. The combination ofnatural resources, systematic analysis, andimagination has traditionally been explosive.One never knows in advance what the resultswill be.

For the design of the quality assurance pro-gram, Louis Ronsivalli and his assistants tookinto account all the technical findings that hadbeen accumulated over the years by theGloucester Laboratory of the National MarineFisheries Service and many other laboratoriesall over the world. Since seafood is a perishablecommodity, the most important of these find-ings concerned the time limitations that deter-mine how long seafood can be maintained in aU.S. grade A condition. That limitation deter-mined all the technical requirements that hadto be met to assure the maintenance of thehighest quality standard for its most extendedduration. Time, temperature, and sanitationwere found to be the most decisive factors. Butthere were many others. Handling at eachstage of the distribution chain was a factor;and so were packaging and transportation.These factors are innumerable, but they arewell documented.

Rather than discuss these issues in this con-text, it might be more useful to touch upon onepolicy implication of our work - an implicationthat is sufficiently described in Gorga andRonsivalli 1988, chapters 3, 12, and 13. Con-sidering the low (concentrated) costs and the

potentially large (diffused) benefits, it is gener-ally appropriate for the government to assist inthe R&D process. A successful R&D effortfunctions as an insurance that the project isindeed financially viable.

The Financial ResourcesAs we shall see in a separate paper, finan-

cial resources vary from internal to externalresources. But in nearly all cases, quality as-surance plays a pivotal role.

The Human ResourcesArguably the best comment ever encoun-

tered in the field of human resources wasmade by an elder statesman of the fisheriesindustry, Mr. Frank Foley. Mr. Foley (1981)said, “Quality fish, quality people.” One cannothave the one without the other.

The field is vast and the literature burgeon-ing. Perhaps the two best sources are Crosby1979 and Covey 1989. But let us not be de-ceived or try to deceive others by this train ofthought. Unless two essential conditions arerespected, all efforts in the field of human re-sources are vain. The first condition is what allthe religions insist upon. People must respecteach other. True respect is a complex phenom-enon - it runs the gamut from appreciation ofthe other person to acceptance of his or herlimitations to true empowerment. When oneenters this sphere of observation, one goes be-yond status: the other person can be either theboss or the worker.

The other essential condition is financialreward. Talk can indeed be cheap. Deedscount. Financial reward is essential; after all,as even Adam Smith (1776, p. 275) well knew,“It is better . . . to play for nothing, than towork for nothing.” Respect with financialreward - that is the winning combination.

That is why employee stock ownershipplans (ESOPs) (when properly implemented)are such powerful instruments. They are theplatform on which human, legal, and financialrequirements can fairly be weighed.

The Implementation MethodologyMarshaling all the resources at its disposal

into a coherent plan of action is what each firmmust do. Next is to implement the plan. Allthis is just like a relay race. The baton-theproduct of the highest possible quality that thefirm can produce - is passed down the line. Isone’s best effort indispensable to the ultimate

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success of the enterprise? Of course, it is. Is itsufficient, however? The answer is no.

It is the entire team that either wins orloses. Quality control is not enough. What isrequired is quality assurance.

What is the difference between the two?Quality control is an individualistic, solo,

prima donna performance; quality assurance isa communitarian, service-oriented, team effort.Quality control is an inter-firm affair; qualityassurance is an intrafirm affair. One concernsone firm at a time; the other the industry as awhole. One is concerned with the parts of thesystem; the other with the system as a whole.

QUALITY ASSURANCEQuality assurance, a seemingly unknown

discipline, is as complex as the much betterknown discipline of quality control. Louis J.Ronsivalli and I explored many of its featuresin a book we wrote on the topic. Many otheraspects still need to be investigated. In ourbook, we reduced the whole of quality assur-ance to the recommendation that the industryfollow two rules (1988, p. 95):

1. Make sure that the seafood enteringthe system has high enough reservequality to last until the moment ofconsumption.

2. Handle the product in such a way as tominimize the loss of quality.

Throughout the book we reminded the prac-titioner of quality assurance that it is notenough that fish are of high quality when theyare landed in port, leave the processing plant,reach the retail counter, or are purchased bythe consumer.

It is when seafood is consumed that its levelof quality must be high.

The Components of a Quality AssuranceProgram

In our book we explored quite a few of thecomponents of a quality assurance program.We paid attention especially to the pledge ofquality assurance, sanitation, product safety,quality control, strict adherence to a timetable,separation of the catch at landing, inspection,grade labeling, planning, and coordination. Inthe remainder of this paper, I would like toenlarge upon the topic of coordination andtreat it under the more general heading oforganization.

THE STRATEGIC PLAN:EXTERNALORGANIZATIONAL REQUIREMENTS

Industry knows three main forms of exter-nal organization: total decentralization, hybridforms that fall between total decentralizationand total integration, and total integration.After reviewing the advantages and disadvan-tages of each form, we will see that it is worth-while to examine the merits of a fourth form:functional integration.

Total DecentralizationDecentralization offers many advantages.

Primary among them are flexibility and inde-pendence. They are both essential, especiallytoday when nearly every industry is in a stateof deep transition. But flexibility and indepen-dence are not supreme values. They must besubordinated to the goal of quality assurance,and quality assurance requires coordination ofefforts. That is the order that must be broughtto the industry if it wants to achieve its goal;otherwise, my father’s dictum prevails: Wherethere is no order there is disorder.” Hobbes putit in starker terms: in a society where there isno order, “Homo homini lupus.” That is, dogeats dog; every one is against everyone else.

Hybrid FormsAs soon as one mentions coordination of ef-

forts, of course, one abandons the pure form ofdecentralization and admits to the necessity ofsome form of control that is short of total sub-ordination. One enters the field of trade asso-ciations and marketing agreements, forinstance. It is within these hybrid forms thatthe best businessmen operate. They establishtheir own form of cooperation and subtle con-trol. For instance, Steve Connolly, with estab-lishments in Boston and Gloucester,Massachusetts, and Mike Foley, with estab-lishments in Boston and New Bedford, Massa-chusetts, not only maintain close relationswith the fishers but are always ready to sharetheir knowledge and expertise, whether for-mally in training settings - respectively desig-nated as the Steve Connolly Seafood Instituteand the Foley School of Fish - or informallywith the retailer. This type of coordination isoften the result of the will and the ability ofonly one person. With the disappearance ofthis catalytic element, the organization of theindustry tends to revert to total decentraliza-tion or is forced into total integration.

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Total IntegrationThe integration that concerns the seafood

industry is mainly vertical integration. TheAmerican model proceeds from the top down:the financial and marketing operation tends toextend total control over all the segments ofthe industry, at least from fishing boats to pro-duction lines. The Icelandic model proceedsfrom the bottom up: it is the producers whoown and control the overall marketing organi-zation. An interesting variety of total integra-tion is the McDonald model: either thestandards of quality are strictly adhered to byall members of the industry, or McDonald Cor-poration will not buy the product. GeneralMills covers the entire spectrum. For its RedLobster restaurants, it does not only dictatethe quality standards of the seafood it buys; italso owns fishing vessels and processingplants. In these forms of organization orderand discipline reign, but nearly all members ofthe organization are subjected to total loss ofindependence and control over the operationsthey perform.

Clearly, each form of organization imposesits own forms of control and its own sanctionswhenever the necessary standards of coopera-tion are not adhered to. Decentralization car-ries with it the sanction of total extinction ofthe firm; hybrid forms mainly carry with themexpressions of moral disapprobation; and inte-gration loss of job. Clearly, each of these formsof organization offers benefits that are counter-balanced by the existence of deep-seated disad-vantages. Is there the possibility of lesseningthe disadvantages while preserving the advan-tages? Only one form of industrial organizationseems able to achieve this goal. This formmight be called functional integration.

Functional IntegrationIn a functionally integrated industry, activi-

ties are organized by function. An analysis ofthe functions performed by each member of theindustry will reveal that some functions arethe same throughout the industry. Managingreal estate, purchasing hardware, maintainingreal estate and equipment, financing, and col-lecting and analyzing information are some ofthose functions. Why perform them piecemeal?Why not have them performed systematicallyand professionally throughout the entire in-dustry? Why not delegate these secondary ac-tivities and be left free to perform the primaryactivities of catching the fish, filleting, trans-porting, and marketing it?

If the industry adopts the model of func-tional integration, the separation of functionscan be agreed upon by the members of the in-dustry, and the model can become operationaleither as a whole or through a set of gradualsteps. Let us assume that the industry wantsto delegate as a first step the function of qual-ity assurance and for this purpose establishesa quality assurance board.

Quality Assurance BoardThe board will enforce the quality standards

set by the industry; it will not set those stan-dards. Therefore, there will not be any oppor-tunity for the industry to become subservientto the board. Also many other safeguards con-cerning the selection of the employees of theboard as well as control over their salaries canbe established to assure the same result. Theboard must remain an instrument of the will ofthe industry as a whole.

The Real Estate, Equipment, andMaintenance Board

The same approach can be followed with allissues concerning real estate and equipment.Purchase, sale, and lease of real estate andequipment as well as maintenance of all thehardware, in the final analysis, have very littleto do with the preparation of high-quality sea-food. Those are tasks that today must be per-formed by each entrepreneur, but they do taketime and attention from the essential tasks athand. Why not delegate those functions?

The Financing and Information BoardThe same is true for all functions concerning

financing and information, with two additions.By monitoring and coordinating landings (whylet everyone fish the same day and the samehour?) and gathering and analyzing price in-formation (why go after the same species at thesame time?), in the long run, the board has theopportunity to help establish some form ofquantity assurance as well as price stabiliza-tion.

Some Common Features of TheseFunctions

There are some features that all these func-tions share, They are all highly specializedfunctions whose mastery cannot be acquiredovernight; the details of such functions are alsoliable to change abruptly and drastically overtime. Finally, they are functions whose length

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of performance varies in nearly direct relationto the size of the firm. Small firms performthese functions only intermittently; large firmsperform them on a nearly continuous basis.The separation of intermittent functions fromday-to-day continuous functions is an emi-nently reasonable operation.

Dominating the issue is of course the ques-tion of costs: how much does an inopportuneinterruption to take care of any of those issuescost? How much duplication of efforts is neces-sary when the industry as a whole is takeninto account? How much does the prompt andefficient treatment of any such issue finan-cially benefit the firm?

A Likely Result: a Merging of BoardsIf the boards become too numerous and too

active, it might make sense to consider the pos-sibility of merging the boards and letting themoperate as one coherent entity. Thus, the endof this logical progression of events in theimplementation process might be found in thiscondition: the organization of asupercorporation (a super-ESOP?) that willlegally own all the hardware and in turn beowned by all members of the industry in accor-dance with their initial contribution of values.

Each individual firm will then lease thosefacilities it needs and attend to the primarycare of purchasing, handling, and distributingseafood of the highest possible quality.

Shopping malls are mostly organized alongthese lines. They let retailers be independentretailers - free of the task of performing suchextraneous functions as developing the mall,building the facilities, and maintaining them.The present model goes further: the fishers,processors, and retailers share in the owner-ship of the physical facilities. In essence, thefunctional integration model isolates manage-ment functions and renders them fully inde-pendent; it also unifies ownership rights inshared physical facilities and renders themfully efficient.

The integration of functions might cover ei-ther part or the entire spectrum of requiredactivities from fishing boats to retailing facili-ties-certainly, the supercorporation mightwant to own retail shops or lease counter spacewithin established supermarkets. All hard-ware might not only be more effectively main-tained but also be more efficiently used.fishing boats - not unlike airplanes - could beserviced and then immediately used on a turn-around basis. Why are they allowed to sit and

wait for the crew to rest? As for safety, liveswould be entrusted, not to the previous crew,but to a thoroughly professional maintenancecrew. Processing facilities and equipment couldthen be organized on the basis of species ratherthan processor specialization.

The Limits of the OrganizationIt is hard to predict the entire development

of events, but it is logical to set up the limits tothe organization from the outset. At this stage,one can envision only three limits. One is trust;the second is geography; and the last is thelaw.

TrustThe entire development must start with a

high degree of trust in the other fellow. Only ifand when two people trust each other can theyenter upon the road to this type of organiza-tion, always keeping in mind that trust, likemost other things, is refined through use. Thegoal is to be all inclusive, but there is no way ofmaking the organization work if an applicanthas not gained at least a minimum amount oftrust from the rest of the industry. Participa-tion is not a right, but a privilege.

The second major limitation is geography.Technical developments today tend to free usfrom the limitations of space, thus allowingany organization to grow to a greater size thanat any time in the past. But technology has itsown limits, and the major limit is the set of hu-man relationships in which the organizationmust grow. If people do not grow with the orga-nization, if the organization stunts theirgrowth, that is probably a sign that the organi-zation has grown too large. The resulting effi-ciency level will tell the tale.

The LawAntitrust laws have been promulgated for

good reasons. Some of the effects of those lawsmight not have been as beneficent as the in-tent of the framers of those laws would leadone to expect. But the reasons behind thoselaws are valid. Such reasons must be respectedby any form of functional integration. If that isdone, it will be discovered that the law - as anexpression of a caring and efficient society - does not restrict anyone. It simply frees us all,even those of us who are prone to excesses.

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CONCLUDING COMMENTSThe assurance of quality will not be deliv-

ered to the consumer unless there is a con-certed effort to achieve that goal - not only byeach firm but by all firms in the industry. Thatis the major difference between quality controland quality assurance. That is also the majordifference between internal and external orga-nizational requirements to assure that onlyproducts of the highest possible quality reachthe consumer. Such an effort requires a highdegree of coordination among different firms.Hence, it is essential to have a responsive in-ternal and external organization. Externally,the seafood industry - no more than other in-dustries - oscillates between two extremepoles. There is either extreme decentralizationor extreme centralization. Both forms of orga-nization offer considerable advantages. Butthey also have considerable innate disadvan-tages. Hybrid forms of organization tend to in-crease the level of negatives without

necessarily raising the level of positives. Thus,a fourth form of organization suggests itself:functional integration. Functional integrationhas the potential of yielding maximum flexibil-ity coupled with maximum independence.

REFERENCESCovey, S.R. 1989. The seven habits of highly

effective people: restoring the characterethic. New York: Simon and Schuster.

Crosby, P.B. 1979. Quality is free: the art ofmaking quality certain. New York: McGraw-Hill.

Foley, F. quoted in Boston Globe July 15, 1981.Gorga, C. and L.J. Ronsivalli. 1988. Quality

assurance of seafood. New York: VanNostrand Reinhold.

Smith, A. 1776 (1909). An inquiry into thenature and causes of the wealth of nations.C. J. Bullock, ed. New York: Collier.

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Allen KimballArctic Alaska, Seattle, Washington

Arctic Alaska Fisheries Corporation started inabout 1985 with just a couple of boats, andFrancis Miller, our founder, increased thatnumber to a pretty large outfit. Recently, wewere purchased by Tyson Foods out ofSpringdale, Arkansas. In addition to the LouisKemp Seafoods Group, we have all now beenplaced in what they call the Seafood Division.It’s been quite different for us, from the past,when we did business with a lot of the old crabfishermen, to the situation now, when a lot ofpeople speak funny and talk about chickensmost of the time. But it’s really been an experi-ence in terms of getting us to think about ournext level of growth. Tyson does about $4 bil-lion in sales a year. The seafood side is about$300 million annually. Currently we have over30 catcher processors and six shore plants.Two of those plants, one in Newport and one inCanada, are specifically associated with theprocessing of Pacific whiting. We also have anaquaculture facility in Idaho where we raisetalapia. We hope to see more growth in thatarea.

I want to concentrate my remarks on just acouple of areas. One is identifying the orienta-tion of the customer. That is probably the mainfocal point Tison has brought into our busi-ness. Meshing production and marketing isdifficult. Most of us come from a production-driven industry that is highly regulated by thegovernment. This determines many of our ob-jectives as a company. Then we say “O.K.,sales and marketing people, do what you can -here’s the lump of fish that we have been givenfor this specific period of time.” On top of this,we say that we have to exceed the customer’sexpectations. Often we have to determine whatthose expectations are. I think that to be ableto determine what those customer expectationsare, we need to further identify who those cus-tomers are, whether they are governmentregulators or buyers, and what aspect of themarket they represent. In our business, we’vecategorized most customers as food service,club stores, retail, or export. Each of those seg-ments of the market has specific needs and de-sires that must be addressed.

Hazard analysis and critical control points(HACCP), total quality management (TQM),and good manufacturing practices show usthat we are evolving. In our company we havea wide range of ships, from small catcher pro-cessors that have crews of fewer than a dozenpeople who do everything from cooking toswabbing the deck to handling the quality con-trol, to surimi vessels that have very sophisti-cated laboratories where the crew performs amyriad of tests and evaluations. So all of thetests have to be very specific. One of the mes-sages I get from fishers is that they have to betreated on an individual operational basis. Ifyou go aboard, for example, the Ocean Phoe-nix - a large factory trawler - you see a differ-ent operation from that of a catcher processorthat’s only a hundred feet long.

A great benefit from HACCP is that in put-ting together our plans, in recording our data,we become accountable. That’s where we areable to provide the necessary incentive to havepeople do their job properly. TQM, the buzzwork in the industry, is what I call motivationand attitude. And through good manufacturingpractices, we provide our operations depart-ment with continuous guidelines. These threeaspects have to be the driving force and thedirection of the quality assurance program.

By identifying product safety and line con-trol, we are starting to address some of thefood safety issues of the 1990s. We need toidentify the quality of our products in a quanti-fiable way. That can be done through microbio-logical testing. We also need a strong auditprogram. We have a field quality assurancestaff that operates out of Alaska in a couple ofdifferent ports; in port, they go through an au-diting process with on-board quality assurancepeople. That audit provides immediate, con-structive feedback to the processors, right onthe grounds. Furthermore, through our auditsystem, we have a Seattle laboratory that gen-erates and analyzes additional data that wemake available to our customers. Through ouraudit system, we are continually improvingwhat we are doing at sea. It is a long-term pro-cess. When we first started, it was tough to get

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even little things done in terms of quality as-surance programs.

We also have been very lucky, throughTyson’s acquisition of our company, to becomea buyer of seafood. As a buyer, I get to wear adifferent hat sometimes. I get to see what isavailable on the market. One of the thingsTyson has done in terms of quality assuranceis to generate a preferred supplier list. Tysonranks suppliers on three levels: deferred in-spection, re-inspection, and probationary trial.The company lets its customers know wherethey stand on this preferred supplier list. Theywork very closely with customers to give themall the necessary feedback and tools so thatthey can approach preferred supplier status.That, of course, rolls into sales and price andthe other attributes associated with being ableto have that type of relationship.

I want to make a point about training. Inthe past year our program has had an in-housecertification program. As an industry, we needto identify the specific needs of individual ves-sels and individual plants. There needs to be acertification process so that individual vesselsand plants can meet company requirements -knowing how to inspect, what to inspect, andhow to record and report that information. It isimportant to have inventory control and beable to identify your product through distribu-tion. You need an adequate recall program toactually identify your product in a meaningfulway all the way through the system. Our com-pany is in a fully integrated role now becausewe are a catcher-processor. We provide valueto add to our product, and then that productgoes on to those customers I mentioned in foodservice, club stores, retail, or export markets.Tracking the inventory provides us with a tre-mendous tool as a processor. The buyer cancome in and work right with the vessel, provid-ing us with data to improve the system. This iswhat integration of data is about: providingthe data for all the various levels of processingand fine tuning what you’re actually able toproduce to a certain specification. It’s findingyour weak spots and then fixing them. I thinkquality assurance or quality control is an inte-gral part of being able to make those determi-nations.

One of the big things we learn in thecorporate gridlock of a big company is that youhave to be able to operate successfully in ateam environment and have cross-functionalgroups that participate in quality assurance. Iwish I had done more of this early on with the

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organizations I was in, especially when theywere smaller.

The following areas are critical to a goodquality assurance program for any seafoodcompany.

Sales and MarketingThe sales and marketing effort is directed at

the customers. Working with customers toidentify their needs is the key force that drivessales and marketing. It gets back to the con-flict between production-driven and market-driven efforts. You can’t necessarily have onewithout the other; I don’t think that you can bejust market driven, especially the way our fishare regulated in this industry.

OperationsOperations are what I call the mechanical

ability to do the job. You need to become famil-iar enough with our operations to know thatour facilities have the proper tools to make thequality of product we expect. If you had a handcutting line instead of the fancy 182 automaticcutters, it would be tough to make a skinless,boneless fillet at 60,000 tons a day or 60,000pounds a day or whatever the production goalsyour company has set. Through R&D, we nowdevelop specifications. Tyson provides qualityassurance tailored to a particular customer.Tyson may assign an individual to work with aSam’s or with a McDonald’s and organize tech-nical people and buyers into a working team toidentify what the buyer’s requirements are.Bob Joseph and his group at Red Lobster arevery talented in that area; they have the expe-rience necessary to work with the processors toidentify what their needs are going to be.

To be able to have the technical servicespeople aboard the operations gives you an in-credible advantage when it comes to gettingyour operations up to speed and up to cus-tomer specifications quickly.

PersonnelPersonnel is an area that all of us are work-

ing in. Human resources departments weredeveloped partly to give us a consistent workforce, to help us get into the brain of the pro-cessors. Sometimes I wonder about this whenI’m out on the boat and we’re listening toTwisted Sister and packing fillets. I have beenamazed how you can communicate with four-letter words. I don’t say that in any negative

light, because that's just the environment thatwe're in. From a personnel standpoint, we needto train and maintain those people; we need toeducate them to the point where they becomevery familiar with the processes. Some of thosepeople I would rather have packing and pro-cessing my fish from a quality standpoint thananybody because they know it the best. So youhave to figure out ways to keep hold of them.That’s really a human resource issue, but ithas a profound effect on quality assurance.

ProcurementWe are also procurers of product, as I

mentioned earlier. From that aspect, we needto be able to know what level of quality andvalue is available. Regulators are includedbecause they are customers as well. Eventhough we don’t necessarily have to have oursystems meet their program, we need tointegrate the regulations so that we can oper-ate effectively and reach our common goal. Weoften fall into the fallacy that we’re going tohave to reorganize and change everything tomeet the regulations; in reality, I don’t thinkthat is necessarily the case with many of ourprograms.

Government AffairsHow would it be if we had a season when we

could be given a certain amount of fish and wehad all year to catch it? Or even better, what if

we could catch these fish and they weren’tspawned out and skinnier than a hot dog? Howmany times do we enter into these seasons? Iwould like to challenge all of you, if you havethe opportunity, to participate in the councilsor with your respective companies and staff.There needs to be more discussion from ourend, from the technical end. Why do you try tocatch yellow fin sole in May? Wby are we outhere catching whiting on April 15 when thefish are in pretty poor condition? I know thatsome of this fishing activity revolves aroundthe times that we can actually get the fishgrouped together to catch them, but that’spretty minor in terms of management. Wehave to get the regulators thinking about themarketing and quality assurance aspects offisheries. We all can have a profound effect onthe final quality of our products.

In closing, we need to understand our abilityto evolve and change in this quality assurancefield. The most successful operations are thosethat respond most quickly to correct a newmarket, for example, when we’ve got to makedeep-skinned fillets, cut the loins off of them,and do something to the crab to get them ineven weights. Our ability to adjust is the realadvantage. For us to develop our quality assur-ance programs to be able to meet those needs,for us to act as a service organization, for us tohave our operations, our sales, and marketingachieve that goal is what it’s all about. Then inthe end we make money.

SENSORY ANALYSIS

EXPERT ASSESSORS OF

Terriann I. RiellyStandards and Specifications Branch, U.S. Department of Commerce

Roberta K YorkCanadian Department of Fisheries and Oceans

INTRODUCTION Sensory analysis of seafood has always beenSeafood is an important commodity in interna- part of the production process through the ap-tional trade, and the amount being traded is plication of government - or industry-developedrising steadily. FAO fishery statistics from grading systems (York 1990). Sensory analysis1990 show that of the total world catch of over is a practical, reliable, and sensitive method97 million metric tons, nearly 40 percent is for determining seafood quality. In a realtraded internationally by 183 countries. The sense, fish inspectors are sensory analysts, orU.S. and Canada are ranked first and second assessors, who work as expert evaluators inin value of fish exported (over U.S. $5 billion the application of the trading countries’ prod-total). uct standards. In this paper the terms inspec-

As product moves across borders, quality tor, analyst, and assessor will be usedand safety are often either officially regulated interchangeably.or must meet common industry standards for In the last few years, there has been athat country. Failure to comply with regula- strong movement towards the development oftions or customary standards can lead to prod- common international standards for productsuct detention or rejections, which certainly and harmonization of sensory testing criteria.impedes trade. Detention or rejection of prod- The next step in this process is joint participa-uct for these reasons means financial losses tion in standardized analyst training and cali-and further deterioration of product quality. bration to ensure a uniform application ofComparable quality standards will encourage sensory testing for seafood quality.competitiveness in the international market Quality standards frequently vary amongfor that product (Weekes 1993), whereas varia- exporting and importing countries (Lupientions in product standards when trading fish- 1993). One group may have more stringentery products can act as a nontariff trade regulations when it comes to seafood quality.barrier between countries (Lupien 1993). Food standards and food trade were among

In considering standards for fish products, several topics discussed at an internationalwe must distinguish between government and conference held in Rome in March 1991. Theindustry product standards. Government stan- conference stressed the need to accelerate thedards may be regulatory, describing specific harmonization of national and internationalrequirements for minimum quality levels in food regulations and identified the training ofresponse to legislative mandates, or may be personnel for inspection and laboratory func-grade related, describing attributes associated tions as the cornerstone of the project (Lupienwith quality levels. Industry standards may be 1993).specific to individual companies, products, or In the proceedings of three major confer-user groups. Government grade standards andindustry standards are often more stringent

ences on fish quality held since 1968, the topicsof fish inspection and product standards have

than the regulatory minimum quality levels. been described in terms of the need for harmo-Our aim in this paper is to discuss the role nized standards given by representatives of

of sensory analysis in the application to fishinspection through our experience in the

specific countries and information on product

harmonization of inspectors from their twostandards used by these countries. The mostcurrent reports include information on the de-

countries. velopment of product standards in Codex

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Alimentarius and in the EEC. (Kreuzer 1971;Connell 1980; and Kramer and Liston 1987).Little or no information is recorded on thetraining of the expert assessor who will admin-ister these product standards.

Historically, sensory analysts from differentcountries, regulatory agencies, and private in-dustry have participated in varying levels oftraining in sensory inspection of fish products.Joint training, across countries or groups, hasnot been common practice up to this point.Within each of these groups, the individual as-sessors have been trained according to the spe-cific product standards that may have variedin stringency and requirements.

Efforts have begun to harmonize standardsamong countries, both internationally and re-gionally (Miller 1993). A United States-CanadaCommittee on Fish and Fishery Products hasbeen established under the 1988 U.S.-CanadaFree Trade Agreement (FTA). The three in-spection agencies from the two countries weregiven a l0-year window of time to harmonizeregulations and establish equivalent inspectionsystems.

The committee has various technical work-ing groups, one of which has a subworkinggroup on essential composition and quality,whose aim is to ensure that sound, wholesomeproduct is traded.

Decomposition in fishery products, both asafety and quality issue, continues to be aproblem. The development of equitable qualitycriteria and the application of sensory testingpractices to detect decomposition will facilitatetrade by reducing product rejections and de-tention.

Recently, the FTA subworking group recom-mended that Canada and the U.S. maximizeagreement among the analysts on the accep-tance or rejection of fish, based on decomposi-tion. Analysts worked toward defining andstandardizing the point of decomposition byspecies or species group, using sensory proce-dures.

That sensory assessment was an importanttool in the measurement of fish quality relativeto, product standards was emphasized in a1986 report on fish inspection in Canada byA.B. Morrison. This report further recom-mended that the level of sensory training givento fisheries inspectors include university-leveltraining in sensory science as well as trainingin fishery products and the standards appliedto them.

Sensory science can be classified into fourcategories according to analyst type. Each ana-lyst type functions differently and has specificselection, training, and validation require-ments. Different purposes, situations, or de-sired types of information require the use ofdifferent analyst types.

Seafood inspectors fall into the fourth, mosthighly trained and experienced, category of“expert assessors.” Expert assessors evaluateproduct full time, function independently, andare responsible for their samples. Product ex-perts usually have extensive training andproduct experience and are often used in qual-ity control and product development.

Because seafood inspectors have extensiveproduct knowledge and experience, they areessentially already trained. Training in specificproducts has been both as on-the-job trainingwhile working with senior inspectors, and asspecial workshops held to demonstrate qualitychanges and regulatory action levels of productdecomposition for specific products or productgroups. Demonstration workshops may provideinformation that is in conflict with data experi-ences that sensory assessors have picked up onthe job

A more effective approach would be to ad-dress inspectors as expert assessors under theguidance of a discussion leader using samplesfrom a full range of quality as a tool to facili-tate communication among the analysts. It hasbeen established that through the applicationof qualitative and quantitative sensory meth-odology, analysts can be brought into harmoni-zation. This methodology has not beenroutinely applied to the inspection of fish andfish products.

Experienced analysts from different regula-tory agencies can be successfully “harmonized”or “calibrated” by applying established sensoryscience methodology to joint training work-shops. Calibration of analysts was accom-plished in a workshop setting where facilities,conditions, and sample preparation procedureswere standardized.

MATERIALS AND METHODS

Workshop FormatThe harmonization exercise took place over

a five-day period beginning with an orientationon the first day, then evaluating three species,one each day, and concluding on the last daywith a revisitation of each species to determine

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the degree of retention. Nine analysts partici-pated, three from each agency. Samples werepresented in sets of 15 with l5-minute rest pe-riods in between. The sets were arranged intothree categories, each with a different objec-tive, which were called sessions. The harmoni-zation process for each species consisted ofthree parts: (1) a demonstration session, (2) apractice session, and (3) a test session. Eachsession had a different objective.

An orientation session was held the first dayto familiarize analysts with each other, thedata collection sheet, and the process of sampleexamination. Analysts were encouraged to askquestions, voice concerns, and make sugges-tions.

(1) During the demonstration session,samples representing a full range of qualitywere displayed together in increasing spoilageincrements in a single session. Analysts inde-pendently examined and rated the samples, inorder of increasing spoilage increments, notingterms that best described their sensory percep-tions at that quality level.

The demonstration served as a warm-up ex-ercise, helped analysts develop terminology,provided a useful discussion tool in identifyingquality characteristics, and anchored endpoints of quality so that analysts would bemore comfortable using the full scale (Rainey1986).

(2) The objectives of the practice sessionwere to provide product experience, reinforceconsensus decisions, and gather terminology.The session format was similar to the demon-stration session, except that the samples wereblind coded and displayed in a random spoilageorder. The discussion leader summarized anddiscussed results after each sample set withthe analysts. After the first day, it was broughtup that inspectors felt pressure to hurrythrough samples so that they were not toophysically destroyed by other analysts by thetime they examined them. This pressure wasalleviated by allowing the analysts to walkthrough and observe the appearance of allsamples before the evaluation procedure. Thisobservation step functioned as a warm-up pro-cedure within each session and was continuedin the test sessions. At least three practice ses-sions took place, emphasizing discussion andreexamination of samples.

(3) The test session was a data-gatheringexercise to measure the degree of agreement.Blind-coded samples were examined as in theprevious session. Analysts independently ex-amined samples; no discussion was allowed. At

least three test sessions took place to allow foradequate data collection.

On the final day, analysts participated in atest session revisiting each species encoun-tered during the week. This reevaluation wasused to indicate the amount of retention of har-monized sensory criteria.

Data CollectionThe format for data collection was a record-

ing sheet that included the following for eachsample:

Sample code - a three-digit, random-number code.

Inspection decision - P (pass) or F (fail).Sensory scale - an unstructured 10-cm line

scale with anchored end points of P(pass) and F (fail) and the midpointidentified.

Data were collected both on the pass-fail de-cisions and on the unstructured line scale. Forthe unstructured line scale, numerical valuescan be assigned to the assessments of overallquality of each sample. In addition, the scoresheet provided room for recording terminology.

The Discussion Process and TerminologyDevelopment

After independently evaluating samples, thegroup congregated in a central area for datacollection and discussion. To reach group con-sensus, the discussion leader acted to draw outinformation from group members, after exami-nation of 15 samples. To do this, the discussionleader recorded and summarized the data ingroup discussion and then presented it to thegroup. In this process, the discussion leaderrecorded the number of failed units per spoil-age increment on a flip chart. Each analystwas asked to state his or her decision and anyreasons relating to sensory characteristics forthat decision. Differences in perceived sensorycharacteristics were explored through discus-sion and reexamination of the samples. Com-monalities were identified, emphasized, andreinforced.

The discussion process included three steps:development of common terminology (focusingon sensory characteristics), consensus of inten-sity or levels of these characteristics, and ap-plication of this information to the decisionprocess. In other words, when a defect is found,the discussion process must include the follow-ing questions: Do all analysts detect the char-acteristic? What common term or word best

labels the characteristic? Do all agree on thelevel of intensity? Is the presence of this char-acteristic grounds for rejection?

Summarization of data provided immediatefeedback and motivation and allowed the ana-lysts to see where they were in relation to thegroup. Discussion focused on each sample,then on the samples as a group. Focus was onthe pass-fail cut off point, with particular at-tention to sensory defects that pulled a sampleinto the “fail” category. Results from chemicalanalyses were included in the discussion, forcomparison purposes.

SamplesSpecies were chosen by assigning priority to

those products and product forms that repre-sent the largest volume or economic impact totrade between the countries. Samples of cod,flounder, and scallops with a known history,representing a full range of commercially pro-duced product, were examined by the analysts.Samples were analyzed chemically for TVB-Nputrescine and cadaverine before the work-shop. Results from representative sampleswere available for the exercise.

Al l samples were presented to analysts inbooths, except for during the demonstrationsession. During the demonstration session,samples were displayed together to allow ana-lysts to compare samples and view the fullrange of quality.

Bilateral harmonization exercises have be-gun between the U.S. and Canada to decrease,as much as possible, any differences that mayexist on the application of sensory analysis todetect decomposition in seafood.

A fine-tuning of analysts can be realized,and a harmonized pass-fail point can be estab-lished and maintained. This is achievedthrough the application of established sensorymethodology drawing from quantitative analy-sis (unstructured line scale) and qualitativeanalysis (descriptive profiling).

Similarities must be realized and communi-cated through interactive discussion and reex-amination of product.

Similarities and common evaluation criteriashould be identified through common terminol-ogy (Vance Civille and Lawless 1986), levels ofintensity, and application. Most similaritiesand differences surfaced the first day of theexercise, and the analysts were able to carryover the consensus on basic quality criteria to

other species.The application of sensory criteria needs to

be clarified. Groups can perceive the same sen-sory defect but apply the criteria differently tomake different regulatory decisions. One groupmay associate a defect with decompositionwhile the other group considers the defect ob-jectionable, but not indicative of decomposi-tion. In regulatory standards, any presence ofdecomposition that is recognizable (distinctand persistent) will cause product to be re-jected. If the defect is considered to be objec-tionable, but not associated with spoilage, thenthe level of stimulus may have to reach a cer-tain intensity to cause a rejection of thatproduct.

CONCLUSIONSGovernmental agencies and industry alike

have experienced, knowledgeable personnelwho, through the application of focused discus-sion and formalized sensory training, can be-come an extremely objective, accurate,cohesive group of sensory analysts. Throughstandardized training and monitoring, ana-lysts can uniformly and consistently assesssensory quality characteristics of seafood asthey relate to grade level or to decisions to ac-cept or reject product.

Continuation of product workshops using adiscussion format will attune inspectors to theapplication of sensory testing to determine andarrive at consensus on product quality. Prod-uct experts can participate in interagency andintraagency workshops to be internationallyharmonized and calibrated. These sessions canbe regularly scheduled and be product or prod-uct group specific. Calibrated experts can ro-tate among training locations to train otheranalysts.

Development of sensory testing guidelinesand continued participation in joint trainingfor government and industry will increase theagreement and consistency among sensory in-spection personnel. Consistency in the applica-tion of sensory testing to determine seafoodquality will increase constancy in product qual-ity measurements. This will facilitate trade byreducing rejections and detention of product.

FUTURE TRENDS

Internationally, the expert sensory analystis being acknowledged. The International Or-ganization for Standardization’s committee onsensory analysis has a draft document (ISO/CD 8586) that recognizes and establishes

guidelines for sensory assessors. CodexAlimentarius, whose purpose is to protect con-sumers’ health and ensure fair trade practices,is in the process of incorporating sensoryevaluation procedures into their standards toclarify the statement in the Codes of Practicefor fishery products that "sensory evaluationshall only be performed by those properlytrained to do so.” At their last meeting, Codexidentified “the need to establish a uniform ap-proach to inspection procedures, particularlythose involving sensory evaluation.” This is tobe accomplished by the development of a Codeof Practice for Sensory Evaluation of Fish andFish Products, which is now in the draft stage(Howgate 1992).

It is anticipated that sensory evaluation ininternational trade will increase in impor-tance. Often, seafood quality does not meanthe same thing to people of different countries.Through the application of established sensoryscience principles to bilateral “harmonization”exercises, it was demonstrated that a fine-tun-ing, or calibration, of sensory analysts from dif-ferent governmental agencies can occur. Thenext step is to create uniformity in the inspec-tion force through standardized analyst train-ing and calibration using internationallyharmonized analysts.

Connell, J.J. (ed.) 1980. Advances in fishscience and technology. Farnham, Surrey,England Fishing News Books.

Howgate, P. 1992. Codex Alimentarius Com-mission review of inspection procedures(sensoric evaluation) for fish and shellfish.CX/FFP 92/14 FAO/WHO.

ISO/CD 8586 Sensory Analysis - Assessors.ISO/TC 34/SC 12 N 247 revised.

Kramer, D.E. and J. Liston (eds.) 1987. Sea-food quality determination. Amsterdam:Elsevier.

Kreuzer, R. (ed.) 1971. Fish inspection andquality control. London: Fishing News(Books).

Lupien, J.R. 1993. Technical harmonization ofinternational trade agreements. FoodTechnology, 47(3), 106-114.

Miller, S.A. 1993. Health, safety, and stan-dards: do we need an international foodregulatory institution? Food Technology,March, 47(3), 125-130.

Rainey, B.A. 1986. Importance of referencestandards in training panelists. J. SensoryStudies 1,149-154.

Vance Civille, G. and H.T. Lawless 1986. Theimportance of language in describingperceptions. J. Sensory Studies 1, 203-215.

Weekes, J. 1993. The NAFTA and standards.Consensus 20(1), 14-16.

York, R.K. 1990. Canadian fish products-fishinspection and sensory evaluation. Can.Inst. Food Sci. Technol. J. 22(5), 441-444.

Etsuo WatanabeDepartment of Food Science and Technology, Tokyo University of Fisheries

INTRODUCTIONIt is well known that Japanese people eat rawfish as sashimi. As a result, safety standardsfor seafood are stricter in Japan than in othercountries. In this paper, I will describe howseafood quality is measured and controlled inJapan. I will cover the following subjects:

1. Postmortem changes in fish meat2. Fish freshness indicators3. Indicators and methods for determining

the freshness of fish4. Style of raw fish and quality control in

Japan

1. POSTMORTEM CHANGES IN FI S HMEAT

Within the period of time between the deathof a fish and its consumption, a large numberof biochemical and physicochemical changestake place. Postmortem change in fish meatcan be represented briefly as follows:

catching > rigor mortis > dissolution ofrigor mortis > autolysis > spoilageThe prerigor state, in which the muscle is

soft and pliable, is characterized biochemicallyby a decrease in adenosine triphosphate (ATP)and creatine phosphate levels as well as an ac-tive glycolysis . The stiff, rigid condition of themuscle tissue is known as rigor mortis. Fishgenerally exhibit a short rigor mortis periodstarting from 1 to 6 hours after death, with nu-merous factors determining the duration. Be-cause of the depletion of the oxygen supply tothe tissues after the death of a fish, anaerobicmetabolism takes over, resulting in the conver-sion of glycogen to lactic acid. With a fall inATP and creatine phosphate, actin and myosingradually associate to form inextensible ado-mosin (the onset of rigor mortis). The impor-tance of rigor mortis in fish is realized in thefishery industry because, in addition to retard-ing microbial spoilage, it gives fish a stiffnessthat is generally recognized as a sign of goodquality by consumers.

Following the dissolution of rigor mortis, agradual tenderization of fish meat occurs, andhigh-molecular weight compounds such as pro-teins, lipids, and glycogen gradually degradeinto lower-molecular-weight compounds, whichcan be used more readily by microorganisms.Prolonged storage of fish will soon result in mi-crobial spoilage, decomposition of proteinscaused by indigenous enzymes (autolysis), andthe development of unpleasant flavors. In live,healthy fish, the muscle tissue is sterile. How-ever, freshly caught fish have considerablenumbers of microorganisms on their skin andgill surfaces. Following the death of the fish,the mechanisms involved in the control of mi-croorganisms are no longer functional, and mi-crobial growth presumably occurs withmovement into the various tissues throughoutthe vascular systems.

The above process is shown in figure 1.

2. FISH FRESHNESS INDICATORSSince the retention of fish freshness is nec-

essary for the production of good-quality prod-ucts, accurate and rapid determination offreshness is essential for the marine food in-dustry. Many indicators have been proposedfor the estimation of freshness.

Organoleptic IndicatorsIn the organoleptic indicators, fish freshness

can be determined subjectively, through sight,smell, taste, and touch. Although these sensesprovide a rapid way of determining freshness,it is difficult to evaluate fish freshness quanti-tatively.

Physical IndicatorsThe hardness of fish meat (Yamanaka et al,

1978), electric resistivity and dielectric ratio offish meat (Asakawa 1957a; Nagamatsu 1960),viscosity of fish meat exudate (Labarre et al.1942), and refractive index of fish eyes (Love1954, 1956) have all been used as physical in-dicators.

Death of FishAnaerobicGlycolysisF o r m a t i o n - - ILacFFc acid Feedback inhibition

Actiiation of ATPase al Viable Counts

Rigor mortis Degradation of Protein-, PolypeptideTMAO>TMA>DMA + Formaldehyde

Rapid increase of bac

DEATH 1 2 3

Storage Time ( days ) at 5°C

Figure 1. Postmortem changes in fish meat.

Microbiological IndicatorsSpoilage is caused by the action of microor-

ganisms, so that the number of living microor-ganisms correlates with the degree of spoilage(Kimata 1936a, 1936b, 1936c). When fish meatis at the initial stage of spoilage, the number ofliving cells is around 106 cm-2 of skin; a strongodor of spoilage will be perceived when thisnumber is 107 to 108 cm-2 To count the numberof living cells is complex and time-consuming,so it is not a practical method for estimatingfish freshness.

Chemical IndicatorsResearchers have proposed a number of

chemical indices of fish freshness: volatile ba-sic nitrogen (Tomiyama et al. 1952; Takase1953; Kawabata et al. 1953a, 1953b); ammonia(Yamamura 1933; Takahashi 1935; Ota et al.1952, 1954; Tokunaga et al. 1977); amines(Takahashi 1935; Tokunaga et al. 1977); vola-

tile acid (Suzuki 1953; Asakawa 1953, 19541957b, 1959); pH (Yamamura 1936; Kawabataet al. 1952; Yamamoto et al. 1953; Miyake etal. 1955); buffering capacity of muscle (Suyamaet al. 1958); and adenosine triphosphate (ATP)and related compounds (Saito 1961; Ehira etal. 1966; Fuji et al. 1966; Ehira et al. 1969).

According to detailed investigations of phos-phorylation in animal muscles (Saito 1956,1961; Jones et al. 1964, 1965; Burt 1968;Uchiyama 1970; Jahnes et al. 1976; Numata etal. 1981; Yamada et al. 1981; Lee et al. 1982),the decomposition of ATP in the fish meat setsin after the death of fish, and adenosinedisphosphate (ADP), adenosine monophos-phate (AMP), and related compounds are gen-erated subsequently according to the sequenceshown in figure 1. In most cases the rate-deter-mining step is from inosine to hypoxanthine orfrom hypoxanthine to uric acid, depending onthe species of fish, and consequently inosine orhypoxanthine is accumulated with increased

1 %

storage time. The total number of ATP-relatedcompounds is usually constant, so the ratio ofinosine + hypoxanthine to the total number isdefined as the K value (Arai et al. 1961).

inosine +hypoxanthine

K value (%) = x 100

ATP+ADP+AMP+ IMP +inosine+hypoxanthine

K value is the most reliable indicator for fishto be eaten or not to be eaten as sashimi, thatis, raw fish, in Japan. In case of a K value be-low 20%, it is possible to eat the fish meat assashimi. With K value of up to 40%, it is pos-sible to eat the fish by cooking. Of course,above 40%, it should not be eaten.

These values fluctuate widely with the spe-cies tested, and the procedures involved areusually tedious and time-consuming. More-over, postmortem change in fish meat is fairlycomplicated, as noted above. Therefore, it isdifficult to determine fish freshness accuratelyby the single indicators proposed.

A more accurate indicator of fish freshnessis the overall and enzymatic reaction attrib-uted to the changes in fish freshness, becausevarious reactions taking place in fish meat,such as glycolysis, ATP degradation, denatur-ation and degradation of proteins, and oxida-tion of lipids, proceed at individual reactionrates (Watanabe et al. 1987).

The solubility of protein in salt solution andATPase activity of myofibrillar protein (myo-sin) are used as indicators for denaturation ofthe protein. These indicators are very impor-tant in surimi manufacturing.

3. INDICATORS AND METHODS FORDETERMINING FISH FRESHNESS INJAPAN

The methods used in Japan for determiningfish freshness are as follows. (The asterisks [*]indicate products on the market.)a. Judgment from a single component.

VBN (TMA, NH3) - microdiffusion method(Conway)*

Polyamines (histamine, cadaverine, pu-trescine) - HPLC*

K valuee column method (ion exchange resin)*. enzymatic method--Oriental electric Co.

Ltd.*o HPLC method*

l enzyme sensor - New Japan Radio Co.Ltd.*

l test paper - EAC Corp.*

b. All-round judgmentpH (ß-buffer capacity)

viable cell counts Biosensornondestructive biological sensor-electric resistivity - Torrymeter*color, order, elasticity - organoleptic

c. Indicators for processing (especially, surimi)water-holding capacityCa2+-ATPase of myosin

d. Determination of K value with biosensor(Okuma et al. 1992)A continuous system for determining fish

freshness with double enzyme reactors was de-veloped and applied to the determination ofthe freshness indicator {K = [HxR + Hx] / (IMP+ HxR + Hx] x 100} in many types of fish,where IMP, HxR, and Hx are inosine mono-phosphate, inosine, and hypoxanthine, respec-tively. The system was prepared from twocombinations of oxygen electrodes and reac-tors. One reactor for the determination of thetotal amount of HxR and Hx was packed withnucleoside phosphorylase (NP) and xanthineoxidase (XOD), immobilized simultaneously onchitosan porous beads. Similarly, another reac-tor for IMP, HxR, and Hx was packed with 5-nucleotidase (NT), NP and XOD, immobilizedsimultaneously on chitosan beads. The systemwas prepared from two combinations of oxygenelectrodes and reactors. One assay could becompleted within five minutes. The system fordetermining fish freshness was reproduciblewithin 2.1% (n=30). The immobilized enzymeswere sufficiently stable for at least sevenmonths at 4° C. More than 200 samples couldbe analyzed in about one month by using theseenzyme reactors. The results for fish meat (13types) correlated satisfactorily with thoseobtained by liquid chromatography (r = 0.989,n = 253) or ion exchange resin column chroma-tography (r = 0.973, n = 50). These results sug-gest that the proposed sensor system providesa simple, rapid, and economical method for de-termining fish freshness (ki).

Figure 2 and figure 3 show the schematicdiagram of the reactor system and the resultsobtained by the proposed sensor system, re-spectively. Figure 4 shows an article on themarket: BIO FRESH.

127

Figure 2. Schematic diagram of the reactor system: 1. air, 2. buffer tank, 3. peristaltic pump, 4. injection port, 5.precolumn, 6. enzyme column: (co-immobilized nucleoside phosphorylase and xanthine oxidase); (co-immobilized5'-nucleotidase, nucleoside phosphorylase and xanthine oxidase), 8. oxygen probe, 9.A/D converter, 10. computer,11. recorder, 12. valve, 13. waste

I 1 I I I

I I I I I00 10 20 30 40

Ki value ( % )

50 60

HPLC METHOD

Figure 3. Correlationbetween K1 value offish muscledetermined by theenzyme reactorsystem and by theconventional LCmethod.

4. STYLE OF RAW FISH AND QUALITYCONTROL IN JAPAN

Figure 5 is an aqua-farm in Kagoshima Bayin Japan. Now 1.2 million tons of fish are culti-vated in Japan (1989). This is equivalent toone-tenth of the total fish catch per year in Ja-pan and is worth 5 billion dollars.

Fish meat after instant death can be eatenraw as sashimi. Flounder and sea bream are

128

transported to an eating house as live fish.Flounder is eaten before rigor mortis, seabream during rigor mortis, tuna and otherfishes after rigor mortis.

Unfrozen and frozen fishes are used forsashimi or cooking. Of course, these fishes areused as raw materials for canned food andother fish products.

Figure 4. Fishfreshness sensor" B I O FRESH."

Figure 6 is a container fortransporting unfrozen fish. Afterbeing caught, fish are stored at0° C in the container and trans-ported to local retail shops asthey are. This container is stillin the experimental stage.

Figure 7 is the frozen tuna atTsukizi market. Buyers examinethe quality of tuna from thecross section of tail portion. Thisis the actual determination offish quality in Japan.

Figure 5. Seafarm inKagoshima bayin Japan.

Figure 6.Containertransportinonfrozen

Figure 7. Frozen tunaat Tsukizi market inJapan.

REFERENCESArai, K. and Saito, T., 1961, Changes in

adenine nucleotides in the muscles of somemarine invertebrates,Nature, 192,451-457.

Asakawa, S., 1953, Studies on the method ofdetermination for freshness of fish flesh bydistillation ratio of volatile acids in steamdistillate. II, Apparatus and conditions fordistillation, Nippon Suisan Gakkaishi, 19,124-131.

Asakawa, S., 1954, Studies on the method ofdetermination for freshness of fish flesh bydistillation ratio of volatile acids in steamdistillate., VII. Proposition of a new scale forthe freshness determination, Nippon SuisanGakkaishi, 20,158-167.

Asakawa, S., 1957a, A consideration of thepost-mortem change of electric resistance offish muscle, Nippon Suisan Gakkaishi, 22,718-720.

Asakawa, S., 1957b, Studies on the method ofdetermination for freshness of fish flesh bydistillation ratio of volatile acids in steamdistillate. VIII. On the form of volatile acidsin fish meat, Nippon Suisan Gakkaishi, 23,463-466.

Asakawa, S., 1959, Studies on the method ofdetermination for freshness of fish flesh bydistillation ratio of volatile acids in steamdistillate., IX. On the applicability of distil-lation ratio value to the determination of the freshness of oyster, Nippon SuisanGakkaishi 24,714-718. Kawabata, T. and Terui, H., 1953a, Funda-

mental studies on the determination of

Burt, J.R., Murray, J., and Stroud, G.D., 1968,An improved automated analysis of hypox-anthine, J. Food Technol., 3, 165-170.

Ehira, S. and Anekawa, M., 1966, Relationsbetween freshness and changes of nucleoti-des in fish muscle during ice storage,Nippon Suisan Gakkaishi, 32,716-722.

Ehira, S. and Uchiyama, H., 1969, Rapidestimation of freshness of fish by nucleosidephosphorylase and xanthine oxidase,Nippon Suisan Gakkaishi, 35, 1080-1085.

Fujii, Y., Uchiyama, H., Ehira, S., andNoguchi, E., 1966, Change of nucleotidesubstances in plaice muscle during icestorage, Nippon Suisan Gakkaishi, 32,410-416.

Jahns, F.D., Howe, J.L., Coduri, R.J., andRand, A.G,. 1976, A rapid visual enzymetest to assess fish freshness, Food Technol.,30(7), 27-30.

Jones, N.R., Murray, J., Livingston, E.I., andMurray, C.K., 1964, Rapid estimations ofhypoxanthine concentrations as indices ofthe freshness of chill-stored fish, J. Sci. FoodAgric.,15, 763-773,

Jones, N.R., Murray, J., and Burt, J.R., 1965,Automated analysis of hypoxanthine, J.Food Sci., 30, 791-794.

Kawabata, T., Fujimaki, M., Amano, K., andTomiya, F., 1952, Studies of the pH fishmuscle: Variation in pH fresh albacoremuscle on the locality examined, NipponSuisan Gakkaishi, 18, 124-132.

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volatile basic nitrogen by aeration method.I. Studies on some determinative factorsinfluencing the amount of nitrogen obtain-able from ammonium sulfate solution,Nippon Suisan Gakkaishi, 19,741-745.

Kawabata, T. and Terui, H., 1953b, Funda-mental studies on the determination ofvolatile basic nitrogen by aeration method.II. Studies on some determinative factorsinfluencing the volatile bases obtainablefrom fish meat, Nippon Suisan Gakkaishi,19,746-749.

Kimata, M., 1936a, Rates of the decompositionof fish muscle by various kind of bacteria,Nippon Suisan Gakkaishi, 5,77-79.

Kimata, M., 1936b, Effects of hydrogen-ionconcentration upon the decomposition of fishmuscle by bacteria, Nippon SuisanGakkaishi, 5,143-145.

Kimata, M., 1936c, Effect of carbohydratesupon the rates of the decomposition of fishmuscle by bacteria, Nippon SuisanGakkaishi, 5, 219-223.

Labarre, J. and Fougere, H., 1942, Physicaland chemical changes in extract of cod filletswith temperature and time, Trans Roy. Soc.Can. Sect., 5,36, 41-43.

Lee, E.H., Ohshima, T., and Koizumi, C., 1982,High performance liquid chromatographicdetermination of the K value as an index offreshness of fish, Nippon Suisan Gakkaishi,48,255.

Love, R.M., 1954, Post-mortem changes in thelenses of fish eyes. I. Assessment of storagetime and fish quality, J. Sci. Food Agric., 5,566-572.

Love, R.M., 1956, Post-mortem changes in thelenses of fish eyes. II. Effects of freezing andtheir usefulness in determining the pasthistory of the fish, J. Sci. Food Agric., 7,220-226.

Miyake, M. and Hayashi, K., 1955, Relationbetween time post mortem and the phtha-lein values of aquatic animals, NipponSuisan Gakkaishi, 21,123-126.

Nagamatsu, M., 1960, Fish transportation. l.The change in electric resistance of fish,Nippon Suisan Gakkaishi, 26,771-777.

Numata, K, Suzuki, H., and Usui, K, 1981,Relations between freshness and behavior ofATP related substances in chicken muscle,Nippon Shokuhin Kogyo Gakkaishi, 28,542-547.

Okuma, H., Takahashi, H., Yazawa, S.,Sekimukai, S., and Watanabe, E., 1992,

Development of a system with doubleenzyme rectors for the determination of fishfreshness, Anal. Chim. Ada, 260 (1) 93-98.

Ota F., and Nakamura, T., 1952, Variation ofammonia contents in fish meat by heatingunder pressure: Relation between theincrease of ammonia and the freshness offish, Nippon Suisan Gakkaishi, 18, 15-20

Ota, F. and Oshiro, Z., 1954, Calorimetricmethod for measuring the quantities ofammonia in fish meat. III. On the rapidmethod, Nippon Suisan Gakkaishi, 19,1150-1153.

Saito, T., Arai, K., and Matsuyoshi, M., 1956, Anew method for estimating the freshness offish, Nippon Suisan Gakkaishi, 24,749-750.

Saito, T., 1961, Adenosine triphosphate andthe related compounds in the muscles ofaquatic animals, Nippon Suisan Gakkaishi,27,461-470.

Suyama, M. and Tokuhiro, T., 1958, Studies onthe buffering capacity of fish muscle. I. Thebuffering capacity as a measure of fresh-ness, Nippon Suisan Gakkaishi, 24, 267-270.

Suzuki, T., 1953, Determination of volatileacids for judging the freshness of fish,Nippon Suisan Gakkaishi, 19,102-106.

Takahashi, T., 1935, Distribution oftrimethylaminoxide in the piscine andmolluscan muscles, Nippon SuisanGakkaishi, 4, 91-94.

Takase, A., 1953, Some investigations of themethod for the determination of volatilebasic nitrogen in fish flesh, Nippon SuisanGakkaishi, 19,71-74.

Tokunaga, T., Iida, H., and Miwa, K., 1977,The gas chromatographic analysis of aminesin fish, Nippon Suisan Gakkaishi, 43,219-227.

Tomiyama, T., Ide, K, and Akiyama, T., 1952,Studies on the method for testing spoilage offoods: III. A new steam-distilling method forthe determination of volatile base in fishflesh, Nippon Suisan Gakkaishi, 17,191-196.

Uchiyama, H. and Ehira, S., 1970, The currentstudies on the freshness of fish with specialreference to nucleic acids and their relatedcompounds, Nippon Suisan Gakkaishi, 36,977-992.

Yamada, K, Higashino, S., Kawahara, T., andIto, R., 1981, Effect of contamination of thedermis on estimation of the K value an

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index of freshness, of sardine muscle,Nippon Suisan Gakkaishi, 47,631-636.

Yamamoto, M. and Sonehara, M., 1953, Anassay method for freshness of fishes by theestimation of pH value, Nippon SuisanGakkaishi, 19,761-765.

Yamamura, Y., 1933, The putrefactive degreeand the pH value of fish muscle, NipponSuisan Gakkaishi, 2, 118-120.

Yamamura, Y., 1936, The composition of fishmuscle and rate of decomposition, NipponSuisan Gakkaishi, 5,98-102.

Yamanaka, H., Nakagawa, T., Kikuchi, T., andAmano, K., 1978, Studies on he contractionof carp muscle. I Remarkable differencesbetween rigor mortis and thaw rigor,Nippon Suisan Gakkaishi, 44 (10) 1123-1126.

Watanabe, E., Nagumo, A., Hoshi, M.,Konagaya, S., Tanaka, M., 1987, Microbialsensor for the detection of fish freshness, J.Food Sci. 52 (3),592-595

132

OF SEAFOOD PRODUCTS:RS AND STATISTICAL

SEAFOOD INDUSTRY

Gregg J. SmallGolden Age Fisheries, Seattle, Washington

There are many ways and reasons to measurethe quality of seafood products. Using comput-ers to assist in this monitoring and then re-porting the information in a usable mannermakes even more sense. The purpose of thispaper is to discuss some computer aids to helpseafood processors become more profitable,that is, to have better control over the produc-tion environment and, at the same time, keepbuyers and government agencies satisfied.

Unfortunately, as a rule, the seafood indus-try is behind in monitoring the quality of itsproducts and its production processes. Cannersare the exception. The good news is that pro-cessing seafood is really no different than thou-sands of other manufacturing operations.There are lessons to be learned, and some ofthese other methods can be adapted to seafood.The size and location of the seafood processordo not seem to matter. Whether the facility isbig or small, in a large city, small coastal town,or on fishing boats, the technology is there and,albeit slow in arriving to the industry, has al-ready proven its value.

Some of the things described here are usedon Golden Age Fisheries vessels and by the of-fice staff to report to buyers prior to delivery.

WAYS TO MEASURE QUALITYFirst, what is quality and why does it need

to be monitored? Quality has many meaningsto many people. Quality is the set of attributesor characteristics of a product that the cus-tomer needs. To keep a customer, you mustsatisfy the customer’s demands. Quality at-tributes for fish fillets might include color, tex-ture, size, number of bones, and odor.

Traditionally, the measurement of quality isbased on inspection of finished product ratherthan inspection of the product at each distinctprocessing step. Understanding the differencebetween these two methods is vital to improv-ing quality attributes and being able to sum-marize these parameters for the customer.

Finished product inspection is based on asample, and tests are carried out to try to de-tect if the product is good enough or if it is toobad. Sampling itself adds variability into thisstep. By chance a sample can be representativeof the rest of the product or not representativeat all. In any case, if a problem is found, suchas there are too many bones in the fillets, theproduction effort was wasted. Instead of doingthe processing steps right the first time toachieve optimum quality, the company madean out-of-tolerance product. The quality is al-ready in the product and it is too late to changeanything without cost.

If a problem exists, the focus then shifts todisposition. A good sales person can sell any-thing, but at what cost? The process from thispoint is filled with lost time, labor, and money.It would have been much better to haveavoided these problems in the first place.

Finished product testing is not only inexactand too late in the process; it does not answer anumber of other questions either. For example,during production of individually quick frozen(IQF) fillets, the number of bones per pound ofproduct must be monitored. The customer willnot accept more than one bone per pound. Ifduring an inspection three bones per poundwere detected, the only thing that is known isthat the sample is out of specification. Lookingat the result of the inspection does not tellwhere the problem occurred or if it is represen-tative of the complete production.

Was it a candling line error by one person orby everyone? Did the automatic fillet machinemiscut so badly that the best candling inspec-tor could not have kept up with the flow? Werediscarded fillets accidentally being packed inwith the “good” fillets? If the problem was de-tected at all, the problem was in the boxquickly and it is too late to fix it. Where do yousell this product? What about the money al-ready invested?

In spite of the inherent shortcomings of thisold system of inspection, many customers Stillrely on finished product tests because fish istreated as a commodity. To understand how aproduct will be seen by the customer, it is wiseto carry out a minimum level of finished blockinspections in the same manner as the cus-tomer.

Any company trying to make a new productshould first get the customer’s incoming in-spection form and follow it (for example, seefigure 1.) The company should double checkthe procedures on a day-to-day and hour-to-hour basis. Some customer would like to seethe results of the effort written down becauseit will reassure them that tests are being madeand it saves them time in duplicating the sameprocedures (figure 2).

German whitefish buyers - like many com-panies here in the United States - rely uponfinished product testing to determine the ac-ceptability of numerous quality attributes.German companies use statistical tests such asa standard deviation of measurements. Theresults of these tests from the production plantare compared to those found once the productarrives in Germany. Information from bothsources are also compared to what was done inthe past from one supplier and several com-petitors. The historical statistical informationprovides evidence and a basis for comparison.Phrases like "Don't worry about quality; every-thing is OK, we promise it’s good" are onlyempty words without the evidence. More im-portant, more and more companies are refus-ing to buy from suppliers that don’t have hardevidence of what was produced in the plant.

In summary, finished product inspection inseafood is based on how many samples are ex-amined, to get the best picture, many samplesmust be taken at an ever increasing cost.Years of experience have proven that finishedproduct testing doesn’t work with seafood anybetter than it does with making ball bearings,car doors, or food for NASA But for manyyears, finished product inspection was all thatwas used. Its practice still exists and will bewith US in some areas (possibly Germany) forsome time to come.

STATISTICAL PROCESS CONTROLThere is a better way than finished product

inspection The method is called statistical pro-cess control (SPC). The method provides statis-tics, information on the process in real time, or,evidence that satisfies the buyers. Importantly,

this technique monitors the process to preventa problem from being produced in the firstplace. It is not necessary to use a computer forthis analysis, but a computer makes it mucheasier.

SPC emphasizes the measurement at keysteps in a process to assure that the productwill be good. An example is monitoringsamples of fillets four times every hour fromthe candling line (frequency and number of fil-lets examined are based on a sampling table).If the count of bones goes over the specificationnumber, the machines, the people, or other fac-tors can be examined and the exact problempinpointed.

A program of monitoring control charts isthe fastest method of observing a process thatis going out of control and determining when tomake adjustments to the processing line.SQCpack, by PQ systems (available locallyfrom Research Consultants, Seattle, Washing-ton, 206-933-6663), is one of the most fre-quently used programs by seafood buyers andis very easy to learn and use.

RUN AND DISTRIBUTION CHART

A simple run chart may be all that is neededto see if your process is under control and tomonitor the variance in the process. See fig-ures 3 and 4.

By studying a control chart, another tool inthe SPC armory, you can know the variabilityin a process over time. The major concerns (inthis case defects of bones, fins, and parasites)are recorded, a summary is graphically plotted,and, if a problem occurred, the disposition ofthe product is noted. In the example, the prod-uct is being checked every 15 minutes and atotal defect level of greater than two, is clearlyvisible. Action should be taken in such an inci-dence and the product reworked or down-graded.

Control charts can be made by hand or gen-erated with software such as SQCpack if it islinked to an electronic balance or other mea-suring device, even calipers or light sensors.

The best place to use a control chart is inthe factory, hands on. Because of the wet envi-ronment at sea, computers have not been verypractical. The Marel scale/computer systemthat tracks product inventory and weight con-trol is a notable exception. If computers are notpractical, manual control charts, waterproofpaper and a pencil will work and provide awealth of information in a timely manner.

134

MANUFACTURER: TECHNICIAN(S):

‘ROCESSING FACILITY: DATE:

COMMENTS

ADAPTED FROM: MRS. PAULS/CAMPBELL SOUP

Figure 1. Mrs. Paul's /Campbell Soup raw product inspection format.

135

3twn maENDIS

slodsmla

I SWd I

File: 11-30-1993 02:22;n;Etny:

OREG003GOLDEN AGE FISHERIES

Charaiteristic: NEWPORT PLANTPACIFIC WHITING FILLET WEIGHTS

gzi Ae frequency:yN;ItLg;&:-__________________________________~~--~~~-------------------------------~~~

Moving range, n=2 IndividualsLCL = --- MEAN=5.8 UCL=19 LCL=48.5 M E A N = 6 4 UCL=79.4

USING TABULAR CONSTANTS, BASED ON SAMPLES 1-106

I---_ I

----L_II ‘1I

---L---I

/ IIIIIrI

Figure 3. Run Chart from SQCpack showing upper and tower control limits. This format show’s thevariability associated with production data.

137

P A C I F I C W H I T I N G F I L L E T W E I G HT S

File :OREG003 Date:ll-30-1993, 02:39:11Company :GOLDEN AGE FISHERIESPlant :NEWPORT PLANT Part name :Department : Part number :Machine : Sample frequency:ONE / HROperation : Units :1 FILLETCharacteristic :PACIFIC WHITING FILLET WEIGHTS

Descriptive StatisticsAll (n=l) Interval = 3.0137 data points lower boundaryMean = 64.3 Min. Value = 47 Chi Squared= 9.710S i g m a Indiv= 7 .8 Max. Value = 88 deg. free. = 7Est. Sigma = 4.1 Kurtosis = -0.151 Conf. Level= 95%Coeff.Var. = 0.1 Skewness = 0.360 NormalMean + 3s = 87.9Mean - 3s = 40.8

Histogram

Figure 4. Distribution chart from SQCpack. Weights of Pacific Whiting fillets.

138

Control charts provide a basis for separating customer or production Staff. Selection of infor-random from nonrandom events in a process. mation does not overwhelm the client with in-The goal is to have a production system that appropriate data, comments, or formats thathas inherent variation from random causes the customer can not relate too. Customers ap-only. In addition, control charts help keep fu- preciate a one-page summary and can alwaysture production similar to what has been previ- ask for more information if theyously determined as acceptable. Consistency of need it.Product is very important to any of the buyers, Weight histories on a daily basis along withwhether the product is H&G rockfish, surimi, the rest of the processing information haveor fillet block. saved thousands of dollars in product claims

Photocopying all the paperwork produced when small buyer samples come up withfor the buyers or government agencies is not skewed sample weights that are not truly rep-worthwhile because of the difficulty for some- resentative of the shipment. Daily weights alsoone to interpret the mass of excessive detail. allow production staff to adjust their packSummaries, on the other hand, are valuable to weights so that just enough product is leavingmany buyers of product. Using a data base pro- the facility, not too much or too little. The sav-gram such as R:Base allows selection of defect ings in this one area will, by itself, pay for thelevels, weight checks, microbiological tests, software and computer equipment many timesfreezing temperatures, chlorine logs, sanitation over.checks, and many other tests that are impor- Summary information, with originals avail-tant to buyers. This detailed summary infor- able as reference material, is also acceptable tomation helps sales of seafood products fit with the National Marine Fisheries Service in asso-the buyer’s needs and gives the level of confi- ciation with HACCP certification and will bedence necessary to keep customers. acceptable to the Food and Drug Administra-

A relational data base allows selection of a tion and other government agencies as pro-specific day’s production, product type, or an- grams are proposed at this time.other category that may be of interest to a

139

MAKING QUALITYIMPROVING SEAFVESSELS

Jim OstergardNew England Fisheries Development Association

During the 1970s, the stocks on the GeorgesBank fishing grounds, considered to be therichest fishing grounds in the world, were rou-tinely attacked by 13 to 15 different nations,including the U.S. and Canada. The fleets ofthe U.S. and Canada were antiquated, mainlycomposed of smaller, wooden, “eastern rigged”side trawlers, while the foreign nations hadlarge, well-supported fleets of steel-sterntrawler-catchers and large factory trawlersand processors. Supply fleets of freighters andtankers allowed these fleets to stay on thegrounds for periods of as long as 9 to 12months. The Magnuson Act became law in1976, extending our territorial waters to 200miles, thus effectively eliminating the foreigncompetition for our stocks.

During the remaining years of the decade,the U.S. fleet slowly converted to steel-sterntrawlers as replacement vessels for the olderwooden-side trawlers. Landings for a six- toseven-day trip to the fresh markets of 80,000to 100,000 pounds were common. Generally,the industry was satisfied with the commoditymentality of the fishery. However, a smallgroup became concerned that we were losingmarket share and that the resource would nothold up.

An industry group made up of harvesters,processors, and end users in the major marketsof New Bedford and Boston came together withthe New England Fisheries Development Asso-ciation to plan a strategy for the future of theregion’s fisheries. The major areas of concernwere impending stock reductions and loss ofmarket share caused by higher-quality importsfrom other countires in the North Atlanticbasin.

Funding was secured through theSaltonstall-Kennedy Fund from the federalgovernment, and the Quality at Sea Projectwas launched in 1981. It was felt from the out-set that because this project came from indus-try, it must include active participation andsupport from across the industry. We neededto tackle the question of the quality of landedproduct and the impact of the entire processing

and distribution chain on the ultimate qualityof the product delivered to the end user, theconsumer.

Oversight for the project through the tradeassociation, its broad-based membership, andan industry oversight committee was an im-portant component of the project’s manage-ment. Equally important was the projectdirector, Captain Eugene Connors, a 25-yearveteran of the New England groundfisherywho came ashore to manage the day-to-day ef-forts of the project. A key to the team buildingand problem solving needed in such a project isthe ability of the personnel involved to tran-scend social and personal differences betweenharvesting and shore-side production, distribu-tion, and marketing of the product.

After an exhaustive literature search ofmethods and tools available, the participantsset up guidelines for vessel participation. Theproject director enlisted the volunteer help of ahigh-line trawler and went to sea with equip-ment and methodology to implement the firstphases of the product. Of major importancewas this groundwork, which took a hard, long,and collaborative look at how we were doingthe job of harvesting and of transporting catchto the market.

In addition, the harvesters themselves, fromnumerous vessels and feeder ports to the majorports in the region, were enlisted in the pro-cess. It was felt from the outset that this wasan opportunity for industry to demonstrate itsexpertise. The empowering effect of thisground level participation generated furtherenthusiasm for the goals of the project. Oftentips on handling that the “old timers” remem-bered or had passed on to their sons or men-tors turned out to be helpful in planning thenext steps of the project. The four major goalsof the project were to (1) develop quality fishhandling procedures, (2) demonstrate the ben-efits of those procedures, (3) establish a pricedifferential for premium fish, and (4) reducethe labor intensiveness of producing such fish.

On board the vessels, attention centered onsanitation, work flow, and storage methods.

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Traditional bulk storage of product in pens 10to 12 feet deep was compared with shelvingand short shelving the fish pens to reduce theweight on the fish. Boxing of fish on boardrather than bulk stowage was demonstratedusing side-draining, nesting plastic fish boxesfrom Norway and Iceland. The boxing demon-stration was introduced on the volunteertrawler, the F/V Odin, sailing out of NewBedford, Massachusetts.

Early in the project, bled and boxed codfishwas placed on the fish auction in New Bedford,which is a “blind” auction, not a display auc-tion. Despite the high quality of the fish, it re-ceived a price below the market, which was aclear message from some of the dealers andprocessors opposed to change. Subsequentsales of fish landed during the remainder ofthe project were made “under the door” to pro-cessors involved in the project. (A display auc-tion was established in Portland, Maine, afterthe conclusion of the project, and a premiumwas established there for boxed and bled fish.)

Using a combination of private, academic,and government agencies, we followed the fishproduced under this project through the distri-bution system. We measured shelf life andquality attributes to document the advantagesof special handling on board. A manual for useon board the vessels was written and distrib-uted as was a processing manual during theyears the Quality Project worked along theMassachusetts shoreline. National trade me-dia, as well as local and regional newspapers,reported the findings of the project.

Project personnel didn’t confine themselvesto the trip boats from the larger market ports(Boston and New Bedford). Numerous tripsaboard other trip and day boats from the portsof Gloucester and Provincetown established anetwork of information about the advantagesof the fish-handling systems approach demon-strated during the project.

Having set the stage along the Massachu-setts shore, organizers extended the projectfarther east to include the Maine and NewHampshire coasts in 1984. Fish along thosecoasts were marketed in a different manner.Most ports, with the exception of Portland andRockland, Maine, were located many milesfrom major markets in isolated ruraI ports.Fresh fish were typically landed at a small pro-cessing facility with whom the vessel captainhad a marketing and supply relationship. Partof the catch might have been processed andpart shipped to Boston, New York, and Phila-delphia or other distant markets on consign-

ment. Often the vessel didn’t learn the price ofthose fish until returning from the next trip,and recourse to pricing was limited.

The Maine Groundfish Association, in con-junction with the Maine State Department ofMarine Resources, worked with the New En-gland Fisheries Development Association tobring the project to their members. Again, thiswas a diverse group including vessel operators,processors, brokers, and regulators. This over-sight group felt it was of the utmost impor-tance that the project leader come from theharvesting sector so that little time would bewasted in presenting the program and itwould be much easier to sell the programgoals.

Using information and experience gainedfrom the first stages of the project, the teamselected several volunteer vessels from threeports to participate. These vessels reflected dif-ferent market conditions and different styles ofvessel management. One trawler was part of alarge vertically integrated processing and mar-keting facility; the second reflected short-trip,independently owned vessels; and a third wasa large trip boat that sold on the open market.Several processors actively worked with theproject team, allowing sensory inspection ofproduct after receipt either by vessel or truckand allowing the state inspectors to partici-pate. At this time, additional laboratory test-ing was done to corroborate sensory grading ofthe fish shoreside.

During the later phase of the project, thegoal of improving the quality of the landedproduct was further investigated by looking atthree factors affecting the quality of the fish:enzymatic and bacterial breakdown after thefish has died and the effects of rigor mortis onthe overall quality and shelf life of the product.Given a good sanitation regime in place onboard, it was concluded that temperature con-trol and proper handling were the most impor-tant factors affecting the quality of theproduct. Fish hauled up the stern ramp warmto the sea surface temperature. During thewinter months in the Gulf of Maine, it is notuncommon to have surface water temperaturesin the 40 degree range.

Traditional deck practices often leave fishon deck for extended periods of time, and be-cause of the style in which they are movedfrom checker to checker, the fish are prone tobruising and increased deterioration from bac-teria and enzymes located on the fish them-selves. When fish can be rapidly chilled, theirtime in rigor mortis is extended; this extends

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the shelf life of the product. Storage techniques Shelf life studies indicated that properlyalso affect the overall quality of the fish. Bulkstorage is the most damaging, followed byshelving. The best technique for preserving theinherent quality of the harvested product isboxing the fish at sea. The economic return tothe harvester from improved storage methodscan exceed 12 percent more landed weightfrom boxes than from bulk storage. Other con-tainerized methods have merit as they too canreduce weight loss prior to landing the catch.

Solutions to the work flow on deck most of-ten came from the crews themselves, and be-cause of the capital requirements of large-scalecooling systems, proved to be a simple and low-cost alternative. A case in point: The use ofwharf boxes with circulating seawater to keepfish wet and at a constant temperature greatlyinfluenced the quality of the landed catch. Inaddition to preventing bacteria buildup, it keptthe fish from bruising and allowed bleeding.Viscera, when removed, did not recontaminatethe fish.

handled boxed codfish could maintain its shelflife for up to 21 days from harvest.

By the end of the project in 1985, all thegoals of the project had been met. Its findingswere widely published in the trade press andwere available in manuals. Personnel involvedin the project spoke on many occasions to allsectors of the industry, from harvesters to pro-cessors, retailers, and food service operators.To this day, individuals are profiting from useof the systems advocated during the project.However, the industry as a whole failed toadopt many of the recommendations of theQuality at Sea Project.

With the HACCP-based system of seafoodinspection about to become mandatory, itwould be timely for the industry to revisitthese fish-handling recommendations.

-

ent

Terje E. MartinussenNorwegian Institute of Fisheries and Aquaculture

THE DEVELOPMENT OF THE FISH-FARMING USTRY IN NORWAY SINCE1980The farming of salmon in Norway consists ofmany small units, with a relatively uniformtechnology based on floating dip net systems.Seven hundred twenty-nine units were regis-tered in 1991. While 190 units are approved forsmolt production, several of them are being in-tegrated with the farming of fish.

Growth in VolumeThe fish-farming industry in Norway, based

on the farming of Atlantic salmon, developedduring the 1980s from a relatively modest in-dustry to a large, economically significant in-dustry. Volume rose from approximately 7,500metric tonnes in 1980 to over 160,000 metrictonnes in 1990, but has fallen to approximately130,000 in recent years. Fish farming from1983 to 1993 has been marked by steadygrowth up to 1987 and an explosive increaseover the period from 1987 to 1990, which hasbeen the peak year to date.

Such sharp growth has been possible be-cause Norway has good natural conditions forfish farming and has had the necessary tech-nology and expertise. Furthermore, active ef-forts have been made to market fish products.

This development in the fish-farming indus-try has occurred despite relatively strict regu-lations governing participation and the size ofunits. Fish farming has been a licensed indus-try, and so not everyone who has wanted tohas been able to set up in business as a fishfarmer, There have also been stipulations onthe expertise required (minimum final exam inaquaculture from upper secondary school orrelevant professional experience), on who isentitled to own farms, and on the size of thefarms, with an original maximum of 8,000 cu-bic meters that in 1988 was increased to12,000 cubic meters.

Price DevelopmentThe price of Norwegian salmon increased in

the first phase of the fish-farming adventure.It rose regularly and steadily up to 1985, whenan average price was recorded of NOK 54.22per kilogram of fresh salmon. Since 1985 it hasbeen clear that Norwegian salmon is encoun-tering greater resistance in the market, withincreasing competition from other countriesand other products in the food market. Thesharp increase that has occurred in Norwegianproduction also means that since 1985 therehas been more intense competition betweenNorwegian producers and exporters, showingclearly that salmon no longer sells itself Weare thus witnessing the transition from aseller’s market to a prolonged period in whichthere is a buyer’s market, and major chal-lenges have to be faced in marketing and mar-ket development.

To counteract the effects on price of thesharp increase in volume, a scheme was estab-lished in 1990 under which a marketing coop-erative, the Norwegian Fish Farmers’ SalesOrganization (NFFSO), started to buy all sur-plus fish. This fish was frozen and stored atlow temperature (-50°C) to be sold in the mar-ket during periods of reduced supply and soensure more stable prices. In view of the sizethe “salmon mountain” gradually assumed,while individual fish farmers were not at thesame time reducing their production, the exist-ence of this stock of salmon in itself became asource of concern, creating uncertainty and lowprices in the market. Finally the cost of thisfreezing scheme became so high that NFFSOand several salmon farmers went bankrupt in1992. The stock of frozen fish from this periodhas now been sold.

Organization of SalesRight up to the time of the bankruptcy in

1992, the sale, processing and exporting of

farmed fish was regulated1 under the RawFish Act. This statutory protection was en-trusted to NFFSO, whose task was to organizeand check sales of farmed salmon and trout toapproved exporters. This responsibility putsthe sales organizations in the fisheries indus-try in a special position, on the one hand per-forming administrative tasks on behalf of theauthorities and on the other attending to theinterests of a group of fish producers.

After the bankruptcy, both direct and indi-rect sales were deregulated. Many people claimthe bankruptcy came at an opportune moment,with the result that the adjustment to the Eu-ropean Economic Community (EEC) could bemade less painfully. The system involving adominant marketing cooperative in the fish-farming industry was claimed by many to becontrary to the market regime in the EEC; crit-ics felt that it might therefore be declared in-valid by the EEC, which has a system ofvoluntary producer organizations (PO). Inpractice, the discontinuation of NFFSO hasimplied that the old system of approving pur-chasers of salmon has been done away with,while a change in the export law has providedgreater freedom for performing export services.Today, an export license is given on the basisof economic soundness rather than on perfor-mance in the market. The result is that thereare now more exporters. This has meant thestart of a certain amount of restructuring inthe fish-farming industry. I shall return to thislater in the article.

MARKETING OF THE NORWEGIANSALMON TRADEMARK UNDER THEDIRECTION OF NFFSO

NFFSO showed itself early on to be a salesorganization that differed from the other mar-keting cooperatives in the Norwegian fish-farming industry and played an active role inpromoting the joint marketing of Norwegiansalmon. In the traditional whitefish sector, themarketing cooperatives have had very littleinvolvement in activities other than direct sale,that is, fixing prices, directing catches, and un-dertaking various inspection duties on behalfof the fisheries authorities.

Through the Market Council, a councilmade up of representatives of exporters and

1Royal Decree of 28 July 1978, pursuant to the Raw FishAct of 14 December 1951

producers under NFFSO’s management,NFSSO has worked towards the joint promo-tion and marketing of Norwegian farmed fish(generic marketing). The aim was to give Nor-wegian salmon and trout a profile as “the fin-est and freshest fish on the market” andestablish this product as a trademarked prod-uct of high quality.

As part of this strategy, separate opera-tional units were established in the main mar-kets of France, Germany, Spain, and the U.S.The market offices conducted practical marketwork in the form of trade fairs, advertisingcampaigns, and direct contact with customersof Norwegian salmon exporters. The work fo-cused on establishing the trademark and con-cept of Norwegian salmon in the market. Asurvey undertaken among importers and dis-tributors of Norwegian salmon in the U.S. be-fore trade restrictions were imposed onimports, shows that Norwegian salmon wasregarded as the best quality and the best valuefor money (Olsen 1992).

The marketing effort on behalf of Norwe-gian salmon grew steadily from the time theMarket Council was set up in 1979. The bud-get in 1979 was NOK 640,000, rising to NOK62 million in 1990. It is clear, therefore, thatthe bankruptcy of NFFSO has resulted in asevere setback for the joint marketing of Nor-wegian salmon abroad. Marketing was fi-nanced by a compulsory levy on all sales ofproducts through the cooperative.

Budget (NOK):1986 1987 1988 1989 199012.5 m 25m 3 5 m 55 m 6 2 mThe dominant position Norway held in the

total market for salmon meant that the mar-keting activity to some extent also benefitedfish farmers in other countries. The problemwith this type of marketing is that it is difficultto make the effect of the promotional work ex-clusive, so that when the customers have beenpersuaded to demand more salmon, it is notcertain that they will demand salmon fromNorway; they may just as well buy salmonfrom other producer countries, depending onavailability and market price.

The marketing of Norwegian salmon hasdemonstrated how difficult it is to establish anexclusive trademark or concept unless the onewho undertakes the marketing work also hasresponsibility for production and quality in-spection as the individual actor in the system.It is easy to be wise after the event-certain

things that could have been done differentlycan readily be identified. For example, weshould have registered the Norwegian Salmontrademark. Today we can see the results of nothaving done so: Norwegian salmon can befound on the menu in virtually every restau-rant in the U.S., despite sales having almostcompletely ceased in 1991. By way of compari-son, it may be mentioned that New Zealandhas protected the Greenshell Mussels trade-mark with great success. We have witnessedthe same development in Scotland, where thetrademark has been protected through the in-troduction of a certification and inspectionscheme for approved producers of “quality ap-proved Scottish salmon.” Producers must beapproved (certified) before they can use thetrademark.

From the Norwegian point of view, the lackof supervision of individual producers and ex-porters meant that quality became uneven. Al-though the vast majority could still produceproducts of the right quality, it does not takemany rotten apples in a barrel to spoil theoverall impression.

The lack of supervision over the productionand sale of farmed fish resulted in the productsultimately presented to the customer not al-ways living up to the expectations aroused byour mass marketing efforts. To some extentthis weakened trust in Norwegian salmon inthe market. It has been particularly apparentthat the quality of Norwegian salmon hasdropped in periods of overproduction and toughprice competition. When the authorities had inaddition cleared the way for free exports, sev-eral unscrupulous actors entered the arena.Their entrance soon weakened the quality im-age of Norwegian salmon, which had beenbuilt through a long and laborious process.

The lack of supervision was not a problemjust in primary production; it was just as muchof a problem in the distribution chain throughto the customer, where salmon of differingquality was sometimes mixed together andsold as “superior Norwegian salmon.” Nor wasit difficult to get hold of Norwegian gill clipsand attach them to fish of different quality andfrom different countries of origin. The “prob-lem" of gill clips that are too solid has led, forexample, to work in Scotland to develop amark that falls off more easily and thus makesunauthorized reuse of quality marks more dif-ficult. Workers are also examining ideas forthe permanent labeling of individual fish, theuse of bar codes, and so on.

QUALITY INSPECTION AND THEDEVELOPMENT OF THE STANDARDPRODUCT NORWEGIAN SALMON

The fish-farming industry decided on astrategy of supplying a raw material of thehighest possible quality and thus making theproduct attractive in the market. In addition,the strategy involved supplying the product inlarge quantities.

The philosophy was to supply the finest andbest fish, based on the ideas that “high qualitywill certainly find a market” and “high qualitycan be put to any use required.”

Superior SalmonTo safeguard quality, a relatively simple

system for grading salmon in different qualityclasses was established in 1985: superior, ordi-nary, and production fish.

The grading system was made subject topublic quality inspection and thus representeda minimum standard of quality it was legallypermissible to put on the market. For manyfish farmers, this unfortunately also became amaximum standard, and the aim became toproduce as much as possible as cheaply as pos-sible. There was thus no need to make an ef-fort to produce a product that did more thansatisfy the requirements laid down by the su-pervisory authorities. The proportion of supe-rior salmon at first was around 90 percent butfell as the volume of production rose.

The grading system established was arather simple and subjective one, with gradingaccording to size and glossy surface, and to alesser extent a grading according to raw mate-rial-based characteristics (fat, color, consis-tency). The emphasis was put on the externalquality characteristics of the raw material (ap-pearance) and less account was taken of thequality requirements necessitated by differentproducts. The system therefore became vulner-able to variations in quality, while at the sametime everyone was marketing the product un-der the common quality mark of Norwegiansalmon.

To avoid the adverse effects of the trustplaced by the market in Norwegian salmon,individual exporters chose to establish theirown trademarks, such as Grand Nord, to en-sure the necessary recognition and trust.

Development of Norwegian SalmonAs part of producing a standard product of

high quality, NF’FSO, in cooperation with the

trade organization, the authorities, and re-search councils, launched research and devel-opment programs such as New Fish (researchinto new species) and Healthy Fish (researchto prevent and combat disease).

In addition, NFFSO launched its own activi-ties with emphases on health monitoring, vet-erinary service, breeding, and computersystems for information and productioncontrol.

The purpose behind these activities wastwofold: to develop fish with better qualitycharacteristics and to make a greater commit-ment to training fish farmers in correct tech-nology and processes for producing Norwegiansalmon. In addition to this developmental workunder the direction of NFFSO, Norwegian feedmanufacturers and research communitiesmade their own contributions to research anddevelopment, which has benefited the fish-farming industry.

Personnel were offered short courses in sub-jects such as breeding, feed and feeding, pro-duction and financial management,slaughtering, and quality grading. NFFSO alsoemployed its own production advisers for thedirect training of fish farmers. The trainingwas organized through a separate founda-tion - the Aquaculture Training Foundation -which the sales organization established in1988 in cooperation with the Norwegian Asso-ciation for Aquaculture Research and the Asso-ciation of Norwegian Fish Farmers. Theobjective of the foundation is to hold coursesfor fish farmers and foster closer cooperationbetween researchers and fish farmers.

The Fish Inspection Authority(Fiskeridirektoratets Kontrollverk) has alsobeen used by the NFFSO in setting up the sys-tem and supervising the actual grading.

Towards the end of the 1980s NFFSO be-gan working to a greater extent on questionsrelating to the standardization of productionprocesses in the industry, for example, stan-dards for the measurement of fat and color sothat this could be quantified,

In connection with the freezing scheme,standards were drawn up for the handling andfreezing of fish to ensure optimum quality andshelf life for the fish.

Developments in the market, with pre-parations for the establishment of a commonEuropean market with common rules forstandardization and certification, also helpedpersuade NFFSO to give more thought to thecertification of farms and businesses towardsthe end of the 1980s.

In 1988 the Good Fish Project was launchedas a collaborative project between the authori-ties and the fish-farming industry. The aimwas to bring together knowledge about qualitywork in one organization, spread this knowl-edge, and point out the need for research anddevelopment. The work was project oriented inthe initial phase, with the emphasis onprojects to improve the quality of Norwegiansalmon and bring about a more uniform con-ception of quality among practitioners. In time,the Good Fish Project developed to become adriving force behind the establishment of qual-ity assurance systems and certification in thefish-farming industry.

As part of the work to improve the quality ofthe Norwegian salmon product and to developmore customer-related product specificationsfor fresh farmed salmon, a wide-ranging cus-tomer-market survey was conducted in the pe-riod 1990 to 1992 under the Good Fish Projectin the nine most important markets for Norwe-gian salmon (Koteng 1992). One of the conclu-sions from this survey, which was mainlyconducted among importers, wholesalers, andsmokeries, was that the five most importantquality criteria are

1. freshness2. color of the flesh3. consistency4. red gills5. fat contentThe results of the survey emphasize that

customers in different countries and in differ-ent groups have differing tastes. This is re-flected for example in different requirementsfor color and fat content, and thus differing as-sessments of whether Norwegian salmon is ofgood or poor quality.

An aspect that was emphasized as particu-larly positive in relation to Norwegian salmonis regularity of supplies. A negative aspect thatwas mentioned was that Norwegian salmonought to be of more even quality.

The survey also confirms that Europeancustomers prefer Atlantic salmon to Pacificsalmon.

This market survey supported NFFSO in itsbelief in the need to safeguard the quality ofNorwegian salmon and to establish systems forquality assurance in the industry. Whereas in1987 fish farmers were not at all receptive tothe idea of introducing quality assurance

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systems, by around 1990 the situation hadchanged substantially.

Plans were drawn up under the Good FishProject and NFFSO to establish quality assur-ance systems in all Norwegian fish farms. Toprovide a basis for this plan, a systematic re-cording and description was made of all operat-ing procedures in rearing, slaughtering,packing, and sales, in order to create standard-ized “model procedures” in the industry. Theidea of a standardized product was also appliedin the plan to introduce quality systems in fishfarming.

The aim was to be able to certify all fish-farming businesses under NS ISO 9002. Thepossibility of developing a special quality em-blem for certified firms that could be used inmarketing was also discussed. This, as Ipointed out earlier, was one of the shortcom-ings in the marketing of Norwegian salmon.

The aim was to implement a nationwideprogram, but because of the bankruptcy ofNFFSO and inadequate financing, the projectwas launched as a trial project limited to thecounty of Hordaland. The results of the trialproject will be the deciding factor in settlingwhether this program obtains the necessaryfunds to be expanded to other counties.

Because the quality program did not startuntil 1992, no conclusions can yet be drawn onhow the work of establishing the quality sys-tems has progressed. Our general impressionis that the plan has focused too much on stan-dard procedures in order to be more effective inproducing a standard Norwegian salmon, andnot enough on how to improve quality and howto bring about greater customer satisfaction.

EXPERIENCE FROM THEESTABLISHMENTT OF QUALITYMANAGEMENT IN THE FISHERIESINDUSTRY IN GENERAL,

Quality Systems in the Fisheries IndustryThe Norwegian Institute of Fisheries and

Aquaculture has been involved in three differ-ent programs for the establishment of qualitysystems in traditional fish processing, prawnf i rms and fish farms.

The Norwegian Institute of Fisheries andAquaculture has had a dual aim in theseprojects. First, we have had responsibility forestablishing quality systems in individualbusinesses and for training consultants, who inthe next phase are to take on responsibility forestablishing quality systems in new busi-nesses. The motto has been to educate the

educators, whether they be consultants or in-ternal quality coordinators in the businesses.The Norwegian Institute of Fisheries andAquaculture has also developed methods offinding an appropriate way of establishingquality systems in this type of firm and adapt-ing the requirements of NS ISO 9002 to opera-tional procedures in the fisheries industry. Inaddition, we have cooperated with a certifica-tion society to provide assistance with special-ist knowledge of fisheries and take part in thecertification work in businesses.

MethodThe method that has been used is based on

principles learned from experience. There isagreement that the employees are the mostimportant element in a company's quality sys-tem. We have therefore invested a great deal ofeffort in developing a method that can commitand motivate the employees. The projects havebeen developed by a team consisting of re-searchers, consultants, and educators(Robertsen et al. 1992).

The projects are divided into two phases.The first phase focuses on the motivation andparticipation of the employees, in whom it isimportant to activate the knowledge alreadypresent in the firm. The employees are prob-ably the firm’s best “consultants,” and activecommitment is therefore valuable in manyways.

Improvement projects also occupy an impor-tant position in the first phase. Because prior-ity is given to identifying and solvingproblems, the employees will see positivethings actually being done in the firm so thatthey are encouraged to make further efforts.

Phase two focuses on documenting the qual-ity system of the firm. This documentation alsoprovides a critical examination of existing rou-tines and processes. They are changed if neces-sary before the system is finally documented ina quality manual. The firms usually need to besupported in the work of structuring the mate-rial in the quality manual.

The first production firm was certified forquality work under the NS ISO 9002 standardin April 1993. More firms will probably be cer-tified soon. The first firm in the fisheries in-dustry, the export business NORFRA, wascertified in March 1993.

What Has Been Difficult?Experience from the projects has been favor-

able, and they will therefore continue with the

next round, albeit with a few changes. First, itis essential that the senior managementshould sign contracts stating that they willparticipate fully in the development project. Ifnot, the firm will be dropped from the project.

A second point is that in periods of high pro-duction it has been difficult to set aside thenecessary time for quality work in firms.Third, more emphasis should be put on im-provement work in businesses. To remedy thissituation, it has been decided that most firmsin the next phase, depending on size, will haveto employ a full-time person for two years tomanage and coordinate quality work in thefirm. It is important that every firm have spe-cific tasks to work on at an early stage andthat requirements be set for improvement. Inthis way the process is set in motion and thefirms feel that they attain practical results in areasonably short time. Most firms that haveachieved or are in the process of achieving a9002 certificate have worked on quality im-provement and quality systems for at leastthree years.

The process of establishing quality manage-ment systems according to an internationalstandard will be useful in the overall work ofestablishing TQM. Quality management andpossible certification of it will therefore be oneof the aims in a firm’s development plans. Theultimate aim should be to have a productionprocess and products that result in satisfiedcustomers and satisfied staff, at the same timeas the firm earns money.

EXPECTED DEVELOPMENTS IN SALESOF SALMON - THE NEED FOR QUALITYMANAGEME NT IN RELATION TO THECUSTOMERS

The salmon market developed in the 1980sfrom being a relatively homogenous marketwith demand for a standard product distrib-uted through long and complex sales channels.

As the market reached approximately100,000 tonnes in 1987/1988, it divided intotwo separate segments. In addition to the tra-ditional channel, a segment became estab-lished with several product variants, increasedprocessing, and the establishment of shorterand more specialized distribution channels.

The third stage is developing a more seg-mented market, a large number of products,trademarked products, and sales through afew specialized channels.

Requirements and Trends among SalmonBuyers

Developments in the retail market have re-sulted in supermarkets’ cooperating moreclosely with fish farmers and processors to de-fine the best specifications and testing mecha-nisms to ensure that the requirements aremet. The specifications are given in the form ofmanuals that are provided only to producerswho enter the negotiation phase.

For supermarkets that sell their ownbrands, there should be the best possiblechecks on the source of the raw product. Onthe one hand, retailers in several countries aresubject to strict legal requirements regardingproduct liability. On the other hand, the in-creased share of own brands makes it very im-portant to check the quality of the products.This checking of the chain of supply has be-come visible through a close check of the selec-tion of suppliers. It can therefore be expectedthat greater requirements will be set for for-mal quality approval according to an interna-tional standard in order to get into anegotiating position at all. Certification inother words is becoming a necessary, but farfrom adequate, condition for ensuring sales ofproducts.

Product SpecificationsRetailers set specifications for all the links

in the chain of supply. They start with primaryand secondary processing and go all the wayback to packing and distribution. The specifica-tions apply to the following areas:

Rearing:

Rawmaterial:

Processing:

Finished product:

operation of the farm,clean environment, feed,amount of biomass inthe dip net, preparationfor slaughtering

size, color, fat content,appearance, firm consis-tency, freshness, antibi-otics, microbiologicalcontent, even quality

hygiene, technicalstandard, handling,health and safety,chilling

taste, even size andclean cutting, slicethickness, packing, salt

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content, skinning,boneless, no bloodpatches

Delivery: Fresh salmon must notbe more than three daysold when it reaches theretailer.

The retailers cooperate with a small numberof suppliers, and the trend proves that it isworth maintaining a stable relationship withsuppliers rather than change constantly andalways be on the lookout for the best offer.

Salmon is changing in character, from ageneral commercial product of standard qual-ity to a more differentiated product with manyforms, qualities, and specifications. The pricemust be “right” and preferably stable over agiven period. The main thing is to secure goodand stable suppliers who can fit in with a givenmarket concept or trademarked product.

Key actors in the industry believe that thefuture makeup of the industry will be asfollows:

exporter-controlledfish farming 10-20 percent

integrated firms (export-production-rearing) 20-30 percent

joint operation (fishfarmers with jointproduction plants,purchasing,slaughtering, andso on) 40-50 percent

individual firms(independent) 10-20 percent

Since the export monopoly was discontin-ued, we have seen a development in the direc-tion of larger amalgamations of fish farmersand exporters. These amalgamations establish

their own quality systems and use qualitymanagement actively in the groups’ market-ing. Development seems to be moving in thedirection of statutory regulations that set cer-tain minimum requirements a firm must meetwith regard to health, environment, and safetywhile the detailed requirements on quality aredeveloped in a close dialogue between theseller and purchaser.

Large customers in the European marketwill require a firm to have documented qualitysystems in order to enter into negotiations. Ifthe group is accepted, the challenge will be toproduce products according to detailed productspecifications for customers. It is thus not suf-ficient to be qualified for the Olympic Games;you have to be properly prepared to win goldmedals too.

We anticipate a stronger trend towards anincreased number of products and conse-quently a need for producers who are flexiblein adapting to different market requirements.Market orientation and marketing will there-fore be key concepts in the 1990s.

ReferencesKoteng, D. 1992. Markedsundersøkelse forkelse for

norsk laks. FNL.NFFSO. Annual reports 1985-1990.Olsen, S.O. 1991. Norges profil blant

amerikanske distributører av sjømat.Rapport 2/1991, Fiskeriforskning, Tromsø.

PA Consulting Group 1992. Videreforedling avnorsk laks. DU-NFFR-NTNF prosjekt.

Robertsen, et al. 1992. Total quality manage-ment in the Norwegian fishing industry.Page 561-569 in Quality Assurance in theFish industry. H.H. Huss et al., eds.Amsterdam: Elsevier.

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DEMAND FOR SEAFOGRADES: CASEGilbert SylviaCoastal Oregon Marine Experiment Station

Michael MurphyMarine Resource Management Program, Oregon State University

Sherry LarkinDepartment of Agriculture and Resource Economics, Oregon State University

INTRODUCTIONQuality assurance (QA) programs can generateseveral benefits to the seafood industry. Theseprograms can result in higher product prices,increased sales, lower inventory costs, and re-duced risk liability. They can help firms meetthe requirements of national and internationalinspection programs in seafood quality andsafety. QA programs also function as a frame-work for integrating marketing and produc-tion, as well as balancing costs and benefits.Such “marketing management” schemes canbe helpful in developing production strategiesthat maximize industry objectives and oppor-tunities.

Development of an industrywide quality as-surance program has been proposed to improvemarket opportunities and reduce variation inPacific whiting products. Past research has in-dicated that product consistency is importantto industry buyers and may increase marketprices, improve product reputation, establishbrand loyalty, and provide market stability(Sylvia and Peters 1991).

The following paper summarizes some pre-liminary results from selected portions of anongoing study sponsored by the Oregon TrawlCommission and the Oregon Department ofAgriculture. The purpose of the study is to helpOregon seafood industries and fisheries man-agement agencies develop optimal production,management, and quality control programs forPacific whiting. Recently, over 100 surveyshave been sent to groundfish industry mem-bers, including processors, brokers, wholesal-ers, and distributors. Survey questions weredesigned to delineate product quality issuesand standards that affect fishers and proces-sors in the Pacific whiting industry. The sur-vey also attempted to explore the potentialeconomic effects of adopting gradingstandards.

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SURVEY/DATA

Three Pacific whiting product forms wereincluded in this survey: individual quick-frozenfillets, headed and gutted, and surimi. Onlythe information obtained from the fillet sur-veys are discussed in this paper. The surveycontained seven sections, which are briefly de-scribed below.

In the first section, respondents analyzedsamples of frozen and thawed fillets that ac-companied the survey. For individual frozenfillets, respondents scored the desirability ofthe package form, the general appearance ofthe fillets in the package, dehydration, and netweight. For the thawed fillet, respondentsevaluated flesh color, appearance defects, full-ness of flesh, texture, color, and overall consis-tency of product characteristics. The nextsection addressed the firm’s experience withPacific whiting. The third section focused onquantifying the importance of different productcharacteristics when purchasing whitingfillets.

In the fourth section, respondents wereasked to select levels of characteristics thatwould define a grade A and grade B Pacificwhiting fillet product. Respondents also scoredthe importance of various federal, state, indus-try, and firm inspection and grading programsdesigned to maintain and improve consistentproduct quality. In the fifth section, a hypo-thetical market experiment was conducted inwhich respondents identified the relative im-portance of frozen fillet characteristics in con-tributing to firm profitability. The “market”consisted of eight Pacific whiting frozen filletproducts that represented a different combina-tion of quality for five characteristics. The lasttwo sections of the survey asked questionsabout the market potential of different Pacificwhiting products and general firm attributes.

Figure 1. Acceptability score of product with varying consistency in net weight and texture.

3.22

PRODUCT CONSISTENCY

SOME PRELIMINARY RESULTSOne important issue in developing a QA

program is controlling variation in productcharacteristics. A seafood industry buyer mayprefer to purchase a product that consistentlyhas the same characteristics, even if the prod-uct has slightly lower average quality. How-ever, maintaining consistency may be moreimportant for some characteristics than others.

In the product quality section of the survey,respondents were asked to rank the relativeimportance of maintaining consistency forseven characteristics. Preliminary resultsshow that net weight was the most importantcharacteristic in maintaining consistencywhereas texture was the least important (fig-ure 1). The majority of respondents felt itwould be unacceptable if 10 percent or more ofthe product packages were less than the statednet weight. Conversely, product remained ac-ceptable if up to 20 percent did not conform tothe stated texture. The five other characteris-tics surveyed had acceptability levels rangingfrom 10 percent to 20 percent, the order beingbone count (similar to acceptability level of netweight), appearance defects, workmanship,shelf life, and color.

The remaining portion of the survey focusedon the relative importance of different productcharacteristics for industry buyers and howthese characteristics could affect profitability.Analysis was accomplished in three stages: (1)respondents developed two hypothetical gradesby choosing a quality level for seven fillet char-acteristics; (2) results of a hypothetical marketexperiment were used to calculate break-even

prices (see Sylvia and Peters 1991, for detailsof the analytical approach); and (3) a single op-timization problem for a fillet producer wasexamined.

Stage 1: Respondents Established GradesEach respondent specified his or her desired

grade A and grade B product by completing theform shown in figure 2 for each proposedgrade.

The results of the survey for the grade Aand grade B products are summarized intable 1.

A total score for the grade A and grade Bproducts was calculated by summing thescores for each of the six fillet characteristicsthat defined the grades. The score for eachcharacteristic was found by multiplying theaverage score for overall product consistencyby the average acceptability of the characteris-tic. Hence, the difference in scores betweengrades resulted from using the average accept-ability scores at the 95 percent consistencylevel for grade A versus the 85 percent consis-tency level for grade B. The difference betweentotal score for each grade was then used to ex-plain the difference in estimated break-evenprices determined from the hypothetical mar-ket experiment described below.

Stage 2: Hypothetical Market ExperimentThe hypothetical market experiment pro-

vided information that identified the indi-vidual contributions of firm attributes andproduct characteristics to firm profitability. By

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The Pacific whiting industry is concerned with developing grading standards for frozen fillet productsthat will meet our customers’ needs and requirements. You can help us by defining a grade A andgrade B standard for Pacific whiting frozen fillets. Below are two identical listings of quality charac-teristics. Please indicate which options of the quality characteristics would best describe your defini-tion of a grade A and grade B Pacific whiting frozen fillet product by circling one option per qualitycharacteristic for both the grade A and grade B standards.

OVERALL PRODUCT a) 99%QUALITY CONSISTENCY d) 70%

TEXTURE a) Firm

FLESH COLOR a) White

SHELF LIFE a) 18 months

APPEARANCE DEFECTS a) None(bruising, blood spots, etc.)

WORKMANSHIP a) Excellent(cut/trim imperfections, No imperfectionsforeign materials, etc.)

b) 95% c) 85%e) 50% f) Other

b) Moderately firm c) Soft

b) Off-white c) Light pink

b) 12 months c) 6 months

b) Slight c) Moderate1-3 defects 4-5 defects

b) Good c) Fair1-2 defects 3-4 defects

BONE COUNT(each instance of bone is apiece exceeding 10 mm inlength and 0.355 mm indiameter)

a) No bones per 0.5 kg b) 1-2 bones per 0.5 kg c) 2-3 bones perof fish flesh of fish flesh 0.5 kg of fish

flesh

Figure 2: Survey sheet for grade A standards.

Table 1.Composition ofgrades asdetermined byrespondents.

Characteristic

Overall Product

Average AverageGrade A Grade B

1 96.8% I 86.1%ConsistencyTextureFlesh Color

Bone CountShelf-LifeWorkmanship

Appearance of Defects

Firm to moderateWhite to off-white

0.5 bones/lb12.7 monthsExcellent to good(0.8 defects)

None to slight(1.8 defects)

Moderately firmOff-white to slightlypink1.5 bones/lb9.3 monthsGood to fair(2.0 defects)

Slight to moderate (3.2defects)

specifying a zero level of profit, we derived a“break-even-price” equation. Using this equa-tion, we determined various break-even pricesby specifying different levels of firm attibutesand product characteristics.

In the “market” experiment, respondentsscored the profitability of eight products on ascale of -10 (very unprofitable) to +lO (veryprofitable). The Pacific whiting fillets were as-sumed to be skinless, off-white, and frozenwith the pinbone removed. The factors hypoth-esized to affect product profitability repre-sented both the characteristics of the firm and

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the product. The products varied by grade,shelf life, supply availability, price, and tex-ture. Firm-specific factors were annual grosssales, position in the marketing chain, andwhether Pacific whiting is among the top threespecies (in volume) the firm handles.

The proposed equation was estimated usingthe statistical technique of ordinary leastsquares, and the results are summarized intable 2. All factors measured were found tohave a statistically significant effect on profit-ability except supply availability.

Table 2.Profitability ofwhiting fillets.

receiver) I IHandle Pacific Whiting? (1=yes, - 4.30 2.94**

Equation Statistics: Observations=62F=9.88Adjusted R2=0.54

* 90% significant** 99% significant

To examine the effect that each factor hason price, we set profit at the break-even level(zero) and solved the estimated equation forprice. Larger firms, represented by annualgross sales, were found to operate at a lowerprice, presumably because of the ability oflarger firms to obtain volume discounts. As ex-pected, second receivers had a higher break-even price because of the additional costsassociated with their position in the marketingchain. Firms that have handled Pacific whitingbreak even at a lower price, presumably be-cause of the historically poor product qualityand reputation of Pacific whiting fillets. Thistendency is consistent with previous researchby Sylvia and Peters (1991), who found thatthe characteristics of Pacific whiting are per-ceived to be inferior to those of Argentine andChilean whiting fillets. Fillet products thathad a higher grade or longer supply availabil-ity received a higher price because these char-acteristics were more desirable.

In this analysis, one focus was on the effecton break-even price for fillet grade, given afirm’s position in the marketing chain andgiven whether the firm handles Pacific whit-ing. For moderately firm fillets with a nine-month shelf life, a five-month supplyavailability, and purchased by a buyer, the fol-lowing break-even price equation resulted:

break-even price = 0.93 + 0.37 (grade) - 0.17(first receiver) - 0.32 (Pacific whiting)

Using the above equation, we calculatedseveral break-even prices. In figure 3, theseprices are categorized by whether or not thefirm has handled Pacific whiting and by its po-sition in the marketing chain. Notice that theprice differentials correspond to the coefficientsin the break-even price equation, that is, gradeA is consistently $0.37 more than grade B.

We were also interested in explaining theprice difference of $0.37 attributed to movingfrom a grade B to a grade A product. The pricedifference can be calculated by the characteris-tics that defined each grade using the score dif-ferentials shown in table 3. This wasaccomplished by dividing the price differenceby the total score difference to obtain the valueof a unit of score. When the unit score value ismultiplied by the score differential for eachcharacteristic, of a grade A and grade B prod-uct, the value of each characteristic is ob-tained. This is shown in table 4. For example,the value of texture equals $0.0021 x 19.

Stage 3: Grade Score OptimizationThe goal of a firm is to maximize profits by

increasing price while controlling costs.Switching production from grade B to grade A

Figure 3.Break-euenprices forfrozen Pacificwhiting fillet

Table 3. Gradescores bycharacteristics.

Total Score:

may generate higher gross returns, buthigher costs associated with producing

Table 4. Additional value of Grade A characteristicsrelative to Grade B.

grade A may actually make the product lessprofitable. If all costs were known, this deci-sion would be straightforward, but many ofthe relationships between product qualityand production costs are not yet established.Therefore, for this preliminary analysis, weassumed different cost functions to illustratethe different production decisions that a firmmay face based on varying costs. The unitprice is composed of a base price (the esti-mated grade B price) and a grade scorevalue (the additional revenue received fromproducing a product with a higher score than agrade B product). The base price was calcu-lated from the break-even equation, assumingthat the firms are first receivers (first receiver= 1) and that they handle Pacific whiting (Pa-cific whiting = 1). The assumptions were madeto specify a typical on-shore Pacific Northwestprocessor. The following linear price equationresults:

price = 0.51+ 0.0021(score)The hypothetical cost structures consisted of

a base cost and two values associated with thegrade score. Production of a higher grade,represented by a higher score, was assumed toincrease costs. One grade score had a directand constant (linear) impact on cost. The otherwas squared (quadratic) to represent costs thatincrease as score is increased. Three alterna-tive cost structures were assumed (since actualcosts were unknown) to emphasize how theirdifferences affect production decisions.

The results in figure 4 show that differentcost structures will influence which grade ismost profitable. For example, production ofgrade A in example 1 would result in a loss of$0.03/lb.; however, production of grade Bwould generate profits of $0.05/lb. Therefore,for the cost structure given in example 1,production of grade B would be the mostprofitable. In example 2, both grades could beproduced and generate a profit whereas in

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Total additional value:

example 3, only production of grade A willgenerate a profit. If cost information can bedetermined, cost equations like those shownin figure 4 can aid in making productiondecisions.

SUMMARYThe adoption of QA programs can be used as

a mechanism to integrate marketing and pro-duction decisions. Responses from the ongoingsurvey indicate that net weight should conformto the stated package weight, grade A has asignificantly higher price because of its moredesirable characteristics, and those firms thathave handled Pacific whiting in the past scoredthe hypothetical products lower because of pastexperience and reputation.

Before QA programs can be developed andimplemented for Pacific whiting, market infor-mation must be incorporated with cost infor-mation into management decisions. The costinformation must consider all supply-side is-sues, including how the fishery is managed.For example, the behavior of fishers will varyin response to regulations that can have impor-tant implications on the quality of fish deliv-ered to the processor. Industry must alsoconsider short-run versus long-run planninghorizons. QA programs will incur up-frontcosts, but market benefits in the form of higherprices and increased sales may take a longer

0.46+0.001(score)+0.000009(score2)

Example 2:0.46+0.0013(score)+0.000005(score2)

Example 3:0.56+0.0005(score)+0.000004(score2)

time to generate, depending on marketingskills, promotional budgets, and the past repu-tation of the product. A successful QA programmust incorporate both market and cost infor-mation and be a part of marketing and promo-tional efforts to expand market opportunities.

REFERENCES

Beaudoin, R.M. 1992. Personal communica-tion. Director of Marketing, Maine Depart-ment of Marine Resources, Augusta.

Daniels, J. as summarized by A. Shriver. 1992.The importance of quality assurance for theintroduction of Pacific hake into traditionalfrozen seafood markets. Pages 56-57 inPacific Whiting Harvesting, Processing,Marketing, and Quality Assurance. G.Sylvia and M.T. Morrissey eds. CorvaIlis:

Scores Profits

Optimal=60 $0.08Grade B $0.05Grade A $-0.03

Optimal=80 $0.08Grade B $0.05Grade A $0.03

Optimal=200 $0.11Grade B $-0.05Grade A $0.11

Oregon Sea Grant.

Production

Grade B only

Grade B andGrade A

Grade A only Figure 4. Grade production

Gorga, C., and L.J. Ronsivalli. 1988. Quality

given alternative cost structures

assurance of seafood. New York: VanNostrand Reinhold.

Love, M. 1988. The food fishes: their intrinsicvariation and practical implications. Lon-don: Farrand Press.

Port, O., and J. Carey. 1991. Questing for thebest. Business Week, October 25:8-16

Sylvia, G., and L. Gains. 1992. Quality assur-ance programs for Pacific whiting. Pages 41-46 in Pacific Whiting Harvesting,Processing, Marketing, and Quality Assur-ance. G. Sylvia and M.T. Morrissey eds.Corvallis: Oregon Sea Grant.

Sylvia, G., and G. Peters. 1991. Market oppor-tunities for Pacific whiting. Oregon CoastalManagement Association, Newport, Oregon.

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Carmine GorgaPolis.tics Incorporated, Gloucester, Massachusetts

QUALITY ASSURANCE AS A SOURCE OFF’INANCINGMoney is many things, but to the entrepreneurmoney is primarily a conveyor of information.And the essential information about which thisperson wants to be kept abreast is the level ofsatisfaction expressed by the consumer. Themore money comes in - a steady flow - the bet-ter an indication that the firm is satisfying theneeds of the consumer.

Information is a word that perhaps isabused today. Let us therefore leave the worldof communication and directly enter that offinance. It might sound surprising at first, butthis is the reality: the consumer is the primarysource of financing for the firm. If the con-sumer is fully satisfied, the firm will not lackfinancial resources. Is this not the most signifi-cant confirmation of the overriding importanceof quality assurance?

Quality assurance then is the ultimatesource of financing. Indeed, we shall see that,even setting aside the role of the consumer,quality assurance is a direct and immediate-internal as well as external-source of financ-ing opportunities.

INTERNAL FINANCING OPPORTUNITIESIt does not cost money to achieve quality.

Rather, quality pays. It pays back the effort ofits implementation, not only in increased con-sumer satisfaction and therefore a steadystream of incoming funds, but also as an arrayof cost reductions.

The Number of Refunds Is NearlyEliminated.

With or without an explicit pledge of re-funds, an angry customer does demand re-funds and is often accommodated. Refunds arecostly, not only for the waste they cause, butbecause most often they imply the loss of a cus-tomer. It is not only the present but the futurelevel of sales that is implicated. Along thesame vein, it is also whispered that with qual-ity assurance even the number of law suits isreduced.

The Number of Rejects Is duced.When all that needs to be done over the en-

tire chain of production to assure the quality ofthe product is indeed done, one of the most evi-dent benefits is the noticeable reduction in thenumber of rejects. Rejects are costly, not onlyfor the evident loss of value, but also for theloss implicit in the inability to satisfy a poten-tial consumer.

Morale Is Raised.When refunds are nearly eliminated and the

number of rejects is reduced, the morale of theemployees is raised. Everyone within the firm,if not within the industry, soon knows of thoseresults and is proud of being part of an outfitthat does good work. The financial effects ofthis by-product of quality assurance might behard to measure, but people work better andfaster if they are proud of their work.

Expenses Can Be Eliminated.Empire Fish Company, of Gloucester, Mas-

sachusetts, was the first seafood producer toimplement the details of the quality assuranceprogram developed by the Gloucester Labora-tory of the National Marine Fisheries Service(NMFS) during the late seventies and earlyeighties. Knowledge of the quality of its prod-uct spread by word of mouth. The firm soonsold fish throughout the United States, and itdid not spend one penny for marketing or ad-vertising campaigns. This is an effect that canbe easily quantified. And it does not mean thatall marketing and advertising campaigns mustbe eliminated. Efforts to educate the consumer,for instance, would be highly useful. And fi-nancial resources devoted to this purpose couldeasily be found if the need for traditional mar-keting and advertising campaigns is reducedor even eliminated altogether.

The Financial Effects of QualityAssurance.

There have been many attempts to quantifyeach of these fields. See, for example, Crosby

1979, pp. 119-126, or Gorga and Ronsivalli1988, pp. 180-216. Unless figures are related toeach firm, these cost estimates generally tendto have a mere theoretical flavor. But certainlyit ought to be part and parcel of the statisticalmeasurements relating to quality control todevelop precise information for each firm onthese effects. Firms that do take such mea-surements report consistently positive results.Fredrik Palsson, president of Icelandic Freez-ing Plants Corporation, put it quite well. Asquoted in Bidner 1992, he said: ‘We spend anawful lot of money on quality control. It’scostly, but we get it back. We’re essentiallybuying consumer confidence through our ag-gressive quality-control programs,” Here onlytwo points need to be made. First, a program ofquality assurance redoubles the effects of strin-gent quality control measures, because it cov-ers not any one firm alone but the industry asa whole; the efforts of each firm are not ne-gated but validated by the efforts of all otherfirms participating in the program. The secondpoint is that a firm raises money internally byreducing costs and lowering expenditures.Since quality pays, in the microworld of eachfirm quality assurance is an implicit financingtool.

EXTERNAL FINANCING OPPORTUNITIESBanks do not need hair-brained schemes.

The nation does not need hair-brainedschemes. The quality assurance program is asolid program. Another one of its hidden ben-efits is that it can become an explicit financingtool when put in relation to the outside worldof finance. Any financial institution will morereadily extend loans - at preferential rates - tofirms whose costs are low and whose custom-ers are satisfied.

Armed with this significant tool, it behoovesthe firm to explore all opportunities that existin the macroworld of finance. Governmentaland nongovernmental avenues have to be ex-plored on a systematic basis. Here I reviewonly a few such avenues.

I place most emphasis on two avenues thatare little traveled by the seafood industry andare more often taken in other industries. Thesetwo avenues are employee stock ownershipplans and access to national credit.

The World of Grants, Loans, andSubsidies

There is an entire world of grants, subsidies,and loans at preferential rates that is worth

pursuing, provided one has the time and initialresources to pursue it. This is only another oneof the reasons that organization, organization,and organization is so important. It is enoughto start reciting the so-called alphabet soup ofgovernmental agencies-such as NMFS, withits Saltonstall-Kennedy funding program; theEconomic Development Administration; theSmall Business Association, with its SmallBusiness Innovation Research program, ad-ministered by various agencies; even the De-partment of Defense - to realize how manyopportunities are there to smooth the path ofresearch and development in todays world ofso-called mixed economies. Nor should one ne-glect local and state governments - and evenprivate foundations. For many good reasons,one might be personally opposed to the exist-ence of such a world, and yet two points needto be made. First, at a very practical level, onemust remember that one can be put at a com-petitive disadvantage if the benefits offered bysuch a world are left by default to one’s com-petitors. Second, many positive things can besaid about effective, well-conceived, and well-managed R&D programs. Many projects mightnever be undertaken without such assistance;and once successfully undertaken, they func-tion as insurance that the project is viable -hence the rush of applications from which,generally, the entire nation benefits.

The Employee Stock Ownership PlanThe employee stock ownership plan (ESOP)

is one of the most important tools that can beused in the process of capital formation. Notunlike cooperatives, it is the only developmenttool that integrates economic and legal issues.Not unlike cooperatives, it is the only legal toolthat addresses in advance the issue of equi-table distribution of future ownership of thewealth that is being created. Unlike any otherlegal instrument, however, the ESOP is theonly financing tool that alIows for the deduc-tion of principal as well as interest from thetaxable burden of the firm. Congress allows forsuch a unique preferential treatment because,when it is well planned and implemented, theESOP distributes a considerable number ofbenefits to all participants to the plan and tosociety as a whole.

Before looking at these benefits, let us be-come familiar with the mechanics of the planitself. The literature on ESOP is vast and con-tinuously growing; an updated reference list ismaintained by the National Center for Em-ployee Ownership in Oakland, California.

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The Mechanics of the ESOPThe ESOP is a flexible legal instrument that

must be designed to fit the particular needs ofa specific firm. It is essentially a form of tax-qualified stock bonus plan. Thus the ESOP ba-sically is a deferred compensation planestablished for the benefit of all full-time andsome part-time employees. The corporationcontributes financial resources to this trust asa variable percentage of its yearly covered pay-roll. At present this figure is about 25 percentper year. It was the genius of Louis 0. Kelso,its designer, however, not to leave this trustfund in a passive state but to conceive of it asan active entity. Thus was born the leveragedESOP (Kelso and Adler 1958; and Kelso andHetter 1967). Since the trust fund is fully taxexempt, it is the trust that applies for loansfrom financial institutions and repays theloans with the proceeds from the yearly contri-butions to the fund. The assets of the corpora-tion also serve as guarantee of the repaymentof the loan.

The Benefits of the ESOPThe benefits that accrue from an ESOP are

better observed by singling out the benefits toeach participant in the plan.

StockholdersThe stockholders of the corporation benefit

from the creation of capital formation in a taxshelter environment. Certainly there is somedilution of their ownership, but this dilutionrefers to the ownership of future wealth - thatwealth whose creation is assisted by the em-ployees and is pursued under a favorable taxtreatment. It is society as a whole that pays inthe short run through the loss of tax revenues.But society too benefits in the short as well asthe long run.

SocietyThe benefits that accrue to society stem

from three major sources. The wealthier theemployees become, the higher the individualincome taxes they will pay when they with-draw their share of dividends or capital fromthe plan. And the wealthier employees and re-tired persons become, the less need they havefor all sorts of welfare benefits. Thus, theESOP tax deferral of today is compensated bythe reduction in the welfare burden of tomor-row. The tax deduction is a true investment forthe community as a whole. Society will also

benefit from the rather immediate result oflower inflationary and deflationary pressures,because employees are more prone to lowertheir demands for wage increase in periods ofinflation and to tolerate a greater level of wagereduction in periods of deflation.

EmployeesCertainly employees can buy shares of stock

today. But they have generally not done so inthe past and are unlikely to do so in the futurebecause to purchase shares of stock requiresan amount of money that most employees donot have. With ESOPs, the corporation makesits credit status available to its employees, toborrow money from financial institutions. Em-ployees-aided by tax deferments - in essenceuse their future profits to repay the loan andbecome owners of the stock. While at first sightthere is only a shift between future wages andfuture ownership of stock, the changes aremore fundamental than that. With the cer-tainty of legal ownership comes a greater will-ingness to work hard and to see thatco-workers work hard.

Stephen Covey (1989) distinguishes be-tween production (P) and production capacity(PC), encourages building a balance betweenthe two, and then (p. 58) points out, “You canbuy a person’s hand, but you can’t buy hisheart. His heart is where his enthusiasm, hisloyalty is. You can buy his back, but you can’tbuy his brain. That’s where his creativity is,his ingenuity, his resourcefulness.

“PC work is treating employees as volun-teers just as you treat customers as volunteers,because that’s what they are. They volunteerthe best part-their hearts and minds.” Em-ployees who use their hearts and minds aremore likely to observe and improve upon qual-ity standards than employees who work solelyfor a wage. ESOPs are an internal insurancethat quality standards will be the highest pos-sible - from both a financial and a technologi-cal point of view. Is not that the beginning ofwisdom concerning quality assurance? AsFrank Foley (1981), an elder statesman of thefisheries industry used to say, “Quality fish,quality people.”

ACCESS TO FEDERAL CREDITWhile it is true that quality pays, it is also

true that - depending on the position fromwhich one starts and the technology one wantsto use - quality assurance requires variableinvestment sums at the outset. The money will

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be recovered because consumers are ready topay a higher price for seafood of assured qual-ity, but the initial outlay is inevitable (Gorgaand Ronsivalli 1988, pp. 189-192). Where willthe money come from?

The traditional approach is to go to banksand other financial institutions for such funds.Banks and financial institutions then go totheir depositors, pay going market rates of in-terest, and lend the money. This approach hastwo major limitations: the cost is high, and theavailability of funds is generally low.

At times such as the present, such limita-tions are more severe than at other times. Butthey are always present. The question is, Isthere any alternative to the prevailing state ofaffairs?

The alternative is this: rather than goingliterally to collect available savings from de-positors and investors, banks and other finan-cial institutions can go to the ultimate sourceof money, the monetary authority.

In the United States, the monetary author-ity is the Federal Reserve System. The FederalReserve System is the ultimate source ofmoney because it is the administrator of na-tional credit: not personal credit or bank credit,but national credit. We individually create ourown creditworthiness; we administer it and areresponsible for it. So banks - and other finan-cial institutions - are the creators, the admin-istrators, and are responsible for their owncreditworthiness. National credit is somethingdifferent.

National credit is something that is createdby all citizens of a country. All citizens contrib-ute to the increase - or decrease - in its value.It is a common good. For additional character-istics, see Gorga 1991. And since it is a com-mon good, it must be administered for thecommon good. It must be administered for thebenefit of all. It cannot be administered for thebenefit of a few people.

From this essential characteristic stemthree criteria that must be met in the adminis-tration of national credit. These criteria werefirst enunciated in Gorga and Kurland 1987.National credit must be issued (1) for the cre-ation of new wealth only, (2) for the benefit ofall, and (3) at cost.

National credit must be used to foster thecreation of only new real wealth. It is the cre-ation of new wealth that directly or indirectlybenefits all. Therefore, national credit must beissued only for the creation of new wealth. Thiscriterion can also be justified on the basis ofnumerous other factors. If the issuance of

national credit is accompanied by the creationof new real wealth, its creation will not spurinflationary tendencies. By definition, the issu-ance of national credit does stem deflationarytendencies. Hence new money created for thecreation of new real wealth is stable money. Bycontrast, new money created for the purchaseof consumer goods, goods to be hoarded, exist-ing wealth, or simply paper wealth repre-sented by government and corporate equity ordebt is inflationary and hence unstable money.National credit must be issued for the creationof only real wealth.

National credit must be issued to benefit all.Again, there are many factors that justify thedeployment of this criterion. If everyone ben-efits, an array of supreme values is set in mo-tion. Justice prevails. The deleterious impact ofenvy is lessened. The need to satisfy materialnecessities assumes its proper role: it is placedneither too high nor too low on the scale of hu-man requirements. With justice ruling societyand a citizenry exercising a balanced core ofvalues, not only the beneficial forces of themarket are reinforced but even those of democ-racy. When negative forces are in check, posi-tive forces are more liable to manifestthemselves. The benefits of “good government”become widespread. Is not this what we all re-quest from the administration of earthly af-fairs? Once all that is granted, the questionbecomes, How can the use of such a commongood as national credit be administered for thebenefit of all? In a society in which the law issupreme, the answer is surprisingly simple:the legal ownership of the wealth created un-der the wings of national credit must be aswidespread among the citizens as possible. Itcan only be hinted here that, just as there aremany forms of cooperatives, so conceptuallythere is a whole family of ESOPs - such as in-dividual stock ownership plans, consumerstock ownership plans, or general stock owner-ship plans (see Bureau of National Affairs1987, pp. 207-208).

National credit must be issued at cost. TheFederal Reserve System prides itself on addingfrom its operations millions of dollars to thenational treasury every year. While it is pleas-ing to hear that there are federal agencies thatare concerned with the “bottom line,” the mak-ing of profit is not an appropriate function ofgovernment. As a result, national credit shouldbe issued at cost. From the exercise of this cri-terion, it follows that the interest rate to becharged on loans that use national credit - even when a premium is charged to insure

against the risk of default - be in the 2 percentto 3 percent range.

The Legislative AuthorityThe legislative authority to use national

credit along the lines pointed out in the previ-ous paragraphs is already in place. In fact, it ispart of the original legislation instituting theFederal Reserve System. The intent of theframers of this legislation is made explicit inparagraph 2, section 13 of the Federal ReserveAct of 1913, where it is mandated that the Fed-eral Reserve System be empowered to discounteligible industrial, commercial, and agricul-tural paper.

The Political WillThe political will is the necessary ingredient

that is missing for the use of national credit tobecome a common occurrence along the linesindicated above. In a democracy, the politicalwill resides not in the politicians but in thepeople. If the people request that nationalcredit be used in a certain way, it will eventu-ally be used that way. This point is perhapsbest clarified with a brief reference to the his-tory of the Federal Reserve legislation.

A Brief History of the LegislationThe legislation on the Federal Reserve Sys-

tem was a product of the reform movement atthe beginning of this century, and ultimately itwas the outcome of the agrarian movementthat was the hallmark of the second part of thelast century. The agrarian movement had spe-cific needs. The essential need was for short-term credit to tide over the farmers until theharvest.

A particular economic doctrine, the so-calledReal Bills Doctrine, analyzed and codifiedthose needs. But it did not extend the analysisto the needs of society as a whole - an indus-trial society at that. The needs of the industrialsociety vary a great deal and range from theovernight draft to the very long term. All thoseneeds have to be accommodated if the nationalmonetary policy is to be successful. The RealBills Doctrine also placed no limitation on theuse of the funds. Presumably, people could bor-row money from the banking system for thesole purpose o f accumulating supplies in orderto jack their prices up exclusively for personalbenefit. The third major limitation consisted ofthe disregard for the public good also from another point of view, the point of view of legal

ownership of the wealth created with the assis-tance of public funds. There was no concern forenlarging the basis of the ownership of wealthand ultimately there was no concern for thevery health of the market itself. A pyramidalmarket system, in which the ownership ofwealth is concentrated in a few hands, can eas-ily be toppled by manias, panics, and crashes,to borrow Professor Kindleberger’s felicitousphrase.

With such weaknesses inherent in thetheory, when the policy was implemented be-tween 1914 and 1925, the results were un-avoidably disappointing. The use of thediscount window at the Federal Reserve Sys-tem fell into disrepute, and funds from thissource were thereafter only sporadically re-leased (Burstein 1986, pp. 20-22 and 59-60).

There seems to be no reason why the errorsof the past cannot be avoided in the future.Certainly, a new policy cannot be tainted bythe errors of the past.

CONCLUDING COMMENTSFrom the point of view of the consumer, the

quality assurance program is a tool to assurethe consumer of the quality of the product, pur-chased. From the point of view of the producer,the quality assurance program is a tool to as-sure the producer of the financial viability ofthe product that is produced. Thus the loop isclosed; consumers and producers both obtainwhat they want and what they unquestionablyneed.

In the long run, the quality assurance pro-gram is a tool of internal financing, not onlybecause it lowers costs and expenditures forthe firm but also because a product whosequality is assured commands a higher pricethan any comparable product. In the short run,however, the implementation of the quality as-surance program might require considerableoutlays of funds. When considering the techni-cal requirements of the quality assurance pro-gram, one simply wants to obtain all the bestthat the technology can offer. As pointed outabove, there are three major external sourcesof funding that need to be explored. One con-sists of all government programs assisting inthe process of capital formation. The second isthe use of employee stock ownership plans,since such plans are very well received by theconventional financial world today. The thirdis the recourse to the discount window of theFederal Reserve System. All three financialtools deserve to be researched, and if any of

them is found appropriate to the particularneeds of an individual firm - or group offirms - at any particular time, all steps shouldbe taken to adopt it.

REFERENCESBidner, J.B. 1992. Iceland’s success story:

marketing and quality control make thislittle nation a big player in world seafoodproduction. Seafood Business 11(1):44-54.

Bureau of National Affairs. 1987. Employeeownership plans: how 8,000 companies and8,000,000 employees invest in their futures.Rockville, Md.

Burstein, M.L. 1986. Modern monetary theory.New York: St. Martin’s.

Covey, S.R. 1989. The seven habits of highlyeffective people: restoring the characterethic. New York: Simon and Schuster.

Crosby, P.B. 1979. Quality is free: the art ofmaking quality certain. New York: McGraw-Hill.

Foley, F. Quoted in Boston Globe July 15,1981.

Gorga, C. 1991. Bold new directions in politicsand economics. The human economy news-letter 12(l): 3-6,12.

Gorga, C. and N.G. Kurland. 1987. The produc-tivity standard: a true golden standard.Pages 83-86 in Every worker an owner: arevolutionary free enterprise challenge toMarxism. D. M. Kurland, ed. Washington,D.C.: Center for Economic and SocialJustice.

Gorga, C. and L.J. Ronsivalli. 1988. Qualityassurance of seafood. New York: VanNostrand Reinhold.

Kelso, L.O. and M. Adler 1958. The capitalistmanifesto. New York: Random House.

Kelso, L.O. and P. Hetter. 1967. Two-factortheory: the economics of reality. New York:Random House.

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Harold SchildTillamook County Creamery Association, Tillamook, Oregon

The settlers who populated the Tillamook Val-ley between 1855 and 1900 had some uniquechallenges to overcome. There were no roadsfor commerce. All supplies and cash salesmoved by boat. Dairy was the only agriculturaleffort that was viable. Butter was the onlydairy product they knew how to make. Andsporadic transportation caused quality prob-lems with customers.

In 1898, Peter McIntosh came to the valleyfrom Canada to make Cheddar cheese. Hisknowledge of bacteriology and sanitationtaught Tillamook dairy farmers how to make agood quality product that would withstand thevariable delivery schedules.

Early dairy production was by private op-erators in competition with each other, but by1909 many of them were operating as coopera-tives, and Carl Haberlach, a young attorney,convinced ten of these small cheese plants tocontribute $25 each and form a marketing co-operative. The Tillamook County CreameryAssociation was born.

Cheese, bearing the Tillamook brand on therind, was sold throughout the west, but cus-tomers soon recognized a variation in thecheese from different factories and began toexpress their preference, affecting sales.

The most successful cheesemaker, FredChristenson, was selected by Haberlach andapproved by the cooperative’s board to workwith each cheesemaker to improve the qualityand consistency of Cheddar cheeses carryingthe Tillamook brand.

Soon, Christenson and the othercheesemakers recognized that even if every-thing was done properly at the factory, manyvats of cheese were less than desirable becausemilk coming from the farm was variable, fromgood to lousy.

Back to the board again, this time to hire afieldman, Guy Ford, to work with the morethan 800 dairy farmers, many of them milkingonly two or three COWS. Some of the items thatbecame important to the inspector were coolingmilk after night milking, washing milkingbuckets every day, having milking pails tinnedto remove rust, testing for flavors and sedi-ment at the factories, and rejecting milk notmeeting standards

Quality soon began to show up in sales and,as sales improved, so did the price. As the priceinched upward, it was possible to return amodest premium to the dairy farmers. Eco-nomics were established as a quality incentiveby instituting a penalty system for substan-dard production. Many dairy farmers of mar-ginal quality were encouraged to improve theirpractices or turn to other methods of earning aliving.

In the decade between 1940 and 1950, mostdairy farmers were forced to work at construc-tion or lumber mill jobs to help support theirdairies. Quality continued to improve from1960 to 1970 as science taught dairy farmersmore about controlling bacteria. Dairies con-tinued to get larger and more advanced, andmost dairy farmers now devoted all their timeto the farm. Management practices improvedas the grade A fluid milk market became a lu-crative prize for those who could meet themore rigorous facility, equipment, and man-agement requirements. A general attitude inthe industry was that "manufacturing," or“cheese,” milk did not need to meet the samestandards. This was not the feeling atTillamook, where the same level of quality wasexpected for cheese as for fluid milk. Someother cheese manufacturers in the Northwestfailed to recognize that top-quality milk wasessential for the production of top-qualitycheeses. These companies are no longer a forcein the marketplace.

In the 1980s, Tillamook’s board imple-mented an aggressive incentive plan that pro-vided a premium to dairy farmers whoattained a higher level of quality. At that time,the company average for somatic cell count(SCC) in milk was 400,000 per milliliter. Bo-nuses of up to 25 cents per hundred pounds ofmilk were offered to dairy farmers who wouldreduce their SCC count to less than 100,000.Few farmers felt that such a low number wasattainable. Yet, within months, test results in-dicated a significant improvement in herdhealth, with company average results droppingbelow 200,000 and as many as 50 of theTillamook County Creamery Association’sdairy farmers attaining the less than 100,000goal.

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Today, the quality heritage is a major partof Tillamook’s message. We are unique in theclose contact our field staff has with the dairyfarmers. Nearly all of the dairies are locatedwithin a 30-mile radius of the plant, with two-thirds of them less than 10 miles away.

This allows daily contact with any dairyfarmer who experiences quality problems, andit allows the milk to be transported quickly tothe plant for daily processing. Our facility,which operates 365 days a year, processes vir-tually all milk the same day it is produced.

With the emphasis on quality have comesome pleasant benefits. Tillamook products donot use any preservatives for extending shelflife. Vacuum packaging, or the lack of oxygen,is the only mold inhibitor used in storage ofcheese. Heat treating of the milk, but not pas-teurizing it, allows many beneficial enzymes toremain in the cheese, imparting the specialTillamook flavor and body.

All Tillamook cheese is aged over 60 daysbefore final preparation for sale. Quality assur-ance tests at this point, and lactic acid develop-ment, gives double protection frompostpasteurization contamination, which hasbeen the source of illnesses in some cheesesthat are manufactured and sold without properaging.

Lush green pastures, pristine streams, amoderate climate, and isolation from urbanpollution all contribute to the Tillamook mys-tique. Furthermore, with the 1949 opening of

the large plant on Highway 101, north ofTillamook, visitors began asking if they couldview the cheesemaking process. At first,groups were ushered through the plant, but asnumbers swelled, sanitation and safety becamemore of a concern, and a viewing area was con-structed.

Since 1968, interest in this area has grownsteadily. Now more than 800,000 visitors ayear stop by to view production, browse in thegift ship, or indulge themselves with one ofmore than 650,000 ice cream cones served upeach year. This volume of visitors rates as thethird highest in Oregon, according to the Or-egon Department of Transportation.

As potential customers view the actual pro-duction and packaging of Tillamook cheese, themessages of quality and care are reinforced. Anexample of the effectiveness of these messagesis the public acceptance of Tillamook ice creamthroughout the Northwest. As more and morevisitors sampled Tillamook ice cream at theplant, they asked why it was not available inthe grocery stores back home. Even though wehad produced it since 1949, ice cream was soldonly locally until three years ago when we em-barked on a distribution plan for Tillamook icecream that has already placed 6 of the top 10selling flavors of premium ice creams in Or-egon, according to Info Scan, a market salesreporting service. The message is clear: qualityis a product that cannot be oversold.

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Pat ShanahanStrategic Planning and Communications, Seattle, Washington

Consumer concern over seafood safety hasmade quality assurance programs a fact of lifefor the seafood industry. Gone are the dayswhen simply having a quality assurance pro-gram sharpened your product’s competitiveedge. Today, quality assurance programs are anecessary part of doing business. The distin-guishing factor is how you market your qualityassurance program, how you let consumers,the trade, and business partners know howyour program assures them of a safe, high-quality product. Creative, strategic marketingof your quality assurance program can greatlyinfluence the perception of your product and itsperceived value.

To illustrate the state of the art in innova-tive marketing of quality assurance programs,I present case studies of three marketing asso-ciations: the Association of Chilean SalmonFarmers, the Maine Department of Marine Re-sources, and the Alaska Seafood MarketingInstitute. These, along with others, are organi-zations that are breaking new ground in mak-ing the most of their quality assuranceprograms.

ASSOCIATION OF CHILEAN SALMONFARMERS-QUALITY ASSURANCE IN

TODAY’S COMPETITIVE MARKETPLACEWhen the Association of Chilean Salmon

Farmers formed in 1986, it faced a very com-petitive marketplace. The world knew littleabout Chile in general and even less about itsfledgling salmon farming industry. Given thehigh quality of product produced in Europe,primarily by the market leader, Norway, theChileans realized that a successful entry intothe world market depended on guaranteeingthis high quality themselves.

With this in mind, the association set out toensure that all salmon raised by its memberswas harvested, processed, packed, and shippedat the highest level of quality. The associationadopted a code of quality standards and an in-dependent inspection process that rank amongthe most rigorous in the world. This quality

assurance program has been marketed aggres-sively, becoming a “competitive edge” for Chil-ean salmon and contributing to the rapid risein global demand for the Chilean product.Japanese seafood buyers, who are among theworld’s most selective, purchased over 28,000metric tons of Chilean salmon in 1992.

Brief Outline of the Association’s QualityAssurance Program

The association’s quality assurance programis based on a set of rigorous guidelines forplant construction and sanitation, worker hy-giene, equipment specifications and sanitation,and processing standards. The program alsoincludes specific product characteristics foreach species of salmon produced in Chile, alongwith descriptions of the characteristics for eachgrade of product. To give the program realteeth, the association requires that quality con-trol inspectors from independent certifyingagencies supervise all inspections.

The process begins at the point of harvest,where inspectors check the salmon for size,shape, appearance, and overall health accord-ing to the code’s criteria.

Inspectors are also present during process-ing, making sure the fish are headed, gutted,and cleaned under exceedingly sanitary condi-tions. After processing, inspectors grade thefish, rejecting those salmon not meeting theassociation’s standards. Fish that pass inspec-tion are iced and packed for export with theAssociation of Chilean Salmon Farmers’ seal.This seal, the centerpiece of the association’sprogram, is given only to fish that have beenprocessed in a certified plant by an indepen-dent inspector and have been classified as Pre-mium or Grade 1 quality.

The fish are also inspected once they reachthe Santiago airport, before being flown freshto world markets. At this checkpoint, producttemperature and the condition of the ice andpackaging come under the inspector’s scrutiny.

These final inspectors also pay close atten-tion to elapsed processing time - the time that

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has passed from leaving the water to ship-ment. Again, if the fish do not meet the ap-proval of the inspectors, they are not shipped.

In 1992, the association expanded its inspec-tion manual to include regulations for the tech-nical requirements and sanitary conditions ineach salmon processing plant. The manualnow specifies plant code regulations for walland floor coverings, processing tools, clothing,gloves, and masks. The association also devel-oped individual quality standards for each spe-cies of fish raised in Chile.

Each year, the association organizes a sym-posium to review its quality standards. Im-provements are made on the basis of pastexperience and new techniques.

Marketing the ProgramThe association has made its quality assur-

ance program one of the cornerstones of itsstrategic positioning. All elements of its mar-keting program reinforce the quality assurancemessage to educate buyers, consumers, andthe trade.

The quality seal itself serves as the primarymarketing tool. The seal is a visual reminder ofthe quality assurance program and a guaran-tee that the product has met its high stan-dards. As well as appearing on inspectedproduct, the seal has been used as a graphicelement in trade advertising. Trade advertis-ing copy always incorporates the quality assur-ance message. Here is a quote from theassociation’s current trade ad:

In this land of unspoiled beauty, each andevery salmon is hand-raised, painstakinglytended, and processed according to the mostexacting standards in the world.

There’s a difference, too, in the way Chil-ean salmon is packed and shipped, so it ar-rives at its destination as fresh as themoment it left the water.

Public relations is another way the associa-tion gets the word out about its quality assur-ance program. The association’s press kitincludes a two-page release that outlines theinspection program in detail. And all otherpress materials incorporate the quality assur-ance message.

The association’s quarterly newsletter, TheChilean Salmon Farmer’s Almanac, also stra-tegically markets the program to importersand buyers from retail and restaurant chains.Each issue includes an article on the quality or

the safety of the product. Recent headlines in-clude, “Chilean Salmon: A Safe Choice” and“Chile Toughens Already Strict InspectionStandards.”

One of the association’s most successfulmarketing efforts was the January 1992 FoodEditor’s Tour of Chile. The tour aimed to edu-cate consumers and the trade about the qualityassurance program by showing them firsthandhow it works. Food editors from a dozen na-tional consumer broadcast and print media,including Better Homes and Gardens, Woman’sDay, Good Housekeeping, McCall’s, HouseBeautiful, and Ladies Home Journal, partici-pated in the tour. The editors travelled to thesalmon-growing region in the south of Chile tovisit salmon farms and processing plants. Thetour resulted in numerous articles and broad-cast coverage, all stressing the association’squality assurance messages. The tour won a1992 Seafood Business Marketing ExcellenceCertificate of Merit,

By strategically marketing its quality con-trol system, the association has successfullybuilt the reputation of its product in key mar-kets, allowing it to develop from a relativelyunknown producer of farmed salmon in 1986to the second largest producer of farmedsalmon in the world today.

MAINE DEPARTMENT OF MARINERESOURCES:MAINE FRESHGROUNDFISH QUALITY CONTROLPROGRAM--START SMALL AND GROW

The Maine Department of Marine Be-sources’ Maine Fresh Groundfish Quality Con-trol Program developed 10 years ago out of apilot program which had as its goal to developa “Maine identity” for groundfish while re-sponding to consumer quality and health con-cerns. At the time, the state had little in-stateprocessing; instead, whole fish were shipped tothe Boston area where they were sold as "Bos-ton” or “New England” fish.

The department established a set of Stan-dards based on the federal grade A program,which provides for a consistent level of qualityand extends the shelf life of the product. Fishmeeting the criteria received the “Maine Certi-fied” logo. As with the Chileans, the Maine logobecame the cornerstone of all marketing ef-forts. According to a Department of Marine Re-sources representative, studies have shown astrong Iink between the perception of qualityand a seal or stamp. The Maine logo not only

provides this association with quality, butbacks it up. They have built their program byimplementing tough standards, workingclosely with the state’s processors to enlist in-dustry cooperation, and then creativelymarketing these standards nationwide.

"In the Beginning”-Creative marketingto the Supermarket Industry

Maine adopted a marketing program thatwas more narrowly focused than that of theChilean salmon farmers. To introduce theirnew logo, the department developed a Pilotproject targeted to supermarkets. Two proces-sors and two chain supermarkets, Shop andSave and Shaw’s, agreed to participate. Thesupermarkets each sold the Maine label in sixstores in the Portland, Maine, market. The de-partment developed recipe brochures to dis-play near the product in the stores. Clip-ontabs with the logo were also attached to theprice tags in the display case so that consum-ers could immediately identify the Maine certi-fication. The initial pilot program was intendedto run for six months, but after only 14 weeksit had become so successful that both chainsextended it into all of their stores.

Based on the success of the pilot program,the department set up a full-blown supermar-ket campaign, putting their own representa-tives in the stores to help supermarketpersonnel improve sanitation and increaseproduct shelf life. The department helped writeindividual company manuals, developed on-site training programs, and conducted freeseminars if a store agreed to purchase theMaine product exclusively.

As the Maine product made its way intometro New York supermarkets, the depart-ment found their in-person training effortsstrained because of the high turnover of super-market employees. Tbis inspired the depart-ment to create a video retail training programconsisting of four videos: identifying qualityproduct; setting up and sanitizing a cooler;sanitizing, icing, and setting up a full-servicecase; and merchandising product. Since its de-velopment, many companies have purchasedthis program. Through its videos and training

programs, the Maine department quickly es-tablished itself as the expert in quality assur-ance at the supermarket level.

The industry has recognized Maine'sachievements. The Maine program was given atop prize in the Seafood Business MarketingExcellence Awards.

The Alaska Seafood Marketing Institute’s(ASMI) quality control marketing program dif-fers from my first two case studies in that itfocuses on internal marketing - educatingthose involved in the harvesting and process-ing of Alaska seafood.

ASMI has developed species-specific han-dling guidelines for fishermen, tender opera-tors, processors, cold storage facilities, anddistributors, with the major emphasis on fish-ermen and processors. These recommendationsare “sold” through videos, workshops, bro-chures, trade shows, and conferences.

Having enrolled the cooperation of fisher-men in quality assurance, ASMI backsellstheir participation and expertise to seafoodbuyers. As an example, here is a line from arecent ad for Alaska Halibut: “And the qualityis ensured by the experience and expertise ofthe Alaskan fishermen who catch it.”

Currently, ASMI also has an advertisingcampaign in Seafood Leader that aims to edu-cate retailers about quality assurance for theAlaska product. The campaign advertises a se-ries of training videos for retail employees thatfocus on maintaining seafood quality in a retailenvironment.

TEN TIPS FOR MARKETING YOURQUALITY ASSURANCE PROGRAM

The Association of Chilean Salmon Farm-ers, the Maine Department of Marine Re-sources, and the Alaska Seafood MarketingInstitute each offer examples of creative strate-gies for marketing a quality assurance pro-gram. Clearly though, each group has adifferent target market and different market-ing objectives and therefore employs uniquetactics. Some of these you might have foundpotentially applicable to your group-othersnot.

I would like to close by giving some tips thatare generally applicable, what I call my “TenTips for Making the Most of Quality AssuranceMarketing.”

1. Quality assurance is no longer theexception. It’s the rule.

Given the seafood safety issue, especially inthe United States, a good quality assuranceprogram is a necessary part of doing businessin the seafood industry today.

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2. You can't market what you don't have.Make sure that your quality assurance pro-

gram is in place and running well before mar-keting it. False starts make your marketingjob much more difficult.

3. Make sure your team knows the score.Develop and clearly articulate your position

on customer safety and product quality. Then,make sure everyone in your organizationknows about it and subscribes to it.

4. Get a handle on handling complaints.Marketing your quality assurance program

will heighten the expectations of your custom-ers. Be sure you have a response mechanism inplace to handle any complaints that come upquickly and effectively.

5. Start small and grow.If you have a limited marketing budget, use

it to do a few things well. Then expand yourprogram from there.

6. Don’t forget your customer's customer.For real impact, market your program up

and down the distribution chain. If yourbuyer’s customer believes in your quality as-surance program, then that’s added value.

7. Quality assurance doesn’t stop withyou.

Your quality assurance job doesn’t endwhen the product leaves your door. Follow-upto make sure your product is well handled bythose who transport and handle it. And buildinto your marketing plan the time and budgetto educate your customer about how to main-tain the quality of your product.

8. Make your package count.By placing your quality assurance message

directly on the package, you are saying some-thing about what’s inside. Don’t forget to re-peat your quality assurance message in all ofyour marketing communications.

9. Beware of the words “high quality."Everyone uses the words "high quality" and

soon everyone will be touting their latest qual-ity assurance program. You must find ways tocommunicate how your program is different.

10. Tell the world your story.Work with the trade and consumer media to

get the word out about your quality assuranceprogram. These “third-party” endorsementsare invaluable in establishing a favorablereputation for your product.

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