However, the application of these quality concepts and systems to the food and fish industry requires demystification and adaptation to take into account two major specifications of this industry. Fish is a perishable commodity and quality defects can have public health repercussions. Therefore, quality systems need to be mandatory, through food legislation, with the responsibility for the protection of consumer health and fair trade practices vested with the Government.
However, successful implementation of such mandatory fish quality systems requires the complementary involvement of the four major stakeholders: the fishery industry, the control authority, the support institutions and the consumer and consumer advocate groups. It entails mandatory adherence by the industry to good hygienic and manufacturing practices (GHP/GMP), and the implementation of a HACCP program.
FAO has committed significant resources to build capacity in developing countries through training and technical assistance and many exporting developing countries are capable now of meeting the HACCP-based safety and quality requirements of the international markets. This activity will continue to represent a major output of FAO programme of assistance.
Although HACCP is accepted worldwide as the best cost-effective system for quality and safety assurance and has been made mandatory in many countries, differences in the depth and ways of its practical implementation exist. These differences entail questions such as:
- Should HACCP address fish safety (USA) only or safety and spoilage (European Union)?
- What is the clear demarcation between GHP/GMP and HACCP?
- Should the competent authority assist the industry in developing HACCP programs or should it confine its role to monitoring and verification?
- Is HACCP always needed regardless of the product and process?
- In international trade, who should be responsible for verification of HACCP manuals? Is it the importer, the exporter, the importing competent authority, the exporting competent authority, a third party?
- What is the role of the precautionary principle within the framework of risk analysis
- How can we achieve common understanding of equivalency and what are the recognition tools?
Complete answers to all these questions are still debated in international fora and organizations. Unfortunately, national economic considerations and economic protection reflexes keep impeding on this work.
Also, it is believed that comprehensive implementation of HACCP in the fish industry should remove the need for end-product sampling and inspection. Unfortunately, this is not the case yet and significant end-product control is still carried out cross borders. Here again, there is no international agreement on the frequency of these controls and the product standards that should be applied. For example, only one European microbiological standard has been developed in 1993 for cooked crustaceans and shellfish. For all the other fish products, member countries of the EU apply their national standards that differ from one country to the other. It is hoped that this problem can be alleviated by the use of the risk analysis for developing scientifically based standards. Here again, developing countries are at a disadvantage because of insufficient capacity and funds.