Joint Ministerial Decree
No ( 1909 ), Year 2001
Regarding Regulations and Procedures
Related to Fish and Marine Products Exports
To the European Union Countries
Deputy Prime Minister and Minister of Agriculture and Land Reclamation, Minister of Economy and Foreign Trade,
After reviewing;
Law No 53, issued in 1966 for the issuance of Unified Law for Agriculture, And
Law No 118, issued in 1975 concerning Import and Export, And
And
And
And
And
And
Law No 10, issued in1966 concerning Food Control and regulating its distribution and its executive Ministerial decrees,
Presidential Decree No 187, issued in1984 for the Establishment of the General Organization for Veterinary Services,
Presidential Decree No 106, issued in 2000 to facilitate the Control and Inspection Procedures on Imported and Exported Commodities,
Minister of Health Decree No 880 issued in 1960 concerning the transport of fresh fish,
Minister of Health Decree No 362 issued in 1984 concerning the transport of Frozen Commodities,
Ministerial Decree No 275 issued in 1991 concerning the Executive Regulations of Import and Export Law previously mentioned,
Decided
Article (1): The Catch, Storage, Preparation and Inspection of exported fish to the European Union countries is performed according to the attached system
Article (2): The exporter is temporarily suspended in case of any violation of regulations and procedures included in the attached system until proven not responsible for such violation. The exporter is suspended for a year in case of committing a second violation.
Article (3): The General Organization for Veterinary Services, Ministry of Agriculture and Land Reclamation will supervise the implementation of this system, in this respect it has the power to: One) Present any suggestions to amend procedures included in the attached
system. Two) Prepare a list of Egyptian companies, which abide by the sanitation
regulation and production charts.
Article (4): This decree is published in Al-Wakaaei Al-Massreya Newspaper and is active as of date of its issuance.
Minister of Economy
And
Foreign Trade
Deputy Prime Minister And Minister of Agriculture & Land Reclamation
Dr Youssef Botrous Ghaly
Dr. Youssef Wally
Regulations and Procedures
Related to Fish and Marine Products Exports
To the European Union Countries
1. Definitions:
Fish:
Animals existing in waters and breathing through Gills whether in sweat or sea waters, including fish eggs and excluding aquatic mammals and other aquatic animals.
Fresh Fish Products:
Fish or its parts prepared naturally without any interference by any processing operation for preservation except cooling.
Preserved Fish Products:
Fish which have been preserved by adding preservative materials or by conducting a physiological treatment such as heating or smoking or drying or freezing or canning.
Marine Products:
Include Mollusks, crustaceans and bivalve mollusk.
Fisheries:
Places where fish are bred whether naturally or have been established and\or outlined.
Competent Authority:
The agency that is responsible for, authorized to, has the right to perform control and veterinary review to the preparation, processing and exports operations (General Organization for Veterinary Services-Ministry of Agriculture).
"authorized officer" means any public officer designated by the GOVS to be an officer authorized under Section 2 of this Decree.
"Establishment" means any premises where fishery products are prepared, processed, chilled, frozen, packaged or stored, excluding auction and wholesale markets in which fishery products are only displayed and sold by wholesale, but including any fish processing establishment under the terms of the Fisheries Management and Development Act 1996.
"Fishing vessel" means any vessel designed and equipped for the capture of fish and operated for this purpose, but does not include vessels used exclusively for the transport of fish or fishery products.
"Freezer vessel" means fishing vessel which is equipped for the preservation by freezing of fish and fishery products, which may include packing, but does not include any of the operations conducted by factory vessels.
"Factory vessel" means any vessel on which fishery products undergo one or more of the following operations followed by packaging, filleting, slicing, skinning, mincing, freezing, or processing, but excludes any fishing vessels on which only freezing of fish (whole or with gills or guts removed) and shrimp (head- on or head-off) is carried out.
"fishery product" means any cold blooded aquatic animal, or part or product derived therefrom, intended for food for human consumption , and includes any fish, crustacean, mollusc, echinoderm, holothurian, or aquatic reptile, but does not include live animals (excluding shellfish).
"aquaculture" means managed production in artificial enclosures of fish species which are used for human consumption, and includes the production of intermediate stages of the life cycle including eggs and larval stages. It does not include the holding of live fish for short periods for the purpose of collecting for market or for purification.
"compound feed" means a manufactured animal feedstuff used for feeding to fish, which contains two or more ingredients blended by the feed producer
"extensive aquaculture" means aquaculture which takes place with limited or no inputs in terms of feed, fertiliser and other interventions, relying mainly on natural productivity for growth.
"diseased fish" means a fish on or in which pathological changes or other abnormalities are apparent.
"disinfection" means the application of hygienically satisfactory physical and/or chemical agents and processes to cleaned surfaces, with the intention of eliminating or reducing the number of microorganisms to a level that will not lead to harmful contamination of human food.
"veterinary drug means any substance applied or administered to any food producing animal whether used for therapeutic, prophylactic or diagnostic purposes or for modification of physiological functions or behaviour.
"withdrawal time" is the period of time between the administration of a veterinary drug to fish, or exposure of fish to a chemical, and harvesting of the fish to ensure that the concentration of the drug or chemical in the edible flesh of the fish complies with the maximum permitted concentration of the drug or chemical in fish for human consumption.
"Batch" of fishery products means an amount of harvested fish or molluscan shellfish of the same species produced at the same location at the same time.
"Frog's legs" means the back part of the body divided by a transversal cut behind the front limbs, eviscerated and skinned of members of the genus Rana spp. (family Ranidae) presented fresh, frozen or processed.
"Fresh water fisheries" includes fisheries undertaken within the limits of coastal lagoons and lakes
Provisions for control and inspection of health conditions of production Approval of establishments and factory vessels exporting fishery products
•
2 Provision for control and inspection of health
conditions of production 2.1 Approval of establishments and factory vessels exporting products
1. (1) No shore-based establishment may be used for the storage orpackaging of fishery products intended for export except under an accordance with an approval granted under this Decree.
(2) No factory vessel may be used for the storage, processing of fishery products intended for export except under and in accordance with approval granted under this Decree.
(3)An approval granted in accordance with subsections (1) and in respect of an establishment or factory vessel will authorise that establishment or vessel to store, process or package fishery products intended for export for a six months period and for such products and processes as may be specified in the approval.
(4)Health certificates for export to the EU will only be awarded lvalve mollusks which are consigned for export from an approved dispatch centre or approved purification centre
2.2 Approval conditions
(1) Every establishment or factory vessel required under Decree to be awarded an approval shall be subject to any general or specific operation and management requirements which are described in this Decree:
2.3. Suspension and Cancellation of Approval
1 .Any approval granted in accordance with Section 1 of this Decree must be suspended or cancelled at any time and without notice by the written order of the Board of the GOVS:
(a)where an establishment or processing vessel has been used in contravention of the this decree or any regulations made thereunder or in contravention of the
conditions of the approval
(b)where such action is deemed necessary or expedient for ensuring the safety of
exported fishery products
2.4 Fees
(1)There shall be payable in respect of every application for an approval
granted under Section 1 an appropriate fee as may be prescribed by the GOVS.
(2)The schedule of fees prescribed by the GOVS will be published from time
to time in the Gazette.
2.5 Provisions for Enforcement
2.5.1Authorised officers
1(1) The GOVS may authorise any public officer to act as an authorised officer under this Decree.
(2) The GOVS shall issue to every person authorised to act as an authorised officer a certificate of his authority.
2.5.2Powers of authorised officers
1. (1) An authorised officer may without a warrant -
(a)at any reasonable hour or whenever work is in progress in any establishment or
factory vessel in which fishery products are believed to be stored, processed or
packaged, enter and search that establishment or factory vessel for the purposes of
determining the existence, nature and extent of any trade or business in fishery products.
(b)examine any fishery product in any establishment or factory vessels to which he
believes this Decree applies, take samples thereof and examine anything which he
believes is used or capable of being used for the preparation of any fishery product
(c)stop search or detain any vehicle, vessel or aircraft in which he believes that any
fishery product to which this Decree applies is conveyed, examine the fishery product
and take samples of it;
(d)open and examine any receptacle or package which he believes contains any fishery
product to which this Decree applies, examine the article and take samples of it;
(e)call for any books, documents or other records which h? believes contain any
information relevant to the enforcement of this Decree with respect to any fishery
product, make copies thereof and take extracts from it;
(f)seize and detain for such time as may be necessary any fishery product by means of,
or in relation to which, he believes this Decree, or the conditions of an approval issued
under this Decree, have been contravened
(2)An authorised officer shall release any fishery product seized by him under
subsection (1) where he is satisfied that the provisions of this Decree in relation to the
fishery product have been complied with or where he is satisfied that product is not
destined for export.
(3)An authorised officer shall in the exercise of his powers under subsection (1) if
required by any person affected thereby, produce his certificate of authority issued to him
under Section 7(2).
(4)The owner or occupier or person in charge of any establishment or the master of any
factory vessel entered into by an authorised officer pursuant to subsection (1) or any
employee found therein or any person who when requested to give information or any
assistance to an authorised officer,
(a)fails to give the information or assistance reasonably requested or,
(b)knowingly makes any statement which he knows or believes to be false or
does not believe to be true
is guilty of an offence.
6
I
(5)Any person who wilfully obstructs an authorised officer in the execution of his
functions under this Decree is guilty of an offence.
(6)Any person who without the written permission of an authorised officer, removes,
alters or interferes in any way with any fishery product seized under this Decree is guilty
of an offence.
2.6 Appeals
1. (l)Any person aggrieved by a decision of an inspector in relation to export approvals or approvals, or in relation to certification of individual batches of fishery products may appeal to the Chairman of the GO VS.
(2)The Chairman will investigate the appeal within 30 days and will provide a written decision, with reasoned arguments for his decision.
3 HACCP and own checks
3.1Staffing for food safety management
A person should be appointed with the responsibility of managing and implementing food safety systems within the establishment.
This manager should be a person of suitable qualifications for the post, and should have a broad experience in fish processing, quality control and quality evaluation techniques
The quality control manager will have the following responsibilities.
a)to ensure compliance with the requirements of this Decree
b)to communicate with senior management regarding the need for
any works or changes of practice which may be necessary to maintain or improve the
quality of the finished product.
c)to accompany inspectors from state agencies when they visit the
plant, and to put into effect any recommendations which they make.
to implement a quality control program based on the analyses and tests specified in Section 9 of this Decree
Sufficient quality control staff should be employed to ensure the smooth running of the quality control function.
3.2Laboratory
A laboratory should be prided at each establishment, which should comprise of a room(s) of sufficient size to undertake all the quality analyses specified.
The laboratory should be provided with sufficient work surfaces and tables to permit the laboratory to function normally without crowding of staff or equipment.
The floor and walls of the quality control laboratory should be smooth, impermeable and easy to clean.
The laboratory should possess suitable facilities for the storage of equipment and reagents.
The laboratory should be provided with an adequate supply of hot and cold water.
The laboratory should be provided with a sink of sufficient size for the washing of
equipment. If
necessary, a separate sink should be provided for the defrosting of fish.
The laboratory should be well ventilated with a suitable forced extraction fan, in order to prevent the accumulation of gases emanating from the chemical analysis offish.
The laboratory should be well illuminated with daylight and fluorescent strip lighting.
3.3Laboratory Equipment and Materials
Suitable equipment and materials should be provided for the carrying out of the following tests and analyses.
•Temperature measurement
•Weighing
•free available chlorine content of water
•Microbiological contamination (including faecal indicators) of the surfaces of
tables and equipment in the plant
•Sensory evaluation of raw material and final product
•Separation and identification of extraneous material
3.4Hazard Analysis and Critical Control Points
All export establishments must introduce and implement a system of Hazard Analysis and Critical Control Point (HACCP) for each product and each species subject to export approval. The principles of the system to be applied are as follows:
•Identification of hazards, analysis of risks and determination of control measures
•Identification of critical points
•Establishment of critical limits for each critical point
•Establishment of monitoring and checking procedures
•Establishment of corrective actions, and conditions in which they are to be applied
•Establishment of verification and review procedures
•Establishment of documentation concerning all procedures and records
The written HACCP plan(s) must be submitted to GO VS.
Written records of measurements made under the plan, and any corrective actions taken, must be held on file by the establishment and be available for inspection by an authorised officer.
3.5Water Analysis
The quality of the water which is used in the plant should be tested on a daily basis. Samples should be taken at the point of use and the following parameters analyzed for compliance with the standards expressed in Section 9.
-organoleptic quality
-free chlorine and combined chlorine residuals
-PH
If water from different sources is used in the same plant, the tests should be repeated for each source.
At least once every week, water samples from each source should be submitted for a microbiological analysis, to ensure that there is no contamination of the water supply.
3.6Raw Material
On arrival at the plant the internal temperature of each batch should be measured. The average internal temperature of frozen raw material should be below 10(C.
On arrival at the plant samples offish should be selected from each batch for organoleptic analysis of smell and appearance of raw fish, and the flavour of the cooked flesh.
The quality control manager should indicate his approval of the batch, based on the results of the above tests. He or she should sign an inspection form and assign a lot code to the fish before the commencement of processing.
9
3.7Process Control
Quality control staff should regularly observe the processing of the fish in order to ensure that the requirements of this code are complied with, particularly those of Section 8.
Quality control staff should ensure that fish does not remain exposed on the tables during stoppages in the process.
Quality control staff should ensure that the correct lot code is applied to the finished product.
3.8Hygiene Control
Quality control staff should ensure that all persons entering the plant comply with the relevant provisions of Section 8 of this Decree.
Quality control staff should ensure that the cleaning of the plant and equipment is carried out in such a way, and as frequently as necessary, to maintain a high level of hygiene.
A cleaning and sanitizing program should be specifically written covering the disassembly, cleaning and disinfection of all areas in which fish is handled and equipment, tables, fish boxes, tools, and other materials with which fish comes into contact.
The plan should specify a suitable methodology and frequency of cleaning and identify the individuals responsible for each component.
Check lists which reflect the plan should be maintained by the Quality Control Manager to ensure that the cleaning schedule is met.
A copy of the program and completed check lists should be available to inspectors during inspections of the plant.
Each week, or more frequently if necessary, a microbiological analysis (total plate count or equivalent) should be made of work surfaces, fish boxes and equipment which comes into contact with fish, in order to test the efficiency of the plant cleaning and disinfection routine.
3.9Data Storage
All the results of the analysis and tests mentioned in this section should be recorded on specially designed forms.
All the completed forms containing data which applies to each production batch code should be stored in a permanent filing system.