Smoked Fish: Storage Conditions

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The purpose of this information is to advise all firms that manufacture, distribute or retail smoked fish products that are sealed to exclude air of the requirements of Division B.21.025 of the Food and Drug Regulations. Packages that are sealed to exclude air include, but are not restricted to, vacuum packages, modified atmosphere pouches, plastic bags with twist closures, plastic film overwrapping, Styrofoam trays overwrapped with plastic film or any other packaging that does not permit free exchange of oxygen with all portions of the contents. Smoked fish in packages that are sealed to exclude air and without any other means of preservation must be kept frozen. [underlining added]

Regulation B.21.025 is designed to ensure the safety of smoked fish products distributed and sold in Canada. It was established in response to botulism food poisoning incidents resulting from temperature abuse of vacuum packaged whole smoked fish. The bacteria that caused these outbreaks was Clostridium botulinum, type E which is prevalent in marine environments and therefore present in many fish. This organism is of particular public health concern because under anaerobic (oxygen free) conditions it can grow and produce toxin at refrigeration temperatures without evidence of food spoilage.

Division B.21.025 of the Food and Drug Regulations prohibit the sale of marine and fresh water animal or animal products that are smoked (or to which liquid smoke has been added) if they are packaged in a container that is sealed to exclude air unless the following conditions are met:

  1. the container has been heat processed after sealing at the temperature and for a time sufficient to destroy all spores of the species Clostridium botulinum, or
  2. the content of the container contain not less than nine percent salt, or
  3. the contents of the container are customarily cooked before eating, or
  4. the contents of the container are frozen and the principal display panel of the label of the container carries the statement "Keep Frozen Prior to Use" in the same size type used for the common name of the contents of the container.

For the contents of the container to be frozen, they must undergo a phase change, i.e. they must be congealed, solid or rigid because of the cold. The temperature of frozen product must be maintained constantly at less than -18°C (0°F) however shelf life will be enhanced if kept at -26°C (- 15°F) or colder.

Packaging materials are available that have adequate oxygen transfer to prevent the development of an anaerobic environment within a package. Containers or packages made of materials with an oxygen permeability equal to or greater than 2,000 cm3/m2/24 hours at 24°C and 1 atmosphere are not considered to be sealed to exclude air. These packages will be permitted for use with refrigerated product stored at C or less. Product should have a labelled shelf life not to exceed 14 days from the date of packaging. Processors and retailers using such sealed containers or films should have a record of the type of film used and its permeability. This should be available to inspectors at the retail level. This permeability is for a single overwrap of the film. If overwrap is double or more, data should be available to show that the minimum permeability is being met. Styrofoam trays with a single wrap are permitted if the total permeability of the final package meets the minimum specifications. Care should be taken to avoid stacking the packages in a manner that will inhibit the oxygen permeability.

Products not in compliance that remain for sale in Canada will be subject to enforcement action as a means to protect the Canadian public from this health concern. Additional action against offending companies will be taken as deemed necessary.

Originally issued November 17, 1993 (Letter to Industry)

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