Chapter: Facilities, Equipment and Design
Section: F.A.2 Building Interior
Sub-Section: General

Elements

The regulatory requirements contained in this guideline will be met when:

F.A.2 (01) No room or space used or intended to be used as a dwelling forms part of or opens directly into the fish processing plant. (Risk Ranking: Medium)

F.A.2 (02) The fish processing plant is designed, constructed and equipped in a manner that minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials during processing, packaging, labelling, handling, shipping, receiving and storage; and allows good manufacturing practices to be followed. (Risk Ranking: Medium)

F.A.2 (03) The fish processing plant is designed, constructed and equipped to allow for incompatible activities to be done at different times and/or in separate areas. (Risk Ranking: High)

F.A.2 (04) The fish processing plant is designed, constructed and equipped to allow for and to withstand repeated cleaning and sanitizing. (Risk Ranking: High)

F.A.2 (05) The fish processing plant is constructed of materials that are suitable for their intended purpose and are unlikely to contaminate fish products, ingredients, labelling materials and packaging materials. (Risk Ranking: Medium)

F.A.2 (06) The fish processing plant is equipped with fixed or portable lighting that provides adequate intensity to facilitate the hygienic operation of the plant and the hygienic processing, packaging, labelling, handling and storing of fish products, ingredients, labelling materials and packaging materials; and the lighting does not distort the colour or other appearance of fish products or ingredients. (Risk Ranking: Medium)

F.A.2 (07) Light fixtures and other light sources are protected in a manner that prevents contamination of fish products, ingredients, labelling materials and packaging materials. (Risk Ranking: Low)

F.A.2 (08) The fish processing plant is designed, constructed and equipped in a manner that provides heating, cooling and ventilation; plumbing systems are adequate to meet the requirements of the activities carried out at the plant and are designed and constructed to ensure air flows in a manner that does not contaminate fish products. (Risk Ranking: Medium)

F.A.2 (09) All sinks and drains are properly equipped and maintained to minimize the risk of contamination of the plant. (Risk Ranking: Medium)

F.A.2 (10) There is an effective system for effluent removal and disposal; the system prevents the accumulation of solids and the pooling of liquids and minimizes the risk of contamination of the fish processing plant, its equipment, utensils and potable water system and of any fish products ingredients and labelling materials and packaging materials. (Risk Ranking: High)

F.A.2 (11) There is a separate area(s) equipped with refrigeration or freezing facilities for the storage of fish products that require refrigeration or freezing. (Risk Ranking: High)

Rationale

General building interior requirements

A fish processing plant must be designed, constructed and equipped in a manner that:

  • allows for good manufacturing practices to be followed,
  • allows the separation of incompatible activities, and
  • minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials.

The plant must be designed and constructed to minimize the risk of contamination using suitable materials that are easy to clean and sanitize, and that allow for and withstand repeated cleaning and sanitizing.

Construction factors

Plant construction and the design of internal structures (floors, walls, windows, doors etc.), as well as the materials used, can significantly impact food safety. Inadequate plant design or inappropriate building materials can lead to problems such as peeling paint, rust, pitted surfaces, cracks, and crevices. These issues can cause food and debris to build-up on surfaces, which are hard to clean, and lead to contamination and/or growth of microorganisms and biofilms, which are very difficult to remove.

It is important that all structures and areas in a food plant are cleanable. The materials used in a fish processing plant should be hard, smooth, and corrosion-resistant to facilitate repeated cleaning and sanitizing, and the production of safe fish products.

Porous or pitted surfaces, such as wood, are not fully cleanable and may provide harborage for microorganisms despite repeated cleaning.

Location of exterior doors

An important construction factor is the entrance and exit locations because they directly impact the flow and movement of people and product within the fish processing plant. Their placement plays an important role in maintaining hygienic operations and they should be strategically located to minimize the risk of contamination of fish products.

Doors leading to the outside of the plant should not open directly into areas where fish products, ingredients, packaging materials and labelling materials may become contaminated. The exception is for emergency exits and doors located in the shipping/receiving area that are intended for shipping and receiving activities. Emergency exits should be properly marked and used only in emergency situations.

Employees should use a separate entrance from where products are received/shipped or processed. If the employee entrance is through a retail area, fish products in that area should be protected to minimize the risk of contamination (for example, by packaging).

Dwellings (homes)

Direct access from a home/living space into a fish processing plant can present a risk of cross-contamination. Rooms or areas of the plant must not be used as a living space. If a premises contains both a fish processing plant and a home, the two must be separated so that there is no direct access from the home to any part or area of the plant.

Examples of such access points may include:

  • doors
  • windows
  • stairs
  • elevators
  • loading or unloading areas
  • passageways, etc.

Incompatible activities

Fish processing plants must be constructed, designed and equipped to allow for incompatible activities to occur at different times and/or in separate areas. To minimize the risk of contamination, plants must have enough rooms or areas to accommodate this separation when time separation is not an option. Ideally, plants should have physically separate areas, work surfaces and equipment for handling non-ready-to-eat (RTE) and ready-to-eat fish products. If this is not feasible, non-RTE and RTE products must be processed at different times, and with full sanitation procedures between activities.

Drainage and sewage systems

Drainage and sewage systems of a fish processing plant must be designed to effectively remove and dispose of effluent (e.g. wastewater, sewage) and prevent the accumulation of solids and pooling liquids. Wastewater is water that has been used within a plant for purposes such as washing, flushing, processing, etc. Systems designed to remove and dispose of wastewater and sewage must minimize the risk of contamination of the plant or the plant’s equipment, utensils, products, materials and potable water supply.

All sinks and drains should be equipped and maintained in a manner that minimizes the risk of odours and fumes from entering areas where fish products are processed, handled, packaged, labelled, stored, shipped or received. Floor drains should have a trap to prevent gases from entering the fish processing plant. Drain grates and screens should be regularly cleaned and inspected. This is particularly important as moisture and organic matter in drains provide good growing conditions for Listeria monocytogenes.

Pooling water may also encourage the growth of Listeria monocytogenes and other microorganisms; therefore, floors should always slope toward drain inlets. For best drainage, drain pipes should be sloped at least 2 cm per metre and have a minimum inner diameter of 10 cm. It is recommended that drain inlets should be 30 cm × 30 cm with a minimum 30% free area and one drain inlet should be provided for each 40 m2 of floor space. Operators are encouraged to seek building advice from professionals.

Some fish processing plants are located in pre-existing structures where drains are not present and cannot be installed (for example, in shipping and receiving areas). In these cases, the operator would be required to effectively manage wastewater using an alternate method to facilitate proper sanitation.

Catch basins, grease traps and interceptors

Catch basins, grease traps and interceptors are devices that remove solid materials and fats from fluid waste. The solid material and fat in catch basins, grease traps and interceptors should be removed regularly to limit microbial growth and odour issues.

Catch basins, grease traps and interceptors should be located in an area of the fish processing plant where fish products are not handled, stored, processed, packaged, labelled, shipped or received. If a catch basin, grease trap or interceptor is located in one of these areas, cleaning should occur outside of production hours so that fish products are not present during cleaning. After these devices are cleaned out, the entire area should be cleaned and sanitized before it is used for handling, storing, processing, packaging, labelling, shipping or receiving fish products.

Lighting

Lighting is an important factor in fish processing plants because it allows inspection staff and plant employees to perform their duties effectively and safely. Fish processing plants must have fixed or portable lighting that is adequate in intensity to facilitate the hygienic operations of the plant. Common lighting standards are 220 lux where fish products are processed, packaged or labelled and 110 lux in other areas of the fish processing plant.

Attention should be given to the source and direction of lighting to avoid glare and to prevent distortion in colour and appearance of fish products and ingredients.

Light fixtures and other light sources must be protected in such a way that does not cause food contamination in the event of breakage (e.g. shatterproof). Light sources such as portable lighting, incandescent bulbs or fluorescent tubes and their covers may become a source of physical contamination if the bulb or glass cover is damaged or broken. As a best practice, operators should have a written glass policy that outlines procedures to deal with broken bulbs or glass that result in a contaminated plant environment or fish product.

All light fixtures and other light sources must be cleanable. Light fixtures that have accumulated dust, debris or other types of contamination could transfer these hazards to fish products, ingredients, packaging materials or labelling materials.

Heating, cooling, ventilation and plumbing systems

A fish processing plant must have heating, cooling, ventilation and plumbing systems that are adequate to meet the requirements for the activities carried out in the plant.

Heating, cooling and ventilation systems, when properly designed, installed and maintained, work together to manage air quality and facilitate the hygienic operation of the plant. Proper airflow can prevent condensation in high-humidity areas and the transmission of airborne contaminants.

Some activities and equipment in the plant may produce excess odour or moisture and require direct venting to the outside; such as smokehouses, smokehouse areas, and equipment that generates steam. The plant’s heating and cooling system should maintain appropriate temperatures for the activities carried out.

To reduce airborne contamination, air should flow from cleaner areas of the fish plant to less clean areas. Positive and negative air pressure can be used to control air flow and mitigate airborne contamination in a plant. Air pressure in a room under positive pressure is higher than outside so contaminants are kept out. This means if a door is opened in a room under positive air pressure, air will flow out of that room and air from a less clean area cannot come in. Therefore, the fish products in the room with positive air pressure are protected from airborne contamination.

The air pressure in a room under negative pressure is lower than outside so that contamination from the room does not flow out into surrounding areas. To achieve a negative pressure environment, the ventilation system must be designed to remove more air from the room than air allowed into the room.

Proper location of air intakes and exhaust fans, and use of effective filters are essential in order to prevent and mitigate the risk of airborne contaminants. Operators should test the air flow in all areas of the plant to ensure air moves in the opposite direction of product flow.

The plumbing system must be designed and constructed in a manner that protects the potable water system from contamination and provides the plant with a supply of hot and cold potable water at all times. For more information on water supply and use of water, refer to the “Water” FPG.

Refrigeration and freezing facilities

Some fish products must be stored at appropriate temperatures to limit microbial growth and food safety risks. Fish processing plants are required to have separate areas equipped with refrigeration and freezing facilities for storage of fish products that require refrigeration or freezing. These facilities should ensure enough space for adequate air circulation that allows for appropriate temperatures to be reached throughout the area. Design factors, such as floor and wall racks, may also facilitate air circulation and rapid chilling.

Regulatory references

Food Safety and Quality Act, 2001; O. Reg. 465/19 s. 16 (1) (a) (c)(d)(e)(g)(h),17,18, 24, 35(a)

    1. A fish processing plant must be designed, constructed and equipped in a manner that,
      1. minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials during processing, packaging, labelling, handling, shipping, receiving and storage, as the case may be;
      1. allows for incompatible activities to be done at different times or in separate areas;
      2. allows good manufacturing practices to be followed;
      3. allows for and withstands repeated cleaning and sanitizing;
      1. provides heating, cooling, ventilation and plumbing systems that are adequate to meet the requirements of the activities carried out at the plant; and
      2. allows a fish processing operation to be operated in compliance with this Regulation.
    2. A room or space used or intended to be used as a dwelling must not form part of or open directly into a fish processing plant.
    3. A fish processing plant must be constructed of materials that are suitable for their intended purpose and are unlikely to contaminate fish products, ingredients, labelling materials and packaging materials.
    1. A fish processing plant must have an effective system for effluent removal and disposal.
    2. The system for effluent removal must effectively prevent accumulation of solids and the pooling of liquids.
    3. The system for effluent removal must minimize the risk of contamination of the fish processing plant, its equipment, utensils and potable water system and of any fish products, ingredients, labelling materials and packaging materials.
    4. All sinks and drains in a fish processing plant must be properly equipped and maintained to minimize the risk of contamination of the plant.
  3. A fish processing plant must be equipped with fixed or portable sources of lighting that,
    1. are adequate in intensity to facilitate the hygienic operation of the plant and the hygienic processing, packaging, labelling, handling and storing of fish products, ingredients, labelling materials and packaging materials;
    2. are protected in such a way as to prevent contamination of fish products, ingredients, labelling materials and packaging materials; and
    3. do not distort the colour or other appearance of fish products or ingredients.
  1. If there are fish products that are required to be refrigerated or frozen, the fish processing plant must have a separate area equipped with refrigeration and freezing facilities for the storage of those products.
  1. The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that every area of a fish processing plant used by the operation is operated and maintained in a manner that,
    1. facilitates the hygienic processing, packaging, labelling, handling, shipping, receiving and storing of fish products, ingredients, labelling materials and packaging materials