Chapter: Operations and Documentation
Section: Process Controls
Sub-section: F.B.14.16 Pickling and Acidifying

Elements

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

F.B.14.16 (01) Pickling methods and parameters are suitable for the type of fish product to control or mitigate microbial growth, or other contamination. (Risk Ranking: Medium)

Rationale

Pickling (also called acidification) is a preservation method for fish products. Pickling involves reducing the pH of the fish product, and can be achieved by:

  • immersion of the product in an acidic solution (acidulant), or
  • immersion of the product in a salt brine prior to immersion in an acidic solution to raise the salt content and to lower pH.

Fish products that may be pickled include whole fish or parts of fish, such as pickled herring, pickled pike, and other fish products stored in a pickling solution.

Parasites can survive when processed fish products do not receive a heat lethality treatment, such as during drying, pickling, salting, fermenting etc. Ready-to-eat (RTE) pickled products that have not received a heat lethality treatment must have other controls for parasites (e.g. freezing), as pickling may reduce the parasite hazard in a fish product, but they do not eliminate it or minimize it to an acceptable level (Refer to FPG Process Controls – Parasite Control).

Lowering the product pH slows microbial growth and toxin formation; however, pickling alone does not destroy microorganisms such as Clostridium botulinum or their toxins. Thus, other processes such as salting are usually done in combination with acidification to control pathogens.

For example:

  • there is at least 50% acid (vinegar, citrus or other acidulant) in the pickling solution,
  • the pickling solution has a pH 4.6 or less,
  • salting and pickling processes take place under refrigeration (at or below 4 degrees Celsius) to control microbial growth.

The process control procedures for pickled fish products should contain the following technical process information:

Best practices include:

  • processing a single species of fish within a lot,
  • maintaining a uniform size, shape and thickness of pieces to be pickled.

Refer to FPG Process Controls – Final Product Controls for refrigerated RTE fish products that have been pickled or acidified and have not been subjected to a heat lethality treatment. These controls are for pathogen control, including Clostridium botulinum and Listeria monocytogenes.

For additional Clostridium botulinum control in refrigerated pickled products a water phase salt (WPS) level of 5.0% or greater could be used (Refer to FPG Process Controls – Salting).

If pickled products are not refrigerated, but are shelf-stable, they are ‘shelf-stable acidified low-acid foods’. Fish processing operations must submit to, and obtain approval from, the Food Safety Inspection Delivery Branch for any processes or procedures that do not follow examples provided in relevant FPGs (Refer to FPG Process Controls – Alternative, new, novel or unique process controls).

Other acidified ingredients

In some raw RTE products (e.g. sushi containing raw fish), special care must be taken in preparation of the rice and pasta used. Acidification of the rice or pasta is a method used to inhibit the growth of pathogenic bacteria and to control bacterial spores that can grow to be toxic.

Best practices include:

  • keeping the cooked rice above 60 degrees Celsius before adding a vinegar solution,
  • adequate and uniform acidification of the rice with a vinegar solution to achieve a pH of 4.6 or less,
  • ensure proper temperature control of the final fish product (Refer to FPG – Handling and Storage).

Regulatory References

Food Safety and Quality Act, 2001; O. Reg. 465/19 s. 5 (1)(2), 43 (1)(4), 51, 52

  1. (1) No operator, employee or contractor of a fish processing operation in respect of which a licence is required under this Regulation shall sell, offer for sale, hold in possession for sale, transport or distribute any fish product processed, packaged, labelled, stored or handled at a fish processing plant that is intended for human consumption if the fish product is contaminated.

    (2) The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that no employee or contractor of the operation sells, offers for sale, holds in possession for sale, transports or distributes any fish product described in subsection (1).

  1. (1) The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that fish products and ingredients are kept at a temperature and humidity that keeps them safe during processing, packaging, labelling, storing and handling.

    (4) The operator shall ensure that the temperature and humidity of every room in the fish processing plant used by the operation where fish products are received, processed, packaged, labelled, shipped, stored or handled are controlled to prevent the contamination of fish products, ingredients, labelling materials and packaging materials.

  1. (1) The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that written process control procedures are developed, implemented and monitored to effectively identify any risk of contamination of fish products, ingredients, labelling materials and packaging materials and to prevent, eliminate or minimize any identified risk.

    (2) The operator shall ensure that at the time the process control procedures referred to in subsection (1) are performed and monitored, a record is created that includes,

    1. the date the procedure was performed and monitored;
    2. the results of the monitoring, including any deviations from the process control procedures; and
    3. the actions taken in response to any deviations from the process control procedures, including disposing of the fish product or taking measures to produce a safe fish product.

    (3) The operator shall ensure that the process control procedures referred to in subsection (1),

    1. are reviewed as needed in order to,
      1. evaluate whether the procedures are being properly implemented, and
      2. verify the effectiveness of the implemented procedures with respect to producing a safe fish product; and
    2. are updated as needed.

    (4) The operator shall ensure that at the time a review referred to in clause (3) (a) is undertaken, a record is created that includes,

    1. the date the review was performed; and
    2. the results of the review.

    (5) The operator shall ensure that every record created under this section,

    1. is kept for at least one year from the date the record is created; and
    2. is readily accessible.
  2. The operator of a fish processing operation in respect of which a licence is required under this Regulation shall ensure that any regulatable activities engaged in by the operation are performed in a manner that minimizes the risk of contamination of fish products, ingredients, labelling materials and packaging materials and produces fish products that are safe.