India: Microbiological Standards for Fish

On 13 November 2015, India’s food regulator, FSSAI, proposed new microbiological standards for fish and fish products. Microbiological standards are currently covered under Appendix B of Food Safety and Standards (Food Products Standards and Food Additives) Regulation, 2011.

These are the main changes proposed for the microbiological standards:

  • The microbial requirements are distinguished into hygiene indicator organisms and safety indicator organisms. The current 2011 regulation makes no distinction between hygiene indicator and safety indicator organisms.
  • Hygiene indicator organisms covered include: aerobic plate count, coagulase positive staphylococci, yeast and mold count.
  • Safety indicator organisms covered include: Escherichia coli, Salmonella, Vibrio cholerae (O1 and O139), Listeria monocytogenes, Clostridium botulinum.
  • The microbiological criteria to comply with are listed for individual products under hygiene indicator and safety indicator organisms’ tables.
  • Sampling guidelines and sampling plan are explained specifically for this category of products. In the current regulations, no specific sampling guidelines and sampling plan are mentioned for fish and fish products.
  • Sampling plan for compliance of microbiological criteria for manufacturing units and retailers for fish and fish products are outlined. The current regulation does not differentiate between manufacturing units and retail points.
  • The criteria to interpret microbiological results are divided into: satisfactory, unsatisfactory and potentially hazardous and detailed explanation for arriving at the conclusion for each criterion is given.
  • Reference test methods, sample preparation that have to be followed for testing presence of organisms are outlined. The current regulations do not convey the information on reference test method for fish and fish products.
  • Detailed standards have been included in the proposal for the following categories: Raw/Chilled/Frozen Finfish; Raw/Chilled/Frozen Crustaceans; Raw/Chilled/Frozen Cephalopods; Chilled/Frozen Bivalves; Frozen cooked Crustaceans/Frozen heat shucked Mollusca; Dried/ Salted and Dried fishery Products; Thermally Processed Fishery Products; Fermented Fishery Products; Smoked Fishery Products; Accelerated Freeze dried Fishery Products; Fish Mince/Surimi and analogues; Fish Pickle; Battered and Breaded Fishery products; Convenience Fishery Products; Powdered Fish based Products.

The proposed regulations will replace the existing microbial criteria regulations for fish and fish products. The comments regarding the draft proposal will be accepted from the stakeholders within a 60 days period. Comments can be submitted to: regulation@fssai.gov.in or via website at this address.

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