Code of Practice for the Harvest, Transport, Processing, and Export of Seal Products Intended for Human Consumption

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Table of Contents



This Code Of Practice is intended to identify and establish procedures and requirements, which, when implemented, will ensure that seal meat and products intended for human food have been subjected to regulatory oversight which will ensure their compliance with Canadian regulatory requirements. This Code of Practice in intended to establish controls pertaining to the entire chain of events from harvest to final packaging of this product for domestic consumption or export.


This Code of Practice is predicated upon the recognized principles of the Hazard Analysis, Critical Control Point system of ensuring food safety. It recognizes and is designed to ensure consistency with international standards. The Canadian seal processing industry will be responsible to develop and implement the required monitoring and processing controls identified in this Code.

This Code of Practice consists of Six Appendices. Each Appendix has been developed to identify the controls which must be exercised at that step in the harvest/production continuum. Regulatory oversight will be exercised to ensure that all controls are in place. Failure to implement satisfactory controls will result in follow-up actions. Only products which have been handled and processed in accordance with acceptable controls will be permitted to be offered for human consumption.

1) Appendix I: Harvest Activities
Controls for slaughter, evisceration, pelting, washing, cooling, handling of seal meat, and pelt.

2) Appendix II: Assessing Suitability of Seals
Identification of healthy seals suitable for human consumption.

3) Appendix III: Vessel Requirements
Controls for Construction, Sanitation, Storage, Ice, Protection From Contamination/Cross Contamination, and Record Keeping requirements for the harvest/transport vessel.

4) Appendix IV: UHHT Requirements
Controls for Unloading, Holding, Handling, and Transportation, (UHHT) following harvest.

5) Appendix V: QMP Reference Standard
Processing Controls required by the Quality Management Plan of registered processors.

6) Appendix VI: Export Certification Control Program (ECCP) Plan
Controls identifying requirements related to certification of final product.

7) Appendix VII: Seal Product Standard
Final product requirements, including microbiological, and chemical standards.

Appendix I: Harvest Activities
Seal Products: Slaughter and Handling

1.0 Training

Controls must be established to ensure that seal harvesters are adequately trained in the sanitary slaughter, pelting, evisceration, and handling of products intended for human consumption.

Note: Aspects pertaining to "Humane slaughter" is the mandate of the Department of Fisheries and Oceans (DFO). The slaughter requirements contained in this Code of Practice pertain to the sanitary aspects of harvesting of seals for human consumption.

1.1 All harvesters must be adequately trained in the sanitary slaughter of seals which are harvested. Each harvester must be trained in the proper methods of slaughter, pelting, evisceration, handling, storage, sanitation, personal hygiene, and effective measures to ensure that contamination of the meat and fat to be processed for human consumption does not occur.

1.2 Documentation of the delivery of adequate training must be maintained. Each harvester/harvest vessel must be able to demonstrate to the CFIA, and to the processor of the seal products, that they have received adequate training which ensures that they are capable of processing acceptable food products.

1.3 A copy of the training material must be available upon request of the competent authority.

2.0 Humane Slaughter

2.1 Harvesters must ensure slaughter is conducted to ensure the animal is quickly euthanized following regulations and procedures as have been established by the competent authority.

3.0 Post Harvest: Bleeding/Sanitary Pelting/Evisceration

3.1 Once harvested the seal must be quickly and properly bled.

3.2 Once the pelt of the animal is perforated for bleeding, care must be taken to ensure that there is no contamination of the exposed fat/meat, from the time of bleeding to the time that the pelt is removed from the animal. Care must be taken at the harvest site, en route to the harvest vessel, and during handling/placement upon the harvest vessel to ensure that contamination does not occur.

3.3 The surface upon which the seal is bled must be acceptable. Once the pelt of the animal has been perforated care must be taken to ensure that foreign matter, or other sources of contamination within the harvest environment, or upon the vessel do not come into contact with exposed meat/fat. When the seal is turned belly down for bleeding, care must be taken to protect the exposed meat/fat from foreign matter and contamination. Clean snow, ice, or other suitable surface is considered to be satisfactory.

From the time of harvesting to the time of evisceration, contact with clean snow, ice, sea water, or other sanitary surface which is designed or intended for the placement of the animal is acceptable.

3.4 Pelting/Evisceration may occur at the harvest location (i.e. upon the ice), upon the harvest vessel, or under controlled conditions at a land based facility. All locations where seals are pelted/eviscerated are subject to the regulatory provisions of the Fish Inspection Regulations. The seal products must be protected from contamination at all times.

No person other than the vessel crew who were present at the harvest, may engage in pelting, evisceration or other processing of the seal, unless that processing is conducted in a registered establishment.

3.5 Following bleeding and pelting, evisceration must be conducted as soon as is practical. As a general rule evisceration should occur within several hours of harvesting. The carcass must be handled at all times in a manner so as to prevent contamination of the edible portions of the animal. Knives or any other utensils used in the pelting/evisceration/handling of the seal must be appropriate for their intended use.

3.6 If placed on the harvest vessel prior to pelting the animals must be handled in a manner to protect any exposed meat/fat surfaces. The animal shall be placed on the vessel so that any exposed meat/fat only comes in contact with a clean/sanitary surface.

3.7 Care must be taken to ensure that the gut is not perforated during evisceration. Should the gut become perforated, all affected areas of the carcass shall be immediately trimmed and discarded, up to and including the entire carcass.

3.8 Care must be taken during evisceration (conducted at the site of harvest or upon the harvest vessel) to ensure the entrails are removed in a sanitary manner. Training as to proper evisceration techniques shall be included in the training (identified in section 1.1 of this appendix). During evisceration, care must be taken to ensure that the natural leakage of intestinal contents does not serve as a source of contamination of any meat/fat intended for human consumption.

3.9 Once pelting and evisceration have been completed, the pelt and the carcass shall be immediately separated and thoroughly washed using an acceptable water supply.

3.10 The meat/fat must be quickly cooled as soon as possible following harvesting. (Immersion of whole seals in cold sea water following bleeding but prior to evisceration/pelting will foster rapid cooling of the animal). Eviscerated meat, and pelts containing fat shall be immediately cooled. The washing and immersion of meat/pelts with cold seawater will rapidly cool the product. Placement of meat/pelts upon clean sea ice will also ensure rapid cooling. Once cooled the meat/pelts must be packed and stored in a manner which will ensure that the temperature of storage does not exceed 4°C.

3.11 Once evisceration has been completed, the gut material must be discarded or otherwise handled to ensure that the meat and fat of the pelt do not make contact with gut material.

3.12 Where evisceration/pelting occurs at the harvest site, the pelts/meat shall be transported to the vessel for proper storage as soon as is possible. Care must be taken to ensure that prior to and during transport from the harvest site to the vessel that the meat and fat is not exposed to any form of contamination.

Appendix II: Assessing Suitability of Seals

1.0 Harvest of Healthy Seals that are Suitable for Human Consumption

Seals that are harvested and processed must be healthy and suitable for human consumption. To achieve this, each harvester must be adequately trained to recognize signs which might indicate that the seal is not acceptable for human consumption. Controls to ensure that only seals are that are suitable for human consumption are harvested and processed begin with evaluation of the live seals. Any seal displaying abnormal signs indicating that it may not be healthy and suitable for human consumption must not be harvested for entry into the food chain. Controls to adequately evaluate harvested seals to ensure they are healthy and suitable for human consumption also include appropriate evaluation of the eviscerated animal, and the gut/organs of the animal.


1.1 Each harvester who slaughters, pelts, and eviscerates seals must be adequately trained. Records of delivery of training to each harvester/crew member must be maintained to document that the appropriate training has been delivered.

1.2 Training material developed to ensure that harvesters can identify healthy seals that are suitable for human consumption must be documented. All methods and personnel involved in the development and delivery of the training material must also be documented. All documents must be maintained and provided to CFIA upon request.

2.0 Guidelines to Identify Healthy Seals that are Suitable for Human Consumption

The following information is intended as a guideline, and reflects the training material generated to identify healthy seals that are suitable for human consumption.

A carcass of good quality that is suitable for human consumption is dependent on the health of the seal. If the animal has a disease or infection, this can affect its whole body. Some diseases known as zoonotic diseases can be transmitted from seals to humans, especially if the meat is not cooked properly.

It is very important that animals displaying abnormal signs indicating potential presence of disease do not enter the human food chain. A seal must not be included in the harvest if the sealer is at all unsure about its health.

There are various degrees of disease or infection. For example, disease can be seen in only one organ of the body and may not necessarily affect the overall health of the animal.

However, in order to ensure that products of the highest possible safety will be brought back to shore during seal harvest, the carcass and fat from seals with even minor disease or infection in a single organ must be discarded.

If a harvester notices signs of disease in a seal at evisceration/pelting, he shall immediately notify an observer from the Department of Fisheries and Oceans (DFO) so that samples can be taken for evaluation.

The carcasses of all seals harvested must be subject to a complete examination. This can be done without interfering with the efficacy of the harvesting process.

Seals and other wild animals typically live in a very harsh environment that does not allow the survival of most diseased or injured animals for any length of time. Therefore, a large proportion of the seals harvested will likely show no evidence of disease, and abnormalities will likely be obvious in those that suffer from a significant disease process.

The purpose of this section is to provide guidance regarding the normal external and internal appearance of animal carcasses and on the different ways in which diseases can be recognized in seals. This information will allow harvesters to identify carcasses with any abnormality such that the carcasses will be segregated and discarded.

2.1 External Examination

2.1.1 Nutritional condition

A good state of nutrition is shown by a plump, round body. The seal should not be skinny. Poor body condition is shown by a thin blubber layer which causes the seal's shoulder blades, hips, and back bone to stick out and be easily recognized. Seals that are in poor body condition must not be harvested.

2.1.2 Skin and haircoat

Hair loss in seals can be normal and simply result from rubbing against surfaces. However, it may also be associated with disease, in which case bald patches may be in a few scattered locations, or the entire body may be affected. If a seal is mostly bald, it is a sign of being unhealthy and is considered unfit for harvest.

In addition to hair loss, seals with skin problems may have a crusty skin surface and sores on the skin and/or around the mouth.

External parasites, such as lice, may be found on the skin. Parasites are common in all wild animals, and usually do not cause disease. However, animals that have a large number of parasites visible on the skin may be unhealthy and must not be harvested.

2.1.3 Eyes and nose

Sealers should watch for thick fluid coming from the eyes and nose, especially if it is yellow or green which indicates a bacterial infection. However, small amounts of clear fluid discharge from the eyes may simply be caused by irritation from blowing dirt.

A decision about the fitness of the animal for harvest should not be based only on the presence or absence of discharge from the eyes and nose. The amount of discharge and the appearance of the rest of the body should also be considered.

2.2 Internal Examination

Experienced sealers who have opened hundreds of seal carcasses have a very good idea of what a normal seal looks like. If a carcass is opened and the sealer notices something abnormal, he may not know the exact cause, but will recognize the abnormality. The carcass and fat of seals showing any abnormalities must be discarded.

2.2.1 Blubber (fat)

Seals store most of their body fat as blubber under the skin. Therefore, the thickness of this blubber is a good indication of the nutritional status and overall health of these animals, although this can vary a lot according to the time of year.

In healthy young harp and grey seals that have just been weaned, the blubber can easily be 4-5 cm thick but some of it will be used up as the animal fasts before going into the water. A very thin blubber layer means that the seal is either starving or suffers from some chronic disease. These animals must be discarded.

Normal blubber is white. In some cases, it may have an abnormal colour. In particular, yellow fat throughout the carcass may indicate a serious disease such as chronic liver damage, and the carcass and fat must be discarded.

Rarely, people have reported blubber with a bright orange colour in harp seals that otherwise appeared normal. The cause of this change in colour was not determined. To be safe the carcasses and fat of these seals must be discarded.

2.2.2 Organ surfaces and internal surface of body wall

The animal's internal organs and body wall should have a shiny surface. Organs should not stick to the body wall or to each other. Very firm attachments that have formed between organs or with the body wall are caused by scar tissue which is formed as a result of a chronic disease. These carcasses and their fat must be discarded.

If the surface of an organ looks dull or is covered by a layer of whitish or yellowish material, even if this layer is very thin, the animal is diseased, and the carcass and fat must be discarded.

2.2.3 Joints

Normal joints contain a small amount of clear yellow syrupy fluid which is responsible for lubricating the joint surfaces. A diseased joint will be swollen and filled with, or surrounded by, variable amounts of thick, cloudy, white or yellow fluid or firm but crumbly material.

2.2.4 Lymph nodes

A lymph node is a small round mass of white or grey tissue. It filters fluids that have leaked from blood vessels and will return to the general blood circulation. Lymph nodes are part of the body's immune system responsible for fighting infections.

When there is an infection in an area of the body drained by a lymph node, the node gets bigger (enlarges) especially when the infection has been present for some time (roughly one week or longer). Lymph nodes that are enlarged are good indicators of disease.

The lymph node enlarges because cells within it multiply as they attack the microbes within the fluid filtered by the node.

Lymph nodes are found throughout the body, more or less in the same locations in all species of mammals. Most are small and difficult to find in normal animals. The tonsils are an example of lymph nodes in our throat.

The most important nodes for quick diagnosis of disease can be found under the jaw and close to the lungs, liver, digestive tract, and kidneys.

If, during pelting, the sealer notices large lumps near the jaw, lungs, liver and kidneys, this suggests that the seal has enlarged lymph nodes and may be diseased. However, the lymph nodes near the digestive tract are normally larger than those found in the rest of the body.

Animals have both lymph nodes and salivary glands below their jaw. These glands should not be mistaken for enlarged lymph nodes. They are generally larger, feel firmer than lymph nodes, and on cut surface look like they are divided into small portions, in contrast to lymph nodes which have a more uniform texture.

In seals, the lymph nodes associated with the intestine are normally quite large, typically forming a long, thick mass of tissue.

The adrenal gland is a very important structure which produces hormones. It is located just above each of the two kidneys and can be confused with a lymph node. However, it is flatter, and on cut surface it has a pale outer zone and a dark red or brown centre.

Enlarged or otherwise abnormal lymph nodes in only one area suggest that this area is infected and, therefore, the carcass must not be used for human consumption.

The disease problem in the affected area is usually easy to see. In domestic animals at slaughter, the diseased area may simply be cut away, depending on the severity of the disease problem and the condition of the rest of the carcass. In seals, however, the whole carcass and fat must be discarded if even one area of the body shows evidence of disease.

Enlarged lymph nodes throughout the body indicate that the whole carcass is diseased and must be discarded.

2.2.5 Lungs

Normal lungs are pink, have a shiny surface, and feel soft and spongy. Any large lump or firm, darkly coloured area within the lungs is abnormal.

The lungs of seals that have been clubbed or shot in the head may contain dark red areas caused by bleeding. This may be caused by a sudden change in blood pressure and is a common finding in animals that have died from severe acute injury to the head. As long as the lung tissue in the dark red areas is spongy, the lungs are normal.

2.2.6 Heart

The heart muscle should be of a dark red colour on cut surface. The outer surface may have some white streaks because of the presence of fat. A diseased heart muscle may have irregular areas that have either a lighter or darker colour than normal.

When the heart is removed from the rest of the organs, it should be cut so that the heart valves are visible. The heart valves should be thin, white and shiny. Diseased heart valves may be discoloured and have a rough surface or have lumpy, cauliflower-like growths on their surfaces. This is an indication of serious disease. The heart valves move constantly, and parts of the lumpy growths can break off into the bloodstream, contaminating the entire carcass with bacteria. The carcass and fat of these seals must be discarded.

2.2.7 Liver

A normal liver is uniformly dark brown and has a smooth, shiny surface. Small white dots either on its surface or within it indicate disease, which can result from infection by bacteria or viruses. If these white dots are present, it is likely that the rest of the body is also infected, and the carcass and fat must be discarded.

Parasites that are in the liver or have moved through it can also cause white spots, but these are generally bigger than those caused by bacteria or viruses.

In domestic animals at slaughter, it is often possible to determine whether white spots on the liver are caused by parasites or by bacteria or viruses. Livers damaged by parasites are discarded, but the rest of the carcass can be kept if no other abnormalities are found. In wild animals, however, it is not possible to be sure of the cause of white spots in the liver. As a result, the carcass and fat of seals with a diseased liver must be discarded.

2.2.8 Digestive tract (stomach and intestine)

The surface of the stomach and of all loops of intestine should be shiny and smooth and of a pale colour. Loops of intestine should not stick together or to the body wall.

Any obvious abnormality in the appearance of the digestive tract means that the large number of bacteria present within it may have contaminated the rest of the body. The carcass and fat of these seals must therefore be discarded.

2.2.9 Kidneys

Normal seal kidneys have a brown, shiny surface. They are actually made up of multiple miniature kidneys, like a densely packed bunch of grapes. Because of this, their cut surface shows multiple whitish areas, each surrounded by brown tissue.

Kidneys with an irregular colour on the surface or which contain lumps or cloudy fluid when cut are likely infected, and the carcass and fat must be discarded.

Appendix III: Harvest Vessel Processing/Construction/ Storage Requirements

1.0 Training

Controls must be established to ensure that all crew members involved in processing (pelting/evisceration) upon the harvest vessel are appropriately and adequately trained.

1.1 Each crew member who will be processing seals upon the vessel must be trained in the proper methods of pelting, evisceration, handling, storage, sanitation, personal hygiene, and effective measures to ensure that contamination of the meat and fat to be processed for human consumption does not occur. The training shall include appropriate sections of the Code of Practice.

1.2 Documentation of the delivery of adequate training must be maintained. Each harvester/harvest vessel must be able to verify to the competent authority, and to the registered processor of the seal products, that they have received adequate training which ensures they are capable of processing acceptable food products.

2.0 Holding/Processing Controls On the Harvest Vessel

Holding of harvested seals upon the vessel is conducted in a manner to prevent contamination.

2.1 On-deck holding areas for un-eviscerated bled seals must be designed so that any deck water/processing residues of blood etc. do not come into contact with the stored animals.

2.2 On-deck holding areas shall be adequately elevated above the deck, and drained to remove water/blood from this area on a continual basis. Cleaning of this area should be conducted as is required.

2.3 During holding, seals shall be placed so there is no excessive weight upon them which would result in leakage of the gut/anal contents. Care must be taken to minimize the exposure of the seals to contamination during on deck holding.

2.4 Processing tables upon which seals are placed for processing/evisceration must be of suitable construction, and designed for effective cleaning/sanitation. They should be free of cracks, depressions or any other feature which would prevent effective cleaning and sanitation. Wooden processing tables, or other processing equipment such as wooden chop blocks are not acceptable.

2.5 Processing equipment including knives/saws shall be of appropriate design and construction. Wooden handles are not acceptable. All processing equipment must be designed to be easily cleaned and sanitized.

2.6 During pelting/evisceration care shall be taken to minimize exposure of meat/fat to visceral contents. Processing tables and equipment (e.g. knives) onto which visceral contents may spill must be effectively cleaned and sanitized. Exposure of meat/fat to any such contamination should be prevented. The seal shall be eviscerated in a manner to prevent the spillage of gut material onto the processing table.

2.7 Cleaning and sanitizing chemicals needed for such cleanup of food contact surfaces in response to exposure of the surfaces to gut material, shall be readily available when needed. They shall be stored in a manner as to not spill onto meat/fat products.

2.8 During processing there must be a continual flow of clean sea water upon the deck to remove blood and other material resulting from evisceration and pelting activities.

2.9 Viscera removed must be immediately discarded to prevent contact with meat/fat product. If discarded into the sea, the visceral contents, and the deck wash water must not come into contact with the intake water supply or any seals or seal products which are in the sea being cooled, or awaiting processing.

2.10 Following evisceration and pelting (identified in sections 3.2.5-3.2.7 in Appendix I), the meat and the pelt must be immediately washed, and cooled. The meat must not come into contact with the pelt once pelting has been completed. Re-circulating wash water is not acceptable.

2.11 Following the washing of the meat and pelt, they must be cooled and stored to maintain a storage temperature of 4°C or colder.

2.12 Pelts and meat must be handled to protect them from all sources of contamination. Contact with the deck, or other non-food contact surfaces must be avoided.

3.0 Storage on the Vessel

Seal products and ice are protected from contamination during processing, handling, storage, and transportation, upon the harvest vessel. Vessels of any size (including vessels with below deck storage holds, and open vessels with mid-ship storage lockers) must be designed to meet these requirements.

3.1 Seal meat must be stored separately from pelts in order to prevent cross contamination. Storage areas (e.g. pounds of larger vessels, mid-ship rooms of smaller vessels) must provide physical separation of the meat and the pelts. Vessel holds/storage areas where required, shall be constructed to provide drainage and to ensure that melt water and bilge water does not come in contact with seal products and ice.

Vessels with chilled seawater or that use slush ice systems are exempt from this provision.

Melt water must not become a source of contamination. Excess water/effluent from the pelts must not have access to the pounds containing the meat. Excess water should be disposed of through proper drainage/bilge pumps.

3.2 Handling practices in placing the seal product into the storage areas must not result in cross contamination of the meat from the pelt. During storage care shall be taken to ensure that the storage areas are not contaminated. Personnel shall not tread in the pounds or upon stored pelts/meat.

3.3 Ice stored upon the vessel for use in refrigeration of meat/pelts must be stored in an approved container or compartment which protects it from sources of contamination until it is placed upon the product.

3.4 All containers/holds where seal products are stored must be outfitted with tight fitting covers. Vessels with holds, including mid ship storage rooms, will be required to have tight fitting preferably insulated, covers to aid in maintaining refrigeration of the fish. Vessels with below deck storage shall have colemans of an adequate height to ensure there is no leakage from the deck into the hold.

Unacceptable Covers

Canvas or polypropylene tarpaulins are unacceptable.

3.5 Seal products must be protected from the sun, weather, environment, and such contaminants as grease, oil, fuel, glass, or bilge oil. Equipment such as chain drives, drive shafts, and bearings, if present, must be enclosed to protect the product and the ice from contamination.

Bulkheads are required to be watertight to prevent any contamination of the seal product storage area with fuel, grease, and other contaminants.

Equipment, including fuel lines, fuelling ports, waste disposal lines and fuel storage tanks, shall not be located in a seal product storage area. If these cannot be relocated, they must be totally enclosed and watertight.

It will not be necessary to enclose below deck bilge pumps, solid hydraulic lines, and hydraulically operated fish pumps provided they are adequately maintained and coated with a suitable epoxy or paint.

Rubber hoses must not be painted as the flexing causes the paint flake off.

All lights must be of a shatterproof design or be adequately protected with a shield to prevent breakage.

Stored seal products must not be stored in any area where it is prone to contamination with rust or any other form of foreign matter.

Animals are not allowed onboard fishing vessels or in areas where seal products are unloaded from those vessels.

3.6 Seal products must not be contaminated with pieces of viscera, or visceral contents, as they are heavily laden with spoilage bacteria and digestive enzymes.

Seal offal and waste water must not be allowed to contaminate seal products during storage. Disposal of offal or refuse must not create obnoxious odours or unsanitary conditions upon the vessel.

4.0 Transport Conditions

Seal products must be transported in a manner to prevent decomposition or contamination of the product.

4.1 Areas/containers which have been previously used for transporting hazardous or unsanitary materials such as chemicals, pesticides, fertilizers, fish offal and other waste, shall not be used for transporting seal products.

Only approved containers (e.g. polyethylene tubs) may be used to transport seal products.

4.2 During transport, seal products must be maintained at a storage temperature of 4°C or colder, in order to maintain product safety and to ensure that decomposition does not occur. Refrigeration may be achieved through the use of ice or other acceptable means (e.g. slush ice, clean cold circulated sea water).

4.3 Ice used to chill seal products must be obtained from an approved source. Clean ice obtained from the harvest site is acceptable. When ice is used, sufficient ice shall be added to reduce and hold the temperature at 4°C or colder. Additional ice may be used to replace the ice as it melts in order to maintain the required holding temperature.

Previously used ice shall not be reused.

4.4 Chilling systems other than ice may be used to maintain adequate storage temperatures of seal products during transport. Such systems or other methods must be capable of cooling and maintaining the temperature of the seal products to 4°C or colder. Vessels using refrigerated seawater or chilled seawater systems must have a thermometer which continuously measures the temperature of the seawater.

Cool ambient temperatures, or refrigeration systems producing cool air have not been found to be suitable replacements for ice, as a means to refrigerate seal products.

4.5 During transport seal products must be stored in a manner so that they are protected from crushing. Where necessary, bulk storage pens shall be divided vertically to prevent crushing of the bottom levels of stored seal products from occurring. The requirement for fish is that storage pens be divided vertically at intervals of 90cm or less where it is necessary. Where the industry can verify that a storage height of greater than 90cm will not result in the crushing of stored seals products during transport, the CFIA may consider holding this regulatory requirement in abeyance.

4.6 Seal products must not be handled in any manner that causes physical damage. Forks, tools or other equipment and practices that tear, or otherwise damage or contaminate the seal product shall not be used.

Seal products must not be thrown or dropped into storage area but rather be allowed to slide down chutes, flumes and other devices designed to minimize physical damage to the seal product.

Seal products must not be trampled, walked upon, roughly handled or otherwise mis-handled at any time during processing, transportation or handling.

4.7 Frozen storage (if applicable). Seal meat which is frozen upon the vessel, must be held under conditions that maintains safety and quality. Storage areas in which frozen seal meat is held onboard a vessel shall be maintained at a temperature at -18°C or lower.

4.8 Frozen seal meat shall be protected from dehydration and oxidation. After freezing the seal meat shall be glazed or packed with a suitable impervious packaging material onboard the vessel to protect it from dehydration and oxidation.

4.9 Frozen storage temperatures must be monitored. Each cold storage room on the vessel which is used to hold frozen seal meat, must be equipped with an automatic temperature recording device. (Note: This does not apply to storage areas where seal meat/pelts are stored in ice.)

5.0 Construction, Equipment and Maintenance

All vessels engaged in the transport of seal products for human consumption must meet the requirements of Schedule III of the FIR. Responsible personnel should be familiar with the requirements of Schedule III.

Seal product storage and handling equipment are made with approved materials which are easy to clean and will not physically damage or contaminate the seal products.

5.1 Materials and Design. Seal product contact surfaces must be constructed of approved materials.

Seal product contact surfaces on equipment, holds, pens (shelving and dividers), boxes and chilled water tanks shall be constructed of non corrodible, smooth surfaced materials impervious to water. Examples include steel, sea water resistant aluminum alloys, high density plastic, polyurethane coated cement or fibreglass reinforced plastic. Surfaces shall be smooth and free of crevices to prevent physical damage of the seal products and to facilitate cleaning. Electrical wires, piping, or any other auxiliary structures must not interfere with the effective cleaning of storage areas.

Equipment with direct contact with seal products and ice shall be made of non absorbent, non corrodible materials, other than wood.

Containers into which seal products are placed shall be of smooth, non absorbent, non corrodible material other than wood, free from cracks and crevices, and constructed to provide drainage and protect the seal products from damage when the boxes are stacked.

Unacceptable Surfaces

It is not acceptable to coat wood or other surfaces made of materials that are not suitable for food contact with coatings that are prone to damage. Epoxy coated wooden boxes will not comply. Paints and other coatings such as some types of epoxy resins that are used on these surfaces that are prone to damage may result in direct contamination of the seal products and will make the surfaces difficult to clean.

Galvanized metal and wood are not permitted.

5.2 Equipment design facilitates cleaning. Equipment must be designed to be accessible during regular cleaning operation to prevent accumulation of debris. If necessary, equipment should be easily dismantled to facilitate cleaning of all parts.

5.3 Storage compartments are insulated from heat sources. The engine compartment and other heated areas must be separated from the ice and seal product storage area by water tight, insulated bulkheads and wall surfaces. Bulkheads and deck heads in frozen storage areas of a vessel shall be well insulated.

All insulating materials must be properly installed. Any ice melt water, blood, or slime seeping through the fish lining will reduce their efficiency of the insulation and this will in turn lead to an increase in the temperature of the seal products. All insulation must be properly covered with approved, impervious fish hold lining material. All joints must be watertight.

5.4 Refrigeration Equipment

If the vessel is equipped with refrigeration systems, those systems will reduce the temperature of the fish at a rate that maintains product safety and quality. Systems must provide adequate cooling rates and holding temperatures.

Materials used in these systems must be non-porous to reduce the risk of contamination. Appropriate materials include stainless steel, high density plastics, seawater resistant aluminium and copper based alloys.

The entire system must be designed to allow an easy introduction and effective circulation of the cleaning and disinfecting solutions ensuring all surfaces are kept clean.

5.5 Regular cleaning and maintenance is followed such that storage areas, equipment and other fish contact surfaces do not become a source of contamination.

Seal product handling equipment is maintained to prevent contamination of the seal product. Equipment must be kept clean and sound.

Surfaces of equipment are free of corrosion, peeling paint, or other defects that will contaminate the seal products or make cleaning difficult.

Any surfaces that contact seal products shall be maintained to be sound, smooth, and free from cracks and crevices. All seal product receiving areas, equipment, containers and utensils used to handle the seal in preparation for storage, must be cleaned with suitable water and disinfected at least once per day while the vessel is operating.

6.0 Sanitation

Each vessel must implement sanitation procedures to ensure that the vessel and all food contact surfaces are maintained in a clean and sanitary condition.

6.1 Sanitation procedures must be documented. Procedures should identify the area to be cleaned, the frequency of cleaning, the procedures to be followed, cleaning and sanitizing chemicals to be used and their method of preparation, and persons responsible for cleaning procedures.

6.2 Adequate cleaning requires that all equipment and processing surfaces, as well as other areas (e.g. where seals are handled) of the vessel, be rinsed, thoroughly cleaned (with cleaning chemicals), rinsed and sanitized.

6.3 All cleaning chemicals shall only be used following the manufactures recommendations.

6.4 Containers and equipment must be allowed to air dry prior to stacking or storing.

6.5 Following the discharge of seal products from a vessel, all equipment, utensils, storage areas, and containers shall be subject to cleaning procedures.

6.6 Cleaning must occur promptly after unloading at the end of each fishing trip. All seal product holding facilities, and other equipment and utensils that come in contact with the product shall be washed with suitable cold water (includes clean seawater under adequate pressure). Surfaces must be thoroughly scrubbed with a brush or high pressure cleaning equipment and an acceptable detergent and then rinsed. Clean surfaces should then be disinfected with hypochlorite solution or another suitable sanitizing agent and rinsed with cold water to then again remove the disinfectant.

In the case of boats equipped with chilled water systems, all pipes and heat exchangers must be flushed with suitable water and a cleaning solution to remove slime, blood, and viscera. These systems must be flushed again with suitable water to remove all traces of the cleaning solution. The use of a disinfectant is also strongly recommended providing the system is rinsed with water before the tanks are filled prior to fishing.

Cleaning and disinfecting as appropriate must be completed prior to taking on fresh ice for the next trip, and prior to the initiation of subsequent processing activities.

6.7 Cleaning Chemicals Are Acceptable For Food Contact Surfaces.

Cleaning chemicals must be suitable for food contact surfaces. If in doubt, please refer to the Reference Listing of Accepted Construction Materials, Packaging Materials and Non-Food Chemical Products.

7.0 Water Source

Water used for cleaning must be obtained from an acceptable source and not be a source of contamination.

7.1 Water must be obtained from a suitable source. Harbour water, or water from alongside the dock where the vessel is tied up, must never be used for cleaning purposes as its safety cannot be verified. This is also true for water in close vicinity to towns, villages, industrial plants, fish plants and factory freezer ships.

Re-circulating cleaning water is not permitted.

8.0 Hand Washing and Toilet Facilities

Seal Products Must Not Be Contaminated by Human Waste.

8.1 There must be an adequate number and placement of toilet facilities. Hand washing and marine type toilet facilities shall be provided on vessels over 13.7 metres or more in overall length that have sleeping accommodations.

8.2 The owner of the vessel must be able to demonstrate that the location and number of flush toilets and wash basins is appropriate for the number of crew on board the vessel.

8.3 The hand wash facilities shall be located close to the seal product handling area to encourage frequent hand washing. The use of the galley sink for hand washing is considered acceptable.

8.4 As a general guide, one marine type flush toilet and one wash basin shall be provided for every ten crew members.

8.5 Toilets and washbasins must be properly equipped, clean, sanitary and must be maintained in a clean and sanitary condition.

8.6 Hand washing facilities shall be equipped with running water, (use of a reservoir piped to a sink is acceptable), liquid or powdered soap and single service towels.

8.7 In the absence of adequate hand washing facilities (smaller vessels) persons handling seal products must use proper hygienic practices (hand sanitizers).

8.8 Waste from toilets and washbasins must be properly handled. The waste discharge must drain overboard, be equipped with a check valve if necessary, and be situated on the opposite side of water intakes and further towards the stern in order to minimize the possibility of contamination when the vessel is in forward motion.

A washbasin draining into a pail is unacceptable.

9.0 Daily Catch Log

Harvesters must be able to identify the time and location where seals were harvested.

9.1 The vessel owner/operators must maintain an accurate log onboard the vessel, indicating the numbers of seals harvested and the harvest location. These records shall be maintained on a daily basis. These records must be made available to the competent authority upon request.

10.0 Training Records

Training procedures and records must be maintained to clearly document that harvesters are adequately trained in the proper processing, handling, storage and transportation of seal products.

10.1 Written procedures which document the requirements for the handling and storage of seal products upon the harvest vessel, and the procedures to monitor adherence to the construction requirements of harvest vessels must be maintained.

10.2 The vessel captain shall ensure that crew members that participate in the fishery are properly trained in the harvesting, handling, storage and transportation requirements.

10.3 A record of the training shall be kept on file by the harvester for a minimum of three years.

Appendix IV: Requirements for Conveyances and Equipment Used For Unloading, Handling, Holding, and Transportation, (UHHT)

1. Offloading

1.1 Seal products shall be offloaded from the harvest vessel, in a manner to ensure that they are protected from sources of contamination.

1.1.1 During offloading activities there must be no cross contamination between the meat, and the pelts. The meat is to be handled so that it remains isolated from the pelts and any other source which may serve to contaminate the meat.

1.1.2 Equipment and containers which have previously been used to offload/handle pelts shall not be used to offload/handle meat unless the equipment and containers are first subjected to appropriate cleaning and sanitation procedures.

1.1.3 Offloading procedures shall be conducted in an efficient and timely manner. During offloading vessel hold covers shall only be removed during offloading activities. Where there is a break in offloading from the hold the cover shall be replaced so as to protect the stored seal products from sources of contamination.

1.1.4 Care must be taken so that the offloading is not conducted in an area where there are significant sources of environmental contamination. Exposed seal product must be protected from sources of dust, debris, pests, animals, and any other source of chemical, or environmental contamination. Areas where seal product is landed or handled, and all surfaces that come into contact with the seal during unloading, and handling shall be maintained in a clean and sanitary condition.

1.1.5 Offal and other refuse must be disposed of in a sanitary manner so that in the opinion of the inspector, such disposal activities do not result in the presence of unsanitary conditions at the offloading premises.

1.1.6 Personnel having direct contact with seal product during offloading/handling activities must ensure that they are not a source of contamination into the product. Care shall be taken to ensure that product is not trampled upon, and that boots or other attire does not become a source of contamination. All offloading activities shall be conducted in an hygienic manner.

2. Offloading/Transport Equipment

2.1 Equipment which is used to offload/transport seal product shall be adequately designed for the sanitary handling of food products.

2.1.1 Forks, pumps, tools, baskets, vats, and other equipment which contacts the seal product during offloading/handling, must not pierce, tear, or otherwise damage or contaminate product which is destined for human consumption.

2.1.2 Equipment used to handle or transport the seal product, including chutes, conveyors, tables, utensils, vats, or other contact surfaces shall be of smooth, non-absorbent, non-corrodible material other than wood, shall be free from cracks and crevices and shall be designed, constructed and maintained so as to facilitate effective cleaning and sanitation.

2.1.3 Where hydraulic equipment is used during offloading care must be taken to ensure that there are no hydraulic leaks from the equipment/lines into the seal product or upon food contact surfaces. Should accidental leakage occur all affected product must be disposed of immediately.

2.1.4 The containers used to hold or transport seal product shall be filled to a level no higher than 90 cm of its depth. Seal products shall not be stored or transported in bulk unless it is contained in a manner such that there are divisions at intervals of a maximum of 1 metre along its length.

3. Holding/Transport

3.1 During Holding/Transport seal product shall be adequately protected to prevent contamination/spoilage.

3.1.1 Seal product shall be transported in containers with tight fitting covers, or otherwise, covered in a manner which protects the product from sources of contamination.

3.1.2 Seal product shall be adequately iced and chilled during transportation. Ice should be added in an amount so that there is an excess of ice remaining at the time that the seal is delivered to the registered establishment for further processing.

3.1.3 Once the seal product is packed for transportation, it must not be further handled except at the premises of a registered establishment under accepted QMP controls. All processing of seal product intended for human consumption must be conducted within a registered premises.

3.1.4 During transportation seal product shall be contained so that there is no leakage into a container holding the product. Should containers be designed for drainage care must be taken that the container is stored so that neither the drain hole, nor the cover, allows entry of contamination into the container.

3.1.5 All contact surfaces to which the seal product is exposed during transportation must be of appropriate construction for the hygienic handling of food, and must be maintained in a sound, clean, and sanitary manner, free from cracks and crevices which cannot be effectively cleaned.

3.1.6 Seal product held prior to transport shall be adequately iced and chilled after unloading, and be stored in containers with tight fitting covers, or otherwise covered and contained, so that it is protected for sources of contamination.

4. Ice/Water Supply

4.1 Water/Ice used during offloading/holding/transport/storage of seal product shall be obtained from an acceptable source.

4.1.1 Water used during offloading, and which makes contact with food contact surfaces must not be a source of contamination into the product. The source and acceptable quality of the water must be confirmed and documented to be acceptable. Such sources may include a monitored municipal supply, a drilled well, or sea water which has been verified to be obtained from an acceptable location. Water obtained from a source adjacent to the offloading site, or wharf, is not to be used. Water must not be obtained from any source unless there is adequate documentation as to its acceptability.

4.1.2 Ice used during holding or transport of seal product must not be a source of contamination into the product. The ice shall be made from an acceptable source of water. Ice supplied at the offloading site to be used to chill seal product during transport must originate from a facility which has been verified to be acceptable to handle food. The ice must be stored and transported in a sanitary manner prior to, and during delivery, to the unloading facility.

4.1.3 All contact surfaces to which the supply of water and ice is exposed shall be of acceptable material, and shall be maintained in a new, clean, sound condition. These contact surfaces shall be inspected, cleaned and sanitized as required to maintain them in a clean and sanitary condition.

5. Cleaning/Sanitation

5.1 All contact surfaces to which seal product is exposed during offloading shall be subjected to adequate inspection, monitoring, and sanitation activities.

5.1.1 All equipment used to offload/handle or transport seal products which will be processed for human consumption (meat and fat), which has direct contact with the product shall be maintained in a clean and sanitary condition. The equipment shall be inspected prior to use to ensure that it is sanitary.

5.1.2 All equipment used to offload/handle/transport seal products intended for human consumption shall be cleaned and sanitized following use.

5.1.3 The persons responsible for cleaning and sanitizing equipment used in the offloading/handling/transport of seal products shall be identified and shall be knowledgeable in the application of sanitation procedures.

5.1.4 Chemicals and sanitizers used shall be approved for that use and used following the directions provided by the manufacturer of the cleaning chemical.

Appendix V: QMP Reference Standard and Compliance Guidelines

Please see Facilities Inspection Manual : chapter 3, Subject 4 - QMP Reference Standard and Compliance Guidelines (and associated appendices)

Appendix VI: Export Certification Control Plan (ECCP)

Please refer to the Export Certification Control Program Reference Standard for the requirements for seal meat and seal products to be eligible for export certification.

Appendix VII: Fresh and Frozen Seal Standard

1. Introduction

This standard for fresh and frozen seal or minced seal derives its authority from the Fish Inspection Act and Regulations. It defines minimum acceptability for taint, decomposition, and unwholesomeness, and other requirements, other than weight, as defined in the Fish Inspection Act and Regulations.

2. Scope

This standard applies to all fresh, frozen or defrosted seal or minced seal, prepared from any one of the following species:

  1. Harp seal - Pagophilus groenlandicus
  2. Hooded seal - Cystophora cristata
  3. Grey seal - Halichoerus grypus

Fresh and frozen or defrosted seal or minced seal shall be prepared from sound, wholesome raw material.

3. Nomenclature

The common name of the product shall be "seal". The word "seal" may be qualified as to the species type and the form of presentation.

4. Forms of Presentation

4.1 Seal meat may be cut and processed to be presented in various forms. Label information shall accurately represent the form of presentation, e.g., barbecued seal meat, seasoned seal meat.

Specific cuts of seal meat may be labeled to accurately indicate the nature of the cut, e.g., seal flippers, seal loins, etc.

4.2 A form of presentation which differs from meat portions cut from the carcass, is a distinct portion of the animal (e.g., internal organs, sex organs), or is processed to the degree that the physical presentation and the appearance of the final product is unique (e.g., seal sausages, minced seal meat):

  1. may not be labeled as a form of presentation as set out in 4.1; and
  2. must be accurately labeled to identify the presentation form; and
  3. must meet all other requirements of the Fish Inspection Regulations

5. Sampling

The sampling and tolerance plans to be used to determine the acceptability of the lot shall be in accordance with the FAO/WHO Codex Alimentarius Sampling Plan for Prepackaged Foods, (AQL 6.5) (CAC/RM 42-1969) except that a lower acceptance number for decomposition shall be used.

Tables within AQL 6.5 specify the minimum number of sample units to be used for the following types of inspections:

  1. Level I - Sensory examinations of all products subject to inspection other than lots which are subject to re-inspection.
  2. Level II - Sensory examinations of all products which are under re-inspection.

6. Description of Defects

6.1 Taint

A unit will be considered tainted when more than 10% of the declared weight is affected by any of the following conditions:

  1. Rancid
    characterized by the distinct or persistent odour or colour of oxidized oil;
  2. Moldy
    characterized by a distinct, or persistant musty odour and appearance.

6.2 Decomposition

A unit will be considered decomposed when more than 10% of the declared weight is affected by the following condition:

  1. Odour
    persistent, distinct and uncharacteristic odour including but not limited to the following:
    ammonia, faecal, hydrogen sulphide, putrid, sour.

6.3 Unwholesome

a) Critical foreign material

A lot will be considered defective when any of the following conditions are found:

  1. The presence of any material which has not been derived from seal and which poses a threat to human health, (such as glass, etc.); or
  2. Distinct and persistent odour of any material which has not been derived from seal and which poses a threat to human health, (such as solvents, fuel oil, etc.); or
  3. Detectable fluorescence indicative of contamination by anti-yellowing solutions or other contaminants.

b) Foreign material

A unit will be considered defective when the following condition is found:

  1. The presence of readily detectable material which has not been derived from seal but does not pose a threat to human health (such as insect pieces, sand, paint, rope, wood chips etc.)

c) Other defects

A lot will be considered defective when the following condition is found:

  1. Any incidence of diseased conditions.

A unit will be considered defective when any of the following conditions are found:

  1. Dehydration (freezer burn)
    • Minced packs - more than 10% of the surface area of the sample unit is affected
    • Other packs - more than 10% of the declared weight of the seal in the unit is affected by dehydration affecting more than 10% of the surface area.
  2. Bone chips (prepared and boneless packs only)

    Each incidence of bone or bone chips.

  3. Undesirable parts
    • Each incidence of viscera or body organs; or
    • Each incidence of tumours or sores; or
    • Each incidence of seal teeth, seal lips, seal whiskers, seal fur etc.
  4. Nematodes

    Each incidence of nematodes found upon the meat. (Nematodes are not normally found in seal meat but due to inadequate cleaning and poor bleeding and evisceration practices, some carcasses can be contaminated by worms from the gut material.)

  5. Gelatinous conditions

    More than 10% of the declared weight of the seal in the unit affected by severely bruised flesh resulting from gunshot wounds or abusive/excessive handling practices, affecting more than 10% of the surface area.

7. Classification of Defects

A sample unit of seal, including minced seal meat is classified defective when one or more of the following conditions are encountered:

  1. Decomposed, when more than 10% of the declared weight of the seal is found to be decomposed as described in Section 6.2, the sample unit is considered decomposed and the lower acceptance number in parentheses is used to determine lot acceptance; or
  2. Tainted, when more than 10% of the declared weight of the seal is found to be tainted as described in Section 6.1, the sample unit is considered tainted and the regular acceptance number is used to determine lot acceptance; or
  3. Tainted/Decomposed, when assessed individually the amounts of tainted or decomposed seal meat are less than 10%, but when combined, the amount of tainted and decomposed seal exceeds more than 10% of the declared weight, the sample unit is rejected as tainted/decomposed and the regular acceptance number is used to determine the lot acceptance.
  4. Unwholesome, when:
    1. The sample unit is affected by foreign matter; or
    2. The sample unit is affected by dehydration that exceeds the tolerance described in Section 6.3; or
    3. The sample unit is affected by gelatinous conditions that exceeds the tolerance described in Section 6.3; or
    4. The sample unit is affected by bones or bone chips (prepared and boneless packs only); or
    5. The sample unit is affected by undesirable parts; or
    6. The sample unit is affected by nematodes.

8. Lot Acceptance

A lot will fail the requirements of this standard when:

  1. any single instance of critical foreign matter is encountered; or
  2. the total number of sample units found defective for tainted, decomposed or unwholesome conditions, individually or in combination, exceeds the acceptance number for the sample size described in the sampling plans; or
  3. the total number of sample units found defective for decomposition exceeds the acceptance number shown in the parentheses for the sample size described in the sampling plans;or
  4. any single instance of diseased conditions is found.

9. Requirements for Physiochemical Attributes and for Contaminant Levels

Seal products processed for human consumption shall meet all of the applicable standards of the Fish Inspection Regulations, and the Food and Drugs Act and Regulations of Canada. In addition seal products exported shall meet the import standards and requirements of the importing country.


The odour/flavour stimulus associated with ammonia production from such processes as protein breakdown and illustrated by ammonia-based cleaning compounds.
With respect to seal, seal flesh consisting of meat, pieces of meat or minced seal which has been frozen in a uniform rectangular shape.
Calcified skeletal material derived from seal.
With respect to seal, seal in which the processor has removed all bones or bone chips.
A process by which seal is changed from the frozen state to a thawed state under controlled time and temperature conditions such that the internal product temperature does not exceed 4°C after the thawing has been completed.
A white or yellowish abnormality on the surface of frozen seal which masks the colour of the flesh and penetrates below the surface. This defect caused by the sublimation process can only be removed with a knife or other sharp instrument.
Unhealthy condition of the animal's body or body parts.
Capable of being readily perceived (by sight, smell, touch or taste) through a sharp clear unmistaken impression, not blurred, obscured or indefinite.
The odour/flavour stimulus such as that associated with sewage.
Raw seal or minced seal which has not been changed to any other state by freezing, cooking etc.
Seal that has been changed from the fresh state to that in which the thermal centre of the product has been frozen to a temperature of -21°C or colder.
Hydrogen Sulphide
The odour/flavour stimulus associated with rotten eggs. A reference is hydrogen sulphide gas.
Minced Seal
Particles of seal flesh that have been ground from clean, sound material free from internal organs.
A wooly or furry growth of minute fungi.
Oxidized oil
The odour/flavour stimulus associated with the oxidation of fats or oils.
Existing without significant change; not fleeting.
Product consisting of seal meat and other non-seal ingredients such as fillers and spices.
The odour/flavour stimulus associated with the advanced decay of protein.
The odour/flavour/colour stimulus associated with oxidized fat or an oil.
A localized spot on the flesh usually with tissues ruptured or abraded and usually with infection.
The odour/flavour stimulus associated with acidic compounds such as vinegar and characterized by a pungent sensation.
A swollen, abnormal mass of tissue.
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