Audit of Polish fish checks highlights areas for improvement

Poland has a solid system to monitor fish product safety but its effectiveness is weakened by issues with training and Listeria sampling.

An audit by DG Sante took place in May and June 2024 to evaluate the control system for fishery products. Six recommendations were made. The last audit on the topic was in 2020.

DG Sante said Poland has developed a comprehensive control system covering the fishery production chain which is mostly well implemented and effective.

However, there were shortcomings around food safety aspects at aquaculture farms, the training of veterinarians and of officials who assess food businesses’ environmental sampling plans for Listeria monocytogenes, and the management of raw material from certain catch zones in the Baltic Sea with high levels of environmental contaminants.

Examples of issues identified
Since 2020, members of the Rapid Alert System for Food and Feed (RASFF) network issued 42 reports involving fish products processed in Poland. They included 32 for Listeria monocytogenes with a decrease from 16 in 2021 to three in 2023.

During visits to facilities handling fish products, the audit team noted shortcomings that were not detected by official controls.

In one establishment, requirements for thawing of raw histamine sensitive material before smoking were not respected as fish was thawed at ambient temperature. Dioxin hazards were not reflected in HACCP analyses and the raw material specifications.

In one site producing raw salmon, the environmental sampling to detect Listeria monocytogenes was not in line with EURL guidelines on sampling the food processing area and equipment. Samples were taken before production, on clean food contact surfaces, and not during processing. The operator stated that salmon is exclusively not ready-to-eat (RTE) and is in need of further cooking when purchased. However, there was at least one customer producing RTE fishery products using this salmon as a raw material.

In 2021, 2022, and 2023 fishery products were tested for microorganisms. Results showed 62, 36, and 16 positives, respectively. One cadmium and lead non-compliance was found in 2023.

The 2020 audit report described how businesses were allowed to keep frozen products for up to three months at above -18 degrees C (-0.4 degrees F). This practice is called stiffening and was said to be a necessary step in the production of some smoked salmon products. Operators have since adapted their facilities, working process and HACCP systems so the stiffening process does not exceed 92 hours.

Update to EU rules
The European Commission has also updated a piece of regulation relating to countries and their approved control plans for pharmacologically active substances, pesticides, and contaminants.

Brazil and Thailand submitted a plan for eggs while Singapore has provided one for crustaceans.

Armenia expressed interest in starting exports of finfish and finfish products. A control plan covers these products such as caviar and roes. 

New Zealand has not submitted a control plan concerning equine animals, because of the absence of equine production.

Kazakhstan has submitted a plan for honey which provides the required guarantees and should be approved, said the EU Commission.

The United Arab Emirates informed the EU Commission that it is not interested in exporting honey to Europe. Brunei and Costa Rica do not want to export composite products manufactured using processed milk or processed egg products to Europe. This has prompted a change in the annex of the legislation.

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Source: https://www.foodsafetynews.com/2025/03/audit-of-polish-fish-checks-highlights-areas-for-improvement/