Boat Direct Consulting


Your Freezing Game Plan: Lotting for Traceability

Salmon fisheries are open up and down the West Coast. It's a wonderful and productive time for many fishing communities, and possibly the best time to invest in freezing some of your catch. In the past few years, which have been lean, California King salmon easily find a fresh market. Boat prices have been high and have made freezing cost prohibitive in most markets. It is possible that in this upcoming extended period of commercial fishing, prices may drop and catch levels may rise, making freezing a viable option for future direct sales. Alaskan fishermen and brokers typically rely heavily on freezing due to geographic isolation and high catch volumes. I always advise clients to run the numbers on their product before investing in processing and freezer storage. Frozen product costs more than fresh to produce after accounting for processing labor, packaging, and frozen storage fees. It’s important to make sure that the market will support selling frozen product at a profit. Who wants to take a loss after all of that additional work? Just because a large processor decides to freeze a lot of salmon doesn’t mean that a small fishing operation can make a profit on frozen product. The big guys are accessing different markets and their labor costs are likely much lower than a small producer’s will be. Run the numbers for your operation before committing. If you need help navigating this, get in touch, I’m happy to walk you through it.

If freezing is a good choice for your catch, it’s important to be intentional with the way you organize your stored frozen product. You are required to be able to recall your product, and in order to do that you need to properly label the product you store. This is where lotting strategy comes in. Lot numbers are the labeling and tracking system that is used to trace sold product back to its source and forward to customers. It can be as simple as a packing date or as sophisticated as a multi-digit alphanumeric code that traces back to a particular offload and processing time. For small to mid-sized operations, a processing date is often enough. No matter which path you choose, it’s important to make some decisions ahead of time that make lotting painless and potentially useful to you in the marketing of your product.

Planning Your Lotting Strategy

1.     Establish your lot size. There are a couple of ways to approach this. Pick one and stick with it.

  • Each offload. Each offload will have its own lot code. This is usually the offload date plus a number or abbreviation that links back to the vessel. I prefer an abbreviation over a number because you will recognizer the vessel name without needing to reference a numerical code sheet. ie: 072618BADG for fish offloaded on 7/26/18 from F/V Badger. If you are a single vessel operation, you can simply use your offload date.
    • Upside: Boat traceability! You can accurately and easily trace your frozen product back to the vessel and offload. This is very helpful for marketing and recalls.
    •  Downside: Mixed cases. One case of product can have multiple lot numbers as it may take multiple offloads to complete a case of product.
  • A set number of cases or pounds. A lot can equal x number of cases of frozen product or x number of pounds. ie: The first 50 cases are lot 001, cases 51-100 are lot 002 and so on.
    • Upside: It’s easy and you never have to worry about one case having multiple lots.
    • Downside: No traceability to the offload date or boat, so you will need to maintain a “key” to your lotting system that connects the lot numbers to offload or processing dates.
  •  Each processing day. Everything processed and frozen on a day is lotted with that date. ie: Fish frozen on 7/26/18 is lotted 072618 or 7/26/18.
    • Upside: Easy recalls.
    • Downside: You might need to recall more than necessary if the recall is triggered by the fishery rather than the processor. You will need to maintain records connecting offload dates and vessels to processing lot dates.

2.     Choose your Lotting System: Transparent  or Coded?

  • Transparent: Use the date for the date.
    • Upside: Transparency. Your customers know exactly when fish was caught/processed.
      • Downside: Security. Larger firms (Think HUGE processing facilities.) prefer to disguise dates to avoid providing information to people wishing to do harm. This is likely not a concern for small operations.
  • Coded: Establish a coding system that represents dates/times/vessels, whichever information you have decided to include. Some firms prefer Julian Dating. ie: G6211 for 7/26/18. You can pretty much make up any system you want as long as you document a “key” for your system and keep it accurate and consistent.
    • Upside: Privacy. Only you will know where that fish truly came from.
    • Downside: Lack of transparency and an insane amount of record keeping.

3.     Design your lot label and decide where it goes on your case.

  • Figure out what size label and what material/ink needs to be used. You can keep it as simple as writing your lot numbers on your cases with a Sharpie. You can also add lot numbers to your existing product labels.
  • Pick a location on your cases for your lotting information and stick with it. There’s honestly nothing worse than shivering in a freezer while you flip over hundreds of cases looking for a specific production lot. Consider palletization when choosing a label location. Ideally you want to see as many labels as possible when cases are palletized.

4.     Decide if lot numbers will be printed or written on your invoices.

  • DO THIS. It is as simple as recording your code from the case onto your invoice. This closes the traceability loop and allows you to easily manage recalls should they arise.
  • If you choose not to do this, you need to maintain internal records of which lot numbers went to which customers in order to be able to perform recalls.

5.     Put it all in Writing

  • Create a document outlining how you address each of the above questions.
  • EXAMPLE: ABL Fish Co. lots all frozen seafood by offload date and catch vessel. We use a six digit date separated by dashes with a four letter all caps abbreviation for the catch vessel. We maintain a key of vessel abbreviations. Lot numbers are printed on all case labels, which are applied to the top and right side of each case. ie: The lot number for fish offloaded on 4/1/16 by F/V Theo B would be 04-01-16THEO  Lot numbers are recorded on all outgoing invoices.

This is a process that can seem unnecessary and overwhelming, but I promise that it is well worth the small headache up front to avoid the agony  of a recall that you cannot properly perform. The FDA now requires a recall plan for processors of all sizes. If you have a HACCP plan you need a recall plan, and if you need a recall plan you need to lot your product.

Overwhelmed or confused? Get in touch for a free consultation and we can get you on the right track.

Am I a Processor?

I get asked this question a lot, mostly because it dictates the level to which you are regulated by local, state, and federal agencies. Many small-scale producers are surprised to find out that the answer is yes, according to regulators. Offloading, holding, and transporting fish is considered “processing” if you are engaged in sales to anyone other than an end user. That means that you are a processor if you sell to restaurants or retail markets, even if you never cook a crab or fillet a fish. HINT: If anyone has EVER asked you for a HACCP letter, you are most likely a processor.

(k)(1) Processing means, with respect to fish or fishery products: Handling, storing, preparing, heading, eviscerating, shucking, freezing, changing into different market forms, manufacturing, preserving, packing, labeling, dockside unloading, or holding.

(2) The regulations in this part do not apply to:

(i) Harvesting or transporting fish or fishery products, without otherwise engaging in processing.

(ii) Practices such as heading, eviscerating, or freezing intended solely to prepare a fish for holding on board a harvest vessel.

(iii) The operation of a retail establishment.
— CFR 21 Part 123.3

The way the regulations are written can be confusing. You do NOT need a HACCP plan for any action you perform on board a vessel and you do not need HACCP plans if you are a retail store. If your situation is unclear, get in touch for a free compliance review and I can point you in the right direction. 

Okay, so you're a processor, now what? Well, you are held to a higher food safety standard. Meet our old pal 21 CFR part 123. In fact, you are now required to have HACCP plans for everything you sell as well as written sanitation monitoring, staff training records, and a recall plan. The good news is that there's a lot of open-source HACCP information out there, the bad news is that you are legally obligated to monitor anything you list on your HACCP plans as a Critical Control Point (CCP). I've reviewed many HACCP plans that go overboard, committing a fisher to a crazy amount of unnecessary documentation. It makes sense to have an expert review your plans should you choose to create them yourself prior to implementation.

The goal of a good HACCP plan is to properly identify and fully address CCP's while not committing to processes and documentation that are not part of the regulations. You will very likely go above and beyond your HACCP plans in your day to day operations for the sake of quality, but you do not want to list quality control measures in your plan. Why? Anything you list in your plan must be documented and that documentation must be reviewed within seven days of its creation. You also must provide verification of your CCP's via a scientific study or an excerpt from the Fish and Fisheries Products Hazards and Controls Guidance. Essentially, anything you put in your HACCP plan is going to generate paperwork and suck up your time, so you only put in what is necessary. It is common for a well-organized processor to have a HACCP plan that addresses the 21 CFR Part 123 requirements and other internal documents and Standard Operating Procedures that fully outline all quality control measures taken. When it comes to seafood HACCP, keeping it simple is always best.

If you suspect (Or know.) that you are a processor and you are lagging on your compliance paperwork, it's not too late to get compliant. It's always best to get your systems in place before you get a citation or even worse, an order to stop production. As you can tell, I love talking about this stuff. Get in touch and I can help you get on track.