What was the cannery’s starting point?
The cannery was compliant with the sanitary authority but not ready for a BRCGS audit. The case presented here is a typical case: it brings together situations our teams meet in the canneries of Safi and Agadir, two port cities on Morocco’s Atlantic coast, without describing any specific client.
The site produces sardines in oil and in tomato sauce, plus a few mackerel lines. It exports to Europe and the United Kingdom. Its British customer, an importer supplying the retail trade, announces that it will require a BRCGS Food Safety certificate to renew the contract. A European prospect sets the same condition.
What the gap analysis found:
- an ONSSA sanitary approval in place, issued by Morocco’s national food safety office (Office national de sécurité sanitaire des produits alimentaires), with a HACCP plan that follows Moroccan regulations, in particular Law 28-07 on the safety of food products;
- a sound HACCP plan on sterilisation, but designed for inspection, not for the audit of a GFSI standard;
- scattered documentation, partly in French, partly missing;
- no food safety culture plan and no food fraud vulnerability assessment;
- old infrastructure in the receiving and heading area, with floors and drains to be redone;
- a largely seasonal workforce, trained on the job.
ONSSA sanitary approval is the regulatory prerequisite for exporting to the European Union; ONSSA publishes on its website the list of approved fishery products processing establishments. BRCGS, for its part, is a commercial requirement that comes on top of that foundation.
Which risks must a fish cannery control for BRCGS?
A fish cannery combines severe microbiological hazards, a chemical hazard specific to fish and packaging risks. The BRCGS auditor naturally concentrates on these points.
Hazard or risk | Where it arises | Expected control | Evidence to show the auditor |
|---|---|---|---|
Survival of Clostridium botulinum | Sterilisation | Schedule validated per can size and per product | Validation study, records of every cycle, probe calibration |
Loss of seal | Seaming | Seam checks at a defined frequency | Check sheets, measurements, actions when a drift occurs |
Recontamination after sterilisation | Cooling | Cooling water treated and monitored | Chlorination records, analyses |
Histamine | Fish receipt and storage | Temperature control from landing, tests at receipt | Temperature logs, test results, acceptance criteria |
Allergens | Sauces, fillings, oils | Allergen matrix, segregation, validated cleaning | Up-to-date matrix, cleaning validation, label checks |
Foreign bodies | The whole line | Detection suited to metal cans, control of glass and hard plastics | Check register, detector tests |
Fraud | Species, origin, oil | Vulnerability assessment, supplier controls | Documented assessment, control plan |
Traceability | From vessel to customer | Identification of lots of fish, oil, sauce and cans | Full, timed traceability test |
Two points demanded the most work in this typical case.
Histamine. Species such as sardine and mackerel form histamine if the cold chain is not maintained between landing and canning. The site tested histamine on finished product. The auditor expects upstream control: supplier requirements, temperature at receipt, a maximum waiting time and rejection criteria.
Allergens. Fish is itself a major allergen, but sauces bring others. A mustard recipe or a filling containing celery, for example, calls for a precise matrix and validated cleaning between production runs. Export labelling must also meet the rules of the destination country.
How was the support organised?
It followed the standard route of BRCGS support, adapted to the sardine season. The main constraint was not the documentation but the production calendar.
- On-site gap analysis during a production period, using the official BRCGS self-assessment checklist for Issue 9.
- Action plan approved by the managing director, with a specific line for the works in the receiving area.
- Training of the HACCP team, line leaders and future internal auditors, in French and Arabic.
- Revision of the HACCP plan to cover every product, including allergens in sauces and upstream histamine control.
- Introduction of the food safety culture plan, presented by management to the team leaders.
- Evidence produced over the season: sterilisation and seaming records, traceability tests, a recall test, internal audits.
- Full mock audit, then close-out of major gaps before the audit date was confirmed with the certification body.
This case study does not give a timeline by phase. In the projects we support, the observed duration ranges from 3 to 12 months depending on the starting point: maturity of the system, condition of the buildings, existing HACCP basis and availability of the team. For a cannery, the season adds a constraint, because the audit must take place during production. This is an observed range, not a guarantee.
The seasonal workforce called for a specific set-up: short training sessions on hiring, visual aids at workstations and checks of understanding by line leaders. The auditor interviews operators; a seasonal worker who started the week before must know what they check and why.
Two workstreams ran in parallel, because they depend on third parties.
Suppliers. The site buys its cans, ends, oil and tomato concentrate. Each went through a risk assessment, an approval procedure and performance monitoring. For cans, attention focused on suitability for food contact and on the packaging manufacturer’s certificates. For fish, the requirements cover temperature on board and at landing.
Site security. A cannery close to a port receives many carriers and contractors. The assessment of deliberate threats led to a review of access, visitor registration and the protection of sensitive areas such as the storage of oils and ingredients.
What made the difference on audit day?
Three things: a management team able to explain its approach, operators who talk about their checks, and evidence that is consistent from one document to the next.
In this typical case, the managing director presents the food safety culture plan and its first results in person. The sterilisation manager shows the schedule validation study and the records of a cycle chosen by the auditor. The traceability test is rerun in front of the auditor, on a lot picked at random, from the vessel to the customer. That is the level of control to aim for.
After the audit, any non-conformities are closed within 28 days, with corrective action, root cause analysis and preventive action, as BRCGS requires. The certificate is issued within 42 calendar days of the first audit day, if certification is granted.
What lessons for other canneries in Safi and Agadir?
The main one: start early, during a production season, and have the project led by management. Everything else follows from that decision.
For a buyer sourcing canned fish from Morocco, the same list doubles as a grid for questioning a supplier; ACG also carries out second-party supplier audits during the production season. The wider picture for seafood sites, from ONSSA approval to EU and UK market access, is on our seafood and canning sector page.
To understand the consultant’s role and the other BRCGS standards, read our complete guide to choosing a BRCGS consultant in Africa. To budget, see BRCGS consultancy cost, timeline and funding in Morocco, and for the method, working with a BRCGS consultant, step by step.