What was the cannery’s starting point?
A cannery in order on paper, with a HACCP plan that no longer described the plant. This typical case brings together situations met in canneries on the Atlantic coast; it describes no client, and its technical points are generic.
The site produces sardines in oil and in tomato sauce, in several can formats, during the sardine season. Establishments that produce, process and preserve fishery products are on the list of activities under sanitary approval annexed to Decree 2-10-473, the implementing decree of Law 28-07 on the safety of food products. As such, Article 34 of the decree requires the site to run an own-check programme in line with Moroccan standard NM 08.0.002 (HACCP), the standard that replaces it or an equivalent system. Approval is granted and monitored by ONSSA (Office National de Sécurité Sanitaire des Produits Alimentaires), Morocco’s national food safety authority.
Two deadlines fall in the same season: a regular sanitary inspection visit, which checks that the conditions of approval are still met (Article 16), and the audit of a European importer whose specification requires a HACCP plan in line with the Codex. Since Order 2010-25, published in the Official Bulletin (Bulletin officiel) on 15 January 2026, the visit may be carried out by an approved body to which ONSSA delegates it. The diagnostic found:
- a plan written before two can formats were added, which the validation file of the scheduled process did not cover;
- an own-check manual filed with ONSSA that still described the old line layout;
- a HACCP team reduced to the quality manager, with no one from production or maintenance;
- seam checks recorded per shift, without identifying the seamer or the head;
- histamine control limited to testing the finished product;
- chlorination of the cooling water measured, but not always recorded.
How did the team rework the hazard analysis?
By starting again from the shop floor. The team was widened to production, maintenance, the retort supervisor and the fish buyer, then the flow diagram was reconfirmed on the line, in the middle of the season, for every shift, as IFS Food Version 8 requires (2.3.5.1).
The corrected diagram brought out what the office had missed: the circuit of empty cans and ends, the cooling water, the possible wait between filling and seaming, cans rejected for defects, and storage of fish under ice when deliveries arrive together. The hazard analysis was then redone step by step, with its sources: site history, complaints, the requirements of the importer’s specification and the regulations of the country of sale.
Point of the plan | Before the review | After the review | Evidence prepared |
|---|---|---|---|
HACCP team | Quality manager alone | Quality, production, maintenance, retort, purchasing | Named list, training evidence (Decree 2-10-473, Article 63) |
Flow diagram | Drawn in the office, without water or empty cans | Confirmed on the line for every shift | Dated and signed diagram |
Sterilisation | One schedule for all formats | Schedule validated per format and per recipe | Validation file per product reference |
Seaming | Checks per shift | Checks per seamer and per head | Sheets per machine, destructive measurements |
Histamine | Finished product testing | Cold chain control from landing to filling | Supplier requirements, readings at receipt, sampling plan |
Cooling water | Chlorination measured, not recorded | Measurement recorded at a set frequency | Signed readings, action in case of deviation |
Sanitary file | Old manual | Manual updated with current lines and formats | Manual under version control |
The classification of each measure as a CCP, a control measure requiring greater attention or a good hygiene practice was written down and justified. The full method is described in our article on how to build a HACCP plan step by step.
How was the sterilisation CCP strengthened?
By matching each format and each recipe with a validated schedule, and each cycle with a record reviewed before release. Sterilisation is the step where the essential measure against the survival of spore-forming organisms, including Clostridium botulinum, is applied.
The scheduled process sets the time-temperature combination to be reached and the conditions under which it was validated: can format, recipe, fill, initial product temperature and retort loading pattern. These factors vary from one site to another; they come from the validation study, established by a person or body competent in thermal processing. BRCGS allows such external expertise, with day-to-day management remaining with the site (1.2.4), and requires each CCP to be validated with documented evidence (2.9.2). The two new formats were not produced until their schedule had been validated: BRCGS requires the plan to be validated prior to any change that may affect product safety (2.12.1).
Monitoring relies on the record of each cycle, read by the retort operator and reviewed by a competent person before the batch is released (BRCGS 2.10.2). Probes and thermometers are calibrated at defined intervals (IFS 5.4.2). If a cycle runs off-schedule, the batch is isolated and assessed by a person competent in thermal processing before any decision; the action covers all the product concerned (BRCGS 2.11.1).
How were histamine, seaming and cooling water dealt with?
As three complementary protections: histamine is controlled before the can, while the seam and the cooling water protect the can after the retort.
Histamine. It forms in certain species, including sardine, when the cold chain is not maintained between catch and filling, and sterilisation does not eliminate it. The revised plan sets requirements for suppliers on storage on board and at landing, a temperature measurement on each delivery, a sensory check, a maximum waiting time before processing and a sampling plan per lot. The acceptance criteria follow the regulations of the country of sale, cited in the hazard analysis. Finished product testing remains, but as verification.
Seaming. Visual checks are made at a defined frequency on each seamer and each head, and destructive checks measure seam dimensions against the specifications of the can and end manufacturer. The sheets identify the machine, the head, the time and the person checking. In case of deviation, the output since the last compliant check is isolated, the machine reset and the cans assessed. The supplier of cans and ends is approved and monitored.
Cooling water. Article 33 of Decree 2-10-473 requires that water used to cool hermetically sealed containers after heat treatment must not be a source of contamination. A seam defect can let cooling water into the can. Chlorination is measured and recorded at a set frequency, with a defined action on the water and on the batches cooled during the deviation.
Fish is itself an allergen that must be declared, and sauces may bring others: label checks at start-up and at each changeover were built into the plan.
How did the site prepare for the sanitary visit and the importer’s audit?
By preparing two readings of the same plan: the inspector’s, which checks compliance with the approval file and the decree, and the auditor’s, which picks a batch and traces the whole chain back.
Likely question | Who answers | Evidence |
|---|---|---|
Does the own-check manual describe the current lines? | Quality manager | Manual under version control, in line with point 3 of the ONSSA approval file |
Have the recommendations of the last visit been dealt with? | Management and quality | Report, closed action plan, visit register (Articles 23 and 24) |
What is the limit for this cycle, and what do you do if it drifts? | Retort operator | Displayed schedule, deviation procedure, cycle record |
Show me the seam checks for this batch. | Seamer setter and checker | Sheets per seamer and per head, destructive measurements |
Where did the fish in this batch come from, and at what temperature did it arrive? | Receipt | Receipt note, temperature reading, sampling plan results |
Are records kept? | Quality | Archives covering at least 5 years (Law 28-07, Article 9) |
Can you trace and withdraw this batch? | Quality and logistics | Traceability and withdrawal test carried out (Decree 2-10-473, Article 75) |
The legal framework behind each answer is detailed in our HACCP plan Morocco guide.
What lessons for other canneries?
A cannery’s HACCP plan is judged on three points: a validated schedule for each format actually produced, seams monitored machine by machine, and a cold chain under control before the can. The rest follows if production owns the plan.
The budget for this kind of rework, item by item, is set out in our article on HACCP plan cost. To move on to a certification required by retailers, see our case study of BRCGS certification for a fish cannery and our seafood and canning page.