Council on Food Safety and Environmental Hygiene
of Vibrio Cholerae in Retail Fish Stalls and
Quality of Fish Tank Water
This paper briefs Members on (i) existing control and monitoring of
seawater in fish tanks used for keeping live seafood, (ii) investigations into
recent incidents of discovery of Vibrio cholerae in retail fish stalls, and
(iii) further measures taken/to be taken to promote fish tank water quality and
CONTROL AND MONITORING SYSTEM
Under section 10A of the Food Business Regulation (Cap 132 sub leg X), no
person shall in the course of any food business keep any live fish or shell fish
intended for human consumption in water of a quality below the standard
specified by the Director of Food and Environmental Hygiene by notice published
in the Gazette. The specified
standard is ��E. Coli less than 610 per 100ml and absence of pathogenic
organisms��. Anyone in breach of
the provision is liable to a maximum fine of $10,000 and imprisonment for three
months upon conviction.
Arrangements for Inspecting Retail
In accordance with the licensing
requirements/conditions and market tenancy conditions of Food and Environmental
Hygiene Department (FEHD), licensed food premises and market stalls are required
to install proper filtration and disinfection facilities to filter and disinfect
water used for keeping live marine fish or shell fish intended for human
are also prohibited from using flushing water for keeping live marine fish or
shell fish. Supermarkets and fresh
provision shops selling live marine fish are covered by FEHD��s inspection.
FEHD officers inspect market fish stalls once every eight weeks.
As for supermarkets, fresh provision shops and restaurants, the
inspection frequency will depend on the risk classification of the premises
concerned, ranging from once every four weeks for premises with higher risks to
once every 12 weeks for premises with lower risks.
During inspections, FEHD officers check, among other things �V
whether proper filtration and disinfection systems are installed;
whether these systems are working properly;
whether flush water is used for keeping live marine fish/shell fish; and
whether the fish tanks and their surroundings are clean.
FEHD officers also remind operators to
arrange regular cleansing and maintenance of the filtration and disinfection
From January to August 2003, FEHD issued 121 verbal warnings and two
written warnings for breach of licensing requirements/conditions and tenancy
conditions in relation to the quality of fish tank water.
Irregularities were all rectified subsequently.
In addition to routine inspections, FEHD collects water samples from all
licensed food premises, including supermarkets, and seafood stalls for E. Coli
testing once every eight weeks. Separately,
two samples are collected for Vibrio cholerae testing every year, of which one
is taken between June and August. Inspection
of filtration and disinfection facilities will also be conducted when water
samples are taken.
From January to August 2003, a total of 9,404 fish tank water samples
were taken. 140 samples were found
to contain E. Coli exceeding the legal limit of 610 per 100 ml.
Another two samples (i.e. one from a market fish stall in Tokwawan Market
and another one from a supermarket in Pok Fu Lam) were found to contain
pathogenic Vibrio cholerae. Details
of these two cases are provided in paragraphs 11 to 15.
for the Trade
Following a comprehensive review on the control of fish tank water for
keeping live seafood in 2002, FEHD drew up and issued detailed guidance notes to
seafood operators to apprise them of the proper procedures for four common
disinfection methods and management practices that should be observed for better
quality control of fish tank water. Briefing
sessions were also conducted and relevant pamphlets distributed to the seafood
operators and suppliers of filtration and disinfection facilities.
Furthermore, FEHD issued letters to fish tank water suppliers to remind
them of the measures that they should adopt to ensure the quality of seawater
delivered to seafood premises.
on Prevention of Cholera infection
Apart from the inspection, surveillance and sampling measures in place,
we have all along attached great importance to public education on personal and
food hygiene in preventing cholera infection from seafood. Educational measures include organisation of regular seminars
and talks on food hygiene for the food trade, the general public and target
groups such as domestic helpers and school children; distribution of publicity
materials to the public and stakeholders; publication of relevant articles on
the Food Safety Bulletin; dissemination of preventive tips through FEHD��s
telephone hotline system, broadcasting van, website and press releases.
Every summer, educational pamphlets are issued to seafood operators and
fish tank water suppliers to remind them of the measures that should be taken to
ensure quality control of fish tank water.
Recent Cases of Vibrio
Recently, two cases of presence of Vibrio cholerae in retail fish stalls
were discovered by FEHD through its monitoring and surveillance system.
The following is a brief account of the background and current position
of these two cases.
Case 1: Fish Stall at Tokwawan
A water sample taken from a fish stall inside Tokwawan Market on 20
August 2003 was found to contain Vibrio cholerae O1 El Tor serotype Ogawa.
The stall was ordered to close on 26 August 2003 under section 128C of
the Public Health and Municipal Services Ordinance (Cap 132).
Subsequent to the closure, FEHD took environmental swabs from the stall
and water samples from the stall��s supplier at Lei Yue Mun.
No virulent pathogens were found from the swabs/samples.
It was noted that the ultra-violet disinfection system was not
functioning properly when the initial water sample was taken on 20 August 2003.
The tenant concerned installed a new ozone disinfection system after the
closure of the stall. Water samples taken on 1 September 2003 indicated the absence
of virulent pathogens. These
preliminary investigation findings suggest that the presence of Vibrio cholerae
in the water sample taken on 20 August 2003 might be caused by the
malfunctioning of the ultra-violet disinfection system.
Case 2: Supermarket
Fish Stall in Pok Fu Lam
A water sample taken from a fish stall inside a supermarket in Pok Fu Lam
on 26 August 2003 was found to contain Vibrio cholerae O1 El Tor serotype Ogawa. The stall was ordered to close on 1 September 2003.
Subsequent to the closure, FEHD took environmental swabs from the stall
and water samples from the licensee��s supplier at Apleichau.
FEHD is still in the course of detailed investigation and will not allow
the fish stall to re-open until the Department is completely satisfied that the
hygienic conditions there would not pose any risk to public health.
Meanwhile, FEHD will take water samples from the re-opened fish stalls of
the supermarket chain for laboratory tests.
Control Measures to Promote Fish Tank Water Quality and Seafood Safety
In the wake of the recent discovery of Vibrio cholerae in two retail fish
stalls, we have revisited our surveillance programme and control measures in
relation to quality control of fish tank water.
In the interest of protection of public health and seafood safety, FEHD
has stepped up inspection of live fish wholesale outlets and collected water
samples for laboratory tests from individual stalls. Once the presence of highly infectious cholera bacteria is
detected, FEHD will close the premises concerned on health hazard grounds under
the authority conferred by section 128C of the Public Health and Municipal
Services Ordinance (Cap 132).
Concurrently, the Agriculture, Fisheries and Conservation Department (AFCD)
has implemented a water quality monitoring programme for live fish wholesale
stalls under management of the Fish Marketing Organisation (FMO).
This programme includes -
taking of water samples from wholesale stalls for testing of Vibrio
requesting all live fish stallholders to install filtration and
disinfection system to reduce the bacterial concentration in fish tank water;
educating live fish stallholders on how best to source fish tank water
and to arrange filtration and disinfection, thereby ensuring compliance with the
The Administration��s surveillance and enforcement in respect of seafood
safety has hitherto placed emphasis on the retail level.
Retailers selling fish are required to hold a valid licence issued by
FEHD and to comply with the licensing conditions. Such licensing requirements currently do not apply to the
wholesale level. As the hygienic
conditions and operations of wholesale fish stalls could also bear on seafood
safety downstream, we plan to introduce a licensing scheme whereby fish
wholesalers will be required to install sanitary fitments, drainage and
disinfection facilities in accordance with standards set by FEHD.
The licensing scheme will apply to both wholesale fish stalls managed by
FMO and those outside its purview.
In the light of public and media concerns about the hygiene, food safety
and venue management problems associated with the live fish wholesaling
activities conducted outside the FMO Wholesale Fish Market in Aberdeen, we are
working on practicable means of regularisation.
At a recent inter-departmental meeting convened by Health, Welfare and
Food Bureau and attended by representatives of FEHD, AFCD, Home Affairs
Department, Lands Department, Environmental Protection Department, Planning
Department, Marine Department, Transport Department, Architectural Services
Department and the Police, it was broadly agreed that the regularisation scheme
for the wholesale market at Aberdeen promenade should be able to -
result in orderly, hygienic, efficient and law-abiding wholesaling
operations of live marine fish;
provide a level playing field for the incumbent wholesalers at the
promenade and those operating inside the Wholesale Fish Market run by FMO;
pose strong incentives (or remove inherent disincentives) for the live
fish wholesalers to use fish tank water from a source that does not put public
health at risk;
contribute to reducing the risk of contamination by cholera or other
highly infectious bacteria of seafood/fish tank water connected with wholesaling
activities at the promenade;
provide effective solutions to long-standing district management problems
in respect of traffic congestion, carpark management, unauthorised use of
government land, environmental nuisances, marine littering, etc.;
ensure uninterrupted supply and distribution of live seafood to
communities now served by the unauthorised wholesale market; and
bring about tangible and visible improvements on the ground, thereby
enhancing the attractiveness of the promenade area as a tourist spot.
The inter-departmental group will consult the Southern District Council,
the local community, the incumbent wholesalers and other interest groups
involved on the details of the scheme.
The Administration recognizes that quality assurance of fish tank water
is just one of the aspects in ensuring the seafood offered for sale at retail
outlets and restaurants are fit for human consumption.
For the longer term, we will review the adequacy of existing legislative
framework and regulatory measures with respect to surveillance, examination and
sampling of seafood in the food distribution chain.
In the review process, we will seek expert opinions from local healthcare
and veterinary professionals and draw on international best practices as
Welfare and Food Bureau
and Environmental Hygiene Department
Fisheries and Conservation Department