How I Use the Sushi Products Template with Customers in Pilla

I'm Liam Jones, NEBOSH-qualified health and safety consultant, Level 3 Food Safety, and founder of Pilla. This is how I approach sushi products policies in a food safety management system, based on close to twenty years in frontline operations and advising hundreds of businesses on compliance. You can email me directly; I read every email.

Raw fish is the highest-risk category of food most kitchens will handle. There's no cooking step. No heat to kill parasites or bacteria. If something goes wrong during preparation, the customer eats the problem. I've reviewed sushi operations where the written procedures were solid but the prep team were pulling three fillets out of the fridge at once and losing track of which one had been out longest. The gap between what's documented and what happens at 12:30 on a Saturday is where incidents come from.

That's what this article covers. I'll walk you through the controls your sushi products policy needs, give you a template you can edit for your own kitchen, and explain the parts that matter most when an EHO is watching your team work the sushi station.

Key Takeaways

  • What are sushi products in food safety? Sushi and sashimi are high-risk ready-to-eat foods served without a cooking step. Your policy needs to cover parasite freezing, approved suppliers, time and temperature control during preparation, and corrective actions when limits are breached
  • Why do you need a sushi products policy? Regulation (EC) 852/2004 requires controls for ready-to-eat foods, and fish served raw carries specific parasite, scombrotoxin, and bacterial risks that demand tighter handling rules than cooked dishes
  • How do you set it up in Pilla? Use the knowledge hub template below, edit it to match your operation, and share it with your team through the app so everyone has access and you can track who's read it
  • How do you automate the follow-up? Set up Poppi to chase staff who haven't acknowledged the policy and flag when it's due for review

Article Content

Understanding What's Required of You

Sushi and sashimi are ready-to-eat foods with no cooking step. That single fact changes everything about how you handle them. With cooked food, heat is your safety net. With raw fish, you don't have one.

There are three specific hazards that your policy needs to address. Parasites live naturally in fish and are harmful to humans. Cooking kills them, but since you're serving the fish raw, a prior freezing step at -20°c for at least 24 hours is the legal alternative. Without that freezing step, you're serving parasites to your customers. Scombrotoxin is the second hazard. At temperatures above 4°c, certain fish (tuna, mackerel, sardines) start producing histamines. Those histamines cause scombrotoxic fish poisoning, which presents like a severe allergic reaction. The critical thing to understand is that heat doesn't destroy histamines. Once they've formed, cooking the fish won't help. The third hazard is straightforward bacterial contamination. Any bacteria transferred from hands, surfaces, or equipment during preparation will be consumed by the customer.

The legal basis sits in Regulation (EC) 852/2004, which requires food business operators to put controls in place for ready-to-eat foods. For raw fish specifically, that means approved suppliers with HACCP procedures, documented parasite freezing, delivery temperatures at 4°c or below, and strict time controls during preparation.

Your EHO will look at this closely. I've been present during inspections where the officer stood at the sushi station and timed how long the fish was out of the fridge. They'll ask to see your parasite freezing certificates, your delivery temperature records, and your discard logs. If you can't produce those documents, you have a problem. If your staff can't explain the 20-minute preparation window, you have a bigger one.

The standard that catches most businesses out is the time control. Each fillet gets a 20-minute window from fridge to finished preparation. The absolute maximum out of refrigeration is one hour, and that's a discard point, not a target. I've worked with kitchens where the team thought "one hour" meant they had an hour to work with. They didn't understand that 20 minutes is the working window and one hour is the point at which you throw the fish away.

Setting It Up as a Knowledge Hub Entry

I've built a sushi products template in Pilla covering hand hygiene, approved suppliers, parasite freezing for tuna and salmon, delivery checks, storage requirements, fish cutting and maki preparation, corrective actions, and record keeping. It gives you a structured starting point, but you need to edit it to reflect your own operation.

In the knowledge hub, create a new entry and tag it with "Food Safety Management System". Use the same tag across all of your food safety policies so they are grouped together and Poppi can track them as a set. Assign the entry to all teams so that everyone in the business can access it.

The template is designed to be edited, not just filed. If you only serve salmon and not tuna, adjust accordingly. If you have a dedicated fish fridge, say so. If your supplier provides farmed Atlantic salmon and you're relying on that rather than freezing certification, document that specifically. The EHO wants to see that your policy describes what actually happens in your kitchen.

Knowledge Hub Template·Sushi Products

Tuna that is served raw as a ready to eat (RTE) product is classified as "high risk" and must be stored and handled appropriately to reduce the risk of contamination and multiplication of bacteria.

Tuna tartare and ceviche undergoes minimal processing and so must be handled with extreme care.

Staff must undergo extra training to understand the risks with raw fish, extra supervision should also be given until staff are confident and competent.

Staff must exercise strict diligence when handling raw fish products and follow the safety points below to ensure a consistent level of safety is achieved.

Safety points

Hand and personal hygiene

  • Staff must ensure strict levels of hand hygiene when preparing sushi and sashimi
  • High standards and regular occurrence of hand washing will remove harmful bacteria to safe levels, helping to prevent the transference of pathogenic bacteria to food

Suppliers

  • Fish must only be purchased from reputable approved suppliers who can give quality and safety assurances and have robust HACCP procedures in place in regard to storage and delivery
  • Delivery notes must be retained for all fish products to ensure traceability

Tuna special conditions and requirements

  • Tuna which is to be served raw must firstly be frozen for a minimum of 24 hours at -20°c or lower by the supplier
  • Written confirmation and certification of this freezing process must be obtained by the supplier
  • Parasites which naturally live in tuna but are harmful to human health must be removed by prior correct freezing method if fish is intended to be served raw or lightly cooked
  • Tuna must never be taken from alternative suppliers unless prior permission has been given by head office, where written confirmation and certification has been provided by the supplier

Salmon special conditions and requirements

  • Salmon which is to be served raw must be frozen for a minimum of 24 hours at -20°c or lower by the supplier
  • Written confirmation and certification of this freezing process must be obtained by the supplier
  • Or confirmation must be obtained from the supplier that the fish is farmed Atlantic salmon
  • Salmon must never be taken from alternative suppliers unless prior permission has been given by head office, where written confirmation and certification has been provided by the supplier

Delivery

  • All raw fish must be delivered on ice within or at a maximum temperature not exceeding 4°c in a container that ensures a temperature of near freezing is maintained
  • It is essential that delivery checks are taken on all deliveries of fish, most importantly temperature checks to ensure fish is being supplied at safe temperatures and that the integrity of the packaging and ice is compliant with the standard expected
  • Deliveries must be rejected if any of the above conditions are unsuitable or there is insufficient shelf life on the product
  • Staff should understand that at temperatures above 4°c, fish start to spoil and these spoilage organisms can cause changes in the fish causing the fish to produce histamines which can lead to scombrotoxic fish poisoning, a serious illness with symptoms similar to a severe allergic reaction

Storage

  • Ready to eat items must never be prepared in the designated fish section
  • If possible, the provision of a designated fridge for raw fish will help to ensure that cross contamination does not occur
  • If no designated raw fish fridge is available, then fish must be stored in a standard fridge below ready to eat foods but above other raw items such as raw meats

Preparation - fish cutting

  • During salmon preparation the fillet is checked for bones, any found to be present are removed with tweezers
  • Fish bones can render the food unfit for consumption as they can cause physical injury to the consumer
  • Only one salmon or tuna fillet is to be removed from refrigeration and cut at any one time
  • Each fish must be prepared within a 20-minute window then returned promptly to refrigerated storage below 5°c
  • Any trimmings which are not used should be kept in a small gastronorm and disposed of at regular intervals

Preparation - maki

  • Salmon is removed from the refrigeration and placed in the small gastronorm wells to ensure that excessive amounts are not left at ambient temperatures
  • Salmon used in maki must be prepared within 20 minutes and must not be out of refrigeration for longer than one hour
  • Any remaining maki in the gastronorm should be discarded after one hour
  • Salmon maki must be prepared and placed into refrigeration or served to customers within 20 minutes

Sushi and sashimi preparation

  • Small quantities only of tuna or salmon should be removed from refrigerated storage at a time
  • Tuna and salmon are to be prepared within a 20-minute window and must not be out of refrigeration for longer than one hour

Corrective actions

  • Fish that is supplied must be on a bed of ice and arrive at a temperature no higher than 4°c
  • Designated fish storage refrigerators with a digital reading showing air temperature in excess of 5°c requires that the internal temperature of the unit be taken with a fridge thermometer. If after 30 minutes the temperature is still above 5°c, then the temperature of the food must be taken with a calibrated probe thermometer. If the product is 5°c or above but below 8°c, then the fish temperature must be monitored closely for 30 minutes and if it is still above 5°c then it must be discarded
  • Any fish found to be above 8°c must be discarded
  • All faults to refrigerators must be reported immediately and engineers called
  • Sushi and sashimi products must be prepared within 20 minutes. If sushi (fish) is out of temperature control for more than 20 minutes, continue to monitor the time it takes to make the sushi (fish) and sashimi and if out of temperature control for longer than one hour the sushi (fish) and sashimi products must be discarded
  • If staff do not follow the safety points above, then they must be retrained in safe methods
  • Retrain staff if required and increase supervision until competency can be shown

Record keeping

  • Record fish deliveries that have been rejected stating reasons and any corrective actions subsequently taken
  • Record temperatures of the fish storage fridge at regular intervals
  • Record temperatures of display fridges at regular intervals
  • Keep a record of waste or discarded products and the reason why discarded
  • Keep records of any contraventions of the above safety points and any corrective actions taken
  • Record any training or retraining undertaken

This is a preview of the template. In Pilla, you can edit this to match your business.

What I'd want to see when reviewing this:

The parasite freezing section is the part I check first. You need written confirmation from your supplier that tuna has been frozen at -20°c for a minimum of 24 hours. For salmon, you need either the same freezing certification or confirmation that the fish is farmed Atlantic salmon. Without one of those documents, you can't serve the fish raw. I've reviewed businesses that had been open for months without ever requesting this paperwork from their supplier. That's a serious gap.

The 20-minute preparation window needs to be understood by every member of staff who touches raw fish. One fillet comes out of the fridge at a time. You prepare it within 20 minutes. It goes back into refrigeration or onto the plate for immediate service. For maki, the salmon goes into small gastronorm wells so you're not leaving large quantities at ambient temperature. Any fish out of refrigeration for longer than one hour gets discarded. No exceptions based on how it looks or smells, because histamines are invisible.

The delivery section should specify rejection criteria: temperature above 4°c, damaged packaging, insufficient ice, inadequate shelf life. Your team needs to know that rejecting a delivery is the right call, not something that gets them in trouble with the kitchen.

Common mistakes I see:

The most common mistake is pulling multiple fillets from the fridge at the same time. Each fillet starts its own 20-minute clock, and once you have two or three out, nobody can remember which one came out first. One fillet at a time is the rule.

I regularly see businesses that accept fish deliveries without checking for parasite freezing certification. The supplier might have the documentation, but if you haven't asked for it and can't produce it during an inspection, it's the same as not having it.

The corrective actions section is often missing detail on what to do when fridge temperatures drift. If your fish storage fridge reads above 5°c, you need a defined process: wait 30 minutes, recheck, probe the food if still above 5°c, and discard anything at or above 8°c. Writing "check fridge temperatures" without specifying what happens when they're wrong isn't a corrective action.

Trimmings get forgotten. Offcuts sitting in a gastronorm on the prep bench are still raw fish, still warming up, still on the clock. They need to be disposed of at regular intervals, not left to accumulate through a busy service.

Automate the Follow-Up with Poppi

Writing the policy is one thing. Making sure your team has actually read it is another. Poppi can handle the chasing so you don't have to.

If you mark the knowledge hub entry as mandatory, Poppi will track who's read it and who hasn't. You can set up automations to chase staff who are behind, notify managers when someone completes the policy, and get a regular report showing where the gaps are.

Here are three automations I'd set up for any knowledge hub policy:

Overdue training reminders

Automatically chase team members who have mandatory policies they haven't read yet. Poppi sends the reminder so you don't have to.

Poppi
Poppi

Tom, you have 2 overdue policies to read and acknowledge

Video completion alerts

Get notified when a team member finishes reading or watching a policy, so you can track progress without chasing.

Poppi
Poppi

Emma has completed a mandatory policy

Training gap analysis

Get a regular AI report showing which team members are behind on mandatory policies and where the gaps are across your team.

Poppi
Poppi

Training Report: 87% team completion. Tom and Sarah behind on 2 mandatory policies, due 3 days ago.