Processing connotes a change from the natural state of the marine
product and first processing would constitute the first operation or
series of continuous operations that effectuate this change. It appears
that the first processing operations ordinarily performed on the fishing
vessels at sea consist for the most part of eviscerating, removal of the
gills, beheading certain fish that have large heads, and the removal of
the scallop from its shell. Icing or freezing operations, which
ordinarily immediately follow these operations, would also constitute an
integral part of the first processing operations, as would such
activities as filleting, cutting, scaling, or salting when performed as
part of a continuous series of operations. Employment aboard the fishing
vessel in freezing operations thus performed is within the exemption if
the first processing of which it is a part otherwise meets the
conditions of section 13(a)(5), notwithstanding the transfer by the 1961
amendments of ``freezing'', as such, from this exemption to the
exemption from overtime only provided by section 13(b)(4). Such
preliminary operations as cleaning, washing, and grading of the marine
products, though not exempt as first processing since they effect no
change, would be exempt as part of first processing when done in
preparation for the first processing operation described above including
freezing. The same would be true with respect to the removal of the
waste products resulting from the above described operations on board
the fishing vessel.
