Dear Group :
We would like your advice and opinions on a product that is being proposed
for export here in French Polynesia. It would be frozen tuna loins produced
in a land-base facility. This would not be an IQF product such as is now
produced on several of our longline tuna vessels (i.e. blast frozen, plastic
wrapped loins on board the vessel - all with HACCP and EU certification for
export). The proposed loins would be cut from fresh-chilled tuna, caught by
longline vessels (7 - 10 day trips, storage in ice in refrigerated holds).
Under a proposed HACCP plan, is it feasible (and authorized under FDA
regulations) to freeze these loins (av. wt 7 - 10 kg) in a reefer set at -
18° C rather than using a blast freezer ? Storage would of course be at
< -18° C thereafter. If this is the case, what is the maximum
time/temperature delay allowed to get the product from ambient to final
target temperature of - 18° C ? Given that this is not an IQF product, and
that the fresh product shelf life (depending on species and quality of
course) is at most 2 weeks from time of capture, can it still be considered
safe to freeze within the safe "best used before" date, or is there a time
limit after harvest (from time of catch - 5 days are recommended limit for
vacuum packed or processed products) for which such processing can be
allowed ? Are these tuna loins considered a processed product or a simple
transformed product ? In any case, I imagine we will have to perform
histamine analyses on a few lots before any export can be envisaged, since
this is the identified danger, through possible time/temperature abuse. For
labeling, other than not stating IQF, would there need to be special mention
for "frozen in a land-based facility" ? What would be the estimated (legal
?) time limit or "use by" date once the product is thawed and sold ?
I trust I have not burdened everyone, but I do appreciate your collective
wisdom and input.
Thanking you all in advance. Charles Daxboeck.
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