>From Ted Labuza
> Dear List
>
> I am currently doing a HACCP Plan for our land based Meal Plant which produces
> fish meal, fish oil and fish solubles from a variety of fish species. I am
> hoping someone can help me with some information about mercury.
>
> I know that potentially mercury could pose a food safety hazard for animal
> health as mercury is retained in the animals body and does not pass through
> their system. Due to the removal of water during processing would average
> mercury levels be increased in the fish meal, fish oil and fish solubles?
>
> Thnaks for your help.
>
> Regards
>
> Stella Stacey
>
>
>
> Stella Stacey
> Quality Assurance
> Independent Fisheries Limited
> Phone: +64 3384 3244
> Fax: +64 384 4650
> E-mail: stella.stacey@indfish.co.nz
>
>
Since the mercury is concentrated in the lipid, drying obstensively
increases the ppm on a total weight basis but remains the same on a fat or
solids basis. The tolerance for mercury (as methyl mercury) is found in GPG
540.600 which is 1 ppm in the edible portion. Thus the question why you dry
is that the edible portion. I think it would be so the concentration goes
up. This is similar to the argument used for increases in pesticide content
when drying.
The relevant text is:
Sec. 540.600 Fish, Shellfish, Crustaceans and Other Aquatic Animals - Fresh,
Frozen or Processed - Methyl Mercury (CPG 7108.07)
REGULATORY ACTION GUIDANCE:
The following represents criteria for recommending legal action to
*CFSAN/Office of Field Programs/Division of Enforcement (HFS-605)*:
The composite analyzed in accordance with the applicable methods outlined in
the current edition of the Official Methods of Analysis of the Association
of Official Analytical Chemists and supplements (at the time of this
transmittal Fourteenth Edition, Section 25.146-152) shows:
Mercury expressed as Methyl Mercury in excess of 1 ppm (edible portion
only).
NOTE: Recommendations for legal action must clearly indicate the exact
portion of the food used for analysis. The portion used for analysis must be
prepared by the appropriate procedure outlined in Volume I of the Pesticide
Analytical Manual, Sections 141.12 and 141.22.
Issued: 11/6/84
Revised: 3/95
This is covered in the regulations under
[Code of Federal Regulations]
[Title 21, Volume 2]
[Revised as of April 1, 2001]
>From the U.S. Government Printing Office via GPO Access
[CITE: 21CFR109.6]
[Page 210-211]
TITLE 21--FOOD AND DRUGS
CHAPTER I--FOOD AND DRUG ADMINISTRATION, DEPARTMENT OF HEALTH AND HUMAN
SERVICES--CONTINUED
PART 109--UNAVOIDABLE CONTAMINANTS IN FOOD FOR HUMAN CONSUMPTION AND
FOOD-PACKAGING MATERIAL--Table of Contents
Subpart A--General Provisions
Sec. 109.6 Added poisonous or deleterious substances.
(a) Use of an added poisonous or deleterious substance, other than a
pesticide chemical, that is also a food additive, will be controlled by
a regulation issued under section 409 of the act when possible. When
such a use cannot be approved under the criteria of section 409 of the
act, or when the added poisonous or deleterious substance is not a food
additive, a tolerance, regulatory limit, or action level may be
established pursuant to the criteria in paragraphs (b), (c), or (d) of
this section. Residues resulting from the use of an added poisonous or
deleterious substance that is also a pesticide chemical will ordinarily
be controlled by a tolerance established in a regulation issued under
sections 406, 408, or 409 of the act by the U.S. Environmental
Protection Agency (EPA). When such a regulation has not been issued, an
action level for an added poisonous or deleterious substance that is
also a pesticide chemical may be established by the Food and Drug
Administration. The Food and Drug Administration will request EPA to
recommend such an action level pursuant to the criteria established in
paragraph (d) of this section.
(b) A tolerance for an added poisonous or deleterious substance in
any food may be established when the following criteria are met:
(1) The substance cannot be avoided by good manufacturing practice.
(2) The tolerance established is sufficient for the protection of
the public health, taking into account the extent to which the presence
of the substance cannot be avoided and the other ways in which the
consumer may be affected by the same or related poisonous or deleterious
substances.
(3) No technological or other changes are foreseeable in the near
future that might affect the appropriateness of the tolerance
established. Examples of changes that might affect the appropriateness
of the tolerance include anticipated improvements in good manufacturing
practice that would change the extent to which use of the substance is
unavoidable and anticipated studies expected to provide significant new
toxicological or use data.
(c) A regulatory limit for an added poisonous or deleterious
substance in any food may be established when each of the following
criteria is met:
(1) The substance cannot be avoided by current good manufacturing
practices.
(2) There is no tolerance established for the substance in the
particular food under sections 406, 408, or 409 of the act.
(3) There is insufficient information by which a tolerance may be
established for the substance under section 406 of the act or
technological changes appear reasonably possible that may affect the
appropriateness of a tolerance. The regulatory limit established
represents the level at which food is adulterated within the meaning of
section 402(a)(1) of the act.
(d) An action level for an added poisonous or deleterious substance
in any food may be established when the criteria in paragraph (b) of
this section are met, except that technological or other changes that
might affect the appropriateness of the tolerance are foreseeable in the
near future. An action level for an added poisonous or deleterious
substance in any food may be established at a level at which the Food
and Drug Administration may regard the food as adulterated within the
meaning of section 402(a)(1) of the act, without regard to the criteria
in paragraph (b) of this section or in section 406 of the act. An action
level will be withdrawn when a tolerance or regulatory limit for the
same substance and use has been established.
(e) Tolerances will be established under authority appropriate for
action levels (sections 306, 402(a), and 701(a) of the act, together
with section 408 or 409 of the act, if appropriate) as well as under
authority appropriate for tolerances (sections 406 and 701 of the act).
In the event the effectiveness of a tolerance is stayed pursuant to
section
[[Page 211]]
701(e)(2) of the act by the filing of an objection, the order
establishing the tolerance shall be deemed to be an order establishing
an action level until final action is taken upon such objection.
[42 FR 52819, Sept. 30, 1977, as amended at 55 FR 20785, May 21, 1990]
-Dr. Ted Labuza tplabuza@tc.umn.edu
Morse Alumni Distinguished Professor of Food Science and Engineering
Dept. of Food Science & Nutrition 136 ABLMS U of Minn St Paul, MN 55108
Voice 612-624-9701 Fax 612-625-5272 home fax 651-483-3302
cell 612-290-2851
http://fscn.che.umn.edu/Ted_Labuza/tpl.html
"SURFING THE WAVES OF CYBERSPACE"
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"Science is what we have learned about how to keep from fooling ourselves."
Richard Feynman
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