Mr. Roques,
The Third Edition of the Fish & Fisheries Products and Controls Guidance
states:
For refrigerated, reduced oxygen packaged raw, unpreserved fish (e.g. vacuum
packaged fresh fish fillets)...the sole barrier to toxin formation by C.
botulinum type E and nonproteolytic types B and F during finished product
storage and distribution is refrigeration. These types of C. botulinum will
grow at temperatures as low as 38 degrees F....maintenance of temperature at
or below 38 degrees F after the product leaves the processor's control
cannot normally be ensured. Time temperature integrators on each consumer
package may be an appropriate means of providing such control. If you
intend to use a reduced oxygen packaging technique for these products and
you intend to market the products refrigerated without time temperature
integrators on each consumer package, you will need to evaluate the
effectiveness of other preventive measures, either singularly, or in
combination. Such evaluation will usually necessitate the performance of
inoculated pack studies under moderate abuse conditions. A suitable
protocol for the performance of such studies is contained in a 1992
publication by the National Advisory Committee on Microbiological Criteria
for Foods, "Vacuum or modified atmosphere packing for refrigerated, raw
fishery products.
Sincerely,
Tanya Malais
USFDA
Los Angeles District Office
-----Original Message-----
From: Jose Roques [mailto:Jose.Roques@bellcold.com]
Sent: Thursday, May 09, 2002 11:18 AM
To: 'seafood@ucdavis.edu'
Subject: VACUUM-PACKED FISH
Dear List:
I have just gone through our HACCP review for 2002 and a question was
brought up. We receive fresh salmon that has been vacuum-packed. In our
HACCP we established that reception of vacuum-packed fish is a CCP and the
critical limit was set at 38F. The problem is that we do not own this
product and, therefore, we cannot puncture the package to get a core
temperature. We have resolved this by inserting a wire-probe between 2
packages. Unfortunately, our production representative indicates that by
following this procedure the temperatures are always above 38F (in the high
40s).
Does anybody have any ideas to deal with this type of product?
Thank you for your help.
José M. Roqués
Bellingham Cold Storage
Special Projects Manager/QA Manager
Phone: (360)733-1640
Fax: (360)671-2587
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