Hello group :
I posted a similar question to this body back in November but did not receive any definitive answer, so here goes again. It appears that the latest "hazards" associated with eating pelagic fishes (tunas, swordfish, marlin), aside from mercury (that's still total for the EU but at least the USFDA acknowledges that its methlymercury!!), are cadmium and lead (for the EU at the moment). Should these potental "nartural" environmental contaminants (for pelagics) be included in future HACCP analyses ? For the moment, USFDA only has action and guidance levels for Cd (3 ppm crustaceans - 4 ppm bivalves) and Pb (1.5 ppm crustaceans - 1.7 bivalves). For the EU however, in addition to crustaceans (Cd at 0.5 ppm, Pb at 0.5 ppm) and bivalves (Cd at 1.0 ppm, Pb at 1.5 ppm), fresh fish are also included (tunas at 0.1 ppm Cd and all other fishes at 0.05 ppm Cd and tunas at 0.4 ppm Pb, all other fishes at 0.2 ppm). What is it that the Veterinary inspectors in the EU know (or don't know) about these potential hazards that the USFDA, Seafood Inspection does not know ????? Why are there such large differences in presumed action levels between the two competent authorities ? Since recent tests (albeit very few) from French Polynesia have shown Cd and Pb levels slightly above EU limits in swordfish and striped marlin, it may become an important issue in the near future for anyone exporting marlin and swordfish to the EU. Would someone on the list be able to enlighten me on this issue please ?
Sincerely,
Charles Daxboeck, Ph.D.
HACCP Consultant to the longline industry
French Polynesia
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