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I am still trying to get to the bottom of the sodium nitrite problem. The tuna product we are trying to produce is a dried ethnic one (not smoked) and has traditionally had sodium nitrite added to produce red colour and tangy favour.
FDA Policy Guide Sec. 540.500 Tuna, Sable, Salmon, Shad - Smoked Cured, Adulteration Involving Food Additives, Sodium Nitrite (CPG 7108.18) POLICY: The food additives regulations provide for the addition of sodium nitrite in smoked, cured, tuna, sable, salmon and shad (21 CFR 172.175).
Note two words: smoked cured and later smoke, cured.
Tuna is to be kept under 15ppm while salmon etc under 200ppm. I imagine this was addressed years ago but I do not have the references.
Why the difference? I am only concerned as I am unable to compete with this product produced and sold in one State and it appears is therefore not subject to FDA rules. I have finally produced a product that when tested was 11ppm sodium nitrite but did not, and never will, compare to the product we are trying to emulate. If I could go to 50ppm then we would be home and hosed.
So three questions.
1.. What is the reason for difference between Tuna and Salmon?
2.. Is it true that FDA cannot enforce regs in same State produced and marketed products?
3.. In guide 540.500 are dried and smoked separate and under different regs. (wishful thinking) or the same?
Robert Stone
Gourmet Food Company
Fiji Islands
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