Thanks to Pamela Tom and Steve Otwell for the actual FDA reference. The FDA
limits listed therein are thus:
*** <80% = "dry"
*** 80% to 84% = "water added scallop product"
*** >84% = cannot be marketed
This contrasts to information from the USDC as stated in my initial
response, namely:
*** <82% = "dry"
*** 82% to 86% = "water added scallop product"
*** >86% = cannot be marketed
These more generous limits are taken from information out of "Working
Instructions for Ohaus Balance Model MB200 Moisture Determination", 20pp.,
dated 12/18/01 and authored by Jane E. Fox-Dobson, NMFS, Seafood Inspection
Program, Technical Services Branch, and are the limits quoted by USDC
inspectors I have dealt with. Our in-plant inspector informs me that these
latter limits are the ones the USDC enforces if asked to certify a given
lot as "Grade A".
Actual enforcement issues aside, can anyone from the USDC or FDA speak to
which limits are currently in place? The FDA "Interim Labeling Policy" cited
below is dated August of 1992, and states that:
"FDA will take these data into account in establishing a comprehensive
policy. While this research is being conducted, FDA will likely not object
if..."
Can it be assumed that this research has been completed & adjustments made?
Is this the reason for the adjusted USDC numbers?
Cheers,
Fredrik J. Stengard
Director of Research/QC/HACCP-Bio Safety
Bama Sea Products, Inc.
756 28th Street South
St. Petersburg, FL 33712
Phone (727) 327-3474 x374
Fax (727) 327-7574
email: fstengard@bamasea.com
-----Original Message-----
From: Pamela Tom [mailto:pdtom@ucdavis.edu]
Sent: Wednesday, April 14, 2004 9:15 PM
To: Seafood HACCP Mailing List
Subject: Re: scallops
The status quo on the US Food and Drug Administration's policy statement
on moisture content of scallops is as follows.
Regards,
Pamela Tom
University of California
Sea Grant Extension Program
===========================================================================
Answers 08/31/1992
T92-40 Food and Drug Administration
August 31, 1992 Brad Stone - (202) 245-1144
INTERIM LABELING POLICY ESTABLISHED FOR SCALLOPS
New labeling to appear on scallop products treated with sodium
tripolyphosphate (STP) and water will provide consumers with a better
indication about the amount of water in the scallop products they buy. In
addition, FDA is planning to evaluate new data on STP processing in order
to develop a comprehensive policy governing this practice.
The following can be used to answer questions:
STP is used by the scallop industry to prevent the loss of moisture
("drip loss") in scallops and retain the scallops' original weight.
Scallops usually consist of 75 - 79 percent water. Drip loss has been a
problem for the scallop industry because scallops lose a considerable
amount of natural moisture after they have been taken from the water. STP
has long been on FDA's "generally recognized as safe" (GRAS) list of
substances.
However, prolonged soaking can result in scallops with excessive water
content, which adds to the scallop product's total weight. If consumers
buy water-augmented scallops at the same price per pound as scallops that
are naturally larger, they are paying for water weight.
FDA met with industry representatives to discuss STP use. The
industry agreed to develop data to determine the effects of various
treatment times and STP concentrations on scallops, and to determine
whether STP soaking has functional benefits beyond the prevention of drip
loss. FDA will take these data into account in establishing a
comprehensive policy.
While this research is being conducted, FDA will likely not object if
a scallop that has been processed to add weight through STP soaking is
labeled with an identity statement of "X % Water Added Scallop Product."
FDA expects such a statement to appear on any product with 80 percent
water or more. The agency also expects the statement, "Processed with
Sodium Tripolyphosphate," or any other polyphosphates used, to appear if
the product has been processed with the ingredient. In addition, the
ingredient listing on the labels for these products has to include water
and STP (or other polyphosphates).
In the absence of evidence to the contatry, scallops consisting of 79
percent water or less are assumed to be scallops alone. Scallop products
exceeding 84 percent water cannot be marketed.
The agency will treat imported and domestic products equally.
http://www.fda.gov/bbs/topics/ANSWERS/ANS00422.html
==========================================================================
On Wed, 14 Apr 2004, alma tina wrote:
> Dear list,
> I would like to ask anybody who have the knowledge regarding scallops.
> What is the difference between soaked and dry pack, is it a practice
> that scallops are soaked, in what? plain water or with the use of
> phosphates. I saw a scallops product where in you will find in the
> label, 25 % water added. Are there any reading materials or publication
> that concentrates on scallops. Any information will be highly
> appreciated.
>
> Thanks and Best Regards,
>
> Alma O. Tina
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