Re: U.S. FDA has made an important change in scallop moisture policy - clarification

From: Pamela Tom (pdtom@ucdavis.edu)
Date: Thu May 20 2004 - 12:32:37 PDT

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    To: Seafood Community
    Fr: Pamela Tom, Univ. of Calif., Sea Grant Extension Program

    Recently, I was asked by someone in the seafood industry how the FDA would
    inspect scallops based on its revised policy of May 10, 2004. (See:
    http://listproc.ucdavis.edu/archives/seafood/log0405/0009.html)

    The underlying Food Drug and Cosmetic Act and regulations still apply to
    scallop moisture i.e. if a significant amount of water is added to the
    product with labeling it could be considered misbranded and subject to
    regulatory action.

    In the May 10, 2004 revision, the U.S. FDA deleted the requirement for
    discrete moisture percentages referenced in the 1992 interim policy
    because "significant" is more difficult to determine based on new
    information related to the varying water content of scallops.

    Hopefully future scientific research will help define moisture limits.
    Egregious misbranding would still probably evoke regulatory action.

    Pamela Tom
    University of California



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