To: Seafood HACCP Mailing List
To add to Brian Himelbloom's comments and Liz Brown's question, here's
what the U.S. FDA's Fish and Fisheries Products Hazards aand Controls
Guidance has to say about processing (salting, drying, pickling, or
fermentation) whole fish:
"Evisceration of fish before processing. Because spores are known to be
present in the viscera of fish, any product that will be preserved by
salting, drying, pickling, or fermentation must be eviscerated prior to
processing (see Compliance Policy Guide sec. 540.650). Without
evisceration, toxin formation is possible during the process even with
strict control of temperature. Evisceration must be thorough and performed
to minimize contamination of the fish flesh. If even a portion of the
viscera or its contents is left behind, the risk of toxin formation by C.
botulinum remains. Small fish, less than 5 inches in length (e.g.
anchovies and herring sprats), that are processed in a manner that
prevents toxin formation, and that reach a water phase salt content of 10
percent in refrigerated products, or a water activity of below 0.85 (Note:
this value is based on the minimum water activity for growth of S. aureus)
or a pH of 4.6 or less, in shelf-stable products are exempt from the
evisceration requirement."
Source: Ch. 13, Clostridium botulinum Toxin Formation (A Biological
Hazard) http://www.cfsan.fda.gov/~comm/haccp4m.html
This web site goes into further details on the FDA's Compliance Policy
Guidance on: Sec. 540.650 Uneviscerated Fish Products that are
Salt-cured, Dried, or Smoked (CPG 7108.17):
http://www.fda.gov/ora/compliance_ref/cpg/cpgfod/cpg540-650.htm (Revised
8/10/2000)
Regards,
Pamela Tom, Univ. of California, Sea Grant Extension Program
On Thu, 27 May 2004, Brian Himelbloom wrote:
> Hi Liz,
>
> My guess is this may be due to consumption of raw, whole (not gutted),
> dried fish which has caused Type E botulism among Russian immigrants in
> the US. The following is an excerpt from the FDA Bad Bug Book
> <http://www.cfsan.fda.gov/~mow/chap2.html>:
>
> "...In October and November, 1987, 8 cases of type E botulism occurred,
> 2 in New York City and 6 in Israel. All 8 patients had consumed
> Kapchunka, an uneviscerated, dry-salted, air-dried, whole whitefish. The
> product was made in New York City and some of it was transported by
> individuals to Israel. All 8 patients with botulism developed symptoms
> within 36 hours of consuming the Kapchunka. One female died, 2 required
> breathing assistance, 3 were treated therapeutically with antitoxin, and
> 3 recovered spontaneously. The Kapchunka involved in this outbreak
> contained high levels of type E botulinal toxin despite salt levels that
> exceeded those sufficient to inhibit C. botulinum type E outgrowth. One
> possible explanation was that the fish contained low salt levels when
> air-dried at room temperature, became toxic, and then were re-brined.
> Regulations were published to prohibit the processing, distribution and
> sale of Kapchunka and Kapchunka-type products in the United States..."
>
> Regards,
>
> Brian Himelbloom
> Associate Professor of Seafood Microbiology
> University of Alaska Fairbanks
> Fishery Industrial Technology Center
> 118 Trident Way
> Kodiak, AK 99615-7401
>
> Liz Brown wrote:
>
> > Does anyone on the Seafood NIC listserve know about the packaging or
> > production method of these products?
> >
> >> Date: Wed, 26 May 2004 19:40:40 -0400 (EDT)
> >> From: ProMED-mail <promed@promed.isid.harvard.edu>
> >> Subject: PRO/EDR> Botulism, dried fish suspected - Russia (Volgograd)....
> >
>
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