Jon,
Good point. I wonder if sampling the vicera has ever been done before in
regards to histamine testing?
Paul
In a message dated 11/8/2004 10:56:50 AM Eastern Standard Time,
JonMcGraw@seafreeze.com writes:
> Subj: RE: Histamine concern in Ecuador.
> Date: 11/8/2004 10:56:50 AM Eastern Standard Time
> From: JonMcGraw@seafreeze.com
> To: alain.schalk@cotecna.ch, seafood@ucdavis.edu
Sent from the Internet
Hi
Two points.
My participation in this discussion is regards professional curiosity only.
My company neither exports nor imports fish of any kind.
While I find the idea of viscera sampling intriguing, I'm not sure it is
appropriate. A positive sample in viscera would not necessarily indicate that the
flesh is likewise affected. A negative result, while
much more likely to correlate with flesh, may not be satisfactory to
regulatory agencies or purchasers.
Regards
Jon McGraw
Seafreeze
Seattle
> -----Original Message-----
> From: Schalk Alain [mailto:alain.schalk@cotecna.ch]
> Sent: Monday, November 08, 2004 2:17 AM
> To: PDIONPDA@aol.com
> Cc: seafood@ucdavis.edu; Jon McGraw
> Subject: Histamine concern in Ecuador.
>
>
> Dear Paul,
>
>
>
> As I said last Friday the possibility to sample and conduct most of the
> analysis on the Viscera basis would be to my point of view a very interesting way
> of not damaging the Fish appearance while doing sampling……this could be
> applicable to a 100% sampling as well as to a standard FDA sampling….
>
> This is already a possibility for Jon to approach his future shipments from
> Ecuador….if FDA (and scientific parameters) would accept this approach ?
>
>
>
> I also found very interesting the intervention from Walter Staruszkiewicz
> FDA especially the following statement:
>
>
>
> "Until a valid control mechanism is established from the point of harvest at
> sea through the delivery of fish, chemical analysis will remain the only
> reliable test of safety for scombroid-type fish. "Certificates" and good
> intentions will not suffice as substitutes."
>
>
>
> The question is certainly to decide today on who and how such “valid control
> mechanism” could be set up ?
>
> Is it left to the industry to decide or would FDA be ready to discuss or
> even push one way or another for implementing same?
>
> According to my records, in the 1990 the National fishery Institute NFI
> started something similar by making a joint venture with a major
>
> consulting firm for offering HACCP training/audits in several countries…
> .This kind of “Train the Trainers” program might be the solution but it should
> then be extended to cover on board handling, HACCP/Temperature monitoring and
> final lab procedure...This is the direction the EU is taking by offering some
> funding to selected countries who accept to put their fishing dept at level
> regarding EU regulation (done through the use of consultants).
>
>
>
> Alain Schalk
>
> Cotecna Inspection SA
>
>
>
>
> ----------------------------------------------------------------------------------------------------------------------------------------------------------
> ----------
>
>
>
> Alain,
>
> Sounds like an interesting approach. However the scientists in the list will
> have to respond as the laboratory analysis end of it is out of my realm. I
> am also not sure what the FDA will accept as a viable sample. Once again the
> FDA has to respond to that question. I know that the FDA does encourage the
> use of time/temp data loggers onboard as a record of handling.
>
> Paul Dion
> Paul Dion Associates, Inc.
> Plymouth, MA
> USA
>
>
> ----------------------------------------------------------------------------------------------------------------------------------------------------------
> -----------------------------------------------------------------------------
> ---
>
>
>
> Dear Paul,
>
>
> I would try 2 different approaches:
>
>
>
> 1. ask scientists to confirm that histamine test could be effectively
> done on viscera and rejects assuming that fish are processed, cleaned and
> subject to current export preparation. If the answer is yes the processing plant
> should convince FDA to sample and analyze such viscera. The argument might
> be that those samples were withdrawn before the FDA intervention. In such case
> you ask a reputable inspection company to either seal and keep a composite
> sample of those or you ask the inspection company to mix 100% of those rejects
> and conduct its own analysis on those. The presentation of a reputable
> quality certificate might be enough for FDA to forget about damaging the fish
> itself…..and you will cover 100 % of the lot if it is what they want….
>
> 2. The other option is to bring confidence on the quality of the
> presented lot. For that you need to demonstrate proper HACCP and temperature
> monitoring at different stages of the chain…..the more stages the better….I
> believe your company went through field experiments to demonstrate that better
> fish handling (on board and in land) and temperature monitoring could lead to
> low reject rates by Lab/FDA with an improved quality label and maximum shelf
> life and this would surely be a plus in the actual available standard HACCP
> programs to the benefit of all parties.
>
> When I was in Chile working on Salmon farming we also looked at some of
> these issues and I must agree with you that results were very encouraging…
>
> Alain Schalk
> Cotecna Inspection SA
>
> ----------------------------------------------------------------
>
> [mailto:PDIONPDA@aol.com]
> Sent: 05 November 2004 14:12
> To: alain.schalk@cotecna.ch
> Cc: seafood@ucdavis.edu
> Subject: Re: Histamine concern in Ecuador.
>
>
>
>
> Alain,
>
> Good point. You being an inspection specialist how would you approach the
> sampling of tuna for histamines that would not require 100% sampling as in the
> case of the tuna from Equador thus maintaining saleability integrity of the
> lot as well as safety for the consumer?
>
> Paul Dion
> Paul Dion Associates, Inc.
>
> In a message dated 11/5/2004 3:56:58 AM Eastern Standard Time,
> alain.schalk@cotecna.ch writes:
>
>
>
>
> Subj: RE: Histamine concern in Ecuador.
> Date: 11/5/2004 3:56:58 AM Eastern Standard Time
> From: alain.schalk@cotecna.ch
> To: JonMcGraw@seafreeze.com
> CC: seafood@ucdavis.edu, PDIONPDA@aol.com
> Sent from the Internet
>
>
>
> John,
>
>
>
> I do not know about a particular way of sampling the fish for histamine test…
> and if there is a directive on the subject it has to be with FDA.
>
> But on a very practical point of view if FDA considers that there is not
> enough flesh or concentration on the tail to sample they would obviously look
> for another sampling point trying not to damage the body which is the main
> selling part….so there are left with the head part….
>
>
>
> But let us be realistic the very damage comes from the fact that the
> sampling is imposed at 100 %.........If only 5 % were sampled nobody would really
> care about the sampling procedure/point ! For me the solution is to get the
> sampling plan reduced by gaining quality confidence…
>
>
>
> Alain Schalk
>
> Cotecna Inspection Services
>
>
>
>
>
>
>
>
>
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This archive was generated by hypermail 2b29 : Mon Nov 08 2004 - 10:01:58 PST