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
_____
From: PDIONPDA@aol.com [mailto:PDIONPDA@aol.com]
Sent: 04 November 2004 19:21
To: JonMcGraw@seafreeze.com
Cc: alain.schalk@cotecna.ch; seafood@ucdavis.edu
Subject: Re: Histamine concern in Ecuador.
John,
I would assume that taking the sample from the nape is simillar to taking
samples from Swordfish for Mercury testing. That the nape would contain the
highest concentration of histamines or mercury is cases of swordfish.
In posting an answer to the original quaetion I would have to say that
safety would be the priority over salability. Isen't that what HACCP is all
about?
Paul Dion
Paul Dion Associates, Inc.
Plymouth, MA 02360
USA
In a message dated 11/4/2004 12:28:09 PM Eastern Standard Time,
JonMcGraw@seafreeze.com writes:
Subj: RE: Histamine concern in Ecuador.
Date: 11/4/2004 12:28:09 PM Eastern Standard Time
From: JonMcGraw@seafreeze.com <mailto:JonMcGraw@seafreeze.com>
To: alain.schalk@cotecna.ch <mailto:alain.schalk@cotecna.ch> ,
seafood@ucdavis.edu <mailto:seafood@ucdavis.edu>
Sent from the Internet
Hello,
I have yet to see an answer to the original question posed. I don't disagree
with what Alain has said but I am curious as to the directive to test neck
line vs tail. Requiring a seller to disfigure his fish in such a way as to
reduce his market is a hardship. Is it necessary.? Is it being required
universally? Does it provide a more definitive result?
Regards
Jon McGraw
Seafreeze
Seattle, Wa
-----Original Message-----
From: Schalk Alain [mailto:alain.schalk@cotecna.ch]
Sent: Thursday, November 04, 2004 7:31 AM
To: seafood@ucdavis.edu
Subject: Histamine concern in Ecuador.
To anonymous subscriber,
It is clear that FDA did not have confidence in the final product as same
probably reached the packing plant already with a low quality label....and
the producer could not probably demonstrate any kind of pre-quality concern
before final check at packing...so FDA was obliged to impose 100% sampling
basis....According to my experience the sampling plan reduces when the
confidence increases in the lot you have to inspect. And the only way to do
that is to have the industry to start considering global safety programs
considering critical points definition on board vessel or at farm side, at
landing/transfer and processing points....The plant having suffered the
penalty from FDA admits that they have lost the value of the shipment as not
being sellable anymore....so now whom would they turn to for getting
help/advices for future shipments ?? Who can answer this question today ??
Only a few consultants are able to help them with the full package
handling/temperature and HACCP monitoring ? I am afraid we have to urgently
address the issue of providing training to the industry on the subject if we
want seafood and fish to be on the menu for the years to come...
Alain Schalk
Cotecna Inspection SA
----------------------------------------------------------------------------
--------------------
Seafood HACCP Mailing List
A subscriber to this list asked me to post this message. If you have
information, would you either share via the listserv for open discussion
or with me privately (pdtom@ucdavis.edu)?
"During my visit to Ecuadora question came up about sampling for
histamine in tuna. The firm packs headed and gutted tuna (high quality)
for the USfresh market - Miami Seafood market and NY Fulton Seafood
market. They air freight everyday. After an FDA inspection they were
told to sample each fish for histamine by removing at least 50 grams of
flesh near the neck line fins (instead of the previous tail location).
This type of sampling will destroy the esthetic quality of the fish and
make it unsaleable in this particular market. How is this matter is being
handled by other sellers of this product?
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