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
alain.schalk@cotecna.ch writes:
> 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 be that those samples were withdrawn before the FDA intervention.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
>
>
>
>
>
>
> From: PDIONPDA@aol.com [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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