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
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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
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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
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[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 <mailto:alain.schalk@cotecna.ch>
To: JonMcGraw@seafreeze.com <mailto:JonMcGraw@seafreeze.com>
CC: seafood@ucdavis.edu <mailto:seafood@ucdavis.edu> , PDIONPDA@aol.com
<mailto: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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