Alain,
Onboard monitoring must be objective and not subjective as daily entries into
the fishing log by the fishing master. Fishermen never lie but sometimes they
don't tell the truth. The monitoring must be done by tamper proof and totally
waterproof time/temp data loggers that are strategically placed that will
monitor the fishing procerss in time/temp parameters. When these monitors are
read by a properly trained person it will give a history of the fishing trip.
This documentation will lend itself to a more comprehensive and accurate sampling
process.
I am sorry that I cannot comment on your idea of sampling the vicera. Maybe
someone else could shed ssome light on that area.
You are in the inspection business what do you think of that appoach?
Paul Dion
Paul Dion Associates, Inc.
Plymouth, MA
USA
In a message dated 11/8/2004 5:15:10 AM Eastern Standard Time,
alain.schalk@cotecna.ch writes:
> Subj: Histamine concern in Ecuador.
> Date: 11/8/2004 5:15:10 AM Eastern Standard Time
> From: alain.schalk@cotecna.ch
> To: PDIONPDA@aol.com
> CC: JonMcGraw@seafreeze.com
> Sent from the Internet
>
>
>
> 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 - 10:46:52 PST