Enough! The primary problem is not tuna, it's mahi mahi and the on-board
handling of mahi is distinct from tuna relative to time and thermal
consequences. Likewise, the majority of domestic mahi are recreational
harvested, not subject to HACCP, yet with a significant portion sold in
commercial settings. Despite this situation, epidemiology indicates it
is primarily an import problem. Likewise, the thermal consequences
involve issues beyond the vessel and beyond the processors. Handling in
the distribution and retail settings warrant reconsiderations, both
fresh and thawed. The increasing use of CO and filter-smoked fishes will
also contribute to this controversy.
________________________________
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
Behalf Of PDIONPDA@aol.com
Sent: Monday, November 08, 2004 1:45 PM
To: alain.schalk@cotecna.ch
Cc: seafood@ucdavis.edu
Subject: Re: Histamine concern in Ecuador.
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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