Dear Messrs Walter, Blaha,
I have only been on the list for a few days and I was very excited about the
possibility to discuss very important issues such as the one which was on
the list at time of my arrival, so I just got involved in a technical
discussion following an anonymous question from a member but.... I have
already been told to shut up...!?
Sorry but I do not understand...The very first question was regarding
sampling basis and certification of histamine on an exported lot and I would
consider myself very knowledgeable of such issue...
So I do not understand how in a free discussion Forum one could be kicked
out like that ("botté en touche" as we say in french) ....especially if your
comments are very true but in my opinion only related to a very small part
of the iceberg...
I do not feel very attacked in your answer to Paul Dion but as being
directly addressed by same I also feel concerned so I have to react to your
message...
Do we have to hold a certain academic level to be able to talk on the list ?
Just an impression....
Regards.
Alain Schalk
Cotecna inspection SA
_____
From: OTWELL,WALTER S [mailto:Otwell@mail.ifas.ufl.edu]
Sent: 08 November 2004 20:21
To: PDIONPDA@aol.com; alain.schalk@cotecna.ch
Cc: seafood@ucdavis.edu
Subject: RE: Histamine concern in Ecuador.
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.
YEIIHHH!!!
thanks for adding some sence to this discussion!!
Francisco Blaha
NZ Seafood Standards Council
_____
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 <mailto:alain.schalk@cotecna.ch>
To: PDIONPDA@aol.com <mailto:PDIONPDA@aol.com>
CC: JonMcGraw@seafreeze.com <mailto: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
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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
----------------------------------------------------------------
[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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________________________________________________________________
This communication contains information that is confidential and is intended
for the exclusive use of the addressee(s) only. The unauthorized reading,
disclosure or copying of this email is strictly prohibited. If you are not
the intended recipient(s), please note that any distribution, copying or use
of this communication or the information contained in it is strictly
prohibited. If you have received this communication in error, please notify
the sender immediately and then destroy any copies of it. The content of
this message does not reflect the opinion of the Cotecna Group or any of its
affiliates except to the extent that it relates to their official business.
Cotecna Group strives to protect itself from computer
viruses. However, as new viruses constantly appear, we do not accept
responsibility for the effects of any virus which you may contract from us.
We encourage our correspondents to implement anti-virus software, and to
keep it up to date.
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