To All Valued Participants in the Discussion:
Let's refocus the discussion back to the original question. We were talking about FDA histamine sampling requirements for premium headed and gutted tuna exported to the US fresh market. The term "premium" denotes that this product gets special handling from catch to market to preserve its freshness and appearance.
For the sake of this discussion, let's assume the sampling regime of concern requires a minimum of 18 fish/lot to be sampled, and if the lot is less than 18 fish, then all fish must be sampled. The total flesh sampled from the 18 fish must be at least 2 lbs., or approximately 900 grams (50 grams/fish). FDA specifically requires that the samples from each fish be taken from a cross-sectional cut at the head end of the fish and that "The (steak) cut should include the nape (base) of the neck, pass behind the gills and include the ventral portion of the loin (where histamine concentration is usually the greatest)."
Let's assume that this is the routine procedure expected by FDA for this type of product - not a special, or elevated sampling procedure for a problem packer. It is my understanding that this sampling procedure, even at 50 grams/fish, does indeed mutilate the product to such an extent to make it at least much less valuable, and at worst, unsalable. And in many cases lots are small for this type of product, so we are talking about considerable impact on the processor and his market.
Should there not be some flexibility on the part of FDA to recognize the difference between this type of tuna product vs. bulk tuna quantities destined for the canned market for example? I am sure that it is not only one processor in Ecuador that is affected by this policy.
Regards,
Dan Brooks
Managing Director
International Food Technology, Ltd.
Bangkok, Thailand
p: (662) 267-5013
f: (662) 267-5017
m: (661) 847-4997
email: brooks@ift-ltd.com
web: www.ift-ltd.com
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