Dan,
Thanks for continuing and refocusing our discussion of the sampling process
for histamines in headed or head on gutted tuna. I can only remember when I was
dealing with headed and gutted swordfish that those fish that were sampled
(in the nape portion) were sold at a reduced price of sometimes as low as 50% of
its original value prior to sampling. If we had the opportunity we loined out
the sampled fish and sold the loins separately. But that only recouped
original cost at best and was labor intensive. Much the same as selling lobster meat
from those lobsters that are no longer with us at the end of the trip or in
the morning.
Alain's suggestion that possibly the sampling could be done by using the
viscera. However, on headed and gutted fish this would not be possible. Or that
maybe some fish could be held aside during the capturing process onboard to
serve as samples with head on and guts in. The crew would have to take these fish
according to size of catch, etc.. However, this would possibly lead to a
process that I call, "Selective sampling." Taking fish for samples that are more
apt to test positive rather than negative.
I really think that the heart of problem of accurate and reliable testing is
in the sampling process. However, as you have said, in order that the sampling
process be representative of the makeup of the lot and reflects the
conditions in which the fish were handled onboard, the fish must be cut in such a way
that much of the effort in keeping the fish at premium grade is lost. Thus why
the effort in the first place.
I would think that we as professional seafood people worldwide, that run the
entire gamut of services and expertise could come up with at least some viable
alternatives to the current FDA sampling process. I also feel that the FDA
looks to industry for solutions to such problems.
Paul Dion
Post Harvest Handling
Paul Dion Associates, Inc.
Plymouth, MA
USA
In a message dated 11/11/2004 2:21:01 AM Eastern Standard Time,
brooks@ift-ltd.com writes:
> Subj: Histamine in Ecuador
> Date: 11/11/2004 2:21:01 AM Eastern Standard Time
> From: brooks@ift-ltd.com
> To: seafood@ucdavis.edu
> Sent from the Internet
>
>
>
> 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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