Alain,
Your plan sounds feasible. It is common knowledge that histamine contaminated
tuna are making its way into the marketplace in both the US and the EC on a
regular basis. This is from shipments with health certificates marked "Safe for
human consumption." One has to ask the question, "Why is this so in an
industry that prides itself on the ability to apply state of the art techniques in
its catching process?" Then how come this modern day technology is not applied
to post harvest handling and traceability as it applies to the handling of
tuna? Especiall tuna caught in the equatorial zones.
Simple question. Anyone care to offer any answers?
Paul Dion
Post Harvest Handling Specialist
Plymouth, MA
USA
From: Schalk Alain
>
> Sent: 01 February 2005 17:47
> To: 'Hungerford, James M'
> Cc: 'alainschalk@yahoo.fr'
> Subject: Histamine Field Test
>
Dear James,
I have put together the last 2 messages received from FDA specialists on the
subject and I believe there is certainly something to reflect on…
If you ask me today about my need, as an inspection company, to purchase or
detain such equipments I would say yes but without real interest as
today the certification of the quality relies on some export certification
schemes, quality assurance programs or state regulations which put practically
at the same level the controls for histamine and Microbio…..and the microbio
test requiring a long time to process there is sufficient time for the histamine
tests to also take place in a laboratory….so no real need for quick tests as
you imagine….
But as suggested by Walter the establishment of a proper control mechanism
along the supply chain would certainly call for numerous field tests
to be duly recorded as part of a global quality insurance program involving
spot controls at time of catch, on board handling, discharge, transit points,
transport, process, export ….
I believe we all know where the problem lies but we do not want to see it….
FDA and EU are pushing very hard for some new regulation to take place to force
the suppliers (through the importers concern and liability) to build up,
monitor, audit and promote a full quality program including, HACCP, Temperature
abuse, mixture of catches reacting differently to histamine creation, clean
process, and final export certification. And we must all admit that it just does
not work but the consumer desperately need that confidence building process…And
such needed program goes with traceability and field spot checks for sensible
parameters such as histamine……
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? Even if FDA does not
wish or cannot be directly involved could we imagine them giving the blessing
to an inspection firm having sufficient network and resources to prepare and
audit the industry worldwide ? In such case the need for those quick checkers
on histamine would be there and the main client/user would be the inspection
company itself…being the arm of FDA and EU…
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….The
scheme was voluntary and lacked strong support from state agencies…
This kind of “Train the Trainers” program might be the solution but it
should then be extended to cover on board handling, Histamine creation,
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).
Same potential partner could even set up control programs for checking sea
food in restaurants, markets, cold stores etc…. under a different mandate in a
specific country !
Just some thoughts. I am not really sure they fit in your concern and even
answer your question but I believe this is a question to start working on if we
want safe sea food in our plate for the years to come…
Best regards.
Alain Schalk
Cotecna Inspection SA
In a message dated 2/1/2005 4:21:23 AM Eastern Standard Time,
straddiegal@optusnet.com.au writes:
> Subj: RE: Histamine Field Test
> Date: 2/1/2005 4:21:23 AM Eastern Standard Time
> From: straddiegal@optusnet.com.au
> To: JHUNGERF@ORA.FDA.GOV, seafood@ucdavis.edu
> Sent from the Internet
>
>
>
> Dear James,
>
> In Australia the major supermarket chain requires all seafood suppliers to
> test for histamine in "raw fish fillets/loin" to the maximum limits of <
> 100mg/kg.
>
> This is a cost burden for small suppliers and a hassle for the suppliers in
> the more remote areas away from labs. It also pretty ineffective as they only
> test the most basic requirements and often test non histamine species either
> deliberately or through ignorance.
>
> A test kit would be really appreciated and please remember that most of the
> worlds currency is running at less than the USD.
>
> Does anyone in the group know of a charity that is working to rebuild the
> boats for the Sri LANKAN fishermen to donate to? Also if anyone is involved
> with the fishing people do they need a HACCP trainer/consultant/auditor
> volunteer ?
>
> Clare Winkel
> Australia
>
> >> -----Original Message-----
>> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
>> Of Hungerford, James M
>> Sent: Tuesday, February 01, 2005 4:40 AM
>> To: 'seafood@ucdavis.edu'
>> Subject: Histamine Field Test
>>
>>
>> A question for those in the seafood industry, government regulators,
>> inspectors, analysts, etc:
>>
>> How many of you would purchase and use a simple and rapid field test for
>> histamine in fresh, frozen, or canned fish?
>>
>> I am exploring the possiblities for a commercially available field test kit
>> for histamine that would use a simple cassette format (lateral flow
>> cassette as used in pregnancy test kits). There would be no chemicals to handle,
>> and no solutions other than the distilled-water extract of fish (prepared on
>> site) since the test kit itself is "solid state." The kit would respond in
>> approx 30 min. Sample requirements are low and their is potential for less
>> "disfigurement" of the fish as discussed on this forum. Results would be
>> qualitative (for example "above 50 PPM" or "below 50 PPM") and would mainly be
>> used for screening and for quality control.
>>
>>
>> Roughly how many tests would your firm or agency perform each year?
>>
>> What do you feel is a reasonable cost per sample?
>> Please note that although I work for FDA, statements made in this message
>> do not reflect FDA policy.
>>
>> Please respond with your thoughts on this.
>>
>> Thank You for your time.
>>
>> Sincerely,
>>
>>
>> James Hungerford, Ph.D.
>> Chair of AOAC Task Force and GR, Marine and Freshwater Toxins,
>>
>> Research Chemist
>> FDA Seafood Products Research Center
>> 22201 23rd Dr SE
>> Bothell, WA 98021
>> USA
>> Phone 425-483-4894
>> FAX 425-483-4996
>>
>> James.Hungerford@fda.gov
>>
>>
>
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