Dear Ian and Seafood colleagues
<Are there any volunteers for carrying the cost of proving a negative?>
Quite! And that is just one concern I have the EU Regulation quoted by Ian;
I consider it is defective in other ways.
It seems to me that the principle is adequately conveyed in 1. (a) of
Chapter IIID: fishery products intended to be consumed raw or almost raw
should be held frozen for at least a day before processing or distribution.
Because cold smoked products of whatever species are almost raw such
products are subject to the provisions of subsection (a) anyway and
subsection (b) is not necessary. But the situation is worse than just
redundancy. Listing particular species of fish in (b) gives the impression
that cold smoked fish of other species do not pose a risk and do not need to
be frozen. This, of course, is not the case. Why is 'wild' in (iv) in
brackets? Does this imply that the legislators were unsure of the risk
status of Atlantic salmon and wild salmon might not pose a risk after all.
Does '(wild)' apply to Pacific salmon or just to Atlantic salmon? All
species of Pacific salmon?
Provision (c) requires that a processor needs to investigate the risk from
nematode parasites in marinated or salted products. Is there then no risk
from trematode or cestode parasites?
Provision 2. requires that for exemption from earlier provisions, food
business operators need to have 'epidemiological data' indicating absence of
a '.. hazard with regard to presence of parasites'. Presence of a hazard can
be demonstrated by observational data, for example by the finding of
parasites in fish from the fishing ground of origin. Epidemiological data
can help establish the risk that the hazard poses. Texts on HACCP point to
the difference between hazard and risk. Epidemiological data are available
after the event, but only if the accounts of food poisoning episodes are
reported to the authorities and collated. If a food business operator wishes
to introduce a new product on the market there might not be any
epidemiological data on food poisoning from that product from a particular
fishing ground. However, there might be data on hazards associated with that
species/fishing ground, (and from this it might be possible to estimate the
risk of harmful effects), but only if surveys had been conducted for the
hazard. Absence of epidemiological data does not imply that there is no risk
or that a hazard does not exist.
Ian's comment is very pertinent, and does not see to have occurred to the
drafters of the EU Regulation.
Peter Howgate
----- Original Message -----
From: "Listreader" <listreader@megapesca.com>
To: "P Howgate" <phowgate@clara.co.uk>
Cc: <seafood@ucdavis.edu>
Sent: Thursday, August 04, 2005 11:50 AM
Subject: Re[2]: Fish for raw consumption in US
Hello Peter and Seafood colleagues
Tuesday, July 26, 2005, 8:36:54 PM, you wrote:
PH> Yes, I agree. You will see from my message that I am not entirely happy
with
PH> the EU derogation of farmed salmon from the requirement of freezing
before
PH> using raw.
For information Regulation (EC)No 853/2004 of the European Parliament and of
the Council of 29 April 2004 laying down specific hygiene rules for food of
animal origin (Official Journal of the European Union L 139 of 30 April
2004) will come into force at a date after 1st.January 2006, and contains
provisions which will substantially amend EU law with respect to parasites
in fishery products.
Annex II Section VIII Fishery Products Chapter III D states:
REQUIREMENTS CONCERNING PARASITES
1.The following fishery products must be frozen at a temperature of not more
than -20 °C in all parts of the product for not less than 24 hours;this
treatment must be applied to the raw product or the finished product:
(a)fishery products to be consumed raw or almost raw;
(b)fishery products from the following species, if they are to undergo a
cold smoking process in which the internal temperature of the fishery
product is not more than 60 °C:
(i)herring;
(ii)mackerel;
(iii)sprat;
(iv)(wild)Atlantic and Pacific salmon;
and
(c)marinated and/or salted fishery products,if the processing is
insufficient to destroy nematode larvae.
2.Food business operators need not carry out the treatment required under
point 1 if:
(a)epidemiological data are available indicating that the fishing grounds of
origin do not present a health haz-
ard with regard to the presence of parasites;
and
(b)the competent authority so authorises.
3.A document from the manufacturer, stating the type of process they have
undergone, must accompany fishery products referred to in point 1 when
placed on the market,except when supplied to the final consumer.
Therefore it wouold seem that the default requiremenbt for raw consumption
is that the products must be frozen, except where there is positive
epidemiological avidence that "fishing grounds of origin do not present a
health hazard"
Are there any volunteers for carrying the cost of proving a negative?
All the best
Ian Goulding
Megapesca lda
Rua Gago Coutinho
Valado Sta.Quiteria
2460 207 Alfeizerao
PORTUGAL
Tel.+ 351 262 990 372
Fax.+ 351 262 990 496
www.megapesca.com
megapesca@mail.telepac.pt
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