Richard,
Well said. I never would have believed that a common objective parameter like
0C and 12 hours could generate so much discussion. I suppose that its is a
good thing if it leads to a better understanding of it's implications.
The reason I shied away from working with the fisherman on Lake Victoria is
the possibility of a bull Hippo coming out and turning over a dugout. Sharks I
can accept... Hippos no! However, getting safe into those state of the art
plants is possible.
Having been a commercial fisherman (Grand Banks swordfish for 10 years) and a
part of the international fishing industry (Fleet QA manager for Pesquera
Friosur for 5 years) for the past 20 years, I tend to take a pragmatic view of
temperature control. All the ice and cold storage state of the art resources
cannot recoup the loss of quality and in some cases safety (histamine in tuna) by
thermal abuse at the time of harvesting (letting the fish sit on deck in the
case of trawl caught or longline) or in the harvesting process (allowing large
catches remain in seines for long periods of time). Where are the state of
the art onboard time/temp real time recorders that can be monitored in the
shoreside testing lab? Words, definitions, checklist and records notwithstanding.
Real time data will result in real time CCP monitoring. I can't wait for the
"real" traceability legislation to be put into effect.
Paul Dion
Paul Dion Associates, Inc.
Plymouth, Massachusetts
USA
In a message dated 10/12/2005 1:27:54 PM Eastern Standard Time,
richard@fishonline.co.uk writes:
> Subj: RE: inquiry about cold storage being considered as CCP
> Date: 10/12/2005 1:27:54 PM Eastern Standard Time
> From: richard@fishonline.co.uk
> To: alain.schalk@cotecna.ch, seafood@ucdavis.edu
> CC: Hector.Lupin@fao.org, oscar.doporto@wanadoo.fr
> Sent from the Internet
>
>
>
> Hector has put together a very valuable précis of the EU Regs which
> serves me well. I would however point out that in drawing up an HACCP study
> we deal primarily with food safety issues, not those of quality. I am unable
> to think of a safety hazard that represents a realistic risk due to the
> temperature changing by several degrees during the 2 year shelf life of a frozen
> fish product; microbiological activity having been effectively halted. I am
> not sure, therefore why a fairly arbitrary figure of -18ºC (the centigrade
> equivalent of a better sounding 0ºF) should be so critical. I believe that 75%
> of the water in the tissue remains frozen even at -7ºC and bio-chemical
> processes are slowed to an acceptable level at warmer temperatures than -18ºC
> (sorry but I have no backup evidence for this which is an assumption based on
> not having come across micro problems in temperature abused frozen fish).
> Flavour deterioration, lipid oxidation and toughening, which are quality issues,
> will be more rapid in product that suffers abuse through temperature rise and
> fluctuation but I still I do not see that freezing is a safety CCP other
> than to kill parasites. The only other way in which it is a CCP is as Hector
> says as a regulatory CCP, i.e. a legal requirement but if we bring in all the
> legal requirements as CCPs, whether safety or quality, are we not digressing
> from the point of analyzing for safety hazards and risk? After all the border
> inspection posts are welcome to turn a product back on the grounds of a poor
> temperature history but this does not make it a matter of safety.
>
>
>
> With respect to the Lake Victoria fishery, we deal with this too and I am
> aware of all the issues raised by Alain. It is as he says serviced by high
> quality factories that would certainly pass muster here in the UK. The refusals
> for entry to the EU that I have heard of have been on the grounds of out of
> specification micro counts, although I would not be surprised to hear of
> organoleptic issues being raised too. Sometimes the refusal has stood, sometimes
> it has been recanted; in the latter case there is an indication that
> commercial interests were at stake i.e. that the purchaser had over ordered.
>
>
>
> The catching side of the fishery is very difficult to advance, particularly
> with respect to getting ice onto the dhows and canoes in remote areas; ice
> means purified water, which means plant and power, maintenance, safety from
> theft and putting into vessels that are not designed for the carrying ice. The
> alternative is to use supplies from existing distant sources. In addition
> the lake water is always at least 24ºC and the fish may hang in it for 8 or
> more hours due to the difficulty and dangers of navigating to nets in remote
> areas. It is a night fishery and staying with the nets brings in the serious
> dangers of attack by armed pirates (expressed to me by fishermen) and changes
> in weather conditions.
>
>
>
> The temperature issue though vital, is one of quality not safety.
>
>
>
> Regards, Richard Chivers
>
>
>
>
>
> -----Original Message-----
> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
> Of Schalk Alain
> Sent: 12 October 2005 08:53
> To: seafood@ucdavis.edu
> Cc: Lupin, Hector (FIIU); oscar.doporto
> Subject: RE: inquiry about cold storage being considered as CCP
>
>
>
> Dear friends,
>
>
>
> This debate is again very interesting and the presentation made by Hector is
> indeed very good….
>
>
>
> To me there is a simple example to illustrate the importance of the
> temperature records in the life and quality of a given product…
>
>
>
> Perche fillets from Victoria lake in Tanzania represent a huge economical
> potential for this country. The product is attractive and cheap but has huge
> difficulties to
>
> enter the EU because it very often fails the EU quality regulations. This is
> something very difficult to understand when one knows that the processing
> plants are mostly supported by foreign investments and can be qualified to my
> point of view as high tech. plants…..so why can’t they match the quality
> standards for EU ?
>
>
>
> Their storage area are beautiful and well maintained so nobody would find a
> risk exposure there but ahead of the plant in the field there is a lot to say
> about the “artisanal” catch Process which gives little
> importance/consideration to the cooling/icing and storage parameters and the product
> unfortunately reaches the plant already with a rather poor quality because of a lack of
> proper temperature chain management….and the risk exposure, the CP, the CCP or
> whatever you call it was there and as a result of not being addressed
> properly the fish gets damaged and looses quality as well as shelf life…
>
>
>
> So all along a given supply chain, the temperature must remain safe and in
> certain cases a deviation at a certain point might even create a KP killing
> point for the entire process. In fact depending on the field reality a storage
> or transport temperature assessment might be given more or less critical
> importance and unfortunately there is no book or manual which could clearly give
> instructions on the subject.
>
>
>
> Surprised to see that Paul Dion has not spoken yet on the subject….
>
>
>
> Regards.
>
>
>
> Alain Schalk
>
>
>
>
> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
> Of oscar.doporto
> Sent: 12 October 2005 00:03
> To: Lupin, Hector (FIIU)
> Cc: seafood@ucdavis.edu
> Subject: Re: inquiry about cold storage being considered as CCP
>
>
>
> Dear Hector,
>
> Each time I am approaching the condition of being ready for the "psy" after
> suffering from exotic interpretations of the EU regulations, you point out
> the matter.
>
> In fact, many European (national services inspectors, going on time to time
> to give some "help" to third countries) spread the idea of all hygiene
> aspects being associated to critical points. I so manuals and guidelines proposing
> HACCP model plans containing about 15 critical points for the most simple
> case of little processes raw product...Additionally the regulation introduce
> the idea of "own-checks" supposed to be equivalent to HACCP but they do not
> trust in the companies "own-control" and, as a consequence in many third
> countries, the inspectors are still convinced that the results depends on the
> inspector presence and interference.
>
> About limits of temperature the interpretations ca be really extreme. My
> view is that frozen storage should no be considered a CCP. How important should
> be a deviation for involving the idea of "Hazard", given in the point (c)
> bellow?.<FONT COLOR="#000000" BACK="#ffffff" style="BACKGROUND-COLOR: #ffffff" SIZE=3 PTSIZE=12 FAMILY="SANSSERIF" FACE="Ari
>
> But what do you think about rejecting (with consequent destruction) tons of
> lobsters because not arriving alive either at a temperature of 0°C to +2°C
> (the criteria for fresh fish in the 493, but referred to the transportation
> and preservation of fresh product in the respective chapter, being a final
> product and not a raw material) having the only problem of being captured and not
> having the time to cool down in the abundant ice present!!!
>
> The problem comes from mixing "hygiene" with process parameters control,
> and taking out from its intention and framework certain regulatory texts.
>
>
>
> (b) CCP is called "Critical Point"
>
> (c) "Hazard is a potential to cause harm to health and is anything covered
> by the hygiene objectives of Directive 91/493/EEC" (bold and Italics mine)
>
>
>
> In addition, with the horizontalisation of regulation, the situation will
> suffer further deterioration.
>
>
>
> Tanks for the opportunity to talk about ,
>
> Best regards
>
> <FONT COLOR="#000000" BACK="#ffffff" style="BACKGROUND-COLOR: #ffffff" SIZE=2 PTSIZE=10 FOscar do Porto
>
> International Consultant
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
> ----- Original Message -----
>
> From: Larry Wyatt
>
>
>
>
> To: Lupin, Hector (FIIU)
>
> Cc: richard@fishonline.co.uk ; alma tina ; seafood@ucdavis.edu
>
> Sent: Tuesday, October 11, 2005 6:33 PM
>
> Subject: Re: inquiry about cold storage being considered as CCP
>
>
>
> Hector,
>
> I think your explanation of the difference between HACCP and regulatory
> actions based on HACCP is excellent, and more important, is that it is too often
> overlooked.
>
> Larry Wyatt
> FoodHorizon Inc.
> www.foodhorizon.com
>
>
>
> Lupin, Hector (FIIU) wrote:
>
>
>
> Dear colleagues:
>
>
>
> This is a very interesting discussion, that pops up very frequently. I think
> that there are some general considerations:
>
>
>
> (i) Regulatory HACCP is not HACCP (e.g. in the sense of HACCP according the
> Codex Alimentarius) but a regulation based on HACCP. Therefore, in principle,
> you have to comply with a regulation and not just with the dry HACCP
> principles and/ or steps.
>
> (ii) Regulations, as any other piece of knowledge, is open to
> interpretations. "Interpretations" are usually a problem. Inspection agencies in general
> make every possible effort to make interpretations, of their own officers,
> uniform. But not always succeed.
>
> (iii) One of the aspects of HACCP-based regulations is that they determine
> directly or indirectly "regulatory hazards"; this means hazards that you
> shall be taken into account in your HACCP plan, regardless which could be your
> own technical opinion. In the case of the US FDA HACCP-based regulations
> theoretically you may eventual appeal (if you are in the US), based on scientific
> grounds. However, for most "regulatory hazards" the possibility somebody could
> demonstrate they are not hazards (e.g. histamine in pelagic fish) is usually
> very remote.
>
>
>
> Regarding the EU directives there are a couple of things to clarify
> (translate from EU English to USA English):
>
> (a) HACCP for fish and fish products is called "own-checks".
>
> (b) CCP is called "Critical Point"
>
> (c) "Hazard is a potential to cause harm to health and is anything covered
> by the hygiene objectives of Directive 91/493/EEC" (bold and Italics mine)
>
> (from Commission Decision 94/356/EC of 20 May 1994)
>
>
>
> Going to Council Directive 91/493/EEC we found the following:
>
> <FONT COLOR="#000000" BACK="#ffffff" style="BACKGROUND-COLOR: #
>
> (1) "- frozen fishery products, with the exception of frozen fish in brine
> intended for the manufacture of canned foods, must be kept at an even
> temperature of -18 º C or less in all parts of the product, allowing for the
> possibility of brief upward fluctuations of not more than 3 º C, during transport;"
> (Council Directive 91/493/EEC, Annex, Chapter VIII, Storage and Transport,
> Point 1) (bold mine)
>
>
>
> (2) "3. Storage rooms must have a temperature recording device in place
> where it can easily be read. The temperature sensor of the recorder must be
> located in the area furthest away from the cold source, i.e. where the temperature
> in the storage room is the highest. Temperature charts must be available for
> inspection by the supervisory authorities at least during the period in
> which the products are stored." (Council Directive 91/493/EEC, Annex, Chapter IV,
> Special Conditions for Handling Fishery Products on Shore, II Conditions fro
> frozen products, Point 3) (bold mine)
>
>
>
> And finally, and perhaps the most important for this discussion:
>
>
>
> (3) "Critical limits may be derived from a variety of sources. When not
> taken from regulatory standards (e.g. frozen storage temperature) or from
> existing and validated guides of good manufacturing practices, the team should
> ascertain their validity relative to the control of identified hazard and critical
> points" (Commission Decision 94/356/EC, Chapter II, Point 1). (bold mine)
>
>
>
> In this case the regulation is not saying that the cold storage temperature
> is a CP (a CCP); but is given all the indications in that sense (critical
> limit, tolerance, measurement and record keeping and use it as regulatory
> example). The need for corrective actions, in the case of deviations, is obviously
> a result; and the need for verifications of measurement and record equipment
> fall into the general principle of verification and calibration and
> re-calibration of measurement equipment. Therefore we have our regulatory hazard and
> CP (or CCP).
>
>
>
> Again, the possibility that in this situation a fish inspector from the EU
> do not consider the temperature in a cold storage room a CP (a CCP) is remote.
> He/ she may eventually accept that continuous records could be replaced by
> recorded lectures, say every 3-5 hours (taking into account the thermal
> inertia of cold storage rooms); but hardly that it is not a CP (CCP).
>
>
>
> The discussion about the rationality or not of frozen storage temperature as
> a CP (or CCP) is interesting; I am tempted to go on that, but not time now.
> In any case we should keep in mind that HACCP based regulations (or by the
> case all Risk Analysis) are based on Science, they are not Science.
>
>
>
> I have worked with people in developing countries that want to export their
> fish. People normally ask you to provide an advice that put them into the
> safe side. Which advise would you provide in this case?
>
>
>
> (Warning: from 1 January 2006 there will be a new set of EU regulations
> dealing with HACCP, and a new careful reading of regulations is necessary for all
> trading fish with the EU)
>
>
>
> Kind regards.
>
>
>
> Hector M. Lupin
>
> Senior Fishery Industry Officer (Quality Assurance)
>
> Fish Utilization and Marketing Service (FIIU)
>
> Fishery Industries Division (FI)
>
> Fisheries Department, FAO, Room F 606
>
> Viale delle Terme di Caracalla
>
> 00100 Rome, Italy
>
> Tel + 39 06 570 56459
>
> Fax + 39 06 570 55188
>
> E-mail: hector.lupin@fao.org
>
>
>
>
>
>
>
>
>
>
>
>
> -----Original Message-----
> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
> Of Richard Chivers
> Sent: 07 October 2005 16:36
> To: alma tina; seafood@ucdavis.edu
> Subject: RE: inquiry about cold storage being considered as CCP
>
> Hi Alma,
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
> These are my views:
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
>
> 1. There are no EU directives that set CCPs, these are up to the
> processor to determine.
>
> 2. I assume you refer to the Competent Authority. I would not consider
> cold (frozen) storage a CCP simply because a product that is intended to be
> kept in be frozen condition would be in breach of specifications and GMP,
> drawing in quality and safety issues. I would set the temperature control as a
> prerequisite programme; a given if you like. I.e. if the product temperature
> were outside the limits, that would be the end of it for its primary purpose
> and disposal or alternative use should be considered.
>
> 3. Pathogen growth is unlikely to present a food safety hazard due to the
> reasonable expectation that the product would be cooked. That is unless
> there were an issue with spore formers or with heat resistant toxins then there
> would be a problem. These matters would be highlighted in the analysis part
> of the HACCP. Unfortunately it is not an argument that sways opinion in
> international trade which will set stringent micro counts.
>
> 4. It is not illegal but may mean that your analysis was invalid if a CCP
> were missed. In the UK this alone would not lead to prosecution but could
> become evidence to support a prosecution if there were more serious matters
> arising from temperature abuse i.e. food poisoning.
>
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
> I hope this helps
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
> Richard Chivers
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
>
> -----Original Message-----
> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu]On Behalf
> Of alma tina
> Sent: 07 October 2005 06:34
> To: seafood@ucdavis.edu
> Subject: inquiry about cold storage being considered as CCP
>
> <!--[if !supportEmptyParas]--><!--[endif]-->
>
> Dear List,
>
>
>
> Please give me some insight or enlightening regarding the issue of
> considering cold storage as CCP.
>
>
>
> These are my questions:
>
>
>
> 1.Is there an EU directives that considers storing at cold storage as CCP.
>
> 2.Can the competitive authority insist on us to consider storing at cold
> storage as CCP.
>
> 3. Is my thinking correct, that since our product is to be fully cooked
> before consumption, then pathogen growth is not a hazard? By the way our
> products are frozen octopus and shrimps.
>
> 4. Is it illegal not to have CCP for a particular item?
>
>
>
>
>
> Plese provide some information on this issue, we badly needed the info.
>
>
>
> Thanks,
>
>
>
> Alma O. Tina
>
> almaorodiotina@yahoo.com
>
>
> Yahoo! for Good
> Click here to donate to the Hurricane Katrina relief effort.
>
>
>
>
>
>
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