Dear All,
There are several EU regulations about the use of biocidal products in
contact with foodstuff:
- Directive No 98/8/EC
- Regulation EC No 1896/2000 amended by Regulation No 2032/2003 -
Positive list of sanitizers allowed to be used
As a matter of fact, EU distinguishes 23 "types of product" or PT (Can be
used for water desinfection, preservation of foodstuff, sanitation of
equipment in contact with foodstuff, etc). The chlorine or hypochlorite is
not classified as PT 20 or Food and Feedstuff Protection Substance, as a
result cannot be used in DIRECT contact with food, BUT IT IS STILL OK FOR
SANITATION PURPOSE (even if indirect contact with foodstuf).
Actually, we are facing to this problem... We studied different
possibilities:
> Ozone
> Chlorine dioxide
> Acidified Sodium chlorite (or Stabilized chlorine dioxide)
> Pool of food grade additives (acids)
> Mix of sucroesters
> Natural biocidal - Citrofresh
Ozone is nice because well-accepted by our customers (and in every country)
BUT the operating costs are very high and it has strong oxidizing
properties, which is a problem for pretty old equipment. Furthermore, if
badly handling, the O3 is toxic for human (furthermore, who cannot say that,
in the future, some residues or by-products are carcinogenic?).
The best solution we found (low investments, easy-to-handle, no maintenance)
is the Acidified Sodium Chlorite: max 50 ppm (as allowed by US FDA) then
decreasing concentration in the process till getting virtually no residues
in the finished product...
To the question, can we use only water to clean the raw material ?
Honestly, I think yes if you respect the basics :
> Workers' hygiene (and, working in Indonesia, I know it is pretty
hard to be 100% sure)
> Equipment sanitation
> Water quality
> Material temperature (Should be kept < + 5 oC AT EVERY MOMENT TILL
FREEZING)
The problem is we cannot ensure that these items are fully respected... and
the sanitizers will always be a way to help us being a "safety player"...
Thanks for your attention.
Remi Michalowski
Indonesia
> ----- Original Message -----
> From: "Chingling R. Tanco (crtanco)" <crtanco@mida-group.com>
> To: "'Pamela Tom'" <>; "'Seafood HACCP Discussion List'" <>
> Sent: Friday, January 06, 2006 5:44 AM
> Subject: RE: Ozonator
>
>
>> There are some other issues on Ozone use:
>>
>> 1. In the Philippines and Indonesia recently (last 2 years), there has
>> been
>> increased questioning on the use of sanitizers in a plant - especially
>> sanitizers to be used to clean product/raw material coming into a plant.
>> The EU has been saying that Chlorine is not allowed for use on product
>> and
>> as a consequence, more and more people have been looking at Ozone -
>> whether
>> Ozone generators to help sanitize the air in the processing areas, or
>> Ozone
>> baths for product.
>>
>> For many many years, chlorine has been the main (if at all) sanitizer
>> used -
>> for hands, footbaths, equipment, walls etc... and for markets outside of
>> Japan, even for sanitizing raw material coming in. We are going back
>> almost
>> about 20 years when many of the plants were learning the difference
>> between
>> selling Black Tiger shrimp to the Japanese vs the US market and figuring
>> out
>> that Japanese standards for product quality - freshness, firmness of
>> shell,
>> uniformity, count - were much stricter than that of the US, but the USA
>> was
>> much stricter in terms of sanitation requirements. At first plants
>> producing for Japan would have a Grade 1, a Grade 2 with some plants
>> producing PUD as a by product. Soon Grade 1.5 started emerging for the
>> USA,
>> and eventually a full U.S. grade came about as plants started
>> understanding
>> the US market needs better.
>>
>> Sanitation wise though, a standard emerged where shrimp (especially raw
>> HO
>> raw material shrimp) entering a plant from the harvest site, would first
>> be
>> dipped in a chlorine dip of as high as 100ppm with 50 ppm being more of
>> the
>> standard. It would just be a quick dip/wash, to remove the dirt and any
>> bacteria that might have been picked up during harvest. Plants would
>> increase the number of washes at all points during the process - with
>> stations having 3 washes after critical points in the plant such as -
>> station after beheading (1x 20ppm chlorine followed by 2 x 0ppm chlorine
>> washes), after sizing, after grading, with the final wash just prior to
>> putting into the cold storage having either 0 or 3 ppm chlorine.
>>
>> About 2 years ago the EU authorities came to visit both Indonesia and the
>> Philippines to review the procedures and standards that the local
>> designated
>> "competent authorities" were using for determining whether a local plant
>> was
>> to be given an "EU Number" or not and among the many issues discussed was
>> the use of Chlorine. The EU took the position that no/zero chlorine
>> should
>> be added in water that the plant used on any product, that only a level
>> of
>> chlorine used to make water "potable" should be allowed. I have asked
>> many
>> people in Asia and Europe if this standard on chlorine use was written
>> anywhere in some official regulation and todate supposedly nothing is
>> actually written. Has anyone seen anything official regulations on the
>> use
>> of chlorine?
>>
>> Questions are:
>> What other sanitizers can be or are used in plants for sanitizing at
>> different levels of processing?
>> If a plant wants to target producing raw shrimp with a TPC of 10,000 at
>> the
>> end of the processing line, is washing with potable water going to
>> achieve
>> this?
>>
>>
>> 2. A 2nd issue I remember hearing on the use of Ozone in a plant is
>> something from a brief discussion also about 15-20 years ago is that to
>> put
>> ozone into a plant for treating its water is that you need to be careful
>> about the material that your water pipes is made of. There is some
>> reaction
>> between ozone and PVC pipes if I recall, and for the ozonated water,
>> something like brass or some other material piping has to be used. Can
>> your
>> friend comment on this Pam?
>>
>> Thanks
>>
>> Chingling Tanco
>> Managing Director
>> Mida Trade Ventures International Inc/Mida Food Distributors Inc.
>> Manila, Philippines.
>>
>>
>>
>> -----Original Message-----
>> From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
>> Behalf
>> Of Pamela Tom
>> Sent: Friday, January 06, 2006 2:02 AM
>> To: Seafood HACCP Discussion List
>> Subject: Re: Ozonator
>>
>> To: Seafood HACCP Community
>>
>> Today I received addition information from two folks today that I wish to
>> share with you on the subject:
>>
>> This person is subscribed to the seafood list and e-mailed me instead of
>> the
>> listserv address which is seafood@ucdavis.edu . "In my opinion try to
>> have
>> a alternative sanitizer as compared to ozone. Ozononators are a bit
>> difficult to maintain, usually there are problems in the bubbler. another
>> problem is regarding setting proper concentrations. There dosen't seem to
>> have too cost effective methods to determine its residual
>> concentrations when compared to chlorine. So depending on your use give a
>> second thought to ozonator before purchasing."
>>
>> This person (not a seafood list subscriber) is an ozone expert and
>> consultant (and good friend of mine): "Roger Boley(Ozonice) conducted
>> tests
>> on use of ozonated ice for fish. The bottom line is ozone dissipates
>> during
>> the freezing process, and the benefit is sterilizing the water in the ice
>> so
>> that no contamination comes from the ice. It is surprising how dirty the
>> ice machines get, with subsequent high counts in the ice." He also noted
>> "Probably the most responsive manufacturer for food systems currently is
>> Del
>> Ozone."
>>
>> Pamela Tom
>>
>>
>>> Hi Jim,
>>>
>>> Here are some companies that supply or manufacture ozonators.
>>>
>>> Del Ozone http://www.delozone.com/
>>> Mazzei Injector Corp. http://www.mazzei.net/ozone_syst.htm
>>> Novazone http://www.novazone.com/
>>> Ozone Water System http://www.ozonewatersystems.com/ Ozonia
>>> http://www.ozonia.com/ Pacific Ozone Technology
>>> http://www.pacificozone.com/catalog/index.html
>>> Trailigaz http://www.trailigaz.com/profile_gb.htm
>>>
>>> Note the above was provided for your information. No endorsement of
>>> products or services is intended, nor is criticism implied of similar
>>> products which are not mentioned.
>>>
>>>
>>> Pamela Tom
>>> University of California
>>> Sea Grant Extension Program
>>
>>
>>
>
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