Dear All:
Happy New Year!
Where can one find the specific EU directive regarding the approved uses of
chlorine solutions in seafood plants? We have heard of this issue
indirectly from processors in Indonesia who have been instructed by their
"competent" authority not to use chlorine. The "competent" authority and/or
the processors seem to be interpreting this ban as plant-wide. If this is
true, then it will be a sea-change in food plant sanitation practices. Does
the EU ban the use of chlorine in all areas of the plant, or only for
certain applications?
Thanks for any additional input.
Dan Brooks
International Food Technology, Ltd.
Bangkok
----- Original Message -----
From: "SEAWAVES" <seawavescorp@gmail.com>
To: "Remi Michalowski" <remi.michalowski@cpbahari.com>; <pdtom@ucdavis.edu>;
<seafood@ucdavis.edu>
Sent: Friday, January 06, 2006 9:53 AM
Subject: Re: Ozonator
> DearTanco,
> Good morning to you.
>
> We had exactly same situation in India eversince the competent authorities
> started approving units for EU. Though not very much prvoven but it is
> assumed that chlorine combines with proteins to form chloramines which are
> carcinogenic. So thats is why, there is fear about chlorine usage but
> nothing has been proved substantially.
>
> Secondly, to use ozone as product sanitizer, you need to use ozone in situ
> at tank where the raw material is washed as it is very very unstable and
> the
> effect is only for few seconds. therefore if you are looking for use of
> ozone as sanitizer then you can not ozonate water elsewhere and then
> bring
> it to the process floor for sanitizing as by then you would only have
> clean
> bacteria free water but it wont have residual ozone to sanitize the
> product.
> This means you need to have a separate room/cell to carry out raw material
> sanitization where ozone hazards should be considered for human beings.
>
> Further, in my opinion just looking at TPC count s of no use. There is
> natural bacterial count the organism carries and there is post harvest
> contamination which contributes to the bacterial count. The best way to
> sanitize product is to take care immediately after harvest and not to
> allow
> any cross contamination post harvest. This will minimise or even
> eliminate
> the need to sanitize the product at process plant. For this just pure
> potable and bacteria free water could be enough along with general and
> personal hygiene standards, SOPs etc. For example, the crates used for
> handling of shrimp should be washed and sanitized every time before use.
> This is major source of contamination. All handling personnel must take
> care of personal hygiene. But in case you do not have control on system
> immediately post harvest then you have no option but to use the sanitizer.
> Then you need to choose between contamination from pathogens or fear of
> carcinogenic residue (which is not substnatially proven). Now a days lot
> of
> things we use in day to day life can get classified as carrying
> carcinogenic
> residue so why bother only about chlorine.
>
> To summarise, option 1 is to use sanitizer at plant and option 2 is to use
> good systems to handle the product. The Japanese use systems and handle
> material very carefully and this comes naturally to them. This is also
> the
> reson why Japanese do not insist on systems and procedures because they
> always assume this a primary and natural requirement which does not need
> to
> be a part of formal procedure.
>
> My suggestion would be to adopt option 2 but it needs training, change of
> attitude and follow up. But it is more secured and with no side effects
> and
> of permanent nature.
>
> Have a nice day!!
> Regards Dipak
>
>
> ----- Original Message -----
> From: "Remi Michalowski" <remi.michalowski@cpbahari.com>
> To: <pdtom@ucdavis.edu>; <seafood@ucdavis.edu>
> Sent: Friday, January 06, 2006 5:39 AM
> Subject: Fw: Ozonator
>
>
>> 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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