Dear Dipak:
I found your opinion to be very sound and well reasoned. It appears to result largely from the application of good, sound common sense, which, to me, should always prevail. I am sure that your opinion will be reassuring to many of us who probably, innately, see it the same way, but have not been able to express it so eloquently.
I completely share your view about the alleged possible carcinogenic effect of the use chlorine and feel very strongly that the benefits resulting from the discriminate use of chlorine greatly outweigh the feared disadvantages, or, putting it another way, more health problems are prevented through the discriminate use of chlorine than are caused through such usage. Admittedly, I have not researched this, but it seems to be a perfectly reasonable supposition.
Best regards.
Ambrose Johnson
From: "SEAWAVES" <seawavescorp@gmail.com>
To: "Remi Michalowski" <remi.michalowski@cpbahari.com>, <pdtom@ucdavis.edu>, <seafood@ucdavis.edu>
Subject: Re: Ozonator
Date: Fri, 6 Jan 2006 08:23:05 +0530
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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