Dear all,
All the info I got regarding the potential carcinogenic effect of chlorine
are from French research institutes, mainly related to workers' safety.
Furthermore, OK EU is concerned about them and published strict regulations
about the biocides that can be used in contact with foodstuff (and
feedstuff).
But, when you look at the positive list, the hypochlorites are forbidden,
whereas other forms of chlorine are allowed (Chlorine dioxide, sodium
chlorite).
The fact is I think EU tried to conciliate consumers' fears, scientific
concerns and economic lobbies. Like in Japan, why is Japan pretty reluctant
to Chlorine Dioxide (that offers less residues in finished products) but
allow the Electrolized Oxidizing Water (with many Japanese manufacturers of
such systems), sodium chlorite and hypochlorite use ?
Thanks for your feed-back.
Kind regards,
Remi Michalowski
Indonesia
----- Original Message -----
From: "SEAWAVES" <seawavescorp@gmail.com>
To: "Remi Michalowski" <remi.michalowski@cpbahari.com>; <pdtom@ucdavis.edu>;
<seafood@ucdavis.edu>
Sent: Saturday, January 07, 2006 7:40 AM
Subject: Re: Ozonator
> Dear Remi,
> Good morning to you.
> Thanks for your message. Is it possible to get some more literature about
> chloramines? Do you know if any istitute or university is studying this
> project?
> It is really interesting topic and has been bothering us for long.
>
> Further to Dan's querry, the use of chlorine is restricted only for direct
> contact with food product so it can still be used for sanitizing of plant
> and equipment provided again that care is taken to rinse the surfaces
> properly before use.
>
> I also thank Ambrose for his comments. I am sure many of us would feel
> the
> same. However, now the issue is, how do we sanitize the product where we
> do
> not have full control on systems? How do we ensure the product is well
> sanitized before being processed? What would be the best and least
> expensive way?
>
> Awaiting opinions.
> 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 5:19 PM
> Subject: Re: Ozonator
>
>
>> Dear All,
>>
>> You can download the regulations. Just go to Google and type the names :
>> Regulation EC No 2032/2003 (that gives the positive list of biocides) and
>> Directive No 98/8/EC (that gives you the 23 TPs denomination and EU
>> procedures for biocides registration).
>>
>> The use of chlorine is not allowed any longer for the "Foodstuff and
>> feedstuff preservation" e.g. PT 20 in the EU laws, that is to say a
>> direct
>> contact with food.
>>
>> However, the positive list is very clear, you can still use chlorine for
>> water treatment (as long as you respect EU standards for potable water)
> and
>> sanitation.
>>
>> About the doubts from Dipak, do you know why chlorine is irritating?
>> Not only because of the hypochlorous acid but also because it reacts with
>> nitrogen from proteins contained in organic material, to produce
>> chloramines, that are, according to litterature, carcinogenic...
>>
>> Kind regards,
>>
>> Remi Michalowski
>> Indonesia
>>
>> ----- Original Message -----
>> From: "Daniel Brooks" <brooks@ift-ltd.com>
>> To: "SEAWAVES" <seawavescorp@gmail.com>; "Remi Michalowski"
>> <remi.michalowski@cpbahari.com>; <pdtom@ucdavis.edu>;
> <seafood@ucdavis.edu>
>> Sent: Friday, January 06, 2006 11:04 AM
>> Subject: Re: Ozonator
>>
>>
>> > 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
>> >>> >>
>> >>> >>
>> >>> >>
>> >>> >
>> >>>
>> >>
>> >>
>> >>
>> >
>> >
>>
>
>
This archive was generated by hypermail 2b29 : Sat Jan 07 2006 - 00:22:51 PST