Sashimi and fish safety

From: Lupin, Hector (FIIU) (Hector.Lupin@fao.org)
Date: Wed Sep 20 2006 - 08:20:43 PDT

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    Dear colleagues,
     
    The discussion on the term "sashimi" brought us to safety aspects related to
    the consumption of raw fish. This could increase confusion in more than one
    way. First of all I understood till here that "sashimi" is Japanese for "raw
    fish" and that "sushi" can contain raw fish, but can also contain cooked or
    prepared fish and vegetables (very common "Sushi" Bars outside Japan now).
     
    From the point of view of Risk Assessment to define the characteristics of a
    whole category of products (e.g. "Sashimi"), that can encompass different
    fish species and situations, all around the world, it is a hard (if not
    impossible) work, and probably would require to define safety conditions that
    would be necessary for some species and unnecessary for others. Moreover,
    according with the main hazards detected (taken from epidemiology data) the
    relative importance of one hazard regarding the others could change according
    with the country.
     
    For instance if we take the FDA Fish and Fisheries Products Hazards and
    Controls Guidance (http://www.cfsan.fda.gov/~comm/haccp4.html) and go to
    Table #3-1 - Potential Vertebrate Species Related Hazards
    <http://www.cfsan.fda.gov/~comm/haccp4c1.html> and look, for instance, for
    "Tuna" Hazards, we find that "Tunas" are divided in two groups "small"and
    "large"; the "small" ones have the "Parasite" hazard, the large ones no. The
    "large" tunas, I guess, are these consumed as "sashimi" in Japan. If that
    were the case, to ask for freezing (to eliminate the hazard of parasites)
    would be unnecessary. But, what happens if instead large tunas alone, we have
    also "small" tunas and many other potential "sashimi" species, including
    freshwater fish? The situation may change even with reference to salmon, a
    normal raw fish utilized for "Sashimi" in Western countries (see Table# 3-1
    again), since in that case the specie may carry the parasite hazard.
     
    I took here salmon as shocking example, but it is clear that a number of
    other fish species could carry parasites of importance to human health.
    Actually under the influence of "Sashimi" and "Sushi" has also spread the
    consumption of a number of other ethnic dishes that utilize raw fish as main
    ingredient like "carpaccios" and "ceviches". I would not be surprised if (at
    least in some) western countries would be a jump in parasitism epidemiology
    records in the last decade. For sure in Brazil it has been an increase in
    human parasitism, in large cities like Sao Paolo, linked to the increased
    consumption of raw fish.
     
    A more in depth analysis (Risk Assessment) would be certainly necessary, but
    from a Western point of view, to ask for freezing before consumption of raw
    fish seems a sensible measure, in the case of possible parasite hazard.
    (Probably this type of risk assessment has been already performed in more
    than one public health agency in developed countries).
     
    However, raw fish, even in the case of absence of parasites of human health
    interest, is not per se safe. I think the Japanese regulation regarding
    Vibrio parahaemolyticus (Vp) is clear. The problem is that Vp (and other
    pathogenic vibrios like V. vulnificus and V. metschinkovii (1) are part of
    the sea water normal flora. Therefore, there is a risk here that deserves
    attention. Pending a more specific risk assessment we could extend here the
    general conclusions of the existing risk assessments of Vp in raw oysters
    (FDA and FAO/WHO) and agree that a key point to keep this hazard low, is to
    keep the fish at a low temperature (at least chilling). Low temperature
    should also take care (in principle) of other hazard associated with tunas
    (Histamine). To keep "sashimi" at a chilling temperature, is (fortunately)
    one of the key conditions for a good quality "sashimi" (2).
     
    But, it is an illusion to think that this will make, in practice, the risk of
    Vp zero. With all the due respect for the opinion of my Japanese colleagues,
    I would like to quote Cliver and Riemann (3): "Raw fish or shellfish are the
    most important source of gastroenteritis caused by this organism (V.
    parahaemolyticus) in Japan, where the high incidence is undoubtedly due to
    the national custom of eating raw fish". But the most important thing, is
    that we could not expect this situation be different outside Japan.
     
    Nevertheless, there could be other risks associated to other hazards too. A
    good candidate could be, for instance, Listeria monocytogenes (Lm). Lm does
    not form part of the normal flora of fish, but is present as a contaminant
    flora in harbours, processing facilities, etc., see for instance: (4). The
    FDA Quantitative Risk Assessment of Relative Risk to Public Health from Food
    borne Listeria monocytogenes Among Selected Categories of Ready-to-Eat Foods
    (that included raw fish) http://www.foodsafety.gov/~dms/lmr2-toc.html ,
    concluded that, raw seafood is a "low risk" food. But again, this should be
    understood with reference to the possible exposure (pathogen concentration,
    dose - size of the portion consumed- and number of meals consumed of that
    product). Different situations may require of a new risk assessment.
     
    It is necessary to notice, with reference to the FDA risk assessment of Lm in
    ready-to-eat foods, that cooking and freezing do not necessarily exclude the
    risk of Lm. For instance, raw shrimp served in Western "Sushi" bars is
    sometimes thawed (peeled or shell on) cooked shrimp. In this case the FDA
    risk assessment exercise on Lm in ready-to-eat fish concluded that concluded
    that ready-to-eat crustaceans implies a "moderate risk" to consumers,
    something to take into account in the US context.
     
    We could eventually think about the possibility of intoxication with S.
    aureus and/ or with its toxin [SFP, (Staphylococcal Food Poisoning)]. "The
    largest number of outbreaks (staphylococcal food poisoning) was 128 per year
    in Japan compared to 9.4 in the US" (Worldwide surveillance of food borne
    disease between 1985 and 1989) and "For the period 1971-1990, 14.9 % and 24.6
    % of outbreaks in Korea and Japan, respectively, were due to staphylococcal
    food poisoning" [both quotes taken from (3)]. Foods involved in SFPs (among
    others) are "fish salads... and generally high-protein leftover foods" (5).
    But, it is really raw fish the responsible for SPFs in Japan? "The frequency
    of SFPs in Japan is 20 to 25 % and rice balls are usually responsible for the
    disease occurrence" (6). As S. aureus is part of human normal flora, SFPs
    will be always there.
     
    In short, we have different potential hazards in raw fish (we could add other
    hazards to the list). Some are more serious than others, some more frequent
    than others and some will depend on local conditions (fish specie, handling
    and processing methods, functioning of the cold chain, etc.). To generalize
    about all of them is not possible.
     
    Regardless the possible definitions of "sashimi"; it seems that from the
    safety point of view the most adequate move is to perform in each case a
    Hazard Analysis ("each case is a case") and implement a HACCP Plan when
    necessary (USA) or always (EU) definitely recommended [Japan Ref. (2)] . A
    more in depth analysis (e.g. Risk Assessment) could be necessary in some
    cases. A key point that producers, industry and fish traders should
    understand is that safety is not produced just fitting at a certain point a
    regulatory requirement or definition; but to handling, storing and processing
    the fish in a way such a conditions can be actually fulfilled, at the time of
    consumption.
     
    Consumption of raw fish, in its different ways, is spreading all over the
    World, including large cities of developing countries. In view that to be
    clear about the right conditions for consumption of raw fish is not possible
    in a generalized way, additional care is necessary to prevent fish outbreaks
    for this reason. The same could be said of international fish trade of raw
    fish, taking into account that nowadays is not only Japan that imports fish
    to be consumed raw.
     
    Kind regards.
     
    Hector M. Lupin
    FAO Consultant
      
    (1) Virulence factors of Vibrio metschinkovii strains isolated from fish in
    Brazil. Maria A. Matté et al.; Food Control (in Press)
     
    (2) Quality assurance of raw fish based on HACCP concept. N. Hamada-Sato, K.
    Usui, T. Kobayashi, C. Imada and E. Watanabe.; Food Control 16 (2005) 301-307
     
    (3) Foodborne Diseases. D.O. Cliver and H. P. Riemann; Academic Press 2nd
    Edition (2002)
     
    (4) Incidence of Listeria spp in fish and environment of fish markets in
    Northern Greece. N. Soultos, et al. Food Control (in press)
     
    (5) Casarett & Doull's Toxicology, 5th Edition, 1999.
     
    (6) Toxins in Food. W.M. Dabrowski and Z.E. Sikorski. CRC Press (2005).
     

            -----Original Message-----
            From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On
    Behalf Of Jin Kim
            Sent: 20 September 2006 09:39
            To: Jon McGraw; 'Robert Greer'; 'Janani Tulasendrapuram';
    'seafood@ucdavis.edu'
            Subject: RE: sashimi question
            
            
            Hi,
             
            I have another response from another friend in Japan. Dr. Kazutaka
    Yamamoto is Laboratory Head, National Food Research Institute in Tsukuba,
    Ibaraki Prefecture, north of Tokyo. His response is almost similar to the one
    from Professor Konno in Hokkaido. I pasted his response here.
             
            There are two categories for Sashimi (eaten in the raw): raw and
    frozen fish.
            Sashimi quality is controlled by Ministry of Health, Labor and
    Welfare in Japan.
            I will translate the standards from Japanese to English.
            ***frozen fresh fish for eating raw***
            
    http://www.mhlw.go.jp/shingi/2006/05/dl/s0522-5g.pdf#search=%22%E8%85%B8%E7%
    <http://www.mhlw.go.jp/shingi/2006/05/dl/s0522-5g.pdf>
            
    82%8E%E3%83%93%E3%83%96%E3%83%AA%E3%82%AA%E3%80%80%E8%A6%8F%E6%A0%BC%E5%9F%B
            A%E6%BA%96%E3%80%80site%3Amhlw.go.jp%22
            (4) frozen fish for eating raw, which is sliced or deshelled fish and
    is raw fish frozen for eating raw, hereafter the same), must garantee a
    bacterial number (survival number) of less than 100,000 /g tested material,
    negative coliform group bacteria, and a and a MPN (most probable number) of
    Vibrio parahaemolyticus of less 100. .....
            ***fresh fish for eating raw***
            http://www.mhlw.go.jp/topics/2002/bukyoku/iyaku/4.html
    <http://www.mhlw.go.jp/topics/2002/bukyoku/iyaku/4.html>
            # sliced or deshelled fresh fish for eating raw
            composition standard (MSN of Vibrio parahaemolyticus of less 100),
    process standard (use of pasteulized see water and so forth), storage
    standard (< 10 degree C), labelling standard (to indicate "for eating raw").
            As you see the above standards, we do not have what you referred to
    as "sashimi grade".
            However, we Japanese in general have an eye for fresh fish, and we
    avoid buying and eating less fresh fish.
            Therefore, we have less food poisoning due to Sashimi than expected
    cases by European and American.
             
            This was Dr. Yamamoto's comment on "sashimi grade" in Japan. So it is
    interesting to see there are not as many food poisoning incidence in Japan as
    in America without much government intervention in the case of sashimi.
    Distributors are very serious and sincere about their own reputation and face
    to their customers. I remember what my long time friend in Minnesota once
    said when we were working for the same company in the US, I would eat sashimi
    only in Japan.
             
            Kim, Jin Moon
            Professor
            School of Food Science and Technology
            Southern Yangtze University
            Wuxi, Jiangsu Province
            China
            jmkim@sytu.edu.cn jinmoonkim01@yahoo.com
             


            Jon McGraw <JonMcGraw@seafreeze.com> wrote:

                    Hello,
                    Cannot answer the original question and I suspect "sashimi"
    means different things to different people. It not only refers to best of the
    best as far as intrinsic and extrinsic quality but then may only apply to
    certain parts of a particular fish or seafood product. The real answer has to
    come from Japan. Perhaps they have codified the term.
                     In the US it seems to be used rather cavalierly and I see
    product presented as "sashimi" grade because that's what the producer/seller
    wants to/needs to/prefers to call it. It's worth more money. Much of what I
    see certainly is not. The proof is in the pudding, you will know it when you
    eat it.
                    Freezing procedures for parasite control for products to be
    eaten raw can be found in the:
                    FDA Fish and Fisheries Products Hazards and Control Guide
    (3rd edition)
                    Chapter 5 Parasites
                    http://www.cfsan.fda.gov/~comm/haccp4e.html
                     
                    Freezing and storing at -4°F (-20°C) or below for 7 days
    (total time), or freezing at -31°F (-35°C) or below until solid and storing
    at -31°F (-35°C) or below for 15 hours, or freezing at -31°F (-35°C) or below
    until solid and storing at -4°F (-20°C) or below for 24 hours is sufficient
    to kill parasites. FDA's Food Code recommends these freezing conditions to
    retailers who provide fish intended for raw consumption.
                     
                    Note this is for PARASITE control and has little if any
    effect on the sanitary properties of the product. If it was sanitary before,
    it still will be, if it wasn't it won't be.
                     
                    Regards
                     
                    Jon McGraw
                    Seafreeze
                    Seattle
                     
                     
                    
      _____

                    From: Robert Greer [mailto:greer@rushmartrading.com]
                    Sent: Sunday, September 17, 2006 8:52 PM
                    To: 'Janani Tulasendrapuram'; seafood@ucdavis.edu
                    Subject: RE: sashimi question
                     
                    Interestingly, I've spent a not inconsiderable amount of time
    in the past month or two trying to find out the answer to this exact same
    question. I have come up with several different answers, so I think the
    "official" definition depends on whom you're talking to.
                     
                    Initially, I researched this question on the website of the
    United States FDA. There are some regs and guidance about qualifying certain
    types of fish as sashimi grade, but as best I could tell, they relate only to
    fresh water species which have different and more potential biological
    hazards than salt water specices. If memory serves, these regs require
    freezing the fish below specified temperatures for specified periods of time
    in order to insure that product that will be eaten uncooked is sanitary.
                     
                    Secondly, I inquired of my sister-in-law, who is a salesman
    for a fresh fish distributor which sells to premium restaurants. Her
    response was that sashimi refers to the very highest quality fish: "the best
    of the best."
                     
                    Lastly, I met only the other day with a supplier of seafood
    (wild caught ocean fish) in Vietnam. This company labels as "sashimi" grade,
    fish that once caught is immediately frozen on board at or below minus 55
    degrees Celsius and kept at such low temperatures continuously.
                     
                    It's my suspicion that the second and third definitions are
    essentially equivalent, though on their face, they seem to describe different
    things.
                     
                    If I learn any more about this, I'll let you know.
                     
                    Sincerely,
                     
                    Robert Greer
                     
                     
                     
                    Robert Greer
                    Rushmar Trading Company LLC
                    Tel (US): 1-713-350-6025
                    Mobile (US): 1-713-594-4996
                    Mobile (VN): 84-(0)90-966-7379
                    EFax: 1-713-583-9667
                    email: greer@RushmarTrading.com
                     
                     
                    
      _____

                    From: owner-seafood@ucdavis.edu
    [mailto:owner-seafood@ucdavis.edu] On Behalf Of Janani Tulasendrapuram
                    Sent: Friday, September 15, 2006 10:17 PM
                    To: seafood@ucdavis.edu
                    Subject: sashimi question
                     
                    Hi,
                    Good morning! I am hoping someone on this listserv will be
    able to answer the following question:
                     
                    -Is there an "official" definition of sashimi grade (mainly
    for tuna)?
                     
                    Thanks,
                     
                    Janani Tulasendrapuram




            Kim, Jin Moon
            Professor
            School of Food Science and Technology
            Southern Yangtze University
            170 Huihe Road
            Wuxi, Jiangsu Province
            China 214036
            Tel) 86-510-8340-3818
            jmkim@sytu.edu.cn jinmoonkim01@yahoo.com

            
      _____

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