Hi Francisco,
Right, Directive No 98/83 on potable water requires that the level of free chlorine at the distribution point does not exceed 0.5 ppm.
But, the EU legislation Reg No 852 and 853/2004 allow the use of CLEAN water once it is not a threat for the product safety. Clean means no pathogen, if I am right.
Anyway, use of chlorine in DIRECT contact with the foodstuff is forbidden in EU as stated in the legislation for biocidal products.
But, Codex still allows the use if below 10 ppm.
Anyway, the fact is EU FVO inspectors (I apologize to the inspectors, if registered on the list) do not know the rationale behind it.
Mainly, and I remember a visit in Indonesia, they simply state "no Chlorine in a processing plant", which has created a lot of issues for the local producers, especially for water treatment and surfaces sanitation, whereas EU legislation is clear: Sodium hypochlorite is still allowed for disinfection of surfaces in contact with foodstuffs and for water disinfection.
Chlorine use in food industry will be a long-term issue, and SANCO shall give a clear statement on this. The fact is I am sure they are pretty annoyed about this because it creates financial, technological and food safety problems (Chlorine was widely used in France and Spain for vegetables disinfection and it is still a cheap disinfectant with wide-spectrum action).
At last, you can find reports of EFSA state that sodium hypochlorite, used at the usual levels, does not appear to be a food safety issue.
Rgds,
Dipl. Ing. Remi Michalowski
Deputy General Manager IQA Food Processing
PT. Centralpertiwi Bahari - Lampung, Indonesia
HP + 62 815 4040 484
Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
CPB - Integrated Shrimp Farming. "From Pond to Plate"
A CPP Company. Member of Charoen Pokphand Group
On Jan 13, 2007, at 7:10 PM, Francisco Blaha wrote:
Hello all
As far as I understand it (mostly by having endure various EU visits), the rationale behind is that only potable water is to be in contact with the product, and they normally base their judgement on the local requirement for chlorine in potable water (around .5 to 1ppm in most countries). Hence water that has more than that is hyper chlorinated and not potable, therefore should not be in contact with the product.
Hope it helps
Best regards
-- Francisco Blaha www.franciscoblaha.com<http://www.franciscoblaha.com>On 12/1/07 3:08 AM, "Remi Michalowski" <remi.michalowski@cpp.co.id<mailto:remi.michalowski@cpp.co.id>> wrote:
Hello Chingling,
Happy new year, all my best wishes for 2007.
Indeed if u look at the EU legislation on biocidal compounds, the peracetic acid is unfortunately not registered as washing aid to be used in contact with foodstuffs, but u can still use it for water disinfection (like the sodium hypochlorite).
Abt the 5 to 10 ppm in the water, u can still try to push Philippines and other ASEAN countries to sue SANCO through WTO as Codex Alimentarius still recommend the use of chlorinated water in contact with fishery products (max 10 ppm) until the Guidance on the use of chlorinated water is issued.
Rgds,
Dipl. Ing. Remi Michalowski Deputy General Manager IQA Food Processing PT. Centralpertiwi Bahari - Lampung, Indonesia HP x2B; 62 815 4040 484 Yahoo Messenger ID: michalowski_rmi@yahoo.fr<mailto:michalowski_rmi@yahoo.fr>
CPB - Integrated Shrimp Farming. "From Pond to Plate" A CPP Company. Member of Charoen Pokphand Group
On Jan 11, 2007, at 3:11 AM, Chingling R. Tanco (mida) wrote:
Question: Your using chlorinated water in the chiller – does this mean a chiller as in refrigerator or chilling water used for the fillets? Doesn’t Europe frown on the use of chlorine on any water used for the product and if this Is correct, wouldn’t they also frown on peracetic acid? EU officials recently visited the Philippines and Indonesia and one of the main criticisms is that chlorinated water at levels of even as low as 5-10% in any wash water that would come in contact with product – whether with skin or not, is frowned upon. The problem was that many plants had this chlorinated wash in their HACCP plans because it was/is an acceptable practice for the USA and Canadian markets.
Can anyone comment on this?
Chingling R. Tanco Managing Director Mida Trade Ventures Int’l Inc,/Mida Food Distributors Inc. Manila, Jakarta, Surabaya, Ho Chi Minh City
________________________________ From: owner-seafood@ucdavis.edu<mailto:owner-seafood@ucdavis.edu> [mailto:owner-seafood@ucdavis.edu] On Behalf Of Luiz Henrique Sent: Thursday, January 11, 2007 2:13 AM To: seafood@ucdavis.edu<mailto:seafood@ucdavis.edu> Subject: RES: green coloration in frozen tilapia
Janani, The situation happened with me in two opportunities, also. All our fish is produced for instance free from drugs as malachite green (MG) and leucomalachite green (LMG) The suspicions were deterioration for resistant bacterias to the low temperature, presents in the visceras, meantime in my analyzes it was not detected an number high of resistant bacterias the low temperature. Another suspicion was the high exposition to chlorinated water in the chiller. The problem can be solved when substituting the chlorine for peracetic acid. best regards, _______________________________________________ Luiz Henrique Barrochelo Plant Manager - Veterinarian Tilápia do Brasil Ind. de Pescados de Aquicultura. Tel/Fax: 55 (18) 3694.7200 / 3694.7255 / 3694.7256 Cel: 55 (18) 9101.5787 e-mail: luizhenrique@tilapiadobrasil.com.br<mailto:luizhenrique@tilapiadobrasil.com.br> <mailto:luizhenrique@tilapiadobrasil.com.br><mailto:luizhenrique@tilapiadobrasil.com.br> www.tilapiadobrasil.com.br <http://www.tilapiadobrasil.com.br/><http://www.tilapiadobrasil.com.br/>
________________________________
De: Janani Tulasendrapuram [mailto:tkjanani@gmail.com] Enviada em: terça-feira, 9 de janeiro de 2007 18:58 Para: luizhenrique@tilapiadobrasil.com.br<mailto:luizhenrique@tilapiadobrasil.com.br> Assunto: green coloration in frozen tilapia
Hi,
I was referring to frozen tilapia fillets, and frozen for 4-5 months. If you have any knowledge of the green coloration in tilapia, I would appreciate your input.
Thanks, Janani
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