RE: The EU inspections and the chlorinated water

From: Chingling R. Tanco \(mida\) (crtanco@mida-group.com)
Date: Sat Jan 13 2007 - 05:52:22 PST

  • Next message: Remi Michalowski: "Re: The EU inspections and the chlorinated water"

    HI Francisco and Remi,

    Thanks for the discussion on this and I am fascinated here as I see the
    regulations you quote and the so called rationale and the Codex allowed use
    at 10ppm.

     

    Historically in practice, chlorine used to be used in shrimp washing (for
    the USA) at levels as high as 50ppm for raw material coming in from the
    ponds, and several washes afterwards decreasing to 20ppm and then even still
    about 5ppm at the final wash water and maybe even final water put in with
    the blocks before entering the contact freezer. This goes back almost 15
    years ago. Things have changed and some of these levels have fallen but i
    know some people’s HACCP plans accepted by US buyers have washes at the
    20ppm level, and this was caught during the EU visits to Indonesia and the
    Philippines about 2 years ago and that is the first many people here,
    including government officials heard that no chlorine should be used on
    product – yes – even tuna with skin.

     

    Are other treatments acceptable? I know that in china, they dip the final
    fillets (especially after CO or filterned smoke treatments), in an ozonated
    water bath. Is this considered an additive and thus also not acceptable for
    EU?

     

    Another sanitation issue that came up in the recent EU visits to the
    Philippines was the drainage from tables (processing tables – whether for
    beheading or sizing or peeling/cutting of shrimp or other product
    processing) and the splashing of the water from these tables to the floor.
    EU inspectors felt that that drainage water should not splash on the floor
    because the splash of potentially “dirty” or “contaminated” water from
    product will get to boots of workers and as workers walk around the plant,
    this contamination would spread and especially if it comes into contact with
    ice in the ice storage, then this contamination could move from the ice back
    to product and contaminate product. So not only does the EU prefer that
    tables be outfitted with long chutes for water to not simply drain down and
    “SPLASH” into the floor and into boots, they would much prefer that the long
    chutes or pipes draining water and gunk from the table, be made such that
    they drain directly into the floor drains and flow out of the plant. I
    guess the theory there is that this “dirty” water could flow through the
    floor and somehow contaminate product indirectly. I know that some
    processing plants here that were recently inspected by the EU had to redo
    their entire plant floors because they had center drains and so obviously
    the chutes from the processing tables could not go directly to those drains
    unless tables were located only above those center drains. I know many EU
    accredited plants in Indonesia that do not have this kind of drains from
    tables much less table chutes that go directly into floor drains. Our
    Bureau of Fisheries has inspectors that consider it a major defect if plant
    drains are not fit accordingly. See attached photo.

     

    Do you or anyone else on this listserve know anything about this type of
    requirement or a better rationale to this requirement and should it be a
    major infraction if processing tables are not positioned as such and drain
    to the floor perhaps without splashing but not necessarily directly into a
    floor drainhole?

     

    Regards,

    Chingling Tanco

    Mida Trade Ventures Int’l Inc.

    Manila, Philippines

     

      _____

    From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
    Of Remi Michalowski
    Sent: Saturday, January 13, 2007 8:42 PM
    To: Francisco Blaha
    Cc: seafood@ucdavis.edu; Chingling R. Tanco (mida)
    Subject: Re: The EU inspections and the chlorinated water

     

    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: <mailto:michalowski_rmi@yahoo.fr>
    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

    On 12/1/07 3:08 AM, "Remi Michalowski" <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

    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%5d>  On Behalf Of Luiz Henrique
Sent: Thursday, January 11, 2007 2:13 AM
To: 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> 
www.tilapiadobrasil.com.br  <http://www.tilapiadobrasil.com.br/>
<http://www.tilapiadobrasil.com.br/> 

      _____  

    De: Janani Tulasendrapuram [mailto:tkjanani@gmail.com]
<mailto:tkjanani@gmail.com%5d>  
Enviada em: terça-feira, 9 de janeiro de 2007 18:58
Para: 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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    table_draining_to_floor_drain_hole.JPG

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