Hi Chingling,
Thanks a lot for the feed-back. It will be very very useful as the EU FVO comes here by January 22nd.
First, about the ozone, it is perfectly allowed to be used in contact with foodstuffs in EU, but you will need to check for the residues e.g. bromates.
The, about the GHPs, please keep in mind that the FVO inspectors are at 80-90% veterinarians... they have basically no education in food industry. So they have a certain sensitivity to hygiene mainly resulting from their experience in meat, poulty and farms industry.
Then, about their "rationale", I do not follow their point of view: Ice, baskets, utensils, etc. are not in direct contact with the floor (e.g. on racks). The EU legislation only states that there is no stagnant water in processing areas and that the waste waters / effluents do not accumulate and are easily disposed outside the processing areas (which leads to another issue: the washing - No washing tank shall be used to wash your material).
So, theorically, and if we analyze the risk of such "infraction", is it really relevant?
A contact with boots is pretty difficult to avoid, don't you think? as the fishery industries are pretty wet processes...
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 8:52 PM, Chingling R. Tanco (mida) wrote:
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<mailto: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: 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]<mailto:owner-seafood@ucdavis.edu%5d> 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]<mailto:tkjanani@gmail.com%5d> 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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