Agree Remi on the question on contact with boots. Also, many ice rooms in
plants have separate foot dips before anyone is allowed to walk into the
room even from the plant so I don’t follow the logic either. Also if you
fix your tables and design the drains to the location of tables, what
happens if you want to adjust your process flows and move your tables. This
becomes very very unreasonable.
Re: Ozone - One thing I heard about ozone systems is that they do not match
with PVC pipes – I think ozone corrodes PVC so be careful.
I think that for the Philippine visit, the local Fisheries Bureau was at
much under scrutiny as the plants that were inspected so I hope the Dept of
Fisheries officials there are as prepared as the Philippine ones. Ours here
were so strict that many plants here even accused them of being more on the
side of the EU than of the Philippine exporters. To date there are only 4
plants that are EU accredited to export shrimp, so now that the ban on the
vannamei has been lifted, we need to work on getting more plants to be able
to ship to the EU when shrimp volume comes up and local prices come down.
Chingling Tanco
Managing Director,
Mida Trade Ventures Int’l Inc.
_____
From: Remi Michalowski [mailto:remi.michalowski@cpp.co.id]
Sent: Saturday, January 13, 2007 10:30 PM
To: Chingling R. Tanco (mida)
Cc: 'Francisco Blaha'; seafood@ucdavis.edu
Subject: Re: The EU inspections and the chlorinated water
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: <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 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; 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.comOn 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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