Responding to an earlier message - if shrimp are washed with 50ppm
chlorine don't they taste like chlorine? We went round and round about
chlorinating chute transport water for our salmon roe for that reason.
Interesting discussion!
-Liz
Shahul Hameed wrote:
>
> Hello,
> If you have a very good "risk analysis" for any process or fixture, it
> should solve all your problems. I agree with Remi on the views on EU
> inspectors, but they also hear your view points if you have one. It is
> always good for the table to drain direct into the main drainage, but
> design restrictions of the processing floor will make it difficult and
> you need to make a risk analysis and keep record.
>
> As the EU inspectors are visiting to verify the competency of the
> Competent Authorities, I believe, most of the local inspectors are
> afraid to speak out to the inspectors.
>
> Best Regards
>
> Shahul Hameed.
> Grand Lake Co for Fish,
> Abu Simbel Tourist City,
> Aswan,
> Egypt.
> Mob: +20 12 617 8081
> Fax: +20 97 340 1262
> www.Grand-lake.net <http://www.Grand-lake.net>
>
>
> ----- Original Message -----
> *From:* Chingling R. Tanco (mida) <mailto:crtanco@mida-group.com>
> *To:* 'Remi Michalowski' <mailto:remi.michalowski@cpp.co.id>
> *Cc:* 'Francisco Blaha' <mailto:francisco@ihug.co.nz> ;
> seafood@ucdavis.edu <mailto:seafood@ucdavis.edu>
> *Sent:* Saturday, January 13, 2007 4:38 PM
> *Subject:* RE: The EU inspections and the chlorinated water
>
> 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: 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@ucdavisedu]
> <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>
> 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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> exempt from disclosure under applicable law. It is intended only for
> the specific purpose of being used by the individual or entity to
> whom it is addressed. If you are not the addressee indicated in this
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> <table draining to floor drain hole.JPG>
>
>
>
>
> ---
> The information contained in this communication (including any
> attachments) is privileged and confidential, and may be legally
> exempt from disclosure under applicable law. It is intended only for
> the specific purpose of being used by the individual or entity to
> whom it is addressed. If you are not the addressee indicated in this
> message (or are responsible for delivery of the message to such
> person), you must not disclose, disseminate, distribute, deliver,
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> this transmission.
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-- Liz Brown Assistant Professor Alaska Sea Grant Marine Advisory Program School of Fisheries and Ocean Sciences University of Alaska Fairbanks PO Box 1549 Dillingham, Alaska 99576 907-842-1265 fax 907-842-3202 http://seagrant.uaf.edu/map
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