Abt the water, we are using only water and ice since September 2006 (even if our Japanese buyers do not like it at all, and it created me a lot of problems ;)) ). The results are the same. The most important factors: Hygiene, clean surfaces, clean/potable water and cooling.
Abt the HACCP, it is all the power of the ISO 22000... Even if the CA does not like it at all and does not want to understand ! But Regulation EC No 882/2004 recognizes the standard. ISO 22K goes further than Codex directive on HACCP implementation. We see what is about to happen with the FVO inspection...
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 14, 2007, at 1:35 AM, Chingling R. Tanco (mida) wrote:
Hi Liz,
In the case of shrimp processing, there was still a lot of processing and
washing at much lower ppm that the chlorine dissipates by the time you get
to the final step. There would be the initial wash of 3 dips at 50ppm then
2 washes at 0ppm, then shrimp is beheaded then washed again at 20ppm 0ppm
0ppm, then sizing then again washing at 5ppm 0ppm, then weighing and final
wash before layering at 5ppm and 0ppm. Now with the EU requirements packers
are only allowed to use "potable" water with no additional chlorine added.
It will be interesting to see how this affects TPC levels (if at all).
There's a more scientific explanation but we were there for QC-ing and there
was never a smell while waiting for the contact freezers.
For Shahul Hameed
I agree that a HACCP plan should be a live document that should be able to
address any deficiency with a risk analysis and a risk aversion plan but
some of our government officials are not always broad minded and like to
look at absolutes and fall in love with the power they have as competent
authority or auditor.
Chingling Tanco
-----Original Message-----
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of Liz Brown
Sent: Sunday, January 14, 2007 1:34 AM
To: Seafood research and extension information exchange
Subject: Re: The EU inspections and the chlorinated water
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<mailto: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>
<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>
[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>
<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>
<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>
<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@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>
<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>
<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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<table draining to floor drain hole.JPG>
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the specific purpose of being used by the individual or entity to
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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--- 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, copy, circulate, rely on or use any of the information contained in this transmission.
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