Hola Francisco, Feliz Ano Nuevo.
Haven't seen it so am not sure of the implications. I will try to look it
up through the SIPA website but can you highlight some of the things there
we should start addressing as an industry? SIPA chat room talked about a
possibility of destruction of cargo again if rejected in the UK - There is
fresh news from the UK that:
"the UK FSA has advised ports that any cargo found to have antibiotic
residues over the permitted tolerance level will now be destroyed " -
This is really disturbing and we are checking if it is only limited to the
UK.
Chingling
_____
From: owner-seafood@ucdavis.edu [mailto:owner-seafood@ucdavis.edu] On Behalf
Of Francisco Blaha
Sent: Sunday, January 14, 2007 5:47 PM
To: Chingling R. Tanco (mida)
Cc: seafood@ucdavis.edu
Subject: EU Market Access, Competent Authorities, and Aquaculture
Hi Ching
Since we are discussing EU Market Access, Competent Authorities, and
Aquaculture, (besides over-chlorination!)
Perhaps is good to enquire if those who have interest in these 3 issues are
aware of the implications of the recent Directive 2006/88/EC of 24 October
2006 on animal health requirements for aquaculture animals and products
thereof, and on the prevention and control of certain diseases in aquatic
animals
Particularly in terms of the interactions and competency of the "competent
authorities (or authority)" regulating, from the animal health and/or food
safety perspectives, and their ability in providing the required official
assurances.
While is a quite reasonable and necessary legislative instrument, I kind of
foresee a nightmare for us (industry)... Anyone has had a good look into it?
Cheers
-- Francisco Blaha www.franciscoblaha.comBy the way, I'm very happy that Philippines "passed" the EU visit, I'm aware that a lot of work was done, good'n'you guys! I would be there in early Feb, doing a mid term review of the present EU-TRTA, so I give you call for some feedback.
On 14/1/07 3:38 AM, "Chingling R. Tanco (mida)" <crtanco@mida-group.com> wrote:
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] <mailto:remi.michalowski@cpp.co.id%5d> 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
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%5d> 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: 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
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