Hello,
Historical perspective: Alaska, late 70's early 80's.
We flumed cooked and peeled cold water pink shrimp off the peelers in water
with 5-15 ppm chlorine (gas injected water system which was way easy to
regulate and WAY dangerous to operate). Then onto inspection belt with spray
bar underneath head of belt at minimum 5 ppm but less than 10 ppm.
Approaching 10 ppm resulted in chlorine fumes that made workers VERY
unhappy. Cutting back at either place on the line (but especially the
inspection belt) caused problems with TPC, coliform, and staph. Never had
issue with residue odor or flavor in finished product.
Yes, I hear you, what about worker hand sanitation which after all WAS a
major part of the problem. Let's just say that when I wasn't crawling in and
out of a shrimp boat hold I was observing, cajoling, berating, re hand
sanitation behavior. Would just get them trained right then 75% of crew
would leave and a new group of kids would roll in.
I have mixed feelings on this issue.
Jon McGraw
Seattle
-----Original Message-----
From: Chingling R. Tanco (mida) [mailto:crtanco@mida-group.com]
Sent: Saturday, January 13, 2007 10:36 AM
To: 'Liz Brown'; 'Seafood research and extension information exchange'
Subject: RE: The EU inspections and the chlorinated water
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
> *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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> <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.
>
> We apologize if you have received this communication in error;
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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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