Re: Chilean Sea Bass nutrient info

From: Jack Wekell (jwekell@comcast.net)
Date: Tue Apr 17 2007 - 16:23:44 PDT

  • Next message: edtjong@redchamber.com: "Re: Chilean Sea Bass nutrient info"

    Eddy
    I heard it back in my days of doing sodium content on fishery products preserved through either refrigerated seawater or brine freezing while working at NOAA. You might want to look at the sodium labeling requirements of FDA, I believe that they might have some explanation of what is acceptable there.

    I would really urge you to read the fine points of the labeling regulations, before you create that label, you might want to have your company lawyers looks closely at the regulations so that you find yourself on the wrong side of a product recall or a fine for mis-labeling. I believe that before you market, you must submit the label to FDA for approval and if so this is where you want to start talking to them. There are reasonable people in FDA and if the product you wish to market experiences wide variation in nutritional content and you can present such evidence, they can work with you on the label. The problem with a lot of fishery products is that some nutrients vary quite a bit depending on the life cycle of the fish and also where it might be caught, e.g., salmon. A cooked or processed product presents other but similar challenges.

    Jack Wekell, Ph.D.

    edtjong@redchamber.com wrote:


    Thanks. Jack. Definitely company who puts the nutrition facts on its product label shall be responsible for the content.

    Technically there are three general ways to formulate the nutrition data, i.e. direct lab analysis of the product, calculate on the basis of USDA data base or calculate with Genesis software. Forget about the direct lab analysis, we all know that both USDA database and Genesis are based on pools of tens of thousands data and should be reliable and should be accountable and "legal".

    I do not mean to make "fraud claim" and later make excuse and said "read it somewhere" where there is no source that is accountable for, but rather than find a source and said "I quote it there", such as in this case quote from alwaysfish. And my question is, is it accountable and legal?

    I have also heard about the 20% variation allowance. But I could not find where the source was from. Could you help?

    Thanks & Regards,

    Eddy


    Jack Wekell <jwekell@comcast.net>

    04/16/2007 07:26 PM
    Please respond to
    jwekell@comcast.net

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    		 edtjong@redchamber.com
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    		 seafood@ucdavis.edu
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    		 Re: Chilean Sea Bass nutrient info







    For legal labeling purposes, if the FDA asked, you would have to provide the data for the analysis on YOUR label. If YOU put it on the label, you would be held responsible for what YOU put there. If there were economic fraud involved, the excuse that "I read it somewhere" may not play too well. You are held responsible for what you put on your label. Also, be aware what FDA defines as a "label", it is not just something that you slap on a can or package, there is a bit more to it than that.

    The last I heard, many years ago (during my sodium days), the analysis for each label nutrient is permitted about a plus/minus 20% co-efficient of variation to account for natural variation. However, be aware that depending on the fish's life cycle (e.g., spawning, location, etc) there might be very high variations in each nutrient that may well exceed the 20% variation. I would suggest that you discuss this with the FDA.

    Jack Wekell, Ph.D.

    edtjong@redchamber.com wrote:

    Dear All:

    Sometimes I wonder should we copy the nutrition facts from private website as the source for our labeling? What would the legal impact be?

    Eddy
    Gerald Schlesinger <gschlesinger@blumos.cl>
    Sent by:     owner-seafood@ucdavis.edu

    04/13/2007 01:32 PM


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    		 seafood@ucdavis.edu
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    		 Re: Chilean Sea Bass nutrient info









    Chilean seabass is also known by Patagonian toothfish (*Dissostichus
    eleginoides*)

    *100 g edible weight:
    Calories...................184.0 kcal
    Protein....................13.2g
    Total lipid (fat).......14.2g
    Omega-3.................1.3g

    Source:     http://www.alwaysfreshfish.com/chilean_sea_bass.html
    *

    Gerald Schlesinger
    *BLUMOS S.A.*
    Fono: 56-2-9473343
    Fax: 56-2-9473399



    Janani Tulasendrapuram escribió:

    > Hello,
    > Is there a reliable source for finding out nutrition facts for Chilean
    > Sea Bass? I usually use the USDA nutrition library, but they don't
    > seem to have information on the above.
    >  
    > Thanks,
    >  
    > Janani

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