Jack, I totally agree with your point. Thanks.
Eddy
Jack Wekell <jwekell@comcast.net>
04/17/2007 04:23 PM
Please respond to
jwekell@comcast.net
To
edtjong@redchamber.com
cc
seafood@ucdavis.edu
Subject
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
To
edtjong@redchamber.com
cc
seafood@ucdavis.edu
Subject
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
To
seafood@ucdavis.edu
cc
Subject
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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