Dear List Members,
A good question and important points raised in response. Mr McHughs' comment
is critical " once the uniformity of freezer temperature is assured " The
scientific validation on frozen storage / histamine formation is appreciated
and well noted.
Would like to contribute re: Basic HACCP -
My understanding of HACCP is that Analysis should be performed on site for
the prevalent conditions on that site by the on site HACCP team for the
species, process and location including specific Hazards in the guide. This
includes consideration for distribution to end user. This would in effect mean
that no hard and fast rules can be applied universally.
This issue has been raised by USFDA during an actual audit and should be by
all auditors during audit of plant HACCP. Page 98 in the guide refers to "
control strategy examples".
Other considerations include :-
- Is the risk reasonably likely to occur ?
- Can the risk be adequately controlled ? (Equipment capacity under
all loading conditions, maintenance programs, back up generators /
compressors.....)
- Are calibrated cold store TTR's used in appropriate locations to
assure monitoring with effective hold/recall procedures in place for
deviations ? (in practice have found manual readings unreliable, this
would be critical also in refrigerated storage after testing prior to
freezing. Deviations assessed by T&T abuse per case).
- Is verification appropriate, effective and reviewed within an
appropriate period ?
- Assurance of lab testing procedures.....
- Is validation reassessed at least annually ?
Regards / AJ Simpson
Shining Sea Foods
Thailand
On 14/02/2008, Brendan McHugh <criticalcontrolpoints@yahoo.com> wrote:
>
> Based on the abstract copied below, it would seem that Histamine
> production is stopped by frozen storage so it would not be necessary to
> conduct Histamine tests on frozen product once they have been tested and
> once the uniformity of freezer temperature is assured
>
>
> English Title: *Histamine* *production* by *Enterobacter aerogenes* in
> sailfish and milkfish at various *storage* temperatures.
> Personal Authors: Tsai YungHsiang, Chang ShiouChung, Kung HsienFeng, Wei,
> C. I., Hwang DengFwu
> Author Affiliation: Department of Food Science and Technology, Tajen
> Institute of Technology, Pingtung, Taiwan.
> Editors: No editors
> Document Title: Journal of Food Protection, 2005 (Vol. 68) (No. 8)
> 1690-1695
>
> Abstract: *Enterobacter aerogenes* was studied for its growth and ability
> to promote the formation of total volatile base nitrogen (TVBN) and *
> histamine* in sailfish (*Istiophorus platypterus*) and milkfish (*Chanos
> chanos*) stored at various temperatures from -20 to 37°C. The optimal
> temperature for bacterial growth in both fish species was 25°C, whereas the
> optimal temperature for *histamine* formation was 37°C. The two fish
> species inoculated with *E. aerogenes*, when not properly stored at low
> temperatures such as 15°C for 36 h, formed *histamine* at above the U.S.
> Food and Drug Administration hazardous guideline level of 50 mg/100 g.
> Milkfish was a better substrate than sailfish for *histamine* formation by
> bacterial histidine decarboxylation at elevated temperatures (>15°C).
> Although higher contents of TVBN were detected in the spiked sailfish than
> milkfish during the same *storage* time at temperatures above 15°C, the
> use of the 30-mg/100 g level of TVBN as a determination index for fish
> quality and decomposition was not a good criterion for assessing potential
> *histamine* hazard for both fish species. Bacterial growth was controlled
> by *cold* *storage* of the fish at 4°C or below, but *histamine* formation
> was stopped only by frozen *storage*. Once the frozen fish samples were
> thawed and stored at 25°C, *histamine* started to accumulate rapidly and
> reached levels greater than the hazardous action level in 36 h.
>
> Publisher: International Association for Food Protection
>
>
>
> *"Sanchez, Sergio" <Sergio.Sanchez@inspectorate.com>* wrote:
>
> Anne,
>
> You should continue performing the histamine testing every quarter. Even
> with frozen product, temperature variances inside the cold storage could
> trigger the production of biogenic amines (e.g., histamine). For the
> actual test, you need 250g for the HPLC method and 150g for the ELISA
> method.
>
> Representative sampling information should be done in accordance with the
> FAO/WHO Codex Alimentarius standards (
> http://www.codexalimentarius.net/web/standard_list.jsp). For example,
> CODEX Standard 70 - Sampling Plans for Prepackaged Foods (1969) (AQL-6.5)
> (Ref. CAC/RM 42-1977).
>
> Regards,
> Sergio Sanchez
> Inspectorate America Corp.
>
> ________________________________
>
> From: owner-seafood@ucdavis.edu on behalf of Anne Espedal
> Sent: Wed 2/13/2008 1:50 PM
> To: seafood@ucdavis.edu
> Subject:
>
>
> I have a question regarding Albacore tuna histamine testing and HACCP.
> Page 98 of Hazards guide says you need to do quarterly histamine testing on
> a representative sample of the raw material. How do you determine what that
> sample amount should be? If you purchase only two months of the year and
> hold the product in cold storage, would you still be expected to continue
> quarterly sampling when you send lots out for production when you have
> already tested those lots?
> thank you
> Anne Espedal
> Bornstein Seafoods
> Astoria, Or
>
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>
>
> Brendan McHugh
>
> CCP International
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