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Freezing exceptions/exemptions (EC) 852/2004


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#1 DRFSM

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Posted 25 October 2017 - 11:18 AM

Good day to you all,

 

I have a mental migraine trying to understand whether im understanding the regs properly or not.

 

 

So we buy Mackerel, Sprats Herring, ocasionaly wild salmon but usually Farmed salmon.

 

My understanding of this Reg is that at some point from being caught by the fisherman there must be a freezing process undertaken to ensure the death of known parasites such as Nemotodes.

 

Now from what i understand from local fisherman etc is that for example today there could be landed 500KG of mackerel that is then sent to market that day and sold as is to Mr and Mrs smith who could then take it home and cook it to be eaten.  This would not have undergone the freezing requirement to control the known hazard.

 

So would this be ilegal by the definition of the reg???

 

Additionally if i buy these fish and then store as fresh chilled, and cold smoke them for sale as ready to cook products or in the case of SALMON ready to eat raw..... would this not also be ilegal if it has not undergone the freezing process?

 

im told and advised that this has been done this way time in memorial but its got me left thinking WTF is right to be legal and to incorporate in to my HACCP plan...

 

on the one hand im reading to say it must be frozen to kill parrasites regardless of whether we sell it as RTC or RTE but then im being told in the real world of fish markets they are not being potentialy frozen from landing to market stall for Mr Mrs Smith.....unless they freeze on boat / defrost by landing to class as fresh...

 

 

Man i got a headache 

 

please somone clear this up for me....

 

Kind regards


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#2 Madam A. D-tor

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Posted 25 October 2017 - 11:47 PM

Dear DRFSM,

 

First I think you are referring to EC 853/2004 instead of 852/2004.

(ref: 853/2004, consolidated version 1-04-2016, annex III, section VIII, chapter III, point D)

 

Freezing or other treatment that kill the parasites is only needed when:

- the product will be eaten raw;

- the processing of the processed fish products is not good enough to kill the parasites.

 

Mackerel is normally not eaten raw.

Herring when eaten raw is mostly (at least it is here) heavy salted. (Dutch matje) Herring is mostly landed in Scandinavia and is frozen there. Declarations are always available for the freezing process.

Mackerel when smoked is usually warm smoking.

Salmon might be warm or cold smoking.

For wild salmon it is known that parasites can be present. So when using this for cold smoked product, the salmon should have been frozen before smoking.

(I do not think the salting before the smoking process is good enough to kill the parasites)

For farmed salmon it is common to rely on the growers for not having parasites

 

Food business operators need not carry out the freezing treatment set out in point 1 for fishery products:

(a) that have undergone, or are intended to undergo before consumption a heat treatment that kills the viable parasite. In the case of parasites other than trematodes the product is heated to a core temperature of 60 °C or more for at least one minute;

(b) that have been preserved as frozen fishery products for a sufficiently long period to kill the viable parasites;

© from wild catches, provided that:

   (i) there are epidemiological data available indicating that the fishing grounds of origin do not present a health hazard with regard to the presence of parasites; and

   (ii) the competent authority so authorises;

(d) derived from fish farming, cultured from embryos and have been fed exclusively on a diet that cannot contain viable parasites that present a health hazard, and one of the following requirements is complied with:  
   (i) have been exclusively reared in an environment that is free from viable parasites; or

   (ii) the food business operator verifies through procedures, approved by the competent authority, that the fishery products do not represent a health hazard with regard to the presence of viable parasites.

 

Above text from requirement gives also other tools to make sure parasites will not cause a food safety risk.

These are more investigation and you should make sure that the catching areas and growing areas are free of pathogens.

Normally in Western Europe the authorities will close catching areas if these contain viruses, pathogens or to much parasites. Growers are also under control of authorities.

 

Please note: also cod from Iceland is known for having parasites (depends on what site of Iceland the fish is caught)


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Madam A. D-tor

#3 DRFSM

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Posted 26 October 2017 - 08:06 AM

thanks for reply, i have been doing tons of research in to this. and im kinda shocked about my findings.

 

Having re-read the regs which you was right, 842 not 843:P 843 had the definitions of Fishery Products and Bi-valve molluscs. anyway i digress.

 

We source mackerel  which can be sold on our market stalls or to other processing entities. and as such i understand that the hazard would not be classed as significant due to the fact that the product MUST be cooked  sufficiently prior to eating. (*1 see my comment below about this) and thus would not require a CCP as a receiving of raw material, and thus would not require freezing process. This is the only way i can see that fish liek mackerel can end up on a market stall the day it landed.

 

Wild salmon which can be used as RTE (sushi / sushimi) or RTC (salmon sides / portions) gets more tricky i think. For the RTE sushi products the hazard is significant i believe and would there fore be a CCP either at receipt of salmon or in house where we would need to undertake that freezing process to ensure parasite death. However if the product is to undertake roasting step gets even more complicated because although there is a listeria kill due to temp over time being greater than 63°c for 10 minutes there is known data about how the parasites can survive cooking process....scary! because they can survive 63°c temps. cooking any hotter, i.e restaurants would result in significant quality issues.

 

Personally i feel that where the risk is significant freezing is the only way to ensure parasite death regardless of whether its RTE or RTC. 

 

Obviously like you state farmed salmon which is what we use mostly 99% is more controlled but still data exists that suggest its not fool proof..

 

*1 comment: i seen many documents on people who have dined at top restaurants where the fish has been supplied by top suppliers fully accredited /certified. and the customer has taken left overs home and found worms in them still alive!!!!!!! this is from more than 1 source also....scary...

 

Also i found this really great PDF 500+pages long albeit a few years old but has some really good info regarding this subject. and even has a table of fish highlighting the likelihood of parasites being present, and sum that up im finding that more than which is disclosed in specific regs is potentially likely to have parasites.

 

i attach a link to this pdf. Fish and Fishery Products Hazards and Controls Guidance Fourth Edition – APRIL 2011

 

chapter 5 is interesting...


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#4 Charles.C

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Posted 26 October 2017 - 09:31 AM

Hi DRFSM,

 

Maybe have a look at this -

 

https://www.fsai.ie/..._parasites.html


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Charles.C


#5 Madam A. D-tor

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Posted 26 October 2017 - 06:54 PM

Dear DRFSM,

 

We source mackerel  which can be sold on our market stalls or to other processing entities. and as such i understand that the hazard would not be classed as significant due to the fact that the product MUST be cooked  sufficiently prior to eating. (*1 see my comment below about this) and thus would not require a CCP as a receiving of raw material, and thus would not require freezing process. This is the only way i can see that fish liek mackerel can end up on a market stall the day it landed.

 

 

I think you are wrong. The hazard is significant and the control measure is the cooking process. You should make sure that there is a cooking process. If you are aware that there is no cooking process, you should take other measures. Not necessary CCP.

 

Wild salmon which can be used as RTE (sushi / sushimi) or RTC (salmon sides / portions) gets more tricky i think. For the RTE sushi products the hazard is significant i believe and would there fore be a CCP either at receipt of salmon or in house where we would need to undertake that freezing process to ensure parasite death. 

 

This is also a nice thing to discuss. I am no a fan of sushi products, but as far as I know these are still all manually produced/ processed and the salmon is sliced very thing. Because of this manual treatment, parasites will be noticed by the producer/cook. If the decision tree, you are using include the question:" is there a next step that will reduce the hazard?" this will therefore not be a CCP.

 

*1 comment: i seen many documents on people who have dined at top restaurants where the fish has been supplied by top suppliers fully accredited /certified. and the customer has taken left overs home and found worms in them still alive!!!!!!! this is from more than 1 source also....scary..

 

I do not understand this behavior. If you spend more than 70 pond per person in a good restaurant, why would you take the left overs with you?

But you are right. If I occasionally dine in a good restaurant, I occasionally get raw mackerel as starter. I don't like to eat raw fish and than immediately start to do a risk assessment somewhere in the back of my head. Conclusion is always that I am in a good restaurant which has to keep up his reputation and can not effort it to make not sure there is nothing harmful in my food.


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Kind Regards,

Madam A. D-tor




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