Jump to content

  • Quick Navigation
Photo
- - - - -

Microbiological criteria for RTE snow crab for export to the US?

microbiology requirement RTE Regulation


  • You cannot start a new topic
  • Please log in to reply
12 replies to this topic

Rachel Hache

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • Canada
    Canada

Posted 13 April 2021 - 06:42 PM

Hi everyone! I am a new supervisor in a snow crab processing company. I am looking for a guide, a table or documents that tell me the microbiological criteria to meet for export to the US. Thanks for your advice 



Scampi

    Fellow

  • IFSQN Fellow
  • 3,920 posts
  • 1068 thanks
743
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 13 April 2021 - 06:54 PM   Best Answer

It may be buried in this link

https://inspection.c...7/1304428174144


Please stop referring to me as Sir/sirs


Thanked by 1 Member:

Rachel Hache

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • Canada
    Canada

Posted 13 April 2021 - 07:12 PM

What could I do if a found a Listeria monocytogenes in our product.  What are we suppose tu do?  Un sampling of 5 sample by lot?  But I need a guide to confirm what I need to continue.



Scampi

    Fellow

  • IFSQN Fellow
  • 3,920 posts
  • 1068 thanks
743
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 13 April 2021 - 07:38 PM

Whoa-ok    Here are 2 CFIA docs to help  Listeria Control Policy and the Sampling Plan

 

By the by-I would HOLD product (recall any if it's already shipped) and retest

 

 

https://inspection.c...on or more of L.

 

The following outlines the parameters for determining the L. monocytogenes risk category of a RTE food:

https://inspection.c...4/1528203403149

 

https://inspection.c...on or more of L.


Please stop referring to me as Sir/sirs


Thanked by 1 Member:

Slab

    Grade - SIFSQN

  • IFSQN Senior
  • 426 posts
  • 200 thanks
99
Excellent

  • United States
    United States
  • Gender:Male
  • Location:The Heel of the Boot
  • Interests:Reading (history, science fiction), Photography, drawing,food safety, metrology, TQM, hoplology, etc.

Posted 13 April 2021 - 07:42 PM

Please see attached guidance for CFR 21 part 123 on pathogens, toxins, and chems;

 

Attached File  Fish-Fishery-Products-Hazards-Controls-FDA-EPA-Safety-Levels-in-Regulations-and-Guidance-Appendix5-August2019 .pdf   490.43KB   8 downloads

 

If any of the limits in attachment are exceeded then you need to recall product. 


Food Safety News  Marine Stewardship Council

 

"Some people freak out when they see small vertebra in their pasta" ~ Chef John


Thanked by 2 Members:

Rachel Hache

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • Canada
    Canada

Posted 13 April 2021 - 07:43 PM

I have the informations for the Canada, but it's for export into US that I can't find anything

Do you have something for US market?



Scampi

    Fellow

  • IFSQN Fellow
  • 3,920 posts
  • 1068 thanks
743
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 13 April 2021 - 07:56 PM

The doc that Slab attached says any detectable limits of l.mono are not permitted. So you need to ensure that your holding and testing prior to exporting

 

 the United States has a “zero tolerance” for L.mono in RTE foods.  A zero tolerance policy means absence of L.mono in 25 gram samples (i.e., less than 1 in 25 g, or less than 0.04 in 1 g), which is typically reported by microbiology laboratories as <1/25g or <0.04/g.

According to the U.S. Food and Drug Administration (FDA), this standard is currently in effect whether or not a food supports the growth of L.mono.


Please stop referring to me as Sir/sirs


Thanked by 1 Member:

Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,987 posts
  • 5292 thanks
1,261
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 14 April 2021 - 07:27 AM

Hi everyone! I am a new supervisor in a snow crab processing company. I am looking for a guide, a table or documents that tell me the microbiological criteria to meet for export to the US. Thanks for your advice 

 

Hi Rachel,

 

Few comments/queries.

 

Some info on presentation would have been useful. I assume frozen and not vac.packed.

 

(1) Rachel - I was personally unable to locate any US data via links in Post 2. Were you ? If so what (or where) were the result(s) ?

 

(2) I speculate that the directly relevant data in Slab's useful attachment may mostly be those that referenced FDA's compliance programme x.842,/policy y.300 +  Shank et al (also see below).  (+ ??) . Unfortunately the current x.842 FDA document seems elusive as far as data is concerned. (older versions of document differ regarding some values and have some additional requirements).

 

My prediction is that definite items in Slab's attachment listed under  "BIOLOGICAL" are -  2(older versions do have this in x.842 ), 3, 5(older versions differ quantitatively) and maybe 4(IMEX of frozen raw seafood [not crab] this was not tested afaik).

 

Sampling for Salmonella is presumably FDA's massive BAM scheme. L.monocytogenes no idea, maybe same since identical requirement ? ("Presence" is a remarkably unquantitative statement !!)

 

Might mention that certain States of USA, eg Texas, appear to have their own additional import micro requirements for crabmeat.


Kind Regards,

 

Charles.C


Thanked by 1 Member:

Rachel Hache

    Grade - Active

  • IFSQN Active
  • 4 posts
  • 0 thanks
0
Neutral

  • Canada
    Canada

Posted 14 April 2021 - 11:35 AM

Yes It's frozen crab - in shell

 

Thanks everyone for you help!

 

It'will be SO easy if FDA could share a chart with all the microbiological specification!



Scampi

    Fellow

  • IFSQN Fellow
  • 3,920 posts
  • 1068 thanks
743
Excellent

  • Canada
    Canada
  • Gender:Not Telling

Posted 14 April 2021 - 11:52 AM

HAHAHA the FDA never shares pertinent information in a timely or easily accessible format---part of the reason they have so many issues

 

Seriously, this is the same organization that took months and months to tell us that animal feces were contaminating lettuce when you could see the animals, the canal and the lettuce field in a photo all at once!!!

 

I have used askFSIS before, it's not quick, but you will get an answer

 

Also, dont be afraid to ask your inspector for assistance, CFIA is a good resource  (that you're paying for i might add)


Please stop referring to me as Sir/sirs


poof

    Grade - Active

  • IFSQN Active
  • 10 posts
  • 1 thanks
1
Neutral

  • United States
    United States

Posted 14 April 2021 - 06:23 PM

AskFSIS is for USDA related questions- however seafood is under FDA jurisdiction..

 

Here is a link to FDA/EPA agreed upon values.. https://www.fda.gov/.../80400/download

 

This is not import specific, but I hope this is at least a starting point for you!



Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,987 posts
  • 5292 thanks
1,261
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 15 April 2021 - 05:22 AM

AskFSIS is for USDA related questions- however seafood is under FDA jurisdiction..

 

Here is a link to FDA/EPA agreed upon values.. https://www.fda.gov/.../80400/download

 

This is not import specific, but I hope this is at least a starting point for you!

 

Hi gballard,

 

Thks but yr link seems  identical to that in Post 5 and discussed in subsequent posts.


Kind Regards,

 

Charles.C


Charles.C

    Grade - FIFSQN

  • IFSQN Moderator
  • 18,987 posts
  • 5292 thanks
1,261
Excellent

  • Earth
    Earth
  • Gender:Male
  • Interests:SF
    TV
    Movies

Posted 15 April 2021 - 07:22 AM

Yes It's frozen crab - in shell

 

Thanks everyone for you help!

 

It'will be SO easy if FDA could share a chart with all the microbiological specification!

 

Hi Rachel,

 

JFI/clarity I have illustrated what I deduce to be the most likely micro requirements (ie 2-5) for frozen, RTE, crab from 2019 document and compared to data in previous edition of FDA Fishery manual (2011)

Attached File  Comparison of RTE Micro. Data 2011, 2019 - FDA-EPA REGS.xlsx   352.17KB   1 downloads

 

And, JFI here is the equivalent, official(afaik) FDA-EPA data for 2001  (micro. solely related to  Compliance Program 7303-842/Policy).

(this pdf may have subsequently been replaced by the appendix 5 in successive editions of the Fishery manual).

Attached File  FDA-EPA safety levels in regs and guidance,3rd ed,2001.pdf   125.2KB   0 downloads


Kind Regards,

 

Charles.C






0 user(s) are reading this topic

0 members, 0 guests, 0 anonymous users