Filthy shrimps
Started by FIQC, Sep 18 2007 10:28 PM
Hi all,
I have a question related mostly to seafood safety specialists: FDA refuses shrimps with the reason for rejection as "filthy". The FDA defines filthy as 'the article appears to consistin whole or in part of ta filthy, putrid or decomposedsubstance or be otherwise unfit for food'. How can the producer address this issue in seafood quality and safety assurance programs? FDA also says "filthy" and ' decomposition" as quality issue which need not be addressed in HACCP.
Your remarks are welcome. Regards
I have a question related mostly to seafood safety specialists: FDA refuses shrimps with the reason for rejection as "filthy". The FDA defines filthy as 'the article appears to consistin whole or in part of ta filthy, putrid or decomposedsubstance or be otherwise unfit for food'. How can the producer address this issue in seafood quality and safety assurance programs? FDA also says "filthy" and ' decomposition" as quality issue which need not be addressed in HACCP.
Your remarks are welcome. Regards
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Sounds pretty disgusting. Can anyone help FIQC with this?Hi all,
I have a question related mostly to seafood safety specialists: FDA refuses shrimps with the reason for rejection as "filthy". The FDA defines filthy as 'the article appears to consistin whole or in part of ta filthy, putrid or decomposedsubstance or be otherwise unfit for food'. How can the producer address this issue in seafood quality and safety assurance programs? FDA also says "filthy" and ' decomposition" as quality issue which need not be addressed in HACCP.
Your remarks are welcome. Regards
Dear FIQC
This is not a simple question.
Not currently involved with US business but from memory the terminology comes from the legal aspects of the FDA function which are spelled out in official standards. These are available on the IT I think although you may well know this already since you are in the USA? Basically the description you refer covers a wide range of defects such as odour, fly fragments etc all of which have specific criteria as to acceptability (or lack of) as related to defined sampling plans.
So the first requirement is to know what specific characteristics are involved and their evaluation procedures. This enables an appraisal of one’s product as per the official requirements and the setting up of an appropriate QA program. Of course, most of the basic issues are normal seafood QA but the exact US interpretations depend on the governing legalities. A lot of this is on the IT but probably requires some digging. If anybody here is currently doing seafood export to the USA, they will have it at their fingertips.?? (or nostrils
Rgds / Charles.C
This is not a simple question.
Not currently involved with US business but from memory the terminology comes from the legal aspects of the FDA function which are spelled out in official standards. These are available on the IT I think although you may well know this already since you are in the USA? Basically the description you refer covers a wide range of defects such as odour, fly fragments etc all of which have specific criteria as to acceptability (or lack of) as related to defined sampling plans.
So the first requirement is to know what specific characteristics are involved and their evaluation procedures. This enables an appraisal of one’s product as per the official requirements and the setting up of an appropriate QA program. Of course, most of the basic issues are normal seafood QA but the exact US interpretations depend on the governing legalities. A lot of this is on the IT but probably requires some digging. If anybody here is currently doing seafood export to the USA, they will have it at their fingertips.?? (or nostrils
Rgds / Charles.C
Hi FIQC:
I have heard of this situation before but with filth in imported dry mushroom. Dry mushroom from China and Hong kong was automatically put in detention by FDA for every shipment. One thing we could do was to proof that dry mushroom was safe from filth, and thus we could send dry mushroom to outsource lab to test filth. And if you get negative result of filth for 5 times on each shipment. FDA will not hold and automatically detend your goods.
Jenny
I have heard of this situation before but with filth in imported dry mushroom. Dry mushroom from China and Hong kong was automatically put in detention by FDA for every shipment. One thing we could do was to proof that dry mushroom was safe from filth, and thus we could send dry mushroom to outsource lab to test filth. And if you get negative result of filth for 5 times on each shipment. FDA will not hold and automatically detend your goods.
Jenny
Dear FIQC,
Here is some background –
In the USA, the Food, Drug and Cosmetic Act authorizes FDA to detain a regulated item that appears to be out of compliance with the act (FDA, 2002). This covers a vast range of commodities: foods, beverages, drugs, cosmetics, animal feed, chemicals, orthopaedic equipment etc. Each month, the import refusal report (IRR) is published based on data generated by the FDA's Operational and Administrative Import Support (OASIS). The data are available by country or by product commodity. Approximately 1/10 of the refused products are seafood products (Table 4.6).
The most common reason for import refusal is "filthy" which describes that the product appears to consist in whole or in part of a filthy, putrid or decomposed substance. Although details are not given for the individual products, it is assumed that microbial spoilage is the major reason for the refusal. Second in terms of rejection reason is the detection of Salmonella. Both cooked, ready-to-eat products and raw, frozen products are rejected if Salmonella is detected. Although Salmonella has its niche in the gastrointestinal tract of birds and mammals, it is a common bacterium in ponds in tropical areas and its detection may not indicate hygienic failure. Whether or not the detection in raw foods constitute a health hazard is debatable.
The category "other" covers a vast range of different reasons such as mis-labelling, lack of description of the process, or lack of verification of a HACCP plan.
(this link is bit old so some dates may hv changed –
http://www.fao.org/d...3e/y4743e06.htm )
Here is a more up-to-date survey of seafood business into USA. I have extracted a chunk-
Import Inspections at the Border
FDA relies primarily on document inspection for food safety oversight. To a lesser extent, it uses three different types of physical inspections: sensory examination, laboratory inspection, and label examination.
The types of inspection are defined below.
Review paperwork submitted by the producer to ensure it contains the health and veterinary checks and other processing information.
Microscopically test for chemicals, antibiotics, contaminants, and filth in a sample of a seafood product.
Examine color, texture, and odor of a sample of seafood product to indicate if it has decomposed.
Samples of frozen products are thawed before the examination.
Inspect the imported product packaging to ensure it conveys all the required nutritional
and content information in English.
Top Reasons For Refusal
Filth was the leading reason for the refusal of imported seafood products, accounting for between 25 percent and 30 percent of refusals each year.
As evident in Figure 13, filth was the most common reason that FDA refused seafood shipments. Although filth does include dirt, insect fragments, rodent hair, and other foreign material, as one might expect, this classification also covers decomposed seafood. Improper handling or refrigeration en route can cause fish to decompose, which U.S. border inspectors detect using sensory examinations. Laboratory inspections can also detect elements of filth.
seafoodJuly2007.pdf 1.52MB 48 downloads
Rgds / Charles.C
added - there is a lot more info on the FDA website which can be searched here -
http://www.fda.gov/search.html
Here is some background –
In the USA, the Food, Drug and Cosmetic Act authorizes FDA to detain a regulated item that appears to be out of compliance with the act (FDA, 2002). This covers a vast range of commodities: foods, beverages, drugs, cosmetics, animal feed, chemicals, orthopaedic equipment etc. Each month, the import refusal report (IRR) is published based on data generated by the FDA's Operational and Administrative Import Support (OASIS). The data are available by country or by product commodity. Approximately 1/10 of the refused products are seafood products (Table 4.6).
The most common reason for import refusal is "filthy" which describes that the product appears to consist in whole or in part of a filthy, putrid or decomposed substance. Although details are not given for the individual products, it is assumed that microbial spoilage is the major reason for the refusal. Second in terms of rejection reason is the detection of Salmonella. Both cooked, ready-to-eat products and raw, frozen products are rejected if Salmonella is detected. Although Salmonella has its niche in the gastrointestinal tract of birds and mammals, it is a common bacterium in ponds in tropical areas and its detection may not indicate hygienic failure. Whether or not the detection in raw foods constitute a health hazard is debatable.
The category "other" covers a vast range of different reasons such as mis-labelling, lack of description of the process, or lack of verification of a HACCP plan.
(this link is bit old so some dates may hv changed –
http://www.fao.org/d...3e/y4743e06.htm )
Here is a more up-to-date survey of seafood business into USA. I have extracted a chunk-
Import Inspections at the Border
FDA relies primarily on document inspection for food safety oversight. To a lesser extent, it uses three different types of physical inspections: sensory examination, laboratory inspection, and label examination.
The types of inspection are defined below.
Review paperwork submitted by the producer to ensure it contains the health and veterinary checks and other processing information.
Microscopically test for chemicals, antibiotics, contaminants, and filth in a sample of a seafood product.
Examine color, texture, and odor of a sample of seafood product to indicate if it has decomposed.
Samples of frozen products are thawed before the examination.
Inspect the imported product packaging to ensure it conveys all the required nutritional
and content information in English.
Top Reasons For Refusal
Filth was the leading reason for the refusal of imported seafood products, accounting for between 25 percent and 30 percent of refusals each year.
As evident in Figure 13, filth was the most common reason that FDA refused seafood shipments. Although filth does include dirt, insect fragments, rodent hair, and other foreign material, as one might expect, this classification also covers decomposed seafood. Improper handling or refrigeration en route can cause fish to decompose, which U.S. border inspectors detect using sensory examinations. Laboratory inspections can also detect elements of filth.
seafoodJuly2007.pdf 1.52MB 48 downloads
Rgds / Charles.C
added - there is a lot more info on the FDA website which can be searched here -
http://www.fda.gov/search.html