USDC Seafood Inspection Program Policy on Filtered Smoke

USDC Seafood Inspection Program Policy on Filtered Smoke Process

Background l l l USDC Involvement Began in 1997 GRAS Petition (1998) USDC Inspection Policy (1998) FDA Import Bulletin – 16 B-95 Response to GRAS Petition

USFDA Concerns l l l Labeled as Processed Food That Has Been Treated with Tasteless Smoke or Carbon Monoxide Not Misrepresented as Fresh Frozen Seafood by Their Label Near Normal in Flesh Color

Verification Protocol l l Request for Service Review Documentation Site Visit (Twice per Year) Color Measurements Analytical Analysis – – – l l Histamine Protein Swabs Microbiological Swabs Letter and Report Approved List of Facilities – http: //seafood. nmfs. noaa. gov

Collection of Color Data l Collected at Selected Process Points – – l Day 1 – 5 for Each Set (Thawed) – l First Cut, After Exposure (Chilled State) 30 Days, 60 Days, 90 Days, 120 Days, 150 Days (Frozen Storage) To Replicate Retail Storage Conditions Control Data Collected

Additional Analysis l l Photographs at Each Stage Gas Analysis Sensory Analysis Histamine Analysis

Color Theory l Color Can Be Separated Into Three Stimulus Points (CIELab Scale—L*, a*, b*) – – – l l L* -- Black to White a* -- Green to Red b* -- Blue to Yellow Each Measurement Stimulus Can Be Statistically Manipulated Possible to Set a Standard Using Only One Stimulus

Color Scale

Statistical Design l l l l Limited Operator Variability Standard Methodology Define Curve of Untreated Data Included Bloomed Tuna Data Deleted Two Outliers Performance Characteristics Highest Value

Setting of the Colormetric Standard l l Define “Near Normal” Tuna Color Commercial Factor a* Value Dramatically Affected by the Process Recommended Standard: a* = 16. 2

Policy Status l l l Standard Field Tested No Adjustments to Standard Warranted Meetings – – Industry Importers and Retailers Regulatory Agencies Consumer Organizations

Enforcement of Standard l Present Results – – l l AFDO Meeting (June 2002) Publications Federal Register Notice Final Standard Set (September 2002)

Decomposition Study l Answer Three Key Questions – – – Can this process mask decomposition? What will decomposed tuna look like if subjected to this process? Can sensory analysis be used reliably for this product?

Decomposition Study Approach l Evaluate Four Quality Levels – l Three CO Concentration Levels – l 1 -5%, 20%, 50% or greater Two Exposure Times – l High Pass, Borderline Fail, High Fail 24 Hours, 48 Hours Two Decomposition Temperatures – Iced, Ambient

Decomposition Study Milestones l l l Sample Preparation – March 2002 Sensory Panel Analyses – April 2002 Final Report – June 2002

Labeling Issues l Processed Product – – l Any Statement on the Label, Must Fully Comply with Labeling Laws (Net Weight) Nutritional Labeling Bulk Pack vs Retail Pack – – – Under 2 lbs—Possible Retail Pack Individual Steak Packs Selling to Wholesale Consumer Clubs