Uneviscerated Fish Feb 2, 2011 Food Safety Partnership
Internal organs Not removed Partially removed Head on/off Air dried Salted Smoked Defined Whole fish, pieces, ground, powdered
Food Safety Issues Clostridium botulinum Type E Processing Controls Drying Salting / Smoking Post process handling Intended use No additional preparation Seasoning / Flavoring
Prior Outbreaks USA, 1981 87: 3 outbreaks of botulism, causing 3 deaths and 11 illnesses, from eating kapchunka Kapchunka is an uneviscerated, salt cured, air dried, whole fish, which may or may not be smoked. It is consumed without further preparation, such as cooking. In 1987: 8 cases of botulism in NYC and Israel Egypt, 1991: 91 cases and 18 deaths from faseikh purchased from one store Faseikh is uneviscerated, salted mullet fish Largest type E botulism outbreak ever reported
Prior Outbreaks May 1992, NJ: 4 family members ill after eating moloha, an uneviscerated, salt cured fish. No moloha was found at the market and ultimate source not identified.
Types Kapchunka (aka rybetz, rostov) Bony fish Kagnabe Yellow Corvina Faseikh Moloha (large, small)
Uneviscerated Kangbe fish, dried and moked.
Uneviscerated small Bony fish, dried and smoked
entrails
Container of small dried, smoked Bony fish
March 2010 Joint Investigation FDA, MDA, Local Health MDA notified that MN Wholesaler was selling the product Violation of FDA Import Alert 16 74 Frozen, Refrigerated, and Ambient Temps No documentation for approved source Products Embargoed and Sampled Traceback indicated sources in Africa
Actions/Findings Issued surveillance assignment to delegated agencies Identify and visit stores potentially carrying African foods Embargo any uneviscerated fish Confirm any eviscerated fish came from approved source Samples collected Trace back investigation
Actions/Findings 120 firms reviewed by MDA and local health Dried Uneviscerated Fish found at 16 Retail Firms African & Non African Sources Products bought directly from Africa, importing firms, and distributors in TX, NJ, NY No documentation of approved source Total 760 pounds Embargoed, Condemned, Destroyed
Trace Back Unknown n Supplier 1 Supplier 2 Guinea Monrovia, Liberia Source for large Bony Source for small fish Bony fish & Kagnbe fish Unknown n Supplier 3 Source for large and small Bony Fish Unknown n Supplier 4 Source for large and small Bony Fish Importer 1 Importer 2 Importer/Supplier 3 Importer/Supplier 4 Newark, NJ Brooklyn Park, MN NW Metro Twin Cities NJ Wholesaler/Retailer 1 Brooklyn oklyn Park, MN Distributor A Brooklyn Center,, MN Retail Store 1 Retail Store 2 Brooklyn Park, MN Brooklyn Park, MN Retail Store 3 Retail Store 4 Brooklyn Park, MN Brooklyn Park, MN
MDA Press Release
Reaching the Somali & Oromo Communities through ECHO
November 2010 Joint Investigation USD AAPHIS, FDA, MDA, Local Health USDA APHIS finds suspect dried fish products in metro warehouse FDA conducts initial investigation appears to be uneviscerated Bony Fish Boxes had minimal labeling additional products? Records (invoices, BOL) are scarce and incomplete Initiate investigation at second firm found additional Bony Fish All suspect products embargoed, sampled
Critical Factors Critical Factors Food Safety Standard Length of Fish Less than 5 inches % Salt in Water Phase Greater than 10 % Water Activity Less than 0.85 Source: FDA Import Alert 16-74 Detention Without Physical Examination of Salt-Cured Air-Dried Uneviscerated Fish" Date Published 02/22/2010.
MDA Laboratory Results Critical Factor Food Safety Results Standard Average Range Length of Fish Less than 5 inches 5.681 inches 4.7 7.08inches % Salt in Water Greater than 10 % 4.3 % 2.8 6. 5 Phase Water Activity Less than 0.85 0.854 0.72 0.95
Actions/Finding Surveillance Assignments limited retail firms No products found outside of original firms Uneviserated Fish deemed Adulterated Condemnation and Destruction
Regulatory Challenges Receiving firms understanding of expectations Approved Source defined? Imported Products required wha tdocumentation is
Authorities/Expectations All agencies that can enforce the MN Food Code have power of Embargo Condemnation Food Sample Collection Look for products during inspections of relevant facilities Notify MDA if products eve nsuspect products are found.
Resources FDA Compliance Policy Guide Sec. 540.650 Uneviscerated Fish Products that are Salt cured, Dried, or Smoked (Revised) Updated 11/29/2005. http://www.fda.gov/iceci/compliancemanuals/compliance PolicyGuidanceManual/UCM124048 FDA Import Alert 16 74 Detention Without Physical Examination of Salt Cured Air Dried Uneviscerated Fish" Date Published 02/22/2010. http://www.accessdata.fda.gov/cms_ia/importalert_48.html
Resources FDA Guidance to Industry: HACCP Regulation for Fish and Fishery Products; Questions and Answers for Guidance to Facilitate the Implementation of a HACCP System in Seafood Processing (Issue Three: January 1999). http://www.fda.gov/food/guidancecomplianceregulatoryinf ormation/guidancedocuments/seafood/ucm176892.htm Title 21 Code of Federal Regulations 123: Fish and Fishery Products. http://www.accessdata.fda.gov/scripts/cdrh/cfdocs/cfcfr/cfr Search.cfm?CFRPart=123
Resources Fish and Fisheries Products Hazards and Controls Guidance: Third Edition June 2001 http://www.fda.gov/food/guidancecomplian ceregulatoryinformation/guidancedocument s/seafood/fishandfisheriesproductshazardsa ndcontrolsguide/default.htm Emergency and Community Health Outreach www.echominnesota.org