USDC Seafood
Inspection Program
Policy on Filtered
Smoke Process
Background





USDC Involvement Began in 1997
GRAS Petition (1998)
USDC Inspection Policy (1998)
FDA Import Bulletin – 16B-95
Response to GRAS Petition
USFDA Concerns



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





Request for Service
Review Documentation
Site Visit (Twice per Year)
Color Measurements
Analytical Analysis
–
–
–


Histamine
Protein Swabs
Microbiological Swabs
Letter and Report
Approved List of Facilities
–
http://seafood.nmfs.noaa.gov
Collection of Color Data

Collected at Selected Process Points
–
–

Day 1 – 5 for Each Set (Thawed)
–

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




Photographs at Each Stage
Gas Analysis
Sensory Analysis
Histamine Analysis
Color Theory

Color Can Be Separated Into Three Stimulus Points
(CIELab Scale—L*, a*, b*)
–
–
–


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







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




Define “Near Normal” Tuna Color
Commercial Factor
a* Value Dramatically Affected by the Process
Recommended Standard:
a* = 16.2
Policy Status



Standard Field Tested
No Adjustments to Standard Warranted
Meetings
–
–
–
–
Industry
Importers and Retailers
Regulatory Agencies
Consumer Organizations
Enforcement of Standard

Present Results
–
–


AFDO Meeting (June 2002)
Publications
Federal Register Notice
Final Standard Set (September 2002)
Decomposition Study

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

Evaluate Four Quality Levels
–

Three CO Concentration Levels
–

1-5%, 20%, 50% or greater
Two Exposure Times
–

High Pass, Borderline Pass, Borderline Fail, High Fail
24 Hours, 48 Hours
Two Decomposition Temperatures
–
Iced, Ambient
Decomposition Study Milestones



Sample Preparation – March 2002
Sensory Panel Analyses – April 2002
Final Report – June 2002
Labeling Issues

Processed Product
–
–

Any Statement on the Label, Must Fully Comply with
Labeling Laws (Net Weight)
Nutritional Labeling
Bulk Pack vs Retail Pack
–
–
–
Under 2lbs—Possible Retail Pack
Individual Steak Packs
Selling to Wholesale Consumer Clubs