1 | - Southeastern Fisheries Associations’ Approach
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2 | - Phosphating agents, including tripolyphosphates and related compounds are “generally regarded as safe” (GRAS) substances that can influence the moisture content and retention in all muscle foods.
- They are allowed in applications for seafood’s THAT ARE TO BE FROZEN.
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3 | - Their use must reference an “intended effect” (i.e., moisture retention) and suit current Good Manufacturing Practices (cGMP’s) prescribed in both federal and state regulations.
- Historically, certain uses of phosphating agents with frozen seafood was to be accompanied by product labeling or ingredient statements that designated prior use, but methods to distinguish prior use beyond actual observations of the process have been lacking.
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4 | - SFA’s approach is to distinguish between the various amounts of chemical agents used.
- Shrimp with NO prior phosphating agent treatment or excessive soaking in water could be labeled “SHRIMP.”
- “Properly” phosphated shrimp could be called, "Shrimp, moisture retained.”
- “Shrimp treated in any manner to cause excess addition of water will be called “Shrimp % Water Added.”
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5 | - The distinction as to what the label must say would rest with analysis for product moisture AND total phosphorous levels.
- Both tests are very simple, rapid and inexpensive.
- Simple reliance on moisture OR phosphorous as separate measures is not reliable.
- Similar approaches have been used with
- hams,
- hams with natural juices,
- hams with water added and
- imitation hams.
- A regulatory precedent exists.
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6 | - The following recommendations are based on over 10 years of research with penaeid shrimp from both wild harvest and pond raised operations involving over 12 different species from at least 8 different countries including all southeastern states bordering the Gulf of Mexico.
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7 | - All work assured product authenticity from moment of harvest through processing, freezing, storage, thawing and standardized cooking procedures for shell-on, peeled and deveined, and breaded shrimp.
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8 | - These SFA STANDARDS are based on extensive work with trained personnel and proven sensory evaluations and numerous consumer preference studies involving sensory comparisons of various shrimp products and processes.
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9 | - According to tests conducted by the University of Florida, consumer opinions in blind tests conducted by food scientists have continually preferred; “properly” phosphated shrimp over non-phosphated shrimp products.
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10 | - Despite this extensive work, these STANDARDS should be verified by commercial interests to assure their products and processes conform to the listed guidelines before requesting regulatory intervention.
- Current regulatory enforcement is lacking and misguided by errant assumptions for product content, intended effects and ingredient labeling.
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11 | - The SFA STANDARDS that follow for peeled and deveined shrimp and shell-on shrimp attempt to address these issues and offer guidance for commercial use, regulatory surveillance and consumer welfare
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