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IA #16-121 - 8/17/04 - REVISION OF IMPORT ALERT #16-121, "DETENTION WITHOUT
PHYSICAL EXAMINATION OF ***PROCESSED*** SEAFOOD PRODUCTS DUE TO E.COLI",
ATTACHMENT 4/19/05

          NOTE:     This revision changes the name of the alert and adds a firm
                    and product to the attachment which lists firms and products
                    subject to detention without physical examination. Changes
                    are bracketed by asterisks (***)

TYPE OF ALERT: Detention Without Physical Examination

          NOTE:     This import alert contains guidance to FDA field personnel
                    only.  It does not establish any requirements, or create any
                    rights or obligations on FDA or on regulated entities.

PRODUCT:       *** Processed *** Seafood Products

PRODUCT
CODE:               16[][][][] (as identified on attachment)

PAC FOR
COLLECTION:         03844

PAF FOR
COLLECTION:         MIC (Microbiological contamination)

COUNTRY:       See attachment

MANUFACTURER:  See attachment

MANUFACTURER/
I.D.#:         See attachment

CHARGE:        "The article is subject to refusal of admission pursuant to
               Section 801(a)(3) in that it appears to contain excessive
               levels of E. coli indicative that it has been prepared,
               packed, or held under insanitary conditions whereby it may
               have become contaminated with E. coli, whereby it may have
               been rendered injurious to health" [Adulteration, Section
               402(a)(4)]."

RECOMMENDING
OFFICE:        Division of Import Operations & Policy, HFC-170 NYK - Import
               Branch (HFR-NE152)

REASON FOR
ALERT:         New York Import Branch collected a sample of frozen cooked
               clam meat.  Analysis by the Northeast Regional Laboratory
               revealed excessive levels of E. coli.

               The Center for Food Safety and Applied Nutrition is prepared
               to support detention without physical examination in
               instances where excessively high   levels of E. coli are
               found.  These levels are an indication that the product has
               been processed under insanitary conditions thereby creating
               a potential threat to the health of consumers.  This meets
               the criteria established in the August 1995 issue of the
               Regulatory Procedures Manual (RPM), Chapter 9, Subchapter -
               Automatic Detention, Recommendations Based on One Violative
               Sample, Item 1, namely, that consumption of this product may
               have adverse health consequences to consumers, warranting a
               class 1 or class 2 recall.

GUIDANCE:      Districts may detain without physical examination
               ***products*** from the ***manufacturers*** identified in
               the attachment to this alert.  Sampling of shipments of
               ***processed seafood products*** from other processors may
               be appropriate.

               For guidance concerning sample collection, sample sizes,
               sample preparation, analytical methodology, and regulatory
               follow-up, refer to the Import Seafood Products Compliance
               Program (7303.844).

               For questions or issues concerning science, science policy,
               sample analysis, preparation or analytical methodology
               contact the Division of Field Science at (301) ***827-7605
               or 7606***.

PRIORITIZATION
GUIDANCE:      I

FOI:           No purging is required.

KEYWORDS:      E. Coli, ***Processed Seafood Products***

PREPARED BY:   Doug Randes, SDWG, DIOP, HFC-172, 301-443-6553

DATE LOADED
INTO FIARS:         August 17, 2004


                ATTACHMENT TO IMPORT ALERT #16-121          4/19/05

LIST OF MANUFACTURERS/SHIPPERS ON DETENTION WITHOUT PHYSICAL EXAMINATION

                          HONG KONG (HK)

FIRM                               PRODUCT

Sun Wah Marine Products                 Fzn. Cooked
Tuen Mun                           Clam Meat
Hong Kong                          16E[][]02
FEI# 1000154306