IA #36-01 - 11/3/97 REVISED, "Adulteration of Honey"
Note: This alert is being revised to reflect updated information.
New changes are bracketed by asterisks (***)
TYPE OF ALERT: Guidance
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 : Honey
PRODUCT CODE : 36C[][][]
PAC FOR
COLLECTION : 21004
PROBLEM : Adulteration (MSSS)
PAF FOR
COLLECTION : ***EDE (Economic Deception)***
COUNTRY : All Countries (ZZ, 999)
MANUFACTURER : N/A
MANUFACTURER/
I.D.# : N/A
CHARGE : "The article is subject to refusal under 801(a)(3)
in that it appears that corn or cane sugar has
been substituted in whole or in part for the
product, honey." [Adulteration, Section 402(b)(2)]
or
"The article is subject to refusal under 801(a)(3)
in that it appears that damage or inferiority has
been concealed." [Adulteration, Section 402(b)(3)]
or
"The article is subject to refusal under 801(a)(3)
in that it appears that corn or cane sugar has
been added to or mixed with the product, honey, so
as to increase its bulk or weight, or reduce its
strength, or make it appear to be of greater value
than it is." [Adulteration, Section 402(b)(4)]
RECOMMENDING
OFFICE : Division of Import Operations & Policy,
HFC-170
Division of Field Science (HFC-140)
REASON FOR
ALERT : During the past several years there have been
detentions of imported honey due to adulteration
with corn or cane sugars. Detentions have been
from Brazil, Mexico and the Soviet Union.
These detentions were based on analytical results
received from Geochron Laboratories. This fast
analytical technique measures the C-13/C-12
isotope ratio of the sugars in the sample.
FDA laboratories do not have the instrumental
capability to analyze honey according to the
***Official Methods of Analysis of AOAC
International, Vol. 2, 16th Ed., Chapter 44,
Method 991.41, which requires an isotope ration
mass spectrometer***.
GUIDANCE: Surveillance of imported honey from all countries
is indicated.
Districts requiring this analysis should contact
one of the following laboratories:
1) Geochron Laboratories
Division of Krueger
Enterprises, Inc.
24 Blackstone Street
Cambridge, Massachusetts 02139
Tel: (617) 876-3691
Fax: (617) 661-0148
2) Coastal Science Laboratories, Inc.
6000 Mountain Shadows Drive
Austin, Texas 78735
Tel & Fax nos.: (512) 288-5533
3) Center for Applied Isotope Studies
University of Georgia
CAIS Building
120 Riverbend Road
Athens, Georgia 30605
Tel: (706) 542-1395
Fax: (706) 542-6106
Arrangements should be made by phone with the
laboratory ahead of time. Approximately two ounces of
sample should be shipped via express mail. Normally,
results can be expected within 3 to 10 days and the
cost ranges from $40 to $50 per analysis; the charge
for expedited analyses can be slightly higher.
***The findings of partial substitution of cane or
corn sweetners in honey should be referred by fax to
CFSAN, Division of Field Programs before detention is
considered. The presence of cane or corn sweetener
in the adulteration of honey can be selectively
detected by using the internal standard stable carbon
radioisotope ratio method. Reference for the
appropriate analytical technique is published in the
Official Methods of Analysis of AOAC International,
Volume II, 16th. ed., Chapter 44, Method 991.41. C-4
Plant Sugars in Honey. Both stable carbon isotope ratios
for the honey and protein therein (internal standard
method) must be obtained.
An appropriate alternate method may be used to
determine cane or corn sweetener in honey if the
method is adequately documented by a validation study
to estimate precision, accuracy, sensitivity, for the
specific analyses. Equivalency to the official method
must be demonstrated in the submission of analytical
data***.
For questions or issues concerning science, science
policy, sample collection, analysis, preparation, or
analytical methodology, contact the Division of Field
Science at (301) 443-3320 or 3007.
PRIORITIZATION
GUIDANCE : III
FOI : No purging is required.
KEYWORDS : Honey, Adulteration, Private Laboratories,
Guidance,
sugars
PREPARED BY: Jack Geltman, SDWG, DIOP, HFC-172,
301-443-6553
DATE LOADED
INTO FIARS: November 3, 1997
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