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  IA #36-04, 12/28/07, IMPORT ALERT #36-04, "DETENTION WITHOUT PHYSICAL
  EXAMINATION OF HONEY AND *** BLENDED SYRUP *** DUE TO PRESENCE OF
  CIPROFLOXACIN AND ENROFLOXACIN" ATTACHMENT A 6/27/08


  NOTE: The revision of this import alert dated 12/28/2007 changes the
  name of the import alert, updates the product codes, and amends the text
  to reflect blended syrups as products of concern. 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:  All honey products (comb honey, strained honey, whipped
            honey, honey)

                 *** Blended Syrups ***

  PRODUCT
  CODE:               36C[][][][]

                 *** 36B[][]10 ***

  PROBLEM:       Fluoroquinolone (Ciprofloxacin and Enrofloxacin)
                 residues

  PAF:           FAD (Food additive)
                 ANT (Drug residues)

  PAC:           04F800
                 09006A

  COUNTRY:       See attachment

  MANUFACTURER/
  SHIPPER:       See attachment

  MANUFACTURER/
  SHIPPER ID#:   N/A

  CHARGE:        "The article is subject to refusal of admission
                 pursuant to  Section 801(a)(3) in that it appears to
                 bear or contain a food  additive, namely,
                 fluoroquinolone(s), that is unsafe within the meaning
                 of Section 409 [Adulteration, Section
                 402(a)(2)(C)(i)]."
                 *** [Charge code = UNSAFE ADD] ***

                             or

                 "The article is subject to refusal of admission
                 pursuant to Section 801(a)(3) in that it appears to be
                 adulterated in that it bears or contains the new
                 animal drug (or conversion product thereof) that is
                 unsafe within the meaning of section 512
                 [Adulteration, 402(a)(2)(C)(ii)]."
                 *** [Charge code = VETDRUGRES] ***

  OASIS CHARGE
  CODE:               UNSAFE ADD
                 VETDRUGRES

  RECOMMENDING
  OFFICES:       CFSAN, OC, DE, Imports Branch (HFS-606)
                 ORA, ORO, DIOP (HFC-170)

  REASON FOR
  ALERT:         Fluoroquinolone antibiotics, including ciprofloxacin
                 and enrofloxacin, have been used in the treatment of
                 diseases.  Enrofloxacin is approved for use in cattle
                 (21 CFR 522.812) but there are no other approvals for
                 use in other food animals.  The use of
                 fluoroquinolones in honey bees or their environment
                 can result in residues in honey.  Fluoroquinolones are
                 not generally recognized as safe to treat any honey
                 bee diseases nor are they approved for such use.  In
                 addition, fluoroquinolones have been prohibited from
                 extra label use in food producing animals as per 21
                 CFR 530.41 because of concerns about the threat to
                 public health.  Fluoroquinolones used to treat any
                 honey bee disease is considered to be an unapproved
                 new animal drug use within the meaning of Section 512.

                 Furthermore, fluoroquinolones are not generally
                 recognized as safe for any use in a manner that could
                 reasonably be expected to result in their becoming a
                 component of honey nor are they approved for this use.
                 Therefore, fluoroquinolones in honey are considered to
                 be unsafe food additives within the meaning of Section
                 409 of the Food, Drug, and Cosmetic Act.

                 In February 2006, the Florida Department of
                 Agriculture and Consumer Services (FDACS) became aware
                 of a problem concerning adulteration of honey with
                 fluoroquinolones.  FDACS collected and analyzed
                 samples of honey for residues of two of the
                 fluoroquinolones of concern, ciprofloxacin and
                 enrofloxacin. The state reported that residues of
                 these antibiotics were found in honey that was traced
                 back to a firm from the People's Republic of China.

                 Because of concerns about the presence of
                 fluoroquinolones in the food supply, the U.S. is
                 continuing to develop methods and strategies to detect
                 illegal residues and prevent their introduction into
                 the U.S. food supply.

                 *** In 2007, two shipments of products declared and
                 labeled as "blended syrups" were analyzed and found to
                 contain ciprofloxacin. For that reason, in December,
                 2007, blended syrups were added to this import alert
                 as a product of concern. ***

  GUIDANCE:      Districts may detain without physical examination
                 (DWPE) all shipments of honey, honey products and ***
                 blended syrups *** from the firms listed in the
                 attachment of this Import Alert.

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

  PRIORITIZATION
  GUIDANCE:      I

  FOI:           No purging required.

  KEYWORDS:      Honey, Antibiotics, Animal drugs, Food additive,
                 Fluoroquinolone, Ciprofloxacin, Enrofloxacin, ***
                 Blended Syrup ***

  PREPARED BY:   Nawab A Siddiqui, DIOP (301) 594-3871
                 Ted Poplawski, DIOP (301) 594 3849
                 Julie Mayer, CFSAN, OC, DE, Imports

  *** Nawab A Siddiqui, DIOP (301) 594-3871 (Revision, 12/28/2007) ***

  DATE LOADED
  INTO FIARS:         December 28, 2007

                        Attachment A              6/27/08

  Firms Recommended for DWPE


                           China (CN)


  Firm Name:                    Residue:       *** Product/
                           Product code ***


  Hubei Yusun Co., Ltd.         Ciprofloxacin       Blended syrup
  168 Jingwu, Hankou       36B[][]10
  Wuhan                         1/4/08
  China
  FEI# 3005404645

  Inner Mongolia Altin Bee-Keeping Co.,Ciprofloxacin     *** Honey ***
  Ltd. Jinshan Development Area      ***6C[][][][] ***
  Hohhot, China                 11/3/2006
  FEI# 3005402797

  Jiangsu Kanghong Natural Health    Ciprofloxacin  *** Honey ***
  Foods Co., Ltd                *** 36C[][][][] ***
  Tngyu North Road, Funing County    11/3/2006
  Yancheng, China
  FEI# 3004299426

  Shanghai Talside Trading Co., Ltd. Ciprofloxacin  *** Honey ***
  216 Lane 1735 Zhen Nan Rd.         *** 36C[][][][] ***
  Shanghai, China                    11/3/2006
  FEI# 3005132954


  Shunchang Industry Co., Ltd        Ciprofloxacin  Blended Syrup
  Jingmen Hi Tech Industrial         36B[][]10
  Development Z                 36B[][]10
  Hubei, Jingmen City           2/12/08
  China (Mainland)
  FEI # 3006378204

  Wuhan Shino-Foods Trade CO., Ltd.  Ciprofloxacin  *** Honey ***
  515 Luoshi Avenue, Hongshan        *** 36C[][][][] ***
  Wuhan, China                  11/3/2006
  FEI# 3005109776

                           INDIA (IN)


  Little Bee Impex              Ciprofloxacin            Honey
  Shahzada S. Kapoor       36C[][]04
  Kashmir House            6/27/08
  G.T. Road, Doraha
  Ludhiana, Punjab, India
  FEI# 2000000395

                           VIETNAM (VN)

  FIRM NAME AND ADDRESS          RESIDUE            PRODUCT/CODE

  Chaochin Industrial Co., Ltd. Norfloxacin              Honey
  Industrial Service Zone       (Fluoroquinolone         36C[][][][]
  National Highway 15      family)
  Long Binh Ward           9/4/08
  Bien Hoa City, Dong Nai
  Vietnam
  FEI # 2000009921