The National Health Federation’s comments on CCCF Histamine EWG 2017 – Proposed draft revision of the Code of Practice for Fish and Fishery Products (new section, for fish at risk for Scombrotoxin formation)
Specific comments – text/grammatical amendments only
Line 53 Scombrotoxin fish poisoning is caused by the ingestion of spoiled
marine fish. Some
Line 54 species contain higher levels of free histidine in their musculature than
others. Annex [X] of this
Line 55 code lists the taxonomic families and scientific names of the fish that contain more
Histidine and will accelerate histamine formation more rapidly.
Line 56 toxic levels of histamine the fastest, after death when subjected to inadequate time-
The next segment is not correct. In a study published by the Norwegian University of Science and Technology, published in Elsevier under Food Chemistry May 14th 2016. “Quality changes of salmon by-products during storage: Assessment and Quantification by NMR” Salmon was alone was found to contain some 25 different metabolites all varying in amounts through 7 days of storage that may well have a profound effect on Histamines we don’t yet understand. Especially Cadaverine, Putrescine, TMA, PCr, Creatinine, Alanine, Hypoxanthine, Inosine, Acetic acid, Succinic acid, Formic acid, Ethanol, 2,3 Butanediol, 1,3-Propanediol, Butyric acid and Tyramine. We cannot claim that the below preface of histamine alone is the culprit is “generally accepted” since studies with exposure to only histamines does not produce the same effect. It is the cumulative effect of several produced metabolites that cause SFP. This is mentioned in FAOs book. Histamines is also contained in many other foods. Neither does it address how toxins like POP dioxins, pesticides like Endosulfan, PCBs and GMO fish feed in farmed salmon increase histamine levels by preventing proper histamine processes.
59 Although detailed components of Scombrotoxin have not been identified, it is generally
60 accepted that biogenic amines produced by spoilage bacteria, especially histamine, play an
61 important role in the pathogenesis of SFP. Other biogenic amines that are also produced during
62 fish spoilage, such as cadaverine and putrescine, are thought to increase the toxicity of
63 histamine. However, in most epidemiological studies, SFP is associated with high histamine 64 levels in the incriminated fish, and the controls used to inhibit histamine-producing bacteria 65 and enzymes are also expected to be effective at preventing the formation of these other
66 biogenic amines. Therefore, histamine serves as a useful indicator compound for scombrotoxin,
67 and histamine is monitored for Scombrotoxin control purposes.
69 Histamine is produced in fish and fishery products by spoilage bacteria that are part of the
70 natural microflora of the skin, gills, and gut of freshly caught fish. After fish die, these
71 migrate into the fish musculature (previously sterile) where they multiply under suitable time-72 temperature conditions. When histamine-producing bacteria multiply in fish flesh, they
73 produce the enzyme histidine decarboxylase that converts naturally present histidine into the 74 toxic metabolite histamine.
Line 483 – 485 This section is incorrect in saying that canned fish is protected until opening. A
Russian study published in 2016 “The problem of histamine in fishery
products”, studied 2000 samples from domestic and international fish such as
mackerel, herring, salmon, tuna families, and wide range of fresh, salted,
smoked and canned products. It found 80% of fish doesn’t exceed toxic
histamine levels, but that frozen, smoked and canned mackerel and frozen tuna is
most likely to exceed safe histamine levels of 50mg/kg. It also found canned
salmon to contain histamine levels of 20-40 mg/kg, and frozen salmon and trout
to contain histamine levels of 12-55 mg/kg so FAO’s determination that salmon
should be excluded due to a lack of histamine is incorrect. In addition the study
addressed how aged, canned, and smoked fish does increase in histamines.
Aged canned Mackerel and tuna in water doesn’t increase in histamines, but tuna in oil increased 150%, and aged canned salmon increased in histamines by 700%. This means canned fish may only have a shelf life of 1 year. Presently expiration dates are 2-4 years.