CODEX STANDARD FOR GRATED DESICCATED COCONUT

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                                      CODEX COMMITTEE ON PROCESSED FRUITS AND VEGETABLES

                                            WORKING GROUP ON GRATED DESICCATED COCONUT

                                                  DEADLINE FOR COMMENTS: 06 of January 2010

                                                                    COMMENTS TO:
                                                                    Mr Andre Oliveira
                                                         E-mail: andre.oliveira@agricultura.gov.br
                                                    PROPOSED DRAFT REVISION TO THE
                                            CODEX STANDARD FOR GRATED DESICCATED COCONUT
1
2    1.    SCOPE
3           This Standard applies to grated desiccated coconut, as defined in Section 2 below, and offered for direct
4    consumption, including for catering purposes or for repacking if required. It does not apply to the product when
5    indicated as being intended for further processing.
6    2.    DESCRIPTION
7    2.1   PRODUCT DEFINITION
8          Grated desiccated coconut is the product:
 9         (a) prepared from substantially sound white meat obtained from the whole nut of coconut (Cocos nucifera
10             L.), having reached appropriate maturity for processing;
11         (b) processed in an appropriate manner, undergoing operations of de-husking, [de-shelling] [hatcheting]      Comment [a1]: Malaysia.
12             peeling, [paring]milling, [comminuting],] drying and sifting; and                                        Comment [W2]: Philippines
                                                                                                                        Comment [a3]: Malaysia
13         (c) initially produced in a range of particle sizes.
                                                                                                                        Comment [a4]: Malaysia
14   2.2   STYLES
15   2.2.1 Grated desiccated coconut with respect to oil content may be designated as:
16         (a) [Low fat] Defatted desiccated coconut – products with total oil content between 55-6562%].               Comment [a5]: Fiji, Malaysia
                                                                                                                        Comment [a6]: Malaysia
17         (b) [High] Whole fat desiccated coconut – products with total oil content above 6562%.
                                                                                                                        Comment [W7]: Philippines
18   2.2.2 Other Styles                                                                                                 Comment [a8]: Fiji

19         Any other presentation of the product should be permitted provided that the product:                         Comment [W9]: Philippines

20         (a) is sufficiently distinctive from other forms of presentation laid down in the Standard;
21         (b) meets all relevant requirements of the Standard, including requirements relating to limitations on
22             defects, drained weight, and any other requirements which are applicable to that style which most
23             closely resembles the style or styles intended to be provided for under this provision; and
24         (c) is adequately described on the label to avoid confusing or misleading the consumer.
25   2.3   SIZING (optional)
26         Grated desiccated coconut may be [graded] [classified] according to their granulometry as follows:           Comment [a10]: Fiji.

27         (a) Extra-fine desiccated coconut - This is grated desiccated coconut of which not less than 90% of the
28             weight shall pass easily through a sieve with square apertures of 0.85 mm, but of which maximum 25% of
29             the weight passes through a sieve of 0.50 mm aperture size.
30         (b) Fine desiccated coconut - This is grated desiccated coconut of which not less than 80% of the weight
31             shall pass easily through a sieve of square aperture size of 1.40 mm, but of which maximum 20% of the
32             weight passes through a sieve of 0.71 mm square aperture size.
                                                                                                                                     2

33    (c) Medium desiccated coconut - This is grated desiccated coconut of which not less than 90% of the weight
34        shall pass easily through a sieve of square aperture size of 2.80 mm, but of which maximum 20% of the
35        weight passes through a sieve of 1.40 mm square aperture size.
36    (d) Unclassified grated desiccated coconut - covers all "fancy cuts" or special cuts (i.e. tender or thin flakes,
37        long and thin chips, extra fancy shreds, long shreds, standard shreds, etc.).
38    3.   ESSENTIAL COMPOSITION AND QUALITY FACTORS
39    3.1 COMPOSITION
40    3.1.1         Basic Ingredients
41         Grated desiccated coconut as defined in Section 2.1.
42    3.1.2         Other Permitted Ingredients
43         [.................................................]                                                                            Comment [a11]: Malaysia

44    3.2 QUALITY CRITERIA
45    3.2.1         Colour and Texture
46         Grated desiccated coconut shall have [normalnatural] white, colour [to light creamy white colour,] and                         Comment [a12]: Fiji, Philippines
47    shall posses a texture characteristic of the product.                                                                               Comment [W13]: Philippines

48    3.2.2         Flavour
49         The taste shall be characteristic of the product without off-flavours due to deterioration or absorption of
50    extraneous substances.
51    3.2.3         Odour
52         The odour shall be characteristic of the product and , shall not be mouldy, [cheesy, smoky,] fermented or                      Comment [W14]: Philippines
53    rancid, [and shall not possess any undesirable odour].                                                                              Comment [W15]: Philippines

54    3.2.4         Definition of Defects and Allowances
55

                                                                                                                    Maximum
                        Defects                                                 Definition
                                                                                                                 limitsTolerances         Comment [a16]: Malaysia,Philippines

                                                                 Fat acid content in free forms, extracted
                                                                                                                         0.3% m/m        Comment [W17]: Brazil, Malaysia
     (a) Total acidity of extracted oil                          and measured under the operating
                                                                                                               measured as lauric acid
                                                                 conditions specified.
                                                                                                                           [ 3% m/m]     Comment [a18]: Malaysia
                                                                 Loss in mass measured under the                          [ 4% m/m]      Comment [a19]: Malaysia
     (b) Moisture
                                                                 operating conditions specified.
                                                                                                                         [ 4,5% m/m]     Comment [W20]: Philippines


                                                                                                                        [ 55% m/m]       Comment [a21]: Malaysia
                                                                                                                   for defatted low fat
                                                                                                                               product
                                                                 Total oil content in product under the
     (c) Oil content
                                                                 operating conditions specified.                    [> 55  65% m/m]
                                                                                                                             65% m/m      Comment [a22]: Malaysia
                                                                                                             for whole high fat product
                                                                 Total mineral content in product under                                   Comment [a23]: Malaysia
     (d) Ash                                                                                                               2.5% m/m
                                                                 the operating conditions specified.
                                                                 Harmless vegetable matter associated                          [ 15]
     (e) Extraneous vegetable material
                                                                 with the product.                                 fragments per 100g
                                                                 Any visible and/or apparent matter or
     (f) Foreign matter                                          material not usually associated with the             Absence in 100g
                                                                 product.
                                                                                                                       3

56   3.3   CLASSIFICATION OF “DEFECTIVES”
57         A container that fails to meet one or more of the applicable quality requirements, as set out in Section 3.2
58   (except those based on sample averages), should be considered as a “defective”.                                       Comment [a24]: Rationale – Contrasting with
                                                                                                                           Codex Stan 61:1985, there is no provision in
59   3.4   LOT ACCEPTANCE                                                                                                  this document based on sample average.

60         A lot should be considered as meeting the applicable quality requirements referred to in Section 3.2 when
61   for those requirements which are not based on averages, the number of “defectives”, as defined in Section 3.3,
62   does not exceed the acceptance number (c) of the appropriate sampling plan with an AQL of 6.5, as described in
63   section 10.; and                                                                                                      Comment [a25]: Brazil

64         (b)the requirements of Section 3.2, which are based on sample averages, are complied with.                      Formatted: Bullets and Numbering

65                complied with.
66   4.    FOOD ADDITIVES
67   [     Only those food additive classes listed below are technologically justified and may be used in grated
68   desiccated coconut. Within each additive class only those food additives listed below, or referred to, may be used
69   and only for the functions, and within limits, specified.
70   4.1 [Functional class(es)] used in accordance with Table 3 of the Codex General Standard for Food Additives
71   (CODEX STAN 192-1995) for Food Category 0.4.1.2.2 – Dried Fruits are acceptable for use in grated desiccated
72   coconut conforming to this Standard.]
73   4.21 PRESERVATIVE
                         INS No.             Name of the Food Additive             Maximum Level
                                                                                   [50] [150] [200] [1000]                 Comment [a26]: Malaysia
                                                                                                     mg/kg                 Comment [W27]: Philippines
                 220-225, 227, 228, 539     Sulfites
                                                                                            as residual SO2                Comment [W28]: Brazil, Malaysia,
                                                                                         in the end product                Philippines

74   4.2   OTHER FUNCTIONAL CLASS(ES)                                                                                      Comment [a29]: Malaysia


                        INS No.              Name of the Food Additive             Maximum Level


75   5.    CONTAMINANTS
76   5.1 The product covered by this Standard shall comply with the maximum levels of the Codex General
77   Standard for Contaminants and Toxins in Food and Feed (CODEX STAN 193-1995).
78   5.2 The product covered by this Standard shall comply with the maximum residue limits for pesticides
79   established by the Codex Alimentarius Commission.
80   6.    HYGIENE
81   6.1 It is recommended that the products covered by the provisions of this Standard be prepared and handled in
82   accordance with the appropriate sections of the Recommended International Code of Practice – General Principles
83   of Food Hygiene (CAC/RCP 1-1969), the Recommended International Code of Hygienic Practice for Desiccated
84   Coconut (CAC/RCP 4-1971) and other relevant Codex texts such as codes of hygienic practice and codes of
85   practice.
86   6.2 The products should comply with any microbiological criteria established in accordance with the Principles
87   for the Establishment and Application of Microbiological Criteria for Foods (CAC/GL 21-1997).
88   7.    WEIGHTS AND MEASURES
89         [Containers shall be as full as practicable without impairment of quality and shall be consistent with a
90   proper declaration of contents for the product...................................................]                    Comment [a30]: Malaysia

91   87.   PACKAGING, TRANSPORT AND STORAGE
                                                                                                                              4

92    87.1 Grated desiccated coconut shall be packaged, transported and stored in containers which will safeguard the
93    hygienic, nutritional, technological and organoleptic qualities of the product.
94    87.2 The packaging material shall be such as to protect the product against bacteriological and other contamination;
95    it shall protect the product as far as possible against any infiltration absorption of moisture , re-hydration and against   Comment [a31]: Brazil
96    leakingspillage. The packaging material shall not impart any odour, taste or colour or any other extraneous property         Comment [a32]: Malaysia
97    to the product and shall not result in contamination of the product with the packaging material.
                                                                                                                                   Comment [a33]: Malaysia
98    98.     LABELLING                                                                                                            Comment [a34]: Malaysia

 99       In addition to the requirements of the Codex General Standard for the Labelling of Pre-packaged Foods
100   (CODEX STAN 1-1985), the following specific provisions apply:
101   98.1 NAME OF THE PRODUCT
102   98.1.1 The name of the product should be "Grated Desiccated Coconut" preceded or followed by the common or
103   ordinary name legally accepted in the country of retail sale.
104   98.1.2 The name may indicate the grade of the product in accordance with the descriptions contained in Section 2.3.
105   98.1.3 The name should indicate the oil content of the product in accordance with the description contained in               Formatted: Not Highlight
106   Section 2.2
107   98.1.34     Other styles - If the product is produced in accordance with the other styles provision (Section 2.2.2),
108   the label should contain in close proximity to the name of the product such additional words or phrases that will avoid
109   misleading or confusing the consumer.
110   98.2 Labelling of Non-Retail Containers
111          Information for non-retail containers shall be given either on the container or in accompanying documents,
112   except that the name of the product, lot identification, and the name and address of the manufacturer, packer,
113   distributor or importer, as well as storage instructions, shall appear on the container. However, lot identification,
114   and the name and address of the manufacturer, packer, distributor or importer may be replaced by an identification
115   mark, provided that such a mark is clearly identifiable with the accompanying documents.
116   109.          METHODS OF ANALYSIS AND SAMPLING

             Provision                            Method                                     Principle                Type
      Acidity total
                                         Described in the Standard                   Titration of extracted oil          I
      (in extracted oil)                                                                                                           Comment [W35]: Brazil, Malaysia

      Ash                                      AOAC 950.49                                  Gravimetry                   I
      Extraneous                                                                  Counting extraneous material
                                         Described in the Standard                                                      IV
      vegetable material                                                              with the naked eye
                                           ISO 2591-1:1988
                                       Test sieving according to                                                        I
      Granularity                                                                             Sieving
                                         British Standard Mesh                                                        (TE)*
                                    Nominal Test Sieves: BS 410-1986
                                                                                            Gravimetry
      Moisture                                 AOAC 925.40                                                               I
                                                                                         (loss on drying)
      Oil content                              AOAC 948.22                                  Gravimetry                   I
                                 Described in the StandardISO 2170-1980                                                            Comment [a36]: Brazil
                                         (Cereals and Pulses) or
      [Sampling                                                                                                          ]
                                 ICC Method of Sampling No. 101-1960
                                     (Sampling of Milled Products)
117   * Temporarily Endorsed (TE) - The 21st Session of the Committee on Methods of Analysis and Sampling extended its
118   temporarily endorsed status (ALINORM 97/23A, Appendix IV).
                                                                                                                            5

119                                DETERMINATION OF TOTAL ACIDITY OF EXTRACTED OIL
120   Principle
121   The sample is extracted by ethyl ether at room temperature. The acidity of the extracted oil is determined by titrations
122   with alkali and the results expressed as percent of lauric acid.
123   Reagents
124      Anhydrous ethyl ether, peroxide free
125      Ethyl ether and ethyl alcohol 95% (1:2) mixture neutralized with sodium hydroxide 0.1N using phenol-phthalein
126       as indicator
127      Sodium hydroxide 0.1N
128      1% ethanolic solution of phenol-phthalein
129   Procedure
130   50 g of the sample is extracted at room temperature in 500 ml erlenmeyer flask with 300 mL of ethyl ether (Reagent
131   1) for one hour with mechanical agitation. The extract is filtered through Whatman No. 542 filter paper and further
132   undergoes dry evaporation in rotary evaporator with nitrogen flow at a maximum temperature of 40 C.
133   20 g of the extracted oil is weighed and dissolved with addition of 100 mL of ethyl alcohol mixture (Reagent 2) and
134   further titrated with 0.1N sodium hydroxide (Reagent 3) using 5 drops of indicator (Reagent 4).
135   Expression of results
136   Acidity is calculated as below:
137   Acidity = VxNx20
138               m
139   V = Volume (ml) of NaOH
140   N = Normality of NaOH solution
141   m = Mass of the sample in grammes
142   The results as obtained above, are expressed in percent lauric acid m/m.
143                                            EXTRANEOUS VEGETABLE MATTER
144   The determination is carried out by spreading 100 g of the sample in a thin layer against a white background and
145   counting the extraneous material with the naked eye.
146                                                         SAMPLING
147   1.Instructions for drawing primary samples according to ISO 2170-1980 (Cereals and Pulses) or ICC Method of                Formatted: Bullets and Numbering
148          Sampling No. 101-1960 (Sampling of Milled Products).
149   2.The size of the sample to be undertaken from a homogeneous lot should be in accordance with Table 3 of the
150         Instructions on Codex Sampling Procedures (CX/MAS 1-1987, Appendix V).
151   3.For all determinations the laboratory sample should be prepared according to the variables plan for proportion
152         defective (CX/MAS 1-1987, Appendix IV).
153   4.For all determinations, except granularity (Section 2.3), analysis should be performed on the “blended bulk
154         sample”.
155   5.For verification of granulation, i.e. size grade (Sections 2.3 and 7.1) as declared on the label, the determination in
156          consignments of repacked product should be on individual packages.
                                                                                                   6

157               SAMPLING PLANS FOR PRE-PACKAGED FOODS WITH AN AQL = 6.5
158        USUALLY APPLYING TO STANDARDS FOR PROCESSED FRUITS AND VEGETABLES FOR
159             QUALITY CRITERIA AND WEIGHTS AND MEASURES (e.g. minimum fill)

                                              Sampling Plans
                           The appropriate inspection level is selected as follows:
      Inspection level I     -    Normal Sampling
      Inspection level II -       Disputes, (Codex referee purposes sample size),
                                  enforcement or need for better lot estimate
160                                        SAMPLING PLAN 1
161                                   (Inspection Level I, AQL = 6.5)
                       NET WEIGHT IS EQUAL TO OR LESS THAN 1 KG (2.2 LB)
            Lot Size (N)                      Sample Size (n)              Acceptance Number (c)
            4,800 or less                             6                               1
           4,801 - 24,000                            13                               2
           24,001 - 48,000                           21                               3
           48,001 - 84,000                           29                               4
          84,001 - 144,000                           38                               5
          144,001 - 240,000                          48                               6
         more than 240,000                           60                               7
         NET WEIGHT IS GREATER THAN 1 KG (2.2 LB) BUT NOT MORE THAN 4.5 KG (10 LB)
            Lot Size (N)                      Sample Size (n)              Acceptance Number (c)
            2,400 or less                             6                               1
           2,401 - 15,000                            13                               2
           15,001 - 24,000                           21                               3
           24,001 - 42,000                           29                               4
           42,001 - 72,000                           38                               5
          72,001 - 120,000                           48                               6
         more than 120,000                           60                               7
                                 NET WEIGHT GREATER THAN 4.5 KG (10 LB)
            Lot Size (N)                      Sample Size (n)              Acceptance Number (c)
             600 or less                              6                               1
             601 - 2,000                             13                               2
            2,001 - 7,200                            21                               3
           7,201 - 15,000                            29                               4
           15,001 - 24,000                           38                               5
           24,001 - 42,000                           48                               6
          more than 42,000                           60                               7
162
                                                                                         7

163                                SAMPLING PLAN 2
164                           (Inspection Level II, AQL = 6.5)
                   NET WEIGHT IS EQUAL TO OR LESS THAN 1 KG (2.2 LB)
         Lot Size (N)                  Sample Size (n)           Acceptance Number (c)
         4,800 or less                       13                           2
        4,801 - 24,000                       21                           3
        24,001 - 48,000                      29                           4
        48,001 - 84,000                      38                           5
       84,001 - 144,000                      48                           6
       144,001 - 240,000                     60                           7
      more than 240,000                      72                           8
      NET WEIGHT IS GREATER THAN 1 KG (2.2 LB) BUT NOT MORE THAN 4.5 KG (10 LB)
         Lot Size (N)                  Sample Size (n)           Acceptance Number (c)
         2,400 or less                       13                           2
        2,401 - 15,000                       21                           3
        15,001 - 24,000                      29                           4
        24,001 - 42,000                      38                           5
        42,001 - 72,000                      48                           6
       72,001 - 120,000                      60                           7
      more than 120,000                      72                           8
                          NET WEIGHT GREATER THAN 4.5 KG (10 LB)
         Lot Size (N)                  Sample Size (n)           Acceptance Number (c)
          600 or less                        13                           2
          601 - 2,000                        21                           3
         2,001 - 7,200                       29                           4
        7,201 - 15,000                       38                           5
        15,001 - 24,000                      48                           6
        24,001 - 42,000                      60                           7
       more than 42,000                      72                           8
                                                                                                                    8

                                  EXPLANATORY NOTES ON THE ANNEX1
GENERAL CONSIDERATIONS
The revised Standard as currently proposed is based on the Comments provided by Brazil, Fiji, Malaysia and the
Philippines.
Comments readily accepted were inserted in the document highlighting the Member Country that proposed the
change and previous wording/provision.
Comments that proposed changes in provisions or consecrated wording were inserted into brackets for further
discussion/clarification on the second phase of the WG.
Comments considered turn points were not inserted in the current version of the Annex, but discussed below and
in APPENDIX – 1 (Referring to: WGGrDesCoconut-Mess01-09) with all the comments listed for further request
of the Member Country if still needed.
SPECIFIC CONSIDERATIONS
Food Additives
The WG should decide whether the section should permit only Sulphites as food additives for the product [first
square brackets] or if the section will be revised in light of the provisions for additives available in the General
Standard for Food Additives relevant to Food Category 0.4.1.2.2 Dried Fruits currently containing more additives
than those specified in the Standard for Grated Desiccated Coconut [second square brackets].
Additionally the WG should decide if for sulphur dioxide, as a preservative, the maximum level set up for grated
desiccated coconut should be justified against the corresponding level applicable to dried fruits in the GSFA. In this
regard, four levels are proposed: 50 mg/kg (Standard in force and Malaysia), 150 mg/kg (1st version of the proposed
annex), 200 mg/kg (Philippines) and 1000 mg/kg (Food Category 0.4.1.2.2 – Dried Fruits, GSFA).
If the WG would like to refer to Tables 1/2 of the GSFA identification of the functional classes is needed, at least
those currently available for use in dried fruit.
Weights and Measures
The WG should decide whether this provision needs to be evaluated/controlled for lot acceptance.
In that case the WG needs to decide if the current sampling plan for pre-packaged foods is applicable. As a reference
there are no provisions for lot acceptance in the standards for dates and resins as regards to weights and measures.
Packaging, Transport and Storage
Although technical comments to revise the section were inserted, the WG is invited to decide whether these
provisions should be retained in the Standard, as may have been better addressed in the RECOMMENDED
INTERNATIONAL CODE OF HYGIENIC PRACTICE FOR DESICCATED COCONUT (CAC/RCP 4-1971), if
so the WG should confirm if just a reference to CAC/RCP 4-1971 is necessary before getting into the actual revision
of the provisions.
Methods of Analysis and Sampling
Provisions for methods of analysis were introduced in accordance with CODEX STAN 234-1999 listing methods of
analysis and sampling for various commodity standards.
Sampling Plans
Provisions for sampling were introduced in accordance with CODEX STAN 234-1999 listing methods of analysis
and sampling for various commodity standards.
Brazil stroke out references to ISO 13690:1999 (Cereals, Pulses and milled products – sampling of static batches), or
ICC Method of Sampling No. 101-1960 (Sampling of Milled Products) and CX/MAS 1-1987, taking in mind that
CX/MAS 1-1987 was a working document discussed in CCMAS but never adopted as official Codex texts and no
longer being further discussed in CCMAS, and because it is not customary to reference such documents.

1
    Prepared by Brazil with the aid of the Secretariat.
                                                                                                                 9

On the other hand ISO 13690:1999 specifies on the scope that is restricted to the general conditions relating to
sampling for the assessment of the quality i.e. good sampling practices.
The WG is invited to decide if these deletions are adequate and to comment on the proposed reference to a Sampling
Plan of AQL 6.5 as currently used in other CCPFV standards, taking in light the guidance provided by the Guidelines
for Sampling Plans (CAC/GL 50-2004) developed by the Committee on Methods of Analysis and Sampling for the
selection of appropriate sampling plans by Codex committees and task forces
                                                                                                 10

                                        APPENDIX – 1 (REF. WGGrDesCoconut-Mess01-09)

      CODEX COMMITTEE ON PROCESSED FRUITS AND VEGETABLES (CCPFV)

                       PROPOSED DRAFT REVISION TO THE
               CODEX STANDARD FOR GRATED DESICCATED COCONUT

                             (DOCUMENT TO GUIDE CCPFV WORK)

          STATUS OF COMMENTS FROM FIJI, MALAYSIA AND THE PHILIPPINES

1. FIJI

    Reference in the                          Member’s Comment                         Updated status
    draft document, Sept.                                                              and reference
    2009                                                                               in the revised
                                                                                       draft document
    Section 2.1 Product        insertion of the word 'fresh'                           Not Addressed.
       Definition- Line 9      - Only fresh coconuts are to be used for making
                               dessicated coconut.                              Section 2.1
                               -prepared from substantially sound white meat
                               obtained from the fresh whole nut of coconut
                               (Cocos nucifera …
    Rationale for not addressing the comment:
    Some highly flavored products are made of coconuts that are harvested and stored as long as a
    month before processing.

    section 2.2.1-lines 16      - insertion of the words 'low fat' and 'high fat'      Addressed.
    and 17                      -I think when we use the words high and low fat - it
                                will make 'naming of the product' section 8.1          Section 2.2.1
                                subsection 8.1.3 easily understandable rather than
                                putting defatted dessicated or whole fat dessicated    Lines 16, 17
                                coconut
                                - (a) Defatted dessicated coconut (low fat) , (b)
                                Whole fat dessicated coconut (high fat)
    section 2.3 Sizing-         word graded to be used instead of classified           Addressed.
    line 26                     - Word graded is to be used so that there is
                                consistency when we go to naming of the product        Section 2.3
                                under 8.1.3- it reads the name may indicate the
                                grade of the product....                               Line 26
                                -Grated dessicated coconut may be graded
                                according to their granulometry as follows..
    section 3.2.1 Colour        word normal to be replaced by natural                  Addressed.
    and texture                 - Use of the word natural in this context seems
    line 46                     more appropriate- (how can a person define             Section 3.2.1
                                normal white colour)
                                - Grated dessicated coconut shall have natural         Line 44
                                white colour and shall ...
    section 5 Contaminants      section 5 contaminants (add line 81 and 81 as 5.3)     Not Addressed.
    section 6 Hygiene           - section 6.2 should come under contaminants as
    lines 70 - 82               section 5.3
                                - Section 6.2 is setting out microbiological
                                compliance and as such is a reflection of the
                                                                                               11

   Reference in the                           Member’s Comment                         Updated status
   draft document, Sept.                                                               and reference
   2009                                                                                in the revised
                                                                                       draft document
                             hygiene operation but is going to give the level of
                             contamination.
   According to the Procedural Manual (Format for Codex Commodity Standards), for the
   presentation of standards, a Format that describes a uniform presentation separating Hygiene
   provisions from Contaminants.

   Section 7. Packaging,        Suggestion that the Packaging, transport and Addressed.
   transport and storage        storage should be better addressed under Code of
   lines 85 - 91                practice

2. MALAYSIA

   Reference in the                           Member’s Comment                     Updated status
   draft document, Sept.                                                           and reference
   2009                                                                            in the revised
                                                                                   draft document
   •Title of standard           deleting the term ‘grated’ preceding the name of Not Addressed.
   •Section 1-Scope, line 3     the product appearing in the title and throughout
   •Section 2.1-Product         the standard.
   Definition, line 8           Desiccated coconut is characteristically a grated
   •Section 2.2-Styles, line    product and is internationally accepted and traded
   15                           as such without explicitly indicating the term
   •Section 2.3-Sizing,         ‘grated’ to its name.
   lines 26, 27, 30 and 36
   •Section 3.1.1-Basic
   Ingredients, line 41
   •Section 3.2.2-Colour
   and Texture, line 46
   •Section 4-Food
   Additives, line 66
   •Section 7-Packaging,
   Transport and Storage,
   line 86
   •Section 8.1-Name of
   the Product, line 96
   Rationale for not addressing the comment:
   Current document adopted the term “grated” and the terminology “grated desiccated coconut” is
   easily translated and understandable in Spanish and French versions of the documents.

   Section 2.1-Product          We propose the following:-                             Addressed.
   Definition, para (b), line   i.      To replace the terms ‘peeling’ and ‘milling’
   11                           with ‘de-shelling’ and ‘paring’ respectively.          Section 2.1
                                ii.     To add in the term ‘comminuting’ before
                                ‘drying’.                                              Lines 11, 12
                                The proposed terms are more commonly used in
                                describing the processes involved in the
                                production of desiccated coconut
   Section 2.2.1 Styles,        We propose the following:-                             Addressed.
   para (a) and (b), lines      i.      To replace the term ‘Defatted’ with ‘Low
                                                                                         12

Reference in the                          Member’s Comment                       Updated status
draft document, Sept.                                                            and reference
2009                                                                             in the revised
                                                                                 draft document
16 and 17                  fat’.                                                 Section 2.2.1
                           ii.     To delete the term ‘Whole fat’.
                                                                                 Lines 16, 17
                           i.      ’Low fat desiccated coconut’ would be a
                           more appropriate name for this product as the
                           extraction of oil from desiccated coconut will form
                           a product with a lower fat content.
                           ii.     Unless otherwise stated, the non-defatted
                           desiccated coconut will contain its inherent fat
                           content and need not be specified as being ‘Whole
                           fat’.

Section 2.2.1 Styles,        iii.    To reduce the range of total oil content for Not Addressed
para (a) and (b), lines      ‘Low fat desiccated coconut’ to 35-45%.
16 and 17                    iv. To reduce the minimum total oil content for
                             ‘Desiccated coconut’ to 55%
                             iii.    The proposed range of 35-45% is typically
                             the total oil content for Low fat desiccated coconut.
                             iv. The proposed 55% m/m min total oil content for
                             Desiccated coconut is based on data from local
                             manufacturing companies.
Rationale for not addressing the comment:
Grated Desiccated Coconut with fat content below 50% is unacceptable as regards to
characteristic flavor of the product.

Section 3.1.2-Other        We propose that this section be deleted.             Addressed.
Permitted Ingredients,     Based on data from local manufacturing
lines 42 and 43            companies, we are of the view that there is no Section 3.1.2
                           justified need for other ingredients to be used in
                           this product.
Section 3.2.4-Definition We propose replacing the term ‘Maximum limits’         Addressed.
of Defects and             with ‘Tolerances’ and to individually indicate
Allowances, line 53        whether the values specified are ‘max’ or ‘min’.     Section 3.2.4
                           So as to accommodate the ‘max’ and ‘min’ values
                           specified in the following rows.                     Table
Section 3.2.4-Definition We propose replacing ‘Total acidity of extracted       Not addressed
of Defects and             oil’ with ‘Free fatty acid measured as lauric acid’.
Allowances, line 53,       For a more clear description of the parameter
item (a)                   being measured.
Rationale for not addressing the comment:
The provision Total Acidity is related to a consecrated approved method listed at Codex
Alimentarius Volume 13 (Codex Stan 177-1991, Section 9).

Section 3.2.4-Definition   We propose to remove the square brackets from         Not Addressed
of Defects and             [3% m/m], to add the term ‘max’ after the specified
Allowances, line 53,       limit and to delete [4% m/m].
item (b)                   Based on data from local manufacturing
                           companies, we are of the view that a moisture
                           content of not more than 3% m/m is typically the
                                                                                         13

Reference in the                          Member’s Comment                       Updated status
draft document, Sept.                                                            and reference
2009                                                                             in the revised
                                                                                 draft document
                           characteristic of this product.

Rationale for not addressing the comment:
The provision as proposed (4%) is more adequate with what is stated in the scope of the
document i.e. for direct consumption, including for catering purposes or for repacking if required.
Therefore, considering the necessary shelf life for products designed to retail market, higher
moisture values consider the natural absorption of moisture (UR%) from the environment,
considering the different types of packing material.
Section 3.2.4-Definition We propose the following:-                               Not Addressed
of Defects and               i.       To replace ‘defatted product’ with ‘low fat
Allowances, line 53,         desiccated coconut’, to change the limit to 45%
item (c)                     m/m and to add in the term ’max’ after the
                             specified limit.
                             ii.      To replace ‘whole fat product’ with
                             ‘desiccated coconut’, to change the limit to 55%
                             m/m and to add in the term ‘min’ after the
                             specified limit.
                             For clarity and consistency with our proposal at
                             Section 2.2.1 Styles, para (a) and (b), lines 16
                             and 17 (above)
Rationale for not addressing the comment:
Grated Desiccated Coconut with fat content below 50% is unacceptable as regards to
characteristic flavor of the product.
Section 3.2.4 Definition We propose to add in the term ‘max’ after the            Addressed.
of Defects and               specified limit.
Allowances, line 53,                                                              Section 3.2.4
item (d)                     For clarity and consistency.
                                                                                  Table
Section 3.2.4-Definition We propose changing the limit to ≤10 fragments per Addressed.
of Defects and               100g.
Allowances, line 53,                                                              Section 3.2.4
item (e).                    We are of the view that this is a more appropriate
                             limit of tolerance.                                  Table

Section 4-Food             We propose deleting this paragraph at lines 62, 63    Not Addressed
Additives, lines 62, 63    and 64.
and 64.
                        This statement is only being mentioned in a few
                        Codex standards such as the Std for Fat Spreads
                        and Blended Spreads (Codex Stand 256-2007)
                        and Std for Infant Formula and Formulas for
                        Special Medical Purposes Intended for Infants
                        (Codex Stan 72-1981, Rev. 2007). Since the use
                        of such statement is not indicated in the
                        Procedural Manual and is not being used in most
                        of the Codex standards, it may not be necessary
                        to include this in the standard.
Proposed adoption of tables 1 & 2 may not fit with the proposed restriction to Sulfites (table
1000ppm; Malaysia’s proposal 50ppm). Besides functional classes need to be identified
                                                                                            14

Reference in the                         Member’s Comment                         Updated status
draft document, Sept.                                                             and reference
2009                                                                              in the revised
                                                                                  draft document
previously.
Section 4-Food            We propose replacing this sentence with the             Partially
Additives, lines 65, 66   complete general reference statement as quoted in       Addressed
and 67.                   the Procedural Manual.                                  (under     square
                          For consistency with the general reference              brackets).
                          statement in the Procedural Manual.
                                                                                  Section 4

                                                                                  Lines 61-69
Section 4-Food            To amend the numbering to 4.2                           Addressed.
Additives, 4.1-
Preservative, line 68                                                             Section 4
                          Editorial
                                                                                  Line 72

Section 4-Food            We propose removing the square brackets from            Addressed.
Additives, 4.1-           [50] and to delete [150] and [1000].
Preservative, line 68                                                             Section 4.1
                          We are of the view that the existing maximum
                          level of 50 mg/kg residual SO2 specified in the         Table
                          GSFA is appropriate.

Section 4-Food            We propose deleting this section.                       Addressed.
Additives, 4.2-Other
Functional Class(es),     Based on data from local manufacturing                  Section 4
line 69                   companies, we are of the view that there is no
                          justified need for other functional classes to be
                          used in this product.

Section 7-Weights and     We can agree with Brazil’s views as mentioned in Addressed.
Measures, lines 83 and    the explanatory notes, that the provision for this
84                        section be in a similar manner as set out in other Section 7
                          standards for dried fruits (e.g. Std for Raisins, Std
                          for Dates) which is as follows:-                      Lines 88, 89

                              ‘Containers shall be as full as practicable
                          without impairment of quality and shall be
                          consistent with a proper declaration of contents for
                          the product.’
                          For clarity and consistency with other standards for
                          dried fruits.

Section 7-Packaging,      We propose the following:                               Addressed.
Transport and Storage,      i.     deleting ‘re-hydration’
para 7.2, line 89           ii.    replacing ‘leaking’ with ‘spillage’            Section 7.2
                            i.     To delete ‘re-hydration’ as ‘infiltration of
                                   moisture’ or absorption of moisture by         Line 94-95
                                   the product will result in the product
                                   being re-hydrated, thus ‘re-hydration’ is
                                                                                               15

Reference in the                           Member’s Comment                            Updated status
draft document, Sept.                                                                  and reference
2009                                                                                   in the revised
                                                                                       draft document
                                      redundant.
                              ii.     We feel that ‘spillage’ is a more
                                      appropriate term in describing the out
                                      flowing of desiccated coconut.


Section 7-Packaging,       We propose the following:                                   Not Addressed.
Transport and Storage,       iii.   inserting ‘light’ after ‘moisture’
para 7.2, line 89                                                                      Section 7.2
                              iii.    Since ‘light’ promotes rancidity, the
                                      packaging material should also protect
                                      desiccated coconut from infiltration of
                                      ‘light’.

Rationale for not addressing the comment:
Current wording without the term “light” considers the different types of packing material used for
direct consumption, besides being aligned with the scope of the document i.e. for direct
consumption, including for catering purposes or for repacking if required.
Brazilian Grounded Desiccated Coconut adopts transparent windows in packing material to
facilitate acceptance at retail market.
Section 8-Labelling,        To amend the numbering to 8.1.4                      Addressed.
8.1.3-Other styles, line
101                         Editorial                                            Section 9.1.4

Section 9-Methods of       We propose to replace ‘Acidity total (in extracted          Not Addressed
Analysis and Sampling,     oil)’ with ‘Free fatty acid measured as lauric acid’.
line 110
                           For consistency with our proposal at Section 3.2.4-
                           Definition of Defects and Allowances, line 53, item
                           (a).

Rationale for not addressing the comment:
The provision Total Acidity is related to a consecrated approved method listed at Codex
Alimentarius Volume 13 (Codex Stan 177-1991, Section 9).

Section 9-Methods of       We wish to seek clarification on the source of the
Analysis and Sampling,     methods as ‘Described in the Standard’ specified
line 110                   for ‘Acidity total (in extracted oil) and for ‘Extraneous
                           vegetable material’.

Rationale for not addressing the comment:
The methods of analysis for Total Acidity and Extraneous Vegetable Method are consecrated
approved methods listed at Codex Alimentarius Volume 13 (see. Codex Stan 177-1991, Section
9).
                                                                                            16


3. PHILIPPINES

    Reference in the                       Member’s Comment                         Updated status
    draft document, Sept.                                                           and reference
    2009                                                                            in the revised
                                                                                    draft document
   Title                      In the Title, the Philippines propose the deletion of Not Addressed.
   Line 1                     the word “grated” from the title and all those
                              appearing in the document text to provide for
                              flexibility and consistency with the industrial
                              practice of grinding the desiccated coconut instead
                              of grating.
   Rationale for not addressing the comment:
   Current document adopted the term “grated” and the terminology “grated desiccated coconut” is
   easily translated and understandable in Spanish and French versions of the documents.

   In Section 2.1 of        inclusion of the words “hatcheting, paring” after the   Addressed.
       Product Definition   word de-husking and to delete the word peeling
       under Line No. 11    and thus the sentence would read as:                    Section 2.1
                                    Processed, in an appropriate manner,
                            undergoing operations of de-husking, hatcheting,        Line, 11, 12
                            paring, milling, drying, and sifting; and
                            These are necessary process step involved in the
                            manufacture of desiccated coconut in an industry
                            set-up or level.
                            Furthermore, to be consistent with the CAC/RCP
                            4-1971, the word “Hatcheting” was used and is
                            referred, as the removal of the shell while “Paring”
                            is the removal of the brown skin around the kernel.
                            The Philippines would like to stress that, in an
                            aqueous process where the meat is subject to
                            pressing to obtain coconut cream before drying,
                            the resulting product (whether pure or blended)
                            shall not be classified as desiccated coconut.
   Section 2.2 of Styles    Under Line No. 16 on Defatted desiccated                Addressed.
      under Lines No. 16-   coconut, 55 – 65% should be changed to “55 –
      17                    *62%” and under Line No. 17, above 65% should           Section 2.2
                            also be changed to “above *62%” to allow for a
                            marginal allowance during the lean season being         Lines 16, 17
                            experienced by the coconut industry and also
                            varieties and hybrids of coconut affect oil content
                            such that, there are occurrence of coconut that are
                            naturally low in fat content. Moreover, this is in
                            coherent with the Philippine National Standard for
                            Desiccated Coconut (PNS/BAFPS 25:2007) thus
                            showing:
                            2.2.1 Grated desiccated coconut with respect to oil
                            content may be designated as:
                            (a)     Defatted desiccated coconut – products
                            with oil content between 55 – *62%.
                            (b)     Whole fat desiccated coconut – products
                            with oil content above *62%.
                                                                                              17

Reference in the                           Member’s Comment                         Updated status
draft document, Sept.                                                               and reference
2009                                                                                in the revised
                                                                                    draft document
Section 2.3 of Sizing       we support the classification of grated desiccated
   under Line No. 25        coconut according to their granulometry as stated.
Section 3.2 of Quality      we propose to change the word normal to natural Addressed.
   Criteria under 3.2.1     before the word white
   of Colour and                                                               Section 3.2.1
   Texture (under Line
   No. 45)                                                                          Line 44

Section 3.2 of Quality      inclusion of words “to light creamy white” after the Addressed.
   Criteria under 3.2.1     word white and the sentence would read as:
   of Colour and                                                                 Section 3.2.1
   Texture (under Line              Grated desiccated coconut shall have
   No. 45)                  natural white to light creamy white colour and shall Line 44
                            possess a texture characteristic of the product.
                            As light creamy white color is also an innate color
                            attribute of a sound or good quality mature
                            coconut.
Section 3.2.3 of Odor       we propose the inclusion of the words “cheesy and Addressed.
   under Line 52            smoky” after the word moldy, to delete the word
                            “or” before the word rancid and to include the Section 3.2.3
                            phrase “or possess any undesirable odor” after the
                            word rancid and thus the sentence would read as: Lines 50, 51

                                  The odor shall be characteristic of the
                            product and shall not be moldy, cheesy, smoky,
                            fermented, rancid or possess any undesirable
                            odor.

                            The use of the words “cheesy and smoky” were
                            also considered as quality criteria for the rejection
                            of the product.

                            The inclusion of the phrase “or possess any
                            undesirable odor” was considered namely to
                            provide for flexibility.
Section 3.2.4 of            the heading (maximum limit) is not consistent to Addressed.
   Definition of Defects    the values stated for oil content that are regarded
   and Allowances           as minimum limits                                   Section 3.2.4
   under Line 53
                                                                                    Table
Section 3.2.4 of            The Philippines proposes that allowances for            Partially
    Definition of Defects   moisture content should be given based on the           Addressed
    and Allowances          classification (sizing) or particle size of grated      considering
    under Line 53           desiccated coconut as follows: (1) For extra fine       Sizing          is
(b) Moisture                and fine, shall not exceed 3% moisture content; (2)     optional.
                            medium, shall not exceed 3.8% moisture content;
                            and (3) unclassified grated desiccated coconut,         Section 3.2.4
                            shall not exceed 4.5% moisture content. It is
                            deemed necessary that for bigger cuts or particle       Table
                                                                                                  18

Reference in the                              Member’s Comment                            Updated status
draft document, Sept.                                                                     and reference
2009                                                                                      in the revised
                                                                                          draft document
                             size, high moisture content should be considered
                             or allowed.

Section 4.1 of               the Philippines proposes a change in the                    Addressed
   Preservative under        maximum levels proposed for Sulfites for the
   Line 70                   following reasons: (1) as this level of use is              Section 4.2
                             considered safe for human consumption; (2) found
                             technologically necessary for shelf life stability of       Table
                             the product during transport wherein it is exposed
                             to high temperature (the product can be stored for
                             11-12 months at ambient temperature); (3) to
                             apply for Philippine climate in general; and (4)
                             achievable by the industry sector.

                             Thus the matrix for Section 4.1 Preservatives
                             should contain the change to 200mg/Kg
I. Justification in Support of Safety Issue as stated above

The use of 1000 mg sulphite/kg level in desiccated coconut, or in fruit and vegetable in general would
not exceed the WHO-ADI of 0.7 mg sulphite/kg body weight. Only about 95% of WHO-ADI is achieved
if we assume that a person eat a 30 grams of desiccated coconut with 1000 mg sulphite/kg
everyday. It is safe to assume that 30 grams of desiccated coconut consumption is an overestimated
value already.

E.g. Assuming that our daily consumption of desiccated coconut is               30 grams (to calculate the
national theoretical maximum daily intake, NTMDI).

To Calculate for 1000 mg/kg:


            1000 mg/kg x 30 g
                         60 kg                          = 0.5 mg/kg body weight



To Calculate for 200mg/kg:

             200 mg/kg x 30 g
                         60 kg                          = 0.1 mg/kg body weight



Hence, we do not exceed the World Health Organization-Adequate Daily Intake (WHO-ADI) for 60
kilograms body weight (estimated average weight of Filipino).


II. Justification in Support to Shelf life stability and to Apply for Philippine Climate in general as stated
    above

A maximum level of 200 mg/kg as residual Sulfur Dioxide in the end product is beneficial both to the
manufacturer and customer since the product can be stored for a period of 11 to 12 months and
longer for temperate countries.
Sulfites are in some ways unique additives, in such that the level of use typically does not reflect the
level remaining in a food at the time of ingestion owing to the losses during processing or further
processing such as cooking and storage (especially when exposed to high temperature environment)
                                                                                             19

Reference in the                           Member’s Comment                          Updated status
draft document, Sept.                                                                and reference
2009                                                                                 in the revised
                                                                                     draft document
of treated foods.

Considering that, most of the producers of desiccated coconut are located from tropical countries
that have an environment temperature ranging from 28C to 32C. And in addition to that, during
shipping, the product is again exposed to high temperature inside the container van.

Therefore, this conditions results to a much lower concentrations of sulfites when it reaches the
country destination and in treated foods at the time of consumption. It is estimated that the rate of
sulfite loss is 1 mg/kg per day.

In Section 8.1.3 of Name of the Product under Line 101, the Philippines support the provision as stated
herein to provide for consistency with labeling requirements and for the information of consumers.

				
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