# fda waring on imports



## bosco500 (Sep 27, 2012)

*Re: fda warning on imports*



rainesridgefarm said:


> http://www.accessdata.fda.gov/cms_ia/importalert_108.html
> 
> 
> It also lists the labs that will test your honey at a high price.


Thanks for this. We have gotten some honey from Saudia Arabia I would like to have tested.


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## Ramona (Apr 26, 2008)

*Re: fda warning on imports*

I talked to Coastal Sciences a couple of years ago. Cost was 25$ per sample if I remember correctly. Isotope technology can only test down to about 10% adulteration and can only detect cane or corn syrup adulteration. 

If you are looking for rice syrup adulteration, isotope technology will not help. They can use an additional test looking for protein profiles (45$?) that can show that there is something that isn't honey in the sample but can't definitively say that it is rice syrup. This inability for the test to "prove" that the sample contains rice syrup makes it difficult legally for packers to refuse shipments adulterated with rice syrup that are relying on the outsourced isotope technology for testing. If the packer has their own internal chemist looking at samples they are probably on different legal ground.

If you are looking to test for pesticides the testing is much more expensive (more than 200$/per sample) and requires different technology.

Ramona


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## jim lyon (Feb 19, 2006)

*Re: fda warning on imports*

Samples are just that......samples. By blending a number of randomly chosen samples and using that as the basis for accepting or rejecting the whole lot then testing costs can be a very minor expense. For example a single $200 dollar test representing a 20000 lb. lot would amount to a penny a pound and let's not forget that with the sophisticated equipment nowadays the LOD may be as low as .44 ppb (or so I have been recently told). Stop for a moment and consider just how tiny that would be. In terms of world population you would be talking about 3 to 4 people. 
Ramona brings up some good points about testing for adulteration, something which she obviously has a much better understanding of than I.


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## bosco500 (Sep 27, 2012)

*Re: fda warning on imports*



Ramona said:


> I talked to Coastal Sciences a couple of years ago. Cost was 25$ per sample if I remember correctly. Isotope technology can only test down to about 10% adulteration and can only detect cane or corn syrup adulteration.
> 
> If you are looking for rice syrup adulteration, isotope technology will not help. They can use an additional test looking for protein profiles (45$?) that can show that there is something that isn't honey in the sample but can't definitively say that it is rice syrup. This inability for the test to "prove" that the sample contains rice syrup makes it difficult legally for packers to refuse shipments adulterated with rice syrup that are relying on the outsourced isotope technology for testing. If the packer has their own internal chemist looking at samples they are probably on different legal ground.
> 
> ...


Thanks for the great info. Do you know who does the pesticide testing?


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## deknow (Jul 17, 2006)

*Re: fda warning on imports*

The problem with pooling samples is that you dilute any anomolous data....for instance.

Lets say you get barrels of honey, and to keep the math easy, lets say they each contain 500lbs of honey (they really hold about 640).

A 20,000lb lot (as Jim suggests pooling) is 40 of these barrels.

Let's say that one of the barrels has 25ppb coumaphos (I think the limit is 20ppb...at least in Canada). Let's say the rest are clean, and only have 1ppb coumaphos.

Now, we pool them. The concentration of Coumaphos is averaged out between all of the 40 source barrels...(25+39)/40...the pooled sample reads 1.6ppb...safe and clean by any reasonable standard. This all works out if you are in fact pooling the honey and making sure it is well mixed from all sources before bottling...but if you bottle a barrel at a time, you have 500lbs of honey going out with 25ppb...even though you spent $200 on a test. If the results make you suspcicous and you want to follow up and find out what is going on, now you are doing another 40 tests at the tune of $8000 for 20,000lbs of honey.

If your goal is to provide honey with really low levels of coumaphos (rather than making sure it isn't an illegal level), it gets even tougher. Let's say one barrel is at 7ppb and the rest are at 1ppb ....now, the pooled sample reads (7+39)/40 1.1ppb...good by any standard (many tests would see this as below the limit of detection...essentially a zero)...but you still have honey going out at 7ppb.

If you are going to pool samples, you need some kind of plan based upon how big the samples are, how much you are going to pool the product for bottling, and what levels you are looking for. Pooling 20,000lbs together for a sample...unless all 20,000lbs are blended together for bottling...makes little sense to me.

deknow


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## AstroBee (Jan 3, 2003)

*Re: fda warning on imports*



deknow said:


> .(25+19)/40...


should be (25+39)/40=1.6


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## Rader Sidetrack (Nov 30, 2011)

*Re: fda warning on imports*

not needed anymore, Dean corrected his math ...


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## deknow (Jul 17, 2006)

*Re: fda warning on imports*

Sorry, I made some dumb mistakes, and made dumber ones trying to fix them 

I'll fix the data/math in my post above. The conclusion stands.

deknow


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## deknow (Jul 17, 2006)

*Re: fda warning on imports*

...and since this thread is really looking at sugar adulteration (where the LOD is somewhere between 5-15% depending on the test used), we are really out in left field pooling samples.

In the slightly simplified example I give above (where a barrel is 500lbs of honey), of the 40 barrels, if one was pure corn syrup, and the rest were pure honey, the result would be 2.5%...well below the LOD for the tests cited...and again, unless the barrels are pooled for bottling, you have 500lbs of pure corn syrup going out labeled as pure honey.

deknow


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