IA#16-13 - 6/5/96, REVISED, ATTACHMENT - 4/27/92


SUBJECT       :  "***Detention Without Physical Examination*** of
                 Anchovy or Bagoong Products from Philippines" -

TYPE OF ALERT :  ***Detention Without Physical Examination***

                 Note: this alert is being revised to provide
                 changes to format and/or terminology and are
                 bracketed by asterisks (***).

                 ***(Note: This import alert contains guidance to
                 FDA field personnel only.  It does not establish
                 any requirement, or create any rights or
                 obligations on FDA or on regulated entities.)***

PRODUCT       :  a. Anchovies
                 b. Bagoong, a sauce made from anchovies or small
                    fish which have been salted and fermented or
                    products from Bagoong.

PRODUCT CODE  :  16A--01

PROBLEM       :  Filth (FLNF, Insert; FLRF-Rodent)
                 E. Coli, Coliforms (FLEC)

COUNTRY       :  Philippines (PH,725)

MANUFACTURER/
SHIPPER       :  N/A

MANUFACTURER
SHIPPER I.D.# :  N/A

IMPORTER'S
I.D.#         :  N/A

CHARGE        :  For Filth, Charge:

                 "The article is subject to refusal of admission
                 pursuant to Section 801(a)(3) in that it appears
                 to consist in whole or in part of a filthy,
                 putrid, or decomposed substance or is otherwise
                 unfit for food, in that it contains insect,
                 rodent, animal or other filth" [Adulteration,
                 Section 402(a)(3)].

                 For presence of E. Coli/Coliforms, Charge:







                 "This article is subject to refusal of admission
                 pursuant to Section 801(a)(3) in that it appears
                 to consist in whole or in part of a filthy,
                 putrid, or decomposed substance, or is otherwise
                 unfit for food in that it contains
                 E.Coli/Coliforms" [Adulteration, Section
                 402(a)(3)].

RECOMMENDING
OFFICE        :  Division of Import Operations and Policy,
                 HFC-170

REASON FOR
ALERT         :  During the six month period from November 16,
                 1982, through May 18, 1983, 12 out of 18 lots of
                 anchovy products sampled and examined for filth
                 were detained (a 67% violation rate).  Ten
                 detentions were for insect and/or rodent filth
                 and two detentions were for E. Coli and
                 Coliforms.  Product detained included salted
                 anchovies, anchovy sauce (bagoong), dried
                 anchovies, and frozen anchovies.  Dual
                 declaration of the products which are subject to
                 this action are bagoong monamon-dilis, dilis-
                 monamon, and bagoong mabgas dilis.

                 Review of FY 91 detention data indicates that 41
                 detentions of these products were made.  Further
                 review indicated that the majority were refused
                 due to lack of private laboratory analyses,
                 requested refusals and physical analyses showing
                 presence of filth.  Of 8 samples collected and
                 analyzed 15 (63%) were violative.  No detentions
                 were noted for presence of E. Coli.

GUIDANCE      :  When entries declared as bagoong, bagoong
                 manomon-dilis, dilis-monamon, and bagoong mabgas
                 dilis are encountered they should be checked to
                 determine if they are anchovy products.

                 ***Districts may detain, without physical
                 examination***, all anchovy products from the
                 Philippines except the packers/products
                 identified on the attachment to this Import
                 Alert.

                 When examining audit samples from entries that
                 have been found acceptable by private laboratory
                 results, in addition to an examination for
                 filth, analyze for E. Coli and coliforms.





                 ***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           :  Bagoong, Anchovy, Dilis, Monamon, Filth,
                 Coliforms. E. Coli

KEYWORDS      :  No purging required

PREPARED BY   :  Linda A. Wisniowski, DIOP, (301 )443-6553


             ATTACHMENT- IMPORT ALERT #16-13 4/27/92


PACKER/PRODUCTS EXCLUDED FROM DETENTION WITHOUT PHYSICAL
EXAMINATION



1.   Ayala Corporation Fish (Patis) Sauce
     Makati, Metro Manila
     Philippines

2.   Rufina Patis Factory Fish (Patis) Sauce
     Manila, Philippines