15 



Each member of the management in our restaurants is a 

 member of our quaUty assurance team. When you go to a Red Lob- 

 ster, the person with the thermometer in his or her pocket is prob- 

 ably the manager. Temperature control is a critical part of seafood 

 quality and is built into a HACCP system. Since its founding in 

 1968 Red Lobster has made safety and quality a part of its operat- 

 ing credo. We believe it is in the best interests of our company, our 

 industry, and consumers if the entire industry employs a similar 

 dedication to seafood safety. That is why we have urged the FDA to 

 move forward with a HACCP proposal. 



Mr. Chairman, there is no crisis in seafood safety to solve. There 

 is, however, a need to move forward with new technology and regu- 

 latory procedures to give assurance to consumers that all reasona- 

 ble steps are being taken to provide safe, wholesome seafood. Mr. 

 Chairman, there have been many, many hearings on seafood safety 

 and inspection in this Committee room and in others on both sides 

 of the Capitol. There were hearings in the late 1960's, in the 1970's, 

 still again in the 1980's and in the early 1990's. Despite all the in- 

 terest there was never enough consensus to produce legislation 

 mandating a specific seafood regulatory or inspection system. 



Thousands of pages of testimony and dozens of bills were pro- 

 duced, but there was no legislation. In the industry, however, every 

 new flurry of activity produced renewed self-examination and im- 

 provements. For example, the most recent legislative interest re- 

 sulted in the development of HACCP models for every section of 

 the industry. These manuals of HACCP models for every process 

 from fresh fish to cooked shrimp plants are the guidelines for com- 

 panies to be responsive to a HACCP regulatory program. These 

 were developed by the National Fisheries Education and Research 

 Foundation in concert with government and academic scientists. 

 The legislative proposals of the last two sessions of Congress were 

 based on use of a HACCP system. The industry supported that con- 

 cept. Unfortunately the legislative process became embroiled in 

 contention over jurisdiction and other agenda items extraneous to 

 seafood safety, so there was not final action. 



Now, it appears that FDA plans to make something new happen 

 by initiating a bold new chapter in the evolution of seafood, regula- 

 tion, and inspection. Let's not jeopardize this by reopening conten- 

 tious debate in Congress. The industry wants to see the FDA pro- 

 posal. We want a chance to comment on it and then put it into 

 place. We can then determine if there is need for legislation to pro- 

 vide additional authorities or direction. Getting regulations on the 

 books is only a first step. The industry wants to be sure enforce- 

 ment is consistent and thorough enough to make sure all the in- 

 dustry adhere to the new requirements. 



We believe FDA should consider establishing a force of expert 

 personnel dedicated to the seafood program. There can be great ad- 

 vantage in forming a Federal-State compact like the Interstate 

 Shellfish Sanitation Conference, or the ISSC to provide for ongoing 

 cooperation among all concerned with the seafood safety in a 

 HACCP regime. 



In summary, Mr. Chairman, we commend the Subcommittee for 

 its interest. We ask that nothing be done to impede or confuse the 

 very positive steps planned by the FDA. Let a HACCP regulation 



