16 



move forward and be put in place, then let's see if the needs of con- 

 sumers and the industry are satisfied or if there is need for further 

 legislation. Thank you for the opportunity to be here. 



[The statement of Mr. Salmon can be found at the end of the 

 hearing.] 



Mr. Manton. Thank you very much, Mr. Salmon. 



Mr. Manton. Our next witness Mr. Bill Taylor, President, Pacif- 

 ic Coast Oyster Growers. 



STATEMENT OF BILL TAYLOR 



Mr. Bill Taylor. Thank you. Mr. Chairman, members of the 

 Subcommittee, my name is Bill Taylor. I am a shellfish farmer in 

 Washington State and President of the Pacific Coast Oyster Grow- 

 ers Association. PCOG represents 120 member companies in Wash- 

 ington, California, Oregon, Alaska, and British Columbia involved 

 in the farming of oysters, clams, and mussels. PCOG is the largest 

 shellfish organization in the U.S. 



Shellfish pose a tremendous regulatory challenge. They require a 

 comprehensive inspection program unmatched in other foods. This 

 fact was recognized as early as 1925 when the Surgeon General 

 summoned State and local health officials to Washington, D.C. to 

 develop a National Shellfish Sanitation Program. 



Remarkably, the conclusions of that conference still serve as the 

 foundation of today's inspection program. Because shellfish feed by 

 filtering nutrients out of the water, the beds on which they grow 

 must be inspected. The plants in which shellfish are prepared must 

 be inspected, the products must conform to an established bacterial 

 standard, the method of shipping must be inspected and finally, the 

 responsibility for sanitary control of shellfish rests chiefly upon the 

 individual States. 



This year, the FDA issued a policy statement on the consumption 

 of raw molluscan shellfish. In the statement, FDA endorsed the 

 National Shellfish Sanitation Program as the best means of 

 making molluscan shellfish as safe as possible. 



In fact, the standards and procedures of the NSSP are the most 

 comprehensive of all the regulatory programs for meat products. If 

 you were to apply similarly stringent standards to beef production, 

 for instance, you would have to establish bacterial standards for 

 the soil in which the corn is grown that is eventually fed to the 

 cattle. 



But if the NSSP is so effective, why has so much of the seafood 

 safety debate focused on shellfish? There are primarily two rea- 

 sons, both of which are problems that the FDA acknowledges in its 

 policy statement. 



First is the illegal harvest of shellfish from closed waters re- 

 ferred to as bootlegging. In parts of the country where oystering is 

 a wild harvest fishery, bootlegging is extremely difficult to control. 

 In its policy statement FDA called bootlegging a practice that prob- 

 ably leads to most shellfish illnesses. 



The second problem is that the current program is designed to 

 protect against illnesses associated with pollution from human 

 sewage, but perhaps the greatest health risks currently are from 

 highly toxic, naturally occurring organisms unrelated to pollution, 



