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fish Sanitation Program has evolved over approximately the last 75 

 years to the present day National Shellfish Sanitation Program. In 

 this extremely comprehensive program, FDA works cooperatively 

 with the States and industry through the Interstate Shellfish Sani- 

 tation Conference. This inspection program has always been based 

 on microbiological testing, not just on superficial sensory inspec- 

 tion. Not only are our shellfish products tested, but shellfish grow- 

 ing waters must meet strict microbiological standards to insure 

 freedom from fecal contamination. 



Our seafood industry, working with NFI and USDC, was one of 

 the first to apply the HACCP concept for the control of foodborne 

 hazards. Even USDA has acknowledged that their traditional con- 

 tinuous visual inspection system is not effective for invisible micro- 

 organisms. They are now looking to our program in developing an 

 improved HACCP-based system to control potential microbiological 

 hazards. 



All of this is certainly ironic in view of the fact that certain con- 

 sumer lobbying groups and regulatory agencies have used the 

 media over the last six years to continuously propagate misleading 

 or false information regarding the safety of domestic seafood and 

 especially shellfish. They also relentlessly assert that our products 

 are not properly inspected or that our current inspection is carried 

 out by too many groups or agencies. 



Our members will certainly concur with the latter, since we are, 

 in fact, inspected by local and State regulatory agencies, FDA, 

 EPA, and if we pay them, even USDC. 



Those special interest consumer lobby groups and agencies who 

 maintain that we are not sufficiently inspected and who continue 

 to malign our products in the National press as unsafe have gained 

 tremendous financial and political power. The press quotes them 

 avidly without thought to researching the actual scientific facts 

 and data. The FDA has gained a whole new division of seafood, and 

 a greatly increased budget and bureaucracy. This has all been ac- 

 complished at the expense and near extinction of our very small 

 but traditional shellfish industry that represents an important her- 

 itage in our coastal States. 



If you consider that of 1,460 pounds of food consumed per person 

 per year only 15.5 pounds represents fish products and less than 

 one-tenth of a pound of this is shellfish, it is extremely hard to ra- 

 tionalize and justify the tremendous expense to the taxpayer and 

 our industry for these numerous seafood hearings and proposed in- 

 spection systems. This is especially true when considering the 

 actual scientific data and facts regarding seafood safety. The re- 

 cently published National Academy of Science's seafood safety 

 report clearly states that "most sea foods are wholesome and un- 

 likely to cause illness in the consumer." 



For all of these reasons and because House bill 1412 singles out 

 only shellfish for additional regulations and expanded FDA author- 

 ity, the majority of the shellfish industry is opposed to House bill 

 1412. 



We have always supported a single HACCP-based inspection 

 system for all sea foods, but cannot support additional regulations 

 that solely target the overregulated shellfish industry. 



