20 



Ms. Foster. Well, under the Magnuson Act we can implement a 

 90-day emergency and then it can be extended for another 90 days. 

 We do this under recommendations and in consultation with FDA; 

 we do it when there is a recognized public health hazard. We are 

 contemplating seeking an amendment to the Magnuson Act that 

 would allow us to extend that emergency. I mean emergencies have 

 a habit of not going away because your emergency rule expired, 

 and we think that it makes more sense to have the emergency in 

 effect until FDA indicates that the public safety hazard is gone. 



Mr. Manton. Mr. Billy, when do you foresee the seafood inspec- 

 tion rule being published in the Federal Register? 



Mr. Billy. I can share with you the current status. It is in the 

 final policy clearance in the Commissioner's office. The proposed 

 rule will then be forwarded to the department and then on to the 

 Office of Management and Budget. We have had preliminary dis- 

 cussions with the department and are providing a briefing to the 

 Secretary's office this coming Monday. I am not sure I can predict 

 how quickly we will be able to get the proposed rule through that 

 process, but the Commissioner is committed to moving the pro- 

 posed rule as quickly as possible. 



Mr. Manton. After the inspection rule is published, does the 

 FDA foresee the need for additional legislation granting the agency 

 greater regulatory authority? 



Mr. Billy. We believe that we have adequate authority to pub- 

 lish this rule and implement a comprehensive mandatory HACCP- 

 based seafood inspection program. 



Mr. Manton. Mr. Salmon, you and your company exercised great 

 foresight in instituting your HACCP-based inspection program in 

 1979. What was the reasoning behind this, how has the program 

 met, failed or exceeded your expectations? 



Mr. Salmon. Actually our program started way before then. In 

 1972 we started our first buying department and we had put in our 

 inspection labs at that point in time because of our concern about 

 quality. It really starts with the philosophy of quality, value and 

 service, which was our QVS, but we knew we had to have quality 

 seafood to be more competitive, to stay competitive and to be one 

 up. In so doing we started our labs at that time. 



Our system has really been a HACCP system all along. I guess 

 we just didn't know the name of it at that point in time. 



Mr. Manton. We like fancy names around here that you can't 

 pronounce. 



Mr. Salmon. Acronyms are great. We knew we had to have 

 something in place. You can use the term "HACCP," but define 

 those points along the line of where that food is going from source 

 to plate and knowing where those critical control points are and 

 putting something in place to check it, and that is what we did and 

 so from that timeframe since 1972 up to the present we have been 

 using a system that is very similar to a HACCP program. 



Mr. Manton. Thank you. I don't want to monopolize the time for 

 questions. I will recognize the gentleman from North Carolina, Mr. 

 Coble. 



Mr. Coble. Thank you, Mr. Chairman. I am sorry for my belated 

 arrival. I have two other meetings going on. Good to have you all 

 with us. Any of you can answer this, but perhaps Mr. Billy and Ms. 



