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All of the legislation whicfi had been considered in the past several years was tjased on 

 use of HACCP t}ased regulation and inspection. NFI's position has been constant. It 

 t}elieves the nation would t>e well sen/ed by a comprehensive, constantly enforced 

 seafood regulatory - inspection program. 



NFI believes an improved mandatory program should toe based the following principles: 



o The regulatory system should tie based on the Hazard Analysis Critical 

 Control Point (HACCP) principles endorsed by the National Academy of 

 Sciences. 



o A single federal agency should be responsible and accountable for 

 regulating fish products and operations. Agency jurisdiction should tie 

 clearly defined to eliminate duplicate or conflicting authority or activities 

 among agencies. Companies and products should not be subject to 

 inspections for compliance by more than one agency. 



o Delegation of inspection responsibilities to qualified states should t>e 

 encouraged to avoid duplicate or conflicting programs. 



o Tolerances and action levels for substances which may adulterate seafood 

 should tie tiased on definitions, criteria and practices which apply to all 

 foods. Enforcement emphasis should be on surveillance testing and 

 HACCP system correction. 



o Enforcement and penalty procedures should provide due process and 

 protect against disclosure of confidential business information. Harvesting 

 and processing operations should be stopped only to avoid an immediate 

 and serious adverse impact on human health. 



o The system should apply to both domestic and imported product 



o Government costs should be covered in the same way as competitive food 

 products. 



In the past two sessions of Congress the NFI has asked for legislation to put this type of 

 program in place. While progress was made, no legislation resulted, as various factions 

 used the legislative process as a platform for agenda items extraneous to seafood safety. 

 Now FDA has indicated it plans to move forward with regulations which will require 

 HACCP based preventive control systems throughout the industry. We commend this 

 action as it's the heart of the various legislative proposals which had been considered in 

 the past. 



Since the FDA, which has regulatory authority over seafood, is initiating a bold new 

 chapter in the evolution of the seafood inspections system, we t>elieve it's critical to 

 encourage the FDA to publish the regulations, put them in effect, and assess their efficacy 

 tiefore reopening the legislative process. 



