100 



Congress has spent the last four years talking about seafood inspection. It had spent four 

 years In the 70's talking about It and more years in the 60's. FDA's plans will actually 

 make something happen. NFI does not want this positive action to be jeopardized by 

 reopening contentious debate in Congress. 



Instead, the NFI asks this subcommittee to give the FDA program a chance to work. 

 Once the program is in place, it would be appropriate for the Sutxommittee to initiate an 

 oversight to see if the desired effect is tieing accomplished. 



Looking ahead, the NFI does have concern over enforcement of the new HACCP 

 regulations. Getting progressive regulations on the books is only the first step. 

 Effectiveness will depend on consistency of enforcement. The action of the FDA 

 represents a major step in the evolution of the food safety program in the United States 

 by incorporating on going process monitoring into the system. 



We urge the FDA to also reassess its enforcement apparatus to possibly institute a force 

 dedicated to seafood. It's long been recognized that seafood is a unique food. 

 Assessing its safety requires expertise. Assessment of HACCP procedures will require 

 even more expertise. We would like the FDA to move towards a dedicated force of 

 seafood experts to provide the best possible enforcement of the new program. The 

 HACCP system will be effective only if all adhere to it. 



We tjelieve the state governments must be made a part of the new program as well. The 

 Interstate Shellfish Sanitation Conference could well sen/e as a model for a joint federal- 

 state cooperative effort. 



In summary, the NFI is anxious to study and comment on FDA's proposal, the concept of 

 which we fully support. It requests that attention be paid early on to developing a 

 specialized enforcement capability. Finally, we ask Congress to resen/e judgment on new 

 legislation until after the new program is fully implemented. 



Thank you again for the opportunity to participate in this hearing. I would be happy to 

 respond to questions. 



6/2 1/93/c:rlseafood/mkr 



