102 



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 (referred to as the NSSP) 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 reasons, both of 

 which are problems that FDA acknowledges in its policy statement. 



First is the illegal harvest of shellfish from closed waters, referred 

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

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



