106 



i 



Shellfish 

 Institute of 

 North 

 America 



1525 WILSON BOULEVARD • SUITE 500 • ARLINGTON, VA 22209 • (703) 524-8883 • FAX (703) 524-1619 



of the Conmittee: 



My name is Bill Morgan. I ajn the President of the Shellfish Institute of 

 north America (SItJA). I greatly appreciate the opportunity you have given 

 me to testify in these hearings on HBM12, "The Shellfish Safety Act of 1993". 



I represent the oldest trade association in the United States. We also have 

 the oldest inspection system in this country. Our Shellfish Sanitation Program 

 has evolved over approximately the last 75 years to the present day National 

 Shellfish Sanitation Program (NSSP). Tn this extremely comprehensive program, 

 FDA works cooperatively vrith states and industry through the Interstate Shellfish 

 Sanitation Conference (TSSC). This inspection program has always been based 

 on microbiological testing, not just on &>^perficial sensory inspection. Hot 

 only are our shellfish products tested, but shellfish growing waters must 

 meet strict microbiological standards to insure freedom from fecal contamination. 



Our seafood industry, working with TJFI and USDC, was also one of the first 

 to apply the HACCP (Hazard Analysis Critical Control Point) concept for the 

 control of foodbome hazards. Even USDA has acknowledged that their traditional 

 continuous visual inspection system is not effective for invisible microorganisms. 

 Ttiey are now looking to our program in developing an improved HACCP-based 

 system to control potential microbiological hazards. 



