Ill 



1525 WILSON BOULEVARD • SUITE 500 • ARUNGTON. VA 22209 • (703) 524-8883 • FAX a03) 524^19 



July 25, 1993 



The Honorable Thomas Manton 



331 Cannon House Office Building 



Washington, D.C. 20515-3207 



Dear Congressman Manton: 



I would like to thank you again for your consideration of 

 the seafood industry perspective of seafood safety. 



In answer to your letter of July 5, 1993, you have five 

 questions under Seafood Safety Hearing, and seven questions 

 listed under Morgan heading. I shall list numerically as 

 follows: 



Questions for Seafood Safety Hearings 



General : 



(Q-1) How will the anticipated European Economic Community 

 seafood standards affect the U.S. exporting seafood 

 Industry? Will these standards have any effect on the 

 domestic seafood industry? 



(A-1) Irradiation is the only EEC standard other than the 

 MOU's between the country and FDA which is 

 unenforceable. As of July 1, 1993, European Economic 

 Community seafood safety standards require U.S. 

 exporters to obtain documentation from the FDA or USDC 

 certifying that an export shipment was produced 

 consistent with EEC requirements. 



At the present time, the EEC is accepting certifications 

 that a U.S. seafood company is complying with present 

 U.S. requirements. Thus, EEC requirements have not been 

 a major disruption to U.S. seafood exports. Future 

 disruptions are possible, however, depending upon 

 whether the EEC continues to accept U.S. certifications. 



(Q-2) Do voluntary seafood safety efforts work? 



(A-2) The NSSP has been in existence since 1925. The NSSP is 

 the oldest food safety program and does have 

 microbiological standards for shellfish growing waters 

 and market guidelines for shellfish meats. Although it 

 is considered "voluntary", it is essentially mandatory, 

 since a state cannot ship shellfish in interstate 

 commerce unless their program is in conformity with NSSP 

 regulations and guidelines. The state program is 

 evaluated by the FDA and must meet the criteria of the 

 NSSP. 



(Q-3) Are imported seafoods adequately inspected? 



(A-3) No. All imported seafoods, including raw shellfish, 

 should have to meet the same growing water, plant and 

 market standards, guidelines and regulations as U.S. 

 shellfish and other seafoods. 75% of shellfish related 



