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14 SEAFOOD SAFETY 



One of the more important activities at both the federal and the state levels is 

 environmental monitoring. Because the majority of seafood is from wild stocks, the 

 quality of harvesting waters is of fundamental concern. The EPA and certain state 

 governments (primarily by way of their involvement in the National Shellfish Sanitation 

 Program (NSSP)] have instituted programs to establish the level of contaminants in 

 seafood harvesting waters. 



These efforts have led to important insights into general water quality but, for 

 the most pan, do not supply sufficient information on the question of seafood safety. 

 Among other things, they lack (1) sufficient geographic scope, (2) a common 

 methodological approach, and (3) sufficient focus on the edible portion of seafood in 

 order to determine public health, as opposed to environmental health, impacts. This 

 last point is an important one. Except for the monitoring of harvesting waters carried 

 out as part of the NSSP, data evaluating contaminant levels in fish and shellfish do not 

 consistently focus on the analysis of edible tissue. More often the focus is on whole 

 fish or on liver and gallbladder analysis. These analyses, by their design, offer 

 insufficient insight into contaminant levels in the edible portion of seafood products. 



Inspection efforts by FDA and various state and local public health agencies are 

 designed to ensure safety, but are insufficient to ensure in all cases that the regulatory 

 guidelines defined by FDA and EPA are not being exceeded. The sampling strategies 

 employed by these various agencies are designed to focus inspection and enforcement 

 activities on areas in which the probability of a problem appears highest. Ongoing 

 governmental efforts to develop new inspection programs, with a focus on the public 

 health aspects of the raw product and the environment from which these products are 

 derived, along with continued control of seafood production and processing, could 

 provide measurable additional benefits in seafood safety. 



Given many of the intrinsic attributes of seafood already discussed, it is clear 

 that an approach recognizing the advantages of regional/local control and surveillance 

 is essential. The question of seafood safety should continue to be one in which federal 

 and state roles are viewed as a cooperative partnership. It is also apparent that 

 seafood commerce is taking place within an increasingly interdependent international 

 economy. Many of the major trading partners of the United States are developing or 

 further refining formal regulatory programs for seafood safety. These efforts should 

 be taken into account in designing a domestic program. 



Principal Conclusions 



• Federal (mostly FDA) guidelines for microbial and natural toxin 

 contamination should be extended and updated. Those that exist have not been 

 adequately conveyed to the fishing industry and to interested members of the public. 



• Federal guidelines on chemical contaminants in seafoods are limited in scope 

 and, in some cases, questionable as to the levels set. There is an apparent lack of 

 coordination in the development and use of data on chemicals in the aquatic 

 environment among FDA, EPA, the National Oceanic and Atmospheric Administration 

 (NOAA), and the states. Better recognition is required of the importance of regional 

 factors in the occurrence of toxic fish and shellfish and of the existence of high at- 

 risk groups (e.g., pregnant women, children, recreational and subsistence fishers). 



