16 



0.5 ppm. On the other hand, fish weighing more than 150 pounds from this area 

 had an average mercury content of 0.3 ppm with 18 out of 58 exceeding 0.5 ppm. 

 These data liave been utilized by industry to develop management practices 

 which minimize harvesting halibut with a high mercury content. 



Halibut Association of Noeth America, 



Seattle, Wash., May 1, 1972. 

 Dr. Maynard A. Steinberg, 



Director, Technological Laboratory, National Marine Fisheries Service, Seattle, 

 WasJi. 

 Dear Dr. Steinberg : For your information, I am enclosing copy of Halibut 

 Association of North America's bulletin dated May 1, 1972 concerning procedures 

 for handling and testing Halibut for the 1972 season. 

 Sincerely yours, 



RuFUS A. LiTTLEFiELD, Pre.iident. 

 Enclosure. 



To : All members of the Halibut Association of North America. 



Gentlemen : Last July our Association presented the Food and Drug Admin- 

 istration a plan which our members proposed to follow in an effort to minimize 

 the possibility of Halibut being marketed in the United States which contained 

 Mercury in excess of Food and Drug guideline tolerances. Although the statistical 

 data and any other information on the subject of Mercury in Halibut was very 

 slight at that time, the plan seemed to work quite well. Food and Drug seemed 

 to be reasonably well satisfied with our program and just as important we avoided 

 getting any great amount of poor publicity through the news media. 



As a result of our testing program last season and with the cooperation of Food 

 and Drug and with assistance from the National Marine Fisheries Service, we 

 have more data and information to work with during the coming season. 



Also our last season's program was modified two or three times by subsequent 

 bulletins. Because of this we feel that our plan should be updated. 



Our Committee met with Food and Drug officials on April 14, 1972. Our Com- 

 mittee also met April 25, 1972 and developed the following plan for the coming 

 season : 



1. RESTRICTION OF SIZES OF HALIBUT 



A. Areas III and IV (except Cape Fairweather and Cape Spencer). No restric- 

 tions on sized Halibut which dealers will buy. 



B. Cape Spencer and Cape Fairweather: The maximum sized Halibut accept- 

 able to buyers will be 100 pounds. 



C. Area II (except Cape Cook and South). The maximum sized Halibut ac- 

 ceptable to buyers will be 100 pounds. 



D. Cape Cook and South: The maximum sized Halibut acceptable to buyers 

 will be 60 pounds. 



We are aware that the Canadian Fisheries Department has withdrawn their 

 size restrictions for Ilaliliut delivered to Canadian ports by Ciiiiadinu boats. 

 Regardless of this our Committee recommends that the same size restrictions that 

 we had last year be continued. 



Statistical data which has been compiled indicates that a high percentage of 

 Halibut 100 pounds or more out of Area II (and Cape Spencer and Cape Fair- 

 weather) contains over 0.5 ppm Mercury. Because of this we strongly recommend 

 that our members do not accept Halibut over 100 pounds out of Area II on any 

 basis, whether it be purchased outright, on consignment subject to inspection, or 

 for the fisherman's account, or on any other plan. However, if voti do decide to 

 take Halibut over 100 pounds (over (50 pounds from Cape Cook and South), the 

 Halibut must l)e tested on an individual fish l>y fish basis and only the fish testing 

 under 0.5 ppm Mercury may be .sold on the American market. 



We feel that by taking the fish on any ba.sis will — 



1. Jeopardize our program in that the fish may get on the market, be discovered, 

 and be publicized. 



2. By taking the fish may cause Food and Drug to increase their surveillance 

 of the fish and the plants accepting the fish. 



Food and Drug has re-confirmed that their position on Mercury has not changed 

 and if we can not effectively manage the program through our Association that 

 they will have to become more active in policing the problem. 



