**Enhancing NOAA Fisheries Seafood Safety, Quality,**

**and Outreach, Programs**

**EXECUTIVE SUMMARY**

The U.S. seafood supply has changed dramatically over the last decade.
There are many more species from more countries and more total poundage.
Many concerns have arisen about the safety, quality and integrity of
seafood available to the American consumer. These changes, coupled with
resource constraints, have limited the ability of the Federal Government
to address these issues.

There are several noteworthy trends. They are: the consumer demand for
fish and shellfish will continue to grow; demand for safe seafood will
continue to exceed domestic supply; the contribution of aquaculture to
the seafood supply will continue to grow; increasing seafood supply is
exceeding the Government capacity for seafood inspection; economic fraud
in the seafood supply is increasing; consumer confidence in seafood is
declining; the human health benefits are increasingly apparent.

Seven findings and 15 options are offered. The findings are: Government
inspection resources are inadequate to ensure safe seafood; adding
additional responsibilities is impractical under current funding and
human resources levels; economic fraud is decreasing consumer
confidence; consumer confidence in the sustainability of the seafood
supply is decreasing; the U.S. public is unsure how to balance the
benefits and risks of seafood consumption; U.S. seafood quality and
safety standards need to be updated; NOAA needs to better organize its
seafood assets in order to be more effective. The options are: work
closely with FDA; increase NOAA's analytical and monitoring capability;
establish monitoring programs for seafood contaminants and species
substitution; develop and implement new rapid tests for contaminants and
antibiotics; increase enforcement of contaminant and drug residue
regulations and economic fraud; increase the capacity of Seafood
Inspection Program to inspect foreign seafood processors; improve
methods and increase capacity for species identification; create and
apply sustainability standards; augment research directed at evaluating
benefits versus the risks of seafood consumption; augment research to
better understand the beneficial factors in seafood and the health
impacts of seafood contaminants; establish databases that track
beneficial nutritional information; improve public outreach and
communication; revise U.S. Grade Standards; increase NOAA Fisheries
involvement in the Codex Committee for Fish and Fishery Products;
consider directing and coordinating seafood issues form one headquarters
office.

Strategic considerations are that enhancing seafood safety and quality
capabilities within NOAA will benefit the U.S. consumer and enhance the
image of the agency, this will address a political issue, and this may
attract more funding and will satisfy certain provisions of the
Magnuson-Stevens Reauthorization Act. These initiatives will need to be
funded. NOAA should not encroach or attempt to supplant FDA authorities
but should be a partner with FDA and other Federal agencies to solve
these problems. NOAA should move to sign an Memorandum of Understanding
with FDA and meet with USDA to understand the effects of recent
legislation.

**SECTION 1: BACKGROUND INFORMATION**

One of the basic goals of the Magnuson Stevens Reauthorization Act
(MSRA) has been to manage and conserve fisheries products to ensure that
there be an economically viable industry that provides a safe seafood
supply for the Nation. This has become increasingly important as
domestic resources are unable to meet demand, as the potential health
benefits of seafood consumption from fetus to old age are better
understood, and as the issues and information around seafood consumption
become increasingly complex. Integral to the NOAA mission is our
responsibility to ensure that a healthy and sustainable seafood supply
be available for the Nation, that information regarding the supply be
readily available and understandable, and that our activities, in any of
the areas of research, inspection, or education, contribute to the body
of knowledge about seafood safety, quality, health benefits, and
sustainability.

The face of the nation's seafood supply is rapidly changing due to
increasing reliance on imports from over 150 countries with much of the
increases coming from aquaculture operations in developing nations. In
2007 seafood imports were valued at \$14.3 billion, an increase of over
\$6 billion in just ten years. Increased per capita consumption,
population growth, availability of an increasing array of wild and
farmed species, and the lower cost of a number of previously considered
luxury items such as shrimp and salmon are fueling these changes as well
as the recognition that seafood consumption promotes health. Over 80% of
the nation's seafood consumed is imported, with increasing reliance on
product coming from countries such as China, Thailand, Indonesia,
Vietnam, Malaysia, Bangladesh, and Chile. Imports of tilapia and catfish
from China, for example, have risen more than ten-fold in the past seven
years -- to over 240 million pounds of tilapia and 22 million pounds of
catfish. Shrimp imports, which currently represent approximately
one-third of all seafood imports by value, have almost doubled in volume
to over one billion pounds in just ten years. Domestically produced
salmon, once our primary export commodity and the mainstay of the
domestic salmon market is now also supplemented by imports; in 2007
imports grew to over 250,000 mt (550 million pounds) of *finished*
product valued at over \$1.8 billion.

These developments have also resulted in the nation's seafood supply
being vulnerable to contamination, malicious endangerment, and
fraudulent practices. Consumers are left confused about the safety,
health benefits, risks, and integrity of the seafood products available
to them and the problem appears to be getting worse. Our programs for
ensuring the safety and quality of the seafood we consume were not
designed to accommodate the growth in imports nor did they anticipate
the multiplicity of seafood sources both wild and farmed, and all the
attendant complications they bring.

With the increased volume of imports we have witnessed an increase in a
variety of infractions, some with economic consequences, and some with
human health implications. For example, shipments of catfish from Asia
have been found not to be catfish and there are many instances of
packages of seafood having short weights. The extent of economic fraud
in seafood is unknown since species identification of seafood is not
commonly done. Enforcement of product accuracy has been a low priority
because it has not been considered to be a human health issue; however
this ignores issues of food safety hazards and allergies to substitute
species. A number of aquaculture species have been found to contain
antibiotics banned for use in aquaculture, for example, chloramphenicol,
malachite green, and nitrofurans. In 2007, imported seafood was found to
contain cancer-causing chemicals or antibiotic residues, resulting in
hundreds of shipments of seafood from China being turned away or subject
to extensive analytical testing. Most alarming is a lack of capacity of
the nation's seafood surveillance programs needed to keep pace with
these changes, and effectively assure the public of the safety of our
seafood as well as identifying seafood types and sources.

Inaction in addressing this crisis will lead to greater uncertainty in
the safety and security of our seafood supply.

This paper presents a plan and suite of options for how NOAA Fisheries
could position its seafood safety and quality programs in the near
future to effectively respond to the nation's changing seafood supply.
Currently two federal agencies, the National Oceanic and Atmospheric
Administration (NOAA) and the Food and Drug Administration (FDA) are
responsible for seafood safety; however, neither has the capability to
ensure the U.S. seafood supply is completely safe, because their
programs have not been changed to meet the challenges of a radically
different landscape in seafood production and consumption. Congress has
just provided authority in seafood through the Farm Bill to a third and
a fourth agency, the Food Safety Inspection Service (FSIS) of USDA, is
authorized to conduct food safety inspections for catfish and possibly
all farm raised fish; The Agricultural Marketing Service (AMS) is
authorized to conduct voluntary quality services for catfish and
possibly all farm-raised fish; this will add further confusion to the
process and will take very little pressure off NOAA and FDA. To develop
the necessary seafood safety capacities, NOAA and FDA will need to
leverage their existing resources as well as aggressively augment their
seafood safety programs. The effort required to safeguard the U.S.
seafood supply is significant, and strong commitment by both agencies is
needed to improve our capability to ensure safe, high quality seafood
for the American consumer.

A plethora of media reports based on both accurate and inaccurate
information from government, industry, and environmental NGOs regarding
seafood sustainability, seafood safety, and the risks and benefits of
seafood consumption have resulted in the consumer being confused about
seafood and sometimes making the choice to consume a different protein
-- beef, chicken, pork, etc. The confusion about the safety, health
benefits, and risks of seafood consumption is growing for a number of
reasons. Not only are we sourcing seafood from many more countries than
before but we are also getting seafood from many different production
sources. Consumers are being bombarded with information about different
wild harvesting practices, different aquaculture practices, and a
variety of nutrients, micro-constituents, and contaminants which may be
present -- from omega-3 fatty acids, selenium, and iodine, to
methyl-mercury, chloramphenicol, nitrofurans and malachite green. We
have a responsibility to make sure that the information available to the
consumer is based on science.

NOAA resources to address these issues are arrayed in the Seafood
Inspection Program, the Partnerships and Communications Branch of the
Office of Sustainable Fisheries, the National Seafood Inspection
Laboratory, the Northwest Fisheries Science Center and to some degree
the Pacific Island Science Center. These organizational components
cooperate and rely on each other but operate independently. Closer, more
coordinated activity on the part of these organizational components may
be necessary for NOAA Fisheries to better address these issues.

**SECTION 2: EXISTING SEAFOOD SAFETY AND INSPECTION ACTIVITIES AND
PROGRAMS**

The two principal federal agencies involved in seafood inspection and
safety are the Food and Drug Administration and NOAA Fisheries. FDA,
operating under the authority of the Federal Food Drug, and Cosmetic Act
and several related public health laws, is responsible for protecting
and promoting the public's health by ensuring, among other things, that
the nation's food supply is safe, sanitary, wholesome, and honestly and
informatively labeled. Their major purpose is consumer protection.

The National Marine Fisheries Service's (NMFS) Seafood Inspection
Program in the National Oceanic and Atmospheric Administration of the
Department of Commerce, operating under authority of the Agriculture
Marketing Act and the Fish and Wildlife Act, is responsible for the
development and advancement of commercial grade standards for fishery
products and better health and sanitation standards in the industry and
for furnishing inspection, evaluation, analytical, grading, and
certification services to interested parties. Its major purpose is to
encourage and assist the industry in improving the quality,
wholesomeness, safety, proper labeling, and marketability of its
products for the benefit of the consumer.

FSIS of USDA has just been given authority to provide the same services
for catfish and possibly all farm-raised fish that FDA currently has
authority for. Moreover, AMS has been given authority to provide similar
voluntary services that NOAA Seafood Inspection Program now provides. In
neither case has authority been taken away from FDA or NOAA. How these
programs will operate is as yet unknown however discussions between NOAA
Fisheries AMS and FSIS are expected to occur before the new program is
implemented.

States have adopted a variety of programs regarding seafood safety, and
in some instances quality, which are meant to augment federal
requirements and programs.

The different responsibilities and activities are outlined in Appendix
III.

[NOAA/NMFS and FDA MOU: Cooperation in Inspection of Fish and Fishery
Products]{.underline}

As of this writing, the MOU between NOAA/NMFS and FDA has not been
signed and is under final review by the respective agency General
Counsels. The document cannot be shared as it is still pre-decisional
however we are sharing a number of the salient points:

-   NMFS inspection services will not change or diminish FDA's authority
    under the Federal Food, Drug, and Cosmetic Act

-   NMFS will ensure that plants within their program are in compliance
    with FDA and NMFS regulations.

-   NMFS will suspend services or terminate a contract with an
    establishment if it does not correct objectionable conditions and
    practices, in accordance with NMFS' Inspection and Certification
    regulations[^1].

-   NMFS will refuse to inspect, approve, or certify establishments
    which are not under contract with NMFS that have been identified by
    FDA as being problematic, in accordance with NMFS' Inspection and
    Certification regulations, unless otherwise agreed upon by both
    Agencies.

-   NMFS will ensure that all products that bear Federal inspection and
    grade marks from Approved Establishments are in compliance with
    FDA's food labeling, food additives, and standards of identity
    regulations, where applicable.

-   NMFS will decline to permit the use of Federal inspection and grade
    marks on food products that are adulterated or misbranded under the
    Food, Drug, and Cosmetic Act.

-   NMFS will cooperate with FDA in responding to food safety
    emergencies involving fish and fishery products, within resource
    constraints.

-   NMFS will perform sample analysis and/or conduct inspections of fish
    and fishery product processors, on FDA's request and upon mutual
    agreement.

-   Both agencies will participate in meetings with industry, as
    resources permit, to promote better communication and understanding
    of regulations, policy, and statutory responsibilities, and to
    improve sanitation and food-handling practices in processing
    establishments.

-   With the exception of the publication of general inspection
    statistics, FDA and NMFS agree to accept and treat records or
    information obtained from the other agency pursuant to this MOU as
    exempt from public disclosure.

-   Each agency will take advantage of the inspectional capabilities of
    the other to achieve the maximum utilization of resources, when
    appropriate and as resources permit.

-   Both agencies will exchange information concerning respective
    international fish and fishery product inspection related activities
    to facilitate achieving common goals and avoid costly duplication of
    effort.

Once the MOU for seafood inspection is signed, the NMFS Seafood
Inspection Program will be able to work more closely with FDA to ensure
the safety of the U.S. seafood supply. NOAA should also pursue renewing
the research MOU with FDA since the current one is about twenty years
old and needs to take into account changes that have occurred in the
recent past.

**SECTION 3: How Much Seafood is Inspected?**

Much confusion surrounds the question of how much of the seafood we
consume in the United States is inspected. The question is difficult to
answer precisely as different inspection and certification programs
approach the issue differently.

FDA inspects approximately 1% of imports; this is 1% of import shipments
not 1% of volume. In addition to these inspections, FDA requires 100%
inspection of products coming from either companies or countries which
have been identified as being on "import detention". These inspections
probably are equivalent to another 1% of imports however with all
products from China being on the import detention list, the percentage
will increase. FDA does not track the volume or poundage these imports
represent. Depending on where these products end up in the U.S. seafood
chain, they may be subject to additional inspection by NMFS.

NMFS inspects close to two billion pounds of seafood through its
multiple inspection programs, including continuous plant inspections and
lot inspections for domestic consumption, and export inspection and
certifications.

**FISHERY PRODUCTS AND ESTABLISHMENTS INSPECTED BY NMFS** IN CALENDAR
YEAR, 2006

  ----------- --------------- ------------ ------------- ------------ --------------- ---------------
  Region      **Edible                                                                
              Fishery                                                                 
              Products**                                                              

              Establishment   Amount                                                  
              (1)             Inspected                                               
                              (6)                                                     

              In-Plant (2)    Grade A (3)  PUFI (3)      No Mark (4)  Lot (5)         Total

              -Average        Thousand                                                
              Number-         Pounds                                                  

  Northeast   72              23,080       103,099       25,169       395,132         546,480

  Southeast   93              7,992        33,726        26,085       157,208         225,010

  West        212             20.681       13,663        15,780       1,071,952       1,122,076

  **Total**   **377**         **51,753**   **150,487**   **67.034**   **1,624,293**   **1,893,566**
  ----------- --------------- ------------ ------------- ------------ --------------- ---------------

(1)These establishments are inspected under contract and certified as
meeting U.S. Department of Commerce (USDC) regulations for construction
and maintenance of facilities and equipment processing techniques, and
employment practices.

\(2\) Sanitarily inspected fish establishments processing fishery
products under USDC inspection. Many of these were in the HACCP Quality
Management Program.

\(3\) Products processed under USDC inspection in inspected
establishments and labeled with USDC inspection mark as "Processed Under
Federal Inspection" (PUFI) and/or "U.S. Grade A."

\(4\) Products processed under inspection in inspected establishments
but bearing no USDC inspection mark.

\(5\) Lot inspected and marked products checked for quality and
condition at the time of examination and located in processing plants,
warehouses, cold storage facilities, or terminal markets anywhere in the
United States.

\(6\) Data include product inspected for export. Based on 2006 per
capita consumption data, approximately 33 percent of seafood consumed in
the U.S. is certified under the auspices of the Seafood Inspection
Program.

To arrive at a 33% rate of seafood inspection of domestic consumption,
the poundage known to be inspected by NMFS is divided by the total
consumption (civilian resident population x pounds per capita
consumption). While the statement has been made that approximately 33%
of seafood consumed in the United States is certified under the auspices
of the Seafood Inspection Program, some of this product is actually
destined for export.

**SECTION 4: STRATEGIC DISCUSSION**

The information above demonstrates that the issues revolving around
seafood safety, quality and nutrition are ones the Federal Government
ought to address and attempt to solve or minimize. There are both real
and perceived food safety problems related to seafood consumption; the
consumer is subject to economic deception on a significant portion of
their seafood purchases; the Federal Government through FDA and NOAA
does not appear to have the resources, organization or capability to
ensure that seafood is safe for the consumer. Despite these problems
there is growing evidence of the positive human health benefits of
consuming seafood especially those species that are high in omega-3
fatty acids. This component of fat has many benefits. For example, it is
essential for the proper neural development of human fetuses and
children, promotes cardiovascular health and counteracts depression. The
nutritional benefits are compelling and seafood consumption within
sustainable limits ought to be encouraged. Unfortunately the consumer is
faced with making buying and consumption decisions without easy access
to science-based and unbiased information.

NOAA Fisheries is the lead agency for conserving and sustaining the
nation's wild fisheries resources and developing marine aquaculture. The
agency has considerable resources in research, public outreach, trade
advocacy and seafood inspection services that could make a positive
impact on seafood safety and quality problems and the promotion of a
healthy food source. What steps should NOAA Fisheries take to address
these issues? The group that developed this paper highly recommends that
NOAA Fisheries take strong measures to address these issues to promote
the economic well being of the U.S. fishing industry and coastal
communities, and the health of the American consumer. Enhancing our
seafood safety and quality capability can result in several benefits to
the agency as well. First, we will be responsive to the problems and
needs of our taxpayers. It can be another "good story" about all the
beneficial activity NOAA undertakes. Second, seafood safety has been a
potent political issue recently. Trying to solve these problems and
promote health may be seen by Congress and others as an agency that
takes its mission very seriously. Third, these activities may attract
more funding from Congress as it will probably be seen in a positive
light. Fourth, we will be carrying out the provisions of MSRA P.L.
109-479, sec. 208 16 U.S.C. 1891b FISHERIES CONSERVATION AND MANAGEMENT
FUND that stipulates that NOAA Fisheries develop new analytical methods
to improve the quality and safety of fish; conduct analyses for health
benefits and risks; improve marketing of wild domestic fish. Given that
the United States relies on imports for over 80% of what we consume we
need to broaden our scope of activities, particularly for testing and
monitoring products and developing databases regarding nutritional
values as well as contaminants, to imports as well as domestically
produced seafood products.

For all the possible benefits of vigorously pursuing an enhanced seafood
safety and quality program there are caveats that we may want to
consider. First, although we are recommending that more emphasis should
be placed on seafood safety and quality issues as sustainable fisheries
measures, they will never supplant our agency's main mission as a
protector of our nation's living marine resources. However, we believe
that enhanced seafood safety and quality activities are so beneficial
that senior management should consider a balanced approach and authorize
funding. Second, if these proposed options are accepted then they will
need to be adequately funded. That will mean Congress will need to
provide additional resources as the agency does not have enough funding
that can be diverted to cover all of these activities. Third, NOAA
Fisheries should be careful not to encroach on or assume the role of the
Food and Drug Administration (FDA) which is the lead competent authority
for food regulation in the United States. FDA has a huge mission and is
estimated to regulate up to 58% of the U.S. economy. It is well known
that their budget has been reduced by Congress which has affected their
ability to regulate foods effectively. It is unlikely that NOAA
Fisheries will be able to offer enough resources to make a significant
effect on the FDA regulatory burden for seafood. We can, nevertheless
leverage each others resources and work together to help address these
important issues. NOAA Fisheries is in a good position to assist in
solving these problems. NOAA has capability in the area of post-harvest
research, aquaculture and seafood inspection that are designed to assist
industry in addressing these issues. Moreover, these activities are
integrated into the process of developing regional fisheries management
plans so the oversight of marine resources is comprehensive from
fisheries management, habitat protection and consumer safety.

> **Section 5: Trends and their Impact on Seafood Safety and Quality**

**TREND: [The consumer demand for fish and shellfish continues to
grow.]{.smallcaps}**

Global seafood consumption has more than doubled since 1973. Substantial
increases in consumption are occurring in developing countries, for
example, rapid income growth and urbanization in China is creating a
large demand for fish. In the United States, average per capita
consumption rose to 16.5 pounds (2006 data), which amounts to 4.9
billion pounds total annual consumption of finished product. The
recognition of the health benefits of seafood consumption and current
FDA/EPA guidelines for women of child-bearing age and children to
consume two meals of seafood per week will further increase demand by an
additional 3 billion pounds per year at current population levels.

Experience in the food industry also has shown that the food marketplace
is changing and these transformations create new seafood safety and
quality challenges. It has been said that a dinner entree can consist of
ingredients from five countries. For example, a nice sea bass with a
mango chutney sauce could contain seafood from Chile as the base,
thickeners or gums from Germany, mango puree from Ecuador, ginger root
from Asia, and spices from India.

Globalization of the seafood industry and our reliance on imports, have
caused a decided change in consumer preference and eating habits. While
the public still asks for traditional food items, they now also demand
foods touting fresh taste, ethnic styles, and foods that are easily
prepared. Due to time pressures, consumers are less likely to prepare
their own meals from the start and are more likely to rely on processed
heat-and-serve items. This has increased the need to rely on food safety
systems employed by growers, processors, and various
national/international regulatory authorities.

The trend in all food safety inspection, including seafood, is to rely
less on command and control approaches, and move toward a preventive
approach to minimize levels of risk.

Coupled with changing consumer risk exposure, advanced analytical
technology now allows for more sensitive measures of contaminants and/or
carcinogens -- forcing regulatory agencies to reexamine current risk
levels. Nevertheless, innovative food control systems are being executed
such as Hazard Analysis Critical Control Point (HACCP), and there is an
increased effort to provide for more broad global standards for foods.
These international food safety issues are being addressed through a
newly revamped Joint WHO/FAO Codex Alimentarius International Food
Standard Program, in which NOAA Fisheries has been participating since
its inception.

It is becoming increasingly apparent that the task of ensuring food
safety is so huge and complex that no one country or organizational
entity will be able to accomplish the job alone. In accordance with the
World Trade Organizational Agreement (WTO), the North American Free
Trade Agreement (NAFTA), and numerous other regional trade agreements,
food safety standardization efforts are accelerating in order to meet
the challenge. Increased international trade in seafood, concerns about
emerging food pathogens and new sources of chemical contamination and
changes in distribution patterns have increased the risk profile for the
consumer.

**TREND: [domestic wild-caught fish stocks are improving, BUT domestic
demand for safe seafood will continue to exceed domestic supply from
wild stocks.]{.smallcaps}**

The U.S. supply of seafood is currently more than 12.3 million metric
tons, including imports. Current domestic production of wild-caught
seafood is 3.5 million metric tons. According to NOAA Fisheries Service
statistics, more than 80% of the nation's fish stocks are at sustainable
levels, leaving little room for expansion of the supply from domestic
production. The U.S. currently imports over 80% of its seafood supply,
and that percentage will continue to increase, adding to the current
seafood trade deficit of over \$9 billion.

**TREND: [The contribution of aquaculture to supply fish, crustaceans,
mollusks and other aquatic resources will continue to
grow.]{.smallcaps}**

While the global wild catch has plateaued and is relatively stable,
global aquaculture production has increased by approximately 8% per year
since 1970. Aquaculture's contribution to the global seafood supply
reached 43% in 2004 and is expected to exceed 50% by 2025. U.S. seafood
production from aquaculture is growing at a rate of less than 2% per
year and is responsible for only 1.5% of global seafood production. Even
if domestic production of cultured seafood were to double, the United
States will continue to import the majority of its seafood.

**TREND: [Increasing seafood consumption and demand are exceeding
capacity for seafood inspection.]{.smallcaps}**

Over 25,000 seafood processing plants contribute to the U.S. seafood
supply; approximately 80% of these firms are in other countries. The
current inspection system is wholly inadequate for monitoring an
industry of this scale, especially with regard to imports. FDA inspects
about 1% of total seafood imports and in 2007 they conducted inspections
of less than 2,000 domestic and 100 foreign suppliers. NOAA's Seafood
Inspection Program conducted audits of 274 domestic and about 50 foreign
firms in 2007 and inspects about a third of the seafood that is consumed
in the U.S. This inspection rate covers only a small fraction of the
seafood suppliers, especially with foreign suppliers, where only 100 of
the over 20,000 plants are inspected annually. At the current level of
inspection, a given domestic plant is inspected once every 2.7 years and
a given foreign plant once every 200 years. Moreover, as a result of a
recent incident concerning banned chemical contaminants in foreign
seafood, 700 Chinese processors are subject to mandatory product
analysis, which is overwhelming the FDA inspection capacity and
significantly disrupting trade.

**TREND: [Economic fraud in the nation's seafood supply is
increasing.]{.smallcaps}**

Short weights, species substitution, and mislabeling are major forms of
economic fraud in the seafood supply. Species fraud is difficult to
detect since fillets from many different species look alike and there
are many species available in the market. Catfish sold as grouper or red
snapper, unknown species sold as catfish, puffer fish sold as monkfish,
and farmed Atlantic salmon sold as wild-caught Pacific salmon are common
examples of cheaper species sold as more expensive ones. In the United
States, we currently lack the capacity to adequately test for species
fraud.

**TREND: [Consumer confidence in seafood safety is
declining.]{.smallcaps}**

Highly publicized seafood safety and fraud events have elevated concern
among the public. Often the level of concern about seafood risks works
counter to the known benefits. For example, warnings about
methyl-mercury levels in some species have led to decreased consumption
of all seafood by some segments of the population. Facts about the risks
and benefits of seafood must be accessible to a public that is demanding
accurate and scientifically sound information to make informed decisions
on eating seafood.

**TREND: [The human health benefits of seafood consumption are becoming
increasingly apparent.]{.smallcaps}**

The accumulation of scientific evidence from human clinical studies
clearly demonstrates the high nutritional value and benefits towards
reducing cardiovascular disease, promoting brain development, and
enhancing intelligence, as summarized in a 2006 report by the Institute
of Medicine, National Academy of Sciences, and in a number of other
recently published scientific journals. Clinical and laboratory studies
are expanding the list of potential human health benefits in relation to
inflammatory diseases, Alzheimer's disease, and macular degeneration,
among others. Although science and nutritional studies are demonstrating
the strong benefits of seafood consumption, consumer confidence is
declining because of the high profile of seafood contamination events
and the fact that very little of the seafood that enters the marketplace
is inspected. In actuality, documented cases of seafood contamination
are low and primarily come from only a few countries.

**SECTION 6: FINDINGS and PROPOSED OPTIONS**

The observed trends support a picture of a rapidly changing seafood
supply with increased reliance on imports of aquaculture products,
evidence of contaminants and economic fraud, and inadequate levels of
seafood inspection, especially for imports. Consumers are overwhelmed by
messages about what they should and should not eat, what fishing and
aquaculture practices are sustainable and safe, and what the benefits
and risks of seafood consumption are. Our proposed options address these
issues. We envision a future when the U.S. consumer has confidence in
the safety, quality, and nutritional value of the seafood supply;
confidence that stems from knowledge that our seafood supply is
adequately monitored, free of contaminants, replete with nutritional
attributes, and from a known source and verified species. The options
that are offered are intended to be a "cafeteria" of choices that the
committee may deem appropriate or not. Some may address these seafood
safety issues more than others.

**FINDING 1**: FDA's and NOAA's current seafood inspection resources are
inadequate for effective surveillance of the nation's seafood supply,
and this situation will significantly worsen as imports and domestic
aquaculture production increase to meet growing seafood demand and
consumption.

**OPTION 1:** Work more closely with the Food and Drug Administration
and provide support for regulatory activity as well as assisting the
seafood industry in understanding food law compliance issues.

**FINDING 2**: Adequate inspections of imported seafood are not
practical given the amount of resources available. The large number of
foreign suppliers has exceeded the agencies' current capacity.

**OPTION 2:** Increase analytical capacities to effectively support
seafood monitoring programs in NOAA Fisheries Service at the National
Seafood Inspection Laboratory and the Northwest Fisheries Science
Center, and develop an accreditation program for NOAA third party
laboratories. Analytical capacity will supplement and complement FDA
capabilities.

**OPTION 3:** Establish systematic monitoring programs and databases for
the U.S. seafood supply for contaminants and species substitutions.

**OPTION 4:** Develop new and automated technologies for more rapid,
timely, and cost-efficient analyses of contaminants and antibiotic
residues.

**OPTION 5:** Increase enforcement of contaminant and drug residue
regulations and economic fraud cases based on monitoring programs.

**OPTION 6:** Increase the capacity of the Seafood Inspection Program to
inspect foreign seafood processors to meet U.S. standards.

**FINDING 3**: Economic fraud from species substitution and mis-labeling
are decreasing consumer confidence.

**OPTION 7:** Employ new analytical methods and increase capacity for
species identification.

**FINDING 4**: Consumer confidence in the sustainability of the nation's
seafood supply is decreasing.

**OPTION 8:** Create and apply sustainability standards for U.S. wild
caught fisheries and place a sustainability logo on seafood products
deemed by NOAA to come from sustainable fishery stocks.

**FINDING 5:** The U.S. public is unsure of how to balance the benefits
and risks of seafood consumption.

**OPTION 9**: Augment research directed at defining benefits versus
risks of seafood consumption, including contemporary assessments of
mercury, selenium, banned chemical contaminants, emerging chemicals of
concern, and omega-3 fatty acids.

**OPTION 10:** Augment research to better understand human requirements
for beneficial factors in seafood and health impacts of seafood
contaminants.

**OPTION 11**: Improve public outreach and communication by providing
up-to-date information and descriptions of programs to protect seafood
consumers (e.g., NOAA Fisheries Service Fish Watch web page,
conferences, and correcting media inaccuracies).

OPTION 12: Develop and make available to the public databases that track
beneficial nutritional content of seafood products such as Omega-3 fatty
acids and selenium, as well as micro-contaminants.

**FINDING 6:** Established US Product Quality and Safety Standards are
obsolete and do not reflect the capability of modern processing
technology although there is a great demand for the use of these
standards by the retail trade. International product quality and safety
standards are in development.

**OPTION 13:** Revise US Grade Standards for Fish and Fishery Products
to be more useful in describing high quality and desirable consumer
products that will increase demand for seafood products.

**OPTION 14:** Increase NOAA Fisheries' involvement in the Codex
Committee for Fish and Fishery Products (CCFFP) beyond the current level
of providing an Alternate US delegate.

**FINDING 7:**

While many of the issues regarding seafood safety and quality, seafood
and health, outreach regarding the aforementioned, and seafood trade are
already being dealt with, though inadequately, within NOAA Fisheries,
the individuals involved are housed in several different offices,
branches, and geographic locations and suffer from the lack of program
integration and poor communications.

**OPTION 15:** Consider providing direction and coordination from one
office in NOAA Fisheries headquarters.

To enhance NOAA Fisheries seafood safety and quality capability the
function will need specific direction from an Office or staff at the
headquarters level. The components that could be brought together for
closer collaboration are the Seafood Inspection Program, The National
Seafood Inspection Laboratory, Trade staff and Partnership and
Communication (with the exception of Recreational Fishing) staff and the
addition of two positions of a trade coordinator and a seafood research
coordinator.

**SECTION 5: CONCLUSION**

NOAA Fisheries has the capabilities through an enhanced program for
seafood safety and quality to help address some serious seafood safety
issues and to enable the Federal Government to better assure the public
about the risks and benefits of consuming seafood. If the above options
are adopted, it will benefit the agency's image, and encourage the
consumption of a highly nutritious food source that promotes human
health NOAA Fisheries should work cooperatively with FDA and other
Federal and state agencies as appropriate in order to leverage resources
and enhance the effectiveness of all agencies in addressing seafood
problems. Central direction and coordination from one office in
headquarters is desirable.

[^1]: Title 50 of the Code of Federal Regulations (CFR) Part 260 \[50
    CFR260\]