# Presentation: 090716

## Current Seafood Quality and Safety Concerns

**Problems, Opportunities and Threats**

- Presented by Tim Hansen
- DOC/NOAA/NMFS
- St. Petersburg FL
- December 18, 2007

## U.S. Department of Commerce Voluntary Seafood Inspection Program

- Mission
- Assist industry and consumers in improving seafood safety, quality and marketability
- Assure all inspected products meet all FDA safety and DOC quality regulations

## Services to the Seafood Industry

- Voluntary fee-for-service
- Inspection and certification services (processors and products)
- Inspects both domestic and foreign firms for products consumed in U.S. (33%, 1.9 Billion Pounds in 2006)
- Product analysis
- Consultative services                                       and training

## Purpose

- Ensures
- Quality and safety of seafood
- Grade standards
- Company or customer specifications
- Compliance to applicable regulations
- Sanitation
- Hazard Analysis Critical Control Point (HACCP)—Systems Audits
- Proper labeling

## Purpose (continued)

- Core business model satisfies quality needs of large buyers of seafood (supermarkets, federal agencies, distributors)
- Offer various federal marks that participants may use for labeling and marketing
- Participates in national and international food safety and quality fora

## NOAA Seafood Inspection Program in Food Regulatory Context

**FDA Responsible for Food Safety Except for Meat and Poultry**
- Sharing information between agencies
- Currently negotiating an updated Inspection Agreement
**USDA Food Safety Inspection Service Responsible for Meat and Poultry Safety**
- USDA has similar voluntary inspection programs to SIP with the same authority (Ag. Marketing Service)
- Work with USDA voluntary inspection programs to ensure quality and safety of food for the military and large distributors
- Cross Utilize Inspection Staffs

## HOW SAFE

*IS SEAFOOD?*

**Notes:**
The question often asked is, “How Safe if Seafood?”

## Seafood-borne Illnesses

- % of Seafood

- Category

**Notes:**
The vast majority of reported seafood illnesses and cases are those relate to ciguatoxin (some isolated tropical reef fishes), scombrotoxin (histamine toxicity resulting from mishandling and temperature abuse of a few species); and molluscan shellfish.

## Microbiological Risks

- Natural
*Vibrios*
*Clostridium botulinum*
*Listeria monocytogenes*
- Anthropogenic
*Salmonella*
*Staphylococcus*

## Seafood Public Health Profile

- Environmental – “Natural”
- Environmental – “Anthropogenic”
- Process-induced
- Distribution
- Consumer

**Notes:**
The seafood public health profile can be divided into environmental, process-induced, distribution, and consumer induced hazards with the environmental category being further divided into either “natural” or “anthropogenic.”

## Chemical Contaminants

- Raw Materials – “Natural”

- Process/Handling

- Raw Material--“Anthropogenic”

**PSP**
**Ciguatoxin**

**Domoic Acid**
**Mercury**

**Pesticides and PCBs**
**Mercury**

**Antibiotics**

**Histamine**
**Bisulfite**
**Pesticides**

**Food Additives**
**Other**

**Notes:**
In terms of chemical contaminants, raw materials may be affected by “natural” hazards such as PSP ciguatoxin, domoic acid, and mercury or other heavy metals.  Raw materials can also contain “anthropogenic” contaminants such as pesticides, PCBs, mercury, antibiotics, etc.  Process, distribution hazards can relate to histamine, bisulfite, pesticides, food additives, and other considerations.  Consumer induced hazards usually relate to microbiological issues such as handling, cross contamination during preparation, improper cooking, and storage of leftovers.  Microbiological hazards can also be natural such as marine vibrios, or pathogenic growth during processing, and distribution.

## The Great Debate: Contaminant Risks and Benefits of Consuming Seafood

- News Articles Question the Safety of Seafood
- Two Contaminants
- Methyl Mercury
- Poly Chlorinated Biphenyls (PCB”s)

## Methyl Mercury

**Known to Occur in Significant Amounts in About 25 Species**
**Shark**
**Swordfish**
**Tilefish**
**King Mackerel**
**Tuna**
**A Neurotoxin**
**No Cases of Methyl Mercury intoxication in U.S. Due to Consuming Fish**

**FDA Safety Assessment Tolerance 1.0 PPM**
**“****May Render Injurious” Standard**
**Single Level Not Useful**
**Doesn’t Take Into Consideration the Benefits of the Food**
**FDA Consumer Advisory Suggests Limiting Consumption to 12 ounces per week**
**Designed to Limit Exposure to Methyl Mercury**
**What About the Benefits?**

## PCB’s

**Associated With Farm Raised Salmon**
**Farm Raised Salmon Has Levels Well Below FDA Action Levels**
**Many Types of PCB’s**
**Toxicity Level Depends on Molecule Shape**
**Dioxin-like Molecules are Much More Toxic Than Others**
**Toxicity Depends on What PCB’s The Fish Has Been Exposed**
**More Research of the Risk is Needed**

## Some of The Benefits of Consuming Seafood

**Less Fat**
**More Healthy Fat**
**More Digestible Protein**
**Omega 3’s**
**Heart Benefits**
**Neural Development in Fetuses and Children**
**Positively Affects Mood in Human**
**Benefits Tremendously Outweigh the Risks**

## NOAA Scientific SupportSeafood Safety Research and Monitoring Program

- Seafood Safety
- Aquatic Animal Health
- Risk Assessment
- Contaminant Monitoring
- Ecological Monitoring
- Benefits of Scientific
- 	Support for SIP
- Risk Communication

## Recent documents on seafood safety

**Recent documents on seafood safety**
**provide a basis for this presentation**

**Notes:**
The issues discussed in this presentation rely in part on the authority of two recently completed documents - the agency’s FAQ sheet on seafood safety, and the NOAA Fisheries/FDA sponsored 
Institute of Medicine study Seafood Choices.

## Slide 18

## Current Conditions in The Seafood Industry and Regulation

- ~80% of Consumed Seafood is Imported
- ~20,000 Foreign Firms Shipping to the U.S.
- Food Safety Controls are Questionable in Some Countries

## Current Conditions in The Seafood Industry and Regulation

- Unknowns in Foreign Countries
**Sanitation Conditions**
**Pre-requisite Programs e.g. Building, Water Supply, Health Checks**
**Compliance with HACCP Regulation e.g. Preventive Program for Food Safety Hazards**
**Supply Chain Compliance with HACCP Regulation**

## Current Conditions in The Seafood Industry and Regulation

- Aquaculture Drug Control is Often Weak or Non-Existent
- Very Little Analytical Testing for Drugs By Foreign Competent Authorities
- Cost
- Pressure to Not Regulate
- No Testing Methodology

## Current Conditions in The Seafood Industry and Regulation

- FDA Performs ~100 Seafood Inspections Per Year World-wide
- Has “Affirmative Step” Documentation Requirement in the Seafood HACCP Regulation
**Generally Very Weak**
**Easily Falsified**
**Regulatory Actions Not Vigorously Pursued**

## The Regulators

**Current Challenges for FDA**
**Not Organized to Deal with Imported Food**
**Decision-making Process is Burdensome**
**Staff Reduction Due to Retirement and Staff Shrinkage**
**Loss of Critical Skills e.g. Filth, Parasites, Scombrotoxin **
**Funding Reduction of ~40% in 3 years**
**Dissolved the Focused Policy/Planning Function (Office of Seafood)**
**Reduced Focused Research on Seafood Safety**
**Often Distracted by Other Food Safety or Health Crises e.g. Monkey Pox, Spinach, Pharmaceuticals**

## Congress and Executive Branch Interest in Import Problems

- Congressional Hearings Both House and Senate
- OMB Food Safety Cross-cutting Agency Group
- Import Safety Taskforce

## A Perfect Storm for Seafood Safety Problems?

- Opportunities
- Partnership with FDA
- Inspection (Including NSIL for Analytical Work)
- Research NSIL and NWFSC
- Risk Management & Policy

## Seafood Inspection Program NSIL

**F**ield Opportunities for SIP
**Recognition of Domestic Program**
**Involvement in Imports**
**Overseas HACCP Inspections**
**Analytical Assistance**
**Foreign Laboratory Approval**
**Collaboration in Training and Technical Development**
**Assistance in Compliance Work**

## NSIL and NWFSC

**Research Opportunities**
**Toxic Algal Blooms**
**Scrombrotoxin**
***Clostridium botulinum *****(MAP Packaging)**
**Methods Development (Aquaculture Drugs and Contaminants)**
**Metal and Glass Inclusion**
**Parasites (e.g. Sushi, Sashimi, **
**	****Seviche)**
**Decomposition**
***Listeria monocytogenes***
**Pathogens at Retail**

## NOAA Fisheries in General

**Risk Management and Policy Opportunities**
**Risk Communication e.g. Development of Fish Watch with Collaboration with FDA**
**Risk Assessment of Seafood Safety and Quality Hazards**
**Development of Good Aquaculture Practices**
**Involvement in Further Development of the Fish and Fishery Product Hazard Guide**

## NOAA Fisheries in General

**Down Sides**
**“****Turf” e.g. perception by FDA of Taking On Their Mission**
**Assistance Activities Inconsistent with NOAA Fisheries Mission**
**Assumed Burden of FDA Mission**
**Increased Expectation in **
**	****Seafood Safety Area**

## NOAA Fisheries Mission and Seafood Quality and Safety

**MAFAC Advice Sought:**
**What is the most important long term objective for NMFS to accomplish in the area of seafood quality and safety?**
**Are there any immediate structural, organizational or other important process impediments to the success of the program that can and should be addressed in the short term?**
**Current program: strengths and weaknesses?**
**What is the highest priority policy or strategic seafood quality and safety issue needing resolution in the next administration?**