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The committee also notes that the development or reassessment of contaminant guidelines should take into account critical regional differences in seafood harvesting and consumption patterns. A focus on the creation of national contaminant standards (as opposed to regionally based standards, for example) could lead to a situation in which a higher than anticipated seafood risk could be characterized for critical subpopulations (e.g., pregnant women, women of childbearing age, children, and recreational fishermen). Among other things, this leads to a recommendation that regional and high-risk group consumption data be collected so that more realistic seafood risk characterizations can be developed.
The development of regulatory guidelines for seafood safety is a responsibility shared by EPA and FDA (for pesticides), and by FDA and states (for shellfish). Although a rather impressive number of interagency boards, councils, and formal understandings exists, these arrangements have not been used sufficiently to reduce the problems that result from the lack of interagency cooperation. Of particular concern are the rather important differences between EPA and FDA in their respective risk assessment methodologies. The development of an interagency structure with a single focus on seafood safety could contribute significantly toward reducing these difficulties.
Monitoring and Inspection
In general, the present monitoring and inspection program carried out by all federal agencies lacks both the frequency and the direction sufficient to ensure effective implementation of the nation's regulatory limits for seafood safety. However, the need for a renewed and redesigned seafood inspection effort is now almost universally acknowledged. This committee is not in the position to evaluate prospectively the likely success of alternative inspection models currently under consideration by Congress and the administration. However, whatever inspection does emerge from this effort should address several discrete questions and concerns.
Future efforts must recognize the importance of understanding and quantifying the source and level of contaminants in seafood harvesting areas. Existing environmental monitoring efforts are not, for the most part, designed to be of direct use in evaluating seafood safety concerns. 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 risks, as opposed to environmental health impacts. This last point is of particular importance. Save for the monitoring of harvesting waters carried out as part of the National Shellfish Sanitation Program, 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, liver, or gallbladder analysis which, by design, offers insufficient insights into contaminant levels in the marketable seafood product. In addition, any expanded seafood safety effort must focus on the level of hazard at the point of capture. One strategy to mitigate such risks is for agencies, both federal and state, to more explicitly develop regulations allowing for fishing closure based on questions of public health.
There is widespread application of HACCP-based systems for ensuring control of the safety of food products. Such systems are well designed to control the safety of processing operations in which human activities can either decrease or increase risk. However, control of the intrinsic safety of the raw material may not be easily achieved.