“Not in a Month Without an ‘R’ in its Name”: An Historical Overview of 20th Century Seafood Regulation With a Glimpse of the Challenges at the Beginning of the 21st

Abstract

Part I of this article introduces the American seafood and shellfish industry and provides some background data on the composition of the market as well as consumption patterns in the United States. Consideration is given not only to the domestic commercial supply, but also to a significant import segment of the market as well as recreational fishing and harvesting. Part II addresses the various risks to seafood and shellfish consumers. Again, though risks across the entire industry are addressed, particular attention is given to those risks specific to the shellfish industry. The risks discussed range from those inherent to different types of seafood to health hazards of purely human origin. Both the level of threat and the seriousness of these different health hazards are presented and analyzed. Current means of risk identification and reduction are examined briefly throughout this section. Part III begins a more specific examination of past attempts at health and safety regulation of the shellfish industry. This portion of the article provides the historical context of current shellfish safety programs while documenting the development and ultimate demise of previous attempts at industry regulation. The section begins with the creation of the National Shellfish Sanitation Program (NSSP) in 1925 and continues through its merger into the International Shellfish Sanitation Conference in 1998. Along the way, several safety issues are introduced that continue to present serious challenges to present efforts to regulate the seafood and shellfish industries. Part IV addresses the existing regulatory regime in the seafood and shellfish industries. While particular attention is given to the HACCP program instituted by the Food and Drug Administration, other existing programs such as that run by the National Marine Fisheries Service under the National Oceanic and Atmospheric Administration are also addressed. The current status and vitality of the National Shellfish Sanitation Program, now over 75 years old, is also considered. In Part V, recent criticisms of the existing regulatory regime are addressed. Inadequacies of the current system are discussed along with potential overlap and duplication among the various programs in existence. The primary focus of this portion of the article is directed toward the recent reports issued by the General Accounting Office in January and July 2001. The article concludes in Part VI with a prospective consideration of the safety issues facing the seafood and shellfish industry. The General Accounting Office recommendations are considered in light of the historical basis for the current system. Possible alternative approaches to providing for the safety of seafood and shellfish consumers are discussed, and finally, the article ends with a brief consideration of some recurring themes within health and safety regulation in the seafood and shellfish industries.