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APPENDIX J

INDUSTRY REPORT ON DEPURATION

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Richard H. Loring
Aquacultural Research Corporation

Dennis, Massachusetts

I am speaking for the Oyster Institute of North America, the trade organization for the shellfish producers, processors, and distributors in the United States. We are all very much aware of the problems that are upon us with ever increasing population pressures causing an increased demand on the industry and at the same time, tending to decrease the available areas capable of producing shellfish. Our primary aim is to produce and guarantee a quality product which in itself will insure public confidence. The Institute's membership has been informed of the Public Health Service's present position that there is further need to safeguard the public when they consume shellfish, and that this further safeguard should be in the form of depuration. The industry has been polled and their ideas have been correlated in the following report:

We feel that the present certification program can be accepted by all parties-the Federal agencies, State agencies and the industry--in principal. The program as outlined could meet the problem if it were properly implemented. The Public Health Service has accepted the certification program and has accepted the States' responsibility in certifying clean waters. It appears fool-hardy to throw this concept to one side, when it has proved itself effective in all but a minute portion of the total industry. It seems much more practical and expedient to concentrate our efforts on eliminating the hazard caused by a very small fraction of the harvested shellfish than to underwrite an untried and untested depuration program. As far as anyone knows depuration will be prohibitively expensive and could conceivably put a large segment of the industry out of business.

But let us not use economic hardship as a factor for it should not exist where public health in concerned. We propose to analyze our present program and demonstrate how the problem can be solved with definite, positive steps. Ideally speaking, the certification progran can work. However, it does not resolve two major problems:

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2.

The continued temptation to exploit existing population of contaminated
shellfish.

Our first problem encompasses the entire areas of pollution control and abatement. Our late President, John F. Kennedy, said that our water quality is the most challenging problem facing us right now. We are doing all we can to fight the pollution; we are doing all in our power to strengthen the Federal anti-pollution laws. Now the Public Health Service and other governmental agencies must do all they can as well. Many of the most ardent proponents of pollution control have been re-elected to Congress this year and thus there will be continued congressional interest in this critical area. However, the idea that we will continue to lose ground in maintaining clean shellfish areas may not be as true as it has been. We are trying to hold our own and reclaim lost areas. For example, next year it appears that all of the Westchester County shore of New York will be reopened all but 20% of that acreage in the near future. Pollution abatement programs are growing in number and in quality. Through education and the mass media there is an ever increasing public awareness of the problem. We therefore call upon the Public Health Service to aggressively pursue water pollution control and abatement as forcefully and as vigorously as possible.

The threat to health from polluted shellfish populations has several economically sound solutions. The relaying programs as pioneered by New York and Rhode Island have proved to be sound and effective. In a sense it is a depuration on a larger scale than any man made process. It is by far the most positive action we can take at the present moment, especially with the use of modern harvesting implements. By moans of this one solution we can eliminate the temptation to harvest shellfish from contaminated areas by depleting the population below the level of economic value. In addition we increase the resource and availability of certified natural shellfish and at the same time create more jobs within the industry to make use of any unemployment in the areas. In one operation we achieve all our goals and have something extra to frost the cake.

If a contaminated product cannot be transplanted, for example the soft-shell clams from beds in parts of Massachusetts, (which are truly a public health menace) a drastic last resort should be to erradicate them entirely by poison ing. This seems quite a wanton waste of potential spawning stock, but it is a means to an end, and necessary.

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To supplement the program of relaying contaminated shellfish populations and to avoid such drastic poisoning methods a depuration program can be developed. I say developed because at the present time the process has only been successful with soft clams and is commercially feasible because of the by-product of the operation desanding. The hard clams and the American oyster, the two an imals predominately utilized in the raw state, are not primarily winter feeders. Their reactions to the depuration process are unknown. What we advocate is a pilot depuration program, such as that being set up in Long Island. We want to be able to observe the results and evaluate them. Past experiences in "floating" shell stock, a process similar to depuration, showed oysters survived fairly well, but that hard clams became poor in condition with accompanying high mortalities and a greatly reduced shelf life. Therefore, let us find out what depuration can do under the varying conditions of seasonal changes and geographic locations. Water temperature is going to be a prime factor--can it be warmed enough in the winter months to do the job economically? What condition would the clams be in after the process? And finally, would the process once and for all purify a contaminated animal and make it safe for human consumption? These questions are. altogether too basic and yet unanswered. In truth, the industry has the responsibility to work with the States to insure that the program does work. Suppose, for example, we tried depuration before it is tested-private enterprise invests large sums of money in plants and equipment--and it doesn't work. We would have taken large stocks of clean shellfish and made them unfit for market. Do we use any shellfish and hope the contaminated stock comes clean? We would never know since the conclusive results would not be found until 96 hours after the clams have left the plant. We still would have to maintain strict vigilence over the contaminated areas because depuration, by creating a more expensive product, would only encourage boot legging. This process like the certification program, is based on public integrity. The very small minority of violators lacking this integrity would still florish while the conscientious members of the industry-those who at present are cooperating fully with the program--are being saddled with a white elephant. The problem will not be solved this way.

In addition to the relaying program and pilot depuration process, we urge closer inter-agencies commun i cations on the State level. None of us can avoid the consequences of a mistake such as Pascagoula, Mississippi, when a breakdown in a sewage treatment plant was not noted in time to close shellfish beds. We must have effective cooperative efforts as regards water surveillance and reviews. In this case, accidents cannot happen.

Once we have removed most of the contaminated shellfish, we are still threatened by a fraction of the production being illegally harvested. How is this to be combated? We recommend a central landing area for certification in conjunction with the existing certification program. This operation would check the shellfish as it comes ashore at specific sites. An officer could stamp the tags approved upon rating the product. This then would permit an easement in taking sanitary samples, and it would lay the basis for some stringent laws that any shellfish not passing through these legally controlled points be subject to immediate confiscation. Perhaps a fee

or tax could be placed on each bushel landed to help defray the additional cost and great mechanical problems which this sort of program would entail.

No matter which of the suggestions are adopted we believe more can be done by the State and Federal authorities. More cooperation is needed between the three groups. More is needed in the way of seizing shipments, policing restricted areas, and perfecting the tagging program. Tags are put on containers at the source and in some cases have been replaced with others to keep the customer from knowing the source of the stock. To prevent violations obviously means to increase the police force. It is suggested that Federal funds be used--on a matching basis with the States--to help them improve their law enforcement and for technical assistance. We do not believe that the States can do the job of policing the certification program without additional help.

There is already stringent Federal inspection of opening facilities now. if this inspection went two steps further and inspected the areas and the boats the results would be far reaching. The mere presence of more law enforcement personnel would reduce the temptation of illegal harvesting.

Increased man power can be accomplished by a cooperative program with local police, in addition to conservation officers, supplemented with more sophisticated surveillance equipment. We must reemphasize the seriousness of the crime of bootlegging resulting in the possibility of disease transmission, and utilize all law enforcement agencies and their facilities to combat illegal shellfish. More stringent retribution to the offender is a necessity. The Public Health Service can help the states in an active educational program for law enforcement to promote local understanding. Our judges must realize the importance of tight control and be cognizant of the health threat that is created by the violator. Bootlegging should no longer be considered merely a poaching offense, but be made a more serious offense and the fines and/or jail terms should reflect this. In summary then, we believe that:

1. The Public Health Service Cooperative Shellfish Certification Program

can work,

2.

Pollution control and abatement should be pushed harder,

3. Relaying programs should remove contaminated populations wherever possible,

4. That depuration be tested and researched,

5. Central landing areas for certification be established where practical,

6. Drastic action be taken against unauthorized persons caught removing

shellfish from polluted areas,

7. Federal assistance be made available to the States in their policing

programs.

We recommend the adoption of these seven points, as well as recommend much more stringent law enforcement backed up with an enlightened court to wage a strong battle on the few offenders that would risk human health and the future of the entire shellfish industry for a few quick dollars. We are plagued with some dirty shellfish and dirty people, and must remove both. The industry has presented a progressive, logical program which may differ from that of the Federal government and the States-but an amalgamation of the thinking of the three groups will produce a program that will be effective and strong.

APPENDIX K

POLLUTION CONTROL AND WATER QUALITY OBJECTIVES

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Wesley E. Gilbertson, Chief
Division of Environmental Engineering

and Food Protection
Public Health Service

The absolute need for maintaining satisfactory sanitary quality at all times in those areas from which shellfish are grown or stored is one of the most important elements in the cooperative Program. Not only is it important from the standpoint of public health, but also from those of "setting," rate of growth and taste of the final product, and we are all interested in shellfish that are safe, plentiful, and delectable.

For a variety of reasons a discussion of water quality in the coastal areas of the United States--when expressed in terms of the consumer protection goals of the Shellfish Sanitation Program--becomes one of great challenge. And it is a topic of challenge within almost any frame of reference! In terms of size we are dealing with a coastal strip of the United States in which about 45% of the population resides, and presumably in which an even larger percentage of industrial capacity is located. In terms of economics, we talk in terms of millions of dollars of expenditures for water quality control on the one hand, and the livelihood of perhaps 200,000 people on the other hand. Anyone who thinks that the problems of water quality in the estuaries have no political or social implications needs only to read the 1964 reports of the House and Senate hearings on water pollution control legislation. In terms of technical problems, the water quality requirements of the shellfish sanitation activity are so demanding that they present, at times, an almost impossible challenge to the design engineer. In terms of group interest, we find the conservationist and yachtsman--groups that have championed the cause of clean water--are significant contributors to estuarine pollution due to primitive waste disposal practices afloat. Even the septic tank--the specter of the suburbs--is a major source of trouble on many of the watersheds of shellfish producing estuaries.

As it is so often the case, we can best understand our present predicament by an examination of the past. In our case the history of our shellfish sanitation program, insofar as water quality is concerned, divides itself nicely into four or five periods; pre-sewers, sewers, sewers plus rapid population growth, and sewers plus treatment plants plus population growth.

The first of these eras was a happy one for the shellfish industry and for the public health officials concerned with the safety of the product. The coastal population was small, there were few community sewer systems and consequently there were few problems of pollution of the shellfish beds. This happy period ended in the late 1800's when health authorities in several parts of the world found out what happened when shellfish holding grounds near cities became polluted. It was the dawn of public health and it was the dawn of a long era of problems with water quality in our coastal areas. However, areas involved were infinitely small when compared with the total coastal area available for shellfish use.

The second era was the period of rapid growth of the major coastal cities, and the development of effective water supply and sewer systems. In this period great volumes of untreated sewage reached the coastal waters and the conflict over multiple use of the estuaries became reality. However, the areas involved were still small in terms of the total shellfish areas and no one was too concerned by this "loss."

Our transformation from the second to the third era was so insidious that only a few people realized a change was taking place. The population growth of the coastal cities continued with suburban developments rapidly spilling over into

formerly rural areas. The increased leisure time, a by-product of the short-work week and a high level of economic productivity, the automobile, and the modern highway system all combined to multiply this impact. Thousands of people were suddenly aware that they had the money and time to live near the shore. In addition, the large outboard motor made boating a practical recreation for many of these families. Thus, new sources of pollution were brought to all but the most inaccessible of the shellfish beds. These developments took place slowly. A few areas closed here and there until, at least in some States, there was no place in which to retreat.

While the shellfish industry faced a tightening squeeze, the technical position on shellfish sanitation, as such, was still tenable. When raw sewage is discharged into an estuary--and flows are "normal"--a relatively constant level of pollution becomes established. Field studies and laboratory examinations readily identify polluted areas and permit the control agency to close them to harvesting. (The problems of effective patrol insignificant when only small areas were closed, assumed impossible dimensions as the ratio of open to closed areas diminished.)

The fourth era marked the awakening of the American public to the need for pollution control and abatement to save the water resources of the Nation. To those concerned with shellfish sanitation, it was also the end of the steady-state situation, No longer could a relatively simple sanitary survey suffice to determine the sanitary quality of an area. We had the long-delayed awakening of public interest in the problem of preserving the Nation's water resources. Waste treatment systems were absolutely necessary to handle the pollution load. We entered the twilight zone of the conditionally approved area concept, which involves consideration of satisfactory operation of the waste treatment plants. This carried with it the need for a complete change in the concepts under which the shellfish sanitation program had operated. The change from the "steady-state" level of pollution which one can expect with raw sewage discharge to the "variable state" level which accompanies sewage treatment, in short, has many administrative and technical problems associated with it.

If the discharge of sewage (treated or otherwise) from our municipalities was the sole determinant of water quality in the estuaries, the problems would be serious enough, but that is not all. The very presence of a large city carries additional elements of contamination which cannot be entirely controlled by the treatment of the sewage. We are learning that in many areas the wash-off from a major city following a heavy rain also carries great quantities of polluting organi sms.

It is true that this pollution may not have quite the same public health significance as does the contents of the sanitary sewers. Nevertheless it does contribute to the overall problems and most certainly, the presence of these indicator organisms also obscures the true sanitary quality of the estuary. While we can consider facilities to treat some of the storm flows, especially with combined sewers, at present there is no practical approach to the matter of treatment of all water which runs off of our city streets and buildings. Then, too, we have the largely unevaluated problem of run-off from agricultural fields and forests, which is no longer laden just with simple silt and vegetable organic matter.

The problems of sewage disposal from boats has been mentioned. I will not bore you with statistics on the numbers of small craft which now use our protected waterways. All who are acquainted with coastal developments know of the large increase in the number of boats and in marinas established to service these craft. You also know that many of these boats have flush-type toilets, and that they are a source of pollution. It is true that the total sewage discharge from these boats is small in comparison with the sewage discharges from our big cities. However, it is equally true that in many cases these craft are only a few feet above the habitat of living oysters and clams. Thus, the protective elements of die-out and dilution are not aiding us the same extent as with sewage effluents from shore establishments. The problem is recognized and some steps are already being taken to develop sewage treatment devices which can be installed on these boats. However, it seems that it will be many years before these devices will be installed on all craft, and even then there will be the residual problem--and it may not be an insignificant residue--of policing the operation of these units! This is an area in which we feel that a concerted effort should be made to deve lop suitable corrective devices and that the installation and use of such devices should be required by State or Federal law.

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