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18. Suggested Change, Page 19, Section B, Paragraph 5, "Score'': It is suggested that this paragraph be revised for compatibility with the recommended change in paragraph 4, page 19. (See recommended change No. 17.)

Recommendation:

It is recommended that paragraph 5, page 19, be revised as follows:
Score.--Score is the value which results when the product of column

5 and 6 is divided by 100, minus deduction for faulty area surveillance
program for naturally-occurring shellfish toxins.

19. Suggested Change, Page 25, Section B, Paragraph 3, 2nd Sentence: It has been suggested that State administrators are reluctant to sign any agreement which would tend to commit them beyond the limits of their authority.

Discussion: One State shellfish control agency has voiced objection to Part III requiring a formalized agreement between the State and the PHS which would guarantee an ideal level of patrol activity in restricted or prohibited areas. The State has pointed out that such actions by their agency would be illegal as it would bind the Governor and the State legislature to supply personnel and/or equipment not currently authorized or funds not already appropriated.

The PHS considers the development of a patrol policy document as absolutely essential for the proper evaluation of State patrol programs, and urges that this requirement be retained. The Service will, however, accept an informal patrol document in lieu of a formalized agreement.

Recommendation: It is recommended to revise the 3rd paragraph on page 25 as follows, and to make the necessary compensatory changes in the "Area Patrol" paragraph on page 27:

A necessary step preliminary to the evaluation of a State patrol
program is a joint State-PHS evaluation of the patrol problems,
and a determination of the type of patrol organization and extent
of patrol coverage that is required to achieve the desired results.
The results of such conferences between representatives of the State
and the PHS Regional staff shall be documented and kept on file in
the Regional Office. This patrol document shall review and clarify
the following elements: (1) method of identification of closed areas;
(2) type of patrol problem; (3) listing of areas to be patrolled;
(4) frequency and nature of patrol; (5) type and frequency of report-
ing; and (6) public-educational measures. The patrol document shall
be reviewed annually and be revised when necessary.

20. Suggested Change, Page 29, Section B, "Form VII": It has been suggested that the assigned weighted values for the various sanitation items of Form VII are not commensurate with the relative importance of the items.

Discussion: This particular item was discussed at some length at the 1961
Workshop, at which time the following weighted values were agreed upon:

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There continues, however, to be some dissatisfaction with the above assigned weights and it has been recommended that the assigned values be reconsidered. Mississippi and Georgia have suggested values of 40, 30, 15, and 15. Maryland has suggested values of 45, 30, 5, and 20.

Recommendation: It has been recommended that it would be more realistic if the values were reassigned as follows:

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21. Suggested Change, Page 30, "Summary of Shell-Stock Shipper Inspection Form'': It has been suggested that there is need to revise PHS Form SS-3, "Summary of Shell-Stock Shipper Inspections." (See attachment.)

22.

23.

Discussion: It has been pointed out that Form SS-3, as it currently appears
is needlessly complicated, and requires duplication of the computations
required in rating shell-stock shippers on Inspection Form PHS-769-3.

Recommendation: It is recommended that the Inspection Form PHS-SS-3, page 30, be revised as shown on the following page.

Suggested Change, Page 31, "Instruction for SS-3 (Tentative)": It has been suggested to delete instructions for Form SS-3 appearing on page 31 of the Manual, as they have been proposed to be placed on the revised form.

Recommendation: It is recommended that the suggested change be made.

Suggested Change, Page 36, Section C, Item B: It has been suggested that for clarity and continuity of Manual language, the following sub-items of item B, Section C, be changed as follows:

Item B

- Summary of State Shellfish Sanitation Programs

Item B (1) Form IX, Summary of Appraisal

Item B (2) - Delete the word "supplementaryꞌꞌ

Recommendation:

It is recommended that the proposed suggested changes be accepted.

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APPENDIX AA

USE OF CHEMICALS ON OR NEAR SHELLFISH GROWING A REAS

AN INDUSTRY VIEWPOINT

By

J. Richards Nelson

The F. Mansfield & Sons Co.

New Haven, Connecticut

Although recorded shellfish farming' dates back to 75 B.C. when Sergius Orata grew oysters in Lake Lucrinus to please the Roman palate, it has been practiced in this country for only about a hundred years. Never an exact science, it evolved a general pattern dictated by the nature of the oyster, which is a brackish water form. It spawns, sets and grows in waters of low salinity in which its two main enemies, the prolific starfish and drill, cannot exist. Thus seed was obtained largely in harbors and areas close to shore. The seed was subsequently planted and virtually stored in the north in Long Island Sound, in deeper waters of higher salinity, better protected from storms. There they grew slowly building thicker shells and stronger muscles, making them better able to withstand the ravages of their enemies. After two or three years there they were transplanted to shallower beds suitable for fattening for market. Such areas are always infested with drills. The oyster is so prolific that sufficiently large amounts of seed were obtained to leave, in most years, a considerable harvest, even after the starfish in deeper waters and drills in the shallower areas had done their damage. Control of starfish was largely, and still is, by means of mopping and scattering of lime on the beds. Drill control was never solved. Efforts were largely confined to cleaning the beds with a vacuumcleaner type of dredge.

The rapid growth of population along our shores with resulting expansion of industry, housing and the use of new chemicals, such as detergents, has drastically altered the environment in the last twenty years. The organic and chemical pollution of rivers and harbors has forced the growers of shellfish farther and farther off shore into areas of higher salinity. Many setting grounds have been ruined. In the United States oyster production has declined from a recorded 152 million pounds in 1908 to 56 million pounds last year. In the north in Long Island Sound, the majority of oyster farmers have given up their holdings, leaving only a handful. In addition, unprecedented hordes of starfish invaded Long Island Sound beginning in 1957, when there were few oystermen left to help protect the remaining oyster beds.

The result is that it is now necessary to plant what set is available immediately in shallower areas, subjecting them not only to storm damage but more important to the drill. The small stock is thin shelled and the attrition from drills seriously weakens the industry. Thus it is obvious that pest control is essential if the shellfish grower is going to do his share in producing the finest kind of protein food for our fast increasing population.

Although pesticides were being used in land farming fifty years ago and have become of basic importance, it is improbable that such uses can ever become as important a factor in marine farming. There are several reasons for this. First, is the rapid and infinite dilution of any chemical soluble in sea water. Second, there is the difficulty of treating a crop out of sight in water. (The brief use of scuba divers has shown some interesting results.) The third, of prime importance, is the danger of using any highly toxic chemical that might be stored by shellfish, making them unfit for consumption. We, in the industry fully realize the necessity of raising oysters and clams, in fact all shellfish, that can be consumed raw or cooked with complete confidence and safety. Unless we do this the shellfish industry cannot exist.

The use of chemicals in shellfish farming is at present only on a limited basis. One example of this is the control of "Shell Disease," a fungus, in Holland by soaking very young oyster seed, during the transplanting operations, in a solution containing an organic salt of mercury. Of this method, devised by Dr. P. Korringa, Dr. C. M. Yonge, in his book "Oysters," says: "This killed the fungus in the shell without affecting the oysters, which closed the valves tightly."

Another use in the control of fungus and pathogenic bacteria in the raising of oyster and clam larvae is shellfish hatcheries. Antibiotics were used for this purpose and gave good results at first, but have been less and less effective as their use continued. Consequently, they have been little used during the past two years. Certain sulfa drugs are giving better results at the present time.

A third example is the control of oyster drills and other predatory snails by the application of polystream bonded on kiln dried washed sand, which is then either used as a barrier around the shellfish bed to control invasion or is used directly on the bed before seed is planted. This method, developed at Milford, Connecticut Laboratory by Dr. V. L. Loosanoff and his associates, shows a great deal of promise. Results to date show good snail control. Continued use will be necessary, however, to assess its ultimate value.

The fact that the chemical is drastically insoluble in sea water makes it long lasting and also minimizes the danger of absorption in shellfish tissue. Its effectiveness comes through contact by the snail when its foot is extended.

It is my understanding that preliminary feeding tests show extremely low toxicity for polystream. Also a considerable number of tests have been carried out on oysters and clams grown on treated beds. These show uniformly negative tests after 21 days from the original application.

These steps toward chemical control are just a beginning. Not only do the starfish and drill need to be controlled, but there are marine weeds, fungi and shellfish diseases to be studied. The whole field of chemicals which break down quickly and become harmless needs to be looked at for possible uses. Marine pesticide control is decades behind agriculture. The development of our knowledge of how to use chemicals in this highly specialized field must be based on fundamental research in marine biology. We in the industry are more than pleased with this viewpoint of the Public Health Service and pledge you our complete cooperation.

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