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Discussion: Deletion of the words "unless the entire operation is under direct
supervision by the State" would require that all relaying operations to be under
the direct supervision of the State, as it is believed this requirement is
necessary to prevent lilicit sale of shellfish during relaying operations, It
is also believed the recommendation for a performance bond is presently
unwarranted.

Recommendation: That the Workshop endorse the above change.

Mr. Boschetti inquired if the use of the word "recommended" required applicants to post performance bonds. Mr. Silva said he thought Mr. Boschetti was referring to the present wording of the item in the Manual but that the proposal would delete this recommendation. Mr. Bower said his only objection to it was that it looked like one had to have some record in order to do anything and that if you don't have a past record, you can't do any thing. Mr. Girard commented that ne i ther he nor anyone in the Washington State Health Department really have the right to evaluate "responsibility," as only the courts of Washington determine this. Mr. Pringle commented that in South Carolina the relaying privileges are granted by the State Board of Health, and they had a law that you can't relay except in the closed season.

In the absence of further discussion the proposed change was accepted.

Mr. Brown then introduced Mr. Leroy Houser, Public Health Service, to present the proposed changes in Part It of the Manual.

Mr. Houser presented the next series of proposals as follows:*

PART 11

SANITATION OF THE HARVESTING AND PROCESSING OF SHELLFISH

1.

Suggested Change. Page 3. Definitions: That a definition of the word "person"
should be included in the definitions of Part II. The following wording for
a proposed definition is suggested:

Person.--Person shall mean an individual, or a firm, partnership,
company, corporation, trustee, association, or any public or private
entity.

Discussion: Al though we do not have strong convictions that a definition
of the word "person" is required in the Manual, we have no objection to its
inclusion.

Recommendation: That the Workshop endorse the above definition of person" for inclusion in the definitions of Part 11.

The proposal was accepted without further comment.

2. Suggested Change, Page 4, Section A, Sub-item (a) of "Satisfactory Compliance'':

That the word "ordinarily" be deleted from the wording of sub-i tem (a). This sub-item is presently worded as follows:

a.

Decks and/or storage bins are so constructed and located as to prevent
bilge water or polluted overboard water from coming into contact with
shellfish. Removable false bottoms will ordinarily be required in
all small craft. Including rowboats, skiffs, and power boats used in
the transport of shell stock.

* (The complete paper from which Mr. Houser's presentation was made is included in

these Proceedings as Appendix X.)

Discussion: It is believed the inclusion of the word "ordinarily" in the above paragraph is unnecessary as it adds nothing to the sentence and appears to indicate there may be situations where bilge water or polluted water may be in contact with shellfish.

Recommendation: That the Workshop endor se the above change.

Mr. Hobbs indicated some of the Maryland people questioned the deletion of the word "ordinar i ly" as they had interpreted the deletion to mean they would have to have false bottoms on the decks of buy boats. Mr. Houser replied it was not intended to apply to buy boats with high decks. Mr. Pringle objected to the deletion as it would also be confusing to South Carolina tongers. Mr. Houser then suggested that in view of the opposition to the proposal, that the Workshop go on record as rejecting it.

In the absence of further discussion the proposed change was considered as rejected.

3.

Suggested Change, Page 4, Section A, Item 1. Sub-item (e): Sub-item (e) is presently worded as follows:

e.

Decks and storage bins of boats used for transporting shellfish
from polluted areas to approved areas for relaying are cleaned
and are given bactericidal treatment before they are used for
the transport of shellfish from approved areas.

It is proposed that the above wording be changed to read as follows:

e.

That portion of boats or trucks (decks, storage bins, floor beds, etc.) and all other equipment (shovels, wheelbarrows, rakes, etc.) in contact with shellstock during handling or transport from polluted areas to approved areas for relaying are thoroughly cleaned before they are used for the transport or handling of shellfish from approved areas.

Discussion: The sub-item does not now include trucks and other equipment. In addition, it is questionable as to the effectiveness of bactericidal treatment on wooden surfaces such as boat decks.

Recommendation: That the Workshop endorse the above change.

The proposal was adopted without further comment.

4.

Suggested Change, Page 5. Item 3: That a recommendation be inserted as the last sentence of item 3 to the effect that the State should maintain an educational program for harvesters concerning the dangers inherent in overboard discharge of body excreations. The insertion would be worded as follows:

It is recommended that each State shellfish control agency maintain
an educational program for harvesters concerning the public health
significance and dangers inherent in the overboard discharge of
body excreations.

Discussion: The problem of waste disposal from boats has not been solved. It is believed more emphasis, particularly on'education of harvesters, is warranted.

Recommendation: That the Workshop endorse the inclusion of the above
recommendation.

Dr. Haskin suggested that the last word be changed from "excretions" to 'Was tes", as excretions would only include urine and not fecal waste. Mr. Houser indicated this suggestion was entirely acceptable. Mr. Girard indicated the State of Washington, as has most of the West Coast States, had a number of educational programs for their citizens, including shellfishery personnel, and he doubted the wisdom of specifically indicting one segment of the industry by the above inclusion. Mr. Morgan pointed out that the was tes that go over board by shellfishery operations are so minute compared to docks and

other kinds of shipping that he questioned whether the proposal would be effective. Mr. Howell suggested substitution of the words "all boat owners" for the word "harvesters". Mr. Houser indicated this suggestion was acceptable. Mr. D'Alfonso indicated he was curious as to what type of educational program can be given to harvesters when one does not know who they are. Mr. Houser replied that when the harvester receives his license the State would have some type of leaflet or educational material to give to him, or some means of warning him against the dangers inherent in the overboard discharge of body was tes in shellfish growing areas and that the State would decide on the adequacy of their educational program. Mr. Girard pointed out that we are trying to develop ground rules for sanitary operations of the shel ish industry and since the above is only a recommendation, he recommended that it be deleted as well as all other recommendations currently in the Manual.

After approving the changes in wording suggested by Dr. Haskin and Mr. Howell the Workshop endorsed the above proposal without further comment.

IDENTIFICATION PROPOSAL

5. Suggested Change, Page_5. Section A. Item 4: That a new item be inserted

after item 3 which would be worded as follows:

4. Licenses for Commercial Harvesters.--Each person who handles

unshucked shellfish prior to delivery or sale to a dealer
certified under the Cooperative Program shall have a valid
State permit or license to do so.

In the case of leased land, either the lessee shall be
licensed or the person which harvests shall be licensed
by the State. The State agency having primary responsi-
bility for granting licenses shall maintain a record of
all such licenses granted for review by the appropriate
Public Health Service Rwgional Office.

Satisfactory compliance. --This item will be satisfied when:

Each person harvesting shellfish has a valid permit or license
to do so.

b. The State agency having responsibility for granting licenses

maintains a record of all such licenses granted for review by
the appropriate Public Health Service Regional Office.

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In the case of leased growing area(s), either the lessee or
the person who harvests shall be licensed by the State.

Discussion: This proposal is one of the identification proposals previously discussed with State agency personnel at regional and individual meetings. Licensing of harvesters provides a degree of control over their actions with respect to the Cooperative Program, which is not otherwise possible.

Recommendation: That the Workshop endorse the above addition to the Manual.

Mr. Pringle indicated that the State Board of Health issued a health permit to all harvesters in South Carolina and that he could not commit the Division of Commercial Fisheries to a system of licensing. Mr. Jensen pointed out that the Conservation Agency in South Carolina had prior knowledge of the proposals and had not expressed any opposition, therefore he could see no way at present how we could consider their problem.

Mr. Houser pointed out that the word "permit" was in the first sentence of the item hence either a permit system by the State Board of Health or a licensing system by the Department of Conservation would be acceptable. Mr. Pringle indicated he thought the use of the word 'permit" would in some measure solve his problem. An unidentified voice among the participants indicated that he did not believe we could legitimately license harvesters in Maryland unless it was done by the Health Department in a completely separate set-up. Mr. Harrison indicated he could see not reason for including this in the Manual as he did not know of any State which did not already license its harvesters. Mr. Keys indicated Florida had just instituted a program of issuing permits

and he objected to all the work they had been through recently if the Workshop did not accept this requirement. Mr. Houser complimented Mr. Keys for his foresight in going ahead with the requirement before the Workshop had adopted it, and that Mr. Key's action indicated there must be a good reason for it.

Without further discussion the Workshop adopted the proposal.

6.

Suggested Change. Page 12. Section B. Item 14: That a new item j be added
after sub-i tem (1) which would read as follows:

j. All blower tanks, skimmers, returnable shipping containers, shucking

buckets and pans purchased and/or installed after September 30, 1965, shall comply with the sani tation requirements contained in the Shellfish Industry Equipment Construction Guides published by the Public Health Service. (Copies are available from State shellfish sanitation agencies or Public Health Service Regional Offices.)

Discussion: The Shellfish Industry Equipment Construction Guides were
adopted by the 1961 Shellfish Sanitation Workshop and were published in April
1962. Subsequently, their use has not produced the desired effect of
up-grading the sanitation features of blowers, skimmers, etc., on new pur-
chases. It is believed making their use mandatory on purchases after
September 30, 1964 would gradually improve the sanitary features on such
equipment in use. One State has sugges ted an effective date of September 30,
1966. We are agreeable to any effective date satisfactory to the Workshop.

Recommendation: That the Workshop endorse the above addition.

The proposal was accepted without further comment.

7.

Suggested Change, Page 13. Section B. Item 16: That sub-item (e) be rewritten to include the word "bactericides" in the first sentence. The sub-i tem would then read as follows:

e.

Adequate cleanup facilities, including sinks, bactericides,
detergents, and brushes are available within the plant.

Discussion:
was omitted.

When this portion of the Manual was written the word "bactericides"

Recommendation: That the Workshop endorse the above addition.

The proposal was accepted without further comment.

8. Suggested Change. Page 17, Section B. Item 21: That the Public-Health Reason

and the Satisfactory Compliance of item 21 be changed to prohibit the return
of over age (bluff) from the packing room to the shucker. The first sentence
of the sixth paragraph of the Public-Health Reason would be changed as
indicated in i tem 1 below and in item 2, a new sub-i tem (g) would be added
to the Satisfactory Compliance portion which would be worded as stated in
the following item 2, sub-i tem (g):

1. The return of over age (bluff) from the packing room to

the shucker would ordinarily result in at least a
portion of the shellfish being held on the shucking
bench for more than two hours, and would permit an
undersirable growth of bacteria.

2.

g. The return of overage (bluff) from the packing room
is not permitted.

Discussion: The return of over age from the packing room is considered an
unnecessary practice which permits significant increases in the bacterio-
logical content of the shucked shellfish and should be prohibited.

Recommendation:
Manual.

That the Workshop endorse the above change in i tem 21 of the

The proposal was accepted without further discussion.

IDENTIFICATION PROPOSAL

9. Suggested Change. Page 18, Section B. item 24: That the last sentence of the

first paragraph of item 24 which requires code dating of frozen shellfish be
deleted and that a new par agraph be inserted after the first paragraph of
i tem 24 which would be worded as follows, and that compensatory changes be
included in the Satisfactory Compliance portion; i.e., sub-item (f):

Each State shall establish a uniform code-dating system which
shall be utilized by all shucker packers and repackers in that
State to indicate the date of packing or repacking of all fresh
and frozen shucked shellfish. (A recommended code-dating system
is included in Appendix B.)

Discussion: This proposed change has been discussed with the States and it
is generally agreed that the code dating of shucked shellfish assists the
regulatory agency in determining the age of the product and in tracing shell-
fish to their point of origin. Code dating is also needed to translate age
of product into bacteriological results. However, there are divergent views
among the States as to whether the code-dating system should be uni form
statewide, and whether one gallon containers should be code dated.

Recommendation: That the Workshop endorse the above wording as presently
constituted.

Mr. Gregory reminded Mr. Houser that at the meeting with Region 111 States, it had been agreed that the item would apply only to normal-size retail consumer packages but that as presently worded it included gallon size containers. Mr. Houser said that what Mr. Gregory said was true, but that when he took the Region III States proposal to the meeting with the States of Washington, California, and Oregon, the latter three States pointed out that if there is sufficient justification for code-dating, it should apply to all sizes of containers. Mr. Houser indicated he was in agreement with the West Coast States' position. Mr. Gregory indicated he thought the requirement was impractical for gallon cans. Mr. Carpenter indicated that the State people in Texas were very much concerned about the practicality of code-dating gallon cans. Mr. Morgan said the industry had several objections to this in that they had chain store requirements as to dates of expiration of their choosing. He agreed however, that some classification system for oysters was needed to pin down where they came from and when they were packed, but did not know if it could be done in a uniform manner at the present time.

Mr. Houser indicated that he visualized that each State would establish it's own uniform code-dating system and that the industry in dealing with the chain organizations would simply have to explain to them that their individual States required that they use a specific code for dating purposes. Mr. Houser also explained that the original proposal as first submitted to the States contained a requirement for a uniform code-dating system over the entire U.S.A., but that several of the States objected because they had State-wide systems which they preferred over the system we suggested be included in Appendix B. Mr. Harrison said his industry group had discussed this and came to the conclusion that a uniform system might not be applicable to all packers, but that they would like to see each packer have and use his own system which would be registered with his State authorities.

Mr. Houser then proposed that the word "uniform' be omitted from the proposal to permit the individual packer to use any code-dating system he desired. Mr. Houser pointed out this system was in use prior to the 1959 Manual and permitted the packer to use any system satisfactory to the State as long as the State had knowledge of the code. Mr. Houser indicated this change would be acceptable to the Public Health Service since he gathered there was considerable opposition to a uniform code-dating system statewide. Mr. D'Alfonso then spoke in favor of the latter proposal as he felt code-dating was most important in State authorities having knowledge of the date of packing. Mr. Felsing indicated he had been authorized to speak for the State of California, that they required code-dating, and that they urged the adoption of the requirement. Mr. Gregory inquired of Mr. D'Alfonso if he had seen the code date on gallon containers. Mr. D'Alfonso said "yes" a regular stamp with metallic ink and it was so stamped when the container was dry. Mr. Gregory said that years ago we ruled out the rubber stamp for identification and expressed curious i ty to know how we go about putting a code date on a gallon can if the code is to be embossed or impressed.

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