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Mr. Kelly then told of research accomplished when the Public Health Service laboratory was located at Pensacola where they had attempted to determine the temperature attained in the center of various sized containers. They had started out at 78° F. and wanted to find how long it would take to cool oysters to the Manual requirement of 50° F. A one gallon can when packed in ice required 41 hours. A one gallon can when stored in the refrigerator (with blower) at 32-450 F. took 63 hours. A pint jar took lž hours when packed in ice and 3 hours when in the air circulated refrigerator.

Based on the above, Mr. Kelly submitted to the Workshop that it is possible to attain the 45° temperature within a reasonable period of time and with a reasonable method of refrigeration.

Mr. Van Derwerker inquired if he thought Mr. Blair's amendment to the motion (cooled to 450 F. in four hours) could be attained. Mr. Kelly indicated it could not be, but if the time were extended an hour or two it could be, and that it would not endanger public health.

After some further general discussion of the problem, Mr. David Wallace proposed that the time be changed to five hours. There was then some discussion of what constituted a resonable time with Mr. Carpenter and Mr. Felsing stating that the words "reasonable time" should not be placed in the Manual but that the time allowed to reach a specific temperature should be specified. Mr. Van Derwerker then restated the proposal which was as follows:

"Shucked shellfish shall be cooled to an internal temperature of 450 F. within five hours after packing. Storage temperatures shall not exceed 45° F. Storage at 34-40° F. is strongly recommended to preserve quality."

Mr. Brinsfield suggested that the words "after packing" be changed to "after shucking" since shucked oysters could be retained without cooling until they were packed, and this would be a very bad practice.

The Workshop without further discussion adopted the above proposal with the substitution of the words "after shucking" for the words "after packing."

Mr. Van Derwerker then called on Mr. Houser to proceed with the proposed changes in Part 11 of the Manual.

11.

Suggested Change, Page 20, Section B. item 27 "Records": That the Satisfactory Compliance portion of this item be changed to read as follows:

Satisfactory compliance. --This item will be satisfied when
each shucker-packer, repacker, shellstock shipper, or
reshipper establishes and maintains a ledger record or
record system satisfactory to the State control agency
indicating from whom shellfish were purchased or secured;
the date purchased or secured; State designated areas from
which the shellfish were harvested; and the names and
addresses of persons to whom shellfish were sold. Failure
to establish and maintain adequate records shall result in
refusal of State agencies to certify shucker-packers for
interstate certification. (An example ledger form is con-
tained in Appendix B.)

Discussion: The only new requirement contained in the above which versus
the present wording of the item is the establishment of a ledger record or
record system separate from the financial records of the plant; the refusal
of State agencies to certify plants for interstate sale; and that an
example ledger form is contained in Appendix B. in practice, reviewing
financial records has proven to be a monumental task for investigators and
has led to much uncertainty as to the areas and sources from which shellfish
were obtained.

It is believed that establishment of specific records concerning sources,
area designations, dates, and sales would permit much quicker and more
accurate tracing of suspect shellfish to their source. This change has
been previously discussed with the States, and we are not aware of substan-
tial objections at this time.

Recommendation: That the Workshop endorse the above proposed change in
the Satisfactory Compliance portion of item 27.

Mr. Bassett commented that in circumstances under which the Maryland oyster industry operates, it would b a practical impossibility to keep a record on tongers from whom oysters were purchased. Buy boats worked on State property and bought from 50 to 100 different tongers each day. He suggested changing the requirement to "the area from which they were purchased, rather than the person.

Mr. Houser explained that the reason for the requirement was that during the several outbreaks of hepatitis control authorities had experienced much difficulty in finding out where the shellfish were purchased and from whom, and it was most important that records of these facts be available.

Mr. Pringle indicated that in South Carolina an oyster shucking plant receives oysters from their own leasees. Their pickers work for them and may go into several leased areas of various names and descriptions. All the picker is able to say is that he got the oysters from lease S.E.47. Mr. Pringle was therefore in favor of ommitting the name of the picker and requiring information as to the area from which the oysters were harvested.

Mr. Blair suggested the deletion of the words beginning with "and" following the word "failure" since he considered that these words were rather of a threatening nature.

Dr. Mosley pointed out that during outbreaks of hepatitis since 1961, it had been possible to trace commercially sold shellfish to individual shippers due to the record system in effect. This has been a very great contribution to the industry. If shellfish from a particular area are identified, then it is not necessary to issue any general warning about the hazard of eating shellfish. He further pointed out, however, that record keeping as it now exists is chaotic, non-uniform, and could be definitely improved. As Mr. Felsing and Mr. Wong could testify, as they had spent a number of days putting together data from shipper records during the Connecticut epidemic. He indicated their work could have been greatly faciliated by a uniform system. Dr. Mosley stressed that the record system needed to go beyond the shippers, as a shipper can be the unwitting victim of one or two unscrupulous harvestors, who do not care where they get their shellfish. The shipper may have the best intentions in the world, but he has no protection other than the possibility of identifying harvesters. He thought we had a very practical use for the name of the harvester selling to a shipper and pointed out that the recent epidemic in New Jersy was terminated when it was stressed that shippers whould know their harvesters and to buy only from those whose reputation and integrity they could trust. He felt that this is a matter of great importance. Although the existing record system has been of some protection to the industry, they could achieve more protection if individual harvesters can be identified.

Mr. Sieling indicated that Maryland has such a system and although it might not be operating at the one-hundred percent level at the present time, was being improved as they went along. They currently required the boat number or the name of the person shellfish were purchased from.

Mr. Pringle indicated that he was confused as to how the harvester can be identified after the oysters have crossed the skimmer or how any group of oysters can be identified with any specific harvester. Mr. Houser assured Mr. Pringle that the proposal did not include his point but only required shellstock shippers, shuckerpackers, repackers, and reshippers to keep a record of the persons from whom shellfish were received, the date of receipt, the areas the shellfish were harvested from, and a similar record of sales.

Mr. Van Derwerker pointed out that the change requested had to do only with clarifying the present Manual requirement which says, "complete and accurate records shall be kept by every shellfish dealer."

Mr. Bassett clarified his earlier statement on the basis that he misconstrued the wording and thought it required the shellstock dealer to have to record the name of the original harvester even though the "buy" boat or truck would have this information. He suggested that "buy boats" and "buy trucks" should be included in the requirement.

Mr. Houser pointed out that in another portion of the Manual, "buy boats and buy trucks" were classified as shellstock shippers, consequently his suggestion was already applicable.

Mr. Van Derwerker read the proposal as it was now proposed to the Workshop:

"This item will be satisfied when each shucker-packer, repacker, shellstock
shipper, or reshipper establishes and maintains a ledger record or record
system satisfactory to the State control agency indicating from whom
shellfish were purchased or secured; the date purchased or secured; State
designated areas from which the shellfish were harvested; and the names
and addresses of persons to whom shellfish were sold."

Mr. Bower inquired whether the example given for the Manual appendix, was an attempt to tie in the amounts of oysters purchased or harvested with the amounts sold by the dates of purchase or sale. He was assured by Mr. Houser that this was not the case except that the amounts purchased or harvested should relate reasonably close to the total sold at the end of the month. Mr. Bower felt that this still would not provide an indication of what areas the oysters came from. Mr. Houser indicated that by looking at the plant record and noting the areas harvested control officials would have a better idea in which harvesting area the problem existed. Knowing this quickly, the State would close the immediate area and the rest of the industry within the State would continue to operate as usual. Mr. Bower commented it would cost the industry money to keep these records. Mr. Houser agreed that it might cost some thing but that we had to devise some method of tracing through records the area from which shellfish were harvested and the person who harvested them. Mr. Bower suggested that the matter of records should be left to the States as they had some capabilities in the matter. Mr. Houser replied that this had been considered very seriously after the Olympia meeting with his group since Mr. Bower had suggested it at that time, but that his proposal would lead to misunderstandings and disagreements between the Public Health Service and State personnel when we evaluated their programs annually as to what the States should require. Mr. Bower inquired if there would be standardized form as proposed for Appendix B of the Manual which they would be expected to fill out. Mr. Houser said this would be up to the State people as the words were "ledger record or record system satisfactory to the State control agency," and that the Public Health Service would point out any deficiencies in their annual evaluation.

Mr. Gregory commented that when Virginia had tried to require "buy boats" to maintain records of the tongers from whom they purchased, it had failed. Mr. Houser replied that we were only asking for good records by the dealers and that where good records were not available, it usually resulted in more areas being closed than perhaps was necessary as in some situations it had been proposed that all of a State's certificates be cancelled immediatly because of the inability of the State through lack of records to be able to pinpoint quickly the source of the disease outbreaks.

Mr. Caldwell commented that North Carolina had been using this type of record system for some time and had found it created no undue hardship on the dealer. He pointed out that the record system supplied by the dealer provided a means for their Commercial Fisheries to collect their taxes as well as provide the information needed by the State Health Department.

Mr. Dana Wallace indicated that in Maine the record system had provided them with valuable information as to number of people employed, amounts harvested, value of industry product, etc.

Mr. Harrison pointed out that it would be most difficult for the buy boats to obtain names of tongers with 20 tong boats tied up on each side of the "buy boat" and with the wind blowing. Further, that the industry is not a wealthy industry and is mostly made up of small one man-operations. He felt that area indentification would be sufficient, and there was no need for customer identification.

Mr. Jensen pointed out that in a recent outbreak of hepatitis, one of the intermediate handlers had good records. These records made it possible to recover the oysters, so that no blanket prohibition on shipments from the area was necessary. He pointed out that having such sales records constitutes a big insurance policy for the industry.

Dr. Mosley indicated he seconded Mr. Jensen's views and that the record-system proposed was based on practical experience with attempting to trace shipments in both directions, had not been arrived at arbitrarily, and was the kind of information needed from a practical point of view. As far as cost to the industry was concerned, he indicated it was worth mentioning what happened to sales in 1961 when information about Raritan Bay became known to the public. if records had been available as to where the clams came from and to whom sold, the contaminated shellfish could have been removed from market channels without alarm to the public. He also pointed out the cost of investigating the incident, and that 12 to 15 people were required over a period of several months, is of interest to the industry as taxpayers. He felt that the additional cost to the industry caused by a requirement to keep more adequate records would be well repaid through protection of sales.

Mr. Van Derwerker pointed out that a fundamental concept of the cooperative program since 1925 was to be able to trace shellfish from source to destination. The alternative, he said, would be to condemn the whole industry in a State rather than to pin down the actual source, and identifying the individual harvesting from a polluted area.

Mr. Morgan indicated that he thought it imperative to be able to trace shellfish back to their source. He favored the keeping of records to avoid closing the whole industry down within a State, and indicated that he did not know of any other way to do it than by requiring adequate records, a procedure that a State agency could enforce, and suggested the proposal be adopted as read.

Their being no further discussion of the proposal the Workshop was shown to be on record as adopting it.

SECTION C

PACKING AND SHIPPING SHELLSTOCK

12. Suggested Change. Page 23. Section C: That a new item No. 3 be added after

item 2 on page 23 which would del ineate requirements for shellstock sorting
or culling benches and of floor construction if used for sorting or culling
shellstock. This would require a revision in the Shellstock Shipper
Inspection Form, a copy which is attached. The proposed wording for this
i tem appears below:

3. Construction of Sorting Benches, Tables, and Floors. -- The tops

of shorting benches and tables and contiguous walls to a height of at least 2 feet above the bench top, shall be of smooth, concrete, corrosion-resistant metal, or other durable, nonabsorbent material, free from cracks, and so constructed that drainage is complete and rapid and is directed away from the stored shellfish. Floors, if used for sorting shellstock in shore establishments shall be constructed of concrete or other material impervious to water, and shall be graded to drain quickly, shall be free from cracks and uneven surfaces that interfere with proper cleaning or drainage, and shall be maintained in good condition.

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

a. Sorting benches and tables to a height of at least 2 feet

above the bench tops or table tops are of smooth, concrete, corrosion-resistant metal, or other durable, non-absorbent material, free from cracks.

b. Benches drain completely and rapidly, and drainage is directed

away from any shellfish on the benches.

c.

Sorters' stools have no attached padding, and are so con-
structed as to be easily cleaned.

d. Floors in shore establishments used for shorting shellstock

are of smooth, concrete, or of equally impervious tile laid closely with impervious joint material, or of metal surfacing with impervious joints, or of any other material which is equivalent to good quality concrete; and when such floors are maintained in good repair.

Mr. Bower commented that he had instructions from the Olympia Oyster Growers Association to register disapproval of the proposal as it would have application to culling tables for Olympia oysters which are sometimes floating houses. He suggested the proposal be changed to apply only to clams which gape since there would be no reason to apply it to species which did not gape such as Olympia oysters.

Mr. Girard concurred with Mr. Bowers saying that culling tables for Olympia oysters met the State Health Departments requirement that they be of cleanable design. Mr. Girard indicated he could agree that a gaping clam such as their razor clam could lend itself to contamination and suggested the proposal be deleted or reworded so that it would apply only to the gaping species.

Mr. Hobbs indicated that Maryland opposed the proposal since that State used monitors for culling, and these were entirely satisfactory.

Mr. Houser indicated that in view of the opposition to this proposal, he would be willing to withdraw it if this was satisfactory to Mr. Jensen. Mr. Jensen indicated "it was'', so the proposal was withdrawn,

13. Suggested Change, Page 22, Section C: That item 25, "Refrigeration of

Shucked Shellfish be added to the requirement columns under the words
"Item No. in Section B" in Table 11.

Discussion: This item is recommended for inclusion in Table Il as it is the practice in some areas for shellstock shippers to distribute shucked shellfish as received from certified shucker-packers. It would require that if shell stock shippers buy and sell shucked shellfish, they must provide refrigeration equal to that required of shucker-packers.

Recommendation:
Table 11.

That the Workshop endorse the above for inclusion in

Workshop action:

The proposal was adopted without further discussion.

14. Suggested Change, PHS Shellstock Shipper Inspection Form 769-3: That the

Shellstock Shipper Inspection Form be reviewed to include an item 3 entitled
"Construction of Sorting Benches" which has been previously discussed in
change No 12, to include the refrigeration requirements for shucked shell-
fish if handled by shellstock shippers; and to include provision for use
of the form to inspect reshipper operations. A copy of the revised form
is attached.

Discussion: This revised inspection form now includes an item on con-
struction of sorting benches, an item for refrigeration of shucked shell-
fish. and provision is made to use a portion of the form for inspection
of reshipper operations.

Recommendation: That the workshop endorse this revised inspection form for shellstock shippers and reshippers.

Mr. Houser pointed out that withdrawal of proposed Change No. 14 above automatically withdrew that portion of the proposal related to "Construction of Sorting Benches" but not the portions dealing with refrigeration for shucked shellfish if handled by shellstock dealers and revision of the inspection form to cover reshipper inspections.

Workshop Action:

The proposal was adopted without further discussion.

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