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14. Suggested Change, Page 25, Section E: That Section E be reworded to

emphasize the desirability of more States using the reshipper classification. It is proposed that Section E be reworded as follows:


Persons who reship shellfish from certified shellstock shippers,
shucker-packers, or repackers to other certified shippers or to
final consumers should be licensed and certified as reshippers.
Use of this shipper classification is left to the option of the

(A reshipper is not permitted to shuck shellfish, nor to repack
shucked shellfish.) Requirements for a reshipper depend upon
the type of product handled and the methods of operation. If
shellstock are handled, the applicable requirements outlined
for a shellstock dealer must be met (Sec. c).

If only shucked shellfish are handled, the required items are:

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Mr. Keyes commented that he objected to the proposal. In Florida, he said, they have in the neighborhood of 1200 trucks which travel through the upper west coast each week and pick up shellfish in Georgia and Alabama. A great part of the oysters that have been shucked in gallon cans are sold to truck peddlers who pick up oysters from anyone they can buy them from. The trucks cross the State line to Georgia and Alabama and sell the shellfish to whoever will buy them. Mr. Keyes felt it would be impractical to license such truckers as reshippers.

Mr. Houser pointed out that the words were 'should be licensed" which did not require action by the State but did constitute a recommendation.

Mr. Girard indicated that he thought that the use of the words, "Use of this shipper classification is left to the option of the State," is unwise as the Cooperative Program is oriented towards the growers and packers and involving wholesalers and brokers does not materially add to the sanitary control of shellfish. He moved that it be deleted.

Mr. Houser indicated that Mr. Girard had made a motion to delete the proposal and asked if anyone would support Mr. Girards proposal. There being no response, he asked how many wanted to accept the proposal to which there was also no response.

Mr. Hansell expressed concern over the fact that truckers are picking up oysters in one State and peddling them in another State without san i tary control over refrigeration and other sani tary aspects.

Mr. Jensen pointed out-that what Mr. Keyes had said constituted a very good argument for taking out the portion concerned with "leaving it to the option of the State" and making it a mandatory requirement.

Mr. Caldwell indicated that in their cooperative program with Commercial Fisheries, both agencies felt that anyone who is a dealer in selling shellfish should be licensed and that this should apply to any base from which the truck is operated. He further pointed out that if a loose truck is picking up oysters and keeping no records, then we are all in trouble if there is a disease outbreak. Mr. Caldwell expressed the view that if a North Carolina truck is going into Georgia or Florida, it should be licensed in North Carolina, and if it is a Georgia truck it should be licensed by Georgia, etc.

Mr. Wallace said the State of New York already licences such people and that they believe it to be necessary as a central part of the whole system of record keeping as discussed earlier by Dr. Mosley.

Mr. Sarraf, on being asked by the Chairman to comment, indicated that Pennsylvania does not use the reshipper classification but would favor making it mandatory after extensive study as to all that would be involved.

Mr. Keyes inquired why the reshipper should be licensed when they had the records of packers. It seemed to him to be a duplication.

Mr. Jensen referred to the outbreak of hepatitis which he had mentioned earlier. In this case, the oysters were sold by a shucker-packer to a reshipper who was a broker. For tunately, the broker had excellent records which enabled a tracing of individual shipments quickly, and two things became evident. One, in order to limit the degree of public concern over the problem, because it was soon evident that it was not necessary to close down the entire oyster industry of the Gulf Coast. Two, to provide valuable information to enable the epidemiologists to identify two other small outbreaks which occurred in Mobile and Troy, Alabama, and thereby help to explain the outbreaks which had taken place.

Mr. Gregory pointed out that the Workshop could spend the greater part of a day defining what a reshipper might be. He then indicated the State of Virginia does not propose to have their packers receive shellfish for processing from out-of-State other than directly from certified shucker-packers or shellstock shippers. He said that brokers or wholesalers, acting as reshippers, would not meet the stipulation.

After some slight further discussion the Workshop adopted the proposal as presented.

The Workshop then adjourned for lunch at 12:55 p.m.

Thursday Afternoon - November 19, 1964

Mr. Edward Gruble, Chairman

The Workshop reconvened at 2 p.m. with Mr. Edward Gruble, Vice President, Hilton Seafoods Company Seattle, Washington, as Chairman. He noted the importance of the subject of the afternoon session which was 'Use of Chemicals on or Near Shellfish Growing Areas" and indicated that the use of pesticides in increasing quantities was of cons i derable concern to the industry and to the public. From the industry viewpoint he urged that State agencies mon i tor growing waters, and keep adequate records so that pesticide tolerance levels could be established, which levels might "be lived with" by the industry. Mr. Gruble then read a resolution pertaining to pesticides which had been written by Dr. Litsky for adoption by the Workshop. The resolution was as follows:

Resolution pertaining to pesticides presented November 19, 1964 to the 1964 Shellfish Sanitation Workshop, Washington, D. C.

Resolved that this Workshop go on record as:

1. Recognizing the potential problem of pesticide residuals in shellfish and

shellfish growing areas.

2. Urging that a concerted effort be made at local, State and federal levels,

research experiment stations, shellfish associations and other groups for
a program of research, mon i toring and data collection pertaining to
me thodology of quantitative and qualitative analysis of the various species
of shellfish, and shellfish growing areas in an attempt to advocate realistic
and reliable tolerances.

3. Urging that these data be submitted to a central office, for review of

reliability, and statistical analysis. These reviews are to be sent
to all interested parties at regular intervals.


Requesting that a report of these activities be prepared by the Shellfish
Sanitation Branch, PHS and presented at the next Workshop.

Mr. Hollis said that he heartily endorsed the resolution presented by Dr. Litsky. Mr. Jensen also endorsed Dr. Litsky's resolution and stated he had already discussed the problem of tolerances with the Food and Drug Administration and that he had high hopes such tolerance would soon be established. He pointed out that adoption of the resolution by the Workshop would be helpful in pinpointing a need.

The Workshop then unanimously adopted the resolution as written by Dr. Litsky and read by Mr. Gruble.

Mr. Allen proposed that the Public Health Service develop a management or procedural system for future Workshops. There being no opposition to Mr. Allen's proposal Mr. Jensen said he assumed the applause meant concurrance by all participants and that the Public Health Service would try to move on it as rapidly as possible, and that "it might end up as an advisroy committee to the National Shellfish Sanitation Program."

Mr. Jensen then introduced the subject of the review of Part 111 of the Shellfish Sanitation Manual which constituted a method for evaluation of State Shellfish Sanitation Programs on an annual basis. By way of introduction, Mr. Jensen read the first two paragraphs of a paper prepared by Mr. William A. Felsing entitled ''Suggested Changes for Part 111 - Public Health Service Appraisal of State Shellfish Sanitation Programs". (Mr. Felsing's complete paper is included in these Proceedings as Appendix 2.)

Mr. Jensen reviewed the development of the appraisal procedure and explained that field usage has disclosed relatively few areas of weakness or inadequacies. He also noted that numerous discussions with the State shellfish control agencies have revealed that there is also general satisfaction, but that a few States had expressed concern over low ratings obtained in several of their program elements, although concurring with the Public Health Service these program elements were weak and needed strengthening. several instances, the low ratings tended to be a reflection of the transitional phase of adopting the State program files to the procisions of the new appraisal system and were not necessarily a reflection of serious program deficiencies.

Mr. Jensen then inquired whether anyone had any comments on the general philosophy of the use of Part 111 before he went into the details of the proposed changes.

Mr. Hobbs objected to consideration of Part 111 at the Workshop. He pointed out that its bulk did not enable one to fully absorb its complete meaning. He suggested it be considered at a subsequent meeting.

Mr. Jensen indicated he could not agree with Mr. Hobbs proposal inasmuch as it would put the Public Health Service in the impossible situation of not having an approved system of conducting State program appraisals. He also explained that Branch staff had met with all States including Maryland and Virginia, and discussed the procedure in detail. He stated the Public Health Service viewed the procedure as a significant step forward which would help pinpoint deficiencies in State programs.

Mr. Girard asked whether Mr. Jensen would agree to the continued use of Part 111 on an interim basis until the next Workshop.

Mr. Jensen indicated he was not in favor of this as it would leave the Public Health Service without definite performance standards for another three years.

Mr. Gregory commented that at the Maryland, Virginia, North Carolina meeting it was the consensus that Part 111 in its entirity should not be brought before the Workshop for approval but only the items which were to be revised. He also pointed out that at their meeting it was their view that evaluations should be made only by competent and experienced personnel and only if the evaluations were un i formly enforced. Mr. Gregory further felt that the Workshop was not the place for matters of such a broad scope to be presented for adoption since many attending the Workshop had no responsibility for, and little concern, for State programs. He suggested that a representative group of State officials be selected for this purpose.

Mr. Jensen replied that Part 111 provides the uniformity mentioned by Mr. Gregory. He also agreed that both the Public Health Service and the States had difficulty in obtaining competent and experienced personnel, and that the Public Health Service

had not refused to work with any States because of the lack of graduate oceanographers or engineers with advanced degrees on their staffs. As for the Workshop being the proper place for cons i deration of Part 111, Mr. Jensen said the Workshop was approved by the Association of State and Territorial Health Officers, an advisory group to the Surgeon General, and there is no higher group to which the matter could be appealed.

Mr. David Wallace indicated that after a caucus of the Region 11 States it was their unanimous opinion that Part 111 should be adopted just as it is, as he suspected there was not a person present from a State control agency who had not studied it and debated the various items at length. He fur ther explained that there was no point in arguing the details as all States including New York might object to certain i tems, but that the Part 111 was and constituted a big step forward. He recommended.adoption in toto.

Mr. Sarraf seconded Mr. Wallace's recommended proposal as presently written.

Mr. Harrison objected on the basis that all States had to live with Part 111, and it should be given closer consideration.

Mrs. Wallace said that if Part 111 were adopted by the Workshop at this time, and certain weaknesses were found during its use, these could be easily corrected at the next Workshop.

Mr. Stringer indicated he agreed with Mrs. Wallace that although the documents were not perfect, it could be revised by the next Workshop, and further pointed out that if the founding fathers had gone through this many revisions in writing the Constitution it would never have been completed.

Mr. McIntyre commented that he had used Part 111 in evaluating 3 State programs on the West Coast and that he had found it most useful in making uniform evaluations among those States.

Mr. Jensen Inquired of Mr. Edmonds if adoption of Part 111 would cause the . Government of Canada to lose confidence in our control program

Mr. Edmonds replied, "no", he thought it desirable that a uniform procedure be used, that he was not sure how this appraisal technique would affect their program, and that we should work toward a uniform technique.

Mr. Allen commented that the only way you purchase a pair of shoes is to try them on and if this particular pair of shoes does not fit you will hear plenty of squeaks from the State. He indicated most of those in attendance would go along with it as it is, with the reservation that they had the right to express themselves at the next Workshop if it does not work out.

Mr. Jensen said as he understood it Mr. Wallace's and Mr. Allen's proposal would include the minor changes proposed in Mr. Felsing's paper. Mr. Wallace indicated this was understood.

Mr. Willerford inquired if a report was available on the effect of past usage of Part 111. Mr. Jensen indicated that this information was in Mr. Silva's paper also given at this workshop.

Mr. Brinsfield said he understood two people from Region 111 had spoken (Mr. Hobbs and Mr. Harrison) in opposition to the proposal and he wanted to reiterate what they had said. He expressed fear that Workshop participants would gradually leave and then some items would be rushed through at the last moment. Mr. Brinsfield indicated he was perfectly satisfied to have proposed changes in Parts 1 and 2 whipped through but he did not think there had been time or would be time to complete discussion of the proposal. He further felt this was a very important matter and should be studied in further detail and brought up on the floor at this time.

Mr. Jensen pointed out for the record that this proposal had been well distributed before the Workshop and that practically all coastal States were still represented at the Workshop. He then listed those States presently represented which totaled 21 of the 22 coastal States, exclusive of New Hampshire which had not sent a representative to the Workshop, and in addition included representatives from Canada and Japan. Mr. Jensen asked those for adoption to stand and those opposed to do likewise. He indicated after

the count that all the States and the industry except Maryland and Virginia favored adoption. He also indicated that as far as the Public Health Service was concerned that they would continue to use Part 111 as revised by Mr. Felsing and that the record would indicate that the States of Maryland and Virginia object to use of it.

Mr. Brinsfield remarked that Maryland did not object to the use of it.

Mr. Gregory commented that they objected to the way it was adopted.

Mr. Jensen inquired what would their proposal be as a course of action?

Mr. Gregory said he had not given this a great deal of thought but he thought another series of Regional meetings between the Public Health Service and State control agencies would be helpful.

Mr. Jensen said PHS representatives had met with the States of Virginia and Maryland and had arrived at a few minor changes but that nothing could be accomplished in meetings with the other States since they had already approved it. He further indicated that he thought Maryland's and Virginia's interest was protected by the record which would show their objection to the manner in which it was adopted. He then asked Mr. Gregory if he would object to receiving shellfish from a State whose program is evaluated by Part 111.

Mr. Gregory indicated he would have no objection to the receipt of such shellfish in Virginia but wanted to repeat his objection to the way it was being put before the group for adoption and felt that there were many people present who were not responsible for State programs.

Mr. Jensen then had a roll call read. The States of Maine, Massachusetts, Oregon and Louisiana were all in favor of the proposal. Mr. Girard indicated he doubted if there was sufficient time for a roll call of the States as he had a plane to catch during the weekend. Mr. Jensen said he was only trying to show that the decision being made was by a group who were responsible for State shellfish sanitation programs.

Mr. Harrison indicated he represented the Chesapeake Bay Seafood Industries Association and that the record should show that they also opposed the adoption of Part 1ll.

Mr. Fisher commented that he was beginning to be sorry he came to the Workshop because prior to this meeting he had some confidence in the program. Now he was shaken, he said, because in the discussion on bacteriological standards he was informed that the shellfish were coming from approved sources and that this meant that the state programs were under an effective survey program of the Public Health Service. He pointed out that unless there is a standard method of conducting surveys, such surveys do not mean much. He further indicated that he felt if the products were produced for the benefit of Indiana consumers, that a standard method of checking on the sanitation of the production was necessary. He suggested that we had an interim bacteriological standard which was now changed to a full-time standard and that the same should be done here with the appraisal requirements.

Mr. Brinsfield commented that he wanted to assure Mr. Fisher and everyone else that although Maryland had not officially adopted Part 111 because there has not been time to satisfactorily go through it, that they would be quided by, and he was sure they would be evaluated by Part 111, so Mr. Fisher need not be concerned by their actions.

Mr. Jensen indicated that he wanted to assure Mr. Gregory and Mr. Brinsfield that the Public Health Service would expect to work just as closely as possible with their States and that the Public Health Service would expect to use Part 111 in evaluating all the States programs.

Mr. Gruble then explained that the afternoon speakers had been excused since it was anticipated that the session on Part 111 would take most of the afternoon. However, he noted that Mr. Stringer was still present but had indicated he would pass with regard to his presentation on pesticides.

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