APPENDIX C The Cooperative Program for the Certification of Interstate Shellfish Shippers An Annual Report By Frank J. Silva Eugene T. Jensen Shellfish Sanitation Branch Public Health Service In a few months, the Cooperative Program will be 40 years old and it shows every promise of living up to the adage that "life begins at 40." Instead of a senile, decaying program, we have one that is rapidly being revitalized at both State and Federal levels. We have vastly improved Federal research resources and many States are carrying out research programs of their own. True, we have administrative, financial, technical and legislative problems of varying proportion, but we feel that we know what these problems are, and that we generally know how to solve them. Therefore, we enter the 40th year of the Program, perhaps not on the threshold of the stars, but with a great deal of hope and genuine optimism for the future. Other information will be presented by other Public Health Service speakers describing specific problems and events in the Program during these next three days. Together, they will provide a reasonably good report on where we are, what we have been doing, and where we are going. All papers will, of course, be included in the published Proceedings of this meeting. One of the most important responsibilities of the Public Health Service in the Cooperative State-PHS-Industry Program for the Certification of Interstate Shellfish Shippers is the annual review of State shellfish control programs. The purpose of these reviews is to obtain information on the adequacy of State programs in meeting Cooperative Program "standards." From the information obtained during such reviews, the Public Health Service either endorses or discontinues endorsement of the respective State shellfish control program. While the Public Health Service has been conducting State program reviews since assuming its responsibilities in the Program, the completeness of these reviews, and the uniformity of review procedures between individual States and Regions, have not been entirely ideal. These shortcomings have resulted, in part, from the lack of objective uniform guidelines for program review procedures. Predictably, States being reviewed were not hesitant to remind the Service of the need for uniform evaluation measures. As a result of this recognized need, a State program appraisal procedure entitled, Part III - "Public Health Service Appraisal of State Shellfish Sanitation Programs" of the Manual of Recommended Practice for the Sanitary Control of the Shellfish Industry was developed. After several years of developmental work, this appraisal procedure was tentatively accepted by the participants at the 1961 Shellfish Sanitation Workshop. One of the provisions of this appraisal Manual (Section A, Item 2, Sub-item d) charges the Public Health Service with preparation of a yearly report on the status of the Cooperative Program. The purpose of such a report is to present a statistical review of State activities, describe technical and administrative progress, and discuss current problems. This report is submitted in partial fulfillment of this obligation. The new appraisal Manual was used for State program reviews in fiscal years 1962, 1963, and 1964. In view of the readjustments and initial difficulties associated with the application of this Manual during the first two years, this report will be confined to discussing the FY 1964 State program reviews, otherwise considered as the 1963-1964 shellfish season. The use of the appraisal procedure for FY 1964 produced greatly improved uniformity in State program evaluation procedures, and resulted in an increase in program review detail. It represented an almost complete transition from previous subjective evaluation measures to a more-objective, detailed procedure, and was effective in focusing attention on those program components requiring attention and upgrading. The evaluation procedure was broken down to review the eight identified program elements of the States' programs, namely, Administrative Procedures, Laboratory Procedures, Sanitary Survey, Relaying, Purification, Patrol, Harvesting, and ShuckingPacking. During FY 1964, there were an average of 1,250 shellfish shippers listed per month on the Interstate Shellfish Shippers List. Twenty-two issues of this list were printed and distributed to approximately 4,000 persons. Approximately 300 shucker-packers and repackers were inspected with the weighted sanitation ratings computed to be 87.1%. Approximately 100 shellstock shippers were inspected with an overall rating of 93.5%. Of 387 identified growing areas in the United States, approximately 349 were evaluated. An analysis of these ratings, in terms of individual Program component values, median, maximum and minimum levels is presented in Tables 1., 2., and 3. (attached). Names of States have not been identified with the individual ratings. In FY 1964, all 23 State shellfish sanitation programs were evaluated according to the appraisal Manual procedures. A final rating was established for every State although in a few States reviews for all program elements could not be completed. The appraisal procedure requires that each individual element of a State program rate at least 70% in order to be considered as minimally satisfactory. Table III lists the degree of compliance with this requirement in the eight individual program elements. Of the 23 States evaluated, 19 had final ratings greater than 70%. The highest rating was 100.0% and the lowest was 54.4%. The median value for all States was 84.8%. Twelve States had no program element rating less than 70%, four had one element less than 70%, five had two elements less than 70%, and two had three element ratings less than 70%. It should be recognized that these figures represent last year's ratings. Most ratings have already been or are being upgraded. Discussions have been held with State control officials, and others are scheduled, to review serious program deficiencies and to implement those necessary plans of action leading to their improvement at a satisfactory level. We would recommend caution in the interpretation of combined final State ratings. A combined rating greater than 70% could, and has contained within it, individual elements rating less than 70%. It must be recalled that a satisfactory program requires all program elements rate 70% or better. The "combined rating" is presented only as an overall numerical indicator of quality. It appears that the appraisal procedure has been quite effective in describing areas of program needs, both on a quantitative and qualitative basis. It is gratifying to report that in almost all cases the identification of a problem by the appraisal procedure has been followed by substantial corrective action. In some States, the effects of pinpointing areas of needed support have resulted in additional resources being made available to State shellfish control officials. This has included additions to present staffs, improved salaries, additional equipment for patrol, (such as the inclusion of the purchase of an airplane in expanded patrol plans in one State), stimulation of laboratory support and has also led toward developing cohesiveness and unity of purpose between participating agencies. We are convinced that there has been substantial improvement in the States' programs in the past two years. However, the change in appraisal procedures makes It difficult to express this improvement statistically. Program Expenditures In 1962 and 1963, shellfish control officials of 22 States were contacted to determine the levels of State expenditures directed toward sanitary shellfish control. Information was obtained on current levels of expenditure, and on estimated levels of expenditure needed to conduct adequate and complete shellfish sanitation control programs. In all States, there was a gap between the two levels of expenditures, with the differences ranging from 14% to 4900%. (The latter figure is atypical due to the nature of the State's program.) The median value of needed increase in funds to conduct an adequate shellfish control program was 86%. In those States where needed expenditure increments were less than the median need, only six program elements rated less than 70%. In those States where program needs exceeded the median, there were a total of 14 program elements that rated less than 70%. Three of the four States with combined ratings less than 70% required expenditures exceeding the median need. The necessity for additional resources enabling States to conduct adequate shellfish control programs is apparently confirmed by the positive relationship between program element compliance and current levels of expenditures. The Public Health Service also is not without problems of personnel and funds to carry out its obligations in the Program. During the FY 1964 program reviews, some of the elements of various State programs were not evaluated in depth. This is of particular concern when such limitations affect appraisal measures of critical program elements such as sanitary survey, patrol or relaying. In addition, incomplete appraisal of all pertinent program elements results in a distorted evaluation of the State's program and presents non-typical description of its true status. These conditions reflect the problems of obtaining adequate PHS staff to conduct complete and accurate evaluations of State programs. As a result of these staff shortages, the Regional Office has frequently enlisted the support of staff from the Research Centers to assist in evaluation activities. However, the utilization of personnel from the Research Centers to fill in these man-power gaps has obvious adverse effects upon the Public Health Service research effort. The Public Health Service recognizes these obvious operational shortcomings and is hopeful that corrective action can be realized in the near future. In general, we believe the appraisal Manual is an effective took in measuring the status of State shellfish control programs. Uniformity of evaluation has been enhanced, subjectivity has been replaced by objectivity, and the procedure has been instrumental in identifying areas of program needs, not only on a State by State basis, but on a national level as well. On the whole, the Public Health Service is satisfied with this uniform guideline procedure to evaluate State programs. It is recognized that minor modifications are necessary in the appraisal procedure and these are scheduled for discussion at this Workshop. International During 1962, 1963, and 1964, visits were made by Public Health Service officers to Japan and Canada in connection with shellfish control measures. In October 24, 1962, an agreement was concluded between the Government of Japan and the United States which permits the entry of fresh or frozen shellfish from Japan into the United States. These products are produced under Cooperative Program requirements, and as of this writing, only one plant is currently certified. In 1963, a Branch representative met with Mexican National Health and Fisheries authorities in Mexico City to discuss that nation's shellfish sanitation program, and problems related to the export of Mexican produced oysters to the United States. Future discussions on this matter remain within the initiative of the Republic of Mexico. Interest in shellfish exports to the United States has been expressed by other nations including Venezuela, South Korea and France. There have been numerous recent meetings with representatives of the French Government. In addition to these formal contacts the Public Health Service has had numerous inquiries from export firms in other countries relative to sanitation standards. Epidemiology One of the measuring sticks for demonstrating our degree of effectiveness in sanitary shellfish control is through epidemiological investigations. Through these techniques we can determine if shellfish were or were not involved in any disease outbreak, and also identify program weaknesses and special problems in those events where shellfish may have been involved. Since the last Workshop, the Cooperative Program has experienced several disease outbreaks attributed to consumption of insanitary or toxic shellfish. In December 1962, several persons became ill after eating shellfish from a non-polluted area in a Gulf State. The nature of the illness was expressed by symptoms closely resembling paralytic shellfish poisoning, e.g., numbness in extremities, loss of coordination and general reaction upon the central nervous system. Subsequent investigations revealed that the shellfish became toxic during periods of a Red Tide occurrence and that such events were well-known to local fishermen. This event resulted in closure of several shellfish growing areas, required additional surveillance control measures by the States and brought to focus a new problem in the sanitary control of shellfish in the United States. One One non-fatal outbreak of typhoid fever involving several persons was related to shellfish handling. The epidemiological evidence suggested that the shellfish had been contaminated in shallow growing waters prior to harvesting by overboard fecal discharge from a harvester, who was subsequently found to be a typhoid carrier. of the victims who had eaten shellstock harvested by the carrier was found to have the same unusual S. typhosa phage type as the carrier. It is significant to note, that as a result of this incident, the State instituted a typhoid carrier screening program for all shellfish workers, including harvesters. The screening program has been demonstrably effective by picking up an additional typhoid carrier who was immediately excluded from harvesting. In another event, in a New England State, Salmonellosis was attributed to shellfish harvested from a highly polluted, posted area, by private individuals gathering shellfish for their own use. Incidents of infectious hepatitis related to the consumption of insanitary shellfish continues to be a most important problem in sanitary shellfish control. Last winter, epidemiological investigations revealed that approximately 250 cases of that disease were linked with the consumption of shellfish that had apparently been harvested from unapproved waters. This widespread event received considerable press attention and resulted in substantial depression in shellfish sales. The economic impact associated with those affected persons in lost time, medical bills, etc., also is not without recognition. This problem continues to be one of substantial concern to the program, not only as a public health matter, but as to its related impact upon the shellfish economy. The above incidents offer ample evidence of the variability of epidemiological problems associated with sanitary shellfish production. Through epidemiological findings, specific program weaknesses have been demonstrated and hopefully out of these events corrective action can be planned accordingly. It also reaffirms the need for State control authorities to participate actively in epidemiological investigations to determine what action or resources may be required to avert additional undesirable incidents. National Register of Shellfish Growing Areas We wish that we could present accurate comparative statistics on the total number of shellfish growing areas in the United States with which we are concerned and the water quality trends in those areas. We cannot. Such information, on the whole, is simply not readily available to reflect current conditions in the United States. The need for National data to measure the pulse of our estuarine conditions has been recognized and we are pleased to report that we have made a significant start in this direction. The development of a National Register of Shellfish Growing Areas has accordingly been initiated since the last Workshop. Eventually we hope this register will describe all active and inactive shellfish growing areas in the United States and will provide, through a comprehensive file and rapid retrieval system, a central continuous record of National shellfish growing area water quality. Although State program evaluations describe to a limited degree open and closed areas, this information is quite general and not adequate to reflect national growing area conditions. A central record of shellfish growing area conditions is essential to describe trends and behavior of estuarine quality and to provide information necessary for intelligent program planning. We hope that this data can be gathered through the participation of the producing States. Close liaison will be maintained with the Bureau of Commercial Fisheries in the application of this program in fulfillment of established interdepartmental agreements. Depuration The subject of depuration has gained considerable interest since the last Workshop. This process, which has long been a part of routine shellfish production in Europe, appears to be one of continuing and growing need for domestic shellfish production. Population growths, especially in coastal areas, continue to place additional pressures upon maintaining many of our estuaries as safe for shellfish production. While the need for depuration may be much less critical in areas which are obviously remote from pollution, its use, however, appears to be the only immediate solution to safe shellfish production in areas where pollution influences subjects conventional harvesting practices to substantial risks, and allows little or no margin for error. The additional health safeguards provided by depuration has its analogy in the pasteurization of milk and the treatment of domestic water supplies. In view of the problems associated with the growth of our society, and the attendant effects upon the use of estuarine areas, it seems that depuration offers a solution to the continued production of safe shellfish in marginal areas. Inasmuch that safe shellfish production is so inextricably woven into consumer acceptance of the product, the future survival of the shellfish industry may well hinge on the application of the depuration process. Additional discussions on this subject are on the Workshop program, At present, pilot plants are located in Maine (1), Rhode Island (2) and Alabama (1). Active commercial plants are located in Maine and Massachusetts and a plant, not yet approved for operation by the State agencies, has been built in Florida; New York and New Jersey are considering study of the process; and a large "desanding" plant is being built by a shipper in Maryland. Research The need for additional shellfish sanitation research facilities was discussed at the last Workshop. It is gratifying to report that this need has been partially fulfilled by the construction of two new Research Centers. One is the Gulf Coast Shellfish Sanitation Research Center located at Dauphin Island, Alabama, and the other is the Northeast Shellfish Sanitation Research Center located at Narragansett, Rhode Island. The Gulf Coast Center serves the Gulf and South Atlantic States from Texas to South Carolina and the Northeast Center serves the States from North Carolina to Maine. PHS research programs on the West Coast are centered at the Purdy, Washington laboratory, a facility owned and supported by the State of Washington. Plans are being made for eventual replacement of this temporary structure with a permanent facility containing resources and services paralleling those offered by the Gulf Coast Center. A presentation describing the activities of the Centers will be presented in greater detail later on in the Workshop. Chemicals in Coastal Waters The increasing use of pesticides has produced serious technical problems in sanitary shellfish control, but happily has not caused significant public health or public relations problems. While the presence and distribution of pesticides has become ubiquitous in our lives, perhaps the use of these elements in the science of agriculture or pest control activities touches shellfish sanitation the closest. Pesticides dissolved or suspended in surface run-off from large drainage basins a are mixed, transported and concentrated in the shellfish growing waters of estuarine areas. As a result, pollution by pesticides has become a very important factor in sanitary shellfish control. As shellfish have the demonstrated ability for rapid uptake, but slow release, of pesticides, their presence in shellfish tissue has serious public health considerations. This year, some shellfish beds in an Eastern State had to be closed due to accidental "contamination" with BHC used in mosquito control activities. While the area affected had been previously closed for bacteriological reasons, the shellfish were nevertheless suitable for transplanting and eventual marketing. This event curtailed the transplanting activities with attendant hardship to the transplanting firms and loss of tax revenue to the State conservation agency. The question naturally comes up, how much of what insecticide is too much? Precise standards or tolerance limits have not yet been established for shellfish or shellfish growing waters, but it is hoped that this can be done in the near future. The lack of such standards should not discourage control authorities from maintaining surveillance programs and liaison with agencies engaged in insecticide activities to assure that shellfish sanitation interests are represented. Radioactive Elements The influences of radioactive elements upon shellfish growing areas is a matter of continuing concern to control officials. Since shellfish also have the ability to accumulate and assimilate radionuclides, the necessity for maintaining close control over radioactive elements becomes an additional factor in sanitary shellfish control. |