6 The REAL number of scombroid toxin illnesses could be much Higher….maybe 10 times HIGHER
7 Seafood HACCP Compliance: Since Seafood HACCPregulation, 12/97,FDA collecting data onimplementationEarly on, industry steadilyimproved.However, in past4 years, has plateauedOverall compliance is still very good
8 SEAFOOD HACCP COMPLIANCE AS A FACTOR OF NAI, VAI, AND OAI RATES 2002-2005
9 Seafood HACCP Compliance Several product categoriessubstantially lower complianceControl of Scombrotoxinforming species a leadingcategory.
10 Receiving Documents for Primary ProcessorsI hope the tunawas good offthe boat!Harvest Boat QuestionnaireCrew Interview RecordLetters of Compliance fromFishermenSuppliers Guarantee for TunaHarvester Records
11 An Agency Goal - 2008 HHS/FDA - Goal Public health promotion and protection.Including food-borneillness and foodsafety
12 We Developed Seafood HACCP Goal: To improve compliance withof scombrotoxin controlsThrough information gatheredImplemented in a variety of ways
13 To develop a Plan to improve compliance with scombrotoxin controls we need Information: Conduct interviews with fisherman and processorsabout:What works, what doesn’tSuggested controlsHelp or training needsThen, perhaps do focus groupsfor more detail commentsand suggestions to improvecompliance.
14 Implementation of Seafood HACCP Compliance/Performance Goal Plan: Use information gained to develop a program to addresscauses of non-compliancemay include:Working with others; keytechnical assistancetrainingenforcement activitiesLikely will vary by region,Flexible, tailored to specificproblem areas.
15 Scombroid Control Interviews; Very Preliminary Summary Locations:Northeast U.S.Florida KeysOregonIndonesiaHawaii ?Thanks to Sea Grant Folks inOregon and FL Keys and NMFSIn the NE area!
16 Scombroid Control Interviews Summary Types of FisheryLongline, seine, rod and reel, gill net, midwater trawler boats (mackerel)
18 Scombroid Control Interviews Summary Number of InterviewsFisherman: 14Processors: 8Fisherman/Processors: 2
19 Scombroid Control Interviews Summary Types of FishYellowfin tuna, Yellowtail tuna,Albacore Tuna, Bluefin TunaSpanish mackerelMahi
20 Scombroid Control Interviews Summary Short Fishery Details:RSW, Ice, FreezerDay boats, 3-10 days, up to 30 days out fishingIndonesia uses mother boatsSome will catch one blue fin a day, others hundredsSome eviscerate some don’t; some “bleed out”Water temp for tuna generally between FAir temp wide range depending on location;
21 Scombroid Control Interviews Very Preliminary Summary General Control Comments:Only two fishermen said they kept recordsAnd then only one said took temp of fish on boat and holding temperaturesMost processors say they take the information from the fishermen for the recordsTwo processors said they require the fishermen to hand them recordsRest said the fishermen would not listen to themNot much difference between what fishermen/processors said
22 Scombroid Control Interviews Summary General Control Comments:Think fishermen should be taking care of fish not doing recordsVery common; no control over sports or recreation boats, they are the problem….along with the “foreign” productProcessors know the fish, don’t need recordsProblem is at retailCooling rates are not right; can’t cool down a large tuna to under 40F in 24 hrs.Don’t think there are illnesses or problemsSome fishermen did say their fish quality was reduced when they just didn’t bring enough ice
23 Scombroid Control Interviews Summary General Control Comments:Before HACCP there was never a problem. Used to ship the fish out within 24 hours. Now you have to check the temp and it has to be chilled to 40 degrees before it can be shipped. That means that it now has got be held for a couple of days to chill it down.One processors said he and others “gundecks” it, meaning they just make up the records.Gundecking it is an old naval expression about falsifying records. The deck below the upper deck on British sailing ships-of-war was called the gundeck although it carried no guns. This false deck may have been constructed to deceive enemies as to the amount of armament carried, thus the gundeck was a falsification.
24 Scombroid Control Interviews Very Preliminary Summary General Control Comments:FDA More concerned about getting ya than getting safe products.The FDA guys are poorly trained from a pragmatic standpoint and are taught by the book. Not making decisions on their on during reasonable situations.No consistency in FDA inspectionsReoccurring comment: More focus should be at the dock or boats not processors. I have never seen an inspector at the dock.A tuna processor told a story about one time he received a fish from LA with high temp, rejected it right away. But because it was from a broker, they took the fish back. His point was what happened to that fish and who checks that. He said they normally send it to a freezer company and goes somewhere else.
25 Yes, FDA wants to Learn from Fishermen and Processors
26 Conclusion History of Scombroid Illness in U.S. History of non-compliance with vessel records and monitoringHHS/FDA Goal to improve food safetyIncluded in that is decrease Scombroid Illness outbreaksWant to Learn from industry where and what we need to focus onVariety of local ways to implement changeCollaborate on addressing the Issue!