Chapter 7- International Trade and Seafood Safety
Agricultural Economic Report No. (AER828) 145 pp, November 2003, USDA-ERS
Allshouse, Jane, Jean C. Buzby, David Harvey and David Zorn (FDA); Jean C, Buzby (editor)
Objectives & Key Methods
This paper mainly served as an overview of issues in international trade and seafood safety. The topics discussed included: U.S. Seafood Exports and Imports, Seafood Safety, FDA Import Detention Data for Seafood,
Seafood Safety Incidents Affecting International Trade, Public and Private Actions to Ensure Safer Seafood, and finally Implications for Policymakers which summarized the data presented in the paper.
To address these issues this paper used a literature review and some data analysis of FDA Import Detention data. The bulk of this review will serve to document the noteworthy facts gathered from this paper...
Key Background Info
- During 1976-78, jurisdiction over coastal waters by coastal nations expanded to 200 nautical miles offshore
- Technological advances have increased productivity, altered patterns of trade and added pressures on wild fish stocks
- Growth of aquaculture, led to an oversupply of certain species and thus "dumping"
- US ranked 5th in overall fisheries production, 4th in terms of volume of exports, 2nd in volume of imports (FAO, 2000)
- "No evidence that imported food, as a whole, poses higher food safety risks than domestically produced food" (Zepp et al., 1998)
- Federal agency that governs fishery resources is the National Marine Fisheries Service (NMFS) in the U.S. Department of Commerce’s National Oceanic and Atmospheric Administration (NOAA)
-"In the United States alone, aquaculture production increased from 570 million pounds in 1990 to 880 million pounds in 2000 (National Marine Fisheries Service, 2001)."
U.S. Seafood Exports and Imports
- Values are not all estimated at the same stage of production
* Export: "free alongside ship" value, value of product at port of export based on sales price including inland freight, insurance and other charges incurred prior to exportation
* Production: ex-vessel prices, value of catch at dock where vessel is offloading
- Export value/pound from United States is usually significantly lower than import value/pound to the U.S. because mix of species exported is different than mix imported and level of processing varies
- A significant quantity of U.S. produced seafood is exported to countries with lower labor costs for processing and then reimported into the U.S. for consumption (explains how countries can be large importers and exporters of high quality seafood at low price)
- Because seafood is a seasonal commodity seafood producers use access to international markets to stabilize revenues (this is why seafood producers and consumers have interest in maintaining open markets to provide year-round seafood to as many potential customers)
- Cod, flounder, menhaden (mostly used for fish oil and meal for poultry feed), pollock, salmon, crab, shrimp and squid accounted for 76% of total US exports in 2000; exports dominated by salmon products (Pacific salmon not consumed by western states is exported to Japan and large amounts of farmed Atlantic salmon goes to East Coast from Canada and Chile), surimi (processed seafood that uses pollack as major ingredient), lobster, caviar and other roe (combo of products from herring, salmon, pollock, sea urchin and other species) primarily to Japan and Canada (about 55% of 2001 export value)
- "United States imported roughly $6.8 billion more edible seafood than it exported in 2001: the U.S.
imported $9.9 billion (4.1 million pounds) and exported $3.2 billion (2.6 million pounds) (NMFS, 2002)"
- Top 5 imported products to the U.S.: shrimp ($3.6 billion, 883 million lbs), tuna ($829 million), lobster ($728 million), crab ($368 million), fresh and frozen salmon ($335 million)- 60% of all U.S. fisheries imports
- Seafood trade is less restricted than trade for other ag products because of lack of heavy quotas or duties on imports, vast majority of seafood products are tariff free (i.e. frozen shell-on, head-off shrimp, most common form of imported shrimp & fresh or frozen Atlantic salmon as whole fish or fillets)
- Highest tariff rates are for tuna in airtight container in oil (35%) and sturgeon roe/caviar (7.5%) (Koplin, 2002)
- Low tariffs may be due to lack of availability from local fishermen, lack of availability in sufficient quantities, or lessening of tariffs due to General Agreement on Tariffs and Trade (GATT) negotiations
- 2001: Canada, Thailand, China, Mexico, Chile, Vietnam and Ecuador largest suppliers
- Developing countries supply about half of all worldwide seafood exports (Sun and Caswell, 2002), Asia exports 36.5% of total (Cato, 1998)
Seafood Safety
- "Most seafood-associated illness reported by U.S. consumers point to consumption of raw bivalve mollusks
and to unspecified and unknown foodborne illnesses with Norwalk-like viral gastroenteritis symptoms (Ahmed, 1991)."
- "According to the U.S. Centers for Disease Control and Prevention (CDC), surveillance data for
foodborne disease outbreaks indicates that 6.8% of the 2,751 outbreaks during 1993-97 were attributed to consumption of shellfish and other fish (Olsen et al., 2000)." Does not include unreported cases.
- World Health Organization (WHO) estimates that 40 million people become infected each year from trematode parasites by consuming raw or inadequately processed shellfish, freshwater fish, and aquatic plants (WHO, 1995).
- Types of seafood hazards:
* Bacteria: Vibrio parahaemolyticus, Listeria, Salmonella and Staphylocococcus
* Viruses: Norwalk virus associated with raw shellfish consumption
* Toxins: ciguatera found in large tropical reef fish, domoic acid found in shellfish and mollusks, saxitoxin also found in shellfish, and histamine found in mahi and tuna
* Parasites: roundworms in raw or not fully cooked food; freezing can destroy these organisms in fish for raw consumption
* Chemicals: localized problem in freshwater species, but can also occur in ocean fish from spills, dumping of pesticides, industrial chemicals, heavy metals and petroleum products
* Product inputs: allowance of vaccines, feed additives, antibiotics for farm-raised fishery products has caused food safety concerns (FDA, 2001)
- Seafood is more perishable than livestock or poultry, faster decomposition and shorter shelf life
FDA Import Detention Data for Seafood
- The Federal Food, Drug and Cosmetic Act (FFDCA) was enacted to protect the health and safety of
Americans and to protect them from mislabeled or adulterated domestic or imported food products.
- 2 types of detention:
* Regular detention: physical analysis or records show violation of FFDCA
* Detentions without physical examination (DWPE): automatic based on past violative history or based on alerts that are perceived to be a threat to human health (represent a large majority of detentions)
- Only a small percentage of all seafood imported into U.S. is physically inspected so detention data does not fully capture all food safety problems
- "sampling strategies by FDA and other agencies are designed to focus enforcement and inspection efforts on areas that have the highest probability of having a problem (Ahmed, 1991)"
- 2 main categories for seafood detentions: (2001, 83.6% adulteration and 14.3% misbranding, 2% insanitary manufacturing, processing or packing)
* Midbranding- included untruthful labeling or lack of labeling
* Adulteration- safety, packaging integrity or sanitation problems (Caswell and Wang, 2001), Salmonella (34%) and "filthy" (27%) accounted for more than half of all adulteration violations
- 63% of countries had products detained for “no process,” meaning that the manufacturer had not filed information on its scheduled process
- Highest misbranding violations: Nutrition Labeling (2001: 200 or 3.1% of all violations), Lack Firm (2001: 140 or 2.2% of all violations) and Usual Name (2001: 136 or 2.1% of all violations)
- Top 3 countries with number of violations in 2001: Vietnam (580 detentions, 1.21 detentions per $1 million), Thailand (407 detentions, .25 per $1 million) and Indonesia. Canada is the number one importer (.03 detentions per $1 million)
- Shrimp is the largest single import item (40% of seafood import value in 2001) with a quarter of all detentions, accounts for 58% of all Salmonella detentions and 48% of all filth violations.
Seafood Safety Incidents Affecting International Trade
- Food safety restriction can act as barriers to trade
- Food safety incidents can impose costly requirements on developing countries beyond their ability to afford compliance (Henson et al., 2000)
Public and Private Actions to Ensure Safer Seafood
- 7 HACCP Steps:
1) conduct hazard analysis
2) identify critical control points (CCP) for physical, biological and chemical hazards
3) establish critical limits for preventative measures associated with each CCP
4) establish ccp monitoring requirements
5) determine and perform corrective actions
6) establish recordkeeping systems
7) conduct verification procedures
- Canada: first to establish HACCP-based inspection program for fishery products, importers may develop quality management system for submission to Canadian Food Inspection Agency (CFIA, 2002)
- EU: 1991 and 1994 adopted regulations roughly based on HACCP (FAO, 2000)
- US: 1995 FDA stipulated that importers of seafood to the U.S. meet same HACCP standards as U.S. seafood processors (Federal Register, Dec. 18, 1995)
- Inspection protocols, regulatory limits for contaminants (Ahmed, 1991) and HACCP systems vary across countries. EU regulations apply to whole production chain whereas U.S. seafood HACCP apply only to processors (FAO, 2000)
- Leading trade association for fish and seafood products is the National Fisheries Institute founded in 1945, mission includes food safety education for the seafood industry including scientific and technical information on key issues like HACCP, irradiation, mandatory recalls, mercury and voluntary seafood inspection services
- National Shellfish Sanitation Program (NSSP) requires identity tags from harvest to consumer: "The tags must include the identity of the shellfish harvester/dealer and the date and location of harvest. Lot identity of the shellfish must be maintained throughout the production and marketing chain. The identity preservation system has been very helpful to authorities in the control of foodborne illness. But it is not a complete solution to the seafood safety problem. Tags may be lost or switched and the existence of tags does not control pathogens and other hazards."
- Farm Security and Rural Investment Act of 2002, Section 10816 contains two new labeling requirements pertaining to seafood:
1) Seafood must have country-of-origin labels
2) Labeling has to distinguish between farm-raised and wild harvest seafood products
Implications for Policy makers
1) Salmonella is a potential target for risk reduction efforts
2) Most Salmonella contamination detentions are for shrimp, most seafood Salmonella contamination is due to cross-contamination introduced during the processing stage
3) International seafood markets will continue to expand and become increasingly segmented
* "In the United States, the average import share of fish and shellfish consumption increased from 56.3 percent
in 1990 to 68.3 percent in 2000."
* Increased demand means wealthy countries will want to remove most trade barriers to decrease price (FAO, 2000)
* By 2030 more than 50% of fish supplies will come from aquaculture and wealthy countries will depend more on imports.
Opinion and General Comments
According to Google Scholar this paper has been cited 11 times since 2003. Since this was an overview report, perhaps stated objectives were not necessary, but I arrived at the same three conclusions after reviewing the paper. Given the governmental nature of the data its biases show through. Clearly this paper was pro-trade without considering that local sourcing of seafood could greatly mitigate seafood safety standard issues. One project that was made is that seafood safety may become a source of product differentiation. I don't believe this as people will continue to consume fish that is available, especially given immigrant populations throughout the world. This lack of discretion is also why local sourcing of seafood is not a major focus, most people will eat what is available irregardless of season and safety standards. The paper did point out there there is difficulty in separating the roles of food safety and non-science issues such as consumer preferences in regulatory decision making.
This paper stated: "Difficulties in determining whether an equivalent safety outcome has been achieved when process standards are used" and "Strong differences in consumer risk perceptions and preferences" have caused differences in regulations and standards among countries. According to the authors this could lead to international trade conflicts of disputes that can ultimately affect global patterns of food demand and reduce trade. This is evidence of their pro-trade stance, which is so ingrained in economic, but as I was mentioning earlier the opposite, local sourcing, may do a better job of improving local economies and improving food safety standards.
For the purposes of my research this paper is justification for focusing on aquaculture shrimp: "most contamination problems are from Salmonella in shrimp and prawns, risk reduction efforts theoretically could be focused on that bacterium." (p. 109), shrimp is primarily aquaculture product.
Useful References
Zepp, G., F. Kuchler, and G. Lucier. “Food Safety and Fresh Fruits and Vegetables: Is there a Difference Between Imported and Domestically Produced Products?” U.S. Dept. Agr., Econ. Res. Serv., VGS-
274, (April 1998):23-28.
Cato, J.C. “Seafood Safety—Economics of Hazard Analysis and Critical Control Point (HACCP) Programmes.” FAO Fisheries Technical Paper No. 381, Rome: Food and Agriculture Organization, 1998.
National Marine Fisheries Service (NMFS), U.S. Deptartment of Commerce. “Imports and Exports of
Fishery Products: Annual Summary, 2001,” Dept. of Commerce, 2002.
Food and Agriculture Organization, United Nations. “The State of World Fisheries and Aqua-culture,
2000.” ISBN 92-5-104492-9, Rome, Italy, 2000. www.fao.org/DOCREP/003/X8002E/X8002E00.htm, accessed June 7, 2002.
Ahmed, F.E., editor, Institute of Medicine. “Seafood Safety.” National Academy Press: Washington DC, 1991. www.nap.edu/books/0309043875/html/index.html, accessed Aug. 9, 2002.
WorldCatch, Inc. “EU Fish Products Now Require Extra Labeling,” The Wave, Oct. 23, 2001.
U.S. Food and Drug Administration. Fish and Fisheries Products Hazards and Controls Guide.
2001, pp.16-37. www.cfsan.fda.gov/~acrobat/haccp4c.pdf
Blisard, N., B.-H. Lin, J. Cromartie, and N. Ballenger. “America’s Changing Appetite: Food Consumption and Spending to 2020,” Food Review 25,1(Spring 2002):2-9.
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