Comment from Barbara Blakistone

August 7, 2010 Jerold R. Mande, M.P.H. Chair, National Advisory Committee on Microbiological Criteria for Foods Deputy Under Secretary for Food Safety U.S. Department of Agriculture Washington, D.C. Michael Landa Vice-Chair, National Advisory Committee on Microbiological Criteria for Foods Acting Director Food and Drug Administration, Center for Food Safety and Applied Nutrition College Park, MD Document ID: FSIS-2010-0001-0002 Comment on Nominations for Membership on the National Advisory Committee on Microbiological Criteria for Foods The National Fisheries Institute is the nation’s leading advocacy organization for the seafood industry. Its member companies represent every element of the industry ranging from harvesters, processors, and importers, to distribution, retail and food service operations. The seafood industry is a global industry; approximately eighty percent of the seafood consumed in the United States is imported from countries all around the world. NFI importers, producers, processors and fishermen work hard to ensure the use of practices that promote the sustainability, quality and, and the microbiological safety of their products. Seafood is one of the most regulated foods under FDA’s regulation. The regulation Procedures for the Safe and Sanitary Processing and Importing of Fish and Fishery Products – also known as Seafood HACCP – went into effect for all processors of seafood products in December of 1997. The Seafood HACCP regulation applies equally to all seafood products, both domestic and imported, that are sold in interstate commerce. The National Advisory Committee on Microbiological Criteria for Foods (the Advisory Committee) helped shape the structure and content of this important regulation. The Advisory Committee’s influence in food safety, especially seafood safety, in the U.S. cannot be over-emphasized. In addition to its guidance on HACCP, in 1992 the Advisory Committee provided guidance on the safe production of raw fish in vacuum or modified atmosphere packaging . This information has been incorporated into FDA guidance for industry on the safe production of these types of products. In 2007 the Advisory Committee completed a study commissioned by the Departments of Agriculture, Health and Human Services, Commerce, and Defense to evaluate cooking parameters for safe seafood for consumers. The Advisory Committee evaluated six years of CDC data (from 1998 through 2004) and found that “…seventy-two percent of the seafood associated outbreaks and 38% of the cases from these outbreaks were associated with only three causes: ciguatoxin (from isolated tropical reef fish, scombrotoxin (histamine toxicity resulting from mishandling and temperature abuse of a few species), and pathogens in molluscan shellfish.” These examples demonstrate that the Advisory Committee has been a provider of impartial, scientific advice on seafood safety to the Federal agencies. NFI and its members have used the fact-based decisions of the Advisory Committee in commissioning continuing research on cooking parameters for seafood. The Advisory Committee expressed concern that only a minimal amount of data was available in the scientific literature, and NFI through its Fisheries Scholarship Fund has been working on adding to the database by funding university research. The Advisory Committee’s key attribute is its impartiality. As scientists, the Advisory Committee is free to make its judgments for fact-based regulatory actions. NFI laments the recent request in the Federal Register seeking “nominations for one individual affiliated with a consumer group to serve on the NACMCF. This member will serve as a representative member to provide a consumer viewpoint. This member will not be required to have a scientific background and will not be subject to conflict of interest review.” This request moves the Advisory Committee away from impartial microbiologists to individuals without scientific grounding. This member, who would not bring the same scientific rigor to the Committee’s work as the current members, is likely to confuse his or her perceptions as scientific facts. This will not be of benefit to the agencies or public health. Further, as the Advisory Committee moves beyond the scope of microbiology to chemistry and toxicology, a solid scientific background will be essential. This too diminishes the charter to develop the criteria by which the microbial safety and wholesomeness of food can be assessed. The Federal agencies have numerous Advisory Committees engaged in commenting on issues of interest (e.g. FDA’s Risk Communication, Food Advisory Committee, and the USDA’s National Advisory Committee on Meat and Poultry Inspection). The need still remains for the National Advisory Committee on Microbiological Criteria for Foods, as a group of dedicated microbiologists, to ensure the U.S retains a safe and wholesome food supply. Carving out a seat for a participant without the requisite scientific background provides no value to the Advisory Committee. Sincerely, __________________________ Barbara Blakistone, Ph.D. Director, Scientific Affairs National Fisheries Institute McLean, VA 22102 703-752-8887 (office) www.aboutseafood.org