TROUBLED WATERS:
ARE TOUGH TIMES AHEAD FOR VIRGINIA’S COMMERCIAL FISH AND SEAFOOD INDUSTRY?

George J. Flick, Jr.

The United States is the world’s second largest importer and exporter of fish and shellfish, ranking fifth in total harvest behind, in decreasing order, China, Peru, Chile, and Japan. In 1996 the United States imported twice as much seafood as it exported. The result was a trade deficit of $3.7 billion, up more than 5 percent over the 1995 deficit. Major importers (product volume) included Canada, Thailand,Ecuador, Mexico, China, and Japan, while most exports went to Japan, Canada, and Korea. The amount of fish and shellfish imported into the United States is substantial when compared with other food products. More fish and shellfish are imported than fruits and vegetables, and more seafood than coffee.

In 1966 Virginia ranked fourth domestically in fish and shellfish production behind Louisiana, Alaska, and California. Shortly thereafter, Virginia became the third largest seafood producing state behind Alaska and Louisiana. Latest ex-vessel statistics indicate that Virginia landed 581 million pounds in 1994. While the number of seafood species landed in Virginia is large, only a few species account for the total value. Blue crabs, menhaden, sea scallops, hard clams, and flounder account for almost 90 percent of the total landed value.

The total economic impact of Virginia’s commercial fishing industry currently exceeds three-quarters of a billion dollars, with person employment years of 10,798. The seafood industry contributes significantly to the Virginia economy since most of the money generated by the industry remains in the state, resulting in a multiplier effect between two and three. This means that for every dollar generated from seafood production, two to three additional dollars are produced. One reason for the relatively high multiplier effect is that the Virginia industry consists primarily of small, locally owned firms.

THE PROBLEMS

What is the future for Virginia’s aquatic food resources? Will they continue to serve the important economic and dietary roles they currently enjoy? The answer is uncertain since today’s fish and shellfish resources, both aquacultured and wild, are subject to much controversy, which oftentimes involves food safety. Some of the food safety issues arise from legitimate scientific concerns, while others are derived from misinformation generated by public interest groups, competition for the limited wild resources, and consumers’ concern for a safer food supply.

The harvest of much of our wild fish and shellfish stocks is regulated to prevent damage to existing diminishing stocks. Many of these regulations result in substantial negative economic impacts on Virginia producers. Competition between recreational and commercial fishing and between the coastal tourism industry and commercial fishing has also emerged as an important factor that could adversely affect the industry. Finally, state and federal regulations affecting aquaculture and processing operations have reduced the profitability of some firms to the point that they must cease operations or relocate off-shore.

Significant emerging problems for commercial fishing are access to the resource and resource allocation. Within recent years, the dwindling supply of wild fish stocks has pitted recreational fishermen against commercial fishermen. This problem has the potential to affect not only seafood, but also the production of poultry and aquacultured fish and shellfish products. Many recreational fishing groups have openly stated their desire to completely close all wild fisheries to commercial fishing. Some states have enacted laws prohibiting specific fish species from capture by commercial fishermen. Other regulations have eliminated the use of certain types of fishing gear, such as gill nets.

Another approach promoted by recreational fishermen is the allocation of fish resources on a percentage basis, a predetermined amount for both commercial and recreational fishermen. Interesting discussions arise when the proposed allocations are discussed. It is difficult to obtain consensus since extreme views are usually presented without the possibility of meaningful discussion.

Producers of aquacultured trout have expressed concern about how their farm-raised fish are treated in the Code of Virginia. In some portions of the Code, aquacultured trout are treated as wildlife, while in other parts they are treated as livestock. Some of the traditional statutes enacted to protect wildlife do not apply to cultured fish. One of the major issues concerns the requirement for disease certification to transport fish across state lines. Currently, that certification is not available to producers in Virginia, and out-of-state services are cost-prohibitive. Emerging issues for trout producers are the implementation of affordable waste abatement practices and achievement of increased production through the adaptation of recirculating water technology.

Coastal development is a potential threat to Virginia’s emerging mollusk aquaculture industry. The U.S. Food and Drug Administration (FDA) has established regulations concerning the growing, processing, and distribution of mollusks. One of those regulations restricts the harvesting in areas of known pollution or potential pollution. Potential pollution can come from swimming areas, marinas, housing, and sewer treatment facilities. The FDA regulation basically states that even though growing waters meet the standards for shellfish production, if a potential pollution exists, the water use then becomes incompatible for shellfish production. As a consequence, coastal development can have an immediate and severe impact on shellfish production. As Virginia’s coastal areas become more developed, the shellfish industry has been forced either to adopt alternative production practices or to cease business operations. Too often, the decisions on coastal development are made based on the economic impact to a specific community rather than consideration of a broader socio-economic approach.

Another threat to aquaculture is a rapid reaction by decision makers to an environmental issue that may not be completely defined. Recently, the U.S. Corps of Engineers established a policy prohibiting mollusk aquaculture in areas with submerged aquatic vegetation (SAV) even if that area is controlled under a private lease. While aquatic vegetation serves an important ecological function, there is insufficient scientific evidence that mollusk aquaculture causes environmental deterioration and is, therefore, an unacceptable practice. The economic impact of inappropriate regulations or policies can have an equal or greater economic impact than no action. Unfortunately, remuneration from government agencies for financial losses incurred through the enforcement of faulty policies is not possible.

Tourism has emerged as another controversy affecting the commercial fishing industry. Many business leaders in coastal tourist areas believe that large fishing vessels operating near the shore present a negative impression to visitors. In addition to the negative visual effect, concern exists that dead fish may be spilled accidentally or that escaped petroleum products will pollute the area. Unfortunately, accidents have occurred, but fortunately, these occurrences have been sporadic, affecting a very limited geographic area, and rapidly resolved.

The solution to access and resource allocation remains unanswered today--and will into the future--since there are no simple ways to resolve these issues. One difficult question to answer is Who owns the seafood resources? If we accept the principle that seafood is a common property resource, then ownership belongs to all citizens of the Commonwealth of Virginia and the entire United States. This means that everyone should have equal access to the resource. It is impractical, however, for non-coastal residents to travel to the coast and catch their seafood; consequently, the services of commercial fishermen must be utilized. This fact eliminates one argument used by many recreational fishermen that commercial fishermen should be denied access to the resource. What, then, is an equitable basis for allocation? Should a decision be based on the economic value contributed by the recreational and commercial sectors, or should the allocation be decided on other factors such as sociological or dietary benefits? There are no easy answers to these questions.

Another difficult question is whether commercial fishermen should be denied access to certain fish species. For example, one of Virginia’s largest commercial fisheries is menhaden. The fish is primarily processed into two products, oil and meal. The United States Food and Drug Administration approved fish oil in 1997 for use in human food products, although the oil has been used in European and other countries for many years. Fish meal is a major component of aquaculture feeds and poultry rations. In fact, it currently comprises from 20 to over 40 percent of aquaculture feeds, depending on the species being cultured. A restriction on fish meal production will have drastic consequences for the aquaculture industry, which is the fastest growing component of agriculture. One estimate indicates that 100 percent of the current fish meal production will be required to satisfy the aquaculture industry by 2011. Recreational fishermen have also expressed concern that the harvest of menhaden removes an important source of food required by other fish species, such as bluefish. Some states have succumbed to local pressures to prohibit menhaden fishing in their waters even though fish meal may be an important commodity for their agricultural industries. There has been no scientific evidence indicating that the current commercial menhaden fishery has seriously impacted the wild stocks. In fact, rock-fish (striped bass) and croaker have recently returned to the Chesapeake Bay in greater numbers than previous years. Rather, over-fishing by both recreational and commercial fishermen, habitat destruction, and pollution may be major contributors to the decline of some wild stocks.

Since menhaden vessels are the largest fishing vessels operating on the Gulf and Atlantic coasts and the fish are primarily caught within five miles of shore, the tourist industry also has expressed a desire to restrict menhaden fishing in some areas. The menhaden industry has voluntarily placed restrictions on its fishing operations, but this has not been acceptable to those wanting greater control. Both sides are engaged in discussions and hope that an acceptable compromise can be reached. The elimination of fishing vessels from near-shore will not be an acceptable solution.It seems that each year a health-related crisis arises involving our fish and shellfish supply. One of the first health issues to appear was methyl mercury in certain fish species, particularly swordfish, shark, and tuna. This concern was quickly followed by the pesticide DDT and its degradation products, then PCBs (polychlorinated biphenyls), dioxins, and Kepone. More recently, a question surfaced on the health significance of PANOs (poly- aromatic nucleated hydrocarbons), which result from the degradation of petroleum products. Questions on potential chemical contamination arose for several reasons. First, improved chemical analytical instrumentation has enabled detection of chemical compounds at very low levels, in some cases less than one part per billion or parts per trillion. Second, since the media announced that the compounds are toxic to humans, consumers have become justifiably concerned about the potential danger posed by the contaminants.

Once specific questions on the safety of fish and shellfish supplies were raised, the scientific community could not deliver an immediate response to the questions because the assessment of risk could not be adequately defined. Risk assignment is difficult--if not impossible--to determine for each chemical under scrutiny. Consumers have different dietary habits and live in differing geographical areas, and it is difficult to determine how each food component may contribute to an individual’s health or illness. Also, questions such as Should the health or safety issues associated with seafood consumption in subsistence fishermen or individuals consuming large quantities of fish and shellfish be assigned to an entire population? need to be answered. Other questions that further complicate the assignment of risk are variables in individual responses to toxicity and the effect of age, sex, and physical state. Children’s health differs from adults; pregnant and lactating women have special health concerns different from those of the general population. It is also known that many health issues arising from chemical contamination, e.g., cancer, have effects that will not surface for many years.

The inability to provide consumers with definite answers, or answers in a timely manner, on chemical contamination created an opportunity for special interest groups to obtain recognition and have their causes nationally presented irrespective of the facts. Consumers were warned by some groups not to eat fish or shellfish harvested from certain waters. Other groups questioned whether any fish or shellfish products were safe for consumption, while yet others cautioned against the consumption of specific fish and shellfish species. The purposes of the groups differed. Some groups were genuinely concerned with health and safety; others had specific agendas, such as increases in organizational membership or the ability to obtain increased financial support. Health questions related to seafood consumption have always been able to surface faster than health answers.

While the issues related to chemical contamination have subsided in recent years, they have not disappeared. The FDA has established a 1.0 ppm (parts per million) action level for methyl mercury in seafood, and the agency is currently re-evaluating its action level in light of significant new data on the health effects of methyl mercury from fish consumption that has become available since the action level was developed. The FDA’s response will prevail since there are no identified committed resources by Virginia or other states to provide an independent response. It is highly possible that a reduction in the action level will result in serious consequences for Virginia dealers marketing such fish species as mackerel, shark, tuna, and swordfish.

While the 1970s and 1980s focused primarily on chemical contamination of fish and shellfish, the 1990s may become known as the decade of microbiological concerns. The first issue to arise questioned the safety of molluscan shellfish, specifically the consumption of raw oysters due to the presence of Vibrio vulnificus. The V. vulnificus issue is interesting because individuals who contracted the disease from eating raw or partially cooked oysters were pre-disposed to the microorganism’s infection due to AIDS, hepatitis, diabetes cirrhosis of the liver, renal and heart transplants, or consumption of immunosuppressant chemotherapeutics. The number of deaths resulting from V. vulnificus is relatively low, ranging from 6 to 50 annually. It has been suggested that many of the individuals who have died would have expired within a short period as a consequence of an underlying illness or compromised physiological condition. To date, no deaths have occurred from shellfish harvested from Virginia waters despite the large number of oysters marketed. A national public awareness program was initiated by the FDA with cooperation from state health agencies that included providing materials to physicians, retail food establishments, food editors, and dietitians. The program initially received limited financial support and current activities have been substantially reduced. No plans have been announced by any federal or state agency on whether or how the program may continue into the future. This quick-fix approach to food safety has not been effective, and it will not solve future problems, but it continues to be the preferred solution by government.

Another problem affecting fisheries is the rapid response by federal agencies to emerging food safety issues without consideration of possible long-term consequences. One example is the FDA reaction to Listeria monocytogenes outbreaks associated with milk and soft cheeses. Immediately after the outbreaks, the FDA established a zero tolerance for the microorganism in all ready-to-eat food products. Surveys conducted by the FDA and research organizations showed that the organism was present in 8 to 10 percent of all ready-to-eat seafood. Despite the fact that all Listeria monocytogenes organisms are not pathogenic and no cases have been reported from seafood consumption, the tolerance was, nevertheless, imposed on seafood. The zero tolerance resulted in the recall of seafood products, and legal action was taken against several Virginia dealers. Research has shown that the organism has historically been present in seafood and occurs in relatively low numbers when acceptable sanitation practices are followed. Surveys have also shown that the organism is present in many home refrigerators. Officials of the Centers of Disease Control (CDC) were requested in May 1996 to conduct a survey of home refrigerators to determine the presence and health significance of the microorganism. The purpose of the survey was to provide greater in-sight into the necessity of maintaining the zero tolerance. One year later, the study still has not commenced. Two conclusions may be drawn from the CDC action. First, the study could show that the zero tolerance is inappropriate, and second, the CDC knows the microorganism is not the reported public health problem perceived and, therefore, the study is not needed.

It is interesting that Canada and the European community have established tolerances for Listeria monocytogenes in various food products depending on the associated risk. The standard for seafood is 100 organisms per gram, provided good manufacturing practices (GMPs) are followed by the firm. No apparent reason for the failure of the United States to consider this approach has been given. Unless some action is taken, almost all seafood firms producing ready-to-eat products are at risk for litigation in the federal court system, perhaps unjustifiably.

The issues associated with microbiological contamination of food products are often given great emphasis by consumer groups to attract attention for their personal benefit. For example, a poster depicting medical devices, such as syringes, washing onto the New Jersey shore asked the question, “Was your seafood obtained from safe water?” The poster conveniently contained the name of an organization requesting financial support in its efforts to ensure that seafood was safe and did not contain infectious diseases. The poster was highly effective in attracting public attention, but only limited attention was given to the fact that medical devices, including syringes, dumped into the ocean would not result in human disease.

Another emerging problem is the presence and significance of biogenic amines, particularly histamine, cadaverine, and putrescine, in some fish species. Fish identified by the FDA as capable of producing toxic levels of the compounds include amberjack, bluefish, bonito, tuna, river and sea herring, mackerel, mahi-mahi, shad, and shad roe. After December 18, 1997, the FDA will require that fishermen and processors who handle these species develop a HACCP (Hazard Analysis Critical Control Points) program to prevent toxic fish from reaching the consumer. The FDA has recommended these fish species be chilled to 50 degrees Fahrenheit (F) within six hours post-mortem and to 40 degrees F within an additional 18 hours and the fish maintained at 40 degrees F thereafter. Also, a sensory analysis must be performed on 118 fish or, if smaller, the entire lot. The recommendations also cover temperatures during different delivery strategies. Fishing vessels will have to keep records on the method of capture, time of landing, time of death, method of cooling, time cooling began, cooling rate, decomposition in the lot, and the internal temperature of a representative number of fish at delivery.

In the absence of these records or if one of the limits is violated, two options are available: destroy the fish or chemically analyze 60 fish--or the entire lot if it contains less than 60 fish--for the presence of histamine, and reject any fish containing 50 ppm histamine or greater. There are several major concerns with these policies. First, many fish are caught in gill nets or long lines where the time of death cannot be determined. Consequently, either the fish must be destroyed or a chemical analysis performed. Examining 60 fish analytically is expensive, and the number of fish that may be destroyed or reduced in value due to the sampling may be large. Depending on the required analytical methodology, substantial time may be required, resulting in fish being frozen to maintain quality. For some markets, a frozen fish has a significantly reduced market value.

The purpose of the HACCP legislation was to prevent illnesses that were reasonably likely to occur. However, some of the fish species affected by the above requirements have been implicated in only a few cases of illness world wide. In the opinion of many scientists, the government has not provided sufficient justification for its rigid requirements. There is every reason to believe that fishermen and processors will not abide by the regulation, thereby subjecting them to both criminal and civil prosecution in the federal courts.

As Virginia’s fishery gradually changes from a capture to a cultured industry, significant capital will be required to accommodate the change. Most of the current firms do not have the independent ability to develop required business plans and may lack the technical ability to supervise the type of aquaculture operations suitable for Virginia. Education, research, information transfer, and access to capital are required for the successful transition. Unless such programs and initiated action are taken in the immediate future, seafood imports will continue to increase and Virginia’s seafood industry will began to shrink. The economic impacts may have greater consequences than the costs required to effect the change.

WHAT IS NEEDED

    Policy makers can take several actions to lower the impact of these changes on the seafood industry:

    Resource access and allocation: A plan for Virginia’s fish and shellfish resources needs to be developed that considers the concerns and needs of both coastal and non-coastal citizens.

    Policy for industrial fisheries: The importance of the menhaden fishery to Virginia’s food production industries needs to be identified and action taken to ensure the continuance of the fishery’s use.

    Cooperation with the United States Congress: The Virginia legislature needs to identify the impact of federal regulations on the various commercial fisheries and ensure that scientific and technical input is provided when appropriate.

    Public information: State agencies should develop a coordinated program to ensure that accurate and continuous information on seafood safety issues is available to consumers.

    Financial resources: Assistance is needed for fish and shellfish firms to obtain capital for developing new business strategies, adopting new technology, and implementing production systems that reduce dependence on the wild harvest. A program for low-cost loans or economic incentives provided through a program similar to that currently used to attract new industries should be immediately implemented.

    Aquaculture needs: A comprehensive review of state regulations affecting aquaculture should be initiated to ensure continued growth and profitability of the industry. The impact of coastal development on Virginia’s emerging mollusk aquaculture industry may require legislative attention that considers both parochial and state needs to ensure continuance of the industry. The enactment of environmental regulations and policies need to be thoroughly evaluated prior to implementation to ensure that unnecessary financial burdens are not incurred by aquaculture producers.


George J. Flick, Jr., is a University Distinguished Professor of food science and technology at Virginia Tech and coordinator of the university’s Virginia Sea Grant Marine Advisory Program. He helps the seafood industry with food safety issues and provides seafood advisory services through the CFAST program, a multi-disciplinary effort to help Virginia’s fisheries industry prosper and compete in a global economy. In September he was honored by Vice President Al Gore for his work as a founding member of the National Seafood HACCP (Hazard Analysis Critical Control Points) Alliance.

COAST SENSE

    • Nationally, about 110 million people--almost half the total population--live in coastal areas.
    • Nonpoint source pollution accounts for over one-half of the nation’s water pollution.
    • When the nation was settled by Europeans, 215 million acres of wetlands existed in the continental United States. By the mid-1970s, 99 million acres remained, or 46 percent of the original acres.
    • An average of 440,000 acres of freshwater marsh, bob, and swamp is lost to development every year. This loss equals a land area roughly half the size of Rhode Island.
    • Wetland draining for agriculture accounts for 87 percent of the yearly wetland loss; fill for residential housing, industry, and commercial facilities consumes the rest.
    • About 37 percent of commercial shellfish beds in estuaries--the Chesapeake Bay is one of the largest in the world--are closed or subject to harvest restriction, often because of pollution from sewage treatment plants, septic systems, and urban runoff.
    • More than 705 commercially important fish and shellfish species depend on coast habitats. The combined commercial and recreational catch of these species contributes over $40 billion a year to the U.S. economy.
    Source: NOAA’s Coastal Service Center, Charleston, S.C.

VIRGINIA SEA GRANT: WHAT IS IT?

    The Virginia Sea Grant College Program helps to keep the fisheries industry alive in Virginia and protects the commonwealth’s coastal resources.

    Thirty states in America--any state with a coast or Great Lake--receive funding for this program, which comes under the National Oceanic and Atmospheric Administration (NOAA) of the U.S. Department of Commerce. Essentially, the program has ties with universities and carries out marine research, education, and advisory activities. It promotes the sustainable use and management of our nation’s marine resources.

    Partners include industry and various government entities. In Virginia, Virginia Tech, the University of Virginia, the College of William and Mary, and Virginia State University participate in the state’s Sea Grant consortium.

    Since the population of the Chesapeake Bay watershed will probably double by the year 2000, Sea Grant faces an immense challenge in helping to preserve the integrity of the commonwealth’s 5,000 miles of Chesapeake Bay and Atlantic Ocean shorelines.

    Virginia Tech, using laboratory facilities in Hampton, focuses on helping the seafood industry. Researchers assist seafood processors with modern methods that are safe and profitable, find ways for those companies to dispose of wastes in an environmentally sound manner, keep Virginia seafood businesses globally competitive, and lead the way in aquaculture.

    For information on Sea Grant, call George Flick at 540/231-6965.
    -- Lynn Davis, Sea Grant

FALL 97 VIA