1998N-0359 - Program Priorities in the Center for Food Safety and Applied Nurtrition; Request for Comments
FDA Comment Number : EC159
Submitter : Ms. Christina Cat Date & Time: 08/10/2004 06:08:31
Organization : Weston Price Foundation
Individual Consumer
Category :
Issue Areas/Comments
GENERAL
GENERAL
To: Division of Dockets Management (HFA-305)

Re: Program Priorities in the CFSAN, Request for Comments.
Docket No. 1998N-0359

I am writing to provide input on the program priorities for the
Center
for Food Safety and Applied Nutrition (CFSAN) for fiscal year (FY)
2005.
Public health concerns exist concerning imported farm raised shrimp;
and
therefore, I recommend that the Food and Drug Administration should
prioritize inspections of imported shrimp for FY 2005.

Approximately 80 percent of the shrimp consumed in the United States
is
imported, over half of which is farmed raised. Some chemicals, such
as
chloramphenicol and nitrofurons, are used around the world to raise
shrimp in coastal farms for exportation to the United States.
Chloramphenicol is linked to human aplastic anemia, intestinal
problems,
and neurological reactions; nitrofurons have been found to be
carcinogenic. As you know, these chemicals are actually banned by
FDA.

Imported shrimp inspections fall under the FY 2004 workplan, and
should
be included in the FY 2005 workplan as well. Imported shrimp
inspections uphold the FDA's domestic health standards, as well as
ensure international compliance with U.S. food safety rules. In
order
to
guarantee that imported shrimp is safe for American consumers and
that
it adheres to the current FDA guidelines on chemical usage in foods,
shrimp inspection should be a priority, and placed on the FDA CFSAN
"A-list" for FY 2005.

I urge the FDA to recognize its mandate of ensuring a safe food
supply
by prioritizing imported shrimp inspections and taking the following
steps:

1. For one year, inspect 100% of shrimp imported into the United
States
for banned chemicals, such as chloramphenicol and nitrofurons. This
will
allow the FDA to better understand the extent of the problem.

2. Once the year of 100% testing is complete, the agency should
devise
a testing program for imported farm raised shrimp that is based on
the
prevalence of banned chemicals found during the total testing period.

3. If shrimp entering the U.S. is detected with residues of banned
chemicals, the contaminated shrimp must be destroyed, rather than
dumped
back on consumers in the country of origin or used in animal feed.

Sincerely Yours,