Docket Management
Docket: 01N-0284 - Import Tolerances
Comment Number: EC -4

Accepted - Volume 1

Comment Record
Commentor Ms. anne mosness Date/Time 2002-03-11 00:20:55
Organization institute for agriculture and trade policy
Category Consumer Group

Comments for FDA General
1. General Comments I urge the FDA to undertake immediate and extensive analysis of imported seafoods for drug residues, particularly salmon from Chile, Canada, Scotland and other countries where fish farms have received subsidies, and hence might be subjected to less governmental scrutiny and regulation. There is a human tendency to overuse pesticides and medications when there is little chance of being discovered, and crowded conditions in fish farms provide an opportunity for diseases and parasitic infestations to spread and amplify. There is illegal and underreported usage of chemicals in the production of salmon in Scotland, and I have collected reports since attending an aquaculture conference in western Scotland last October. Further, language differences in some regions between owners and workers in fish farms make it even more crucial that the FDA do adequate testing, since it would be comparatively easy for miscalculations to be made in treatments, and misreading of instructions. For example, hundreds of Chilean farms are located in extremely remote locations, with little oversight. As citizens, we are reliant on a strong FDA to analyze foods that come into this country, and particularly foods that are produced in feedlot conditions. I strongly urge that drug residue levels remain at zero, and that exceptions are not written into US law. When any information becomes available from independent testing facilities on drug residues in farmed fish, I hope that the FDA takes immediate steps to stop all importation of the suspect products, and removes other batches from retail establishment. The FDA labeling regulation on color additives in farmed salmon also needs to be enforced. I urge the FDA to immediately begin to educate retailers and public that farmed salmon must be accurately labeled, since there are reports of consumers who are chemically sensitive becoming ill from eating farmed salmon. I will be interested in commenting on the full rules that FDA proposes on imported seafood, and wish to be placed on a mailing list to receive notice of further comments periods for public input. Thank you.

EC -4