1998N-0359 - Program Priorities in the Center for Food Safety and Applied Nurtrition; Request for Comments
FDA Comment Number : EC101
Submitter : Mr. Gerald Dalton Date & Time: 07/28/2004 05:07:46
Organization : American Citizen/Food purchaser
Food Industry
Category :
Issue Areas/Comments
Shrimp is currently the number one seafood choice for American
consumers. Approximately 80% 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 on coastal farms for exportation to the United States.
Chloramphenicol is linked to human aplastic anemia, intestinal
problems, and neurological reactions; while nitrofurons have been found
to be carcinogenic. Both are widely used to produce shrimp, but both are
also banned in the United States.

Even the House Committee on Appropriations has focused on the public
health concerns surrounding imported shrimp. The recent House Report
108-584, which accompanied the Agriculture, Rural Development, Food and
Drug Administration, and Related Agencies appropriations bill - H.R.
4766, stated:

"The Committee continues to have serious concerns regarding seafood
safety issues posed by banned antibiotic contamination in farm-raised
shrimp imports. The Committee recommends that the FDA, in cooperation
with any state testing programs, continue testing of farm-raised shrimp
imports for chloramphenicol and other related harmful antibiotics used
in the aquaculture industry and ensure that any adulterated shrimp that
tests positive for chloramphenicol or other banned antibiotics will be
destroyed or exported from the United States."

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

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,

Gerald J Dalton