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D. L. ARCHER, Dept. of Food Science & Human Nutrition, Univ. of Florida, 433-A Food Science & Human Nutrition Bldg., PO Box 110370, Gainesville, FL 32611-0370 Shrimp are regulated by the US Food and Drug Administration (FDA). Under the Federal Food Drug and Cosmetic Act (FFDCA), Interpretation of the adulteration provisions of the FFDCA has historically been carried out on a case-by-case basis, and the courts have traditionally given FDA tremendous latitude in its interpretation of those statutory provisions. Several of the adulteration provisions are used to regulate shrimp depending on the problem FDA finds. FDA’s policy on the presence of Salmonella in ready-to-eat foods is clear, in that the food “contains a poisonous or deleterious substance” [FFDCA 402(a)(1)]. FDA has also applied this provision of the FFDCA to uncooked shrimp, and this has been a cause of friction between the agency and the shrimp industry, as in general, application of the “(a)(1)” provision leads to a class I product recall. The controversy is fueled in part by what the industry feels is unequal treatment of uncooked shrimp versus other uncooked commodities such as game birds or raw fish fillets. The presence of Salmonella on those items does not trigger the 402(a)(1) provision of FFDCA, since there is the reasonable presumption that the product will be cooked and any pathogens destroyed. Additionally, there are other, and potentially more lethal pathogens that do not trigger 402(a)(1) when present on uncooked commodities that are traditionally cooked before being consumed. Both domestic and imported shrimp are important to the US economy, and as such, resolving the conflict over the “zero tolerance” policy is desirable. Perhaps that will not be possible without a risk assessment based on scientific studies of the prevalence of Salmonella on shrimp in the wild, as well as post-harvest. uncooked shrimp.
Session 92, Zero tolerance and control of seafood safety
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