environmental implications of the safety and fraud...

T h e S a f e t y a n d F r a u d E n f o r c e m e n t f o r S e a f o o d A c t o f 2 0 1 3

Environmental implications of the Safety and Fraud Enforcement for Seafood Act of 2013

Columbia University, School of International and Public Affairs Master of Public Administration in Environmental Science and Policy Workshop in Applied Earth Systems Management, Summer 2013


Final Report Columbia University, School of International and Public Affairs Summer Workshop in Applied Earth Systems Management Team Manager and Deputy Manager Kelsey Watts-FitzGerald and Mika Maekawa

Team Members Anshana Arora, Bridget Hardy, Brittany Holewinski, Asha Kreiling, Ding Lu, Kimberly Palacios, Arielle Shapiro, Jillian Theibert

Faculty Advisor Dr. Matthew Palmer

Disclaimer This document includes copyrighted material for educational purposes. These materials are included under the fair use exemption of U.S. Copyright Law and are restricted from further use.

This document has been prepared on an “All Care and No Responsibility” basis. Neither the authors nor Columbia University make any express or implied representation or warranty as to the currency, accuracy, or completeness of the information in this document.

Cover page image courtesy of LCDR Eric Johnson, NOAA Corps – NOAA Photo Library


Executive Summary Pervasive mislabeling, poor documentation, and inadequate government regulations in

the seafood industry have been brought to the attention of the American public in recent years by

several nationwide studies of seafood in markets and restaurants. Seafood fraud has been

identified as a widespread phenomenon that has complex economic, public health, and

environmental implications. In response to the issues associated with seafood fraud, Senator Ed

Markey introduced the House Bill 1012, the Safety and Fraud Enforcement for Seafood Act,

commonly known as the SAFE Seafood Act, in March 2013. The proposed legislation is

designed to improve the safety of the seafood supply and prevent seafood fraud, primarily in the

form of mislabeling.

This document provides an analysis of the issues surrounding seafood fraud and how the

SAFE Seafood addresses these issues. We discuss the direct and indirect effects of mislabeling

on public health and fishery management, the scientific and technical aspects behind both the

environmental problem and the proposed solution, controversies associated with the bill, the

expected outcomes, and methods for measuring success.

We conclude that, by means of the bill’s stipulations for interagency cooperation between

the FDA and NOAA, as well as improved traceability and transparency in the seafood industry,

the SAFE Seafood Act will help to mitigate seafood fraud, and will have positive effects on

broader economic, public health, and environmental systems.


Table of Contents Executive Summary ................................................................................................. 3

Introduction .............................................................................................................. 6

Current regulations and inspection methods ........................................................ 7

Seafood fraud - a definition of the problem .......................................................... 8

How fraud impacts the environment ..................................................................... 9

Managing fisheries ............................................................................................ 10

Risk to public health .............................................................................................. 12

Market forces ..................................................................................................... 14

Legislation (The SAFE Seafood Act) ................................................................... 15

Standardized naming & labeling ....................................................................... 15

Increased cooperation and inspections ................................................................ 16

Advantages of the proposed solutions .................................................................. 17

The science behind the solution ............................................................................ 18

Challenges in implementing the solutions ........................................................... 21

Controversies .......................................................................................................... 22

Measuring success .................................................................................................. 24

Case study: gag grouper .......................................................................................... 29

Conclusion ............................................................................................................... 31

References ............................................................................................................... 33


Acronyms and Abbreviations

Commerce: Department of Commerce

HHS: Department of Human Health Services

FDA: Food and Drug Administration

NOAA: National Oceanic and Atmospheric Administration

SAFE Seafood Act: Safety and Fraud Enforcement for Seafood Act

PREDICT: Predictive Risk-based Evaluation for Dynamic Import Compliance Targeting

NMFS: National Marine Fisheries Service


Introduction Many types of marine fish, along with other marine organisms, are experiencing the

threat of catastrophic decline from overfishing and other forms of ecosystem degradation. In

addition to direct threats from overharvest and environmental change, seafood fraud through

mislabeling creates a challenge to successful fisheries management, due to inaccurate data

resulting from this fraud. Fish are a vital source of protein for much of the world’s population.

Since the seafood market is such a large and potentially lucrative industry, with revenues of

approximately $2 billion in the United States in 2012, it is unsurprising that the management

limits required to maintain sustainable fisheries have been challenged by the economic incentive

to harvest more fish (McBee, 2013). The global nature of the seafood industry is apparent when

one considers the fact that Americans import 84% of their seafood (Oceana, 2012). The problem

of overfishing has become so widespread that an estimated 28-33% of global fish stocks are

overexploited and 7-13% stocks have collapsed (Branch et al., 2011). By importing the majority

of their seafood, the U.S. is increasing market demand for seafood products, including those

from overexploited and exhausted fisheries.

Seattle’s Pike Place Fish Market shows the diversity of demand for seafood products in the United States. Image courtesy of Sharat Ganapti.


Fish occupy an important role in the natural functioning of marine ecosystems. Fish serve

as prey for organisms higher up on the food chain and control the populations of their prey items.

They also cycle nutrients throughout the ecosystem by consuming and being consumed, by

releasing their waste products, and from decomposition upon death. By diminishing and, at

times, entirely removing these links through overharvesting, biodiversity is lost and the

ecosystem no longer functions as it has historically (UN FAO, 2013). Later in this analysis, case

studies of this process will be discussed.

The recovery of such fish populations and associated fisheries relies on scientifically

sound management plans, based on the modeling of fish populations and appropriate

policies. Approximately 90% of the world’s fish are caught within national, rather than

international, waters. This enables governments to impose rules and regulations to effect change

in the way humans alter fish populations (A Rising Tide, 2008). Regardless, part of the difficulty

in management rests in the inability to accurately count mobile organisms like fish. The Food

and Agriculture Organization (FAO) of the United Nations proposes several ways to manage

fisheries sustainably, but governments do not always implement these recommendations (UN

FAO, 2013). While some nations have recognized the need for sustainable fisheries, many have

allowed lucrative but highly exploitative fishing, both legal and illegal, to continue. While lax

regulations can be corrected with responsive policy action, the problem of fraud in the seafood

industry is a systemic issue that cannot be easily confronted.

Current regulations and inspection methods Current inspection techniques employed by the National Oceanic and Atmospheric

Administration (NOAA) include checking seafood for color, taste, weight, and smell (Fishwatch:

U.S. Seafood Facts, n.d.). These methods rely heavily on sensory analysis from the use of the

inspector’s highly trained nose and taste buds. They are able to detect the freshness of fish by

knowing what certain species smell like when they have begun to spoil. Inspectors also have the

capability to detect up to 0.5 ppm of oil in seafood on a consistent basis, ten times the level of

sensitivity of an average person (Wilson, 2012). If the Food and Drug Administration (FDA)

does discover fish fraud, it has the authority to seize seafood, and – in extreme cases - prevent

businesses from importing fish (US FDA, n.d.).


Seafood fraud—a definition of the problem The inadequacy of current regulations was highlighted recently in a national study by

Oceana, which described serious mislabeling of seafood and other instances of seafood fraud in

American markets (Oceana, 2012).

The study found that one-third of all analyzed samples were mislabeled. Of particular

concern were the species with health advisories that were marketed and sold as other species, an

error that could have negative health consequences for high risk groups like pregnant women and

children.

Mislabeled fish in the marketplace can potentially threaten human health if the consumer is

unaware of toxins that may be present in the fish. In 2007, NOAA handled a case where a

Florida business illegally imported several hundred thousand pounds of fillets by labeling them

as grouper. The fish were eventually identified as Vietnamese catfish and were also found to be

The table above lists seafood popular in restaurants and markets and also commonly mislabeled, here their fraudulent counterpart is included. Source: ACGT, Inc., SeafoodID.


contaminated with Enrofloxin, a food additive banned in the United States (NOAA, 2012,

December 14). This is but one example of the types of toxins that could unknowingly be

consumed as a result of fraudulently labeled fish. Pervasive mislabeling of seafood products in

the United States also has the possibility to negatively impact the management of fish stocks

worldwide, not only by potentially masking evidence of overharvest, but by compromising the

data used to determine management targets. The proper management of fisheries relies heavily

on accurate scientific information supplied by regulators, fishermen and other key stakeholders.

Since fish populations cannot be directly counted, fishery scientists use sampling and modeling

techniques to estimate population size and structure. These data rely on catch information

(Fishwatch: U.S. Seafood Facts, n.d.). The mislabeling of seafood distorts these data and can

result in faulty estimates of populations which would result in inappropriately high catch limits

for the future, further deteriorating the population.

How fraud impacts the environment While the focus of the impact of fraud is often on economic and public health

consequences, the ecological problems associated with mislabeling are extensive. The SAFE

The table above shows potential profit for fraudulent seafood sales. Those who stand to gain include fishermen, processors, wholesalers, restaurateurs, and retailers; those who lose are consumers. Source: FDA.


Seafood Act is, in effect, a consumer protection bill, which seeks to restore consumer confidence

in the seafood market after recent reports by Oceana (2012) and National Public Radio (2013)

which reported about one-third of all seafood sold in restaurants and markets as mislabeled.

Malicious intent or not, that number is startling. It grows even larger with several types of

seafood commonly found in restaurants like red snapper, Chilean seabass, or grouper, all of

which were found to be mislabeled up to 77% of the time (Oceana, 2012).

Improved and increased inspection and transparency not only improve consumer safety

and accuracy in seafood markets, but can alleviate some of the negative environmental impacts

on marine ecosystems. There are, however, some independent programs that are working to

bring transparency back into the market on a voluntary basis. Gulf Wild uses its

“TransparenSea” program to allow consumers to trace the origins of their seafood (About Gulf

Wild, n.d.). By placing tags on their fish, each having a unique number, participating fishermen

allow consumers and other interested parties to look up the product’s number in their database

and obtain further information. This includes a photo and information about the fishermen who

caught the fish and a map of where and when the fish was caught (NOAA, 2013, April 1).

Managing fisheries Even without the extensive seafood fraud seen today, managing fish populations is a

challenge when trying to account for the delicate balance between maintaining healthy

populations and allowing for enough catch to meet demand and support fishing enterprises.

Already, the ecological damages resulting from the depletion of fish stocks are apparent.

Exploitation of fisheries has greatly altered the abundance of ocean species, especially large

predators at higher trophic levels. Ecological research has shown that changes in predator

abundance can trigger shifts in population abundance of component species (Paine, 1980; Duffy,

2002). In an example of a trophic cascade, a reduction in top predators such as dolphin and

Bluefin tuna decreases predatory consumption and leads to increased biomass of planktivorous

fish (Daskalov 2002). The abundant planktivorous fish consequently consume more zooplankton,

thereby reducing grazing pressure on phytoplankton and ultimately causing an increase in

phytoplankton biomass (Daskalov, 2002). This spike in phytoplankton biomass leads to increases

in water turbidity and declines in surface ocean nutrient levels. In other words, the effects of


altered top predator abundance resonate throughout the entire system and manifests at the

primary production level.

An example of this effect can be seen in the Northwest Atlantic cod fishery, where the

collapse of the cod population was so severe that it prompted the implementation of protective

legislation. Without predation from cod, prey species such as the northern snow crab

experienced rapid population growth. The snow crab’s food source, zooplankton decreased;

phytoplankton populations increased; and nitrate concentrations, a major limiting resource for

marine life, decreased as a result (Whitty, 2011). This cascade of unintended consequences

began with the removal of cod from the northern Atlantic and led to a ban of cod fishing in 1993;

the cod population, however, has not been able to recover in size or function, as adults of the

species are now much smaller in weight and length than pre-collapse adults (Whitty, 2011).

Top predators also impose a strong influence on prey behaviors, such as foraging and

migration routes (Lima, 1990). A recent decline in eleven large shark populations was

associated with an increase in smaller shark and ray numbers, and also altered migration routes

of prey items (Myers, 2007). Historically, cownose rays used a migration route away from the

coastal regions in an effort to avoid predation by sharks. Without the predators, cownose rays

migrate closer to the coast and exploit the abundant food resources in this area, resulting in a

sharp decrease in bay scallop population (Myers, 2007). This example further highlights the

Example of a cod catch. Image courtesy of Derek Keats.


importance of top predators in a system, and how reduction in predatory consumption is coupled

with changes in prey behaviors.

Significant decreased abundance of a top predator has substantial effects on the

remaining species in a food web, as highlighted by our previous examples. The consequences of

change in top predator abundance can only be properly managed if we have accurate data to

predict the change in ecological structure in the first place. This is why proper labeling is a

critical aspect in the monitoring and management of global fisheries.

Risk to public health The bioaccumulation of toxins in

the tissues of certain fish is another

environmental problem related to

mislabeling. Artificial organic pollutants

(e.g., DDT, PCBs, and dioxins) as well as

toxic heavy metals (e.g., mercury, lead,

and arsenic) can be consumed by lower

trophic level fish. For example, mercury

pollution from coal-burning power plants

among other industrial activities is often

found in high concentrations in aquatic

environments (Wallace, 1971). In terms of

human health, highly toxic methylmercury

is of particular importance and is the only

form of mercury found in the flesh of fish

(Wallace, 1971). Methylmercury is an

organic compound with low water

solubility. It is, however, fat-soluble and

therefore accumulates in the fatty tissues of animals (Davis et al., 2002). Organisms low in the

food chain (e.g., zooplankton) consume relatively large amounts of methylmercury over their

lifetime and as a result it bioaccumulates in lower trophic levels. Just as small fish eat

Bilingual warning sign posted to warn the public against consuming toxin-rich white croaker, pointing to high levels of DDTs and PCBs. Image courtesy of Steve Terrell.


zooplankton, large fish eat small fish and top predators eat large fish, concentrating the mercury

as it makes its way up the food chain. Older, and therefore larger, top predator fish tend to

accumulate more toxins like methylmercury in their systems due to the longer exposure duration

over their lifetime (Davis et al., 2002). For example, leopard sharks in Southern California were

found to have median mercury concentrations well over established screening values (Davis et

al., 2002). Southern California has also instituted bans against consuming fat-heavy white

croaker, found to have median mercury levels that pose human health risks (Davis et al., 2002).

Mercury is toxic to fish as well as humans

and causes damage to endocrine, reproductive,

and immune systems (Colborn et al., 1993). In a

controlled lab environment, increased levels of

mercury were shown to have pathological effects

on populations of zooplankton and chum salmon

wherein important elements of copper (Cu) and

zinc (Zn) in the organisms’ tissues cells were

replaced with mercury (Brown et al., 1978).

These fish can serve as the exposure pathway

when humans consume fish with elevated levels

of contaminants. Inorganic mercury chemically

converted to methylmercury can cause health

issues such as decreased kidney function,

neurological damage, and delayed development

and cognitive changes in children which can result

in lower IQ levels (Clarkson, 1997). Prenatal

exposure to methylmercury has been shown to

cause fetal neurotoxicity, and fish high in mercury

have been found to be the main cause. More than

50% of the mercury in fish has been estimated to

be of industrial origin (Landrigan et al., 2007).

The U.S. Centers for Disease Control and

Prevention found that as many as 637,233

This image illustrates bioaccumulation or biomagnification of toxins as a toxin like DDT, of which the concentration we can see in parts per million as they increase on the right, travels up the trophic levels from zooplankton to Osprey. If we replace the Osprey with a human being, consuming 25ppm of DDT per large fish (like tuna) we eat, we can see how grave the dangers are for human health. Source: University of Southern California


children annually have cord blood mercury levels above those shown to affect IQ (Trasande et

al., 2005). The resulting diminished economic productivity is the major cost of methylmercury

toxicity, amounting to $8.7 billion annually (Trasande et al.., 2005). Toxicity in fish poses a

serious threat to human health. Without accurate data, fish sold in markets is not transparent and

jeopardizes consumer safety.

Market forces An often overlooked consequence of seafood fraud which impacts marine ecosystem

stability is the effect of fraud on the market. Due to mislabeling, it becomes difficult for

consumers to make an educated selection if they choose to buy only well-managed seafood

products. Under fair market conditions, consumers can influence supply by increasing demand or

paying a premium for sustainable seafood. When seafood in the market lacks reliable labeling,

consumers have a decreased capacity to influence supply, since they may unwittingly purchase

mislabeled and potentially unsustainable seafood products, perpetuating the cycle of fraud and

mismanagement.

The Seafood Watch Guide, created and distributed by Monterey Bay Aquarium, is a pocket-sized guide that aims to educate consumers so they may purchase “ocean-friendly seafood.” It is available for different regions and is also downloadable as an application on smartphones.


Legislation (The SAFE Seafood Act) As a response to the issues associated with seafood fraud, Senator Markey introduced

House Bill 1012, the Safety and Fraud Enforcement for Seafood Act (SAFE Seafood Act) near

the end of his tenure in the House of Representatives (HR 1012, 2013). This bill’s primary focus

is to address the economic and public health problems associated with seafood fraud. It indirectly

serves to ameliorate some environmental damages as well. The goal of the Act is to ensure

consumer safety and achieve accuracy in seafood markets through multiple mechanisms.

Standardized naming & labeling The first central aspect of the bill is the improved identification measures that would

create a unified naming system for seafood and, therefore, allow greater transparency in the

marketplace. The Secretary of Health and Human Services, with the assistance from the

Secretary of Commerce, would create and maintain the “Guide to Acceptable Market Names for

Seafood Sold in Interstate Commerce”. This list would contain standardized names for seafood

species to be used in distribution, marketing, and retail and would be made available for the

public on the websites of both the Department of Health and Human Services (HHS) and the

Department of Commerce (Commerce). It would clearly indicate for each species which name(s)

may be used to identify seafood throughout processing and sale, and would enumerate which

names are considered mislabels. This list would consider taxonomy, international laws and

customs, market information, and naming precedence. The list would also disclose consumption

advisory information of any species and would be updated annually. Private citizens may be

able to petition to amend the list for purposes of further clarification if they so desire in

accordance with the policies in place under the Secretary of Health and Human Services (HR

1012, 2013).

The bill also requires that certain information accompany seafood from catch to

consumption, including the following:


• UNFAO Major Fishing Area where

the fish was caught

• acceptable market and scientific name

• method of harvest

• gear types used

• date of catch

• weight or number

• treatment or processing methods

(especially if weight if affected)

• country of processing

• if the fish was farm-raised

If any shipment is lacking this information, it could be refused admittance and the exporter’s

ability to bring seafood shipments into US market in the future may be denied (HR 1012, 2013).

Increased cooperation and inspections An important aspect of this bill is that interagency cooperation would be increased

between the Food and Drug Administration (FDA) and National Oceanic and Atmospheric

Association (NOAA) since they have the most involvement in governing the importation of

seafood and ensuring the sustainability of fisheries (HR 1012, 2013). As of now, NOAA is

responsible for monitoring and managing fish stocks, conducting analytical tests on fishery

products, supplying seafood health information to the public and agencies, as well as the

monitoring of fishing vessels via seafood inspections (NOAA fisheries office of sustainable

fisheries, n.d.). They also play a key role in public education through the management of

FishWatch.gov, a major source of seafood industry information to the public (Combating

seafood fraud, n.d.). The FDA has additional roles related to the seafood industry. They operate a

mandatory safety program for all fish and fishery products which includes the development of

regulations and guidelines while maintaining “The Seafood List” and “The Regulatory Fish

A mock-up of a potential seafood facts label containing all required information under the SAFE Seafood Act.


Encyclopedia” (U.S. FDA, 2013). These resources are available to the public to aid in the

identification of seafood species but their use is not mandatory for labeling purposes.

The SAFE Seafood Act would require these agencies create a process to share inspection

data of seafood samples, processing facilities, and seafood retailers to avoid duplication and

maximize efficiency. The bill states that the NOAA Seafood Inspection Program would act as a

third-party auditor with the purpose of inspecting seafood. When published, the online list of

violators would increase as a result of NOAA having the power to impose civil penalties. NOAA

would list by country every importer to the U.S., and would track the timing, type, and frequency

of violations of Federal law for each exporter. The public attention to this list would discourage

fraudulent behavior. In addition to the publicly available database of violators, established and

maintained by the Commerce and HHS departments, the Secretary of Commerce would also

increase the number of inspections for both foreign and domestic seafood shipments, as much as

resources permit. They must ensure that the percentage of seafood shipments inspected each year

will not be lower than that of the previous year. Inspection tests for compliance with the FDA’s

Food Safety Modernization Act would also be incorporated in regards to seafood safety and

seafood fraud (HR 1012, 2013).

Under the SAFE Seafood Act, punitive action could be taken against violators and fines

could be imposed, in addition to the public violation notices. Perhaps more importantly, past

violators would be required to verify the authenticity of future products before reentering the

market (HR 1012, 2013).

Advantages of the proposed solutions The SAFE Seafood Act would result in a number of benefits for consumers and other

stakeholders in the seafood industry. Consumers would be able to save money by not overpaying

for purposely mislabeled, low-quality fish that exporters mark as higher quality products in order

to increase profit.


Consumers would avoid ingesting and

have reduced exposure to harmful toxins such

as methylmercury, which accumulates in

certain types of fish and could be unknowingly

ingested. The SAFE Seafood Act would also

facilitate fair competition between foreign and

domestic fishermen, since they would both be

subject to the same rules and inspections. This

would lead to reduced undercutting of honest

fishermen who do not participate in seafood

fraud. Marine ecosystems would be protected

through the transparency of fishery data in the

marketplace. Consumers who wish to purchase

more sustainably harvested food will have

more information and agency to do so with

these proposed labeling reforms and increased

transparency.

The science behind the solutions Although not explicitly discussed in the SAFE Seafood Act, perhaps the most valuable

resource in combating fraud associated with mislabeling is DNA testing and a comprehensive

database against which samples can be compared. The development of identification databases in

the US began with the Regulatory Fish Encyclopedia (US FDA, 2013; hereafter, RFE). The RFE

was developed for use by the FDA to identify 1700 finfish and shellfish, associating the

following data by species: market name(s) approved by the FDA, common name, scientific

The image to the left depicts several fish filets that are often mislabeled alongside the fraudulent fish filets as well as the cost disparity. Information and image courtesy of Oceana.


name, vernacular names for cross-reference, RFE isoelectric focusing (IEF) data, and several

high quality images of that fish in varying levels of processing (US FDA, 2013). The RFE

design allows the database to incorporate additional information and analytical tools as they

become available (US FDA, 2013). This ability to expand allowed the RFE to incorporate DNA

barcoding in 2007. The DNA barcodes were developed as part of the Barcode of Life (BOL)

initiative which seeks create an identification system for eukaryotes, based on short, unique gene

regions (US FDA, 2013).

The Fish Barcode of Life (FISH-BOL) is the branch of BOL seeking to develop barcodes

for all known species of fish. Once the FISH-BOL database is extensive enough, it “will enable a

fast, accurate, and cost-effective system for molecular identification” of the world’s fish.

Advances in DNA mapping have led collaboration efforts like BOL to undertake the mapping of

known fish species and make this library publicly available. BOL and similar projects in North

America, Europe, and Japan utilize combined barcode databases for comparison to samples.

Through these efforts, 30 percent of all chordates have been mapped (Fish barcode of life, n.d.).

These improved techniques of identification have the potential to contribute to FDA inspectors’

efforts to identify fraud and prevent fraudulent products from entering the market.

Although seafood can be identified by both protein and DNA analysis, DNA-based

methods present a number of advantages, including increased specificity, sensitivity, and

reliability with highly processed samples (Lenstra, 2003). However, traditional DNA analysis

often requires Polymerase Chain Reaction (PCR) equipment in a laboratory setting. The overall

Above are examples of the unique DNA barcodes for their respective fish species. Source: The Canadian Centre for DNA Barcoding.


inspection process can take days using traditional PCR methods (Lenstra, 2003).

A newer technology that uses a DNA chip has been introduced to the market

(Rasmussen, 2008). Like traditional DNA analysis, DNA chip technology is based on the

principle of DNA polymorphism, or genetic variation that naturally occurs as mutations in

genetic code. A DNA chip contains 60,000 or more different DNA sequences, called a DNA

probe (Rasmussen, 2008). Each probe is a section of single-stranded DNA about 20 nucleotides

in length, representing a unique genetic code. The sample DNA is then added to the chip. DNA

that is complementary to the probe will bind with the probe DNA while the other DNA strands

are washed away. Because each probe corresponds to a known genetic sequence, the genetic

code for the bound sample DNA can be determined. The chip is able to compare the unique

genetic combination of each sample against a species database to determine the species

represented by the sample (Rasmussen, 2008). Despite its portable size and quick results, the

DNA chip requires extensive development to distinguish each species, and the cost of such

research and development is often too burdensome for a single company. The only commercially

available DNA chip product for food inspections, called the FoodExpert-ID was launched in

France in 2004 by the biotech company BioMerieux. At the time, it was able to identify 33

species of vertebrates, including 15 fish species (Rasmussen, 2008). However, the product was

not sold in the United States and was discontinued in 2009 due to weak market demand.

At present, a DNA chip is commonly used for human cancer screening. The typical price

for a human DNA chip ranges from $800 to $1200, with an additional cost of $300 for reagents

per use. NOAA currently charges $215 per sample for species identification through the use of

the thin-layer polyacrylamide gel isoelectric focusing method. This service is offered through

their voluntary seafood inspection program which provides seafood inspection services on a per

sample basis (Hansen, 2013). Based on the prior information, though there are methods of

species identification currently in the market, it is not feasible for this type of analysis to occur in

the field at the point of inspection or in a timely manner. On the other hand, DNA chips have the

potential to fundamentally improve this situation due to their quick turnover time and high

reliability; however, this technology is currently limited by its high cost (Hansen, 2013). It is

likely that the cost and readiness of the chip to enter the market would significantly increase

inspection cost to a point that it is not economically feasible.


Challenges in implementing the solutions The SAFE Seafood Act would have multiple benefits to the seafood industry and

consumers – namely, the improved efficiency of safety and fraud inspections and the increased

transparency of seafood product and fraud offender information. However, the Act also presents

potential technical and economic challenges. In addition to increased costs associated with DNA

testing, additional costs would arise from the need to maintain the standardized list of seafood

names and improve NOAA-FDA coordination regarding inspections. Acquiring technical assets

to conduct inspections would likely increase costs as well. Because the bill does not allocate

additional funds for enforcement, consumers may bear these costs through increases in seafood

prices. Disparities in the availability of resources (i.e., inspection technology and personnel) and

enforcement procedures from state to state may also make management more challenging for

both agencies.

The history of coordination between the two agencies also raises some concern regarding

the effectiveness of future collaboration. The FDA and NOAA signed a Memorandum of

Understanding in October of 2009 that increased the working arrangements between the two

agencies and allowed for a discharge of responsibilities in regards to the inspection of fish and

fishery products (NOAA & FDA, 2009). Specifically, the FDA became responsible to notify the

National Marine Fisheries Service (NMFS) when they are taking regulatory action against a

fishery establishment. NMFS assumed responsibility to make sure their list of approved fish

processing establishments operate in accordance with FDA quality regulations. The

Memorandum also called for an increased sharing of information regarding inspections and the

establishment of inspection priorities. In the US Governmental Accountability Office’s 2013

High Risk Report, they cited federal oversight of food safety as a high priority. It was noted in

the report that “fragmented federal oversight of food safety has caused inconsistent oversight,

ineffective coordination, and inefficient use of resources” even after the Memorandum was

signed in 2009 (US GAO, 2013). Given this information, there is still room for improvement in

the coordination and increase of seafood safety that depends on the effective communication

between these two agencies.

The Act also has various complications regarding seafood identification that could

negatively affect the industry. The creation of one definitive list for seafood names could prove


to be a difficult task, as there are many names for certain fish and it may cause confusion for

consumers once it is implemented. There would also be additional costs for increasing

inspections of fish shipments that have not been accounted for within the bill. The legislation

does not identify a source of funding for these costs and states only that they would be added as

far as resources allow (HR 1012, 2013). Fishermen may also face increased labor costs as a

result of mandatory labeling and the requisite detailed tracking of seafood products. It is possible

that these actions would lead to increased costs in the marketplace that would be translated to

consumers.

Controversies There is a great deal of political tension surrounding the proposed addition of regulations

to the seafood industry; opponents to this bill include large companies in the restaurant industry s

well as the seafood processing industry. The rationale of the opponents of this bill is that the

added regulatory cost would outweigh the economic loss resulting from seafood mislabeling.

Such an argument is not new among food industry groups in their efforts to lobby against

labeling. In 2002, when the Farm Bill mandated that every meat product sold in the US be

accompanied by a label indicating the country of origin, a public interest organization found that

giant companies such as Wal-Mart and Tyson Food spent a total of $29.2 million lobbying

against the bill (Clemente et al., 2005). Both corporations claimed the costly segregation of

livestock, record-keeping, and new packaging would cost the industry $500 million in

compliance costs (Clemente et al., 2005). After the Farm Bill requiring this labeling went into

effect in 2009, the Government Accountability Office determined an actual cost to the industry

that was much lower than the industry’s claim, estimating it to be approximately $123 to $192

million (US GAO, 2013).

Industry stakeholders were concerned by the addition of “country of origin” labels to

meat packages. A Congressional Research Service report in 2013 suggests that the debate about

country of origin labeling was temporarily closed on this particular issue in 2009 when the Farm

Bill was finalized (Jurenas & Greene, 2013). However, it was reopened when the Mexican and

Canadian governments filed a complaint to the World Trade Organization (WTO), claiming the

country of origin labeling program was inconsistent with United States’ obligations under the


WTO agreement. Following this disagreement, the WTO’s Dispute Settlement Body Panel found

the labeling program to be “more trade restrictive than necessary” and that it placed imported

products in a less favorable position than domestic products (Jurenas & Greene, 2013). A WTO

arbitrator gave the United States until 2013 to comply with the final ruling, though the US will

still require country-of-origin labels on their meat products. The US government has been

resisted complying with the final ruling announced this year, leading to a series of lawsuits

against the USDA. This controversy highlights the difficulties in applying labels to foreign

markets.

The SAFE Seafood Act similarly seeks to provide thorough information to consumers on

the origin of their products (HR 1012, 2013). Thus, due to the similar natures of the mandates for

improved labeling under the SAFE Seafood Act and 2002 Farm Bill, it is reasonable to expect

that the SAFE Seafood Act will confront some of the same challenges from the seafood industry

as the 2002 Farm Bill.

According to the current Food and Drug Administration (FDA) Seafood List, there are 45

species that can be called “snapper” in the US (FDA, 2013). Under the SAFE Seafood Act, it is

ultimately the FDA’s responsibility to determine how to distinguish these 45 species in the

marketplace. Scientifically, each species is defined in biological terms such as genetic

distinctiveness, ecology, and common physical characteristics. On the other hand, average

seafood retailers and consumers often categorize seafood by taste and texture. An obvious

example would be that cod, haddock, and halibut are all referred to as “whitefish” in various

market situations due to similarities in taste and texture. In addition to the distinction between

scientific and market names, standardizing seafood names may also raise socio-cultural issues

regarding the correct names. For example, residents in a community might have been calling cod

“whitefish” in the market for generations, and it would be a cultural shock for the community if

the FDA forced the adoption of a different name. Additionally, a particular fish with a name in

one community may have a different name for the same fish in another community.


Measuring success A critical aspect in the analysis of any legislation is the measurement of its success. In

order to assess the success of the SAFE Seafood Act, one can analyze the four components of

performance measurement and management: inputs, work processes, outputs and overall

outcomes.

Inputs are all the physical, pecuniary, and time resources that go into a program that

contribute to the production and delivery of outputs. The inputs required of the SAFE Seafood

Act include personnel and staff time by NOAA and the FDA to conduct inspections of domestic

and imported seafood as well as the facilities that would be processing and selling seafood. It is

likely that increased training of inspectors would also be necessary. The facilities, equipment,

and funding required to conduct inspections, such as for DNA testing, would be essential inputs

of the SAFE program.

However, inputs to the SAFE Seafood Act program are not limited to government or

regulatory inputs; efforts of the fishermen, seafood processors and retailers to comply with the

Examples of 4 different fish that can be marketed as “snapper” under FDA guidelines. Clockwise from top left: Blackfin snapper, Lane snapper, Red snapper, Vermillion snapper. Image courtesy of SEFSC Pascagoula Laboratory; Collection of Brandi Noble, NOAA/NMFS/SEFSC


stipulations of the bill, specifically, the expense of extra time for better record keeping, are also

necessary inputs and should not be underestimated in its assessment.

Work processes are the activities that utilize the range of inputs to produce the desired

outputs and outcomes of a program. The primary work processes of the SAFE Seafood Act

program are concerned with detecting fraud via inspections, labeling seafood products, and

public outreach.

Seafood inspections are performed at various points along the foreign and domestic

supply chain by the FDA and NOAA’s Office of Law Enforcement. The FDA requires all

domestic and international seafood processors and retailers to participate in a fish inspection

program called Hazard Analysis Critical Control Point (HACCP). HACCP places the

responsibility on seafood processors, rather than investigators, to detect and police safety

problems, including fraud. Seafood processors are required to document and report their

compliance with FDA regulations, including accurate labeling (Friedman, 1996). To check

compliance, FDA conducts unannounced inspections on the various entities involved in seafood

processing, including packers, repackers, and warehouses (Friedman, 1996). In order to combat

seafood fraud, NOAA conducts inspections on both vessels at sea, and processing plants.

Criminal and civil investigations are also conducted when needed.

Approximately 91% of the seafood consumed in the United States is imported, yet only

2% of this amount is inspected and overseas plants are not held to the same regulatory standards

as domestic producers (Love, et al., 2011). However, in 2011 the FDA was mandated to increase

food inspections of foreign facilities, to meet a goal of 600 facilities with inspection numbers

doubling each of the next five years (FDA, 2013). However, this number encompasses all types

of food facilities – not just seafood. The FDA is currently in the process of implementing a new

screening system for imported seafood known as the Predictive Risk-based Evaluation for

Dynamic Import Compliance Targeting (PREDICT), which will target higher risk products for

screening. This analytics based system will allow for the detection of patterns and trends in

incidences of fraud (FDA, 2012). In addition to inspections, the SAFE Seafood Act will require

NOAA and the FDA to accurately label seafood products and provide public outreach by

maintaining the FishWatch.gov website and a public List of Offenders.

The outputs of a program are the final products, or goods and services produced as a

result of the inputs and work processes. Broadly, the outputs of the SAFE Seafood Act will


include detection of seafood fraud and increased transparency and traceability of seafood

products and their origin. The first output, detection, will catalyze the development of a list of

offenders on the Department of Health and Human Services website, including information on

the exporter and frequency of violations. The Act will also provide for the application of civil

penalties of up to $100,000 for offenders (HR 1012, 2013). Transparency and traceability will be

achieved via accurate seafood labels that include scientific species name, method of harvest, date

of catch, and weight of product, among others. The public website, Fishwatch.gov, will also be

maintained and updated with the Guide to Acceptable Market Names for Seafood Sold in

Interstate Commerce.

By means of these work processes and specific outputs, the reduction of seafood fraud

will produce broader economic, public health, and environmental outcomes. These positive

outcomes listed below are not to say that seafood fraud detection and deterrence are the panacea

for public health and ecological problems related to seafood, but the SAFE Seafood Act will

ameliorate these situations to some degree.

By reducing the mislabeling of seafood and deterring seafood fraud, consumers will be

less likely to unknowingly overpay for less desirable seafood species. The playing field between

foreign and domestic fishermen would become more level as a result of imported seafood

products becoming subject to similar levels of regulation as domestic products. The collaboration

between NOAA and the FDA would also increase the efficiency and enforcement of seafood

safety efforts. Consumers would also benefit in regards to public health, which will also be

strengthened as information about the origins of seafood products becomes more accurate and

available through labels and public websites.

The reduction of fraud and increased availability of data regarding fisheries will

strengthen fisheries management, helping to make fisheries more sustainable. Knowledge of

fishery health and accurate data on populations would enable the development of appropriate

harvest levels and prevent overestimation of fishery health and overestimation of sustainable

harvest levels. One of the primary mechanisms of fisheries managements is guided by the

concept of maximum sustainable yield (MSY). MSY is the largest average yield of a resource,

such as fish, that can be continuously removed from a stock (Pew Environment Group, 2013).

This yield is dependent on the long-term average biomass of the stock, whereby fish are removed

up to the point along the biomass curve with the maximum growth rate. Harvests that bring the


population to this point of biomass and this growth rate are the maximum amount that can be

taken from the stock without depleting the population. Managing fisheries using MSY values,

however, does not account for the uncertainty in the fishery or create a buffer zone around the

core fish population required for prevention of serious risk to the stock due to unexpected

circumstances (Pew Environment Group, 2013). As such, this management tool has been called

into question.

The SAFE Seafood Act stipulates for a memorandum of understanding between NOAA

and FDA, which would require the identification of performance metrics (HR 1012, 2013). In

regards to environmental outcomes, metrics used to evaluate the health of fisheries are often

assessed by Biological Reference Points (BRP) which are calculated for a particular stock and

then used to analyze the health of a fish stock and include target reference points and limit

reference points. Target reference points include fishing mortality rate or rate of harvest, stock

biomass or how much of a species there is, and spawning stock biomass or how much of a

particular population can reproduce and how these parameters are affected by the amount of a

species that is harvested. Limit reference points are measures that attempt to restrict harvests to

ensure biological stability of a specific species and as a result the other species in the same

ecosystem (Kohin et al., 2006).

Having better data from fishermen regarding their catch and harvests will help analysts

better assess sustainable harvest levels (Kohin et al., 2006). A case-in-point example of this is

with the Gulf Wild program, where the tagging and traceability of Gulf of Mexico-caught red

snapper and grouper.


Though there are many ways to measure the success of a program (e.g., financial) this

analysis is focused on the environmental indicators of success. By having better data about fish

products and their origins, there can be more complete information regarding harvest from a

fishery. A better understanding of harvest will improve understanding of fisheries demographics

and result in more accurate Biological Reference Indicators, both limited and target, which will

help to improve management of fisheries.

If a management agency is able to accurately assess stock numbers and health, they can

set appropriate quotas. This responsiveness to the fishery data will be effective and efficient

because it will prevent dramatic changes in fish populations. This will allow current populations

that are worryingly low to recover from having seasons with low harvest levels or temporary

bans on harvesting. Fish populations will be then be able to recover and stabilize. This will

improve the longevity of the fishery and ensure its continued presence for future use.

The identification and measurement of success of the SAFE Seafood Act may not be entirely

clear, at least in the initial stages of implementation. As the rate of inspection increases, the

detection of fraud is likely to become more frequent, which may appear as a worsening of the

situation. In the long run, however, the benefits could become clearer. Increased inspections and

stricter punishments for fraud would both catch the major culprits in seafood fraud as well as

deter other fishermen from partaking in such actions. Though it will not be possible reach

complete certainty and confidence in seafood identification in the market, simply due to the

Pictured above are Gulf of Mexico-caught red snapper with the Wild Gulf tag affixed to the fish gills; these tags have their own unique tracking number that customers can use to trace their fish to port, vessel, and fisherman via www.MyGulfWild.com. Image courtesy of Gulf Wild.

http://www.mygulfwild.com/


sheer volume of seafood imported each day, the SAFE Seafood Act could allow for a vast

improvement from the current situation.

Looking at specific environmental indicators will help to determine if the SAFE Seafood

Act is effective in deterring fraud and producing positive effects on fisheries.

Case Study: Gag Grouper

Wild-caught gag grouper from the Gulf of Mexico is a firm, white fleshed fish

popular in restaurants and markets. It is, however, found to be mislabeled at least 25%

of the time, with weakfish or cheaper farmed fish like pangasius, an asian catfish,

appearing as grouper. Worse, overfished and vulnerable species like speckled hind are

sold as grouper. Perhaps most alarming to human health concerns, fish on the FDA’s

“Do not eat” list for sensitive groups like pregnant women and children, because of

their high mercury content, like king mackerel, are being sold as grouper.

Groupers live a long life of up to 30 years. Because they take so long to mature

and reproduce, they also take much longer to recover from overfishing than other

species. Another important biological fact to understanding gag grouper populations is

that gags are protogynous hermaphrodites, meaning they start as females and develop

into males after reaching a certain age or size. Overfishing has removed many females

that might potentially turn into males and heavy fishing at spawning areas has further

depleted the male gag population. In fact, the ratio of females to males is currently 30

females for every 1 male gag grouper, which is an all-time low for male gags (Pew

Environment, 2012, January 10).

A whole gag grouper. To its left are two filets: on top is a gag grouper filet, below is a filet of Pangasius, an asian catfish, which is often sold as grouper.


The gag grouper population dropped to 39% of a minimum healthy level in 2004

due to recreational and commercial overfishing at over 2.5 times the sustainable rate

(NOAA, 2012). Furthermore, a lack of scientifically sound fishing limits contributed to

the species’ decline (Pew Environment, 2012, January 10). Before 2011, when the first

moratoriums and fishing seasons were imposed, only a small portion of gag spawning

habitat was protected.

Within the species, grouper fish are often confused: there is black grouper,

yellowmouth grouper, scamp grouper, and gag grouper—just to name a few of the 56

kinds of fish called “grouper”. This is certainly a cause for mislabeling, for once the

head and fins are removed from the fish (often done to maintain freshness), the

discerning characteristics of the fish are gone. We can see with this case study how

contentious it will be to try and create a uniform guide to acceptable market names, per

the stipulation of the SAFE Seafood Act. Should, however, the issue of nomenclature be

settled, we can see how this could really benefit the consumer. Having information like

those shown earlier in the “Seafood Facts” table makes transparent an otherwise very

obfuscated chain of custody.

A private certification or tracking program is currently operating in the Gulf of

Mexico called Gulf Wild. Much like Rainforest Alliance or the Fair Trade certification

programs, this voluntary program aims to ensure ongoing conservation and

improvement in Gulf of Mexico fisheries. The improved accountability and data

collection is the result of the collaboration between working gulf fishermen, NOAA,

Community Seafood Initiative, and the Environmental Defense Fund, alongside a few

other groups. Under this unique catch share management plan, Gulf Wild is able to offer

safety assurance, accurate labeling, tracking, and marketing solutions with a single

label. Gulf Wild fish appear in the marketplace like the red snapper image we saw

earlier; the tag includes an identification number that consumers can use to track their

fish via the MyGulfWild.com Transparansea application.


Conclusion The objective of the Safety and Fraud Enforcement for Seafood Act is to “strengthen

Federal consumer protection and product traceability with respect to commercially marketed

seafood” (HR 1012, 2013). By increasing the coordination of activities by NOAA and the FDA,

the inspection of seafood, both imported and domestic, would become more efficient and would

enhance the detection of seafood fraud. The increased collection of data on fisheries and public

outreach of inspection information would aid in improving the transparency of the seafood

industry, which will also have positive economic, public health, and environmental effects.

The seafood industry is one of the least transparent in the food system, and it has a long

way to go before it can become accountable to consumers. The SAFE Seafood Act is one step in

Since its conception and application in 2011, Gulf Wild has been met with a

great deal of enthusiasm and success in the marketplace. Using their alliances, Gulf

Wild vessels participate in establishing better data collection for reef fish stock

assessments, which include discarded fish and accidental catch. This equals better data

and accurate monitoring of individual quotas. Furthermore, fishermen who are trying to

manage grouper fisheries sustainably can now distinguish themselves from competing

double-dealers who may have different priorities.


this direction of greater transparency, not to mention greater efficiency within the regulatory

system. Although the analysis shows that the SAFE Seafood Act is not a universal solution for

the problems in the seafood industry or the environmental impact the seafood industry has on our

ocean’s ecosystem, its implementation will yield a vast improvement on the situation. As

described throughout this report, the confluence of better data, technology, and accountability,

alongside the various metrics in place to measure success will translate to a difference for

consumers—both in their wallets and in the confidence they can have in the accuracy of the

marketplace. Furthermore; fishermen and the seafood industry also stand to gain from the SAFE

Seafood Act, which ultimately aims at keeping plenty of fish in the sea.


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