Why Does Congress Listen to SSA

Two weeks ago, I was honored to testify to Congress on behalf of the shrimp industry on trade fraud with shrimp imports.  I was even more honored to speak in support of strong legislation proposed by Congressmen Boustany and Richmond to address import fraud.  Later that evening, ABC News ran a national segment on the continued detection of harmful antibiotics in imported shrimp.

The two events were not related but trade fraud and food safety have been emphasized by the Southern Shrimp Alliance over the last several years.  To me, the reactions from importers to these issues have been as interesting as our work.

The day after the Congressional hearing, Dick Gutting wrote a commentary titled “Why Is Congress Listening to SSA?” The commentary was based on a question posed to Mr. Gutting from a reader, who asked, “”Why does someone like Mr. Williams of SSA have the ear of this committee and no one from our industry including specific owners of the shrimp importing business?”

Why does anyone listen to the Southern Shrimp Alliance when we complain about trade fraud or the deliberate use of antibiotics and harmful chemicals in shrimp farming?

Answer:  It is because of you, the membership of our organization.  I do not mean just you collectively in terms of numbers, although the continued support of the vast majority of the industry is vital.  When I say our members, I mean that our members embody the Southern Shrimp Alliance.  We don’t cry.  We don’t shout (at least not most of the time).  We don’t make wild allegations.  Whenever a problem has been raised, no one has ever complained when we take the time to investigate and analyze a problem to confirm that one exists or has been correctly understood.

When trade fraud was first raised with me regarding a few containers of falsely labeled shrimp that had landed in Houston, we looked at the issue carefully, proved that fraud was occurring, and developed a plan of attack for dealing with it.  Six years later, we plug along.  If someone thinks fraud is taking place or if a shrimp farming industry in a particular country has backslid to using harmful antibiotics again, we build the case.

Just like with our work in fisheries management, we set out everything we believe is happening, why we have reached those conclusions, and document as much as we can.  Then we meet with people outside the industry.  We meet with government officials, other industries, public interest groups, and the press.  We continue to build the case.

An example:  Last week we again identified a number of U.S. importers for Customs and Border Protection that appear to be involved in transshipment of shrimp to avoid duties and the FDA’s regulations.  One of those importers is also transshipping to evade duties on another product and we notified our contacts in that industry.  Those folks were already monitoring the importer but were not aware of the connection with shrimp.  We will work together to shut this importer down.

On one side of this coin, importing interests tell government officials the same thing they tell the industry press:   There might have been a problem with trade fraud a while ago, but it only involved specialty markets in the United States and has gone away.  I cannot explain the strategy. It effectively kills the credibility of anyone delivering that message.  It does not take much effort to identify where fraud is occurring.  Burying your head in the sand and saying that fraud does not exist just makes it seem like you are benefiting from lawlessness.

Another example:  For the past several years, we have monitored and documented the continued detection of banned chemicals in shrimp exported from Vietnam, India, and Bangladesh.  We are working on something right now that shows the prevalence of antibiotic use in shrimp farming in one of those countries.  We have not painted with a broad brush and I have yet to hear one complaint from our membership that we are not making sweeping claims.  We make the case that harmful antibiotics continue to be used, their use is intentional, and because their use is intentional, the problem can be easily solved.

On the other side of this coin, importing interests declare that no problem exists, antibiotics have been wiped out of fish farming because of good aquaculture practices, and even if a problem exists there is no significant health threat.  Go on then.  Enjoy your farmed shrimp flavored with chloramphenicol, nitrofurans, or fluoroquinolones.  Delicious.

Except, as one of our members noted to me last week, when we were forming ten years ago, National Fisheries Institute members got a memorandum from a private laboratory warning about the threat of chloramphenicol.  Read it for yourself, but I am partial to this passage:

Chloramphenicol is an antibiotic that kills a wide range of bacteria.  The FDA prohibits its use in all food animals and it is a drug given a high priority for regulatory action.  It is toxic to humans and has been found to cause fatal anemia and leukemia.


Except, as another member pointed out, before the Southern Shrimp Alliance provided funding to AOAC to try and help start the development of cheaper testing methods to detect antibiotics and harmful chemicals in seafood, AOAC had met multiple times with importers, including the National Fisheries Institute.  The last meeting, in July 2007, “ended with enthusiasm and agreement of key representatives from government and industry to collaborate and participate in the program.”  AOAC explained that the undertaking “is contingent on the financial support from the seafood industry, including producers, importers, retailers, and kit manufacturers . . . .”  That support did not happen.

So while the shrimp industry, the catfish industry, Slade Gorton, and the Canadian Government contributed funds to make the effort a reality, everyone else quietly walked away.  Not surprisingly, rapid tests are not used by importers to weed out bad shrimp.  It does not surprise me that importers have taken this position. Why spend money to develop a rapid test kit that will only confirm what everyone else in the shrimp eating world knows? That is, a problem exists with illegal antibiotics and pesticides in a significant percentage of imported farm-raised shrimp. I believe FDA testing, along with the EU, Japan, Canada, and now Russia has confirmed many times over that this problem remains.

Recently, there has been a shift from the importers of outright denial of this problem to admitting that it does exist to some degree. I suppose the consumer should be happy that some acknowledgement of illegal chemicals in imported farm-raised shrimp is now occurring, but it kind of takes away from the admission when a video is made saying that these chemicals will not make you ill or sick and there is no danger in having these chemicals in the shrimp. I wonder why they’re illegal? Oh yeah, FDA says so. After noting that the FDA conducted laboratory analysis on only 0.7% of seafood imports in FY2011 and could do much more to address the problem, here is what the GAO Report on catfish, published Friday, had to say:

Because fish grown in confined aquacultured areas can have high rates of bacterial infections, farmers may treat them with drugs, such as antibiotics and antifungal agents, to increase fish survival rates. According to a 2008 FDA report, the residues of some of these drugs can cause cancer, allergic reactions, and antibiotic resistance when consumed by humans. As imports of aquacultured seafood products increase, so do the concerns over the presence of drug residues.

Does this really matter?  Can testing make a difference?  Well, because the addition of antibiotics is intentional, it is also fully preventable.  And because it is fully preventable it is a problem that should not exist.  And we know that testing can wipe out a fully preventable problem because it has already done so with other products:

During the July 26 meeting, Michael Thomas, FDA-Center for Veterinary Medicine (CVM), described how a similar problem of food contaminated by antibiotics (milk in the United States) was solved by highly sensitive rapid test kits.

In 1988, milk samples began showing positive results for the antibiotic sulfamethazine; eventually, 20% of samples were found to have levels higher than permitted.  A collaborative effort between AOAC and the FDA began a search for a rapid screening kit that could check all milk samples for sulfamethazine shortly after the contamination was discovered.  By 1992, a method suitable for screening milk in dairies and on the farm had gone through the AOAC Performance-Tested MethodSM(PTM) validation program.

Once the test kit was available (there are now three listed on the AOAC Web site), dairies and dairy farmers began to test their milk, and contamination in milk bound for the stores dropped precipitously.  Thomas reported that rates of positive results for sulfamethazine in milk dropped from 1% in 1992 to 0.1% in 1998, reaching 0.04% in 2006.  Clearly, when there are good screening methods that can be applied early in the production, the quality of the final product improves enormously.

Spending millions of dollars on a public relations group that teaches you how to ridicule and beat up anybody who says something bad about you is not going to change facts.  Paying someone to furiously wave their arms around might generate some wind, but not enough to blow unpleasantness away.

I am grateful to each of you for understanding this.  So we aren’t going to cry.  We aren’t going to shout.  And we aren’t going to make wild allegations.  We are going to keeping doing what we’ve been doing.  Let them say that imported shrimp is fairly traded.  Let them say that cheating doesn’t happen.  Let them say that antibiotic contamination is overblown.  Let them say they’ve certified their way out of the problem.  We will prove otherwise, time and again, we will prove otherwise.

One day, what importers are saying now will come true.  There will be no more cheating and there will be no more harmful antibiotics in the shrimp consumed in our market.  And, they can thank us then, even if they don’t think highly of us right now.

For now, tell everyone you know, everyone who will listen, what is actually happening. Because I can say and write this stuff over and over again, but I am only one voice. You are SSA.

Why would Congress listen to SSA? Because we’re right.


Read Certified Laboratories Inc. 2002 Memorandum to NFI Members here:


Read AOAC Article on Seafood Initiative here:


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