As the oil spill in the Gulf of Mexico continues to spew oil and unknown quantities of the oil-spill dispersant are being applied in epic proportion, the question remains, from a food safety perspective- how safe are finfish, crustacean (shrimp, crabs) and molluscan (oysters) shellfish from the Gulf of Mexico and surrounding tidal estuarine waters.
There is no question that hydrocarbons (oil) are easy to analyze and significant data exists for hydrocarbons in all types of matrixes. The hydrocarbon of primary importance is testing for levels of polycyclic aromatic hydrocarbons, some of which are known to be carcinogenic. Testing for the hydrocarbons are conducted by both chemical analysis and organoleptic analysis to make sure that the food product does not smell like a petroleum product.
Under the Food, Drug and Cosmetic Act, if either analysis would be positive, the product would be adulterated and not permitted to be put into commerce, as a measure of food safety. Even if the quantitative analysis is low, and there still is a detectable odor, the product would not be able to be placed in commerce for consumption. The question remains, how many species, how many samples, how many areas of the Gulf are being tested, and how often are they being tested to ensure that fish is wholesome and not adulterated with either oil or the chemical dispersant?
Of more concern may be the dispersant, since when you look at the label it states that it is "low toxicity" and "biodegradable". Yet we do not understand how much testing has been done nor what is the best analytical method to test for the chemical dispersant, particularly as it degrades. According to the FDA in a release on June 29, 2010, they state that the seafood would be tested more from the organoleptic, or odor test, than from an actual chemical analysis. They couched their words with "the dispersants used during the Deep Horizon response, have a low potential to bioaccumulate in seafood and are low in human toxicity, therefore there is likely little public health risk associated with consuming seafood that has been exposed to them."
Is there a statistical or epidemiological approach to the testing and clearing of product for human consumption? Are animal models being looked at to assure food safety or threshold level values for these chemicals? If so, what is it? We have not been told by the FDA, CDC, NOAA, or the EPA. How can we have a science and risk-based assessment without an epidemiological study, especially when words like "low" and "little" modify food safety.
It is clearly admirable that some of the top chefs in America, who recognize and cherish the wonderful fishery in the Gulf of Mexico, are going out of their way to support the Gulf States and seafood from the Gulf. However, there does not seem to be a lot of analytical data that has been released to the public that ensures the food safety of seafood - regardless of type. In fact, the EU has banned all seafood from the U.S. as of last week, regardless of its source. Clearly, by not renewing their approval for U.S. seafood, it is a huge economic blow to all seafood from the United States, not just from the Gulf of Mexico. Although it has been discussed in many different venues, the EU has much more stringent regulations than the U.S., starting with prevention of oil spills to the use, or lack thereof, of the chemical dispersant that is currently being utilized in copious amounts.
As the oil seems to be drifting into Galveston Bay, which is one of the richest oyster areas of the Gulf, one can only see the expansion of the questions as to how safe is seafood from the Gulf, how can we be assured by State Departments of Health and Agriculture as well as the FDA to take appropriate testing and provide appropriate risk assessment and risk communication to the public. According to some media reports many oystermen are finding dead oysters in their beds.
Although the NOAA models do not seem to have Apalachicola Bay in Florida as a high probability hit for the oil, this area also is extraordinarily rich in a diverse fishery, including oysters. Although much media attention has been given to the obvious issue with plugging the leak, soiling of beaches and the horrific damage to birds, turtles, dolphins and other marine wildlife there has been very little discussion about the human impact from a food safety perspective from consumption of fish and shellfish from the Gulf. In fact, I have been very pleased to note that the people who seem to be guardians of the estuary, the people who have lost so much, are the people who are the most skeptical about whether or not Gulf seafood is wholesome, and that is the oystermen and fishermen themselves who seem to be our primary guardians of the public’s health in terms of food safety.
There is no question that this has been both an environmental nightmare and tragedy. We must make sure that we are not sowing the seeds of chemical contamination via the consumption of chemicals that their effects on human health may not be understood for a very long period of time. There is no question that before safety of Gulf Seafood can be deemed wholesome, not contaminated, nor adulterated, a specific test for the dispersant chemicals must be created, validated and implemented since clearly, as in other areas where organoleptic analysis is relied on, at times the human nose may not detect what sophisticated chemical analysis can.
Therefore, the FDA, NOAA, and the Sea Grant Universities in the states of Florida, Alabama, Mississippi, Louisiana and Texas have a special duty, responsibility, and challenge to develop an appropriate sampling protocol and analytical methodology so we can analyze and clear products, not just utilizing sensory methods, but also with a well-thought out quantitative approach to specific chemicals which may be difficult, yet present and may well be of significant risk to the public’s health. Unless and until such analytical tools are available and validated, in reality, all seafood from the Gulf is suspect since we seem to be clueless as to how far the oil, the dispersant and any breakdown products could have travelled nor where especially the finfish were let alone the entire feeding chain prior to them being caught for human consumption. However, this process is essential and it is necessary that it be devoid of political interference.
We at EHA are monitoring closely all food safety and epidemiological issues concerning the wholesomeness of seafood from the Gulf, especially in terms of the scientific validity of the regulatory action, or inaction, to this crisis. We hope that food safety will be a primary focus as much as cleaning up the soiled beaches and return the precious wildlife that can be saved back to their natural environment.
EHA Consulting Group, Inc. has over 35 years of experience providing food safety consulting (/food/) to clients before, during, and after a crisis. To obtain more information about EHA's food safety and infectious disease epidemiologic services at http://www.ehagroup.com/epidemiology/ or visit EHA's Bad Bug Blog.