Canadian Shellfish Sanitation Program (CSSP)

The Canadian Shellfish Sanitation Program is jointly administered by the Department of Fisheries and Oceans (DFO), Canadian Food Inspection Agency ( CFIA) and Environment Canada (EC). Its primary objective is to protect the public from the consumption of contaminated shellfish by controlling the recreational and commercial harvesting of all shellfish within Canada.

A second objective of the program is to fulfill the bilateral agreement of 1948 between the Government of Canada and the United States by carrying out the procedures jointly agreed to by each party to improve the sanitary practices prevailing in the shellfish industries of the two countries.

History

The Canadian Shellfish Sanitation Program (CSSP) has been developed over the years as a direct result and response to an outbreak of typhoid fever in the United States during the winter of 1924-25. This outbreak involved 1500 cases and 150 deaths and was traced to the consumption of contaminated oysters. Canada passed regulations under the Fish Inspection Act on July 3, 1925 requiring that they be a "safe food product". The states of New York and Massachusetts also extended requirements for certification to all shipments consigned to their markets. The mutual concerns of Canada and the United States to protect the public from the consumption of contaminated bivalve mollusks led to a formal shellfish agreement on April 30, 1948 dealing with sanitary practices prevailing in the shellfish industries of both countries. This agreement included the following procedures:

1. The use of a manual (approved by both US Public Health Service and Canadian Department of National Health and Welfare) which sets forth the sanitary principles that will govern the certification of shellfish shippers;
2. The notification of the degree of compliance with those sanitary principles obtained by each party to each other;
3. The facilitation of inspections of shellfish handling facilities and shellfish growing areas by either party.
4. The termination by either party giving thirty days' notice.

Initially, the Department of National Health and Welfare was the designated Canadian agency for administration of the 1948 Memorandum of Agreement between the United States and Canada and the US Public Health Service and the corresponding American agency. Presently Department of Fisheries and Oceans (DFO), Canadian Food Inspection Agency (CFIA) and Department of Environment (DOE) share responsibility for honoring the 1948 Canada/US Agreement. In the US, the Food and Drug Administration is now the designated agency.

Legislation

The legal authority for the Canadian Shellfish Sanitation Program is provided by the Fisheries Act, Management of Contaminated Fisheries Regulations, the Fish Inspection Act, and Fish Inspection Regulations. These acts and regulations enable the departments to classify all actual and potential shellfish growing areas for their suitability for shellfish harvesting on the basis of sanitary quality and public health safety. This authority also allows the responsible departments (DFO and CFIA) to: Control the harvesting of shellfish from closed areas; regulate and supervise relaying, transplanting, cleansing and replanting; restrict harvesting of shellfish from actual and potentially affected areas in a public health emergency; prevent sale, shipment or possession of shellfish from unidentified sources; certify, inspect and determine the sanitary compliance of the operations of each shipper or processor; regulate the shipping conditions and labeling requirements for shellstock; regulate the export, import, processing, packaging, shipping storage and repackaging of shellfish; regulate the controlled purification of shellstock; suspend operations or decertify shellfish processors; evaluate laboratories performing shellfish analyses; collect samples and conduct appropriate bacteriological, chemical and physical tests to determine product quality; prohibit the export, or possession of shellfish from unidentified sources, uncertified dealers etc.

The management of contaminated fisheries regulations authorize the Regional Director General of DFO to issue orders prohibiting harvesting of fish (finfish and shellfish) from areas where any kind of contamination or toxicity is present to an extent to be of public health significance. Environment Canada administers the pollution abatement sections 36-42 of the Fisheries Act which control the deposition of any deleterious substances to water frequent by fish or affect the use by man of fish that frequent that water.

Administration

In February 1990 a Memorandum of Understanding was signed between the Department of the Environment and the Department of Fisheries and Oceans defining the relative roles and responsibilities for the Canadian Shellfish Sanitation Program. The MOU is currently being revised to reflect the transfer of Fish Inspection Directorate activities of DFO to the new Canadian Food Inspection Agency.

Under the terms of the MOU, Environment Canada (DOE) is the lead agency with regards to water quality and classification of shellfish growing areas through comprehensive sanitary and bacteriological surveys of molluscan shellfish growing areas. DOE recommends to the Shellfish Growing Area and Survey Classification Committees the specific classification of water areas and their boundaries. DOE chairs the Shellfish Growing Area Survey Classification Committees in the Atlantic, Quebec and Pacific Regions.

Department of Fisheries and Oceans (DFO) is the lead agency with regards to the controlled relaying and depuration and harvesting of shellfish from classified areas. DFO is responsible for the enforcement of closure regulations and enacting the opening and closing of shellfish growing areas under the authority of the Fisheries Act and Regulations.

Canadian Food Inspection Agency (CFIA) is the lead agency with regards to the handling, processing, marketing, import and export of shellfish and liaison with foreign governments. CFIA is also responsible for the management of the marine biotoxin monitoring program.

Program Coordination

Program coordination is achieved through regular interdepartmental meetings at national headquarters and through regularly scheduled meetings of Shellfish Growing Area Survey and Classification Committees in the Atlantic, Quebec and Pacific Regions. The interdepartmental meetings review reports on the operation of program and exchange technical information, discuss national policy issues of mutual concern, consider proposed regulations and amendments and deal with issues on which there is no resolution at the regional level. The regional committees, chaired by Environment Canada, are composed of representatives from the Department of Fisheries and Oceans, Environment Canada, CFIA and appropriate provincial government departments. These committees recommend to DFO changes in regulations pertaining to the classification of shellfish growing areas.

Guidelines

The Canadian Shellfish Sanitation Program (CSSP) follows closely the American National Shellfish Sanitation Program (NSSP) guidelines. The purpose of the Canadian Shellfish Program Manual of Operations is to provide both DOE, CFIA and DFO staff with the policies and procedures to be employed when applying the Fisheries Act, Fish Inspection Act and related regulations governing the control of shellfish growing areas, and the harvesting, processing and distribution of shellfish. The Canadian manual will contribute to uniformity of interpretation and consistency in the application of policies and regulations.

Growing Area Survey and Classification

A major component of the CSSP is the identification of safe shellfish growing areas to permit commercial harvesting for the domestic market as well as for export to the United States.

The sanitary surveys completed by Environmental Protection provide the basis for the classification of coastal areas for the harvesting of clams, oysters and mussels. In order that the area be considered approved for the safe harvesting of shellfish, the waters must be free of hazardous concentrations of pathogenic micro-organisms, radionuclides, and toxic wastes in accordance with criteria established by the National Shellfish Sanitation Program (NSSP) and the Canadian Shellfish Sanitation Protocols.

A comprehensive sanitary survey is composed of the Bacteriological Survey and the Shoreline Survey. The former refers to the measurement of fecal material in the growing areas and the latter describes the studies required to identify and quantify the pollution sources and to estimate the movement, dilution and dispersion of pollutants in the receiving environment.

The CSSP categories of classification resulting from the analysis of sanitary surveys are as follows:

Approved

The sanitary survey indicates, that even under adverse conditions, wastewater effluent from neighboring areas does not represent a risk to public health. In those zones, the median or geometric mean faecal coliform Most Probable Number (MPN) of the water does not exceed 14/100 mL, and not more than 10% of the samples exceed a faecal coliform MPN of 43/100 mL.

Closed

Direct harvesting from this area is prohibited due to chemical or bacteriological contamination Shellfish can be used only by permit under specified conditions for depuration, relaying, experimental purposes or other approved processing.

Under the program guidelines, each shellfish growing area must undergo a comprehensive survey before it can be approved for harvesting.. Re-surveys are conducted regularly to determine if sanitary conditions have undergone significant change. Change in pollution source conditions is evaluated in all approved growing areas annually by means of a formal reappraisal conducted both in the office and in the field. A complete re- evaluation of each approved area is conducted at least once every three years. This evaluation includes the field review of pollution sources, analysis of at least the last fifteen water samples from each key station and other field works as deemed necessary to determine the appropriate classification for the area.

Unclassified areas are regions where the sanitary suitability for harvesting is undetermined and therefore not approved for shellfish harvesting at present. These areas need to be surveyed and classified prior to their approval for commercial harvesting.

Pollution Abatement

In Atlantic Canada, approximately 2000 Km² of coastal waters have been closed to the harvesting of shellfish due to fecal bacterial pollution, representing 33% of the classified shellfish growing area ( Figure 1).

Atlantic Regional Area (sq km) Classification April 2004. Click on image to enlarge.

The number of shellfish growing area has steadily increased since 1940 ( Figure 2 ). Unless adequate measures are taken to control the pollution of coastal waters, further reduction in the acreage of available shellfish areas for harvesting will inevitably result, thereby causing socioeconomic hardships to the region.

Closure Trend- Atlantic Region (1995 to 2004). Click on image to enlarge.

The cleanup of pollution sources and improved water quality also addresses human health concerns. The recent .National Academy of Science report on seafood indicate most human health risks associated with seafood originate in the environment. Molluscan shellfish consumed raw or partially cooked constitute the highest consumer risk as a result of microbial contamination from fecal pollution. Cleaner water also supports recreational activities and the preservation of the aesthetic quality of coastal areas. Often the coastal residents and those participating in coastal recreation and development contribute to the pollution of shellfish areas. Therefore education of coastal communities and school children is critical in the remediation and restoration of contaminated shellfish areas.

Several coastal communities in Atlantic Canada have begun remediation and shellfish restoration activities, and the numbers are increasing. In Charlotte County along the Bay of Fundy in New Brunswick, the Premier’s Clam Bed Action Committee and the ACAP groups are active in pursuing the clean up of bacterial contamination in the area. Similar cleanup activities have also taken place in other parts of New Brunswick, PEI and Nova Scotia. Remediation activities have been successful in re-opening 2485 hectares of shellfish closures for commercial shellfish harvesting.

Control of pollution to shellfish growing areas is only one element of the total problem facing the Atlantic Canada shellfish industry. The other elements are shellfish resource management, rehabilitation and coastal zone planning. Many federal and provincial agencies have jurisdiction and responsibilities for pollution control, shellfish resource management and coastal zone planning and development. These multiple jurisdictional authorities complicate implementation and enforcement of regulations to protect shellfish growing waters. It is important that all levels of government and communities should coordinate and develop means to ensure that activities related to coastal development and waste discharge adequately protect marine environmental quality. The preservation of our estuarine and coastal waters is critical to the health of our shellfish industry. Improved water quality , in concert with habitat improvement and the expansion of aquaculture activities will allow Atlantic Canada to reach its potential in the world production of molluscan shellfish.

Important Notices