3.3 United States of America

3.3.1 Imports

The United States America is the second largest importing country in the world for fish and fish products, importing a huge variety of seafood from across the globe. Its main trading partners for imports are Canada, China and Thailand (Table 25). In fact the bulk of the top ten exporters are Asian or American (South and North). It is interesting to note the emergence of China and Viet Nam as important exporters, and increasing exports from all other countries over the period, with the exception of Thailand (fairly static) and Mexico (decreasing). The increasing Chinese imports is doubly interesting as it contrasts with the dramatic fall off of Chinese exports to the European Union in 2001 and 2002 due to the chloramphenicol problem (see previous section).

TABLE 25
Top ten exporters to the United States 1999-2002 (2002 basis) - tonnes

Source: US Government statistics.

TABLE 26
Total USA imports by exporting continent 1999-2002 (tonnes)

Source: US Government statistics.

The total imports are also broken down by continent (Table 26), which also shows a steady increase in total imports over the four-year period reaching 2 million tonnes in 2002. The most important exporting region was Asia, with almost double the amount imported from the next most important source, its neighbouring countries in North America. In 2002, Asian exports accounted for 46 percent of United States imports of fish and fish products. The next most important exporting regions were South America, Europe and Oceania. It is interesting to note that within Europe, the European Union (fifteen countries) only provided around a quarter of total European exports to the United States.

Table 27 breaks down the imports into species groups and into main product types, again for comparative reasons when examining the border case data.

The dominant species group imported was fish in a variety of forms, followed by shrimp and other crustacea. Similarly, the dominant form was as frozen/fresh accounting for over 80 percent of imports on average over the four-year period. The next most important product group was canned with around 14 percent of all imports on average.

3.3.2 Border cases

Available published information and/or officially disclosed data by FDA indicates that FDA seafood detentions averaged 3 559 per year during 1991-92. During the period January through October 1999 the FDA has issued 3 904 "Notices of Detention and Hearing" for fishery/seafood products. The number of notices issued ranged from a low of 171 in January 1999 to a high of 506 in June in 1999, with a numerical average slightly exceeding 390 detentions notices per month.

In this study, data were available for July 2001 to July 2003 and in order to determine any trends (though it is recognized this is limited data sets), we are breaking down the period to split year periods. During the period July 2001 to June 2002 seafood import detentions reduced to 1 158 per year showing an impressive decrease. However, the latest data disclosed by FDA show a new marked annual increase to 2 415 for July 2002 to June 2003.

TABLE 27
Total USA imports by product type and species group 1999-2002 (tonnes)

Source: US Government statistics.

Caution should be taken when using IRR (Import Refusal Report) data to compare annual figures of product/country quality and safety levels. IRR provide only a rough indication of product/country quality and safety levels because: (1) with the exception of products on Automatic Detention, the FDA randomly selects which shipments to examine and (2) the agency may focus on testing for certain hazards and not others.

Table 28 shows a summary of import border cases extracted from published FDA data. On average seafood accounts for around 10-11 percent of all food border cases.

A direct comparison between the two one-year periods is shown in Table 29. The main causes of border cases in the United States of America were from other causes (mainly filthy), accounting for around 72 percent of all cases (33.1 percent for filthy). Microbiological (approx. 23 percent) and chemical (approx. 5 percent) agents were of less importance.

The FDA has only five categories that specify microbial causes for a refusal -Salmonella, Listeria, Shigella, Hepatitis A and the general term Bacteria. Of interest are the substantial increases in Salmonella incidents. Salmonella increases seem to be related to particular control attention dedicated to some products from Asia during the months of October 2002 and April 2003.

The increase by almost five that occurred in the poison category reflected the FDA decision to introduce additional controls, e.g. analyses for chemical (polycyclic aromatic hydrocarbons, sulphites) and veterinary drug (chloramphenicol and nitrofurans) residues. The main problem was shrimp from Asian countries, especially China. It should be noted that the FDA detection limits for the veterinary drug residues were set at higher limits (5 ppb) than the European Union and Canada (1 ppb). Later, the United States detection limits were lowered to be more in line with the European Union and Canadian limits.

The category "other" covers a large number of different reasons such as mislabelling and lack of description of the process. The United States has over 170 descriptors for the classification of the cause for a border case for all foods. Many of them reflect possible microbial or chemical problems but are not specified as such. The dramatic inflation in numbers appears to be the result of inspection for compliance with requirements such as the HACCP legislation and the labelling of catfish. However, the descriptor "insanitary"^[10] was responsible for the bulk of the increase.

TABLE 28
Seafood import refusals by US FDA from July 2001 to June 2003 (FDA 2002)

* Note that for some products several reasons, e.g. both "filthy" and "Salmonella", are given as reasons for rejection but computed as one border case only. This explains why number of border cases is not the total of causes presented horizontally.
Source: US FDA Office of Regulatory Affairs.

TABLE 29
Annual evolution of seafood imports' detentions

Source: US FDA Office of Regulatory Affairs.

3.3.3 Filthy as a reason for seafood detention

Based on FDA official Seafood Import Refusals statistics "filthy" is the most common reason for seafood import refusal in the USA. According to the FDA Violation Code Translation (last revision dated of 17 March 1999) "filthy" is defined as a condition when ("sic") The article appears to consist in whole or in part of a filthy, putrid, or decomposed substance or be otherwise unfit for food." Although details are not given for the individual products, Huss, Ababouch and Gram (2004) assumed that microbial spoilage is the major reason for this type of refusal. However, previous FDA data clearly indicate that "filthy" was mainly related to product contamination by insect and/or insect parts (Annex A.20).

In the case of developing countries, pre-processing operations, when carried outside the plants under rather poor technical, hygienic and sanitary conditions, can be the main cause for contamination by insect, rodents and other animals. This includes shrimp grading, heading and peeling; cephalopods (squid) grading and cleaning; crab meat picking; shellfish (mussels, clams) shucking, are carried out in sandy beaches, in the ground floor of fish landing places, fish farms, sheds or family homes.

Despite dramatic improvements in a number of countries, sufficient effort is still needed to educate workers in basic principles of personal hygiene. Education and training is very difficult to achieve in countries where the labour force does not remain for a significant period of time in a single plant, for instance, the case of the utilization of daily-paid or piece-work personnel.

There is no doubt that during the last 5 to 10 years the situation has improved significantly and more and more industries have well established and efficient quality control systems based on HACCP principles.

3.3.4 Border cases in the United States in the context of import volume

Unfortunately, we have been unable to make this comparison for exporting area or species or products, as the data sets used were already partly consolidated - there was no line by line data that would allow geographic areas and fish species and products for each border case to be identified. Macrolevel analysis, i.e. no of cases per unit volume, for all border cases is presented in the next section (Analysis) for comparative purposes between countries.

3.4 Japan

3.4.1 Imports of fish and fish products

Japan depends heavily on imports to satisfy the nation's high fish consumption requirements. Total fish imports have been around 3 million tonnes annually (Table 30). China was the key exporter of fish and fishery products to Japan, with increasing amounts exported over the 1999-2002 period. Other major exporters are the United States, Thailand, Norway and the Russian Federation. It is interesting to note the increasing importance of Thailand and Chile, while other countries have been decreasing in importance - the Russian Federation, the Republic of Korea and Norway.

Total imports are also broken down by continent (Table 31), as this allows a later comparison with the border cases from these same regions. Not surprisingly, the major continent exporting to Japan is Asia, which dominates the imports accounting for 47 percent of all fish imports in 1999 to 54 percent in 2002. Europe and the United States are the next most important exporting regions, though Europe is becoming less important. Central and South America is becoming a more important source of fish for Japan, though Chile accounts for over half of the exports from this continent.

Table 32 breaks down imports by species groups and product categories for the period 1999-2001 for which data were available at the time of the study. Fish species dominate imports, accounting for around two-thirds of imports. The main fish species imported are frozen Alaska pollack mince blocks, tunas (frozen, fresh and canned), salmon (fresh and frozen) and pelagic species (mackerels, herring, sardines) and canned eels. Frozen shrimp accounted for around 10 per cent of the total imports. The dominant molluscan import was fresh clams, accounting for over 50 percent of imports. The remaining molluscs spanned the most common commercial species (abalone, mussels, oysters, scallops). Squid, cuttlefish and octopus also form an important group in fish imports.

TABLE 30
Top ten exporters to Japan 1999-2002 (tonnes)

Source: FAO.

TABLE 31
Total Japanese imports by exporting continent 1999-2002 (tonnes)

Source: FAO.

TABLE 32
Total Japanese imports by product type and species group 1999-2001 (tonnes)

Note that for some products several types e.g. prepared and frozen, are used to categorize the product.
Source: FAO.

3.4.2 Import notifications for foods including marine products

The MHLW provides information on its website about importation of all foods which is broken down into the number of cases imported (each consignment must be notified to the authorities), the inspection frequency and number of rejections. The data on the Web is only available for 2000.

TABLE 33
Import notifications, inspections/rejections of food items - 2000

Source: MHLW, Tokyo.

TABLE 34
Import notifications by exporting continent for all foods – 2000

Source: MHLW, Tokyo.

A total of 1 131 050 cases of import notifications^[11] were submitted (Table 33) for a total of over 29 million tonnes of food and related products. Among the notified cargoes, an average of just over 7 percent were subject to inspection. Marine products (including processed products) were inspected at a higher frequency of 10.2 percent. In 2000, the number of notifications had increased by 10.5 percent (3.8 percent by weight) compared to the previous year.

Among all cargoes that went through inspection just over 1 percent were reshipped or disposed of after being rejected due to non-compliance with the Food Sanitation Law (Table 33). However, this reduced to 0.5 percent for marine products (including processed products), indicating a higher standard of imported fish and fish products as against other imported foods, despite a higher inspection rate.

When the numbers of import notifications in 2000 were analysed according to the region of export, Asia accounted for the largest number with cases (Table 34), not too surprising given the dominance of Asian countries in the import volumes (Table 31). The next largest exporting regions were Europe and North America. These three regions accounted for nearly 90 percent of all import notifications by number. Given the dominance of Asian countries in term of volumes, the number of notification cases (a single shipment) is low when compared to the other continents whose volumes are significantly smaller. This may infer that there is a better control at source before shipping due possibly to good understanding of the Japanese requirements by Asian exporters and/or to in plant advice from importers who visit regularly the exporting companies. It may also infer that the shipments from Asia are significantly larger. If so, any rejections may have larger economic repercussions on the exporters. However, this is a supposition that cannot be confirmed from the available data.

3.4.3 Border cases for seafoods

We have also obtained more detailed data from the MHLW specific for seafood imports. This information is not available on the Web. From the data on border cases, we can break down the incidents to the reason, exporting region and to the product type/ species. For this data we have access to two periods, as mentioned in Section 3.1.1.

With respect to marine products and processed marine products, the border cases were based on the following non compliance of the regulations:

(a) Decomposed, hazardous or poisonous (Article 4)
(b) Products without a complete sanitation/health certificate (Article 5)
(c) Products with undesignated additives used (Article 6)
(d) Food or additives that do not meet specifications and standards (Article 7)
(e) Apparatus or containers/package that do not meet specifications and standards (Article 10)

Table 35 breaks down border cases by exporting region. By far and away the largest number of border cases came from Asia, not surprisingly, as this region is the largest exporter to Japan. Border cases from all other continents accounted for only around 7-9 percent of all cases. Contrast this with the total number of notifications of imports above (Table 34) for all foods, where Asia accounted for only 43 percent of import notifications. There will be further discussion of this in the next section.

Also of note is the almost doubling of border cases over the two periods. This has been attributed to increased inspections and stricter controls (Infofish, pers.comm.), no doubt in response to significant food safety events in Japan during the period studied with subsequent media and consumer pressure.

Table 36 breaks down the border cases by the major risk category for comparative reasons with earlier data. In Japan, microbial risks predominate with chemical risks also being significant. Ninety-seven percent of all risks are accounted for by these two categories. This is a similar profile to that of the European Union, where these two categories also dominated. However, the main risk category remained microbial in origin for both periods, whereas in the EU, chemical causes became dominant in 2002 due to the rapid appearance of veterinary drugs as an issue in imports.

Table 37 details the reasons for the border cases during 2000/2001 and 2001/2002. All microbial incidents are accounted for by one of three categories during the year with coliforms accounting for around half of microbial cases. It is apparent that all the microbial cases in Japan arise from tests for indicator organisms or indicative tests (high counts). Specific pathogenic bacteria do not account for any border cases, for instance, Listeria spp., Staphylococcus, Vibrio spp. etc. This will be further discussed in the analysis section at the end of this chapter.

The chemical risks are also a significant factor in border cases. The variety of risks identified under this category is numerous. Table 38 expands on the chemical groupings shown in Table 37. Over 80 percent of border cases due to chemical risk result from contamination with antioxidants, preservatives or biotoxins.

The bulk of the latter group come from ciguatera poisoning from various groupers, red snapper and carpet cod. This group are distinctive in that they are not additives, but are occurring naturally and thus need to be carefully monitored. The main culprits from the additives are sulphur dioxide and sorbic acid.

TABLE 35
Rejections of seafood Imports in Japan by exporting continent - 2000/2001 and 2001/2002

Source: Compiled by INFOFISH based on data from MHLW, Tokyo.

TABLE 36
Border cases in Japan by risk category - 2000/2001 and 2001/2002

Source: Compiled by INFOFISH based on data from MHLW, Tokyo.

TABLE 37
Breakdown of reasons for border cases in Japan - 2000/2001 and 2001/2002

Source: Compiled by INFOFISH based on data from MHLW, Tokyo.

TABLE 38
Border cases in Japan - chemical risks - 2000/2001 and 2001/2002

Source: Compiled by INFOFISH based on data from MHLW, Tokyo.

TABLE 39
Japanese imports - categories of fish products rejected - 2000/2001 and 2001/2002

* includes a wide range of fin-fish /crustacea/cephalopods/ fish fillet and minced products.
Source: Compiled by INFOFISH based on data from MHLW, Tokyo.

Table 39 breaks down the border cases by product type and species group for the periods 2000/1 and 2001/2. The predominant forms of product causing border cases are frozen products accounting for around three-quarters of all detentions. It is interesting that canned and live fish does not constitute a major problem for Japanese importers, and that fresh and cured fish account for only around 20 percent of border cases on average.

3.4.4 Border cases in the context of import volume

We can compare the border cases arising from exporting regions for 2000/2001 and 2001/2002 in the context of export volumes. We can also look at relative border cases arising from problems associated with products, however, this analysis is not possible for species categories as we do not have the border data available. There are some difficulties with the data which is discussed later.

Table 40 breaks down the border cases per 100 000 tonnes from various exporting regions. However some reservation must be exercised with this data, as the border cases are for non-calendar years and the import figures are broken down into calendar year periods. Thus, the import figures for 2001 and 2002 are used for the two periods, as these year groups best represent the period for the border case data.

The picture changes from earlier indications of absolute numbers of border cases. Asia still tops the list, but Oceania has a significant number of cases per unit volume. These two regions (geographically the closest to Japan) are significantly larger in relative border cases than the other continents. Better performers are Europe, North America, Central and South America and Africa. However, as we have noted before, care must be taken in these relative figures where the border cases are low, as changes of one unit in the number of border cases can make significant changes to the relative figure.