United States import safety, environmental health, and food safety regulation in China.

Author:Nyambok, Edward O.

Research Questions and Methods

Imports--including imports of food--comprise an important aspect of the U.S. economy; the country's manufacturing and processing industries are increasingly dependent on imports to meet the rising demand for goods among U.S. consumers. In particular, the volume of U.S. seafood and aquaculture imports has significantly increased as consumer demand continues to rise. According the National Oceanic and Atmospheric Administration, the volume of seafood imports in the U.S. has more than doubled during the past 10 years (National Oceanic and Atmospheric Administration, 2006). Part of this increase has consisted of Chinese seafood products. As of 2007, 100% of basa consumed in the U.S. was imported, and 80% of those imports came from China; meanwhile, approximately 2% of catfish consumed in the U.S. was imported, 99% of which was of Chinese origin (Bottari, 2007). The U.S. currently imports more aquaculture products than it exports. Several recent Food and Drug Administration (FDA) import alerts have raised concerns about the safety of globally traded Chinese seafood (Solomon, 2007). The acknowledgement of safety concerns regarding imports on which the U.S. is already dependent reveals a significant trade-policy dilemma. On the one hand, it is the obligation of the U.S. government's regulatory agencies and the nation's food importers, food processing facilities, and retailers to protect consumers from hazards that may be present in imported seafood products, including aquaculture products from China; on the other hand, sustaining and satisfying the U.S. food industry and American consumer demand requires a continuous supply of seafood imports, including those from China. This dilemma leads to the following fundamental questions:

* What are the sources of environmental health and food safety problems in the Chinese aquaculture industry?

* What steps have been taken by U.S. and Chinese authorities to protect consumers?

To answer these questions, we employed a systematic and multidisciplinary research approach. This involved an in-depth review of government documents (including, but not limited to, U.S. congressional hearings, import safety data, and laboratory test results), conference presentations by experts at the interface of food safety and environmental health, and a number of published studies. In addition, interviews were conducted with government officials from such agencies as FDA and Customs and Border Protection.

Analysis and Discussion: U.S. Import Safety and Chinese Aquaculture

International trade in food, plants, animals, and animal products can transmit infectious disease agents and toxic chemical contaminants across nation-state borders. Increased globalization of the food supply has led to the introduction of new foods, food handling practices, and dietary habits into different regions. Regional food safety problems have increasingly become globalized problems; food safety problems that were once confined to certain regions can now be felt thousands of miles away (Lang, 1999). This globalization has resulted in the emergence and reemergence of foodborne disease outbreaks and incidents of food contamination in different regions of the world. Effective and timely management of such food safety problems requires rapid international exchange of information. Global cooperation between governments is crucial to the timely identification, prevention, or control of emerging food safety problems.

The U.S. has for a long time grappled with safety problems involving imported food, drugs, and raw materials for industries. Recent policy issues involving China include a March 15, 2007, nationwide recall involving several brands of pet food in the U.S. This recall was prompted after pet food caused several illnesses and deaths in cats and dogs. In this incident, contaminated raw material imports from China were used in the manufacture of animal feed. The raw materials were tainted with an industrial chemical--melamine--used in the manufacture of plastics (Associated Press, 2007; Food and Drug Administration [FDA], 2007a). In another incident in June 2007, 52 people in 17 states fell ill after eating a snack produced by an American company. The snack--Veggie Booty--was produced by using contaminated raw materials from China. The raw materials contained pathogenic Salmonella bacteria (Reuters, 2007). These are just a few of the problems that U.S. consumers, regulatory authorities, and companies have faced regarding the safety of imported Chinese food products and raw materials.

For decades, health officials have encouraged increased fish consumption due in part to the health benefits associated with omega-3 fatty acids found in seafood, and the U.S. has increasingly imported aquaculture products to meet rising demands for fish. As mentioned earlier, a large proportion of U.S. aquaculture imports come from China. China in particular, however, has been a source of aquaculture-related health concerns. In March 2007, FDA issued an import alert against Chinese aquaculture imports. This was due to the presence of excessive antimicrobial chemical contaminant residues--most of which are banned for use in food in the U.S. An import alert was issued against imports of catfish, dace, eel, shrimp, and basa (Weiss, 2007). An import alert is a publicized caution alerting regulatory authorities and inspectors to be on the lookout for shipments of goods deemed to be in violation of import regulations. Violations may be technical or safety related; they may involve improper labeling, excessive levels of microbial or chemical contaminants, contravention of endangered-species laws, violations of the country of origin's regulations, shipments containing animal or plant products from countries with outbreaks of infectious animal or plant diseases, and so forth. An import alert enables regulatory authorities to target and intercept violating import shipments at U.S. ports of entry before they enter the American market.

Regulatory authorities typically test for contaminants, which on the basis of risk analysis and experience they believe they will likely encounter in imported food or raw materials. Unfortunately, however, several safety problems encountered in the international trade in food and raw materials (e.g., melamine in wheat gluten from China used in pet food, antibiotics in aquaculture products from China, the United Kingdom's discovery of Sudan III dyes in chilies from India in 2003, etc.) involve contaminants that regulatory authorities and food testing laboratories did not and arguably could not anticipate. In such cases, hazards present in imported food and raw materials come to light after they have caused illnesses and in the worst cases, deaths. Consequently, management of food safety issues in international trade is often performed on a reactionary rather than a preemptive basis. This approach is concerning when one considers the growing magnitude of globally traded agricultural and food products including seafood.

In the midst of rapid growth in international trade, China has emerged as the largest food exporter in the world and the third-largest exporter of food to the U.S. The country dominates international food markets with exports of fruits, vegetables, and seafood. Chinese dominance in international trade in food has been clouded by increases in safety problems in food destined for both export markets as well as domestic consumption (Ellis & Turner, 2008). In the light of current increased global food trade between the U.S. and China and increased safety problems associated with products from China, our study explores (a) the sources of environmental health and food safety problems in the Chinese aquaculture industry and (b) steps taken by the U.S. and Chinese regulatory authorities to protect consumers from contaminants in aquaculture imports.


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