•fm
United States       Office Of Water
'Environmental Protection  . Gulf Of Mexico Program
Agency          Stennis Space Center, MS 39529
                                            EPA 800-K-93-001
                                            September 1993
Public Health Action Agenda
For The Gulf Of Mexico

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Recycled/Recyclable
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            A STATEMENT FROM THE GULF OF MEXICO PROGRAM POLICY REVIEW BOARD

The Gulf of Mexico is a national treasure,containing ecological and commercial riches unmatched by other bodies of
water. The Gulfs many resources include a larger annual yield of finfish, shrimp and shellfish than the South and Mid-
Atlantic, Chesapeakeand New England regions combined; 90% of U.S. offshore production of oil and gas; three of the
nation's busiest seaports providing access to the 63%  of the U.S. land area; critical habitat for 75% of migratory waterfowl
traversingthe U.S.; and vast wetlands that are about h«1f of the national total. Yet, despite these riches and countless
others, the Gulf of Mexico is being subjected to increasingenvironmentalrisks.

In many places, untreatedhuman and animal wastes- rich sources of potentially harmful bacteria and nutrients- are
directly discharged into the coastal watersof the Gulf of Mexico.  Pathogenic microorganisms present a risk to swimmersin
contaminated watersand to consumers of raw oysters and other shellfish harvestedfrom such waters. An excesssupply of
nutrients- nitrogen and phosphorus - may triggeralgal blooms that produce toxins harmful to humans and wreakhavoc on
coastal fish populations.

A significant step toward containing the Public Health problems in the Gulf was taken in 1988, when the Gulf of Mexico
Program was initiated.  The major purpose of the Program is to develop a comprehensive.interagencystrategyto protect
and enhance the environmental quality of the Gulf of Mexico. The Gulf of Mexico Program identifies key issues that are
pervasivein the Gulf and that threaten the future long-term viability of the Gulf ecosystem. This Action Agenda has been
developed to specify the primary activities needed to reduce, and eventually eliminate, public health menaces from Gulf of
Mexico shores and waters.

On September 16,1992, we, the Members of the Policy Review Board of the Gulf of Mexico Program, endorsed this Public
Health Action Agenda in principle. We agree that the achievement of the goals and objectives stated in the agenda is
crucial in solving the public health problems endemic to the Gulf of Mexico ecosystem, and that the action items listed will,
collectively, move us in the direction of a solution. We are directingthe Gulf of Mexico Program to initiate significant
outreach activities on this Action Agenda to both improve the plan and generate support for its implementation. We are
also r equestingthat all lead agencies identified for the action items provide the Gulf of Mexico Program with annual
progress reports on either the status of implementation or thestatusof obtaining commitments for funding.

Public Health issues are a worldwide problem, because people are careless or undereducatedabout the disposal of toxic
chemicals, pesticides, soluble metals, and even human and animal wastesin rivers and oceans.  People are both the source
and the answer to the pollution that endangers the public's health. We, the Members of the Policy Review Board, will do
our part as well as encourage others, to help provide solutions to the pollution problems that imperils the public's health.

                     Leigh Pegues, AL Dept of EnvironmentalManagement (State Co-chairman)
                   LaJuanaWilcher, U.S. EnvironmentalProtection Agency (Federal Co-chairman)
                              Carol Browner, FL Dept. of EnvironmentalRegulation
                                      John Burt, Soil Conservation Service
                                       Captain B. N.Cugowski,U.S. Navy
                               George Dodson, U. S. Air Force (ex officio member)
                         Charles N. Ehler, National Oceanic & Atmospheric Administration
                                   Captain Thomas Greene, U. S. Coast Guard
                             Anthony M. Guarino, U.S. Food & Drug Administration
                         James I. Jones, MS-AL Sea Grant Consortium (ex officio member)
                          Andrew J. Kemmerer, NO AA National Marine Fisheries Service
                             Douglas A. Lipka, U. S. EnvironmentalProtection Agency
                    Gale Martin, MS Soil & Water Conservation Commission (ex officio member)
                                     Garry Mauro, TX General Land Office
                                Kai D. Midboe, LA Dept. of Environmental Quality
                                   Warren T. Olds, U.S. Fish & Wildlife Service
                                James Palmer, MS Dept. of Environmental Qualify
                                 J. Rogers Pearcy, Minerals Management Service
                            Brig. General Pat M. Stevens,U.S Army Corps of Engineers
                          William F. Taylor, National Aeronautics &  Space Administration
                           Barbaras. Todd, Citizens Advisory Committee Vice-chairman
                        John Woeste, FL Cooperative Extension Service (ex officio member)

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Exeeuffv© Summary
EXECUTIVE SUMMARY

The Gulf of Mexico contains ecological and commercial resources matched by few
other bodies of water. Yet its blue-green waters disguise the increasing
environmental threats that endanger these resources. In recognition of the growing
threats, Regions  4 and 6 of the United States Environmental Protection Agency
(EPA), which share jurisdiction over the five Gulf Coast States (Alabama, Florida,
Louisiana, Mississippi, and Texas), initiated the Gulf of Mexico Program in August
1988. The goal of the Gulf of Mexico Program is to protect, restore, and enhance the
coastal and marine waters of the Gulf of Mexico and its coastal natural habitats, to
sustain living resources, to protect human health and the food supply, and to
ensure the recreational use of Gulf shores, beaches, and waters — in ways consistent
with the economic well being of the region.

The Gulf of Mexico Program is a cooperative partnership among federal, state, and
local government agencies, as well as with people and groups who use the Gulf.
During the early stages of Program development, eight priority environmental
problems were identified and the following Subcommittees have been established to
address each of these problems: Marine Debris, Public Health, Habitat Degradation,
Coastal & Shoreline  Erosion, Nutrient Enrichment, Toxic Substances & Pesticides,
Freshwater Inflow, and Living Aquatic Resources.

The Public Health Subcommittee was charged with characterizing factors
contributing to public health problems and identifying ways to reduce the public
health risk from Gulf of Mexico resources.  The Subcommittee has been meeting for
more than three years—to review information and data collected by citizens and
scientists, identify problem areas, discuss actions that can resolve the problems, and
evaluate methods for achieving and monitoring results. The culmination of their
efforts is this Public  Health Action Agenda which specifies the primary activities
needed to reduce, and eventually eliminate, factors contributing to public health
problems in the Gulf of Mexico.  This Action Agenda is part of an  evolving series of
Action Agendas that will be developed to meet the future needs of the Gulf of
Mexico.

Chapter I of the Action Agenda provides an overview of Gulf of Mexico resources
and the threats now  facing those resources. In addition, Chapter I describes the
structure of the Gulf of Mexico Program, including the Action Agenda development
process.

Chapter n is a summary of the preliminary scientific research compiled by the Public
Health Subcommittee.  The final  characterization report is scheduled for completion
in May 1993 and information contained in that report will be included in future
Action Agendas.
 Gulf of Mexico Public Health Action Agenda 4.1

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 Executive Summary
 Chapter HI describes the legal and institutional framework currently in place in the
 Gulf of Mexico to address public health issues and support efforts to reduce public
 health risks.

 Chapter IV, The  Unfinished Agenda, contains the goals, objectives and specific
 activities established by the Gulf of Mexico Program to address public health issues.
 The four goals are to: 1) prevent adverse health effects resulting from consumption
 of raw shellfish harvested from the Gulf of Mexico, 2) prevent illness resulting from
 exposure to marine biotoxins in coastal waters  of the Gulf of Mexico, 3) reduce long
 term health risks from exposure to toxic substances in Gulf of Mexico seafood while
 maintaining the beneficial effects of seafood consumption, and 4) prevent exposure
 to pathogens in coastal waters of the Gulf of Mexico.

 The Gulf of Mexico Program hopes to accomplish these goals by addressing four
 categories of public health concerns. These categories were developed by the Public
 Health Subcommittee during the course of its characterization research on public
 health issues in the Gulf of Mexico. This work, discussed in Chapter H, resulted in
 the following prioritization of concerns:
      I.


      2.

      3.


      4.
Exposure to pathogens in Gulf waters via consumption of raw
molluscan  shellfish.

Marine biotoxins and their effect on human health.

Toxic substances in the food chain, the potential for biomagnification
and human health effects caused by consumption.

Exposure to pathogens in Gulf waters from recreational or occupational
contact.
Forty-four "action items" have been developed to support the goals and these are
grouped under four strategies and seventeen objectives (see Index of Public Health
Strategies and Objectives).  The action items included in Chapter IV have been
screened by the Gulf of Mexico Program and represent those activities that are
currently the most significant and most achievable. This is a fairly comprehensive,
but not exhaustive list.  This document begins an evolving process of Action
Agendas in which action items are designated, implemented, and then reassessed as
progress in the Gulf is made.  In the future, new action items will be developed to
meet the changing needs in the Gulf of Mexico.
Gulf of Mexico Public Health Action Agenda 4.1
                                                               II

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Executive Summary
         Index of Public Health Strategies & Objectives
                          Research and Demonstration

Objective: Conduct scientific studies designed to contribute new empirical information pertinent to the
            prevention of illness in those exposed to Gulf waters or from consumption of products
            harvested from Gulf waters.
Objective: Identify and characterize marine biotoxins and progenitors that have not been
            investigated and continue to develop and improve methods for the detection and
            management of marine biotoxins.

                              Monitoring/Assessment

Objectives Determine the extent of human fecal pollution of shellfish growing areas in the Gulf of
            Mexico.
Objectives  Establish a formal database on the occurrence of seafood-borne disease.
Objectives  Determine Gulf Coaist residents at risk from consumption of potentially contaminated
            seafood.
Objectives  Survey Gulf Coast bathing beaches for the presence of human fecal wastes and other
            pathogens  (i.e., vibrio).                            '
Objectives  Assess the public health significance of marine biotoxins in the Gulf of Mexico.
Objectives  Implement remote-sensing technologies for the detection of phytoplanktbn blooms/red-
            tides in the early stages of development.                  w^»..^

                               Standards/Enforcement

Objective:  Reduce the level of human fecal wastes in the coastal waters of the Gulf of Mexico.
Objectives  Establish a Gulf Coast Fish Contaminants Group (GCFCG).
Objectives  Encourage states to adopt compatible policies for management of public health hazards.
Objectives  Standardize methods for marine biotoxin recovery and analysis from phytoplankton
            producers and seafood vectors.
Objectives  Organize a Gulf-wide marine biotoxins management and consulting group.

                                   Public Outreach

Objectives  Undertake an educational campaign to: 1) help the public understand and control or
            minimize potential risks associated with the consumption of raw molluscan shellfish; 2)
            help health care professionals understand the potential risks associated with the
            consumption of raw molluscan shellfish, especially for high risk patients, and to transmil
            information to those patients; and encourage the reporting of shellfish-associated illness
            3) help legislative and judicial members understand the seriousness of violations of
            shellfishing regulations related to public health; and 4) inform enforcement officials
            about public health aspects of shellfishing regulations.
Objectives  Help the public understand both the nutritional/health benefits and the potential risks
            from consumption of seafood, other than raw molluscan shellfish, as well as how to
            maximize those benefits while avoiding, controlling, or minimizing the risks.
Objectives  Help the public, especially high risk populations, understand the risks associated with
             recreational and occupational exposure to naturally occurring pathogens (i.e.: vibrio) in
            marine waters.
Objective:  Help the public understand the risks associated with consumption of seafood
             contaminated with marine biotoxins and the risks associated with direct exposure to
             marine biotoxins.
 Gulf of Mexico Public Health Action Agenda 4.1
II!

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 Executive Summary
 Action items contained in Chapter IV are not listed in priority order.  Some of the
 actions are already underway but not yet completed. Others are included because
 they will guide federal, state, and local government agencies and private sector
 organizations in allocating resources where they are most needed and in justifying
 future management strategies. This Action Agenda should prompt specific agencies
 and groups to become involved.

 The Gulf of Mexico Program recently developed nine short-term environmental
 challenges to  restore  and maintain the environmental  and economic  health of the
 Gulf.  Within  the next five years, through an integrated effort that complements
 existing local,  state, and federal programs, the Program has pledged efforts to obtain
 the knowledge and resources to:
    •  Significantly reduce the rate of loss of coastal wetlands.
    •  Achieve an increase in Gulf Coast seagrass beds.
    •  Enhance  the sustainability of Gulf commercial and recreational fisheries.
    •  Protect the human health and food supply by reducing input of nutrients, toxic substances, and
       pathogens to the Gulf,
    •  Increase Gulf shellfish beds available for safe harvesting by 10 percent.
    •  Ensure that all Gulf beaches are safe for swimming and recreational uses.
    •  Reduce by at least  10 percent the amount of trash on beaches.
    •  Improve and expand coastal habitats that support migratory birds, fish, and other living
       resources.
    •  Expand public education/outreach tailored for each Gulf Coast county or parish.

This Public Health Action Agenda  supports these five year environmental
challenges.

For the public, the Gulf of Mexico Action Agenda should serve three purposes.
First, it should reflect  the public will with regard  to addressing public health
concerns. Second, it should communicate what activities are needed for
eliminating risk to public health  and provide the momentum for initiating these
actions; and third,  it should provide baseline information from which  success can be
measured.

This Action Agenda is a living document; therefore, the Gulf of Mexico Public
Health Subcommittee  anticipates that it will be periodically revised and updated.
The first formal review is scheduled for 1994.
Gulf of Mexico Public Health Action Agenda 4.1
                                                                              Iv

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Table of Contents
TABLE OF CONTENTS
 LIST OF TABLES	vll

LIST OF FIGURES	v'lll


 I.       OVERVIEW OF THE GULF OF MEXICO	..1

         The Gulf of Mexico -A Vast and Valuable Resource .......................1
         The Gulf of Mexico - A Resource at Risk.....	3
         The Gulf of Mexico Program • Goals and structure	4
         The Public Health Subcommittee	8


 II.      PUBLIC HEALTH ISSUES IN THE GULF OF MEXICO......	1O

         Public Health  Concerns.....	...............10
             Exposure to Pathogens From
                 Consumption of Raw Molluscan Shellfish.	..........12
             Marine Bl&toxlns...	..........18
             Toxic Substances...........	..........................22
             Exposure Ho Pathogens In Gulf Waters............	...........28
         Economic Implications of Consumer Risk.............................29
         Summary......	«	...	3O


  III.     AGENCY FRAMEWORK AND EXISTING LEGISLATION .......32

           Federal Level.	...32
                Federal Statutes............	32
                Involved Federal Agencies...	38
                Interagency Coordination....	.........*....................49
          Regional Level...........	SO
          Stale Level....	52
               Highlights of Current State Programs,
                  Standards & Activities	.56
                      Alabama	.........56
                     Florida	,	58
                     Louisiana	59
                    Mississippi...	.....61
                   Texas	...62
 Gulf of Mexico Public Health Action Agenda 4.1

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 Table of Contents
IV.
 V.
          THE UNFINISHED AGENDA [[[ 63

          Goals .............. .
         Strategies, Objectives, and Action Items ............................. 64
               Research and Demonstration ................... . ........... .......65
               Monitoring/Assessment ......... . ........................... .. ......... 68
               Standards/Enforcement ......................................... ........74
               Public Outreach...... ....... . ............ . ................ ....
         CONCLUSION
 BIBLIOGRAPHY. [[[ . ............. .

 APPENDIX A Acronym Guide .......... . [[[ 91


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List of Tables
 LIST OF TABLES



Table 1.1     Gulf of Mexico Coastal Population per
             Shoreline Mile	,	3

Table 2.1     Consensus of the Importance of Public
             Health Hazards In the Gulf.....	11

Tablo 2.2    Microorganisms Responsible for Causing Adverse
             Human Health Effects	13

Table 2.3    Distribution of Gulf of Mexico
             Classified Estuarine Waters, 1985 and 1990	16

Table 2.4    Hazards and Risks of Seafood
             Consumption and Their Control....	19

Table 2.5    Properties & Effects of Metals
             of Primary Concern In Marine Environments.......	...24

Table 2.6    Properties & Effects of Major
             Classes &f Organic Chemicals In Wastes
             Disposed of In Marine Environments.....	.....26

Table 3.1    National Shellfish Sanitation Program
             (NSSP) State Program Evaluations	40

Table 3.2    State Fishery Management Institutions
             In the Gulf of Mexico.	53

Table 3.3    State Authorities Responsible for NSSP
             Evaluation Segments.	SS
 Gulf of Mexico Public Health Action Agenda 4.1
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  List of Figures
  LIST OF FIGURES
  Figure 1.1          Gulf of Mexico Program Committees	6
Gulf of Mexico Public Health Action Agenda 4.1
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Overview of the Guff of Mexico
                                         Chapter I
I.
OF THE GULF OF MEXICO
The Gulf of Mexico • A Vast and Valuable Resource

Bounded by a shoreline that reaches northwest from Florida along the shores of
Alabama, Mississippi, and Louisiana, and then southwest along Texas and Mexico,
the Gulf of Mexico is the ninth largest body of water in the world.  The Gulf's
United States coastline measures approximately 1,631 miles—longer than the Pacific
coastline of California, Oregon, and Washington.  The Gulf region covers more than
617,600 square miles and contains one of the nation's most extensive barrier-island
systems, outlets from 33 major river systems, and 207 estuaries (Buff and Turner,
1987).  A cornerstone of the Nation's economy, the Gulf's diverse and productive
ecosystem provides a variety of valuable resources and services, including
transportation,  recreation, fish and shellfish, and petroleum and minerals.

Encompassing over five million acres (about half of the national total), Gulf of
Mexico coastal wetlands serve as essential habitat for 75 percent of the United States'
migrating waterfowl (EPA, 1.991a).  Mudflats, salt marshes, mangrove swamps, and
barrier island beaches of the Gulf also provide year-round nesting and feeding
grounds for abundant numbers of gulls, terns, and other shorebirds. Five species of
endangered whales, including four baleen whales and one toothed whale, are found
in Gulf waters. These waters also harbor the endangered American crocodile and
five species of endangered or threatened sea turtles (loggerhead, green, leatherback,
hawksbill, and Kemp's Ridley).  The endangered West Indian (or Florida) manatee
inhabits waterways and bays along the Florida peninsula.

In addition, a complex network of channels and wetlands within the Gulf shoreline
provides habitat for estuarine-dependent commercial and recreational fisheries.
The rich waters yield approximately 2.4 billion pounds of fish and shellfish each
year. Worth more than $780 million at dockside (estimated total economic impacts
of $2.34 billion), this harvest represents 40 percent of the total annual domestic
harvest of commercial fish (DOC, 1992). The Gulf boasts the largest and most
valuable shrimp  fishery in the United States,  and also produces more than half of
the yearly national harvest of oysters (DOC, 1992). Other Gulf fisheries include
diverse shellfisheries for crabs and spiny lobsters, and finfisheries for menhaden,
herring, mackerel, tuna, grouper, snapper, drum, and flounder. The entire U.S.
Gulf of Mexico fishery yields more finfish, shrimp, and shellfish annually than the
South and Mid-Atlantic, Chesapeake, and New England regions combined.

 The Gulfs bountiful waters draw millions of sport fishermen and beach users to
 their shores each year. It is estimated that the Gulf supports more than one-third of
 the nation's  marine recreational fishing, hosting 4 million fishermen in 1985 who
 caught an estimated 42 million fish (DOC, 1992).  Popular nearshore catches include
 sea trout (weak fish), cobia, redfish, flounder, grouper, red snapper, mackerel, and
 Gulf of Mexico Public Health Action Agenda 4.1

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  Overview of the Gulf of Mexico
                                                                   Chapter 1
  tarpon; offshore catches include blue marlin, white marlin, sailfish, swordfish
  dolphin, and wahoo. Tourism related dollars in the Gulf Coast States contribute an
  estimated $20 billion to the economy per year (EPA, 1991a).

  Gulf oil and gas production are equally valuable to the region's economy and are a
  critical part of the nation's total energy supply. In 1990, more than 1,600 Outer
  Continental Shelf (OCS) leases were in production, yielding approximately 90
  percent of U.S. offshore production.  These OCS royalties annually contribute about
  $3 billion to the Federal Treasury. Thirty-eight percent of all petroleum and 48
  percent of all natural gas reserves in the United States are estimated to be in the Gulf
  of Mexico. The industry employs some 30,000 people in the region.

  Approximately 45 percent of U.S. shipping tonnage passes through Gulf ports,
  including four of the nation's busiest: Corpus Christi, Houston/Galveston, Tampa
  and New Orleans. The second largest marine transport industry in the world is
 located in the Gulf of Mexico. According to EPA, vessel trips in and out of
 American Gulf ports and harbors exceeded an estimated 600,000 trips in 1986  The
 U.S. Navy's Gulf Coast Homeporting Plan will dock at least 25 vessels in Ingelside
 TX, Pascagoula, MS, and Mobile, AL.

 Thousands of people depend on the Gulf of Mexico to earn a living and flock to its
 shores and waters for entertainment and relaxation. The temperate climate and
 abundant resources are attracting more and more people. The region currently
 ranks fourth in total population among the five U.S. coastal regions, accounting for
 13 percent of the nation's total coastal population. Although the Gulf region is not
 as densely settled as others, it is experiencing the second fastest rate of growth;
 between 1970 and 1980, the population grew by more than 30 percent (DOC, 19'90a)
 According to the U.S. Department of Commerce, the Gulf's total coastal population
 is projected to increase by 144 percent between 1960 and 2010, to almost 18 million
 people. Table 1.1 shows the Gulf of Mexico coastal population density or population
 per shoreline mile projected to the year 2010.  Florida's population alone is expected
 to have skyrocketed by more than 300 percent by the year 2010. The increasing
 coastal population is of concern with regard to public health issues because the
 population at risk increases, as well as the potential for environmental degradation.
Gulf of Mexico Public Health Action Agenda 4.1

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Overview of th& Gulf of Mexico
Chapter I
Table 1.1  Gulf of Mexico Coastal Popula tion per Shoreline Mile
State
Florida
Alabama
Mississippi
Louisiana
Texas
Gulf of Mexico
1960
433
599
527
248
798
429
1988
1064
800
928
352
1517
820
2010
1411
886
1102
420
1956
1046
(Source: DOG, 1990a)


The Gulfs resources and environmental quality are affected not only by the
millions living and working in the region, but also by activities occurring
throughout  much of the ncition.  Two-thirds of the land area of the contiguous
United  States drains into the Gulf, bringing with it potential environmental
problems associated with pesticides, fertilizer, toxic substances, and trash.
 The Gulf of Mexico •  A Resource At Risk

 Increasing populations result in increased use and demands on Gulf of Mexico
 resources.  Until recently, the Gulf was considered too vast to be affected by
 pollution and overuse.  However, recent trends indicate serious  long-term
 environmental damage unless action is initiated today.  Signs of increasing
 degradation throughout the Gulf system include the following (EPA, 1991a):


       D     Fish kills and toxic "red tides" and "brown tides" were an increasing
           ,-.  phenomenon in Gulf waters during the 1980s.

       Q     Alabama, Mississippi, Louisiana, and Texas are among those states that
             discharge the greatest amount of toxic chemicals into coastal waters.

       Q     More than half of the shellfish-producing areas along the Gulf Coast
             are permanently or conditionally dosed. These closure areas are
             growing as a result of increasing human population along the Gulf
             Coast.
 Gulf of Mexico Public Health Action Agenda  4.1

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  Overview of the Gulf of Mexico
                                                                  Chapter I
             Louisiana is losing valuable coastal wetlands at the rate of
             approximately 78-126 km2/year (30-50 mi2 /year). This represents
             approximately 80 percent of the coastal wetland loss for the contiguous
       Q


       Q



       O
Almost 1,800 kg/mi (2 tons/mi) of marine trash covered Texas beaches
in 1988.

Up to 7770 km2 (3,000 mi2) of oxygen deficient (hypoxia) bottom waters,
known as the "dead zone," have been documented off the Louisiana
and Texas coasts.

Gulf shoreline are eroding up to 30 m/year (100 ft/year). Few coastal
reaches in the Gulf can be characterized as "stable" or "accreting."
 The Gulf of Mexico Program • Goals and Structure

 Problems plaguing the Gulf cannot be addressed in a piecemeal fashion.  These
 problems and the resources needed to address them are too great.  The Gulf of
 Mexico Program was formed to pioneer a broad, geographic focus in order to address
 major environmental issues in the Gulf before the damage is irreversible or too
 costly to correct.

 The program is part of a cooperative effort with other agencies and organizations in
   i/iT   *T    6S' aS Wdl as with people and gfOUPs who use the Gulf.  In addition
 to EPA, other participating federal government agencies include: National Oceanic
 and Atmospheric Administration (NOAA), National Marine Fisheries Service
 (NMFS), U.S. Department of Defense (DOD), U.S. Fish and Wildlife Service (FWS)
 U.S. Soil Conservation Service (SCS), U.S. Minerals Management Service (MMS) '
 National Park Service (NPS), U.S. Coast Guard (USCG), National Aeronautics and
 Space Administration (NASA), U.S. Army Corps of Engineers (COE), Department of
 Energy (DOE), U.S. Geological Survey (USGS), U.S. Food and Drug Administration
 (FDA), and Agency for Toxic Substances and Disease Registry (ATSDR).

 The Gulf of Mexico Program also works in coordination and cooperation with  four
 National Estuary Programs (NEPs) within the Gulf:  Tampa Bay, Sarasota Bay
 Galveston Bay, and the Barataria-Terrebonne Estuary.  The Gulf of Mexico Program
 supports and builds on certain activities of these programs, bringing a Gulf-wide
 focus and forum for addressing issues of Gulf-wide concern.
Gulf of Mexico Public Health Action Agenda 4.1

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Overview of the Gulf of Mexico
Chapter I
By building on and enhancing programs already underway, as well as by
coordinating new activities, the Gulf of Mexico Program will serve as a catalyst for
change. The program's overall goals are to provide:
      Q    A mechanism for addressing complex problems that cross federal, state,
            and international jurisdictional lines;

      Q    Better coordination among federal, state, and local programs, thus
            increasing the effectiveness and efficiency of the long-term effort to
            manage and protect Gulf resources;

      Q    A regional perspective to address research needs, which will result in
            improved transfer of information and methods for supporting
            effective management  decisions; and

      Q    A forum for affected groups using the Gulf,  for public and private
            educational institutions, and for the general public to participate in the
            solution process.

The Gulf of Mexico Program is managed by three committees: a Policy Review
Board, a Technical Steering  Committee, and a Citizens Advisory Committee.
Composed of 20 senior level representatives of state and federal agencies and
representatives of the technical and citizens committees, the Policy Review Board
guides and reviews program activities.  The Citizens Advisory Committee is
composed of five governor-appointed citizens who represent environmental,
fisheries, agricultural, business/industrial, and development/tourism interests in
each of the five Gulf Coast States. This committee provides public input and
assistance in publicizing the Gulf of Mexico Program's goals and results.
Representatives of state and federal agencies, the academic community, and the
private and public sectors appointed by state governors or by the Policy Review
Board are members of the Technical Steering Committee and provide technical
support to the board.

During the early stages of program development, the Gulf of Mexico Program
established the following seven technical subcommittees, each co-chaired by one
federal and one state representative, to address priority environmental problems:

       Q    Habitat Degradation of such areas as coastal wetlands, seagrass beds, and
             sand dunes;

       Q    Freshwater Inflow (i.e.t diversions of water away from coastal
             estuaries) for use in flood control, navigation, and recreation, and to
             service growing coastal populations;

       Q    Nutrient Enrichment resulting from such sources as storm water,
             industries, arid agriculture;
 Gulf of Mexico Public Health Action Agenda 4.1

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  Overview of ffie Gulf of Mexico
                                                                       Chapter I
        Q


        Q


        Q


        Q
Toxic Substance and Pesticide contamination originating from
industrial and agriculturally based sources;

Coastal and Shoreline Erosion caused by natural and human-related
activities;

Public Health threats from swimming in and eating seafood products
coming from contaminated water; and

Marine Debris from land-based and marine recreational and
commercial sources.
 In December 1991, the Gulf of Mexico Program Policy Review Board approved the
 formation of an additional technical subcommittee to address Living Aquatic
 Resources. Two other subcommittees, the Public Education and Outreach
 Subcommittee and the Data and Information Transfer Subcommittee, support the
 other eight technical subcommittees.
 Figure 1.1
      Gulf of Mexico Program Committees
                                  POLICY REVIEW
                                    BOARD
                   TECHNICAL STEERING
                     COMMITTEE
                               CITIZENS ADVISORY
                                 COMMITTEE
                               SUBCOMMITTEES
                               • Hattta Degradation
                               • Marine Debris
                               > Freshwater Inltow
                               • Nutrient Enrichment
                               • Toxic Substances &
                                 Pesticides
                               • Data Information*
                                 Transfer
                               • Public Education ft
                                 Outreach
                               - PublicHeakh
                               • Coastal & Shoreline
                                 Erosion
                               • Living Aquafc
                                 Resources
Gulf of Mexico Public Health Action Agenda  4.1

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Overview of the Gulf of Mexico
Chapter I
The action planning process used by each Gulf of Mexico Program Subcommittee
includes the following key activities:

     Q     Definition of environmental issues;

     Q     Characterization of identified problems, including sources, resources,
            and impacts;

     Q     Establishment of goals and objectives;

     Q     Evaluation/assessment of corrective actions and control measures,
            including cost/benefit analysis;

     Q     Selection of priority action items;

     Q     Establishment of measures of success;

     Q     Implementation of actions; and

     Q     Evaluation of success and revision of the Action Agenda.


 As the Subcommittees progress through each of these activities, ample
 opportunities are provided for  public review, and Policy Review Board
 endorsement is requested at appropriate points.  Through the consensus of Program
 participants, a coordinated response will be directed to the successful maintenance
 and enhancement of resources  of the  Gulf of Mexico.
  Gulf of Mexico Public Health Action Agenda 4.1

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  Overview of the Gulf of Mexico


  The Public Health Subcommittee

  Co-Chairs!
  Dr. Frederick Kopfler
  Mr. Bobby Savoie

  Members;

  Dr. Ann Anderson
  Mr. Bruce Brackin
  Dr. David Cook
  Mr. Robert Dickey
  Mr. Spencer Garrett
  Dr. Anthony Guarino
  Dr. Brian Hughes
  Dr. Richard Hunter
  Mr. Robert P. Jones
  Mr. Jeff Kellam
  Dr. Marilyn B. Kilgen
 Mr. Donald Lirette
 Dr. Merrill McPhearson
 Dr. G. Malcolm Meaburn
 Ms. Cheryl Overstreet
 Dr. Raoul Ratard
 Mr. Lloyd Regier
 Mr. Dugan Sabins
 Mr. Donald Scharr
 Dr. Karen Steidinger
 Dr. Jerry Stober
 Mr. Richard Thompson*
 Dr. Carmelo R. Tomas
 Dr. Charles Woernle

 'Previous Co-Chair 1988-1991
 EPA Gulf of Mexico Program
 Louisiana Department of Health and Hospitals
 Tulane School of Public Health and Tropical Medicine
 Mississippi State Dept. of Health
 Gulf Coast Research Laboratory
 Food and Drug Administration
 National Marine Fisheries Service
 Food and Drug Administration
 Alabama Dept. of Public Health
 Florida Dept. of Health and Rehabilitative Services
 Southeast Fisheries Association (Alternate CAC Rep)
 Agency for Toxic Substances and Disease Registry
 Nicholls State University
 Concerned Shrimpers (CAC Rep)
 Food and Drug Administration
 National Marine Fisheries Service
 U.S. EPA Region 6
 Louisiana Office of Public Health
 National Marine Fisheries Service
 Louisiana Dept. of Environmental  Quality
 Mississippi Gulf Coast Regional Wastewater Authority
 Florida Marine Research Institute
U.S. EPA Region 4
Texas Department of Health
Florida Marine Research Institute
Alabama Dept. of Public Health
Gulf of Mexico Public Health Action Agenda 4.1

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Overview of the Gulf of Mexico
Chapter I
The Public Health Subcommittee developed the following goals for addressing
public health issues in the Gulf of Mexico:


      Q     Prevent adverse health effects resulting from consumption of
            raw shellfish harvested from the Gulf of Mexico.

      Q     Prevent illness resulting from exposure to marine biotoxins in coastal
            waters of the Gulf of Mexico.

      Q     Reduce  long term health risks from exposure to toxic substances in
            Gulf of  Mexico seafood while maintaining the beneficial effects of
            seafood consumption.

      Q     Prevent exposure to pathogens in coastal waters of the Gulf of Mexico.


The Gulf of Mexico Policy Review Board endorsed these goals on November 8,1990.
In developing this Action Agenda, the Public Health Subcommittee has sought
input and advice from other technical Subcommittees as well as from organizations,
interest groups, and  private concerns outside of the Gulf of Mexico Program. A
"brainstorming meeting" sponsored by the Subcommittee in New Orleans, LA, on
November 6-8,1991, to review an early version of the Action Agenda, was attended
by approximately 40 persons comprising a mix of Program and non-Program
participants. This meeting generated a significant number of comments that were
addressed in the present document.
  Gulf of Mexico Public Health Action Agenda 4.1

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Public Health Issues In the Gulf
Chapter II
II.  PUBLIC HEALTH ISSUES IN THE GULF OF MEXICO
Public Health Concerns

Many pollutants found in Gulf of Mexico waters have the potential to produce acute
and chronic human health effects.  Whether these pollutants pose human health
risks depends upon the specific characteristics of the pollutants (e.g. whether they
biodegrade or are persistent), as well as their potential to reach and thereby cause
adverse impacts in humans.

Humans can be exposed to potentially hazardous  contaminants in the Gulf of
Mexico through two principal pathways-indirectly through consumption of fish
and shellfish, and directly from contact with water and aerosols.  Consumption of
contaminated seafood can be a significant route of exposure to toxic organic
chemicals and metals because these substances are able to persist and accumulate in
fish and shellfish. Exposure to toxic constituents from water contact is generally
considered to be less significant, except near storm drains, industrial discharges, and
sewage overflow points.  In the case of human pathogens, exposure through contact
or consumption of contaminated food can be significant because only small
numbers of microorganisms may be necessary to cause acute illness.

During its initial year, the Public Health Subcommittee developed a list of agents of
public health concern and various potential routes for human exposure, and
reached consensus on their relative importance within the Gulf of Mexico  (See
Table 2.1).
 Gulf of Mexico Public Health Action Agenda 4.1
                                                                         1O

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 Public Health Issues in the Gulf
                                               Chapter II
Table 2.1
Consensus of the Relative Importance of Public
Health Hazards in the Gulf of Mexico
Exposure Route
Solid Waste1 Molluscan
Aeent SW MW MD Shellfish Finfish Crustacea
Pathogens
Vibrio2* L L
NorwalkS U L
Toxic Substances
PCBs4 H L
Hg5 H L
Toxins
NSP6 0 0
CFPZ 0 0
1 SW = Solid & Hazardous (to
MW = Medical Waste; MD =
2 Naturally occurring
3 Contaminant
4 Organic
5 Inorganic
6 Neurotoxic shellfish poison
7 Ciguatera fish poison
*Note: Vibrio exposure is "H"
L H L L
L H L L
L U U U
L H HLocal HLocal
0 H U L/M
0 L H L
the extent not covered by MW and MD) Waste;
Marine Debris
for immuno-compromised individuals.
Direct
Water Air
M 0
M U
U U
L U
L/M M
0 0
H= High
M= Medium
L=Low
U= Unknown
0= None
    (Source: Gulf of Mexico Program Public Health Subcommittee, 1989)

 Using this matrix, the Subcommittee identified four potentially significant public
 health problems. These problems in priority order are:

 1.     Exposure to pathogens via consumption of raw molluscan shellfish;

 2.     Marine biotoxins (such as ciguatera fish poisoning) and their effect on
       human  health;

 3.     Toxic substances (such as mercury) in the food chain, the potential for
       biomagnification and human health effects caused by consumption; and

 4.     Exposure to pathogens in Gulf waters from recreational or occupational
       contact.

 These public health issues are discussed in greater detail in the following sections.
 Gulf of Mexico Public Health Action Agenda 4.1
                                                                          11

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  Public Health Issues In the Gulf
                                                                   Chapter li
       »«
  Shellfish
                             Via Consumption of Raw Mollusean
 The Gulf of Mexico, a multiple use estuarine system affected by human waste
 contains the most classified shellfish-growing waters (almost 9,000 square miles) in
 the U.S.  About 3,800 square miles of these are approved for harvesting.  However
 more than half (about 52 percent) of all classified waters in the region have
 regulatory limitations on harvest or harvest is prohibited (NOAA 1991)  In
 Galyeston Bay, 44.9 percent of the total 334,565 acres of shellfish beds are polluted
 (Galveston Bay National Estuary Program, 1991).

 Almost 15 million pounds of oyster meats were harvested in Gulf waters in 1989
 (NOAA, 1990). Commercial harvest occurs throughout the region, from Charlotte
 Harbor to Laguna Madre, and is especially significant in Apalachicola Bay and
 Breton/Chandeleur Sounds, Most harvest limitations are on a conditional basis
 depending on freshwater inflow from highly variable rainfall.  Most of the region's
 productive reefs are in these conditional areas (DOC, 1990).

 Shellfish are non-moving or slow-moving, filter-feeding organisms that cannot
 escape pollution; they concentrate the microorganisms  in that pollution  or any
 other disease-causing agerit, to many times higher than the level to which they are
 exposed. Although only a tiny fraction of all seafood consumed in the U.S.  involves
 mplluscan shellfish consumed live, raw, and whole, including the intestinal tract
 this accounts for approximately 85% of all seafood related illness (FDA, 1991). More
 people get sick from eating raw oysters, clams, and mussels than from any other
 seafood (NAS, 1991). Most illnesses are mild, but a small number can be serious  and
 even fatal, specifically in high risk individuals exposed  to pathogens such as Vibrio
 vulmficus (See Table 2.4 for Hazards and Risks of Seafood  Consumption).

 Two types of pathogenic microorganisms are transmitted to the consumer bv raw
 molluscan shellfish (See Table 2.2):

 •     naturally occurring marine organisms; and

 *     pollution-related or man-induced pathogenic bacteria and viruses.

 Illness associated with consumption of oysters from the  Gulf that are not associated
 with the classification of the growing area are those caused  by naturally occurring
 marine vibrios. These marine bacteria may cause illnesses  particularly in shellfish
 consuming persons whose immune system has been compromised.  This immuno-
suppression has been associated with underlying diseases such as diabetes, cirrhosis
alcoholism, hemochromatosis, etc.                                            '
Gulf of Mexico Public Health Action Agenda 4.1
12

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Public Health Issues In the Gulf
                                                       Chapter II
       Table 2.2   Microorganisms Responsible for
                           Causing Adverse Human Health
                           Effects* (NOAA, 1988)
       Disease
Pathogenic Organism
               Seafood Source
       Hepatitis
 riepatitis A virus
                       SIon-A and non-B hepatitis
raw oysters, steamed and raw clams, cockles
                          raw molluscan shellfish
       Gastroenteritis
Aeromoiws hydrophilia
  andPlesiomonas shigelloides
                       Vibrio mimicus
                       Vibrio parahaemolyticus
                       Vibrio vulnificus
                       Vibrio cholera, O group
                       Vibrio cholera, Non-O group 1
                       Norwalk virus
                       Small round structured virus
                       Campylobacter ieiuni
                                                shellfish
                                                 raw oysters
                          clams, snails, raw oysters, crab, shrimp, lobster
                          raw oysters
                          raw oysters, boiled shrimp, boiled crab
                          raw oysters
                          raw oysters, raw clams
                                                 raw oysters
                          raw clams
      "Includes naturally occurring microorganisms as well as microorganisms associated with pollution.

      Note: At least 11 species of Vibrio are associated with human disease, some from gastroenteritis, but abo from
      systemic infections. Also, species of Salmonella and Shigella are associated with typhoid.

      (Source: EPA, 1991)
Gulf of Mexico Public Health Action Agenda 4.1
                                                                  13

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  Public Health Issues In the Gulf
Chapter II
 Indigenous Vibrio species associated with contamination of shellfish include V.
 parahaemolyticus, V. vulnificus, and other species.  Consumption of seafood
 contaminated with V. parahaemolyticus has been associated with outbreaks of
 gastroenteritis, while consumption of V. TO/m/fcus-contaminated shellfish can
 result in primary, frequently fatal, septicemia (blood poisoning) in patients with
 liver disorders and in diabetic or immuno-compromised individuals (NAS, 1991).

 The most significant public health concern in the Gulf of Mexico is with those
 pathogens (i.e., Norwalk and Norwalk-like viruses) that have caused several
 thousand illnesses between 1978 and 1987, but no deaths (Kaplan et al, 1982). The
 preponderance of evidence indicates that the etiologic agent for water-borne
 outbreaks of acute gastroenteritis (AGI) are the Norwalk-like viruses (Kaplan et al,
 1982). Because these pathogens are pollution related, something can be done about
 this public health concern.

 Many of these pathogenic microorganisms have been associated with both point and
 npnpoint source pollution.  For example, Hepatitis A virus (HAV) and, Norwalk
 viruses may be present in seafood as a result of fecal pollution from municipal
 discharges, industrial/agricultural discharges, and surface water runoff.  Of these
 sources, municipal wastewater sewage presents the greatest risk of infectious disease
 via direct contact through recreational activities such as swimming and surfing, and
 consumption of seafood.  Municipal wastewater treatment plants are numerous
 throughout  the Gulf region (DOC, 1990). Storm water runoff may contribute to this
 problem as well.  Although storm water typically contains little human fecal waste,
 this runoff may contribute pathogens due to animal waste.

 In addition, bacteria responsible for typhoid and cholera are known to be water- and
 seafood-borne.  These pathogens can enter the estuarine environment through the
 discharge of raw sewage, wastewater effluent from sewage treatment plants, failing
 or inadequate septic tanks, and the dumping of sewage sludge (OTA, 1987).
 Shellfish-associated cholera-like disease caused by non-01 strains of  V. cholerae is
 infrequent.  A few cases of Asiatic cholera due to non-01 strains of the organism
 have been detected in specific locations in the Gulf of Mexico,

 Septic tanks and other forms of on-site sewage disposal systems (OSDS) are
 commonly used to dispose of sewage from residences in Gulf rural areas. Septic
 tanks in coastal areas and estuarine watersheds may represent a major source of
 disease-causing microorganisms in coastal waters. Such systems are relatively
 inefficient at degrading human wastes unless several conditions are maintained,
including unsaturated soil conditions, minimal densities, and routine pumping of
solids from the tank.  Discharges from boats and ships may be a source of diseases as
well.
Gulf of Mexico Public Health Action Agenda 4.1
       14

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 Public Health Issues In the Gulf
Chapter II
Public health problems are aggravated because many of the best shellfish growing
waters are located in close proximity to discharges of sewage and other wastes. This
phenomenon is increasingly evident in highly developed coastal areas, as shellfish
flourish in low salinity nearshore waters.

The National Shellfish Sanitation Program and the Interstate Shellfish Sanitation
Conference are charged with ensuring that shellfish brought to market are as safe as
possible (see description in Chapter El). Each state shellfish growing area is required
to be correctly designated by the state shellfish control authority with one of the
following classifications, as described  in Part I,  Section C, of the NSSP Manual of
Operations  (Table 2.3 shows classification percentages by Gulf State for 1985 and
1990):

Q    Approved Area - A growing area that has been approved for growing or
      harvesting shellfish for  direct marketing. An approved shellfish growing
      area may be temporarily dosed when a public health emergency is declared
      (i.e., hurricane or flooding).

Q    Conditionally Approved Area - A growing area determined to meet approved
      area criteria intermittently.  The area is closed when approved area criteria are
      not met, and the conditions affecting this degradation of the water quality
      must be predictable and specified  in a management plan.

Q    Restricted Area - An area from which shellfish may be harvested only if
      permitted and subsequently subject to a suitable and effective purification
      process.

B    Conditionally Restricted Area - An area that meets restricted area criteria
      intermittently. The area is closed  when restricted criteria are not  met, and the
      conditions affecting the degradation of water quality must be predictable and
      specified in a management plan.

Q    Prohibited Area - An area prohibited for the harvesting of shellfish for any
      purpose except depletion thereby eliminating the potential for illegal harvest.

Growing areas are classified on the basis of sanitary and marine biotoxin survey
information. All state coastal and estuarine shellfish growing areas that have not
been  surveyed are designated as prohibited. All closures and classifications are the
primary responsibility of the state shellfish control authority. In 1990, 48% of
shellfish growing waters were approved Gulf-wide; 34% were prohibited; 16% were
conditionally restricted or approved; and 2% were restricted.
 Gulf of Mexico Public Hea/th Action Agenda 4.1

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  Public Health Issues in the Gulf
Chapter II
   Table 2.3     Distribution of Gulf of Mexico Classified Estuarine
                  Waters, 1985 and 199O
	 	 rercein isiassiTiea 	 • — —
State
Florida*
Alabama
Mississippi
Louisiana
Texas
Total % of Gulf of
Mexico Waters
1985 1990
28 15
16 15
35 64
52 56
80 56
54 48
1985 1990
33 35
24 28
25 15
24 35
20 37
24 34
1985 1990
39 43
60 57
40 8
13 10
<1 7
17 16
1985 1990
0 5
0 0
1 13
11 0
0 0
6 2
   •Note: 1990 data from Florida is incomplete by 2%.

   (Source: NOAA,I991)
While NSSP provides guidelines for shellfish growing area classification, none of
the Gulf Coast States is in total compliance with these guidelines. Often this is a
result of inadequate financial resources, a poor understanding of the preventative
nature of classification and inspection activities, and a lack of patrol and
enforcement of shellfish closures.

Various regulatory strategies are available to address pollution related concerns. For
example, to ensure proper conditions are maintained by those using septic tanks,
several strategies can be undertaken, such as increasing the number of field
inspectors to detect and assist in the prosecution of those with failing systems.
Another low-cost and effective option to ensure proper functioning of OSDSs in
coastal areas would be to require an operating permit for  system users.  A permit
renewal could be required every few years, and a renewal granted only if an
inspection proved that the system was functioning properly.
Gulf of Mexico Public Health Action Agenda 4,1
       16

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 Pubffo Health Issues in the Gulf
Chapter If
There are several types of OSDSs that greatly reduce levels of disease-causing
microorganisms. These include composting toilets, incinerator toilets, and aerobic
systems that use methods similar to those used by municipal sewage treatment
plants. The widespread use of improved OSDSs in critical areas, coupled with
requirements for system operating permits, would substantially reduce the input of
disease-causing effluents to the Gulf of Mexico.

In addition, the Subcommittee recommends a broad education effort to
communicate the risks and significance of contaminated seafood.  Fishermen and
the public should know why shellfish beds are closed, the potential impacts to a
large human population from eating contaminated shellfish, and the penalties that
could be levied for violating the law.  Consumers need information that would help
in the selection and purchase of uncontaminated seafood.  Finally, education of
district attorneys and judges about populations at risk and potential harm to
shellfish consumers is needed to establish appropriate penalties for violations.
 Gulf of Mexico Public Health Action Agenda 4.1
         17

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  Public Health Issues in the Gulf
Chapter li
 Marine Blotoxlns (and their effect on human health)

 Marine biotoxins are natural products produced by a variety of marine plants and
 animals.  Marine dinoflagellates, algae classified under the division Pyrrhophyta,
 are among the most prolific biotoxin producers known.  Other divisions of algae,
 bacteria, and cyanobacteria are also known to produce biotoxins which can have a
 severe impact on human health.

 Most of the known biotoxins are heat stable, odorless, colorless,  and otherwise
 completely undetectable by the human senses. Many biotoxins can accumulate in
 important seafood species in the marine environment and cause human  illness
 when consumed.  A few of the biotoxins can become airborne in coastal aerosols,
 causing respiratory irritation; others are known to cause contact dermatitis.

 In most cases methods of seafood preparation will not purge biotoxins from suspect
 seafood. Detection of biotoxins in seafood products is currently possible only by
 cumbersome laboratory methods, although enzyme immuno-assay technology for
 generic detection of some biotoxins is rapidly approaching the point of commercial
 application.

 Gulf waters contain the majority of known toxin producing species. There are two,
 definite, three probable, and several potential marine biotoxin threats to public
 health. The two definite threats are human illness caused by Neurotoxic  Shellfish
 Poisoning (NSP) and Ciguatera Fish Poisoning (Ciguatera) (See Table 2.4).

 Neurotoxic Shellfish Poisoning is caused by the planktonic, vegetative stage of a
 dinoflagellate.  The species, Gymnodinium breve, causes water column blooms and
 can kill fish through respiratory inhibition. Although it can  kill fish and some
 invertebrates, the  toxin of Gymnodinium breve accumulates in oysters and other
 molluscs without harming them, and is responsible for NSP, which can occur
 throughout the Gulf.  These organisms can form extensive "red  tides" which have
 also been responsible for massive mortalities of marine life in the Gulf, as  well as
 along the southeast U.S. coast. Red tides are perennial in southeast Florida and
 noteworthy red tides have also been recorded  in Corpus Christi Bay, Texas. In 1986,
 one covered almost the entire Texas coast.

 Gymnodinium breve toxins can cause human  illness if toxic shellfish  meats are
 consumed. Cooking of shellfish does not destroy the toxic properties. Neurological
 symptoms of NSP are dizziness, tingling sensations in the extremities, and dilated
 pupils, which usually disappear within 3 days. No human fatalities have been
 documented with NSP (Steidinger, 1983). The toxin also affects humans directly
 when the blooms of the algae come near shore and the toxin is aerosolized by the
surf.  This "red tide aerosol" effect causes respiratory irritation which is short-lived
when the affected person leaves the beach or uses a mask to filter out the toxin.
Gulf of Mexico Public Health Action Agenda 4.1
       18

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  Public Health Issues jfn the Gulf
                                                        Chapter II
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 Public Health Issues In the Gulf
Chapter li
 Ciguatera toxins are produced by a group of epiphytic dinoflagellates.  Any one of a
 large variety of shore or reef fishes, which are usually subtropical or tropical, could
 carry ciguatera toxins, and thus cause poisoning if ingested.  Ciguatera is a fish-borne
 disease whereby the biotoxin or its derivatives are accumulated through the food
 web and biomagnified in the flesh of higher carnivores, particularly reef fishes
 (Steidinger, 1983). There is no evidence of a seasonal incidence in ciguatoxicity, but
 the spawning season in some of the large predacious fishes may be a more
 dangerous period than the other seasons of the year (Halstead, 1967).  In the Gulf,
 ciguatera toxins are  prevalent in south Florida and may possibly exist in Texas.
 Outbreaks of ciguatera are sporadic, unpredictable, and not necessarily preceded by
 noticeable algal blooms or red tide events. There is no way to detect a ciguatoxic fish
 by its appearance, and the degree of freshness has no bearing on its toxicity. The
 most recent outbreak in the Gulf region occurred in south Florida in 1988.

 Ciguatera fish poisoning is often confused with other forms of gastrointestinal
 disturbances, particularly bacterial food poisonings, and other types of fish
 biotoxications. The disease is caused by a specific poison, or complex of poisons,
 which affect primarily the gastrointestinal and nervous systems  of humans.
 Ciguatera, like many other diseases, may vary greatly in its clinical manifestations
 depending upon the toxicity of the fish that is eaten, the individual's  sensitivity to
 the poison, amount of fish ingested, and  other factors (Halstead,  1967). Symptoms
 range from nausea, abdominal cramps, weakness, and  numbness to severe
 neurotoxic effects, lasting over a period of years, and even resulting in death.

 The three probable marine biotoxin threats are Diarrheic Shellfish Poisoning (DSP),
 Amnesic Shellfish Poisoning (ASP), and Tetrodotoxic Fish Poisoning  (Pufferfish
 Poisoning). Although no cases of human poisoning from any of these sources have
 been identified in the Gulf, undiagnosed or misdiagnosed symptoms corresponding
 to these forms of seafood poisoning may well have occurred.

 Diarrheic Shellfish Poisoning is caused by the consumption of shellfish  that have
 accumulated toxins produced by several species of the dinoflagellate genus
 Dinophysis and possibly Prorocentrum. Human illness  caused by DSP has not been
 confirmed on  the Gulf Coast; however, several species of Dinophysis implicated in
 toxicity of shellfish elsewhere have been identified from Gulf waters.  Furthermore,
because of the close similarity in human symptomatology, it is possible for DSP to be
misdiagnosed as a commonplace bacteria-related gastrointestinal disorder.
Outbreaks of diarrheic shellfish poisoning are not necessarily preceded by algal
bloom or red tide events. Low levels of  the causative dinoflagellates over shellfish
beds are sufficient to cause toxicity in shellfish.
Gulf of Mexico Public Health Action Agenda 4.1
       20

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 Public Health Issues lin the Gulf
Chapter II
Amnesic Shellfish Poisoning is caused by the consumption of shellfish that have
accumulated toxins produced by the diatoms Nitzschia pungens f. multiseries and
Amphora cofaeiformis.  Algal bloom or red tide events appear to precede the
occurrence of toxic shellfish. Confirmed cases of ASP have not been reported from
the Gulf Coast; however, N. pungens has been identified in plankton samples taken
from Galveston Bay. As is the case with DSP, medical records have not been
evaluated for undiagnosed or possible misdiagnosed symptoms corresponding to
this form of seafood poisoning.

Pufferfish Poisoning is caused by the consumption of puffeffish (blowfish) that have
accumulated tetrodotoxin, a potent toxin of unconfirmed origin. Human cases of
pufferfish poisoning have not been reported from the Gulf of Mexico. Insufficient
information is available to determine the potential for this type of seafood
poisoning in the Gulf of Mexico; however, the toxicity of pufferfish  is generally
thought to be widespread.

Other potential biotoxin threats are represented by species which are known to be
toxic but are poorly understood in the Gulf of Mexico.  These species include
Alexandrium tamarensis,  A, monilatum, A. tropicale, Gymnodinium catenatum, G.
nagasakiense, Prorocentrum  minimum, P. treistenum,  and P. lima.  Several species
of toxic chloronomads, marine bacteria, and cyanobacteria are also known to exist in
the Gulf of Mexico.  However, none of these species have been directly associated
with human illness in the Gulf  area.

There are data and  information gaps concerning the levels of marine toxins in
seawater and seafood that may present a risk to human health, as well as the best
monitoring methods to prevent contaminated products from being introduced into
the market.  There also are data gaps with regard to the survivability, transmission,
and lifecycles of pathogenic microorganisms and dinoflagellates in the marine
environment.  Research in these areas may help control the potential health threat
from exposure. Presently, public health protection depends on control at harvest
sites, so it is important to transfer the results of research and new technologies to the
industry.

In addition, with regard to information transfer, a communication network needs to
be set up to inform "downstream" areas of the presence of phenomena such as toxic
blooms and red tide events. An early warning information network could  alert
downstream states of these problems and activate specific monitoring for early
detection of potential problems.  Efforts can be coordinated within existing facilities
which have set up response teams for detecting and regulating toxic bloom
problems.  Communication and coordination of technical  expertise in these areas is
of critical importance to the Gulf region.
Gulf of Mexico Public Health Action Agenda 4.1
        21

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 Public Health Issues In the Gulf
Chapter li
Toxic Substances (In the food chain, the potential for
blomagnlflcatlon and human health effects caused by consumption)


The Gulf of Mexico region has more point sources of pollution (over 3,700) than any
other region in the Nation (NOAA, 1990). This is a region with concentrations of
industrial activity associated with oil and gas production and development.  Over
half of the point source discharges are industrial facilities, and many of these are
petrochemical discharges.  Galveston Bay, TX, has the greatest concentration of point
sources, followed by Mississippi Sound (DOC, 1991).

In 1982, it was estimated that approximately 11.7 million pounds of commonly used
pesticides were applied to agricultural lands in the Gulf of Mexico region, the most
among all U.S. regions. The average application of pesticides was 366 pounds per
square mile.  Apalachicola Bay, FL, had the highest intensity of application in the
region (1,041 pounds per square mile), followed  by Apalachee Bay, FL, (1,023 pounds
per square mile) (Pait et dl., 1989).

Quantifying the potential human health effects  resulting from exposure to toxic
chemicals present in the marine environment is difficult since the effects may not
take the form of an obvious acute effect.  Few studies have been able to actually
measure the impacts of exposure to toxic chemicals (D'ltri and D'ltri, 1977);
however, this should not necessarily imply that  effects do not occur.  Exposure to
toxic chemicals may induce chronic effects such as an increased incidence of cancer
which may not yet be detectable in an epidemiological study of an exposed
population.

According to the National Academy of Sciences (NAS, 1991), the levels of toxic
chemicals in seafood in certain areas are high enough to warrant additional control
measures. It is suspected, however, that the risks from toxic chemicals are not on
the order of magnitude of environmental health hazards associated with human
pathogens for the population as a whole (NAS,  1991), although certain groups
within the population may be at high risk (e.g., recreational and subsistence
fishermen, children, and pregnant women).

The Subcommittee decided that direct exposure  to hazardous waste (where it occurs)
is a problem in the Gulf of Mexico.  However, little  information is available about
the frequency of exposure in the Gulf States.  The Subcommittee classified toxic
chemicals as organic and inorganic compounds.  It is known that inorganic
contaminants, such as mercury, accumulate in both  fish and shellfish consumed by
humans. The potential for exposure to organic toxic contaminants through
biomagnification in the food chain is not well documented.  Some toxic substances
introduced into Gulf Coast waters may bioaccumulate in the food chain and may
cause illness at some levels.
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 Public Health Issues In the Gulf
Chapter II
Toxic chemicals of primary concern have the following properties:

G     High persistence in the aquatic environment;

Q     High bioaccumulation potential;

Q     High toxicity to humans; and/or

Q     Common chemicals released to the environment by human activity (EPA,
      1989).

Chemicals with these properties that have been found in fish tissue and the marine
environment include dioxins and furans; polychlorinated biphenyls (PCBs);
polycydic aromatic hydrocarbons (e.g., benzo(a)pyrene); pesticides; and heavy metals
such as arsenic, lead, mercury, and selenium. In addition, a variety of potentially
toxic chemicals are introduced into the marine environment from aquaculture.
Chemotherapeutic drugs such as sulfonamides and nitrofurans are the primary
aquaculture chemicals of concern to human health (NAS, 1991).  Although the
effects of many of these compounds on different organ systems in man and/or
animals are known, it is difficult to establish with certainty the degree of hazard
posed by their presence in seafood. This is because of a lack of information on the
exact concentrations present in edible fish tissue and, in the case of metals, the form
in which they exist (e.g. inorganic vs. organic, oxidation states, etc.).  Moreover, the
health effects of exposure to complex chemical mixtures, and the relationships
between chemical contaminants and susceptibility to infectious disease need to be
studied.

Arsenic, cadmium, lead, and mercury are particularly important because of their
known or potential toxicity to humans and their presence in relatively high
concentrations in wastes disposed of in estuaries and coastal waters.  Metals of
secondary concern include chromium, copper, and selenium.  Other toxic metals are
present in much lower concentrations, both in wastes and in regions of the marine
environment that  are likely to lead to human exposure (OTA, 1987).  In marine
environments, consumption of contaminated seafood is generally the major route
of human exposure to metals. Direct human exposure to metals is usually less
important because they are generally present in very low concentrations in the
water column  (OTA, 1987).
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        23

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 Public Health Issues In the Gulf
                                                 Chapter II
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Gu// of Mexico Public Health Action Agenda 4.1
                                                         24

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 Public Health Issues Sn the Gulf
Chapter II
Bioaccumulation and biomagnification are important processes that largely
determine the potential for indirect human exposure to toxic metals and organic
chemicals.  Marine organisms, especially benthic organisms, can bioaccumulate
metals by filtering water during feeding or swimming, ingesting particulate matter
onto which such substances are absorbed, or ingesting other contaminated
organisms (OTA, 1987).  Biomagnification of a metal can result in an increase in an
organism's  tissue concentration of several orders of magnitude or more, and hence
represents a major potential pathway for human exposure.

Even when bioaccumulation is not a factor, significant quantities of metals can
concentrate in the gut or gills of marine organisms without actual absorption into
the tissues. This is especially true for shellfish that filter large quantities of seawater
and ingest solid matter during feeding. Because people generally eat these
organisms whole, toxic substances can be passed to humans even in the absence of
any actual bioaccumulation.  This mechanism probably accounts for most instances
of shellfish contamination involving metals that do not bioaccumulate (OTA, 1987).

Toxic metals are capable of inducing a variety of human health effects—lethal and
sublethal, acute and chronic. Some of the known properties and effects of exposure
to the metals of primary concern in marine environments are summarized in Table
2.5.

Organic chemicals vary considerably with respect to their behavior and toxicities in
natural environments. Given this complexity, it is essential to use some type of
simplified classification if a health hazard evaluation is to become manageable
(OTA, 1987).  One approach is to classify compounds according to how they behave
in the environment, thus concentrating on those substances that have a potential to
reach humans; information  on human health effects would then need to be
developed for only this group.

As is the case for metals, the consumption of contaminated seafood is the primary
pathway for human exposure to most organic chemicals (See Table 2.6).  Indeed,
compounds such as PCBs and DDT have been shown to accumulate in humans
through consumption of contaminated seafood (OTA, 1987).  The importance of
bioaccumulation and biomagnification varies greatly for different organic chemicals
and for different organisms, and there is relatively little information on the  long-
term fate and behavior of most organic compounds in marine environments.

Few documented cases exist of human health impacts from waste-derived organic
chemicals in marine environments.  However, the potential for such exposure and
effects dearly exists in the United States (OTA, 1987).
Gulf of Mexico Public Health Action Agenda 4.1
        25

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 Public Health Issues In the Gulf
                                                   Chapter II
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-------
 Public Health Issues in the Gulf
Chapter li
In addition to the health risks associated with toxic substances discharged directly
into the marine environment, the potential health risk of atmospheric deposition
needs to be investigated further.  Air pollution can cause water pollution either by
direct deposition or through runoff from land. This transfer of toxic substances
among media has already been documented in the Great Lakes and Chesapeake Bay
regions, and may be a source of contamination in Gulf of Mexico waters.  Potential
risks need to be assessed, as well as appropriate alternatives for reducing the amount
of toxic substances released into the atmosphere (i.e., scrubbers for smokestacks).

Once an indication of the relative hazard posed by a pollutant in the marine
environment has been established, the next step is to  characterize the potential risk
to the human population from exposure to the particular contaminant using risk
assessment methods.  Risk assessment involves  quantifying the levels of
contaminants in seafood, identifying the populations exposed to the toxic agent,
estimating the intensity, duration and nature of human exposure, and evaluating
the toxicity of the chemical contaminant.  Several methods have been developed
recently to assess the human health risks from exposure to toxic chemicals in the
marine environment.  EPA's Office of Water is currently developing a
comprehensive guidance manual addressing risk assessment of marine pollutants
with respect to seafood. However, there are several data gaps and uncertainties
associated with the risk assessment process that may be improved by further
research in this area. Identifying the populations likely to be exposed to marine
pollutants and estimating the duration and frequency of exposure require accurate
seafood consumption data. However, currently there are a wide range of national
seafood consumption values being used by regulatory agencies.

There is insufficient information for public health officials to determine the risk
these contaminants in seafood  pose to consumers and there is difficulty in
communicating this risk to the public. In addition to the lack of information ~.
regarding the human health effects from contaminants, there is a paucity of
information on the elimination of chemical contaminants from shellfish.  The few
existing studies indicate that metals remain high for  many months, even following
depuration.
 Gulf of Mexico Public Health Action Agenda 4.1
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 Public Health Issues In the Gulf
Chapter li
 Exposure to Pathogens In Gulf Waters From Recreational or
 Occupational Contact

 Human wastes are discharged from many sources into coastal waters that are also
 used for contact recreation. There is a direct correlation between the level of these
 wastes (fecal coliform, E. coli, and enterococcus) in water and the occurrence of
 illness in swimmers (Cabelli, 1983). Municipal wastewater sewage presents the
 greatest risk of infectious disease from direct contact through such activities as
 swimming, surfing, and diving.

 While the implementation of water quality guidelines and sewage treatment
 requirements has substantially reduced the outbreaks of serious human diseases
 attributable to direct contact with polluted waters, bathing in sewage-impacted
 waters is still responsible for relatively high rates of gastrointestinal illness in the
 United States. In fact, the number of outbreaks of water-borne disease, particularly
 nonbacterial diseases such as viral gastroenteritis and hepatitis, have been steadily
 increasing in recent decades (OTA, 1987). Because of its relatively benign nature,
 this type of illness is probably significantly under-reported as well.

 Epidemics of serious bacterial disease, while rare, have been caused by swimming in
 sewage-contaminated water.  For example, in 1974, an outbreak of shigellosis was
 traced to swimming in a stretch of the Mississippi River downstream of a secondary
 treatment plant.  Fecal coliform counts in the river were almost 90 times  higher
 than the federal standard (OTA, 1987).

 Scuba diving in contaminated marine waters can also lead to increased  incidence of
 water-borne disease (OTA, 1987). These diseases include dermatitis, wound
 infection, and other skin-related ailments, as well as enteric illness.  Under-
 reporting of these diseases is also judged to be considerable.

 Naturally occurring marine bacteria may also cause  illnesses by invading  wounds.
 The V. vulnificus microorganism has been responsible for wound infections among
 users of coastal and estuarine waters (NOAA, 1991);  other species of Vibrio may also
be responsible for wound  infections. These  infections have been relatively few in
number, but very severe in nature and possibly under-reported.

Most Gulf States use the fecal coliform  criterion as a contact recreation bacterial
 standard for aquatic habitats. In 1986, EPA described new criteria organisms (E. coli
 and enterococcus) to monitor the microbial quality of fresh water and enterococcus
for monitoring microbial marine water quality.  EPA has recommended that states
consider using the new indicators.  To date, there has been little activity by states in
using the new criteria organisms in recreational water quality monitoring programs,
although some non-Gulf states are using the new indicators.  The consensus of the
Public Health Subcommittee is that the new  indicators are better predictors of
swimming-related health risks than the old  criteria.
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       28

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 Public Health Issues In the Gulf
Chapter If
Economic Implications of Consumer Risk

The following section discusses the economic implications of consumer risk related
to potential illness from contaminated seafood.

Determining consumer risk and appropriate control measures are complex issues.
The area of seafood safety and product quality needs not only improved scientific
analysis of the nature and extent of public health risks, but also good economic
analyses.

When an outbreak of seafood-borne illness occurs, consumer willingness to pay for
seafood declines because of expectations of increased risk. Consequently, total
demand declines, there is a loss in benefits, market prices are reduced, and there is a
decrease in sales and potentially employment. The impacts of such changes can
reverberate from the fishing grounds to the retail markets.

Not only will there be a loss in the market for the species/product that is the source
of the outbreak, but other markets may suffer losses because consumers have
imperfect information.  For example, an outbreak of ciguatera in barracuda may
cause a reduction in the demand for snapper, another species associated with
ciguatera.  Also in calculating welfare losses, one must consider that those that do
get sick require medical attention, that there will be a loss in production due to
employee illness,  and that government resources will be expended in determining
the cause of the outbreak.

The costs of food-borne diseases are not borne by one sector of society but are shared
among governments, society, individuals, and firms. Policy makers desire
information which will allow  them to understand how the cost burden is shared
and also require some mechanism to allow them to relate costs to control measures
In addition to the complex issues already identified, the desire on the part of
government to take action on food safety issues is often tempered by limited
resources available for the task.
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 Public Health Issues in the Gulf
Chapter II
 Summary

 Fish and shellfish accumulate varying degrees of pollutants (e.g., petroleum,
 hydrocarbons, synthetic organic compounds, pesticides) that enter the environment
 through agricultural and industrial activities and disposal of wastes.  These
 pollutants affect the ability of fishery resources to reproduce and enter into human
 food supplies. Seafood—shellfish in particular—may also harbor pathogenic bacteria
 and viruses originating largely from human and animal waste at levels that can
 cause illness to consumers.  Shellfish and finfish can also accumulate extremely
 toxic compounds naturally produced by toxic marine phytoplankton.  These toxins
 eventually adversely impact humans when they consume seafood (all types), come
 into direct contact through marine aerosols, or swim in contaminated waters.
 According to NMFS, the impact of these contaminants will increase dramatically as
 the human population on the coasts grows faster than waste/run-off management
 can be implemented (GAO, 1991).

 The association between exposure to human pathogens, by ingestion of
 contaminated seafood or swimming in contaminated water, and the development
 of human illness has been established for some agents.  This association is best
 established for exposure to pathogens such as viruses and bacteria. Diseases such as
 hepatitis, gastroenteritis, and cholera are known  to be caused by water- and seafood-
 borne pathogens. However, many gaps exist with regard to potential health risks
 from exposure to other pathogenic microorganisms. The association between
 marine pollution and increased incidence of these human pathogens has not been
 firmly established, particularly for the Vibrio species.  Information gaps exist
 concerning the levels of microorganisms and marine toxins in seawater and seafood
 that may present a risk to human health, as well as the best methods for monitoring
 these microorganisms.  There also are data gaps with regard to the survivability,
 transmission, and life cycles of pathogenic microorganisms and dinoflagellates in
 the marine environment.  Research in these areas may help control the potential
 health threat from exposure to pathogenic microorganisms  and  marine toxins.

 Pollution of coastal and offshore fishing grounds has resulted in intermittent
 closures of some areas  to both finfish and shellfish  harvesting.  NMFS believes that
 without long-term planning for pollution control, the nation's fish stocks are being
jeopardized (GAO, 1991).  The safety of consuming fish from these areas or
 marginally contaminated waters is not well understood. The likelihood of human
 exposure to these pollutants depends on their physical, chemical, and biological
 form; concentration; and persistence or survival. The character and nature of
 environmental pathways leading to human -exposure are also important variables.

According to NMFS, critical information is missing about the depuration of viral
agents in shellfish, and controlled studies have been hindered by a lack of methods
 to enumerate viruses in shellfish (GAO, 1991).  Even with the best treatment
Gulf of Mexico Public Health Action Agenda 4.1
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 Public Health Issues In the Gulf
Chapter If
technology to reduce marine pollution, seafood may still be contaminated with
pathogenic microorganisms and marine toxins.  Effective methods for the removal,
reduction, and/or inactivation of pathogens in fish need to be explored further.

Overall, the incidence of shellfish-borne disease in the United States may be
increasing (OTA, 1987). This trend largely involves increases in the number of
outbreaks of viral disease. For example, in a series of apparently related cases
stretching back over the last 14 years, several dozen people  contracted cholera after
consuming shellfish harvested from coastal marshlands  in southwestern Louisiana
(OTA, 1987). These represent the first indigenous outbreaks of cholera in the U.S.
since 1911.

Toxins in finfish, molluscan shellfish (clams, oysters, mussels, scallops), and
possibly shrimp have increasingly been implicated in human health disorders.
According to the Centers for Disease Control's records for 1983-87, ciguatera and
scombroid poisoning were the first and second most frequently reported illness
associated with eating fish.  In addition to consumer  safety  issues, toxins pose a
severe economic threat to the shellfish industry.
 Gulf of Mexico Public Health Action Agenda 4.1
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Agency Framework an«f Existing Legislation
Chapter III
III.  AGENCY FRAMEWORK AND EXISTING LEGISLATION
This section describes the legal and institutional framework currently in place in the
Gulf of Mexico to address public health problems. It also outlines some of the
positive efforts already underway at the federal, regional, and state levels.
Federal Level

Federal Statutes Affecting Public Health Issues
Agricultural Marketing Act of 1946, as amended (7 LJ.S.D. 1621 et_seg,), Fish and
Wildlife Act of 1956 (16  LJ.S.C. 742a et seq), and Reorganization Plan No. 4 of 1970.

The Agricultural Marketing Act authorizes the Secretary of Agriculture to establish
a voluntary inspection and certification program for agricultural products, including
fish and shellfish, in interstate commerce through services made available  on a fee-
for-service basis. The Act also requires the Secretary to, among other things, conduct
research and development on methods of processing, packaging, handling, storing,
and preserving products and develop and improve standards of quality, condition,
quantity, grade, and packaging to encourage uniformity and consistency in
commercial practices.

Pursuant to the Fish and Wildlife Act, USDA's functions and authorities pertaining
to commercial fisheries  were transferred to the U.S. Department of the Interior in
1958. The transfer included the voluntary seafood inspection program. The Act also
authorizes the Secretary of the Interior to  improve production and marketing
practices. Reorganization Plan No. 4 of 1970 transferred the functions described in
the Fish and Wildlife Act including the voluntary seafood inspection program,
from the Department of the Interior to NOAA.


Clean Water Act of 1977, as  amended by the Water Quality Act of 1987

The objective of the Clean Water Act (CWA) is to restore and maintain the quality
of our water resources to protect the health of humans, fish, shellfish, and wildlife
from harmful pollutants. CWA establishes national water quality goals and creates
a national permit system with minimum standards for the quality of the discharged
waters (effluent). CWA does not set specific standards for water bodies, but does
provide guidance to the states. States, however, are required to establish standards
based on the designated uses of these waters.
 Gulf of Mexico Public Health Action Agenda  4.1
          32

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 Agency Framework and Existing Legislation
Chapter HI
 CWA also establishes types of pollution to be regulated and categories of industries
 to be regulated.  Conventional pollutants, toxic or "priority " pollutants, and non-
 conventional pollutants are regulated under CWA.  Federal numerical "criteria"
 designating allowable concentrations in receiving waters have been established for
 the priority pollutants.  Translating these "criteria" into enforceable standards for
 specific water bodies may be as simple as copying the federal recommendations to a
 state's standards. However, for developing criteria other than federally
 recommended criteria, additional site-specific evaluations may be required.

 CWA requires that direct point source dischargers obtain National Pollutant
 Discharge Elimination System (NPDES)  permits that regulate their discharges to
 attain effluent standards.  Specific waste water dischargers into rivers and storm
 water drainage systems must also receive permits. CWA requires direct point
 source industrial dischargers to control  conventional, as well as toxic and non-
 conventional, pollutants.

 Pretreatment of specified discharges from point sources is  the mechanism for
 controlling toxic and non-conventional pollutants discharged into the sewage
 treatment system. As mandated by CWA, the intent of the pretreatment program is
 to achieve a total reduction in discharges of priority pollutants from indirect
 dischargers that is roughly equivalent to those required by direct point source
 dischargers.

 Municipal waste water treatment plants (called Publicly-Owned Treatment Works
 or POTWs) and  direct industrial dischargers are required to meet different
 technology-based effluent standards.  However, both municipal and industrial
 dischargers are required to meet the same ambient water quality standards.
 Technology-based regulation of POTW discharges focuses almost exclusively on
 conventional pollutant control through  the requirement that POTWs achieve
 "secondary" (85% removal of suspended solids and biological oxygen demand)
 levels of treatment.

 CWA also establishes a program for managing contaminated runoff from nonpoint
 sources of pollution. Each state identifies all water body segments that fail to meet
 water quality standards for designated uses  due to runoff, boating wastes, faulty
 septic systems, and other sources of nonpoint pollution.  The states must then
 submit a four-year management program for controlling the pollutant sources. The
 plans are subject to EPA approval and may be eligible for grants of up to 60 percent
 of costs (excluding construction) to assist in implementation.
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        33

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Agency Framework and Existing Legislation
Chapter III
Coastal Zone Management Act of 1972 (CZMA), as amended

Under CZMA, states receive federal assistance grants to maintain federally-approved
planning programs for enhancing, protecting, and utilizing coastal resources. These
are state programs, but the Act requires that federal activities must be consistent
with the respective states' CZM programs.  Depending upon the individual state's
program, the Act provides the opportunity for considerable protection and
enhancement of fishery resources by regulation of activities and by planning for
future development  in the least environmentally damaging manner.


Comprehensive  Environmental Response,  Compensation,  and Liability Act of 1980
(CERCLA or "Superfund")

CERCLA names NMFS as the federal trustee for living and nonliving natural
resources in coastal and marine areas under United States jurisdiction. It could
provide funds for "clean-up" of hazardous waste in coastal habitats in the event of
an oil spill or other pollution spill.
Federal Food, Drug, and Cosmetic Act (FFDCA), as amended (21 U.S.C. 301 et seq.)

FFDCA authorizes FDA 1) to regulate food (except meat and poultry products)
production and manufacturing to ensure that food is safe, clean, and wholesome
and 2) establish reasonable standards of identity, quality, and fill of containers for
food products.  The Act also prohibits the interstate commerce of adulterated foods
and false or misleading labeling of food products.  A food is adulterated if it contains
substances that may render it injurious to health.  A food is misbranded if
information required by law does not clearly appear on the label. In many instances
FFDCA also requires FDA approval for distribution of certain products. The Act
directly affects the harvest, handling, sale, and packaging of fish and shellfish.
Federal  Water Pollution  Control Act of 1972 (FWPCA) and MARPOL Annexes I, II,
and  V

Discharge of oil and oily mixtures into the navigable waters of the United States is
governed by the FWPCA and 40 Code of Federal Regulations (CFR), part 110.
Discharge of oil and oily substances by foreign ships or by U.S. ships operating or
capable of operating beyond the U.S. territorial sea is governed by MARPOL Annex I.

MARPOL Annex H governs the discharge at sea of noxious liquid substances
primarily derived from  tank cleaning and deballasting. Most categorized substances
are prohibited from being discharged within 12 nautical miles of land and at depths
of less than 25 meters.
 Gulf of Mexico Public Health Action Agenda 4,1
         34

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 Agency Framework and Existing Legislation
Chapter III
 MARPOL Annex V requires that ships which dispose of garbage contaminated with
 foreign food wastes do so in an Animal/Plant Health Inspection Service (U.S.
 Department of Agriculture) approved facility.


 Fish and Wildlife Coordination  Act of 1958

 Under the Fish and Wildlife Coordination Act, FWS and NMFS review and
 comment on fish and wildlife aspects of proposals for work and activities
 sanctioned, permitted, assisted or conducted by federal agencies that take place in or
 affect navigable waters, wetlands or other critical fish and wildlife habitat. The
 review focuses on potential damage to fish and wildlife and their habitat and
 therefore serves  to provide some protection to fish resources from activities that
 may alter critical habitat in nearshore waters.  The Act is important because federal
 agencies must give due consideration to the recommendations of FWS and  NMFS.


 Interjurisdictional Fisheries Act  of 1986 (Title III, Public Law 99-659)

 The Interjurisdictional Fisheries (IJF) Act was established by Congress to:  1)  promote
 and encourage state activities in support of the management of Interjurisdictional
 fishery resources; and 2) promote and encourage management of interjurisdictional
 fishery resources throughout their range. Congress also authorized federal funding
 to support state research and management projects that were consistent with these
 purposes. Additional funds are authorized to support development of interstate
 fishery management plans (FMPs) by the Gulf States Marine Fisheries Commission
 and other marine fishery commissions.


 Lacey Act, as amended (16  U.S.C. 3371  et seq.)

 The Lacey Act, administered by NMFS, makes it unlawful to deliver, carry,
 transport, or ship by any means for commercial or noncommercial purposes  or sell
 in interstate or foreign commerce any fish or wildlife that was taken, transported, or
 sold in violation of any federal, state, or foreign law or regulation.  NMFS
 investigates alleged violations of the Act.


 Magnuson Fishery Conservation and Management Act  (MFCMA)

 The Magnuson Fishery Conservation and Management Act, administered by
 NMFS, requires fishery resources to be used to the greatest overall benefit to the
United States, with specific reference to the use of the nation's fishery resources as
 food. The Act includes a mandate for NMFS programmatic activities to, among
other things, maximize the quality of seafood products to ensure the greatest
economic return for harvested resources.
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        35

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Agency Framework and Existing Legislation
Chapter IK
With the passage of MFCMA, the federal government assumed responsibility for
fishery management within the Exclusive Economic Zone (EEZ), a zone contiguous
to the territorial sea and whose inner boundary is the outer boundary of each coastal
state.  (The outer boundary of the EEZ is a line 200 miles from the (inner) baseline of
the territorial sea.)  Management of the EEZ is to be based on fishery management
plans developed by regional fishery management councils. MFCMA sets national
standards to be met by such plans. Each plan attempts to define, establish and
maintain the optimum yield for a given fishery. Each council prepares plans with
respect to each fishery requiring management within its geographical area of
authority and amends such plans as necessary. Plans are implemented as federal
regulation through the Department of Commerce (DOC).


Marine Protection,  Research and Sanctuaries Act of 1972  (MPRSA), Titles I and III
and Shore Protection Act of 1988 (SPA)

MPRSA provides protection of fish habitat through the establishment and
maintenance of marine  sanctuaries.  MPRSA and SPA regulate ocean transportation
and dumping of dredged materials, sewage sludge and other materials. Criteria for
issuing such permits include consideration of effects of dumping on the marine
environment, ecological systems, and fisheries resources.


National Environmental  Policy Act of 1970 (NEPA)

NEPA requires that all federal agencies recognize and give appropriate consideration
to environmental amenities  and values in the course of their decision-making. In
an effort to create and maintain conditions under which man and nature can exist
in productive harmony, NEPA requires that federal agencies prepare an
environmental impact statement (EIS) prior to undertaking major federal actions
that significantly affect  the quality of the human  environment. Within these
statements, alternatives  to the proposed action that may better safeguard
environmental values are to be carefully assessed.
                                                             t


National  Ocean  Pollution Research,  Development,  and  Monitoring Planning Act of
 1978

The Act requires NOAA to develop the necessary base of information to protect
 public health and provide for the rational, efficient, and equitable conservation and
 development of ocean and coastal resources.
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          36

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 Agency Framework and Existing Le&islation
Chapter ill
 Public Health Service Act, as amended (42  U.S.C. 201 et sec;.)

 The Public Health Service Act provides for federal/state cooperative assistance in
 preventing the interstate transmission of disease, and thus establishes FDA's
 authority for its programs for shellfish, restaurant and retail market operations  and
 interstate travel conveyances.
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        37

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Agency Framework and Existing Legislation
Chapter III
Involved Federal Agencies
Food and Drug Administration (FDA)

The regulation and control of contaminated food stuffs is a joint federal and state
responsibility. FDA shares the federal regulatory role with EPA. FDA has direct
enforcement responsibility over all contaminated food including fish and shellfish,
that are shipped in interstate commerce.  FDA is responsible for establishing safe
levels for poisonous or deleterious substances (other than pesticide residues which
EPA establishes) that contaminate food.  Under ideal conditions, FDA will attempt
to establish a  formal  tolerance or maximum permissible level.  However, when
toxicological data are scanty or conflicting, when additional data are being developed
or when other conditions are rapidly changing, FDA may consider developing an
action level. Action levels meet the same criteria  as tolerances except they are
intended for interim periods and can be instituted and changed more quickly than
tolerances.  The agency also has the task  of seafood inspection, distributed among
the following  four responsibilities:  (1) general plant  and product inspection, (2)
import control inspection, (3) routine and periodic surveys for residual chemicals,
and (4) compliance inspection for the National Shellfish Sanitation Program.

The Center for Food Safety and Applied Nutrition carries out FDA's  Food and
Cosmetics Program. The Center 1) conducts and supports food safety research, 2)
develops and  oversees enforcement of food safety and quality regulations, 3)
coordinates and evaluates FDA's surveillance and compliance programs relating to
foods, 4) coordinates and evaluates federal/state cooperative programs relating to
foods, and 5)  develops and disseminates food safety  and regulatory information to
consumers  and industry.

The Office of  Regulatory Affairs consists  of a headquarters staff and FDA field offices.
The headquarters staff oversees field office activities—investigational and laboratory
functions for  all of FDA's major product areas including foods. Field office food
safety and quality  responsibilities include those relating to research, investigation,
inspections, compliance, enforcement, and laboratory analyses.  For  example,
enforcement actions for  toxic constituents are based upon FDA action levels~the
only available criteria on contaminants in fisheries products.

FDA provides assistance to states and advises the states on matters pertaining to the
preservation  and improvement of public health as they relate to shellfish in the
Public Health Services Act, as amended. Additionally, the Code of Federal
Regulation (21 CFR 1240.610) prohibits the interstate sale of shellfish that are likely
 to spread disease.
 Gulf of Mexico Public Health Action Agenda 4.1
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  Agency Framework and Existing Legislation
Chapter IH
  The Division of Seafood Research, within FDA's Office of Seafood, originates, plans
  and conducts research on marine parasites, natural toxins, chemicals  and
  microbiological organisms that may contaminate seafood and/or harvest waters  In
   u   S*0 numerous responsibilities, this Division provides scientific support to
  other FDA components in sanitary surveys of seafood harvesting waters and
  develops and evaluates methods to  determine the presence and concentration of
  contaminants in seafood and/or harvest waters.

  FDA Action Levels

  The focus of recent controversy, action levels have been widely used in lieu of
  formal tolerances in setting regulatory guidelines for seafood.  Such levels are
  aUowed under Sections 306, 402(a) and 406 of the Food, Drug, and Cosmetic Act
  (FDCA). For FDA, action levels provide the advantage of not requiring formal
  notice-and-comment rule making. In addition, they prove useful as substitutes to
  formal tolerance levels in the absence of consistent and abundant toxicological data
  Because there was no functional difference between an action level and a tolerance
 m practice, however, the U.S. Court of Appeal for the District of Columbia Circuit
 was forced to refine and clarify the legal status of FDA action levels in 1987. In 1990
 FDA proclaimed that action levels were not binding on the agency or industry
 Nevertheless, action levels are valuable  to FDA because of the significant guidance
 and focus they provide to field personnel who direct monitoring and inspection
 programs that contribute to the identification of adulterated seafood products
 Indeed, specific action levels have been developed for several contaminants in
 seafood products. Examples of established action levels, include: Escherichia coli in
 fresh and frozen crabmeat, parasites in finfish, and paralytic shellfish poison in
 clams, mussels, and oysters. Additional action levels have been established for
 residual chemical contaminants, including pesticides.

 National  Shellfish Sanitation Program (NSSP)

 In 1925, NSSP was established as a joint effort between FDA, federal, state and
 municipal authorities, and the  shellfish industry  to set forth guidelines for the
 management of state shellfish programs.  In each participating state, one or more
 regulatory agencies manage the local shellfish sanitation program. As part of NSSP
 FDA provides technical assistance to states in studying specific pollution problems-'
 provides data to establish closure levels for shellfish harvesting;  conducts applied
 research on various contaminants to assist in developing standards and criteria- and
 evaluates the effectiveness of state shellfish sanitary control programs (see Table
 3.1). The criteria of NSSP are applied to both domestic and imported fresh and
 fresh-frozen shellfish.  In addition, since  1966, data have been compiled periodically
 by FDA and NOAA on classification by states of coastal and estuarine waters with
 regard to  suitability for shellfishing activities.
Gulf of Mexico Public Health Action Agenda 4.1

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Agency Framework and Existing Legislation
                                      Chapter III
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 Gulf of Mexico Public Health Action Agenda 4.1
                                              4O

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  Agency Framework and Existing Leetislation
Chapter III
  NSSP is designed to prevent human illness associated with the consumption of
  fresh and fresh-frozen oysters, clams, and mussels through sanitary control over all
  phases of growing, harvesting, shucking, packing, and interstate transportation Its
  purpose is to develop strict guidelines covering the quality of growing waters
  harvesting techniques, record keeping, tagging, processing, and shipping. NSSP
  develops guidelines for classifying shellfish growing waters, inspecting shellfish
  snippers and plants (certification), and preventing shellfish harvesting in areas that
  are not approved for harvesting (e.g., waters contaminated with chemicals or
  sewage). These guidelines and criteria for the program are contained in the NSSP
  Manual of Operations (1990).  The Interstate Shellfish Sanitation CorrferenceOSSQ
  is the organization of industry and state officials that FDA has recognized as the
  primary group to make recommendations to NSSP.

 FDA's Cooperative Programs

 In some food and drug areas, state agencies have more direct control of regulatory
 activities. These areas include milk,  shellfish, retail food stores, and food service
 (restaurants). FDA's role is to provide technical guidance, training, and evaluation
 of these state programs at the state's request through  associations, such as the
 Interstate Shellfish Sanitation Conference (ISSC). FDA sets standards with the
 states, evaluates the states against those standards, and rates state officials  for their
 competency, familiarity with, and uniformity in  applying those national standards
 within an individual state.  FDA, however, is generally in no position to approve or
 disapprove of a state program.

 Through Cooperative Programs, FDA, with a small investment of its own resources
 promotes and hopes to ensure maintenance of a  uniform system of state control
 over a* inventory of about 75° shellfish processors, 1,100 shellfish shippers, and 850
 shellfish-growing areas.

 FDA's  State Contract Program

 This program is designed to obtain state assistance in  inspecting firms that are FDA's
 responsibility but that would not be covered by FDA employees. This program
 includes such projects as investigating pesticide residues in foods and toxins in
 shellfish.
Contact:    Dr. Merrill McPhearson
            U.S. Food and Drug Administration
            Fishery Research Branch
            P.O. Box 158
            Dauphin Island, AL 36528
Gulf of Mexico Public Health Action Agenda 4.1
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Agency Framework and Existing Legislation
Chapter III
Environmental Protection Agency (EPA)

EPA strives to achieve the objectives of the Clean Water Act. CWA directs EPA to
develop criteria for water quality that accurately reflect the latest scientific
knowledge about the effects of pollutants on aquatic life and human health. In
developing criteria to protect water quality, EPA examines the effects of specific
pollutants on plankton, fish, shellfish, wildlife, plant life, aesthetics, and recreation
in any body of waters.  This includes specific information on the concentration and
dispersal of pollutants through biological, physical, and chemical processes as well as
the effects of pollutants on biological communities as a whole.

EPA periodically publishes the results of these examinations to help states
determine the levels of  pollutants that can exist in the water column and the
sediment without harming human and aquatic life. These levels are called "water
quality criteria." Criteria can also describe the biological and physical characteristics
that a lake, river, or estuary must have to support a healthy environment for fish
and wildlife.  States then use these criteria to help set water quality standards that
protect the uses of their waters.

EPA is responsible for establishing ambient marine water quality criteria and for
developing the framework for the issuance of NPDES permits for municipal and
industrial storm water discharges.  EPA establishes standards for oil and hazardous
substances discharges from boats into federal waters and promulgates performance
standards for marine  sanitation devices.  EPA administers the National Estuary
Program.  EPA is responsible for establishing tolerances for residues of pesticides
that may be anticipated to appear in fish, or recommending appropriate action levels
to FDA.

EPA's Office of Research and Development is responsible for the  Environmental
Monitoring and Assessment Program (EMAP).  The Estuarine component of this
program is designed, over the long term, to provide a quantitative assessment of the
regional extent of coastal environmental problems by measuring status and change
in selected ecological  condition indicators. A demonstration project began in the
Louisianian Province  (Gulf of Mexico) in the summer of 1991. One of the
assessment endpoints addresses whether fish contain contaminants. Annual
statistical summaries will be produced and shared with Gulf of Mexico program
managers.

Contact:     Dr. Frederick C. Kopfler
             U.S. Environmental Protection Agency
             Gulf of Mexico Program  Office
             Building 1103, Room 202
             Stennis Space Center, MS 39529                 •
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         42

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 Agency Framework and Existing Legislation
Chapter ill
             Chuck V. Pietrosewicz
             Waste Management Division
             U.S. Environmental Protection Agency—Region 4
             345 Courtland St. NE
             Atlanta, GA  30365

             Carl R. Hickam
             Office of Health Response
             U.S. Environmental Protection Agency-Region 6
             First Interstate Tower
             1445 Ross Ave.
             Dallas, TX 75202
National Oceanic and Atmospheric Administration (NOAA)

National Marine  Fisheries  Service (NMFS)

NMFS is responsible for establishing programs to protect and conserve fishes,
marine mammals, and critical aquatic, estuarine, and marine habitats. NMFS is also
authorized to inspect seafood harvested for commercial use. NMFS has an advisory
role in coastal development permit processes; conducts or supports research and
education; promotes federal marine fisheries (both sport and commercial); provides
funding to develop state Coastal Zone Management Plans; and advises the Secretary
of Commerce on  establishing marine sanctuaries.

The Secretary of Commerce, acting through NMFS, has the ultimate authority to
approve or disapprove all fishery management plans prepared by regional fishery
management councils.  Where a council fails to develop a plan, or to correct an
unacceptable plan, the secretary may do so.  NMFS also collects data and statistics on
fisheries and fishermen. It performs research and conducts management
authorized by international treaties. NMFS has the authority to enforce the
Magnuson Act and Lacey Act and is the federal trustee for living and nonliving
natural resources in coastal and marine areas under Section 107(f) of the
Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA or "Superfund"),  Section 311 (f) (5) of the Clean Water Act (CWA),
Executive Order 12580 of January 23,1987, and Subpart G of the National Oil and
Hazardous Substances  Pollution Contingency Plan.

NMFS's Office of Trade and Industry Services administers two programs dealing
with food safety and quality activities—the voluntary National Seafood Inspection
Program and the Product Safety, Quality and Identity Research Program.  The
National Seafood  Inspection Program is a voluntary, fee-based fish and shellfish
products inspection and grading program. Division employees inspect and certify
plants and seafood products and issue certification marks, including the Packed
Under Federal Inspection mark and/or U.S. Grade A mark.
Gulf of Mexico Public Health Action Agenda 4.1
        43

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Agency Framework and Existing Legislation
Chapter ill
The Product Safety, Quality and Identity Research Program provides services and
information on impediments to the full utilization of fishery resources.  Activities
include the collection, interpretation, publication, and dissemination of
information and research results to facilitate optimum use of living marine
resources.  Safety research includes activities that address the continuing concern
about the impact of environmental and process-induced contamination of seafood
on consumers and the fishing industry. NMFS's  quality research efforts are directed
to improving the overall quality of U.S. seafood marketed domestically and
internationally.

NMFS is currently involved with a number of projects regarding shellfish and
oyster sanitation. Studies regarding methods to depurate and eliminate pathogens
are underway, and an indicator study is proposed.  Also, NMFS has completed and
tested a model for hazard analysis  critical control point (HACCP) inspection.

Contact:    Dr. G. Malcolm Meaburn
            National Marine Fisheries Service                           •   ,
            Model Seafood Surveillance Program
            Charleston Laboratory
            P.O. Box 12607
            Charleston, SC  29412
National Status and Trends Program (NS & T), National Ocean  Service (NOS)

NOAA's NS & T Program is an extensive federal program under the direction and
management of  the Ocean Assessments Division of NO A A (OAD) that monitors
levels of toxicants annually (routine surveillance) in shellfish (Mussel Watch) and
finfish (Benthic Surveillance) from approximately 150 coastal and estuarine sites in
the continental U.S., Alaska, and Hawaii (NOAA, 1989). The objectives of the .
program are:  1) to determine toxic contaminants as a basis for the identification  of
potential geographic differences; 2) to identify areas where environmental quality
may be significantly compromised; 3) to determine significant temporal trends in
toxic contaminant levels on a national basis; and 4)  to evaluate and synthesize
existing sources of information pertinent to the status of contaminants in selected
areas and to augment the basic monitoring program as needed.  NOAA's Mussel .-
Watch Program to assess chemical contamination and various cooperative      ,
enforcement efforts with FDA and states are ongoing programs.  A joint voluntary
inspection system is being developed between NOAA and FDA which uses the
HACCP concepts and will be offered first to the processors. Pilot testing of this
approach is being completed in both the processing and retail sectors of the seafood
industry.
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 Agency Framework and Existing Legislation
Chapter III
Contact:    Dr. Daniel J. Basta
            NOAA/Strategic Assessment Branch
            National Ocean Service
            Rockville,MD 20852

Office of Ocean and Coastal Resource  Management (OCRM)

OCRM asserts authority through the National Marine Sanctuaries Program
pursuant to Title III of the Marine Protection, Research, and Sanctuaries Act
(MPRSA). The OCRM Estuarine Sanctuary Program has designated Looe Key,
Rookery Bay, and the Apalachicola River and Bay in Florida, and Weeks Bay in
Alabama as estuarine sanctuaries.

OCRM may influence fishery management indirectly through administration of the
Coastal Zone Management Program and by setting standards and approving funding
for state coastal zone management programs. Some states in the Gulf utilize a
portion of these monies in their habitat protection and enhancement programs
including reef maintenance and  enhancement.

Proposed Coastal Zone Act Reauthorization. Section 6217 Guidance

On October 16,1991, NOAA and EPA jointly issued a proposed development and
approval guidance for state coastal nonpoint pollution control programs.  When the
final guidance is issued, it will assist states in designing programs to combat the
growing problem of nonpoint source impacts on the nation's coast.

The proposed program guidance identifies and explains provisions state coastal
nonpoint programs must include in order to be approved by EPA and NOAA under
section 6217 of the Coastal Zone Act Reauthorization Amendments (CZARA). Four
of the many requirements for state programs are: 1)  identify critical coastal areas
adjacent to coastal waters which are impaired or threatened by nonpoint source
pollution; 2) implement additional management measures for land uses or critical
coastal areas as necessary to achieve and maintain water quality standards; 3)
establish mechanisms to improve coordination among state and local agencies
responsible for land use programs and permitting, water quality permitting and
enforcement, habitat protection, and public health and safety; and 4)  modify coastal
zone boundaries as the state determines is necessary to implement NOAA's
recommendations under Section 6217(e) of the CZARA. This section requires
NOAA and EPA to determine whether the landward coastal zone of each coastal
state extends  far enough inland to control significant upland sources of nonpoint
source pollution.

Contact:     Ms. Marcella Jansen
            NOAA/Office of Ocean and Coastal Resource Management
            1825 Connecticut Ave. NW, Suite 724
           Washington, D.C.  20235
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Acyenoy Framework and Existing Legislation
Chapter III
Centers for Disease Control (CDC)

The Centers for Disease Control is charged with protecting the nation's public health
by providing leadership and direction in preventing and controlling diseases and
other preventable conditions and responding to public health emergencies.  CDC is
responsible for researching, monitoring, and controlling outbreaks of food-borne
diseases. CDC coordinates its food-borne disease activities with FDA, USDA, and
NMFS.

CDC operates a passive reporting system for food-borne illness that relies on the
submission of reports from local health authorities. Because of voluntary reporting,
different food-borne illnesses are reported at different rates depending on the
difficulties associated with linking illness to specific causes.  This phenomenon can
make a higher risk food appear to be safer and a safer food appear to be a higher risk
when data on two or more foods are compared.

Contact:     Dr. Morris Potter (C-09)
            Division of Bacterial Disease
            Centers for Disease Control
            1600 Clifton Road NE
            Atlanta, GA  30333
U.S. Coast Guard (USCG)

USCG is responsible for enforcing the Clean Water Act prohibitions on discharges of
oil, hazardous substances, and sanitary wastes from marine vessels and for
enforcing the provisions of the MPPRCA regarding disposal of garbage from ships.
USCG establishes regulations for marine sanitation devices (MSDs) to meet federal
performance standards.

Contact:    Lt. Cdr. William Prosser
            U.S. Coast Guard
            Eighth Coast Guard District
            500 Camp Street
            New Orleans, LA 70130-3396
Guff of Mexico Public Health Act/on Agenda  4.1
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Agency Framework and Existing Legislation
Chapter III
Department of the Interior (DOI)

U.S. Fish and Wildlife Service (FWS)

FWS is responsible for protecting and conserving fishes, wildlife, and critical
habitats. FWS provides technical assistance regarding these resources; has an
advisory role in coastal development permit processes; and conducts research on
man's impact to fish and wildlife resources.

Contact:    U.S.  Fish and Wildlife Service
            75 Spring St, SW, Room 1276
            Atlanta, GA 30303

            U.S.  Fish and Wildlife Service
            3530 Pan American Highway NE, Suite D
            Albuquerque, NM 87107

National Park Service (NFS)

NFS under DOI may regulate fishing activities within park boundaries.  Such
regulations may affect fish harvests within specific parks. NFS has authority to
manage fisheries primarily through the establishment of coastal and nearshore
national parks and national monuments. Everglades National Park in Florida and
the Mississippi District of Gulf Islands National Seashore are two examples of areas
where oyster populations are managed by NFS.

Contact:    Ms. Gail Bishop
            National Park Service
            Gulf Islands National Seashore
            3500 Park Road
            Ocean Springs, MS 39564
Agency for Toxic Substances and Disease Registry (ATSDR)

ASTDR's mission is to prevent or mitigate adverse human health effects and
diminished quality of life resulting from exposure to hazardous substances in the
environment.  ASTDR is authorized by the following federal statutes:
Comprehensive Environmental Response, Compensation, and Liability Act of 1980
(CERCLA, Superfund), Superfund Amendments and Reauthorization Act of 1986
(SARA), Resource Conservation and Recovery Act Amendments  of 1984 (RCRA),
Medical Waste Tracking Act of 1988, and Clean Air Act of 1991.

ASTDR conducts Public Health Assessments (PAHs) to evaluate data and
information on the release of hazardous substances into the environment; assess
any impact on human health, past, present or future; develop health advisories or
Gulf of Mexico Public Health Action Agenda 4,1
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Agency Framework and Existing Legislation
Chapter Hi
other health recommendations; identify actions necessary to evaluate and mitigate
or prevent human health effects.  PHAs are conducted for all National Priority List
(NPL) sites and in response to petitions from individuals or groups.

Health investigations are conducted to increase understanding, through various
studies, of the relationship between exposure to hazardous substances and adverse
human health effects. ATSDR provides health-related support to state and local
agencies, health providers, and emergency event first responders in emergencies
involving exposure to hazardous substances. ATSDR is in the initial stages of a
study on the toxic effects of a suite of chemicals present in the waters of the Great
Lakes. This list includes: PCBs, DDT and its metabolites, dieldrin> toxaphene, mirex,
mercury, benso[a]pyrene, hexachorobenzene, furans, dioxins, and lead. It has been
demonstrated that there are associations between the consumption of contaminated
fish from the Great Lakes and long term adverse health effects in certain
populations (especially Native Americans, sport anglers, and the fetuses and
nursing infants of mothers). There is convincing evidence that persistent toxic
substances affect the survival, growth, and reproduction of some aquatic and
wildlife species in the Great Lakes.

ATSDR establishes and maintains a registry of persons exposed to hazardous
substances and a registry of serious diseases and illnesses in persons exposed to
hazardous substances in the environment.  ATSDR summarizes and makes
available to the public data on the health effects of hazardous substances, identifies
significant gaps in knowledge, and initiates research in toxicology and health effects
where needed. Toxicological Profiles are being developed for hazardous substances
which are found at NPL sites.

ATSDR makes available to health care providers materials on the health effects of
toxic substances.  An inventory is maintained of hazardous substances and of sites
dosed or restricted to the public because of hazardous substances contamination.
ATSDR also conducts or sponsors applied research  to increase scientific knowledge
on the effects on human health of hazardous substances released from waste sites or
from  other releases into the environment.

Contact:    Jeff Kellam
            Agency for Toxic Substances and Disease Registry
            Division of Health Assessment and Consultation
            Mail Stop E - 56
            1600 Clifton Road
            Atlanta, GA 30333
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Agency Framework and Existing Legislation
Chapter ill
 IntGragoncy Coordination
Federal agencies typically enter into memoranda of understanding and cooperative
agreements with each other. During fiscal year 1989, FDA had 27 memoranda of
understanding relating to food safety and quality with other federal agencies,
primarily USDA, and NMFS had seven cooperative agreements with other federal
agencies.  Examples of these include:

•     Regulatory Activities Concerning Residues of Drugs, Pesticides, and
      Environmental Contaminants in Food-agreement between FDA, EPA, and
      USDA's Food Safety and Inspection Service (FSIS) and Agricultural
      Marketing Service (AMS) that establishes the working relationships for
      promoting more effective, efficient, and coordinated federal regulatory
      activities concerning residues of drugs, pesticides, and environmental
      contaminants that may adulterate food.

•     Inspection of Fishery Products~an FDA memorandum of understanding with
      NMFS that covers fishery products plants that are under NMFS voluntary
      inspection contracts and also subject to FDA inspection.

•     NMFS agreement with USDA to establish NMFS and USDA responsibilities
      relating to the research and development of standardization  documents for
      fishery products purchased by federal agencies.

•     NMFS agreement with FDA concerning the enforcement of laws against
      illegal commerce in molluscan shellfish. NMFS advises FDA when
      investigations reveal illegal shellfish harvesting that would endanger public
      health by harvesting shellfish from polluted waters.  Both NMFS and FDA
      coordinate their activities under the memorandum  of understanding with
      the public health and fisheries agencies of interested and affected states.
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Agency Framework and Existing Legislation
Chapter ill
Regional Level
Gulf States Marine Fisheries Commission (GSMFC)

GSMFC is an interjurisdictional fisheries management program established by the
Gulf States Marine Fisheries Compact under Public Law 81-66, approved May 19,
1949.  Its charge is to promote better management and utilization of marine
resources in the Gulf of Mexico.  One of the most important functions of GSMFC is
to serve as a forum for discussion of various problems and needs of marine
management authorities, commercial and recreational industries, researchers and
others. GSMFC also plays a key role in implementation of the Interjurisdictional
Fisheries (IJF) Act.

GSMFC initiated the development of a fishery management plan (FMP) planning
and approval process. The Commission decided to pattern its plans after those of
the Gulf of Mexico Fishery Management Council under the Magnuson Act of 1976.
This decision ensured compatibility in format and approach to management among
states, federal agencies and the council.  In March 1991, GSMFC released its oyster
fishery management  plan, The Oyster  Fishery of the Gulf of Mexico,  United States:
A Regional  Management Plan.

Contact:     Mr. Larry B. Simpson
            Gulf States Marine Fisheries Commission
            P.O. Box 726
            Ocean Springs, MS 39564
Interstate Shellfish Sanitation Conference (ISSC)

In 1982, ISSC was established by state regulatory officials (state officials from 22 states
including all five Gulf States).  Other participants at the conference included FDA,
NMFS, DOC, and members of the shellfish industry.  The state officials established a
constitution, by-laws, and procedures for the operation of ISSC.

The purpose of ISSC is to promote conformity within the National Shellfish
Sanitation Program by providing for a formal structure within which regulatory
authorities can establish updated guidelines, procedures for the uniform application
of those guidelines and for sanitary  control of the shellfish industry.
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Agency Framework and Existing Legislation
Chapter III
A memorandum of understanding (MOU) between FDA and ISSC was signed in
1984, and established a basis upon which FDA and the states can work cooperatively
to foster and improve the sanitary quality of shellfish in the U.S.

Contact:    Mr. Ken B. Moore
            Interstate Shellfish Sanitation Conference
            2600 Bull Street
            Columbia, SC  29201
Gulf and South-Atlantic States Shellfish Sanitation Conference

The Gulf and South-Atlantic States sponsor an annual meeting, primarily for state
shellfish regulators, to discuss current issues and problems associated with
molluscan shellfish.  This meeting provides an opportunity for the sharing and
exchange of information, as well as a forum for seeking regional solutions to
identified problems.

Contact:    Mr. Richard Thompson, R.S.
            Division of Shellfish Sanitation Control
            Texas Department of Health
            1100 W. 49th Street
            Austin, TX 78765
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Agency Framework and Existing Legislation
Chapter III
State Level

To protect human health and aquatic life in its waters, states set standards on the
level of protection for each water body within its boundaries. To develop standards,
a state first determines a designated use for each water body—as a drinking water
supply, a fishery, a source for agricultural irrigation, or for boating, swimming, or
ship navigation. Then using EPA's national criteria or other scientific data, a state
establishes standards which include limits for each pollutant in the water column,
the sediment column, or in fish tissues. States may also establish limits based on
the biological diversity of that water body.

State water quality standards form the basis of state programs that control the
amount of pollutants entering waters from such sources as industrial plants,
wastewater treatment plants, storm sewers, and runoff from rural and urban areas.
State water quality standards are maintained by the judicious issuing of permits.

Monitoring for pathogenic microorganisms is currently conducted by state
environmental and human health agencies in shellfish harvesting areas and
ambient waters. National Pollution Discharge Elimination System (NPDES)
pathogen monitoring programs are underway, at selected locations, in order to
assess both the condition of water in the vicinity of discharges and surrounding
areas  and to assess relative pathogen contributions from these permitted effluent
discharges.

Each Gulf State has various agencies responsible for the management of fishery
resources.  Table 3.2 outlines the state fishery management institutions  in the Gulf
of Mexico, including their responsibilities, administrative policy-making bodies, and
legislative involvement in management regulations (please note that in addition to
the agencies listed in Table 3.2, there may be others that also exercise authority over
fishery resources).

Shellfish sanitation is largely regulated by the individual states in the Gulf of
Mexico. Minimum standards are/however, promulgated and recommended to the
states for adoption through the cooperative efforts of the states, the federal
government, and the industry. Enforcement of regulations is primarily a state
function with the possible exception of the use of the Lacey Act and the  Food, Drug
and Cosmetic Act.  State Shellfish Sanitation Control Agencies (SSCA) are the state
agency or agencies having legal authority to classify shellfish growing areas and
issue  permits for the interstate shipment of shellfish in accordance with the
provisions of the NSSP Manual of Operations (see Table 3.3).  SSCA's conduct
inspections and maintain records of those inspections, with such frequency as to
ensure that sanitary conditions of operations are maintained.
Gulf of Mexico Public Health Action Agenda 4.1
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Agency Framework ancf Existing Legislation
             Chapter ili
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Gi/// o/ Mexico Public Health Action Agenda 4.1

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Agency Framework and Existing Legislation
Chapter III
In some states the agency responsible for promulgation of regulations regarding
shellfish sanitation and the agency responsible for enforcing such regulations are
different.  Some sanitation  agencies do not have enforcement authority and must
work with other agencies. Cooperation and understanding of the separate needs
and responsibilities of the agencies involved is necessary in order to implement
management regulations in the most enforceable manner.

In addition to classifying waters as to their suitability as shellfish harvesting areas,
states also issue beach closures. These closures are typically based on water quality
criteria developed by the federal government.
Gulf of Mexico Public Health Action Agenda 4.1
         64

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Agency Framework and Existing Legislation
                                                          Chapter III
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Gtv// o/ Mexico Public Health Action Agenda 4.1

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Agency Framework and Existing Legislation
Chapter III
Highlights of Current State Programs, Standards & Activities
Alabama

Alabama's antidegradation policy hinges on the allowable propagation of fish,
shellfish, wildlife, and recreation in and on the water. General conditions applicable
to all criteria depend on the quantity and composition of influent sewage, industrial
wastes, and other harmful debris. Toxic pollutant levels are determined based on a
number of chemical criteria, including the pH levels of cadmium, copper, and lead
for freshwater and marine aquatic life. For non-carcinogenic pollutants, a series of
equations governing consumable water and fish are provided. These criteria
indicate Alabama's move toward a much more comprehensive water quality plan,
as they are heavily contingent on the potential impact on aquatic life and human
health. The existing criteria are based on fecal coliform and are 100/100 ml in coastal
waters and 200/100 ml in other waters. Consideration of the new indicators will
likely be addressed in the next triennial review in 1993. Before changes are proposed
however, additional information in the form of comparative studies, costs, etc. will
be necessary.

The Division of Food and Lodging Protection of the Alabama Department of Public
Health has the responsibility  of monitoring shellfish for pathogens. The Division
also has the authority to seize and destroy shellfish not in compliance.  This
Division cooperates with the  U.S. Food and Drug Administration at Dauphin
Island, AL, to monitor the water in shellfish growing  areas for fecal coliforms.
Monitoring is conducted once a week when the shellfish growing areas are open for
harvesting and twice a week when the areas are closed as a result of past
bacteriologic testing. The Division of Food and Lodging Protection also has the
authority to close shellfish growing areas  if warranted by its water monitoring
efforts.

The Division of Food and Lodging Protection has, in the  past, monitored for
biotoxins in shellfish and water twice a month. However, this program has been
discontinued due to budget constraints.

Currently, there is no routine monitoring for toxic substances in fish and shellfish.
The Division of Food and Lodging Protection assayed for heavy metals in shellfish
in 1990, but no additional monitoring is expected.

The Alabama Department of Environmental Management, rather than the
Alabama Department of Public Health, monitors  for fecal coliforms at their trend
monitoring stations for water quality once a month in the coastal and near coastal
waters of Alabama. However, the Alabama Department of Public Health has the
authority to close down beaches for recreational use because of public health
concerns.
 Gulf of Mexico Public Health Action Agenda 4.1
         £6

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Agency Framework and Existing Legislation
Chapter ill
The Division of Epidemiology in the Alabama Department of Public Health has the
authority to investigate disease outbreaks concerning the consumption of pathogens
from contaminated shellfish, the consumption of toxic substances or biotoxins in
fish or shellfish, and exposure to pathogens from recreational or occupational use of
the waters.

Contact:    Dr. Charles Woernle
            Director of Epidemiology
            Alabama Department of Public Health
            434 Monroe St., Room 900
            Montgomery, AL 36130-1701
Gulf of Mexico Public Health Action Agenda 4.1
        67

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Agency Framework and Existing Legislation
Chapter 131
Florida

The Florida Department of Environmental Regulation uses the fecal coliform
criterion as its water quality standard for bacteria.  The Florida Department of Health
and Rehabilitative Services has authority for bathing beach standards and would use
the new criteria organisms recommended by EPA, if these are indeed implemented.
However, the Department is concerned about the potential implementation of these
new standards because Florida's water quality classification has a broader scope than
the bathing beach category and other applications must be considered as well.
Florida is currently funding a small study to examine the new indicators and is
developing a side-by-side data base.

The U.S. Food and Drug Administration, Florida Department of Agriculture and
Consumer Services, and Florida Department of Natural Resources have closed
oyster harvesting in the Suwannee area due to the presence of salmonella,  which
has been partially linked to faulty septic tanks.  The State has revised public health
laws to now require: 1) operating permits for types of septic systems currently used
in coastal areas; 2) operating permits for septic systems that may be used by industry
to ensure that they are not used for industrial waste waters and; 3) more restrictive
siting standards for septic systems along floodways.

Florida's State Health Officer, during 1991, issued fish consumption advisories for
mercury in sharks and dioxin in some estuarine fish below pulp mills.
Contact:    Dr. Richard Hunter
            Florida Department of Health and Rehab. Services
            1317 Winewood Blvd.
            Tallahassee, FL 32399
 Gulf of Mexico Public Health Action Agenda 4.1
          68

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 Ag&ncy Framework and Existing Legislation
Chapter III
 Louisiana

 Louisiana is currently using the fecal coliform criterion as its water quality standard
 for bacteria. A large number of water bodies are out of compliance with this
 standard. Louisiana is reviewing the 1986 EPA criteria for adoption into the state
 water quality standards.

 Louisiana's  Department of Health and Hospitals (DHH) is responsible for the
 development and provision of health and medical services for the citizens of
 Louisiana and the protection of public health. One duty of DHH is the development
 of the State Sanitary Code, which among other things regulates discharges of sewage
 and controls the oyster and shellfishing industries. The State Sanitary Code is
 administered through the Office of Public Health which addresses issues concerning
 the general  health of the people, including, but not limited to, the preparation and
 supervision of the sanitary code, local health units, sewerage treatment and
 disposal, and oyster harvest closures.  The Office also performs those public health
 functions related to environmental quality and pollution control that are
 specifically assigned to DHH, with the exception of those duties assigned to the
 Department of Environmental Quality.  The Environmental Epidemiology  Program
 in the Office investigates and characterizes risks to human health from known or
 suspected environmental contaminants in the Gulf and its environs.  The Office has
 jurisdiction  over the conduct of studies, surveys, and hearings on sanitary
 considerations throughout the state. As a result of this research, the Office can make
 recommendations for improving conditions  within Louisiana.

 DHH has comment responsibility on Section 404 applications to the U.S. Army
 Corps of Engineers.  When a project is intended for human occupancy, DHH
 determines whether the site is served or will be served by a public sewerage system
 or an approved private or industrial system.

 DHH administers the "State Food, Drug, and  Cosmetic Law" dealing with
 adulteration, substitution, misbranding, or false advertising.  The State of Louisiana
 Food, Drug, and Cosmetic Regulations cover shellfish depuration, certification
 requirements for shellfish shippers, and shrimp for freezing. Louisiana has adopted
 the federal regulations for Tolerances for Pesticides in Food as administered by the
 EPA.

 The Louisiana Department of Environmental  Quality (DEQ), through  the Office of
 Water Resources, develops and promulgates the state's surface water quality
 standards in accordance with the Clean Water Act.  In setting water quality standards
 for Louisiana, DEQ develops water uses  and criteria to protect public health, aquatic
life, and outstanding resource waters.  DEQ also serves as the state's Nonpoint
 Source Program.  Other responsibilities of the Department include permitting of
municipal and industrial  wastewater dischargers, certification of Section 404
permits, surveillance and assessment of coastal surface waters, and enforcement of
all permits, rules, and regulations.  DEQ works with DHH in issuing fish advisories
Gulf of Mexico Public Health Action Agenda 4.1

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Agency Framework and Existing Legislation
Chapter Iff
to protect seafood consumers in coastal waters and cooperates with DHH and the
Department of Wildlife and Fisheries in assessing bacterial contamination of
shellfish grounds.

While the responsibility for protecting  public health, safety, community well-being,
and enjoyment of that portion of the Gulf of Mexico that is within Louisiana's
border is assigned to numerous agencies, the primary responsibility for protection of
public health rests with the Louisiana Department of Health and Hospitals.

Contact:    Mr. Bobby Savoie
            Louisiana Department of Health and Hospitals
            1201 Capitol Access-East Ent.
            Bin 2
            Baton Rouge, LA 70802
 Gulf of Mexico Public Health Action Agenda 4.1
          60

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 Agency Framework and Existing Legislation
Chapter III
 Mississippi

 The Mississippi Department of Environmental Quality (DEQ), Bureau of Pollution
 Control, is the agency responsible for classifying waters and adopting water quality
 criteria for the State of Mississippi.  By ordinance, the Mississippi Department of
 Wildlife, Fisheries, and Parks annually classifies marine waters for shellfish harvest
 according to NSSP guidelines.  DEQ is currently conducting a triennial review of
 water quality criteria, however, adoption of the proposed bacteriological criteria is
 not currently being considered. Mississippi is interested in adopting a criterion
 which will more accurately reflect public health risks.  However, a review of the
 data comparing the existing fecal coliform criterion with the new proposed
 indicators must be completed before taking action.

 The Mississippi Department of Wildlife, Fisheries, and Parks, in conjunction or
 consultation with the Mississippi Departments of Environmental Quality and
 Health, has issued fish consumption advisories in estuarine areas of the Gulf based
 on water quality criteria.  The Bureau of Marine Resources in the Department of
 Wildlife,  Fisheries, and Parks conducts routine coliform sampling of shellfisheries.
 Shellfish areas are managed based on an ongoing sampling program using fecal
 coliforms as an indicator organism and rainfall and/or river stages as predictive
 models.

 Contact:     Mr. Bruce Brackin
             Mississippi State Department of Health
             P.O. Box 1700
             Jackson, MS  39215-1700
Gulf of Mexico Public Health Action Agenda 4.1
        61

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Agency Framework and Existing Legislation
Chapter III
Texas

Texas water quality standards remain based on fecal coliform bacteria, with a
criterion of 200/100 ml for contact recreation (geometric mean) and a criterion of
14/100 ml for oyster waters (applied as a median).  Contact recreation criteria are
designated for virtually all coastal waters (Houston Ship Channel excepted); and
fecal coliform bacteria are sampled at 174 fixed stations in tidal waters. Texas has
recently adopted toxics criteria for the protection of human health (1991 standards
revision). The next standards revision is scheduled for 1994. The Texas Water
Commission establishes water quality standards and regulates pollution sources.

The Texas Department of Health is initiating, on a small scale, a fish contamination
program. Although this is largely in the evaluation and assessment stage, there has
been action resulting in two closed fisheries and there are five fish consumption
advisories in place. The Texas Department of Health also has the authority to close
areas to shellfishing.

Contact:     Mr. Richard Thompson, R.S.
             Division of Shellfish Sanitation  Control
             Texas Department of Health
             1100  W. 49th Street
             Austin, TX 78765
 Gulf of Mexico Public Heallh Action Agenda 4.1
          62

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The Unfinished Agenda
Chapter IV
IV.    THE  UNFINISHED AGENDA
Goals

This Public Health Action Agenda for the Gulf of Mexico sets forth a framework for
conserving, protecting, and restoring Gulf waters that will minimize public health
risks thereby allowing the use and enjoyment of its resources.  The Gulf of Mexico
Program has established foxir specific goals for addressing public health concerns:

      Q     Prevent adverse health effects resulting from consumption of raw
             shellfish harvested from the Gulf of Mexico (1).

      Q     Prevent illness resulting from exposure to marine biotoxins  in coastal
             waters of the Gulf of Mexico (2).

      Q     Reduce long term health risks from exposure to toxic substances in
             Gulf of Mexico seafood while maintaining the beneficial effects of
             seafood consumption (3).

      Q     Prevent exposure to pathogens in coastal waters of the Gulf of Mexico (4).


The Gulf of Mexico Program hopes to accomplish these goals primarily by
addressing four categories of public health concerns.  These categories were
developed by the Public Health Subcommittee during the course of its
characterization research on public health issues in the Gulf of Mexico. This work,
discussed in Chapter n,  resulted in the following prioritization of concerns:

      Q     Exposure to pathogens in Gulf waters via consumption of raw
             molluscan shellfish (1);

      Q     Marine biotoxins and their effect on human health (2);

       Q     Toxic substances in the food chain, the potential for biomagnification
             and human health effects caused by consumption (3); and

       Q    Exposure to pathogens in Gulf waters from recreational or occupational
             contact (4).
  Gulf of Mexico Public Health Action Agenda 4.1
                                                                          63

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  The Unfinished Agenda
                                                                Chapter IV
 Strategies, Objectives, and Action Items

 Four strategies have been designed to meet the goals:  1) research and
 demonstration, 2) monitoring/assessment, 3) standards/enforcement, and 4) public
 outreach.  Specific objectives are grouped according to these areas. Objectives are
 the specific, short-term targets for attaining the goals.

 Each objective is followed by action items that describe specific tasks to meet the
 goals and objectives for public health.  Each action item is presented under an
 appropriate objective and is referenced to the goal or goals to which it most
 directly contributes. Each action item includes a target date, which is, in the
 Subcommittee's judgment, the date by which the action could be initiated. Some
 action items are cross referenced to other action items  and are designated with a
 "-*•" sign.  This signals  a close relationship among those actions and a need for
 coordination.  Some of  the activities listed may already be underway; these items
 will be highlighted and will contain a short "status" update on the progress of
 the activity in future Action Agendas.

 The Public Health Subcommittee has identified a lead  agency for each action
 item-trie agency with the most  authority or jurisdiction over the particular
 issue.   This does not necessarily  mean that the agency has agreed to carry out  the
 activity or  that the agency has the  necessary funding.   The Public Health
 Subcommittee  understands  these action items will require  commitments by
 agencies and organizations  that  are dependent on budget decisions.   However,
 the Subcommittee members hope this document provides the rationale and
 support for such commitments and that future revisions  of this document will
 include additional specific commitments.

 The Gulf of Mexico Program recognizes the need to identify indicators of
 environmental progress relative  to this Action Agenda for public health. Many
 of the action items specified in Chapter IV of this document will aid the Program
 in developing a baseline for measuring success in the future. For the time being,
 however, acceptance and completion of action items specified in this Action
 Agenda will be considered a measure of success.  As future Action Agendas are
 written, and current action items are completed, new action items will be
 developed to better measure environmental progress.  The Gulf of Mexico
 Program will coordinate among  the ten Gulf of Mexico Program Subcommittees
 to eliminate overlap and duplication of efforts, as well  as to integrate goals and
 activities across  environmental issue areas.
Gulf of Mexico Public Health Action Agenda  4.1
64

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Tfie Un fin Ish ed Agen da
IV
Research and Demonstration

To protect human health from the threats posed by the introduction of or naturally-
occurring contaminants, more complete knowledge is needed concerning the
behavior and effects of such materials. In addition to improving scientific
knowledge, research is also integral to developing more accurate, practical, and cost-
effective methods and technologies for monitoring and sample analyses.  Most
research funds are administered by federal agencies or state program offices in
support of specific missions, with only limited funding going to research that
examines the cumulative effects of decisions on the ecosystem as a whole. This
action planning process provides the necessary mechanism to enable the producers,
consumers, and funders of research to agree on priorities. A closer connection
should be established between the research agenda of the scientific community and
the information needs of managers, regulators, and those involved in decisions for
the management of the Gulf of Mexico. Once a research agenda is developed and
implemented, the research results should be used to understand the underlying
processes and relationships and make appropriate decisions regarding management
of Gulf waters.

Specific objectives and action items under this strategy include:


OBJECTIVE: Conduct scientific studies designed to contribute new
empirical information pertinent to the prevention of illness in those
exposed to Gulf waters or from consumption of products harvested from
Gulf waters.
 ACTION ITEM 1 • Methods for Identification of Indicator Organisms
               Originating From Human Focal Sources
Develop and evaluate methods for identification of indicator
organisms that originate from human fecal sources.
Load Agency

Goal: 1
Interstate Shellfish Sanitation Conference and
National Oceanic and Atmospheric Administration,
in coordination with Food and Drug
Administration, Environmental Protection Agency,
the academic communitv, and industrv
1995
-» 32
  Gulf of Mexico Public Health Action Agenda 4.1
                                                                        65

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  Th& Un finish ed Ay en da
                                                                 Chapter IV
 ACTION ITEM 2 -Identification of Sources of Chemical Contaminants and
                Pathogens
                Identify major sources of chemical contaminants and pathogens
                related to public health concerns from consumption of Gulf seafood
                and/or contact with Gulf waters.
                Load Agency
                Target Dat«_
 Environmental Protection Agency, in coordination
 with Gulf States, Toxic Substances and Pesticides
 Subcommittee, and Public Health Subcommittee
 1994
                Status
                Goal; 1,3 & 4
 The Public Health Subcommittee characterization
 report is scheduled for completion in May 1993.  The
 Toxic Substances & Pesticides Subcommittee
 characterization reports are scheduled for
 completion in 1993.	'   	
 ACTION ITEM 3 - State Ambient Water Quality Assessment and Monitoring Needs
                Describe the existing quality of fresh, marine and estuarine ambient
                waters of the five Gulf Coast States.  The resulting report will
                include an assessment of the adequacy of the monitoring schemes
                employed to collect the data. This will be accomplished by
                conducting a side-by-side analysis of selected marine/estuarine
                bathing beaches in each of the five Gulf States during 1992.  Each
                state will include in its monitoring plan new assays for enterococci
                or E. co/i. to determine the state's abilities to successfully enumerate
                the new bacteria and to improve monitoring frequency.  The Gulf of
                Mexico Program will serve as the coordinator of the project and
                assist in evaluation of the results.
                Lead Agency    EPA's Office of Research and Development, in
                               coordination with Gulf Coast States (agencies with
                               responsibility for monitoring ambient
                               microbiological water quality)	
               Target Date
1993
               Goal: 4
                              -* 14. 1S. 25
ACTION ITEM 4 • Atmospheric Deposition Research
               Complete research on potential air to water transfers of pollutants by
               continuing to site atmospheric deposition monitoring stations
               within the Gulf region and analyze the results
               Lead Agency    Environmental Protection Agency's Office of Air
                              Quality Planning and Standards (OAOPS)	
               Target Data
1994
               Goal:  3
Gulf of Mexico Public Health Action Agenda 4.1
                                           66

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The Unfinished Agenda
                              Chapter IV
OBJECTIVE: Identify and characterize marine biotoxins and progenitors
that have not been investigated and continue to develop and improve
methods for the detection and management of marine biotoxins.
ACTION ITEM 6 • Discussion Meeting-Coordination of Marine Biotoxins Research
Convene a meeting of appropriate academic, state, and federal
organizations to discuss the need for and a mechanism/process to
coordinate marine biotoxins research.
Lead Agency
Tarciet Date
Goal: 2
Gulf of Mexico
Subcommittee
1993
-» 6
Program Public Health


ACTION ITEM 6 • Coordination of Marine Biotoxins Research
              Initiate new coordination mechanisms for marine biotoxins research
              by contingent upon the results of Action Item 5.
              L»ad Agency   Food and Drug Administration, National Marine
                            Fisheries Service, Environmental Protection
                            Agency, and National Institute of Health	
              Target Dat«»
1995
               Goal: 2
 Gulf of Mexico Public Health Action Agenda 4.1
                                                                     67

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  The Unfinished Agenda
                                 Chapter IV
 Monitoring/Assessm en t

 The occurrence, distribution, and types of human illness resulting from
 consumption of Gulf of Mexico seafoods and direct contact with Gulf of Mexico
 waters is currently reported on a limited basis. The ability to link water pollution
 with public health problems and take corrective action is thus hindered.
 Establishing an adequate baseline is very important for monitoring these conditions
 and for measuring the success of this action plan. Current information should be
 used to develop a statistically valid baseline from which to monitor changing
 conditions in the rates and distribution of public health issues related to the Gulf of
 Mexico. Future activities and information collection can then be incorporated into
 the data base. Gulf-wide priorities need to be set and procedures established to
 improve the inventorying and monitoring of this information among agencies and
 programs.

 Specific objectives and action items under this strategy include:


 OBJECTIVE: Determine the extent of human fecal pollution of shellfish
 growing areas in the Gulf of Mexico.
ACTION ITEM 7 • Survey & Classification of Shellfish Growing Areas
               Survey and classify all shellfish growing areas in Gulf Coast States
               and in federal waters in accordance with the National Shellfish
               Sanitation Program (NSSP).
               L.ad Agency    State Shellfish Control Agencies, in conjunction
                              with Food and Drug Administration	
               Target Pate..
               Status
               Goal: 1
1993
The Mississippi Department of Wildlife, Fisheries
and Parks is currently accomplishing this. Louisiana
is currently accomplishing this through their Oyster
Water Monitoring Program.
                              -* 13,  19
Gulf of Mexico Public Health Action Agenda 4.1
                                          68

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The Unfinished Agenda
                                 Chapter IV
OBJECTIVE: Establish a formal database on the occurrence of seafood-
borne disease.
ACTION ITEM 8 • Standard Reporting for Seafood-borne Disease
               Establish minimum data sets and standard reporting formats, as well
               as case definitions, for use by states in reporting the occurrence of
               seafood-borne disease.  CDC should also prepare an annual report on
               the occurrence of seafood associated diseases for the Gulf region and
               other regions of the country.	
               Lead Aaencv
Centers for Disease Control
               Target Dato
1993
               Statue
               Goal; 1, 2 ft 3
While all seafood-borne diseases are considered
reportable, there are currently no specific report
requirements.  Reports are initiated at the county
level and then reported to the state.  If the disease is
shellfish-related, the state then reports to FDA.
Individual states have specific report requirements
and these requirements vary from state to state.
ACTION ITEM 9 - Regular Reporting of Seafood-borne Diseases
               Establish a mechanism for regularly reporting and compiling data on
               the occurrence of seafood-borne disease. This effort should
               accommodate and improve upon any existing data.	
               Lead Aaen«tv
Gulf States
               Target Pat«
1993
               Status
This is currently being done by the Louisiana
Department of Health and Hospitals Epidemiology
Section through data supplied from various sources
(hospitals, consumers, parish health units, etc.).
               Goal: 1, 2 ft 3
 Gulf of Mexico Public Health Action Agenda 4,1
                                            69

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 The Unfinished Agenda
                                  Chapter IV
 OBJECTIVE: Determine Gulf Coast residents at risk from consumption of
 potentially contaminated seafood.
 ACTION ITEM 1O - Seafood Consumption Patterns Study
                Conduct a study of the seafood consumption patterns of residents of
                the Gulf Coast States. This study should have a region-wide focus,
                include a determination of the consumption patterns of subsistence
                and recreational fishermen, other potentially sensitive
                subpopulations, as well as the general public in the Gulf States, and
                identify the most common species consumed.
                    Agency    National Marine Fisheries Service, in coordination
                              with Environmental Protection Agency	
               Target Data
 1993
               Goal: 3
                              -» 12, 13, 19
ACTION ITEM 11 - Seafood Contamination Data Collection
               Collect and summarize all existing data on incidence of seafood
               contamination by toxic substances, trace metals, and pesticides.	
               Lead Agency
               Target Data
               Status
               Goal: 3
_Gulf States
 1993
 EPA Region 4 has been surveying the eight
 southeastern states to determine the status of
 fish/shellfish tissue contamination data, as well as
 consumption advisories which have been issued or
 lifted over the years.  	_____	
                              -» 1 2
ACTION ITEM 12 - Evaluation of Seafood Contamination and Consumption
                  Information
               Evaluate seafood contamination and consumption information to
               determine any additional data needs.
               Load Agency    Gulf of Mexico Program Public Health
               	Subcommittee	
               Target Dai»_
               Goal: 3
1995
                              -» 10, 11, 13. 24
Gulf of Mexico Public Health Action Agenda 4.1
                                           7O

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The Unfinished Agenda
                                Chapter IV
ACTION ITEM i3 • Comprehensive Seafood Contamination Data Monitoring
                 Prog rant
               Develop a comprehensive monitoring program to provide seafood
               contamination data for risk assessment and to track long-term trends
               in contaminant levels of Gulf waters. A systematic sampling
               program should be developed for relevant seafood species for the
               purpose of human health assessments. The program should include
               many species and locations and should be designed for providing
               health advisories in specific locations.	
               Lead Agency    Food and Drug Administration, in coordination
               	     with Gulf State laboratories
                             1993
               Goal: 3
-» 7, 1O, 12, 13, 16, 19
OBJECTIVE: Survey Gulf Coast bathing beaches for the presence of
human fecal wastes and other pathogens (i.e., vibrio).
ACTION ITEM f 4 • Survey of Current Practices for Monitoring Bathing Beaches
               Conduct a survey of Gulf States to determine current practices and
               regulations concerning monitoring of coastal bathing beaches for
               bacterial contamination by human waste.  In addition, GMP should
               evaluate the available data to determine its suitability for judging
               the bacterial contaminant levels at Gulf Coast bathing beaches.
               Lead Agency    Gulf of Mexico Program Public Health
               	Subcommittee	
               Taraet Date
1993
               Goal: 4
— 3, IS, 25
ACTION ITEM IS • State Bathing B&ach Monitoring Plans
Implement ongoing bathing beach monitoring
upon results of Action Item 14).
plans (contingent
LeadAaenev Gulf States
Tarael Date 1995
Goal: 4 -» 3, 14, 25
Gfulf of Mexico Public Health Action Agenda 4.1
                                          71

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 The Unfinished Agenda
                                 Chapter IV
OBJECTIVE: Assess the public health significance of marine biotoxins in
the Gulf of Mexico.
ACTION ITEM 16- Toxigonic Phytoplankton Monitoring Program foe Inshore
                  Water*
               Initiate a program to monitor inshore waters for the frequency,
               duration, and impact of toxic phytoplankton blooms which affect
               human health (through consumption of seafood and/or contact via
               aerosols and skin).  Phytoplankton should be collected, identified,
               and analyzed for toxin production.  Based on this information, the
               degree of public health significance should be assessed.
               Lead Agency    Food and Drug Administration, in coordination
                              with Gulf of Mexico Program Public Health
                              Subcommittee and National Marine Fisheries
                              Service
               Target Date
1994
               Goal: 2
-» 13, 17, 10
ACTION ITEM 17- Monitoring Program lor Marine Blotoxln Residues In Shellfish
                  andFlnflsh
               Monitor shellfish and finfish, concurrently with Action Item 16,
               from inshore waters for the origin of marine biotoxin residues
               present in the Gulf of Mexico. Based on this information, the degree
               of public health significance should be assessed.
               Lead Agency    Food and Drug Administration, in coordination
                              with Gulf of Mexico Program Public Health
                              Subcommittee and National Marine Fisheries
               	Service	
               Target Date
1994
               Goal: 2
-» 13,  16
Gulf of Mexico Public Health Action Agenda 4,1
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The Unfinished Agenda
                                            Chapter IV
OBJECTIVE: Implement remote-sensing technologies for the detection of
phytoplankton blooms/red-tides in the early stages of development.
ACTION ITEM 18
Remote-Sensing Technologies for the Detection of
 Phytoplankton Blooms/Red-Tides
              Determine the current capabilities for remote-sensing technologies
              for the detection of phytoplankton blooms/red-tides in the early
              stages of development and distribute this information to
              responsible/interested parties.	
                   Agency    National Marine Fisheries Service, in coordination
                             with Gulf of Mexico Program Public Health
                             Subcommittee	
              Target Date>
            1993
               Goal: 2
 Gulf of Mexico Public Health Action Agenda 4.1

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 T/ie Unfinished Agenda
                                 Chapter IV
 Stan dards/En forcem en t


 The effective prevention of human illness resulting from consumption of Gulf
 seafood or direct contact with Gulf of Mexico waters will require cooperation from
 many federal, state, and local governments, and private and public user groups, as
 well as a long-term commitment of financial and organizational resources.

 The setting of standards is an essential component of pollution prevention.
 Standards determine enforceable limits and provide a measure for improving
 environmental quality.  The development of compatible standards among federal
 agencies and Gulf Coast States is crucial in order to reduce public health concerns in
 the Gulf of Mexico.

 Laws designed to prevent and reduce public health concerns are difficult to enforce.
 Inadequate enforcement usually results from competing priorities among programs,
 inadequate funding, or lack of expertise in developing needed ordinances or
 programs.

 Specific objectives and action items under this strategy include:
OBJECTIVE: Reduce the level of human fecal wastes in the coastal waters
of the Gulf of Mexico.
ACTION ITEM 19 • Reopening of Gulf Coast Areas Currently Closed Due to Poor
                  Water Quality
               Based on the findings of related Action Items 7,13, and 16, reopen
               areas along the Gulf Coast that are currently closed due to poor water
               quality.  Shellfish beds and bathing beaches should be targeted
               specifically, thus reducing the likelihood of illness.       	
               Lead Agency
_Gulf States
               Target Data
 1996
               Status
               Goal: 1 & 4
 The Mississippi Department of Wildlife, Fisheries
 and Parks is currently accomplishing this.	
 •* 7, 13, 16, 30, 31
Gulf of Mexico Public Health Action Agenda 4.1
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The Unfinished Agenda
                                               Chapter iV
ACTION ITEM 2O • "No Discharge" Areas In State Waters
Adopt "no discharge" areas for all wastes from boats in
state waters.
Lead Aaenev
Taraet Date
Goal: 1 & 4
Gulf States
1995
-* 41
OBJECTIVE:  Establish a Gulf Coast Fish Contaminants Group (GCFCG).
ACTION ITEM 21 • Gulf Coast Fish Contaminants Group
               Facilitate the formation of a Gulf Coast Fish Contaminants Group
               (GCFCG) to develop consistent interagency policies and procedures
               relative to seafood contamination and public health, to conduct
               workshops, and to review state applications of developed guidelines.
               Lead Agency    Gulf of Mexico Program Public Health
               	Subcommittee
               Target Date
               1993
               Goal: 1 & 3
ACTION ITEM 22 • Consistent Intel-agency Policies and Procedures Relative to
                  Seafood Contamination and Public Health
               Encourage EPA and FDA to develop consistent policies and
               procedures relative to seafood contamination and public health and
               update action levels for all pollutants of concern that are found in
               fish and shellfish in the Gulf of Mexico.	
Lead
                             Gulf Coast Fish Contaminants Group
               Target Date
               1993
               Goal: 1 & 3
ACTION ITEM 23 - GCFCG Workshops
               Conduct workshops to develop sampling and laboratory protocols,
               procedures for public health risk assessment and risk management,
               and consumption advisory procedures.
               Lead Agency    Gulf Coast Fish Contaminants Group, in
               	coordination with Gulf State laboratories
               Target Date
               Goal: 1 & 3
               1994
Gulf of Mexico Public Health Action Agenda 4.1
                                                         7G

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TH& Unfinished Agenda
                                Chapter IV
OBJECTIVE:  Encourage states to adopt compatible policies for
management of public health hazards.
ACTION ITEM 24 • Review of State Applications of Developed Guidelines
               Review state application of developed guidelines to determine
               whether Gulf States have adopted compatible polices for
               management of public health hazards related to consumption of
               seafoods.	
               Lead Agency    Gulf Coast Fish Contaminants Group
               Target Date
1995
               Goal: 1 & 3
-» 1 2
ACTION ITEM 25  • State Review, Evaluation & Adoption of New Bacteriological
                  Criteria for Recreational Waters
               Review and evaluate EPA's newly recommended bacteriological
               criteria for protection of Gulf bathing beaches and other recreational
               waters.  Each Gulf State should then initiate appropriate
               administrative procedures to adopt and implement new recreational
               criteria as state standards. To the extent practicable, Gulf States
               should work among themselves to adopt compatible bacteriological
               standards with regard to bathing beaches and recreational waters that
               are adjacent or common to bordering states.	
               Lead Aaenev
Gulf States
                              1994
               Goal: 4
-* 3, 14, 15
ACTION ITEM 26 • State Ballast Exchange Guidelines
               Adopt ballast exchange guidelines, patterned after the International
               Maritime Organization guidelines in effect for the Great Lakes area,
               to prevent the discharge of contaminated ballast from ships in
               critical productive estuaries. This action should be supported by a
               sampling program because of the recent detection of cholera in
               Mobile Bay.	
               L«ad Agency    Gulf States, in coordination with Environmental
               	Protection Agency and U.S. Coast Guard	
               Taraet Date
1995
               Goal: 1 & 4
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The Unfinished Agenda
                                 Chapter IV
ACTION ITEM 27 - Minimum Criteria for Septic Systems in Critical Areas
               Develop minimum criteria for septic systems in critical areas (such
               as estuarine watersheds). To accomplish this, a working group
               consisting of septic system regulators from the Gulf Coast States  .
               should be convened. Examples of criteria which may be developed
               include:  1) operating permit requirements, 2) mandatory use of
               aerobic systems in new installations, and 3) prohibition of new
               systems within flood-prone areas.	
               Lead Anenev
Gulf State regulatory agencies
               Target Date
1993
               Status
A meeting has been tentatively scheduled for
February 1993.	
               Goal:  1 & 4
-* 28
ACTION ITEM 28 • Adoption & Implementation of State Standards for Septlo
                  Systems
               Initiate adoption and implementation of recommended criteria for
               septic systems as state standards through the appropriate process in
               each state by 1994. The Gulf of Mexico Public Health Subcommittee
               will transmit recommended criteria to the governor and appropriate
               state agencies of each Gulf Coast State by 1993 with the
               recommendation that they be adopted as state standards.	
               Lead Aoencv
Gulf States
               Target Date
1994
               Goal: 1 & 4
-» 27
ACTION ITEM 29 • Alternatives to Septic Tank Systems
               Explore opportunities for alternatives to septic tank systems in low
               lying coastal areas. The potential for requiring alternative systems,
               such as composting and incinerator toilets, for new development in
               coastal areas should be investigated.	
               Lead Aaenev
Gulf States
               Target Date
1994
               Goal: 1 & 4
Gulf of Mexico Public Health Action Agenda 4.1
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 The ,Un finish ed Agen da
                                 Chapter IV
ACTION ITEM 3O • Microbiological & Chemical Standards for POTW Permits In
                  Shellfish Areas
               Incorporate microbiological and chemical standards into the NPDES
               and/or state permits of POTWs discharging in the vicinity of
               shellfish growing areas.  These standards should be sufficiently
               stringent to prevent negative effects except in extreme rainfall
               conditions.	
               Lead Agency    Environmental Protection Agency or delegated Gulf
               	States
               Target Data
1995
               Goal: 1
                              -» 18, 31
ACTION ITEM 31 • Limits on Microorganisms In NPDES Permits for POTWs Noar
                  Bathing Beaches
               Modify NPDES permits for POTWs in coastal areas to include limits
               on microorganisms that will allow bathing beach ambient water
                ualitv standards to be achieved.
               Lead Agency    Environmental Protection Agency or delegated Gulf
               	States	
               Taraet Date
1994
               Goal: 4
-» 19, 30
ACTION ITEM 32 • State Adoption of New Indicators of Fecal Pollution
Adopt new indicators of fecal pollution developed by the National
Indicator Study during 1995 as the standard for shellfish growing
waters.
Lead Agency
Target Date
Goal: 1
Food and Drug Administration, Gulf States, and
Interstate Shellfish Sanitation Conference
1996
-» 1
Gulf of Mexico Public Health Action Agenda 4.1
                                           78

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The Unfinished Agenda
                                Chapter IV
OBJECTIVE: Standardize methods for marine biotoxin recovery and
analysis from phytoplankton producers and seafood vectors.
ACTION ITEM 33 - Marine Biotoxin Recovery & Analysis Manual
              Assemble all pertinent information regarding marine biotoxin
              recovery and analysis from phytoplankton producers and seafood
              vectors into a manual format which should be re vie wed/edited by
              appropriate marine biotoxin specialists.	
              Lead Aaenev
Jood and Drug Administration
              Target Date
 1993
              Goal: 2
ACTION ITEM 34 • Distribution of Marine Biotoxin Manual
              Disseminate the marine biotoxin manual to Gulf Coast laboratories
              (academic, state, and federal) and encourage their compliance with
              the methods when engaged in marine biotoxin investigations.
              Further, GMP, FDA, and NMFS should solicit their participation in a
              Gulf-wide monitoring and assessment program.  	
              Load Agency    Food and Drug Administration, in coordination
                             with Gulf of Mexico Program Public Health
                             Subcommittee and National Marine Fisheries
              	     Service	__	
              Target Date
 1993
              Goal: 2
ACTION ITEM 35 • Update/Adoption of Marine Biotoxin Action Levels
Update or adopt action levels for all known marine biotoxins.
Load Agency
Target Date
Food and Drug Administration and National
Marine Fisheries Service
1993
Goal: 2
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The Unfinished Agenda
                                Chapter IV
OBJECTIVE: Organize a Gulf-wide marine biotoxins management and
consulting group.
ACTION ITEM 36 - Investigations for Biotoxin Outbreaks
               Solicit participation of a limited number of marine biotoxin
               specialists from academic, state, and federal organizations to provide
               assistance in the management and conduct of marine biotoxins
               investigations when outbreaks occur and to develop a manual that
               discusses ways to deal with outbreaks and marine biotoxin
               investigations.	
               L*ad Agency    Food and Drug Administration, in coordination
                             with Centers for Disease Control and National
               	Marine Fisheries Service	
              Target Date
1993
               Goal: 2
-» 44
Gulf of Mexico Public Health Action Agenda  4.1
                                          8O

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The Unfinished Agenda
Chapter IV
Public Outreach:  Education and Involvement

People living in two-thirds of the United states ultimately affect the environmental
quality of the Gulf of Mexico. Alternatively, the entire population of the U.S. can
potentially be affected by the environmental quality of the Gulf either from products
harvested from the Gulf of Mexico or from contact with Gulf waters.  Therefore,
effective public health policy requires an ongoing commitment from  an informed
citizenry.  Public outreach nurtures such a commitment.  Public information,
education, and involvement  are three components of  an effective outreach strategy,
which can reap significant benefits both for the Gulf of Mexico and for citizens
utilizing its resources. More and more,  public outreach is recognized  as an effective
resource management tool to address problems resulting from individual actions
and to create a sense of stewardship within the community.  A committed citizenry
presents both a supplement  and an alternative to enforcement programs.

Public outreach can foster recognition of the Gulf as a regional and national
resource; stimulate civic, governmental, and private sector support for changing
lifestyles; and develop the financial commitments necessary to preserve the
resource. Because the general public  can play an important role in the policy
making process, an essential aspect of an effective outreach program is education
about the sources and causes of contamination of the Gulf of Mexico.   Also, an
extensive public education and awareness program can reduce the incidence of
illness resulting from exposure to Gulf waters or products harvested from the Gulf
of Mexico.  A strong outreach program showing the effects human activities have
upon the health of the Gulf  must enable all individuals, whether living on the coast
or along the upper stretches  of the Mississippi, to see themselves as caretakers of a
vital, shared resource.

Specific objectives and action items under this strategy include:
 Gulf of Mexico Public Health Action Agenda 4,1
           81

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 The Unfinished Agenda
                                Chapter IV
 OBJECTIVE: Undertake an educational campaign to:  1) help the public
 understand and control or minimize potential risks associated with the
 consumption of raw molluscan shellfish; 2) help health care professionals
 understand the potential risks associated with the consumption of raw
 molluscan shellfish, especially for high risk patients, and to transmit
 information to those patients; and encourage the reporting of shellfish-
 associated illness; 3) help legislative and judicial members understand the
 seriousness of violations of shellf ishing regulations related to public
 health; and 4) inform enforcement officials about public health aspects of
 shellfishing regulations.
ACTION ITEM 37 - Educational Materials on Risks Associated with Consumption of
                  Raw Molluscan Shellfish
               Ensure the development of appropriate educational materials about
               the risks associated with consumption of raw molluscan shellfish,
               and how to avoid, control or minimize those risks.  A specific
               educational package should be developed for each of the following
               groups: 1) the public (especially high risk individuals), 2) the
               medical community, 3) judicial and legislative members, and 4)
               enforcement officials. Where appropriate, materials should be
               printed in Vietnamese, French, and Spanish, in addition to English.
               To accomplish this, GMP should evaluate and integrate current
               efforts by groups such as FDA, ISSC, NFI, FMI, Sea Grant
               Universities, state health departments, and the Southeastern
               Fisheries Association (SFA).
               L*ad Agency    Gulf of Mexico Program Public Health
                             Subcommittee, in coordination with the Public
                             Education and Outreach Subcommittee and Citizens
                             Advisory Committee	
              Target Date
1993
              Goal: 1
Gulf of Mexico Public Health Action Agenda 4.1
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The Unfinished Agenda
                                Chapter IV
OBJECTIVE: Help the public understand both the nutritional/health
benefits and the potential risks from consumption of seafood, other than
raw molluscan shellfish,, as well as how to maximize those benefits while
avoiding, controlling, or minimizing the risks.
ACTION ITEM 38 • Educational Effort/Materials on Benefits & Risks From
                 Consumption of Seafoods
              Evaluate arid integrate current educational efforts to develop Gulf of
              Mexico Program materials to inform the public of both the
              nutritional/health benefits and the potential risks from
              consumption of seafood, other than raw molluscan shellfish, as well
              as how to maximize those benefits while avoiding, controlling, or
              minimizing the potential risks.	
              Lead Agency    Gulf of Mexico Program Public Health
                             Subcommittee, in coordination with the Public
                             Education and Outreach Subcommittee and Citizens
              	     Advisory Committee	
              Target Date
1993
              Goal:  3
ACTION ITEM 39 • Recreational & Subsistence Fishing Guide
Develop a guide for recreational and subsistence fishermen to: 1)
identify popular Gulf of Mexico fishing sites, and 2) provide
consumption advice on different fish species at specific locations.
Lead Agency
Taraet Date
Status
National Oceanic and Atmospheric Administration,
Sea Grant, and Gulf Coast Fish Contaminants Group
1994
Currently, NOAA Status & Trends conducts limited
testing of oysters and EMAP tests for selected trace
metals and organic compounds in specific fish
species in the Gulf of Mexico.
Goal: 1 & 3
Gulf of Mexico Public Health Action Agenda 4.1
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 Th& Un finishecf Agen da
                                 Chapter IV
 ACTION ITEM 4O • Assessment of Signs & Warnings in Limiting Consumption of
                   Contaminated Sports Fish Species
Integrate ongoing efforts to assess the effectiveness of signs and
warnings in limiting consumption of contaminated sports fish
species bv recreational and subsistence fishermen in thp Gulf.
Lead Agency
Target Date,
Gulf of Mexico
Subcommittee
1993
Program Public Health

Goal: 3
ACTION ITEM 41 - Educational Program on Impacts of Boat Discharges on
                  Seafood
               Develop a program, in coordination with the Boater's Pledge
               Program, to educate the boater community about the potential
               impacts of discharges from boats on seafood. As part of this
               program, information concerning the potentially harmful effects of
               boat discharges on seafood should be included in existing boating
               safety and training programs.
               Lead Agency    U.S. Coast Guard, in coordination with Gulf of
               	Mexico Marine Debris Subcommittee	
               Target Date
               Status
               Goal: 1 & 3
1993
USCG will publish information on the impacts of
boating discharges and distribute it to all Coast
Guard Auxiliary Squadrons on the Gulf Coast. This
information will also be made available to the
boating community through the outreach efforts of
the Auxiliary and the Fishing Vessel Safety
Program.	
Gulf of Mexico Public Health Action Agenda 4.1
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The Unfinished Agenda
                                Chapter IV
OBJECTIVE: Help the public, especially high risk populations, understand
the risks associated with recreational and occupational exposure to
naturally occurring pathogens (i.e.: vibrio) in marine waters.
ACTION ITEM 42 • Marino Water Contact Advisories Related to Recreational &
                  Occupational Exposure
               Develop a standardized public information message for marine
               water contact advisories related to recreational and occupational
               exposure. Health care professionals and especially high risk
               populations should be targeted for this advisory message.	
               Lead Agency    Gulf of Mexico Program Public Health
                             Subcommittee, in coordination with Public
               	Education and Outreach Subcommittee
               Taraet Date
               Goal: 4
1993
ACTION ITEM 43 - Educational Materials for Physicians
               Develop educational materials to increase the awareness of
               physicians about the importance of reporting illnesses and infections
               resulting from recreational and  occupational contact with marine
               waters.	
               Lead Agency    Gulf of Mexico Program Public Health
               	     Subcommittee	
               Target Dat«>
1993
               Goal: 4
 Gulf of Mexico Public Health Action Agenda 4.1
                                          86

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 The Unfinished Agenda
                                                            Chapter IV
 OBJECTIVE: Help the public understand the risks associated with
 consumption of seafood contaminated with marine biotoxins and the risks
 associated with direct exposure to marine biotoxins.
ACTION ITEM
                - Public Information Releases on the Effect of Marine Blotoxln*
                  on Public Health
               Solicit advice from appropriate state and federal organizations, the
               public, and the academic community concerning the form and
               content of public information releases on the effect of marine
               biotoxins on public health.  Based on these findings, appropriate
               public education materials should be developed.
               L«ad Ag*ney    Gulf of Mexico Program Public Health
                             Subcommittee, in coordination with the Public
                             Education and Outreach Subcommittee and Citizens
               	Advisory Committee	
                    Date
                            1993
               Goal: 2
                             -» 36
Gulf of Mexico Public Health Action Agenda 4.1
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Conclusions
                                                       Chapter V
V.
CONCLUSION
We intend this document to be a beginning, not an end.  Our hope is that this
Action Agenda will serve as an inspiration and a call to action for the thousands
who live and work in the Gulf of Mexico region.  Through purposeful and
coordinated action we hope to eliminate public health threats from contaminated
seafood and bathing beaches within Gulf of Mexico waters.

Through the implementation of  the action items highlighted in this Action
Agenda, we can control and eventually eliminate public health threats in the Gulf
of Mexico.
                       The Gulf of Mexico Program
                       Public Health Subcommittee
 Gulf of Mexico Public Health Action Agenda 4.1
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Bibliography
BIBLIOGRAPHY
Ahmed, F.E.  1991.  Seafood Safety.  Institute of Medicine. Food and Nutrition
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Alabama  Department of  Environmental  Management.  Water  Quality  Criteria.
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Broutman, M.A.  and D. L. Leonard.   1988.  National Estuarine Inventory:  The
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Buff, V. and S. Turner.  1987. "The Gulf Initiative."  Coastal Zone.

Cabelli, V. J.  1983.  "Health Effects Criteria for Marine Recreational Waters." EPA
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Caswell, J.A. 1991. Economics of Food Safety.  Elsevier Science Publishing Co., Inc.
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Cato, J. C. and H. E. Kumpf.  The Economic Influence of Population Growth,
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Day, J.W. Jr. and N.J. Craig. 1981.  "Comparisons of effectiveness of management
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General Accounting Office. 1991.  Federal Food Safety and Quality Programs. RECD-
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Gulf States Marine Fisheries Commission.  1991.  The Oyster Fishery of the  Gulf of
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Halstead, B. W.  1967. Poisonous and  Venomous Marine Animals  of  the World.  U.
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Johnston, J.  1991. U.S. Fish  and Wildlife Service. Personal communication.

Kaplan, J.E., R.A. Goodman, L.B. Schonberger, E.C. Lippy, and G.W. Gary. 1982.
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 Blbllograp hy
 Ministry of the Environment.  1990. 2990 Guide to Eating Ontario Sport Fish.
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 National Academy of Sciences. 1991.  Seafood. Safety.  Committee on Evaluation of
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 National Oceanic & Atmospheric Administration.  1988. "Gulf of Mexico
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 National Oceanic & Atmospheric Administration.  1989. "A Summary of Data on
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 National Oceanic & Atmospheric Administration.  1990a.  Fisheries of the United
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 National Oceanic & Atmospheric Administration.  1990b.  National Coastal
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 National Oceanic & Atmospheric Administration.  1991.  The 1990 National
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 Office of Technology Assessment. 1987. Wastes in Marine Environments.  Office of
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 Pait, A.S., D.R.G. Farrow, J.A. Lowe, and P.A. Pacheco.  1989.  The National Coastal
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 Steidinger, K. A.  1983.  "A Re-evaluation of Toxic Dinoflagellate Biology and
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U.S. Department of Commerce. 1990a.  A Special Earthweek Report: 50 Years of
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Bibliography
U.S. Department of Commerce.  1990b. Estuaries of the United States:  Vital
      Statistics of a National Resource Base.  National Oceanic and Atmospheric
      Administration. National Ocean Service.

U.S. Department of Commerce. National  Oceanic and Atmospheric
      Administration. National Ocean Pollution Program.  1991.  Draft Federal
      Plan for Ocean  Pollution  Research, Development, and Monitoring, Fiscal
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U.S. Department of Commerce.  1992.  Fisheries of the United States, 1992. National
      Oceanic and Atmospheric Administration. National Marine Fisheries
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U.S. Environmental Protection Agency. 1988a.  Red Tide in the Eastern Gulf of
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U.S. Environmental Protection Agency. 1991a.   Gulf Facts. Gulf of Mexico Program
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U.S. Environmental Protection Agency.  1991b.  Monitoring Guidance for the
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 Gulf of Mexico Public Health Action Agenda 4.1
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Acronym Guide
Appendix A
ACRONYM GUIDE

   AGI           Acute Gastroenteritis
   AMS          Agricultural Marketing Service, USDA
   APHIS         Animal and Plant Health Inspection Services
   ASP           Amnesic Shellfish Poisoning
   CAC           Citizens Advisory Committee, Gulf of Mexico Program
   CDC           Centers for Disease Control
   COE           Corps of Engineers, Army
   CWA          Clean Water Act
   DHH          Department of Health and Hospitals (Louisiana)
   DOD          Department of Defense
   DOE           Department of Energy
   DSP           Diarrheic Shellfish Poisoning
   EIS            Environmental Impact Statement
   EPA           United States Environmental Protection Agency
   FDA          Food and Drug  Administration
   FFDCA        Federal Food, Drug, and Cosmetic Act
   FMI           Food Marketing Institute
   FMP          Fishery Management Plan
   FSIS          Food Safety and Inspection Service
   FWS          U.S. Fish and Wildlife Service
   GCFCG        Gulf Coast Fish Contaminants Group
   GMP          Gulf of Mexico Program
   GSMFC        Gulf State Marine Fisheries Commission
   HACCP        Hazard Analysis Critical Control Point
   IJF            Interjurisdictional Fisheries Act of 1986
   ISSC          Interstate Shellfish Sanitation  Conference
   MARPOL      International  Convention for the Prevention of Pollution from Ships
   MMS         U.S. Minerals Management Service
   MOU         Memorandum of Understanding
   MPRSA       Marine Protection, Research and Sanctuaries Act
   MSD          Marine Sanitation Device
   NASA        National Aeronautics and Space Administration
   NFI           National Fisheries Institute
   NIH          National Institute of Health
   NMFS        National Marine Fisheries Service
   NOAA        National Oceanic and Atmospheric Administration
   NPDES        National Pollutant Discharge  Elimination System
   NFS          National Park Service
   NSP          Neurotoxic Shellfish Poisoning
   NSSP         National Shellfish Sanitation  Program
   NS&T        National Status & Trends, NOAA
    OAD          Oceans Assessment Division,  NOAA
    OSDS         On-site Sewage Disposal Systems
 Gulf of Mexico Public Health Action Agenda 4.1
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 Acronym Guide
                                                              Appendix A
    PHS
    POTW
    PRB
    PSP
    SCS
    TSC
    TFP
    USCG
    USDA
    USGS
    USPHS
Public Health Service
Publicly-Owned Treatment Works
Policy Review Board, Gulf of Mexico Program
Paralytic Shellfish Poisoning
Soil Conservation Service
Technical Steering Committee, Gulf of Mexico Program
Tetraodon Fish  Poisoning
U.S. Coast Guard
U.S. Department of Agriculture
U.S. Geological  Survey
U.S. Public Health Service
Gulf of Mexico Public Health Action Agenda 4.1
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Glossary
GLOSSARY
action levels
amnesic shellfish
poisoning (ASP)
 bacteria
 bioaccumulation
 biomagnification
Levels set to provide regulatory guidance to FDA field
personnel to determine whether or not a product should
be deemed adulterated and an appropriate enforcement
action imposed.

Syndrome caused by domoic acid.  Severe disease that has
only been identified in Canada during November and
, December 1988; this series of outbreaks involved 103
people.  The toxin is present in some varieties of the
diatom Nitzschia pungens and  accumulates in mussels
and darns during periods of blooms.  Symptoms include:
vomiting, abdominal cramps,  diarrhea, disorientation,
and memory loss.  Short term memory loss was the most
persistent symptom and lasted over a year in several cases.
The disease is particularly severe among older people,
some of whom died in the Canadian outbreak. Nitzschia
pungens and N. pseudodelicatissima reportedly occur in
northern U.S. and Canadian waters, and there is a
potential for development of toxicity  in shellfish growing
 in these areas. States in the northeastern U.S. are now
 testing for domoic acid.

 A group of procaryotic single-celled microorganisms.
 Most bacteria naturally live in, or can survive in, aquatic
 environments. Most marine bacteria associated with
 seafood are not harmful to man.  However, some vibrio
 species are pathogenic and specific subpopulations, such
 as immuno-compromised persons, are more
 susceptible. The primary pathway is consumption of raw
 or partially cooked molluscan  shellfish.

 The process of compounded concentration of substances
 in species whereby a substance enters an aquatic
 organism, either directly from the water through gills or
 epithelial tissue, or indirectly through consumption of
 other organisms.

 The process of compounded concentration of substances
 resulting from bioaccumulation whereby  tissue
 concentrations of bioaccumulated  substances increase as
 the material is passed up through more than one trophic
 level  in the food  chain.
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  Glossary
                                                                 Appendix B
  chemically
  contaminated
 ciguatera
 Crustacea
 depuration
 Presence of significant levels of undesirable (usually toxic)
 chemicals derived from the natural environment or from
 anthropogenic sources. Deep sea species are not generally
 susceptible, with the exceptions of mercury in
 swordfish, halibut, and some minor use species such as
 sharks.  Fresh water species, especially non-migratory
 bottom feeders, are generally the most exposed.  Chemical
 contaminants include industrial chemicals, heavy metals
 (some from natural sources), and pesticides. Some
 chemicals, at sufficiently high concentrations and if
 ingested for a long period of time,  may be toxic to a variety
 of human organ systems. Some chemicals are suspected
 of causing cancer. Strict limits are set for these, and for
 most chemicals, there is a level below which there is no
 cause for concern.

 A natural toxin originating from microorganisms that can
 accumulate in predatory reef fish in subtropical to tropical
 waters. Primarily associated with sport and subsistence
 fishing in tropical areas.  Problem species include grouper,
 snapper, barracuda, Spanish mackerel, and hog fish.

 A class of chiefly aquatic arthropods with segmented
 bodies and paired jointed limbs, including lobsters and
 crabs.

 Removal of biotoxins and pathogens from shellfish.
 Depuration is a potential management consideration that
 could increase shellfish production through a cleansing
 process.  Depuration may also be a  form of processing. By
 placing shellfish in depuration systems, they are being
 stored alive; thus the highest quality is maintained.  Since
 depuration reduces bacterial content, there is potentially a
greater assurance of product wholesomeness and
consumer acceptance. Consequently, depurated shellfish
may command higher prices and be in greater demand.
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Glossary
                                       Appendix B
diarrheic shellfish
poisoning (DSP)
domoic acid
£. coli
enterococci
enzyme unmunoassay
epiphytic
dinoflagellates
fecal colif orm


hazard


hazardous seafood


Hepatitis A
A toxin first isolated from mussels and scallops in 1976 in
Japan. The toxin is fat-soluble and was extracted from the
hepatopancreas of shellfish.  Epidemiological data indicate
that 12 mouse units (mu) will induce a mild form of
poisoning in humans.  The dominant symptoms are
diarrhea, nausea, vomiting, and abdominal pain
occurring within 30 minutes to a few hours after
ingestion. The agent responsible for the production of
this toxin is a marine dinoflagellate, Dinophysis fortii.
Other Dinophysis species, as  well as certain Prorocentrum
species, have been implicated as DSP producers.

A marine toxin produced by certain species of the diatom
genus Nitzschia.  This toxin is responsible for human
Amnesic Shellfish Poisoning.

A species of bacteria frequently found in the intestinal
tract of warm blooded animals and whose presence
indicates a degree of fecal contamination.

A group of bacteria whose presence indicates a degree of
fecal  contamination.

A method for detecting foreign substances which employs
the natural affinity and sensitivity of isolated antibodies
generated against the foreign substance of interest.   .

Dinoflagellates whose life cycle involves close association
or attachment to the surfaces  of larger macrophytic algae
(e.g., seaweeds).

A group of bacteria whose presence indicates a degree of
fecal  contamination.

An organism, substance, or condition having the
potential to cause disease.

Fish or shellfish, the consumption of which can lead to
disease.

An acute infectious disease that ranges from subdinical
infection to sever jaundice, liver degeneration, and death.
Onset ranges from 15 to 50 days after exposure.
Convalescence may be prolonged (several weeks to
months).
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 Glossary
                                       Appendix B
 marine biotoxins
marine dinoflagellates


minamata disease
(mercury poisoning)
molluscan shellfish
neurotoxic

Neurotoxic Shellfish
Poisoning (NSP)
 Poisonous compounds accumulated by shellfish feeding
 upon toxic microorganisms. The poisons may come from
 dinoflagellates such as Alexandrium spp. (formerly
 Protogonyaulax and Gonyaulax  catenella and G.
 amarensis) and Ptychodiscus brevis  (formerly
 Gymnodinium  breve).

 A group of microscopic algae which share common
 morphological characteristics.

 Chronic intoxication from organic mercury begins with
 paresthesia in extremities and leads to total nervous
 system involvement. The disease was named for
 Minamata Bay, Japan, where the disease as found in
 abundance.

 Marine bivalve invertebrates belonging to the phylum
 Mollusca, especially oysters, clams, mussels, and scallops.

 Substances which are detrimental to nerve cells.

 Symptoms of this poisoning are numbness and tingling
 around the mouth and face progressing to involvement
 of the hands and feet and sometimes accompanied by
 difficulty in walking. Deaths from this type of poisoning
 have not been reported. The causative agent is
 Gymnodinium  breve, a marine  dinoflagellate.
Norwalk &
Norwalk-like agents
order of magnitude
Paralytic Shellfish
Poisoning (PSP)
Unclassified viruses. Outbreaks of viral gastroenteritis
due to Norwalk agents have been associated with
swimming in waters contaminated with human sewage,
eating food or drinking water that is fecally contaminated,
and consuming uncooked or partially cooked shellfish
harvested from estuaries contaminated with human fecal
material.

One order of magnitude is ten-fold; two orders of
magnitude is 100-fold, etc.

This shellfish-associated neurotoxin causes paralysis that
may progress from numbness and slight tingling around
the lips, mouth, and face to death by  respiratory failure.
There is no known antidote and the only therapy is
supportive, artificial respiration. The toxin-producing
agents are marine dinoflagellates of  the Gonyaulax genus.
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Glossary
                                        Appendix B
pathogen


point source



Pyrrhophyta


red tide
risk

safety


scromboid poisoning
shellfish
shigelloides
An agent, especially a microorganism, such as a bacterium
or virus, that causes disease.

Any discernible confined and discrete conveyance that
carries pollution, including but not limited to a pipe,
ditch, channel, tunnel, or conduit.

The scientifically correct name for the division of
dinoflagellates.

A massive proliferation of microscopic marine algae such
that vast expanses of the ocean are discolored by their
presence. This dinoflagellate "bloom" can affect shellfish
and some finfish. The primary problem species are
molluscan shellfish (oysters, clams, mussels, and scallops).

Probability that a person will become ill from a hazard.

Probability that harm will not occur under specified
conditions.

This poisoning is caused by a histamine produced by
bacteria multiplying on fish that are mishandled after
capture. The disease is generally mild and self-resolving,
and  symptoms can be ameliorated by antihistamine drugs.
It is widely distributed geographically, but specifically
associated with consumption of specific species:  tuna,
mackerel, mahi mahi (game dolphin), and bluefish. The
disease can be prevented by rapidly cooling fish after
capture and maintaining cooling at all times before
cooking and eating.

All edible species of oysters, clams, mussels, crabs, shrimp,
whelks, conch, and scallops, either shucked, in the shell,
fresh or fresh-frozen, whole or in part.

P. shigelloides is a  common environmental isolate, which
is widespread in nature and is implicated as a cause of
human gastroenteritis.  It is specifically associated with
consumption of raw oysters.  Should be considered in any
program to limit exposure to bacterial pathogens in
shellfish, but there is a need to establish its pathogenicity
for humans before initiating any specific control
measures.
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                        90000
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