Shellfish Sanitation Program
The Connecticut Shellfish Program operates as part of the National Shellfish Sanitation Program (NSSP). The NSSP is a cooperative program consisting of state, FDA, and industry partners who agree to accept and meet specific responsibilities in order to ensure the safety of molluscan shellfish. Shellfish sanitation guidelines are published as the NSSP Guide for the Control of Molluscan Shellfish Model Ordinance (NSSP-MO). Each year the FDA evaluates Connecticut’s shellfish program for compliance with the NSSP-MO. This program is required to assure safe shellfishing areas for commercial and recreational harvesting, protection of public health and to maintain compliance with the U.S. Food and Drug Administration's National Shellfish Sanitation Program.
DA/BA responsibilities include leasing submerged state lands for shellfish operations (including aquaculture), classifying shellfishing waters, monitoring water quality, identifying sources of pollution, seeking corrective actions, and licensing of all commercial shellfish operations. These operations also include municipal recreational relays and scientific studies, as well as commercial seed oyster harvesting, relaying/transplanting operations, shellstock shipping which may include market harvesting, reshipping, shucking and repacking of shucked shellfish. DA/BA is also involved in seed oyster enhancement activities through its cultch program and licenses conch (whelk) fishing. DA/BA works closely with and depends upon the cooperation and assistance of each town where market harvesting, recreational shellfishing and relay activities are allowed in order to correctly classify shellfishing waters within each municipality. The enforcement of laws relating to illegal harvesting is handled by the Department of Energy and Environmental Protection (DEEP) Law Enforcement Division working cooperatively with municipal enforcement officials.
DA/BA performs coastal sanitary surveys along Connecticut's 250-mile shoreline and monitors shellfish growing areas in Long Island Sound for the protection of public health. Seawater samples are collected at numerous routine monitoring locations along the coastline and tested for fecal coliform bacteria. Fecal coliforms are an indicator group of bacteria, that when found at certain levels, suggest bacterial or viral contamination of the waters. Shoreline surveys are conducted to assess and correct sources of pollution. The DA/BA examines plankton tows and shellfish meats as necessary to evaluate the potential for marine biotoxins that can be formed by certain types of phytoplankton. DA/BA also posts signs in areas closed to shellfishing, performs hydrographic dye dilution studies, performs environmental investigations, prepares memorandums of understanding for conditional shellfishing areas, reviews applications for shellfish harvest operations and initiates emergency closures of shellfishing areas.
As part of the shellfish sanitation program, DA/BA is responsible for the sanitary inspection and licensing of shellfish dealers involved in harvesting, shucking, depuration, repacking and reshipping of fresh and frozen oysters, clams, mussels and scallops, if whole or roe-on. All shellfish dealers, including commercial harvesters, must take Hazard Analysis and Critical Control Point (HACCP) training and develop a HACCP plan conforming to the FDA’s Seafood Regulations. All shellfish processing and handling operations are inspected at least twice per year as required by FDA. Harvesting boats, vehicles, facilities, equipment, product handling procedures and record keeping are checked for compliance. Operational licenses are reviewed and appropriate corrective actions are taken. DA/BA assists other state, municipal and federal health officials in investigating food borne illnesses, product recall and embargo.
DA/BA must conform to the US Food and Drug Administration/Interstate Shellfish Sanitation Conference (FDA/ISSC) mandates of the National Shellfish Sanitation Program Model Ordinance (NSSP-MO) in order to maintain its interstate standing and comply with Connecticut General Statutes Section 26-192. The NSSP-MO describes the minimum requirements for classification of shellfishing areas, proper harvesting, handling, labeling, storing, transporting of shellfish, and associated record keeping. Historically, the NSSP was developed cooperatively in 1925 by the states, the US Public Health Services (now the FDA) and the shellfish industry in response to major shellfish related food-borne outbreaks. In 1983, the ISSC was formed to update the NSSP and address shellfish issues. The ISSC is composed of coastal and inland state regulators, with representation by FDA and the shellfish industry. The ISSC developed the current NSSP Model Ordinance. The FDA, through a Memorandum of Understanding with the ISSC, must evaluate each state's shellfish program for compliance with the NSSP-MO. The FDA also standardizes state investigators to examine the sanitary handling, shipping and record keeping of commercial market shellfish operations. Those operations found to be in conformance with the NSSP-MO are licensed by DA/BA and a listing of those operations are forwarded to the FDA for inclusion in the Interstate Certified Shellfish Shippers List (usually referred to as the "List") which is published monthly by the FDA. Those states not in compliance are subject to having their commercial shellfish dealers removed from the FDA "List." Removal from the "List" results in stopping sales and shipment of shellfish from those licensed companies. Such action could be economically devastating to a state's shellfish industry.
Inspection & Licensing of Shellstock Shippers
DA/BA oversees proper shellfish handling, shipping, and record keeping practices of its licensees in order to ensure a safe and wholesome product. The Bureau of Aquaculture enforces regulations outlined in the NSSP MO for the sanitary handling of shellfish. Molluscan shellfish filter large quantities of seawater each day and can accumulate pathogenic bacteria, viruses and contaminants, like heavy metals, as they feed.
Bureau of Aquaculture staff routinely inspects shellfish harvesters and wholesale facilities for compliance with the NSSP MO. Inspections cover all aspects of shellfish handling from harvest vessels to shellfish transport to shellfish wholesalers. Harvest vessels are inspected for proper construction, operation, and maintenance to prevent the contamination, deterioration, or decomposition of shellfish. Inspectors ensure that shellstock is properly identified with a shellfish tag that includes the harvest date and location. The State also inspects the vehicles used to transport shellfish from harvest to wholesaler and from wholesaler to customer for proper construction, operation, and maintenance to prevent the contamination, deterioration, or decomposition of shellfish.
At the wholesale level DA/BA makes sure that dealers follow general Hazard Analysis and Critical Control Point (HACCP) requirements. HACCP is a management tool designed to minimize food-safety hazards and used to protect the food supply against microbiological, chemical, and physical hazards. Wholesalers must follow general sanitation monitoring requirements for factors such as:
· safety of water
· condition and cleanliness of food contact surfaces
· prevention of cross-contamination
· maintenance of hand washing and toilet facilities
· protection from adulterants
· labeling, storage, and use of toxic compounds
· employee health conditions
· exclusion of pests
Growing Area Classifications
Shellfish waters are classified based on findings of a sanitary survey. The sanitary survey identifies all actual and potential pollution sources, and their impact upon a growing area, reviews bacteriological quality of waters in the growing area, analyses meteorological, hydrodynamic, and geographic characteristics of the growing area, evaluates changes in land use and their potential to impact the growing area, evaluates the performance of sewage treatment plants, and looks for any failing septic systems. The NSSP MO requires sanitary surveys to be reevaluated and updated yearly, reviewed and updated every three years, and repeated every 12 years. Any area not meeting all NSSP MO criteria for its current classification, due to new or existing pollution sources or degradation of water quality, will be downgraded. Any upgrade in an areas classification must be supported by the findings of a sanitary survey.