Veterinary Research Communications, 27 Suppl. 1 (2003) 169–172 © 2003 Kluwer Academic Publishers. Printed in the Netherlands

Analysis of the Risks in the Marketing of Fishing Products G. Squintani Servizio Veterinario Azienda USL , Rimini, Italy Keywords: fishing products, , marketing, risk analysis

INTRODUCTION As an employee of the National Sanitary Service, I will deal with this issue from a practical point of view; that is to say, a point of view of someone who daily faces many complicated evaluations in a multidisciplinary area such as public veterinary policy. I will not venture into high-level arguments about the evaluation of the risks of single toxins that are readily found in fishing products, but I will deal with the analysis of the sector as a whole, outlining the critical points in the marketing of fish products, with the intention of presenting an introduction that can help lead to a correct evaluation of the individual topics presented elsewhere. TOXICOLOGICAL EMERGENCIES W hat are the toxins? To frame the argument, it is important to define, ‘what are the toxins that are related to fishing products’. The following substances constitute the concerns of toxicological emergencies. $ $ $ $ $ $ $ $ $ $

Toxins in poisonous fish Ciguatozins and paralysing toxins Heavy metals PCBs Dioxins Algal biotoxins Organic halogenated compounds Medicinal residues Volatile basic nitrogen (ABV), trimethylamine mitrogen (TMA-N), histamines Technical adjuvants

W hen do they occur? The accumulation of the toxins that are found in fishing products may occur at distinct points in the production process: production and marketing. Clearly, the 169

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majority of the toxins listed above accumulate in fishing products during the production phase; that is to say, while the animal is still alive. Secondary contaminations with toxic substances on introduction to the market are less frequent and are related to accidental contact with toxins like motor oils, naphtha and harmful substances in general, or voluntary contaminations, as in the case of the use of technical adjuvants. In this context, the products of the degenerative processes like TMA-N and histamine have to be considered, but these processes can also develop at the time of catching in conditions of excessive stress.

W hat are the causes of contamination? The principal sources of contamination derive from human activities and only in occassional cases are the causes to be found in natural environmental conditions. It is worth mentioning that the aquaculture, like all other types of intensive breedings, is prone to producing food that contains toxic wastes. The recurrent public controversies and alarmist campaigns are testament to the concern over this issue.

ELEMENTS OF RISK EVALUATION From a very practical point of view, the elements that contribute to risk evaluation may be garnered from current rules and legislation, epidemiological data, field studies, the outcome of the National Waste Plan, and the technical preparation of the veterinarian. The current rules are established as an important source of risk evaluation through which many limits on the acceptability of toxin contaminants are implied. Other important elements are the epidemiological data from human medicine; for example, the causes of gastrointestinal infection and aetiological studies on human pathologies. Unfortunately these data are difficult to obtain and very complicated to trace. Field studies are useful alternatives because they offer the veterinarian the opportunity of a complete evaluative outline to be applied to the inspection of fishing products. An example is the work on mercury contamination in the fishing products performed by colleagues in the Ministry of Health, at the IZS Superior Health Institute of Abruzzo e Molise. Evaluation of the results of the National Waste Plan, along with analysis of regional or local sectoral projects, can add weight to the evaluation of some toxic contaminants. One part of the National Waste Plan is dedicated to the aquaculture sector; the wastes from pharmacological treatments, whether therapeutic or augmentative, are considered environmental contamination. In 1999, a total of 933 samples were analysed with the percentage of positives being 2%, in 2000 the total samples were 918 with 8% positive. From evaluation of all the elements discussed above, the veterinarian is prepared

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to evaluate the essence of the problem so as to be able to apply appropriate controls and to estimate the gravity of the problem accurately.

CRITICAL POINTS Critical points in the actual control system can be recognized that represents some risk for the consumer. Some of these are peculiar to fishing products, others are more directly related to veterinary matters. In a proper risk evaluation, the characteristics of fishing products and their production that should be considered are lack of supervision during the production phase, short commercial life of the product, and insufficient homogeneity of the stock. If we exclude aquaculture, the fisheries sector represents the only process of production of human food in which it is not possible to practice control in the phase of production. Nevertheless, fishing zones, fishing techniques, and associated processes on board fishing boats greatly affect the sanitary quality of the catch. It is acknowledged that the majority of fishing products are subject to sanitary control in the production places, where handling and storagae time are reduced to the minimum compatible with sale operations. If we exclude the recognition of poisonous species, all other evaluations of the presence of toxic waste necessitate a laboratory analysis, which however fast it may be, always requires more time than that which suits commercial needs. Another critical element, and therefore an element of risk, is related to lack of homogeneity of the stock under sanitary control, with the exception of the products of aquaculture. Because of the various fishing zones, except for the mollusc, are not known to the veterinary inspector, it is not possible to apply the principles of evaluation that is normally accepted in other areas, such as the testing of a few samples to evaluate the entire stock. The importance of this is demonstrated by the marine biotoxins that are found in the mollusc. As elaborated in other contributions, no monitoring plan implemented at sea or in the shipping centres can deliver an absolute guarantee of the absence of biotoxins in molluscs destined for consumption. Other critical elements can be identified in the education of veterinarians and the organization of public sanitary services. There is no doubt that the veterinarian is the only professional who can monitor appropriately the centre of fishery products as well as of any other food of animal origin. This is not said parochially, but from the belief that involvement in all of the production process allows the veterinarian, as no other professional, to properly evaluate food of animal origin. Unfortunately, there is often observed, especially in inland areas, a tendency for only superficial control of the marketing of fishing products. This is due not only to the difficulty of maintaining high skill levels in the various veterinary sectors, but also to cultural misconceptions. It is perceived by many that the problem is principally one for coastal practitioners and that it necessitates very specific skills that not all possess.

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In reality, the controls on the marketing of fishing products are similar in many respects to those involved in other public veterinary areas. Apart from the recognition of the fish species, which is genuinely complicated and requires a strong specialization, and constitutes one of the first inspection points, the successive phases of manufacturing are based on evaluative rules that are similar to those used for other foods. They certainly require profound knowledge of the entire production procedure, but this cannot and must not be a problem for a professional such as a veterinarian of the public sanitary services. One can outline some critical elements in the operation of certain functions of the public veterinary sanitary services. My colleague Aldo Grasselly will deal with this argument in a more profound way, but it is important to underline how frequently public veterinarians tend to delegate control in the fishing products sector for other specialized colleagues for creating a team that does not really belong to the general service organization. I believe that such an arrangement is inappropriate.

CONCLUSION In the evaluation of the wholesomeness of food the public safety service vererinarian must apply all relevant technical and scientific knowledge and techniques. Among these, risk analysis cannot be considered secondary. It has been emphasized that there are critical points in the production and marketing of fishing products that represent potentially serious hazards for food quality. Some of these critical points are inherent in the production system, others in the marketing and others in the working methods of public veterinarians or in their mind-set. I am convinced that interventions in the last two critical points listed can produce improvements on a short time scale. With adequate information and professional training in the production operations of the fishing industry, the public veterinarian may be enabled to address all the other weak points on the system, with the effect of reducing toxicological emergencies caused by the ingestion of contaminated fish products.