However, that’s not what happened. The Food Conservation and Energy Act of 2008 (aka. Farm Bill) needlessly fragmented the food safety system by directing the USDA’s FSIS to assume inspection of catfish while FDA handled all other fish.

The Farm Bill split the responsibility for seafood safety between FSIS for catfish inspection and the FDA for general seafood. At the time, FSIS was directed to prepare a risk assessment to determine the risks associated with catfish — one of which it identified was Salmonella, which it said was a primary food safety issue. However, other issues remain.

The GAO recently evaluated FDA’s inspection of seafood imports for unsafe drug residues, and took another hard look at FSIS and catfish — and especially imported catfish, some of which have had high levels of residual drugs.

And in a September 2017 GAO report, Imported Seafood Safety: FDA and USDA Could Strengthen Efforts to Prevent Unsafe Drug Residues, GAO made five recommendations for both FDA and USDA to improve food safety with imported seafood. These include:

1. FDA should pursue agreements with other countries to test export seafood for import to the US for drugs of concern.

2. USDA’s FSIS should visit a sample of catfish farms as part of foreign country, on-site audits to determine conditions under which the catfish are being raised, including the drugs being used.

3. The administrator of FSIS should require as part of an equivalence determination that countries exporting catfish to the US include in their residue monitoring plans the drugs of concern to FSIS and the corresponding maximum residue levels (MRLs).

4. The commissioner of the FDA should coordinate and communicate with FSIS in developing drug residue testing methods and corresponding MRLs for imported seafood that may also be applicable to imported catfish.

5. The administrator of FSIS should coordinate and communicate with FDA in developing drug residue testing methods and corresponding MRLs for imported catfish that may also be applicable to other imported seafood.

Unfortunately, GAO is not pleased with the results so far. According to the GAO report, FDA agreed with or partially agreed with two of the above recommendations. FSIS partially agreed with two and said it already addresses a third. GAO disagrees and believes the recommendations should all be implemented.

FDA and FSIS took steps to accomplish the transfer of catfish oversight from FDA to FSIS, as called for in the Agricultural Act of 2014 memorandum of understanding (MOU) that both agencies signed.

However, according to the GAO, FDA and FSIS generally have not coordinated in drug residue testing methods, resulting — in some cases — in differences in drug residue levels used to determine if seafood is unsafe, specifically for unapproved drugs, as called for in a 1984 MOU to exchange information on their drug testing methods and ensure the comparability of their results.

Without this FDA and FSIS coordination, the agencies do not have reasonable assurance that they are consistently protecting consumers from unsafe drug residues.

If you are an importer of seafood into the US, seafood HACCP rules apply, and guidance can be found here.

For more information or to read the GAO (GAO-17-443) report, download it here.