[Update 2/1: EarthFix has posted the January 23 letter detailing the concerns China has over how testing of shellfish for paralytic shellfish poisoning toxins (PSP) and arsenic is implemented. Not mentioned but of probable concern is the Department of Health's reactive system to vibriosis which relies largely on the number of people contracting vibriosis from shellfish before an area is closed or shellfish are recalled. The bi-annual International Shellfish Sanitation Conference (ISSC) meeting through which the National Shellfish Sanitary Program (NSSP) is implemented ended January 31. It is through the policies developed at the ISSC meeting that each state creates its own safety and testing program. To date, heavy lobbying by the shellfish industry has helped to minimize oversight of shellfish safety. It can be expected there will be heavy lobbying by the Chinese to improve those policies.]
Ban On Importing Geoduck to Continue
Dioxins in Oakland Bay Shellfish Next?
The Chinese have informed NOAA they wish to send a team to audit how shellfish are tested. In addition, in a letter dated January 23, they have also informed NOAA that Chinese consumers do in fact eat the skin and gutball of geoduck where elevated levels of arsenic were found. (Seattle Times, January 31, 2014)
All skin samples tested higher than .5ppm
As seen in the graph above from EarthFix, DOH testing of geoduck harvested from Poverty Bay showed levels of arsenic in the outer skin of all geoduck tested to be higher than the level Chinese consider safe (.5ppm). In some samples, levels over 3 times higher were detected in the skin. The response by DOH to these higher levels was to simply say to peel the skin off and do not eat it, something the Chinese have not found to be very comforting.
Dioxin levels found in various shellfish
harvested from Oakland Bay
from the Oakland Bay Site, July 27, 2010, p. 12)
Dioxins in Oakland Bay Shellfish
Another area the Chinese may wish to focus their auditing efforts on is Oakland Bay's shellfish where DOH testing confirmed elevated levels of dioxins exist in Manila calms and oysters. There, testing for dioxins in shellfish was triggered when testing of deeper sediments confirmed elevated levels of dioxins and other chemicals existed. The resulting tests of shellfish showed average (mean) levels ranging from .11 ppt in Manila clams to .45 ppt in Kumo oysters. Why oysters were over 4 times higher was not addressed.
Is this really safe to eat?
DOH Analysis: Eat Manila Clams, Not Oysters
In the analysis performed on possible effects from dioxins, the Department of Health made an assumption that heavy consumers of seafood have 50% of their diet consisting of Manila clams and 1% oysters and mussels. In other words, the shellfish with the highest levels of dioxins were minimized in their model. Test results under another scenario, where consumption was instead 50% Kumo oysters whose mean dioxin levels were four times higher than Manila clams were not performed, nor was a model tested using the highest levels of dioxins found, only the mean (average).
"Ingestion rates – This scenario assumed that manila clams from Oakland Bay are consumed 50% of the time from total seafood, and oysters and mussels from Oakland Bay are consumed 1% of the time from total seafood." (page 30)Oakland Bay's Past not a Mystery
Unlike the tidelands of Poverty Bay, Oakland Bay's tidelands are clearly known to have risk. In fact, many of the tideland deeds in Oakland Bay contain a specific condition about past pollution, many reading:
"Releasing and discharging Rayonier Incorporated, its successors and assigns, from any and all claims or causes of action whether in law or equity, due to acts or operations preceding and including the date of release, it might have against Rayonier, incorporated, with respect to ... past maintenance and operation of a pulp mill and manufacturing plant."Intensity of the Chinese audit is unknown
Shellfish growers in Oakland Bay were fully aware of the business risk they took on when they began growing shellfish in sediments which for decades had been impacted by industrial operation of a pulp mill. The Department of Health is aware of the elevated levels of dioxins in shellfish harvested from those tidelands. Whether the Chinese will be concerned over assumptions used in the model for testing and include shellfish from Oakland Bay in their audit remains to be seen.