The waters of the New York Bight are among the most heavily traveled in North America. Commercial shipping into and out of the ports of New York and Philadelphia, coastwise vessel traffic, over three hundred thousand recreational boats and a large commercial fishing fleet all pass through these waters. Along with this heavy vessel use, rivers that drain some of the most intensively developed areas in the U.S. pour into the Bight. And yet, in spite of all of this, the quality of the waters off New York and New Jersey has been steadily improving.

Thanks to the efforts of a thoroughly committed environmental community, to effective environmental regulations at the local, state, regional and national levels, and to a business community and an industrial base willing to make the required sacrifices, the last several years have shown marked improvements in a number of important indices of water quality.

How much have things improved? Quoting New Jersey Department of Environmental Protection Commissioner Bob Shinn, “In early 1997, more than 600 acres of Navesink River waters were reopened for unrestricted harvesting (of clams) in one of the first successful programs of its type in the nation aimed at controlling nonpoint source pollution.” (NJDEP, Performance Partnerships for the Next Generation - Annual Report 1996). Possibly more exciting from a biological if not a culinary perspective, Dr. John Waldman at the Hudson River Foundation reports that for the last few years oysters have been found in waters - the Arhur Kill, the confluence of the Hackensack and Passaic Rivers, off the Battery - where they have been absent for decades. In Dr. Waldman’s words, this is “a very good sign” of improving water quality. And from farther out in offshore waters, according to Dery Bennett of the American Littoral Society headquartered on Sandy Hook “the catch of the commercial fishing fleet landed in New Jersey is delicious and wholesome. This includes the fish that we usually associate with ocean fisheries - fluke, flounder, hake, weakfish, tuna, etc. - as well as the mollusks - squid, scallops, surf clams and ocean quohogs - that are such an important part of the New Jersey industry.”

Finally, from the perspective of someone whose family has made a living on the waters of the New York Bight for generations, Ray Bogan of United Boatmen of New Jersey and New York says “Water quality and clarity in the Bight has improved over the last twenty years to the degree that the old timers feel that it is cleaner than it was back in the old days. Fin rot, an affliction that was common in the fish we caught in the Sixties and Seventies (and generally attributed to poor water quality), has all but been eliminated from our primary fishing grounds.” United Boatmen represents those fishermen on party and charter boats sailing from Northern New Jersey and Long Island ports who work in the waters in the heart of the Bight.

Does this mean that things are the way they should be in this piece of ocean that plays such a critical role in commerce, transportation and recreation in the Mid-Atlantic region? Certainly not. There are still advisories associated with heavy consumption of particular species of seafood from particular areas, and people with compromised immune systems should take the precautions they usually do. We’ve still got farther to go in a number of areas. But conditions have improved dramatically, and the improvements are far more significant than having bathers able to see their toes in waist-deep water for the first time in years.

Consumer Safety and Seafood Inspection

If things proceed as planned, and they most probably will because the schedule was set by the U.S. Food and Drug Administration in 21 CFR “Safe and Sanitary Processing and Importing of Fish and Fishery Products,” by December 18 of this year all processors of fish and fishery products must have a Hazard Analysis Critical Control Point (HACCP) [] program in place to insure that their products reach the consumer in a wholesome condition. “Fish” in the rule is virtually anything coming out of the water intended for human consumption and “Processing” is very broadly defined to include anyone doing anything to those fish from handling and storing all the way through manufacturing. If it has to do with fish or shellfish that are intended as food, it will most likely fall under these regulations.

The HAACP inspection system is one in which a processor analyzes his operation, determines all of the food safety hazards that are likely to occur to his product, and identifies points in the process where predetermined critical limits must be monitored. For the product to be in compliance these limits can’t be exceeded. Unlike the more “traditional” forms of inspection where the final product is inspected for compliance with various standards, in HAACP the processes used in the production of the product are monitored. In fact, the HAACP system was designed to get away from end-product testing.

In creating a plan the processor isn’t left entirely on his own. The U.S. Food and Drug Administration has published a “Hazards and Controls” guide that provides the agency’s “…best advice on safety hazards that are reasonably likely to occur for virtually all species commercially marketed in the U.S. and for virtually all types of processing operations” as well as “…advice on controls available for those hazards.” (From a presentation by Philip Spiller, Director, Office of Seafood, Center for Food Safety and Applied Nutrition, U.S.F.D.A., at the Food and Drug Law Institute on December 11, 1996)

Because over half of all of the seafood consumed in the United States is imported, seafood HAACP requirements will apply to imported as well as domestic seafood. Importers will be responsible for taking steps to verify that their imports meet the U.S. HAACP requirements.

In 1993 the U.S. Department of Commerce’s National Sea Grant program and the Association of Food and Drug Officials formed a National Seafood HAACP Alliance which is offering training courses across the country. In New Jersey the Regional Food and Drug Administration office, the New Jersey Department of Health and the New Jersey Sea Grant Program are offering HAACP training to industry members through a joint program of the Cape May Seafood Association and the Rutgers Cooperative Extension Fishermen’s Training School. To date 45 seafood processors and 28 shellfish dealers have taken advantage of this program and courses are currently being scheduled for September and October.

What does this mean to the seafood industry? According to Robert Collette, Director of Food Regulatory Affairs at the National Fisheries Institute (in HACCP Management Manual Monthly Report, Vol. 1, No. 8, Jan. 1997) “…a well-designed and properly implemented HACCP plan provides great insight into how well a processing operation is running. This allows firms to better control the process - potentially yielding an improvement in product quality and a reduction in waste, as well as improved product safety.”

And for the consumer? While seafood has consistently been demonstrably safer than other food products in the past, this new program should put any lingering concerns consumers might have about seafood products - whether from our local waters or from distant oceans - to rest.