Center for Science in the Public Interest

I. Executive Summary
II. Introduction
III. The FDA Plays Politics With Public Health
IV. The FDA is Charged With Protecting Consumers Against Unsafe Foods
V. The FDA Should Establish Standards Through A Fair And Impartial Process
VI. The ISSC Process Is Anything But Fair And Impartial
VII. The Shellfish Industry Has "Captured" The ISSC Process
VIII. How The FDA And ISSC Failed To Protect Consumers
IX. Timeline
X. Conclusions And Recommendations
XI. Endnotes

The Shellfish Industry Has "Captured" the ISSC Process

"Louisiana has been more concerned about their seafood business and keeping dollars flowing from this [California] market, one of their largest. They are more concerned with dollars than public health and safety."

— California industry member

The FDA has allowed the ISSC to establish what amounts to an industry "vetting" process for all proposed changes to shellfish-safety standards. That is, industry generally has the same voting power as state regulators on ISSC committees and task forces. In fact, the shellfish industry has far more votes than the FDA in the ISSC. To win acceptance of a proposal, the submitters (including the FDA) must gain the support of at least some members of the shellfish industry. Furthermore, industry representatives can, with just a modicum of support from state regulators, kill a proposal or amend it in ways that the original submitter opposes, even if that submitter is the FDA. Thus, the shellfish industry can negotiate with the FDA on the regulations governing its conduct. And, the industry’s hand is further strengthened because the FDA wants to maintain good relations with the industry since both are "repeat players" in the ISSC process.

Economics, not public health, is the driving force for the ISSC.


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