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I’m just back from a trip sponsored by the Norwegian Seafood Council, whose job it is to promote sales of farmed fish from Norway.  The Council takes great pride in the quality of Norwegian fish farming.

I wrote about the dilemmas of fish farming in What to Eat, but I had never been to one.  I went because I wanted to see a fish farm for myself, and this one was about 400 miles north of the Arctic Circle, near Tromsø.

The principal argument for fish farming is that wild fish are being fished out and will soon disappear.  As the argument goes, if we want fish, farming is how we will have to get them (there is also a pro-farming argument about omega-3 fatty acids, but let’s not go there right now).

Before I left on this trip, I was sent a letter from an anti-farming advocate detailing all of the arguments against fish farming.  This is worth a read (or see the Fish Farming Dilemma chapter in What to Eat).

We were taken to see a farm with 12 nets:

FIsh farm near Skjervoy, Norway

We went out to one of the nets to have a look.

This farm is managed from a control room on a boat, and monitored by computers that measure water conditions, currents, feed, and other factors.

A camera is placed in the nets about half way down looking up at the fish.  This monitors the amount of feed.  If the camera sees feed, it’s time to stop.

We were taken to the plant where the fish are harvested.

This particular plant produces salmon for the Japanese sushi and sashimi markets.  It was pristine.  The fish are harvested under conditions that ought to satisfy any humane society.

Overall, we saw none of the disease and pollution problems that I had expected to see.  Norway tightly regulates fish farming in quantity and quality.  The farms looked well managed, and the fish looked healthy.  The farm tests extensively for contaminating heavy metals and pathogens, reports no lice, and vaccinates young fish against disease.

The fresh salmon looked pink (because they are fed dye), streaked with fat (they are well fed), and had a nice light taste, but one quite different from that of wild Alaskan salmon.

The one set of questions left unanswered had to do with what the salmon are fed (we asked for and have been promised this information).

I came home with a handful of salmon feed pellets.  They look like dog food but feel greasy and smell fishy.

Therein lies the dilemma.  To get salmon or any other farmed fish to taste like fish, it is necessary to supplement their corn and soybean rations with fish meal and fish oil obtained from wild fish stocks, thereby further depleting ocean fish.

If we must have fish farming, it looked to me as though Norway was doing it well.  Elsewhere?  I have no idea.

Should we have fish farming?  I see it as a dilemma.

As always, I await your thoughts.

Addition, October 5: Elyssa Altman, writer of the blog, PoorMansFeast.com, was also on this trip.  Her report of it is more detailed than mine and addresses many of the questions asked in the comments.

In response to my post on tuna scrape, Professor Alan Reilly, Chief Executive, Food Safety Authority of Ireland (the equivalent of our FDA) sent this photograph of an actual tuna scrape label.

After I forwarded it to Bill Marler, he noticed that it is one of several photographs posted on the FDA’s tuna scrape recall web page).

The type is too small to read so I’ve done some cropping:

Professor Reilly asks:

What is puzzling me is why this product “minced tuna” was used in sushi products. The label (copy attached) clearly states that the product must be cooked before consumption and it is for industrial uses only (labelled not for retail).

Those are good questions, but here’s another, equally alarming.  What’s that strangely formatted Nutrition Facts label? It does not precisely follow FDA design or content requirements.

This is a red flag.  If the company is not following labeling rules, it might not be  following other rules either—safety, for example.

Safety?  Uh oh.

Bill Marler reports that the FDA “483 Inspection Report” on the Indian tuna processing facility is now available.  Read these quotes and shudder:

• Tanks used for storage of process waters have apparent visible debris, filth and microbiological contamination.
• There is no laboratory analysis for water used in ice manufacturing at the [redacted] facility to show the water used to make ice is potable.
• Apparent bird feces were observed on the ice manufacturing equipment at Moon Fishery; insects and filth were observed in and on the equipment.
• Tuna processed at your facility, which is consumed raw or cooked, comes in direct contact with water and ice.

I draw several lessons from this episode:

• Food is safer when cooked.
• Labels need to be read—and followed—carefully.
• Raw sushi is a high risk product, especially if it doesn’t cost much.
• The FDA needs to be doing a lot more inspecting of overseas facilities, and before they cause problems.

All of this means that we need a better food safety system, one that can address the enormous proportion of our food supply that comes to us from countries with weaker food safety standards.

Addition, May 17: Ben Embarek, a food safety scientist at the World Health Organization notes that the 483 report reveals that Moon’s HACCP plan did not list appropriate critical control points.  Anyone auditing the plan should have picked up the problems on paper, which is easier and less expensive to do than an on-site inspection.  But the FDA does not pre-audit international HACCP plans.  They are supposed to be cleared by exporting companies registered by FDA.  Comment: it’s hard to imagine that the current system can work, and it clearly does not.

My Q and A column in the San Francisco Chronicle appears on the first Sunday of every month.  This one is about safety problems with tuna scrape.

Q: I had no idea that the tuna in my sushi roll was scraped off the bones in India, ground up, frozen, and shipped to California. Is this another “slime” product? Can I eat it raw?

A: No sooner did the furor over lean, finely textured beef (a.k.a. “pink slime”) die down than we have another one over sushi tuna. On April 13, the Food and Drug Administration said Moon Marine USA, an importing company based in Cupertino, was voluntarily recalling 30 tons of frozen raw ground yellowfin tuna, packaged as Nakaochi scrape.

Centers for Disease Control and Prevention investigations linked consumption of Nakaochi scrape sushi to about 250 diagnosed cases and an estimated 6,000 or so undiagnosed cases of illness caused by two rare strains of salmonella. Among the victims who were interviewed, more than 80 percent said they ate spicy tuna sushi rolls purchased in grocery stores or restaurants.

Scrape refers to the meat left on fish skeletons after the filets are cut off. This is perfectly good fish, but difficult to get at. I once visited an Alaskan salmon packing plant and asked what happened to the delicious looking meat between the bones. The answer: pet food. (Lucky cats.)

A hot commodity

But tuna is too valuable to leave behind, and companies in India use special devices to scoop out the meat, combine it with scrapings from many other fish, chop the mixture, freeze it in blocks, and ship it to importers in the United States. Unlike “pink slime,” tuna scrape is not treated with ammonia or anything else to kill harmful bacteria.

Nevertheless, it is supposed to be safe. The FDA requires producers of imported foods to follow established safety plans. Although the United States imports about 80 percent of seafood sold domestically, the FDA only inspects 1 or 2 percent.

This means we have to rely on the diligence of international food producers in following safe-handling procedures, and of U.S. importers in verifying safety through pathogen testing. But even well-intentioned producers can make safety errors, especially when dealing with high-risk foods.

Tuna scrape is very high risk. Its supply chain is long, complicated and international, leaving many opportunities for contamination. And it is eaten raw.

This tuna scrape came from a single processing plant in India owned by Moon Marine International of Taiwan. Tuna are plentiful off the Indian coast, and the tuna processing industry is expanding rapidly. India has dozens, perhaps hundreds, of fish processing facilities, but most are relatively small and their number, size and geographical dispersion make monitoring difficult.

Safe handling issues

The frozen scrape blocks are supposed to be held at subzero temperatures throughout shipping. Even so, they pose a safety risk. They combine the scrapings from many fish. One contaminated scraping can contaminate the entire lot.

And subzero freezing may kill some salmonella, but large fractions can survive, remain viable, and multiply when the blocks are thawed.

Once the tuna scrape arrived in America, I’m guessing it was trucked to Cupertino and from there to retailers and distributors who further trucked them to restaurants and grocery stores. There, sushi chefs thawed the scrape and used it to make spicy tuna rolls.

Tuna scrape is used in supermarket-grade sushi, not the fancy stuff. Sushi used to be – and still is, in places – an art form requiring exceptional skills. In Japan, sushi chefs can train for as many as 10 years to learn how to recognize the freshest, safest and most delicious fish. Sushi served by such chefs is made to order. It is never pre-prepared. It can be breathtakingly expensive.

But in America, sushi has gone mainstream. You can find prepackaged sushi rolls at practically any supermarket or convenience store, at a cost equivalent to hamburger.

Cheap sushi is made with cheap ingredients – hence, Nakaochi scrape – by chefs with far less training. A typical certification program for sushi chefs in this country can be completed in two or three months. Some offer certification online. Although these programs address safe food-handling procedures, the training is necessarily superficial.

What are the odds?

Sushi aficionados argue that while raw fish is never perfectly safe, the safety odds are much better when the chef is well trained, and the fish are freshly caught and cut to order in front of you. By their standards, tuna scrape is suitable only for pet food, which is at least cooked to kill pathogens.

If anything, the tuna scrape outbreak teaches why it is so important to know where food comes from and how it is made. Caveat emptor.

Nutrition and public policy expert Marion Nestle answers readers’ questions in this monthly column written exclusively for The Chronicle. E-mail your questions to food@sfchronicle.com, with “Marion Nestle” in the subject line.

Addition, May 14:  Bill Marler reports that the FDA “483 Inspection Report” on the Indian tuna processing facility is now available.  Here are excerpts from the most revealing section:

Tanks used for storage of process waters have apparent visible debris, filth and microbiological contamination…There is no laboratory analysis for water used in ice manufacturing at the [redacted] facility to show the water used to make ice is potable…Apparent bird feces were observed on the ice manufacturing equipment at Moon Fishery; insects and filth were observed in and on the equipment…Tuna processed at your facility, which is consumed raw or cooked, comes in direct contact with water and ice.

When I wrote What to Eat, a book devoted to discussion of food issues using supermarkets as an organizing device, I needed five chapters to discuss issues related to fish.  By the time I was through, I considered the fish sections of supermarkets to be the Wild West of the food industry: anything goes and the buyer had best be wary.

Fish regulation, I pointed out, is divided among at least four federal agencies: USDA for marketing, NOAA (National Oceanic and Atmospheric Administration) for ocean fisheries, EPA for fish caught for sport and recreation, and FDA for fish safety.  This alone should tell you that this is a virtually unregulated industry.

Now the Boston Globe presents the latest evidence for this dismal view.  Investigative reporters examined fish served in Boston-area restaurants.  Oops.  They found widespread bait and switch.  In many restaurants—even good ones—the fish served are not what customers think they paid for.

• Photos: Examples of inaccurate fish labeling
• Globe tests fish DNA

From sea to sushi bar, a system open to abuse:  fish is a largely unregulated industry and problems are pervasive.

Suppliers such as Goldwell use the names interchangeably, contributing to a little-known but pervasive problem in the international seafood industry: lower-quality and less expensive fish mislabeled as desirable species. Some distributors do this unknowingly, while others intend to deceive. Lax government oversight, industry indifference, and consumer ignorance allow mislabeling to flourish.

Fish misidentification is especially common at sushi restaurants, partly because they use various names for the same fish. The confusion can be compounded by packaging labels written in other languages that are incorrectly translated into English.

• ‘Key West grouper’ in name only
• Fresh black sea bass, with QR code on side

Bertucci’s tries to right a wrong: How hake ended up as cod on the menu at 94 Bertucci’s restaurants.

• Photos: Bertucci’s searches for a replacement fish

Scrutiny vowed on fish labeling: state officials vow to improve oversight of seafood sales.

Good luck to state officials.  They will have their hands full trying to get on top of this industry.  Here’s what I wrote in What to Eat:

Much of this industry acts like it is virtually unregulated and as if all it cares about is selling fish as quickly as possible at as high a price as the traffic will bear.  Out of ignorance or, sometimes, unscrupulousness, the more profit-minded segments of this industry bend the rules to their own advantage any time they can get away with it.  No wonder “fishy” translates as “suspicious.”  If you want to buy fish, you need to watch out for labels that are sometimes untruthful and often misleading” (p. 232).

Thanks to the Boston Globe for exposing this fish scandal. 

And thanks to Consumer Reports for doing a similar story in its December issue.  Its investigation found 20% of 190 samples to be mislabeled.  And the only fish consistently labeled correctly were Chilean sea bass, coho salmon, and bluefin and ahi tuna. 

Regulation anyone?

I’m frequently asked what food has to do with politics.

Food, as my colleagues in Food Studies like to say, is an entry point into the most important social, economic, and political problems facing the world now and in the past.

Today’s New York Times story on testing seafood for radioactivity is a case in point.  Food may seem remote from energy policy and nuclear power plants, but it is tightly linked to these issues.  The Japanese have had to dump radioactive water from their tsunami-damaged power plants into the ocean.

The ocean is large and the radioactivity will be diluted, but fish and shellfish have the potential to concentrate it.  That is why high-end restaurants are now testing fish for radioactivity.

Government agencies and experts say that the amount of radioactivity is too low to cause harm:

Patricia A. Hansen, a senior scientist at the F.D.A., acknowledged that the radiation detection methods used to screen food imports were not sensitive enough to detect a single contaminated fish in a large shipment. But she said that small amounts of contamination did not represent a public health hazard….But the important context is, is that one fish at the intervention level a public health concern? No, it is not.”

How credible are such statements?

Nicholas Fisher, a professor of marine sciences at the State University of New York at Stony Brook, said that, according to some radiation safety guidelines, people could safely eat 35 pounds of fish each year containing the level of cesium 137 detected in the Japanese fish.

“You’re not going to die from eating it right away,” he said, “but we’re getting to levels where I would think twice about eating it.”

Low-dose radiation accumulates, and the less to which we are exposed, the better.

Food is plenty related to politics, no?

The National Oceanic and Atmospheric Administration (NOAA) has proposed the nation’s first aquaculture policy, which it says it did in response to consumer demand for local, safe, sustainably produced seafood (FoodNavigator.com has a good summary).

Ah yes.  Seafood.  The wild west of the food industry.  Safe and sustainable sounds good, but the statistics are not reassuring.

As NOAA explains, U.S. aquaculture – meaning farmed – currently only accounts for about 5% of our seafood.  Get this: an astonishing 84% of U.S. seafood is imported. Of this, half is farmed.

Worldwide, farmed seafood exceeded catches of wild seafood for the first time in 2009.

NOAA guesses that with wild fish stocks depleting rapidly, we will see plenty more fish and shellfish farming.

NOAA quotes the depressing Food and Agriculture Organization report on world fisheries and aquaculture.  This says that worldwide per capita fish availability is about 17 kg per year, and supplies more than 3 billion people with at least 15% of their average animal protein intake.  No wild fish stock can keep up with that kind of demand.

NOAA’s yawn-inducing recommendations (edited):

• Enable sustainable aquaculture…in harmony with healthy, productive, and resilient marine ecosystems
• Ensure agency decisions to protect wild species and coastal and ocean ecosystems
• Advance scientific knowledge concerning sustainable aquaculture
• Make timely and unbiased aquaculture management decisions
• Support aquaculture innovation and investments that benefit the nation’s coastal
• ecosystems, communities, seafood consumers, industry, and economy.
• Advance public understanding of sustainable aquaculture practices
• Work with our federal partners to provide resources and expertise needed to address aquaculture challenges
• Work internationally to learn from aquaculture practices around the world

It’s going to take a lot more than that to fix the fish situation.

The FDA has just concluded two days of hearings on the safety and labeling of genetically modified (GM) salmon. I’ve been collecting comments about this and will add a few of my own.

USA Today: Let’s begin with Elizabeth Weise’s clear, insightful summary of what this is about. She summarizes the situation with GM salmon in a nifty Q and A format:

Q: What happens next?

A: Nothing soon. Before issuing a decision on the application, FDA will publish an Environmental Assessment of the salmon, followed by a required 30-day comment period. The agency would then determine whether it would file a Finding of No Significant Impact or an Environmental Impact Statemen….then use those findings to make a decision on whether or not to allow the sale of the salmon. The agency has said it has no set timeline for reaching a decision. Were the agency to decide to approve the sale of the salmon, it would take two years before the first crop was ready, company officials say.

Food Chemical News (September 20):  reports that AquaBounty’s CEO has no intention of restricting GM salmon farms to Panama. At the FDA hearing, he “forecast a spread of transgenic salmon operations from a proposed site in Panama to other countries, including the United States.”

Oops. The FDA had to remind him that his company’s application is for Panama only, and any other sites would require supplemental applications from the firm.”  The FDA said it was “not interested in AquaBounty’s future business plans.”

FoodNavigator.com reporter Caroline Scott-Thomas predicts that the hearings will lead to no recommendation.

The FDA’s Veterinary Medicine Advisory Committee (VMAC) did not vote or make a recommendation at the end of the hearings, saying that it does not yet have sufficient data…After two days of hearings, a Food and Drug Administration (FDA) advisory panel has called for more research to decide whether genetically engineered salmon is safe for consumption.

The New York Times says that the advisory group favored approval of the GM salmon, but that this could take ages.

Food Chemical News (September 21) says that most speakers at the hearing on GM labeling did not want it to be mandatory. It quotes Greg Jaffe, the director of biotechnology at Center for Science in the Public Interest (CSPI), as opposing mandatory labeling. Apparently, Jaffe:

urged AquaBounty to require its customers to provide “real” voluntary labeling on food products, such as “AquaBounty salmon,” “fast-growing salmon” or “environmentally friendly salmon”….He agreed that “no ingredients from a genetically engineered source” would be acceptable language provided there’s a comparable GE product in the marketplace.

Why would a representative of a consumer organization oppose mandatory labeling?  For that, go to

Jill Richardson’s lengthy analysis of FDA’s actions, written for Grist.  She lays out some of the more complicated issues, and takes a tough look at the biases of the committee members.

Washington Post: Lindsey Layton writes about the debates over labeling (I’m quoted).

A Washington Post poll found 78% of respondents to be worried about the health and safety risks of GM salmon.

Meanwhile, in the UK, the new government has stopped a scheduled public dialogue about GM foods.  That’s one way to handle it. All those pesky consumers don’t want it? Too bad for them.

My interpretation: of course the public does not trust genetically modified foods. The foods are not labeled. If the biotech industry and the FDA want the public to trust them, they need to label the GM salmon and all the other GM foods in the marketplace.

The public wants the right to choose.  The public should have the right to choose.

The issue of GM foods cannot just be about safety.

My mantra on this one: Even if genetically modified foods are safe, they are not necessarily acceptable.

I was a member of the FDA’s Food Advisory Committee in 1993 when, under pressure from Monsanto, the agency rejected labeling of GM foods.  I wish the FDA had listened to me and the other consumer representatives on the committee, all of us convinced that labeling is essential for promoting trust, and giving the public a choice. And, we said, it’s the right thing to do.

The FDA now has a chance to redeem it’s bad decision.  I hope they take this opportunity and decide to require labeling.

Footnote: I wrote about all this in my book, Safe Food: The Politics of Food Safety, just published in a new edition in July.  In preparing the second edition seven years later, I was surprised by how little about food biotechnology had changed.  The issues have not changed.  The field is stuck.   Labeling is one way to break the stalemate.  Let the public have a choice.  I’ll bet doing that will solve a lot of problems.

The FDA has scheduled meetings September 19-21 to hear advice about whether the agency should approve GM (genetically modified) salmon.

These, you may recall are Atlantic salmon bioengineered by AquaBounty Technologies.   Atlantic salmon only grow for a few months per year; they do not produce growth hormone in non-growth months.  AquaBounty scientists combined growth hormone genes from an unrelated Pacific salmon with DNA from the anti-freeze genes of an eelpout fish.

The result is that the GM salmon produce growth hormone throughout the year and grow at twice the rate of non-GM salmon.

In preparation for these hearings, a coalition of 31 advocacy groups issued a statement urging the FDA not to approve the fish.

Each year millions of farmed salmon escape from open-water net pens, outcompeting wild populations for resources and straining ecosystems…We believe any approval of GE salmon would represent a serious threat to the survival of native salmon populations, many of which have already suffered severe declines related to salmon farms and other man-made impacts….FDA’s decision to go ahead with this approval process is misguided and dangerous, and is made worse by its complete lack of data to review…FDA has been sitting on this application for 10 years and yet it has chosen not to disclose any data about its decision until just a few days before the public meeting.

According to press accounts, salmon are only the first in a long line of potential GM fish and animals.  AquaBounty also raises GM trout and tilapia.  Other companies are working on GM pigs and cows.

AquaBounty lost no time in responding to the Coalition’s objections:

This press release is inaccurate, deliberately misleading, and intended to create fear and misunderstanding. AquAdvantage salmon are, quite literally, the most studied fish in the world. In addition, the U.S. Food and Drug Administration has spent the last fifteen years creating a robust regulatory process to ensure these fish and other transgenic animal applications are appropriately evaluated and regulated.

Comment: In the early 1990s, I was one of four consumer representatives on the FDA’s 30-member Food Advisory Committee.  This was the time when the FDA was considering approval of the first GM crops.   All four of us voted to delay the decision until more information became available or to make sure that GM foods were labeled as such.  Obviously, the FDA did not listen to our excellent advice.

Indeed, when our term on the committee was up, the head of the FDA’s Center for Food Safety and Applied Nutrition explained to us that our committee had not really been advisory.  The FDA had already decided the issues that it brought to the committee for discussion.  All the agency wanted from the committee was some indication of the kind of public reaction its decisions might raise.

Is this still the case with FDA advisory hearings?  I really don’t know, but I hope the FDA will listen carefully to concerns about these fish.