FDA Annual Program Evaluations FY 2009 Processing and shipment element did not meet all of the program requirements established by the Interstate Shellfish Sanitation Conference (ISSC) under the National Shellfish Sanitation Program (NSSP) during the last complete evaluation in 2008: o inspection frequency requirements for Certified Shellfish Dealers were not met o inadequate enforcement staffing at Shellfish Dealers Control of Harvest (Shellfish Patrol) element not conforming to the requirements as stipulated in the NSSP Model Ordinance (MO): o overall patrol frequency levels did not meet minimum NSSP guidance for the number of Patrols in Prohibited, Restricted or Closed status areas o insufficient staffing o need larger more sea-worthy Patrol vessel Identified scientific and gardening projects as “an emerging issue” FY 2010 Processing and Shipping Element is now in substantial conformance for inspection frequency as well as the enforcement of the Vp Control Plan Still not in compliance with Control of Harvest (patrols) although “almost” in compliance due to new staff as promised; still no vessel as promised FDA recommended control of human discharge from harvesters’ boats since there are no regulations in place to require Marine Sanitation Devices or other waste containment systems on harvest vessels Increased demand put on DEP from gardening projects and downgraded areas Gardening is “emerging issue”-DEP is drafting policy FY 2011 Control of harvest (patrols) “substantial compliance”, although still no new boat and need more staff Still no control of human discharge off harvest vessels FY 2012 Substantial compliance with control of harvest (patrols) Still no larger vessel Still no regulations addressing human discharge off harvest vessels Per NJDEP Shellfish Aquaculture Regulatory Workshop 10/8/14: Gary Wolf: NJ has been in 100% compliance since 2013 DEP does patrol W. Raritan Bay, either by land or water, 16 times/month FDA never said state police or marine can’t do enforcement FDA had nothing to do with Keyport removal; they only care about State’s compliance Capt. Fresco: currently patrolling the required 16x/month is RB, Shrewsbury River, IF DEP IS CURRENTLY PATROLLING THE MAXIMUM, WHY CAN WE NOT DO RESEARCH, RESTORATION, AND EDUCATION PROJECTS IN THESE WATERS? Per DEP Meeting 1/5/15 New Shellfish Rules are result of 2014 FDA Audit where NJDEP was found to be out of compliance in the following: o Aquaculture permit-NJ has no permit for aquaculture although the ISCC requires one o Model ordinance is not in DEP rules, which is also required. Dominic Fresco: Enforcement will not be in compliance in 2015 due to losing 2 enforcement officers
© Copyright 2024