Southern Shrimp Alliance Statement on Antibiotics in Imported Shrimp

The Southern Shrimp Alliance opposes the use of banned antibiotics in shrimp aquaculture.  Beyond undermining consumer confidence in the wholesomeness of shrimp in the U.S. market, the use of banned antibiotics unethically reduces production costs for farmed shrimp by shifting risks from the producer to the consumer.
The Southern Shrimp Alliance has made the continued presence of banned antibiotics in shrimp imports a point of emphasis in large part because the problem is limited to and concentrated with particular aquaculture industries.  The fact that many shrimp farming countries refuse to tolerate the use of banned antibiotics in their aquaculture is evidenced by a lack of detection of such antibiotics in their shipments to the United States, Canada, the European Union, Japan, and Australia.  Like U.S. shrimp producers, shrimp farming industries that have taken affirmative steps to eliminate the use of antibiotics in aquaculture are adversely impacted by their continued use in a small number of countries.
The Southern Shrimp Alliance has therefore highlighted and publicized the continued detection of banned antibiotics in farmed shrimp exported from China, Vietnam, India, Malaysia, and Bangladesh.  Further, the organization’s work in this area has pointedly emphasized that problems may be traced back to a small number of market participants in each of these countries.
Consistent with this view, the Southern Shrimp Alliance fully supports the U.S. Food and Drug Administration’s (FDA) decision to limit the application of Import Alert 16-136 to producers and exporters in peninsular Malaysia, as the issues presented by Malaysia’s shrimp shipments were limited to this geographic area.  Further, the Southern Shrimp Alliance supports, and has actively sought to assist, the federal agency’s improvements in its targeting strategies.
This is a simple issue.  So long as the seafood industry in the United States continues to import shrimp contaminated with banned antibiotics, the seafood industry facilitates the unjustified and dangerous use of antibiotics in shrimp aquaculture.  There is simply no question that farmed shrimp raised without antibiotics is readily available in the world market.
In the effort to eradicate the use of banned antibiotics from shrimp aquaculture, the Southern Shrimp Alliance appreciates the sentiment expressed by the Global Aquaculture Alliance in the statement released by that organization in response to SeafoodSource’s article of August 15, 2016.  That sentiment, however, should be supported with specific concrete examples of action taken to achieve the organization’s stated objectives.
The statement from the Global Aquaculture Alliance indicated that if a facility certified under the Best Aquaculture Practices (BAP) program is placed on a list for a prohibited antibiotic, the BAP program contacts the facility, requests that corrective action be taken, and, if no action is taken, the facility is suspended or de-certified.
Around the same time that SeafoodSource’s article was published, Jagadeesh Marine Exports was removed from Import Alert 16-124, an indication that steps had been taken to the FDA’s satisfaction to remove the company from detention without physical examination.  With the removal of Jagadeesh Marine Exports, no Indian shrimp exporters are currently listed on Import Alert 16-124.
However, there are six Indian shrimp exporters listed on Import Alert 16-129 for the presence of nitrofurans, a banned antibiotic, in their shipments to the United States.  Three of these exporters are BAP-certified.  Two of the three have been on that Import Alert for over a year.
For example, Mangala Sea Products has been listed on Import Alert 16-129 since February 26, 2015.  Mangala Seafoods (BAP Number:  P10471) is a four-star BAP-certified plant with associated hatcheries (BAP Number:  H10129), farms (BAP Number:  F10615), and feed mills (BAP Number:  M10040).  The address listed for Mangala Sea Products on Import Alert 16-129 is “CCXVI/1368, Bhat Memorial Building, Thoppumpady, Cochin.”  This is the same address attributed to Mangala Seafoods in an exporter directory found on the Joint Director General of Foreign Trade of Cochin’s website (http://jdgftcochin.gov.in/exporthouse.htm).
Mangala Sea Products has now been on a “list for a prohibited antibiotic” – Import Alert 16-129 – for nearly eighteen months.  Despite the fact that the FDA has not removed the company from detention without physical examination, the BAP program does not indicate that Mangala Seafoods‘ certification has been either suspended or revoked.
Similarly, Sharat Industries has been listed on Import Alert 16-129 since March 9, 2015.  Sharat Industries Limited (BAP Number: P10495) is a one-star BAP-certified plant.  The BAP program does not indicate that Sharat Industries Limited‘s certification has been either suspended or revoked.  Instead, the BAP program indicates that Sharat Industries Limited‘s certification is valid until August 26, 2016 and that a renewal of the certification is in process.  If the certification is renewed, it may come at a time when Sharat Industries has also spent eighteen months on a “list for a prohibited antibiotic.”
While there may be an easily explainable, reasonable explanation for this, it would not be apparent to a neutral third-party observer seeking to verify BAP’s commitment to end the abuse of antibiotics in aquaculture.
Five Star Marine Exports Pvt. Limited has been listed on Import Alert 16-129 since October 9, 2015.  Five Star Marine Exports Pvt. Ltd. (BAP Number: P10244) is a three-star BAP-certified plant with associated hatcheries (BAP Number:  H10078) and farms (BAP Number:  F10430).  The Global Aquaculture Alliance’s statement indicates that Five Star Marine was contacted by the BAP program.  But the statement does not indicate whether Five Star Marine took corrective action in response to that contact.  If corrective action was taken to the satisfaction of the program, it is unclear why such action was not similarly sufficient for the FDA to remove detention without physical examination.
Again, the Southern Shrimp Alliance recognizes that there may be explanations for each of these circumstances.  The BAP program is well positioned to address abuse in aquaculture and, accordingly, our organization supports the Global Aquaculture Alliance’s efforts to eliminate abuse of antibiotics in aquaculture.
This shared commitment is even more important in the face of evidence that the use of antibiotics in shrimp farming may be expanding rather than declining – particularly with the listing of a Thai company, Narong Seafood Co., Ltd.,on Import Alert 16-129 in June of this year.  Prior to FDA’s refusal of an entry line of shrimp shipped by Narong Seafood for the presence of veterinary drug residues, there had not been a shipment of Thai shrimp refused for banned antibiotics since September 2005.  Narong Seafood Company (BAP Number:  P10456) is a one-star BAP-certified plant.  The Southern Shrimp Alliance encourages the BAP program to utilize this certification, and its certification of other Thai shrimp companies, to ensure that there are no further detections of banned antibiotics in Thai shrimp for another decade.

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