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Absence of evidence is not evidence of absence…

In The Sunday Times yesterday, the distinguished conservationist and journalist Charles Clover took the EU and the FSA to task over the food safety regulations that govern the shucking of scallops.

Under EU rules, shucking (or the removal of the viscera) has to be done in premises that have been approved for this process. The rules have been set to give consumers the best protection from the toxins, such as amnesic shellfish poisoning toxins, potentially found in EU waters.

I’m sure debate about the strictness of these rules will continue elsewhere, but there’s one particular point Charles Clover’s raises that I wanted to comment on, he says: ‘I challenged the FSA to produce a record of a person poisoned by a poorly shucked scallop in a restaurant. It could not.’

The inference we’re meant to draw from this is that the rules are, therefore, unnecessary. But just because there’s an absence of cases, this is not proof that a real risk does not exist.  Indeed, conversely it could be thought of as evidence of how successful the regulations are. A subject with which Charles, as the author of a very important and well argued book about over fishing called ‘End of The Line’, should be very familiar – it’s just a cheap shot from a ordinarily thoughtful commentator.
Some years ago, a serious road accident – one in a series sadly – in my part of Pimlico involving a neighbour (delightfully named Boo) resulted in new traffic calming measures on a local through road.  Subsequently there have been no more incidents, but no one, except perhaps impatient white van drivers and pizza delivery boys, is arguing that the measures are unnecessary. Or putting it in ‘End of The Line’ terms: just because some fish stocks have returned, this doesn’t mean we should suddenly abandon restrictions on catching fish.  Changes in legislation must surely be driven by evidence and must be a step-by-step process?

Let me remind everyone of the serious consequences of Amnesic Shellfish Poisoning (ASP) toxins, and for which there is no known antidote. Symptoms include: vomiting, diarrhoea and abdominal cramps, disorientation and memory loss (in serious cases permanent loss of), seizures, renal failure, coma and in some cases it can be fatal.

I realise that newspaper columns are meant to be knockabout stuff (and so are blogs), but scientific rigour and proper use of evidence is at the heart of all good policy making.  Does anybody out there want to defend Mr Clover’s use of evidence, or continue the debate about shucking off our scallop responsibilities?


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The answer to Mr. Clover's argument is quite simple - "if there is no regulation, and a person WILL be harmed for the first time, will you agree to take responsibility for it, knowing the potential existed?"

There is always the first time. Dismissing a risk you were not aware of is one thing (and this is one of the most challenging tasks in HACCP plans), but dismissing a risk you are aware of takes a lot of viscera.

Posted by Itay Shlamkovich on August 16, 2011 at 06:49 AM BST #

The lack of reported incidents of amnesic shellfish poisoning in the UK does not come a great surprise to me. However I suspect there have been cases that have gone unreported (as is the cases with many episodes of mild to moderate food poisoning). Many scallops harvetesed in UK and other European waters tend to have low levels of amnesic shellfish poisons present in their visera. In the vast majority of cases these are below the EU regulatory limits and are thus not deemed danergous. This is based on EFSA opinions based on acute toxicity data. What there is not is evidence to determine what adverse effects to consumers the ingestion of low levels of toxins has on them over prolonged periods of exposure.
Thus as a Professor of food safety I thoroughly believe the shucking regulations are in the best interests of the consumer.

Posted by Professor Chris Elliott on August 20, 2011 at 04:42 PM BST #

Author comment

It’s true, only a small number of food poisoning cases actually get reported. For example, we know that for every case reported in the UK of infectious intestinal disease (IID), which is characterised by diarrhoea and vomiting, there are about 140 more that go unreported – so there’s a huge number that don’t make it into the official statistics.

Having an understanding of the true levels of illness in the community is essential if we’re going to develop effective policy and legislation to protect consumers in the UK. The last study of this kind was carried out more than 10 years ago, so the Agency commissioned an update which will give us a view of the true incidence of IID in the UK now.

The research is almost complete and the report will be published at the beginning of September on, so watch this space.

Posted by Andrew Wadge on August 23, 2011 at 01:02 PM BST #

The comments above are all well reasoned but miss the simple practical point which is that the King scallop can only come to the table having being properly prepared by a qualified Chef.

This preparation involves opening and correctly discarding parts of the scallop that should not be eaten and then washing the meat for over 3 minutes or ideally 10.

So why stop a whole, fresh, live scallop coming into the kitchen when the issue is ABOUT PREPARATION? You could argue that serving game in fur or feather would lead to sickness...However in the case of game we allow Chefs to prepare the meat properly without asking the game keeper to test if there are toxins in the feathers, crop or guts? so what is the difference with Scallops?

Added to this there are well documented, recent scientific studies showing that proper shucking of king scallops -even those well over the regulation limits- always leaves them clear of toxins. Whole un-prepared scallops fail under the NEW levels set by the EU whilst the shucked ones from the same batch always pass. Once again-this is about preperation.

The case is simple-Top Chefs want to see a live fresh scallop in their kitchens not a shucked and dead piece of meat of possibly dubious origin which has probably come from a distasteful fish processing set up which will often be far less hygienic for opening scallops then many good quality kitchens. I know what I am talking about here as I regularly see both sides of this coin.

Chefs have the skill to prepare and clean the fish properly and are not stupid enough to serve the scallop unwashed with its guts included...And if they are THEY should be legislated against not the quality suppliers.

Government in the UK should stand up for small scale artisan fishermen who catch care and preserve(after all these are the only fishers affected by this ruling) and not allow them to be subjugated by legislation which makes no practical sense at all and can easily be proven as such.

Posted by guy grieve on August 23, 2011 at 06:31 PM BST #

Guy, the points you make appear to be in agreement with the legislation. Ensuring scallops are safe is all in the preparation, and if this is not done correctly the risk to the consumer is high.

Therefore, the practical solution is to ensure that the people tasked with preparing scallops safely are appropriately trained and approved.

Posted by Alan on August 24, 2011 at 11:18 AM BST #

Agree completely Alan. We dive for and supply superb King Scallops UK wide but do not export thus have very close links with our Chefs and would happily foot the bill to train up members of staff, from the kitchens we deliver to. Unless of course they already have the appropriate training! Which many do. Do you think this would be an acceptable approach to the challenge of bringing fresh live shellfish to a kitchen whilst also fulfilling the legislation? We could also periodically test the shucked scallops in our kitchens using Jellet.

Posted by guy grieve on August 28, 2011 at 09:05 AM BST #

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