My Sea Shepherd


 

Seal Products May Threaten Human Health by Debbie MacKenzie

May 4, 2006

. . . But more to the point, seal products may threaten human health . . .

Guest Commentary by Debbie MacKenzie

Seal oil leaves a fishy aftertaste...
while idiotfish*, but not seal meat, is a formally accepted name for Canadian seafood

But more to the point, seal products may threaten human health.

  1. Seal products may pose human health risks
  2. What are the health risks?
         Brucellosis (found in Canadian seals)
         Trichinosis (found in Canadian seals)
         Botulism (associated with ingesting seal oil)
         Who knows what else? (chemical pollutants, viruses in seal meat that can kill mink,
              nasty skin diseases, etc.)
  3. What should be done about the poor health of Canadian seals?
         Admit seals are not fish, but mammals, and can transmit significant infectious
               diseases to people.
         Stop eating seals and using their tissues for any purpose, including furs.
         Leave them alone.
  4. What are the veterinarians saying?
  5. What about the idiotfish*?

1. Seal products may pose human health risks

Canadian products from seals that are being sold commercially may be unfit for human use or consumption because seals are not bound by the "healthy at the time of slaughter" rule, nor are they processed in accordance with the Canada's "Meat Hygiene Directives," both practices that are enforced in the legal trade of all other mammals. This exemption is based on seals having been classified as "fish" under certain parts of Canadian law, which creates a legal loophole that is currently being exploited by ill-advised "seafood" processors selling seals. The upshot is that human consumers of seal products, both within Canada and internationally, are potentially exposed to serious health risks that are transmissible to humans from animals. Therefore, Canadian produced seal oil, seal meat and seal pelts may all be unwholesome by accepted international standards.

"Veterinary Health Certificates" are required to accompany all exports of "animal products." This ensures that not even a cowhide destined to be processed as boot leather in the most remote corner of the Earth can be exported from Canada without a veterinarian attesting to the health of the cow, as determined by inspection both before and after its death. Veterinarians systematically screen cows and other livestock for a host of contagious diseases that might be passed on to humans or other animals, and the movement and trade of animals and animal products is restricted accordingly. This activity is regulated under Canada's Meat Inspection Act.

The safe production of "seafood," on the other hand, is regulated under a different law, the Fish Inspection Act, and certificates attesting to the wholesomeness of "fish" are generated not by veterinarians but by fish inspectors, who have been trained to screen for food threats to humans that might be found in fish (you know: in cold-blooded hairless creatures that swim and use gills). Evidence on the website of the Canadian Food Inspection Agency (CFIA) suggests that seal meat has been exported from Canada (to Hong Kong and Korea at least) with "fish and seafood" certificates rather than with "veterinary health certificates" designed for "animal products."


2. What human health risks may be posed by Canadian seal products?

"The time has come," the Walrus said, "to talk of many things..." (Lewis Carroll)

First, let's talk about Brucellosis

Evidence of Brucellosis has been found in Canada in harp seals, grey seals, hooded seals, walrus, polar bears and whales.
Brucellosis in humans is transmitted from animals (i.e. people don't catch it from other people. "Zoonotic" refers to infectious diseases in animals that can also infect people, and that can make people sick). Slaughterhouse workers, farmers and veterinarians can catch brucellosis from contact with infected animals. The bacteria can enter through skin abrasions, mucous membranes or the lungs. Consumers of un-pasteurized dairy products, or occasionally of raw meat from infected animals, can also catch brucellosis. Symptoms of this infection may be insidious and chronic and include fatigue, fever, headache, abdominal pain, weight loss, swollen lymph nodes and arthritis. In chronic brucellosis, which can linger for years, fever may come and go and psychoneurosis may develop in addition to the other symptoms. If medical doctors do not suspect a diagnosis of brucellosis, this disease can be confused with various others, including tuberculosis, Hodgkin's disease and malaria.

From a recent veterinary medical textbook:

"The most significant emerging bacterial disease of pinnipeds (seals) is currently brucellosis ...those dealing with marine mammals or their tissues should not discount the potential zoonotic implications of infection with this organism." (CRC Handbook of Marine Mammal Medicine. 2001. Leslie A. Dierauf and Frances M.D. Gulland, eds.)

Brucellosis (infection with various strains of a bacteria called Brucella) is a highly contagious disease of mammals, that threatens animal and human health. In livestock (cows, pigs, sheep, goats) a high rate of abortion is a prominent consequence of Brucellosis. If Brucella is found in animals being raised for human consumption, strict control measures must be implemented to eradicate this dangerous germ. This means an end to movement and trade of infected and exposed animals, along with various other measures and precautions, including notification of international authorities that Brucella has been found in food animals.

The international authorities are the FAO/OIE/WHO (Food and Agricultural Organization/World Organization for Animal Health/World Health Organization). Brucellosis in farm animals is listed as a "notifiable" disease by the OIE, and when a member country gives notice to the OIE that they have had an outbreak of brucellosis, this severely hampers export trade in that species from that country until three years after the Brucella has been successfully eradicated. It is very important that a country maintain its "brucellosis-free" reputation once this status is attained. Canada is listed as brucellosis-free on the OIE website...but this doesn't mean Canada is absolutely free of brucellosis, of course; it means that Canada is known to be free of brucellosis in cows, sheep, goats and swine (brucellosis-susceptible animals that are commonly sold commercially as meat). According to disease status information published online, Brucellosis was last reported to the OIE by Canada in 1989, involving cows. (The outbreak was "stamped out," meaning that infected cows were destroyed and their carcasses were not sent to market, but were either incinerated or buried in a deep pit with lime.)

Why has Canada not reported to the OIE that practically every species of marine mammal in its waters has tested positive for Brucella antibodies in recent years? Incredibly, it seems that the fishy-seal loophole has been exploited all the way to the OIE, because the OIE divides reporting requirements into lists of diseases affecting "terrestrial animals" and diseases affecting "aquatic animals." A reporting loophole exists because marine mammals do not appear under either of these categories. This may be because, at the time when the disease lists were drawn up by the OIE, there was no international trade in any marine mammals for human consumption, nor was any anticipated.

But now we have "fish and seafood" export certificates written to accompany Canadan seal meat exported to Korea that include the following information:

"Canada has not reported any animal contagious diseases listed by the World Organization for Animal Health (OIE) in seals, and there are no associated animal health restrictions required for Canadian seal meat for human consumption."

The problem is that, in Korea, this information might be misinterpreted to mean that Canadian seals have been tested (as "meat") and found to be free of potentially serious diseases that might affect seals, such as brucellosis. However, if infectious agents are not detected and then slip through the "seafood processors'" methods, unsuspecting Korean consumers might become ill.

Just because the OIE does not list diseases in seals, does not mean that there are no significant diseases in seals.

Canadian authorities at the Department of Fisheries and Oceans (DFO) and the Canadian Food Inspection Agency (CFIA) must be aware of the presence of brucellosis in seals, because their scientists have published this information. For instance:

"Brucellosis in Ringed Seals and Harp Seals from Canada" published in the Journal of Wildlife Diseases, 2000, 36(3): 595-598 (http://www.jwildlifedis.org/cgi/reprint/36/3/595)...by four authors, including scientists employed at DFO and CFIA, and stating that "This is the first confirmed report of brucellosis in marine mammals from Canada, and the first report of this organism in ringed and harp seals."

The following year, in 2001, was reported:

"Serologic survey of Brucella spp. antibodies in some marine mammals of North America" Journal of Wildlife Diseases 37(1): 89 - 100. (http://www.jwildlifedis.org/cgi/reprint/37/1/89) This article included:

"Although little is known about the epidemiology of brucellosis in marine mammals, there is now serological evidence that Brucella is present in marine mammals in British waters, the Canadian Arctic, and on the northwest coast of USA...The overall prevalence of pinnipeds (seals) with antibodies to Brucella spp. was 3.3%"

The scientists noted that harbour seals and grey seals at Sable Island, Nova Scotia, tested particularly high with Brucella antibody prevalence of 12.9% and 11.1%, respectively. Positive findings were also reported in harp seal, hooded seal, ringed seal, walrus, beluga whale and narwhal. Finally, the authors wrote:

"Indeed, the cases of human brucellosis among Inuit on Baffin Island have been increasing in recent years. The zoonotic (making people sick) potential of the newly discovered marine mammal Brucella spp. strains is unknown but given that most of the known strains are human pathogens, it would be prudent to regard the marine mammal strains as such until proven otherwise. An isolate from a marine mammal has caused brucellosis in a British researcher."

It would be "prudent" at this time for Canada to implement the usual animal health restrictions that are enforced whenever brucellosis is found in Canadian market-bound domestic livestock, don't you think? If this step is taken, and ethical notification of the situation is sent to the OIE, it is apt to bring to a quick end all Canadian commercial export trade in seal oil, seal meat, and seal pelts. Brucellosis is a dangerous disease...yet, incredibly, Canada has had nothing to say about brucellosis in seals, but has advised people to consume seal oil for the "health" benefits.

Grey seals in Nova Scotia may already be getting into serious trouble with brucellosis, because the latest pup count showed an unexpected shortage of pups at Sable Island, where this herd is centered, and where seals were found to have a high positive test rate for Brucella antibodies. Based on previous observations of the rate at which the size of this grey seal herd was increasing, DFO scientists would predictably have found about 60,000 pups on the island when they conducted their latest aerial survey in 2004. However, they found 41,000 pups instead, almost 20,000 less than expected.

It must be considered that the Nova Scotia grey seal herd might now be experiencing failed reproductive success because of infection with brucellosis. Are grey seal fetuses being aborted at an unusually high rate in Nova Scotia, and are these abortions being caused by brucellosis infection? This is a very difficult question to answer for a wide-ranging population of wild animals that may drop their aborted fetuses into the sea. Testing the fetus and the placenta is necessary to say with certainty that an abortion was caused by brucellosis.

In September, 2004, I discovered an aborted grey seal fetus at the shore near my home. Since I was unaware at the time that the Nova Scotia grey seal herd carried brucellosis (because the authorities have not told the public) I regrettably did not think to report this finding to the DFO or the CFIA. As a former public health nurse, I would have understood the importance of having the aborted seal placenta tested, if only I had known the seal herd was carrying brucellosis.

The truth is that this was only one of many dead seals I'd come across that summer, because grey seals and harbour seals in my area are killed in an indiscriminate "nuisance seal" hunt by the local fishermen, who then routinely leave the carcasses to litter and foul the shoreline as they decompose. Therefore, my assumption about the aborted grey seal fetus was that the mother seal had likely lost her baby because she'd sustained a gunshot injury. But I now realize that this little dead seal may have held important information about an adverse impact on the grey seal herd itself, from brucellosis.

Since the seal brucellosis was discovered, six years ago, DFO has apparently done nothing about the problem beyond issuing a brief annual media release informing the public that contact with seals might be "risky" because "seals bite." Knowing that the seals have brucellosis, and that this poses a potential threat to human health, DFO has failed even to insist that fishermen retrieve the carcasses of the "nuisance seals" that they shoot. This year, fishermen in Nova Scotia reportedly commercially slaughtered about 800 grey seals on beaches, and the fishermen left the seal offal where the seals were killed, on the shorelines. Residents, visitors, children and pets, all flock to the attractive Nova Scotia shoreline, and all of them may risk becoming ill with brucellosis if they come into contact with any seal, dead or alive.

Human infection and serious illness caused by Bruclla originating in seals has been confirmed in the medical literature. Severe brucellosis, involving brain infection, seizures, blindness and prolonged illness has been reported. (Sohn AH, Probert WS, Glaser CA, Gupta N, Bollen AW, Wong JD, et al. Human neurobrucellosis with intracerebral granuloma caused by a marine mammal Brucella spp. Emerg Infect Dis [serial online] 2003 Apr [cited April 20, 2006)]. Available from: URL: http://www.cdc.gov/ncidod/EID/vol9no4/02-0576.htm)

In recent years, I have asked DFO repeatedly for an open discussion about what its scientists know about the failing health of the ocean ecosystem. But they have refused to engage in any dialogue me on this subject, trusting, it seems, that nothing will come of my questioning because I am not a credentialed scientist and because the public does not understand what I have been trying to talk about (why the fish are starving, etc.). However, it was a shock for me to discover that DFO's reluctance to impede the goals of the fishing industry might extend as far as turning a blind eye to a serious public health concern.

Rather than tell the public that a significant fraction of marine mammals in general are now likely carrying a disease that renders them unfit for human consumption or use in any form, including fur coats, DFO has repeatedly published the misleading claim that Canadian seal herds are "healthy." On DFO's website this year has even been added misleading health claims for the consumption of seal oil capsules. The fishing industry is still being encouraged by DFO (and still being given government money) to develop more seal products and more seal markets, but I have found no evidence that the "seafood" processors working with seals have been informed about the "meat"-type potential hazards to public health that are associated with butchering mammals, hazards that must be controlled before mammal products can be safely marketed. This is beyond disgusting, and what I mean by "disgusting" is what international panels of health experts have formally accepted as the meaning of "disgusting."

As mentioned earlier, most people in this day and age will not knowingly buy even boot leather that was made from an animal infected with brucellosis or any other notifiable disease. And for this reason a prestigious international health body was established in 1924 (the OIE http://www.oie.int/eng/en_index.htm) to protect the public from exposure to such threats through international trade.

Now let's talk about Trichinosis

Trichinosis is another OIE-notifiable disease when it occurs in livestock. Trichinosis has also been found in marine mammals, including seals, in Canada, but this fact appears not to have been reported to the OIE despite Canada's involvement in the international export of seal products. Canada last notified the OIE of trichinosis when two cases were found in swine in 1996. Since then, it appears, Canada has enjoyed a "trichinosis-free" reputation.

Mammals with the potential to spread trichinosis, and that are subject to the "healthy at the time of slaughter" requirement, are nevertheless routinely screened for trichinosis in Canada. This is done for pigs. The testing for trichinosis includes microscopic examination of the muscle tissue for larval cysts, which can hatch into Trichinella worms. But this testing is not required for any "seafood," including seals.

A relevant article published by a scientist employed at the CFIA:

"The occurrence and ecology of Trichinella in marine mammals" by L.B. Forbes published in Veterinary Parasitology, December 1, 2000. 93(3-4): 321-34.   link

Trichinosis was reported as "commonly found in polar bears and increasingly in walruses where it presents a significant zoonotic hazard. This has resulted in the implementation of food safety programs in some arctic communities to test harvested walrus meat for Trichinella larvae prior to consumption." Trichinella was also reportedly found in bearded seals, ringed seals, beluga whale, as well as arctic foxes and domestic dogs. This parasite is usually spread when a carnivore eats the raw flesh of another carnivore. The rather unexpected finding of trichinosis in whales and seals was speculated to have been the result of their having eaten fish that had nibbled at the carrion of carnivores (dead bears, foxes, walrus or dogs that had been deposited in the ocean.) Trichinella found in arctic marine mammals was described as being an unusually "cold tolerant" variety, but also "infectious for man."

The manner in which seal hunting in Canada is currently conducted results in massive amounts of seal carrion being deposited in the ocean, an activity that might facilitate the transmission of trichinosis in marine mammals, considering the hypothetical involvement of a nibbling fish vector.

Most people know that pork should be well cooked to avoid contracting trichinosis. However, the blind entry of worm-laden pork or seal meat into the marketplace accompanied by a consumer warning to cook it well - this is not the goal of modern meat hygiene. The goal is to block meat containing Trichinella worms from entry into the marketplace, whether that meat is raw or cooked. Therefore, it does not matter how long Canada plans to cook "seal salami," this proposed export product may remain unfit for human consumption by international standards unless the product has been proven to be free of Trichinella.

Animals with trichinosis are deemed unfit in this day and age for commercial use as leather, fur, oil, meat or trinkets.

Let's talk about Botulism

Seal oil capsules made in Canada may potentially contain botulism toxin (in addition to Brucella) because the oil appears not to be pasteurized.

A very common bacteria, known as Clostridium botulinum, releases a deadly toxin into foods that are stored improperly in airtight conditions. Many foods can support the growth of this bacteria, and these foods can thereby potentially cause botulism food poisoning. "Low acid" foods (like meat) in cans or other air-tight packages offer the greatest risk of botulism poisoning. But Clostridium can be eliminated if the food is subjected to enough heat, and this principle forms the basis, for instance, of the guidelines for home canning. Pressurized devices are used to raise the temperature of sealed food past the normal boiling point of water, and these conditions must be maintained for a set time to kill Clostridium and its spores. The heat treatment principle also forms the basis of guidelines for the "commercial sterilization" of food.

Seal oil capsules made in Newfoundland are reportedly manufactured "by a process of cold pressing, centrifuging and mechanical filtering." But wait - that can't possibly be right - cold pressing?? Can consumers trust that merely "filtering" seal oil will remove spores of Clostridium? (and the Brucella?) Seems unlikely...and besides, this does not describe an acceptable process to achieve commercial sterilization of food.

Oil naturally creates an airtight environment, and this airtight environment will be well maintained, one must assume, inside a gelatin capsule. Pure food oils, such as olive oil, containing no particles of water-containing food (i.e. meat or vegetable), will not normally support the production of botulism toxin, and they are safe to eat. However, a small amount of other food contaminating stored oil can lead to botulism poisoning. Cases of botulism were reported recently when herbs were added to bottled olive oil and the product was not consumed promptly.

It seems that the seal oil manufacturing process might aim to remove all of the dangerous bits of seal flesh, blood, hair, bacteria and parasites from the oil by "centrifuging and filtering" and that this is how botulism is meant to be prevented. Can that process possibly be good enough? I don't know, but the plant that produces the seal oil capsules, Atlantic Marine Products, reportedly works under CFIA approval, although this claim made on their marketing websites does not indicate whether the plant is approved by CFIA as a "meat" processing plant or as a "fish" processing plant.

Seal oil is being hyped as a healthy source of essential fatty acids, especially omega-3. In an argument against "fish oil" as a good alternate source of omega-3, seal-oil promoter Cosmas Ho wrote in his book, "Omega 3 The Seal Connection," that part of the inferiority of fish oil is related to its production method, which includes "cooking." Is he worried that applying heat to seal oil might damage it?

But interestingly, a similar "omega 3" oil supplement has recently been manufactured from emus, large birds. Some people dismiss "emu oil" health claims as quackery, but the producers of that new brand of "omega 3 oil" at least reassure consumers that when they buy this product for human ingestion, it is safe to eat. From the Emu Oil Institute ( www.emu-oil.com ):

"It is important that the oil be brought up to a high enough temperature to eliminate all bacteria. A safe oil is one which has been heated high enough to kill all bacteria and does not diminish the integrity of the oil...Not all emu oil on the market is "refined," so we must warn consumers to beware. Some forms of emu oil are simply "rendered"; this means the oil has only been filtered, and may contain contaminants."

The American Emu Association ( www.aea-emu.org ) agrees:

"Emu oil is of AO (animal origin) and great care must be taken to provide the consumer with a safe product. Fully refined emu oil has been processed at high temperatures to remove potentially harmful contaminants such as hormones, toxic metals, pesticides, viruses, infection, and harmful bacteria (e-coli, salmonella); which cannot be removed at lower temperatures."

The risk from consuming un-pasteurized seal oil may be higher than the risk from un-pasteurized emu oil because emus, being birds, have no potential to transmit mammalian diseases like brucellosis or trichinosis to humans. But seals certainly do, and at the barest minimum, effective pasteurization of seal food (and seal oil qualifies as "food") should be imperative before this product is sold.

The final consideration on the risk of botulism is to acknowledge that seal oil has recently caused deaths by botulism poisoning among the Inuit people of Alaska. Just try "Googling" on "seal oil botulism Alaska" and see what comes up: far too many outbreaks of this very serious illness.

This is a true story. And seal oil is now promoted as a "health" food, even as a "dramatic new therapy"...you can buy seal oil over the internet at www.tidespoint.ca/health/sealoil.shtml (but not if you live in the United States, mind you, if you live there don't you dare even TRY TO ORDER this product because not only will you NOT receive any seal oil in the mail but you will be slapped with a ten dollar "CHARGEBACK FEE" by the purveyors of Terra Nova Omega 3 Natural Premium Harp Seal Oil Capsules! So there! It seems the U.S. has wisely put up a trade barrier against marine mammal products but that certain Canadian "seafood" promoters are miffed by that. (...p.s. since I first posted this article, I note a change on the tidespoint.ca website indicating that the penalty for Americans who try to order seal oil has now been reduced from the ten dollar "chargeback fee" to a five dollar "handling charge"...uh, for sending nothing by mail.))

(On April 19, 2006, before posting this article, I asked the CFIA to investigate my safety concerns regarding seal oil processing. No reassurances have yet been forthcoming; I have been told only that it is actually Health Canada who will respond to my concern, because seal oil is considered to be a "natural health product" (...although it is not currently included in the list of approved natural health products on Health Canada's website.) When I receive information that mammalian infectious health hazards, and commercial sterilization, are properly addressed by the seal oil processors, I will promptly add this information to this web page.)

Let's talk about who knows what else?

On DFO's website, included in "Facts About Seals 2006 - 2010" , is written:

"Seal oil, once extracted, is marketed in capsule form, which is rich in Omega-3 acids. The fatty acids are known to be helpful in preventing and treating hypertension, diabetes, arthritis and many other health problems.

The Government of Canada encourages the fullest possible commercial use of seals with the emphasis on leather, oil, handicrafts, and in recent years, meat for human and animal consumption."

Does DFO honestly expect these particular "facts" to have a five year shelf life?

Let's try a little quiz now...

Is seal OK for "leather?" ...no...(as explained already, for reasons related to currently uncontrolled hazards that may cause "notifiable" diseases)

For Oil?...no...

For handicrafts?...no...

Is it good for human meat consumption?...no...

Well what about animal consumption, is seal at least fit for animal consumption?...NO, ABSOLUTELY NOT!

...Why not?

First, it is just not a good idea to feed carnivores to carnivores, and "seal" is therefore an unwelcome ingredient in dog and cat food. But secondly, using seal meat for animal feed has been tried in Canada and it has turned out rather badly.

Mink farmers in Ontario tried feeding harp seals to mink, but the mink became ill with a new viral disease called "foot pad necrosis." Below is an excerpt from "Ontario Aquaculture Research and Services Coordinating Committee 2004 Strategic Report (For the Period 2005 - 2009)" ( document online )

"Foot pad necrosis was identified as a "new" emerging disease in Canadian mink in 1996. The disease presents as a vesicular disease with small, fluid-filled vesicles (blisters) forming along the margins of the foot pads and the adjacent haired skin, in the interdigital skin webs and around nail beds. Sometimes lesions are present along the margins of the eyes or nose. If bacteria infect the open vesicular lesion, severe secondary bacterial infections develop that cause pain, lameness and sometimes death. Males affected during breeding often had very sore feet and failed to breed. There is a strong epidemiological link between the emergence of the disease and the feeding of east coast seal meat (mainly Harp seal). The initial research done on this condition described the pathology and epidemiology of the disease but it was not successful in determining the etiologic (causative) agent(s). A marine calicivirus (San Miguel sea lion virus) is the prime candidate, but all attempts to isolate the virus failed, although serologic evidence was found to demonstrate that the virus was circulating in east coast Harp seals.

Foot pad necrosis continues to be a problem on Ontario and Canadian mink farms even though seal meat is no longer used as a food source for mink feeds. There is strong evidence that the disease becomes endemic on an affected mink farm and that it can be transferred from an infected farm to a "naïve" farm through sale of mink. As a result of lost breeding stock sales plus the clinical manifestations, this disease causes significant economic losses to the Canadian mink industry and further has restricted the industry from utilizing seal meat, a readily available and reasonably priced protein source."

Is it possible that DFO's seal meat promoters are unaware of this? "Males affected during breeding often had very sore feet and failed to breed?!" Good grief, did not even this item of information set off a warning bell at DFO and CFIA? ...What about "naïve" sealers? ...What if the new "circulating" harp seal virus ends up causing the same symptoms in human males who eat seal meat or take seal oil capsules? ...What if sealers get sore feet and cannot breed?

What other unexpected contagious agents might lurk in seal meat? There are other known threats, including "seal finger" and "sealpox" (and these are not trivial) but there are also undoubtedly other unknown contagious threats to human health associated with the use of seals. (A nice illustrated two-part brochure describing some of the known contagious risks is "Diseases and Parasites of Marine Mammals of the Eastern Arctic": http://wildlife1.usask.ca/Publications/Marine_Parasites/CCWHC%20Mar%20Mam%20pub%2072_84.pdf Second part at: http://wildlife1.usask.ca/Publications/Marine_Parasites/CCWHC%20Mar%20Mam%20pub%2013_25.pdf )

Let's talk about PCB's, mercury, etc...

Does seal blubber contain enough chemical pollution today to reject seal oil for human consumption on that basis alone? And is Atlantic Marine Products, the maker of Terra Nova seal oil, a bit worried about customers thinking this?

Government documents indicate that Atlantic Marine Products has received at least a million dollars in Canadian government support to build up and promote their seal processing business in Newfoundland. To make jobs for Newfoundland sealers - no? Yet, on one of its promotional websites, this "seafood producer" has written (http://www.tesco-shopping.com/terranovadrho.htm):

"...Seals have been harvested in the Canadian North Atlantic off the coast of Newfoundland for centuries. Those utilized by Atlantic Marine Products are culled from the Canadian side of Greenland where waters are much less polluted, and are younger, juvenile seals that have not migrated from this area..."

Atlantic Marine Products is claiming to use very young seals from Greenland, and to not even be using seals from "this area," i.e. seals from Canada? Seals that have not even had an opportunity to visit Canada? Really?...this statement is being made after all the support Canada has shown to Atlantic Marine Products ? I believe I've read somewhere that Greenland doesn't even harvest seal pups, but takes adult seals. (And hey ho, if you are really importing seals from Greenland, they had better be accompanied by proper veterinary health certificates or you might find yourself in trouble with the CFIA.)

Regarding pollutants, scientists continue to report observations of an increasing trend of accumulating heavy metals, PCB's, etc. in marine mammals. The pollutants are most concentrated in the blubber, and in apex predators such as seals. The pollutants are thought to adversely affect the immune systems of these animals, and this may be one factor that has contributed to the rise of infectious diseases in seals. Newly weaned seal pups carry much higher concentrations of persistent pollutants than do their mothers. This is because, while nursing, a substantial fraction of the mother's body fat is in effect transferred directly from the mother to the pup through the milk. Then an effect called bio-magnification occurs, as pollutants become more concentrated each time they shift into the next consuming animal.

In Pacific killer whales a trend was recently observed of an uncommonly high death rate among the firstborn young. Scientists concluded that the baby killer whales were dying because the firstborn baby whale or seal pup gets hit with the fat-stored toxins that have been accumulating during the entire earlier life of the mother. In seals this would be about five years worth of toxins to be downloaded on the first pup, but then a lesser quantity, depending on the length of the birthing interval, perhaps one or two years worth of toxin accumulation for each subsequently born pup. It is unknown whether firstborn seals are now toxic enough to die early from this cause alone, but this certainly seems to be within the realm of current or near future possibility.

Oddly, Cosmas Ho describes living seals instead as working to "bio-filter" "natural impurities" out of fish oil as part of his claim that seal oil provides the ultimate in healthy omega-3 oil for human consumption. On its promotional websites, Atlantic Marine Products does not report the use of any process to remove fat-stored chemical pollutants from seal oil.

Have any medical problems been noticed in people taking seal oil to date? In "Omega 3 The Seal Connection," Cosmas Ho wrote: "Patients have occasionally reported a fishy after-taste from taking the capsules. This seems to be the only side effect I have encountered."

Neither fish nor fowl...

The face that launched a
thousand protests

Since the early 1970's, animal welfare groups have protested that Canada's slaughter of seal pups is unacceptably cruel, inhumane. Public disapproval of "cute" whitecoat harp seals being clubbed and skinned alive led to a ban on the slaughter (or "harvest," if you prefer to use "fishing" lingo) of whitecoat seal pups in 1987. Now harp seal pups are killed at an age a couple of weeks older than the pup shown above, after the white fur has been shed and the underlying silver-grey coat appears.

DFO today protests that animal rights groups are dishonestly using images of newborn harp seal pups in their publicity materials against the harp seal hunt. So, the animal welfare groups have mostly removed whitecoat pup images from their seal hunt protest websites, showing instead the grey coat "beater" pups, the age of most seals slaughtered today.

Might DFO actually be trying to suppress the (somehow offensive?) image of the whitecoat harp seal pup? To erase this vision from the public memory? And, can a solid argument really be dismissed because it is illustrated with such an appealing photo...?

DFO calls it a "myth" that seal pups are still skinned alive in Canada. However, under the "tightly regulated" seal slaughter, it is not illegal for sealers to skin a seal that is still breathing, that has a pulse, blood pressure, and even a writhing torso. Whether a writhing seal is exhibiting a "swimming reflex" or a conscious struggle, it is not a "dead" animal, but a "live" one. The Canadian rules have never required that seals be "dead" before being skinned, only that sealers try to render them "irreversibly unconscious." There is a difference.

One problem is that the determination of unconsciousness in a mammal (and even harder, the determination that unconsciousness is irreversible) can only be made by a person with appropriate medical training, i.e. a veterinarian. Sealers are not qualified to make this call, and neither are the fishery officers who "monitor" the "hunt." This lack of expertise on the ice may help explain the lack of charges against sealers for violating rules regarding skinning conscious seals. Any defense lawyer could easily have the testimony of a fishery officer thrown out because he is not qualified to attest to the level of consciousness of a seal. ("Fishery Officer, are you a qualified veterinarian?" "No, Your Honour." "Well then, there is no basis for the court to accept your testimony that the seal was not unconscious when it was skinned by the defendant. Since the burden of proof that an offence was committed lies with the crown, and the crown has failed to provide the testimony of a qualified expert witness, the charge must be dismissed.")

A "dead" mammal has no heartbeat, no pulse, and it is not breathing, or writhing, nor is it displaying reflexes, either blinking or swimming. The "Independent Veterinarians Working Group" (IVWG) seemed to be suggesting at DFO's seal forum in 2005 that Canadian rule-makers should now consider moving toward a requirement that seals actually be killed before being skinned. The IVWG recommended "bleeding" seals after "stunning" them and before skinning them. If arteries are cut and enough time is allowed for proper "bleed-out" to occur, then the seals will be dead, with no heartbeat, not breathing, not moving, and they will also of course be finally and "irreversibly unconscious." Prescribed "bleed-out" procedures and times are followed in abattoirs before the carcasses of food animals are cut into. This is what is normally considered to be "humane slaughter" in slaughterhouses - dead before being cut up. However, seals slaughtered in Canada have never been given the same consideration as other mammals. Instead, seals have long been, and continue to be, skinned alive. Animal welfare groups who have protested on this point have always been right.

Canadian "seafood" producers' insistence that seals can be passed off in the marketplace as "fish" because seals are "aquatic animals" may exceed the credulity of most of the world, who are quite aware that Canadian sealers stand and club small furry mammals that cannot even swim. It is all too foolish. I wonder what the CFIA would say if the shoe was on the other foot. What if some remote foreign country decided to "cold press and filter" rat oil and then wanted to sell this product as a wonder cure on the Canadian market? Rats can swim, so they are arguably aquatic animals...so a certificate attesting to the absence of fish diseases in rats should be good enough - right? And the OIE doesn't actually list rat diseases...well, trichinosis is in there but it is listed as a disease affecting "multiple species" but not explicitly listed as affecting "rats"...so the fish and seafood certificate for importing rat oil food to Canadian supermarkets need only add a clause, like Canada did for Korea, attesting that "Remote Foreign Country has not reported any animal contagious diseases listed by the World Organization for Animal Health (OIE) in rats, and there are no associated animal health restrictions required for Remote Foreign Country rat meat for human consumption."


3. What should be done about the poor health of Canada's seals?

a). Canada should report brucellosis and trichinosis in seals in Canada to the OIE, and appropriate domestic seal product recalls should be made, under the direction of the CFIA. The necessary modifications to current seal processing methods that will be required to allow seal products to be deemed safe for human consumption as "meat products" promise to be so onerous that all profitability from commercial sealing stands to be lost. There is likely no point in even trying to implement proper slaughterhouse rules for the inspection of potential seal products (such as veterinarians testing seal blood for Brucella antibodies, examining carcasses and culturing lymph nodes, etc.) because the Canadian harp seal herd is already known to harbour brucellosis. Canada should apologize for its rudeness to people who have offered over the years and who have tried to act as volunteer "humane slaughter" inspectors at the harp seal hunt (the "anti-seal hunt protestors" who have watched as "observers"). Whether the slaughter of food animals is conducted humanely is only one checkpoint in the normal veterinary screening procedure for wholesome animal food production. Canada has avoided implementing any formal veterinary oversight of seal processing, and has thereby left the consuming public potentially exposed to known risks. Systematic ante-mortem and post-mortem health inspections of all animals must ordinarily pass the approval of qualified veterinarians before mammals can be processed into human food. Throwing seal entrails onto volunteer amateur humane slaughter inspectors is not a reasonable substitute for this step in the food safety process. A special apology is owed by Canada to Rebecca Aldworth, and unfortunately, the volunteers who were hit with seal guts should probably be checked for brucellosis.

b) A disease "eradication" program, such as is carried out to deal with reportable diseases in farmyard livestock, cannot be contemplated for seals. Instead, people should simply be warned to stay away from marine animals, and not to "use" them at all. Seals continue to play a very important role in what is now a stressed and unstable ocean ecosystem. In a brief flash of understanding, DFO included the correct seal management guidelines in their recent "seals bite" press release, when someone in the Communications Branch wrote "seals are wild animals and should be left alone." Fine. End of discussion.

c) Canadian Public Health authorities should be notified of the human health threat posed by seals. Medical doctors should be advised that they might encounter cases of now rare human brucellosis and trichinosis in Canada below the arctic, because these diseases exist in our marine mammals. No need for hysterics, though, the seal warning will be something like keeping in mind that bats might carry rabies - so just don't touch them. Seals will be more easily avoided than bats because these fish can't fly. A special alert should be issued regarding brucellosis in grey seals in Nova Scotia.

d) Ethical and accountability issues should be addressed.

If the sealers were not properly warned that they have been putting themselves at risk of contracting brucellosis, for instance, and of what that means, and if any of them have become sick, and then turned out to be sero-positive for marine mammal origin Brucella antibodies, the sealers may have a case against DFO and CFIA. The same goes for other obscure "emerging" diseases that sealers may have inadvertently contracted from contact with seals during the hunt. Is it possible that the authorities decided to use sealers as the guinea pigs to test the seriousness of emerging infectious diseases that have the known potential to be transmitted from seals to humans? At DFO's seal forum in 2005, sealers were asked to provide blood samples to be checked for brucellosis antibodies...

There should be an open investigation into why the CFIA has added "seal meat" to "fish and seafood" health certificates for products exported from Canada. This demonstration of a lack of integrity on the part of Canadian "seafood" processors and government officials may serve to tarnish the reputation of all Canadian seafood exports.

Another question arises regarding information on CFIA's website: where is the missing veterinary health certificate that should be accompanying seal pelts exported from Canada to Russia? Examples of many other such export certificates are available on CFIA website, linked from http://www.inspection.gc.ca/english/anima/
heasan/export/prod/prode.shtml
-- and the only link on that page that produces a "sorry, unavailable" message is the link to the "veterinary health certificate" for "furs dried not treated" to be sent to Russia.

We also need to know why Canadian government money continues to be thrown at a useless pipedream in the modern world, a "sustainable seal fishery."


4. What are the veterinarians saying?

I have been unable to find any record describing any involvement in the monitoring of the Canadian seal product processing by veterinarians employed by the CFIA to ensure the safety and wholesomeness of other Canadian "meat products." However....

An "Independent Veterinarians' Working Group" (IVWG) http://www.ivwg.org reportedly funded by the World Wildlife Fund (WWF) produced a report in August 2005 regarding their assessment of the humaneness of the slaughter techniques used in the Canadian harp seal hunt, and this was presented at DFO's 2005 Seal Forum. No CFIA-employed veterinarian sat on the panel. The IVWG made recommendations for improvements in practices currently being used in the slaughter of seals. The report of the IVWG was focused on "the reduction or elimination of animal suffering," but it included a few pieces of more general information. (Excerpts from the report, below, are followed by my comments in brackets.)

"The Canadian harp seal hunt has the potential to be a humane hunt -- one that should be judged with reference to accepted practices for euthanasia, and in comparison with killing done in abattoirs."

(Abattoir practices are systematically supervised by veterinarians under Canadian law. The seal slaughter is not monitored in this manner, but very obviously is should be if seals are to be treated "humanely" during slaughter, and are to be processed for human consumption.)

"The methodology proposed by the Group is consistent with the AVMA panel on euthanasia report, and accepted abattoir practice....Veterinarians can only advise."

(Advice from professionals should include all that they know that has an important bearing on the matter on which they are being consulted. One must assume, based on their credentials, that the members of the group were fully aware of all usual requirements of "accepted abattoir practice." From veterinarians discussing abattoirs, one might reasonably expect to receive advice regarding the health of animals, and perhaps advice on how animal health can impact on human health. To avoid receiving this sort of information, questions asked would seem to need to be very carefully worded.)

"All members of the Working Group feel that sealers should make every effort to ensure that a seal is bled before hooking or skinning."

(The suggestion that sealers increase their exposure to the blood of the seals (by "cutting arteries") can have been made only in the interest of increasing the "humaneness" of the killing, because brucellosis can be spread through infected air-borne body fluids, including blood.)

"On May 27-28 the IVWG met in camera to discuss the hunt..."

(The online 'Lectric Law Library defines "in camera" as "refers to a hearing or inspection of documents that takes place in private, often in a judge's chambers. Depending on the circumstances, these can be either on or off the record, though they're usually recorded. In camera hearings often take place regarding delicate evidenciary matters, to shield a jury from bias caused by certain matters, or to protect the privacy of the people involved, and are common in cases of guardianships, adoptions and custody disputes alleging child abuse." -- What kind of delicate issue might have caused the IVWG to choose to meet "in camera?" Did they argue during their private meeting about whether or not they should frankly describe to the sealers the symptoms of brucellosis in humans? Or was the debate focused on whether or not they should go as far as to offer the advice that sealers increase their efforts to "bleed" seals? I found no record, but one may exist. The people excluded from the veterinarians' in camera meeting were described in their report as "sealers, industry representatives, government managers and scientists.")

'It is carried out by a large number of hunters, over an extensive area, in a short period of time, and monitored by a relatively small number of regulators."

(Note the use of "regulators" instead of "inspectors" as the word to describe who monitors the hunt. People who monitor practices in abattoirs and meat processing plants are trained inspectors, and not "regulators." The sealers are referred to as "hunters," making it clear that these men do not possess the necessary qualifications to be considered inspectors themselves.)

"This report discusses a range of factors and issues related to the hunt, and makes eleven recommendations to the sealers, industry and regulators."

(The report discusses a limited "range of factors and issues related to the hunt." Omitted was a "factor and issue" of interest to at least one veterinarian in the group, that of testing the sealers themselves for antibodies to Brucella. At the seal forum, separate from the formal report of the IVWG, an American veterinarian told the sealers that he had diagnosed brucellosis in seals in New England, he gave a brief description of brucellosis in farm animals, and then he asked if he could check the sealers' blood for signs of this infection. Although he had previously published his finding of brucellosis in harp seals that had straggled south as far as New England, the recommendations of the IVWG did not extend as far as recommending that "regulators" actually take the step of screening the Canadian harp seal herd to get an idea of the current prevalence of brucellosis in this herd of wild animals headed to market. Advice from the veterinarians to the hunt-monitoring "regulators" included a suggestion that Canada's Marine Mammal Regulations be amended to require bleeding seals and checking clubbed seals for bilateral depressed skull fractures - and very explicit instructions were given to the sealers on how they should carry out this particular recommended, dare I say, "inspection" task. But incredibly, the regulators were not advised to ensure that the seals are checked for diseases that might threaten human health.)

"Individuals should receive training before they are licensed as hunters, and periodic upgrading should be required."

(But licensed and trained hunters are not the same as licensed and trained meat inspectors.)

"Industry should continue to strive for full utilization of each seal killed."

(Irresponsible advice coming from veterinarians who have reason to suspect that some of the seals carry brucellosis. In making this recommendation, the veterinarians seem to have strayed off-topic (their mandate was reportedly only to consider "humane practice"). This particular recommendation sounds like public relations in support of DFO's "full utilization" policy.)

"Development of markets for seal meat should be encouraged, however it should be noted that development of consumer markets for seal meat will necessitate improved carcass handling and storage processes. Such use of seal parts for specific markets is a component of full utilization."

(Since the veterinarians went as far as to mention "improved carcass handling" in the course of providing their advice on a different topic (humane killing technique), the IVWG should have gone on to explain what they meant by this - exactly what "improvements" do these veterinarians believe are needed before Canada "develops consumer markets for seal meat?" The single crucial change that is most needed is to acknowledge that seals and all parts of seal carcasses, including fur, are legally "meat" (as well as "fish") under Canada's Food and Drug Act, and that all of the "meat" rules should therefore be applied before marketing seals. Canada's quirky "seafood" export certificates could still be sent along with seal products, of course, but they should also be accompanied by "veterinary health certificates" to ensure that all potential hazards have been addressed in producing those products.)

"In order for anyone to attest to the humaneness of the hunt, there must be an improved level of supervision and monitoring."

("Attesting" to various aspects of the condition of animals is a major part of the work of abattoir veterinarians. The "Health Attestation" is the most important section of the "veterinary health certificates" that are required to accompany exported animal products. "Certificates of wholesomeness" for fish products do not carry the same meaning. For the export of seal pelts from Canada, "veterinary health certificates" should be being produced and "attested to" by Canadian government-employed veterinarians, however a sample of such a certificate cannot be found on the CFIA website for Russia, a major buyer of Canadian seal pelts. It also appears that seal meat is going to Asia under fish inspection certificates, which are not required to be signed by veterinarians. Canadian veterinarians, it seems, have had nothing at all to say (openly) about the safety of Canadian seal products for human consumption.)

"Sealers would benefit from strong professional associations that support and promote humane practices."

(So would veterinarians. Is it inhumane to withhold information and to thereby allow unnecessary pain and and distress to be suffered by sealers?)


5.What about the idiotfish*?

Truth is stranger than fiction. On the CFIA website is the "List of Canadian Acceptable Common Names for Fish and Seafood." The list is extensive, but "seal," "harp," "meat," "Pagophilus groenlandicus" and "Halichoerus grypus" are nowhere to be found. Several acceptable seafood names sound initially as if they might be disguises for products obtained from mammals, but in each case the name turns out to refer to an organism that is in fact cold-blooded, i.e. fish, molluscs or crustaceans. Checking reveals that the acceptable common seafood names catfish, sheepshead, blue dog, hairtail, rattail, elephantfish, rabbitfish, buffalofish, lionfish, horse mackerel, witch, hairy cockle, wolffish, milkfish, butterfish and even "flathead captainfish" are not used to describe products that were actually derived from mammals. Similarly, "flying fish" and "canary rockfish" are not derived from birds, or from rocks. "Dolphinfish" and "beluga" sound like mammal products for sure, but no, they are both actually fish too...so all of these seafood products would seem to be on the up and up. "Tusk," even, does not refer to part of a walrus, but to a finfish.

Besides "seal," "walrus" and "whale" are found nowhere in the List of Canadian Acceptable Common Names for Fish and Seafood. Obviously, these marine mammals are meat too, and although seals, walrus and whales have long been consumed by indigenous northern communities without the benefit of modern precautionary meat processing techniques, this approach is not an acceptable one for sending animal products to today's commercial consumer market.

CFIA's list of acceptable fish names: http://www.inspection.gc.ca/english/anima/fispoi/fishlist/canadahomee.shtml

IDIOTFISH is an acceptable seafood name: http://www.inspection.gc.ca/english/anima/fispoi/fishlist/canalphafolder/icanalphamastere.shtml

"I am the Walrus, goo goo g'joob" (Lennon/McCartney)

(P.S. I filed formal consumer complaints with DFO and CFIA asking that they investigate potential human health risks that may be associated with the consumption of commercial seal products, as described above. No answers have been forthcoming yet, but I will add the DFO and CFIA replies to my complaint to this webpage once they have been received.)

copyright Debbie MacKenzie 2006 - email: codmother2@aol.com


 

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