Letter to the Minister responsible for the safety of seal products

May 19, 2006

To:       The Honourable Chuck Strahl
            Minister of Agriculture and Agri-Food
            Sir John Carling Building
            930 Carling Avenue
            Ottawa, Ontario     K1A 0C5

From:   Debbie MacKenzie          

Zoonotic pathogens in Canadian seal products: a consumer hazard ignored for political reasons?

Dear Mr. Strahl,

Please investigate the failure of the Canadian Food Inspection Agency (CFIA) to ensure that proper methods are used in Atlantic Canadian seal product processing to avoid zoonotic disease transmission from seals to human consumers. Because Atlantic Canadian seal processors currently do not take precautions necessary to eliminate infectious human health risks from seal products, please also now exercise your power as the responsible Minister to order a precautionary recall of their seal products (under section 19 (1) of the Canadian Food Inspection Agency Act).

Seal products (meat, oil, pelts) inherently carry a suite of potential infectious hazards to human consumers that is comparable to the list of problems that are routinely addressed by CFIA and controlled in the processing of other mammal-derived products, such as beef and pork.

Seals are naturally susceptible to many contagious diseases that can be transmitted to humans, including tuberculosis, brucellosis, trichinosis, giardia, toxoplasmosis, rabies, leptospirosis and others. If proper control measures are not taken, people handling seals or consuming seal products potentially risk contracting these serious diseases. The potential for such disease transmission to occur has been clearly established in the scientific and medical literature.

In recent years, seal herds that are used commercially in the sub-arctic (harp seals, hooded seals and grey seals in the Atlantic provinces) were tested by government scientists and discovered to be affected by zoonotic agents. Despite these findings, no Atlantic surveillance program for seal diseases was initiated by the Department of Fisheries and Oceans (DFO) or by the CFIA, and Atlantic seal products, including raw seal meat and raw seal oil for human consumption, have continued to be marketed lacking any veterinarian assessment of the health of the animals, yet apparently with the “approval” of the CFIA.

In contrast, when similar evidence of disease was found in arctic marine mammals (seals, whales, walrus), new public education and food safety initiatives were undertaken by the CFIA and the DFO. Educational materials were produced to inform arctic subsistence hunters/consumers about zoonotic disease risks associated with marine mammals, and recommending appropriate food safety measures. However, this new public education/warning initiative was not extended to include commercial sealers in Atlantic Canada or the consumers of their products.

It seems CFIA-approval is currently granted to Atlantic commercial seal products on the basis of their meeting “fish inspection” sanitary standards, rather than holding them to the far more stringent controls used in “meat inspection.” There are major differences. When handling “fish,” processors take safety steps aimed primarily at avoiding contamination of the product (i.e. with grass or dirt) and avoiding spoilage (by proper refrigeration). Raw fish flesh itself, if kept clean and cool, is not considered inherently dangerous to humans.

Meat, however, is another story, and seals are meat.

“Meat” processors can only sell commercial products after each animal has passed a tightly regulated health inspection under the supervision of an official veterinarian. “Meat” animals are routinely tested for diseases to which they are known to be susceptible, and the internal organs of food animals are examined in detail at slaughter for signs of contagious diseases. Certain findings cause carcasses to be deemed unfit for human (or other animal) consumption. Basic instructions for applying this information in handling seals were included in the educational material for arctic subsistence hunters. However, this type of inspection is not currently required for commercially processed Atlantic seals. Consumers of commercial Atlantic Canadian seal products are therefore not provided with the same standard of food safety that is considered prudent for subsistence hunters, let alone the higher standard that consumers count on in other CFIA-approved animal products.

The DFO’s “Marine Mammal Research” includes an Atlantic program that reportedly researches “marine mammal diseases and parasites” (in Quebec). The responsibility to monitor the health of seals lies with the DFO, and the DFO recently received $6 million dollars in extra federal money to expand their “Atlantic seal research” (and this followed the first scientific confirmation of zoonotic pathogens in commercially harvested Atlantic seal herds). Although millions of hunter-killed seal carcasses have become available in recent years for potential tissue sampling for infectious disease surveillance…to date, the DFO has initiated no such disease monitoring in Atlantic seals.

No veterinarians assess the health of the commercial seal herds, either at the hunt or during seal product processing. This omission seems somehow related to the seal hunt being regulated under the Fisheries Act.

However, Atlantic seal health is not even being dealt with as a “fish health” issue in Canada. To maintain the confidence of international seafood buyers, the DFO and the CFIA recently collaborated in forming a new National Aquatic Animal Health Program (NAAHP) to implement surveillance and control of fish health and to reassure buyers that Canadian “fish” products are derived from healthy “fish.” However, to date, seals have been excluded from the work done by the NAAHP.

So, Canada (aware that seals carry dangerous diseases) treats Atlantic commercial seal herds as “fish” for the purpose of avoiding their inclusion in the commercial meat inspection sanitary rules, but then turns around and treats the same seals as “not fish” for the purpose of avoiding their inclusion in the NAAHP? Is Canada deliberately avoiding an open investigation into the health of Atlantic seals and avoiding educating the general public on potential human health risks associated with seal products, in order to protect the economic goals of the Atlantic fishing industry? 

Please investigate how the Canadian Cooperative Wildlife Health Centre, the CFIA and the DFO responded to the late-1990’s discovery of brucellosis (a nationally “reportable” and internationally “notifiable” disease) in commercially used seal herds. An investigation should be made into actions that were taken, and actions that were not taken, by responsible individuals who were involved in this matter.

The mandate of the CFIA includes enforcement of the Health of Animals Act, which includes the following prohibition in section 8:

“No person shall conceal the existence of a reportable disease or toxic substance among animals.”

With regards to the handling of evidence of brucellosis in sub-arctic seals in Canada, the CFIA may now find itself in the awkward position of having to investigate its own and other government employees for having possibly committed this offence. This situation therefore deserves an independent inquiry. 

One month ago, I lodged my concern about the uncontrolled zoonotic hazards of seal products with the DFO (Maritimes) and the CFIA. The DFO has not responded. From the CFIA, I have received no response except to be told that the entire matter of my complaint (health risks associated with seal oil, seal meat and seal pelts) has been passed from the CFIA to Health Canada for investigation. Is the CFIA suggesting that this matter falls outside their jurisdiction? I have not followed up with Health Canada because their employees have not responded to my voice messages.

After communicating my concerns to the DFO and the CFIA, I posted an article questioning the safety of seal products on the internet at http://www.fisherycrisis.com/seals/seal%20products.htm . In the month since then, this web page has evidently been viewed repeatedly by employees of the CFIA, the DFO and Health Canada. However, I have as yet received no answer from any of them to the issue I have raised.

Might the responsible government agencies be unwilling to openly discuss the safety of commercial seal products because this issue might have a negative impact on Canada’s seal product marketing plans?


Debbie MacKenzie


cc:        The Honourable Tony Clement
            Minister of Health
            Minister’s Office – Health Canada
            Brooke Claxton Building, Tunney’s Pasture
            Postal Locator: 0906C
            Ottawa, Ontario, Canada
            K1A 0K9

            The Honourable Loyola Hearn
            House of Commons
            Minister, Fisheries and Oceans
            Parliament Buildings, Wellington Street
            Ottawa, Ontario, Canada
            K1A 0A6

            Trevor Swerdfager, chair – CCWHC Board of Directors
            Environment Canada, Canadian Wildlife Service
            351 St. Joseph Blvd, 3rd Floor
            Gatineau, QC, Canada
            K1A 0H3


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