August 6, 2010
RE: Petition to Commission and new language in 2011 Angling Regulations prohibiting the use of Sodium Sulfite in Cured Eggs…“Except Eggs Cured with Sodium Sulfite”
To the Commission:
Thanks for this opportunity to address you in this forum. I commend the staff for taking this issue to the commercial cure manufacturers. Indeed most of the product used to cure eggs, is produced commercially. But that doesn’t address the legality of this issue. The petition to change the language is not moot.
As an Oregon angler I’m confused by some things:
DEQ states the use of Sulfite cured eggs is technically illegal in Oregon but they won’t enforce Oregon law until the public is informed. Fair enough.
Note: DEQ changed their position on the toxicity of Sodium Sulfite used in egg cures after I informed them that the EPA regulates the use of Sodium Sulfite (and similar chemicals used in commercial egg cures) under the Toxic Substance Control Act. To date, I don’t think any Oregon cure manufacturers report to the EPA their use of these toxins.
So here’s where none of his makes sense: If I follow Oregon fishing regulations, I’m technically breaking the law. I don’t like that. But DEQ won’t enforce the law until the public is educated about the issue, which is precisely what the angling regulations do. So why isn’t the public informed in the regulations that technically they’re breaking the law, if they use chemically cured eggs? And by not adding the new language, aren’t the commission and department condoning the violation of Oregon’s Clean Water laws? Just add the words in our petition to the regulations, and the public is informed.
Additionally, it seems odd that toxins are regulated in fish food made for hatchery-raised juveniles in Oregon, but toxic bait made available to wild juveniles through angling practices is not? Have you ever seen the number of wild young of year that swarm just one offering of cured eggs in the spring? It’s a frenzied ball of feasting.
The Department states there is no conservation crisis, but where is the data to support that? And they have no plans to study the real world impacts of sodium sulfite on the life history of wild juveniles. The study clearly states that sodium sulfite killed juveniles at rates over 30% in some brands of egg cures. Some died after eating just one egg. It’s poison.
In addition to the petitioned language change, I suggest adding…”and all substances regulated by EPA.”
Add the following link:
http://iaspub.epa.gov/sor_internet/registry/substreg/searchandretrieve/searchbylist/search.do
Home brewers can conduct a simple chemical search and know whether or not they are putting regulated poisons into fish, and the water
An advisor to this effort said, “This is precisely the type of hard decision making that the agency, and the Commission are supposed to do. Some times they have to make decisions that are unpopular with some segments of the regulated community, for the good of the resource – or to protect anglers from their own misguided conduct. This is one of those times.”
My dad didn’t want to give up his precious eggs cured with sulfites. He said, “well, until they put it in the regulations, how are we supposed to know it’s bad.”
This is low hanging fruit. And its something we can do to help salmon in this time when so many uncontrollable factors are impacting their survival. Just add the six words.
I think, you’re either with the fish, or you’re making excuses.
Thank you very much,
Jeff Mishler
Portland, OR