A blooming dilemma: maintaining access to California crab while managing biotoxin health risks

Abstract

The widespread and persistent 2015–16 domoic acid- (DA) producing algal bloom along the US West Coast led to fishery closures, resulting not only in significant economic losses to California’s commercial Dungeness and rock crab fisheries, but also substantial social impacts and disruption throughout the seafood system. The closures highlighted the need to identify and evaluate strategies for managing and building resilience to future blooms to minimize losses of access and impacts to the seafood system while protecting public health. Using a mixed methods approach, we integrated semi-structured interviews with insights from participant observation, commercial fisheries data, and other archival materials, to begin to address this need. We evaluated the impacts and implications of recent and potential DA management measures for access to crab by fishermen, seafood handlers, retailers and food service providers, and consumers, and explored strategies to mitigate them. Each of the measures considered—area closures, evisceration orders, depuration requirements, and educational campaigns—was found to have particular and potentially profound impacts and implications for the seafood system and its participants. The latter three measures, which are intended to mitigate the risk of consumer exposure to DA while still providing some access to the fishery and seafood products, differ in who can participate in the fishery, how and by whom the catch can be handled, and the product forms that may be sold. All were considered problematic, with evisceration and depuration expected to affect access by re-distributing opportunities, costs and benefits among fishery participants and communities. Various mitigation strategies may lessen the adverse impacts of these measures, including “normalizing” evisceration and directing resources toward training, product development, and marketing to enable broader fishery and market participation, among others. Further, our findings support a fundamental paradigm shift for addressing this issue from one of fishery resource management to one of food system management, utilizing existing frameworks and systems and making it consistent with how other food contaminant concerns are managed. Ultimately, such a paradigm shift could help mitigate impacts throughout the seafood system while offering a more cost-effective, efficient and balanced means for managing fisheries and DA events.

1 Introduction

Harmful algal blooms (HABs), particularly those that produce domoic acid (DA), can have major impacts on US seafood systems, yet few studies have strategically considered the combined impacts throughout the system when managing commercial fisheries and protecting public health during DA events (Jin et al., 2008; Olson et al., 2014; Ritzman et al., 2018). DA is a neurotoxin that is harmful to humans (and other mammals) with the risks directly linked to seafood consumption.¹ It is produced sporadically by certain microalgae and bioaccumulates in organisms that consume it. The bioaccumulated DA is then transferred into and through the food web as organisms with DA are consumed by others including humans (Lefebvre et al., 2002; Zabaglo et al., 2016). The human health risks can be severe, including gastrointestinal and kidney problems and amnesia. The toxin was discovered in 1987 after several people died from consuming cultivated mussels with DA (Perl et al., 1990). Since then, no deaths have been attributed to it, but acute and chronic exposure from consumption of recreationally harvested bivalves, particularly clams, remains a concern especially for those who fish for subsistence and/or consume internal organs of DA-exposed organisms (Lefebvre and Robertson, 2010; Ferriss et al., 2017; Wang et al., 2024).

To help protect human health, public health and natural resource agencies implement management measures when DA is detected above the US Food and Drug Administration (FDA) action level—for Dungeness crab, 30 ppm in the viscera (internal organs) and 20 ppm in the meat. The actions taken variously impact access to commercial fisheries, their products and markets for varying lengths of time depending on the persistence of elevated DA levels. Each state manages DA events for fisheries within their jurisdiction and impacts on the food system vary depending on the actions taken (Otts, 2016).

Since the early 1990s, state health agencies have monitored conditions and, as a management response, issued seafood consumption advisories for species with elevated DA levels (Carter et al., 2013; Trainer and Hardy, 2015). These advisories alert consumers to evidence of DA toxins above the FDA action level in affected seafood, and recommend specific seafood handling methods to reduce, if not eliminate, potential exposure to DA. The recommendations include not consuming the internal organs and not using the water from cooking in soups in other foods (Hatfield et al., 1995). These advisories are intended for those who obtain seafood on their own through subsistence and recreational fishing and those who have recently obtained product from affected areas via commercial markets.

Throughout the US West Coast, including California, area closures of fisheries have been the most widely-used management measure for protecting public health during DA events. These closures prohibit commercial fishing in specified areas and landing the catch at ports within those areas where DA levels exceed the FDA action level. Closed areas are re–opened only after two consecutive samples of the affected species taken at least a week apart indicate DA levels in each animal sampled are at or below the FDA action levels.

Following an unprecedented DA event in 2015–16 (McCabe et al., 2016), West Coast fishery managers and public health officials also have considered or used evisceration orders for the affected commercial fisheries when DA has exceeded alert levels only in the viscera. An evisceration order is a management alternative that can allow for limited commercial fishing, and is intended to mitigate the severe negative impacts of closures. It requires that the internal organs of crab, where DA toxins are stored, be removed before sale to consumers. Evisceration orders were initially developed and used in Oregon to enable the Dungeness crab fishery in a portion of the state (Oregon Department of Agriculture, 2018). California subsequently followed suit, enacting SB 80 in 2020, which led to the development and approval of regulations for implementing evisceration orders in early 2025. When issued, a crab evisceration order allows some crab fishing to occur during DA events, but only if the product is eviscerated by a state–approved processor in accordance with specific registration, handling, record-keeping and other requirements (Hossain, 2025). To date, conditions have not warranted the use of evisceration orders in California.

Another measure being explored is the use of depuration—the process of purging contaminants, wastes and other impurities (e.g., sand) from live organisms. As with evisceration orders, depuration serves as a mitigative management measure for area closures, providing access to the fishery when it otherwise would be closed due to elevated DA levels in crab. Depuration systems are commonly used in bivalve (e.g., oyster, clam) aquaculture, and involve holding the animals in tanks with filtered, typically sterilized seawater and without food for several days to purge sand and excrement from the gut prior to sale. Such systems also have been used to purge excrement from live seafood including crab before shipping. However, depuration has not yet been used as a DA management measure, in part because its efficacy and feasibility for removing DA (and toxins more broadly) are not sufficiently determined. One key consideration based on work by Lund et al. (1997) is that feeding crab is essential for effectively depurating DA, thus requiring modification of depuration systems and adding to operating costs.

The 2015–16 DA event elevated awareness of DA in crab fisheries among California authorities, prompting unprecedented management action and re-examination of the state’s HAB event management approach. Based on test results, the California Department of Public Health (CDPH) and California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) recommended that commercial harvest of crab be halted (California Department of Fish and Wildlife (CDFW), 2020; Juhasz, 2020). CDFW delayed the start of the Dungeness crab fishery less than 2 weeks before the Fall 2015 opener. At the same time, after having been open for 5 months during the event, the year-round rock crab fishery was closed in two-thirds of the state. The rock crab fishery had never before been closed, despite a history of elevated DA levels in rock crab from various ‘hotspot’ areas.

Both crab fisheries remained closed for nearly 4 months, with some fishing areas, primarily those for rock crab, remaining closed several months longer (Figure 1). These actions, taken to protect public health, significantly disrupted the commercial crab fisheries, prompting a federal fishery disaster declaration and funding to offset losses to crab fishermen² and processors (including buyers/receivers). A small portion of funding was directed toward the research reported here, to assess the socioeconomic impacts of the fishery disaster and identify strategies for enhancing resilience to future disruptions. The importance of understanding and addressing the impacts and implications of DA management measures on fishing communities and the seafood system has since been reinforced by others (e.g., Moore et al., 2019, 2020; Ekstrom et al., 2020). Moore et al. (2020) noted that options for coping with the impacts of DA-related management on crab (Dungeness in particular) fisheries are limited and/or ineffective, with Free et al. (2022) suggesting a lack of resources and strategies available to fishing communities. These point to a need to reevaluate DA-related management of the state’s crab fisheries.

Figure 1

Here we explore the ‘blooming dilemma’ of how best to manage California’s commercial crab fisheries during DA events to minimize adverse impacts on access throughout the seafood system while protecting public health. Specifically, we ask: what are the impacts of current and potential DA management measures—area closures, evisceration orders, depuration requirements, and public health advisories/education—on access to California’s Dungeness and rock crab fisheries and seafood products throughout the supply chain, and what strategies could mitigate these impacts? We report on experienced and anticipated impacts particularly for those who catch (‘fishermen’), unload, process and distribute (‘seafood handlers’), sell to the public (‘retailers, food service providers’) and consume (‘consumers’) crab. Although also affected, we do not address ancillary parts of the seafood system—the people and businesses that provide goods and services that enable fishing and seafood production and distribution, such as fuel, ice, packaging, secondary processing—as these are beyond the present scope. We also investigated strategies to better mitigate those management measures’ impacts. Mitigation strategies are actions taken by fishermen, seafood handlers, fishing communities, resource managers and others, individually or collectively, to cope with disturbance to the fisheries system (Aguilera et al., 2018). Such strategies can be used to avoid, reduce or offset the adverse impacts of DA management measures on fishery and seafood systems. Given evidence that HAB events are becoming more frequent and are anticipated to increase in frequency with the changing climate (Moore, 2008; Van Dolah, 2000), this research is timely. And while the information presented here focuses on management of crab fisheries and DA-producing HABs in California, the results have implications beyond the state and these specific fisheries. Finally, we consider the role and suggest rethinking of the connection (or disconnect) between fishery management and food management paradigms to improve access to seafood while still addressing the perceived and real risks associated with consumption of DA-exposed seafood.

2 Methodology

2.1 The setting

California’s commercial fisheries for Dungeness and rock crab differ markedly from one another. The fishery for Dungeness crab (Metacarcinus magister) is seasonal and occurs almost exclusively north of Point Conception, with most landings occurring at ports in the San Francisco Bay and Eureka/Crescent City port areas. Fishermen unload their catch to dockside buyers or handle it themselves. More than half the catch is sold to seafood handlers for processing into a variety of product forms (e.g., cooked, sectioned, picked crabmeat). The remainder is handled and sold live by some of these buyers, other buyers, and some fishermen. Both overseas and domestic consumers have access to Dungeness crab through intrastate, interstate and international commerce.

The state’s commercial fishery for rock crab is open year-round and targets three species: red, yellow and brown rock crab, Cancer productus, Metacarcinus anthonyi, Romaleon antennarium, respectively. The fishery spans the California coast, with most landings typically occurring in the fishery’s southern region (south of Lopez Point in Monterey County) where Dungeness crab are markedly less abundant, and especially in the Santa Barbara port area where all three rock crab species occur. Fishermen unload their catch to dockside seafood buyers or handle it themselves, selling the catch live to California seafood buyers, restaurants and retailers, or directly to consumers via intrastate commerce. What little processing occurs focuses on a claw-only market.

2.2 Data collection and analysis

We evaluated the impacts and implications of three types of fishery management measures and one public health measure on access to California’s Dungeness and rock crab fisheries: (1) area closures/delayed openers (‘closures’), (2) evisceration orders, (3) depuration requirements, and (4) expanded public health advisories and education. To do this, we engaged theory and other prior knowledge early in the research process and creatively throughout, consistent with an abductive approach (Miles et al., 2018; van Hulst and Visser, 2025). Our iterative data collection and analysis included a mix of deductive and inductive logic (Yin, 2016), situated in our long-term (>30 years) marine natural and social science work to address the needs of fishery participants, communities, and decision-makers at multiple levels of governance (e.g., Carter et al., 2013; Culver et al., 2007, 2015; Pomeroy and Dalton, 2003; Pomeroy and Stevens, 2008; Pomeroy et al., 2010, 2020).

We used a combination of primary qualitative data sources—semi-structured interviews, informal conversations, participant observation—and secondary (qualitative and quantitative) data—peer reviewed and grey literature pertaining to the history and management of the two fisheries, commercial fishery landings, license and permit data, DA monitoring, and DA-related decision-making, and news stories. The majority of the research reported here was conducted from 2021 through 2024 under Human Subjects Research protocol HS-FY2021–13, approved by UCSC’s Institutional Review Board, along with a CDFW–UCSC data-sharing agreement for the use of the CDFW commercial fishery data.

We conducted semi-structured interviews with 20 fishermen and seafood handlers representing both fisheries across the geographic range affected by the 2015–16 DA event. Interview topics included individuals’ experience and knowledge related to the fishery and seafood production, the 2015–16 event and management actions, experienced and anticipated impacts of DA management measures, and options for mitigating those impacts in the future (see Supplementary materials). Interview participants were selected based on our cumulative knowledge of and experience working with fishery participants, community members and fishery managers coupled with analysis of commercial fishery landings, license and permit data. Key criteria for identifying and inviting individuals to participate in an interview included: (1) participation in the Dungeness crab and/or rock crab fisheries, (2) the location(s) of their California home port and landing/shoreside locations, (3) role(s) in the fishery, i.e., fishing, receiving, processing, or some combination of these, (4) types of crab products and markets.

To complement our targeted interviews, we also collected information through focused conversations with agency staff and port managers. These conversations focused on descriptions of how management decisions were made, experience related to and observations of the fisheries prior to, during, and since the 2015–16 event, and reflections on fishery and public health decision-making, impacts and implications for the fisheries, seafood supply and access going forward. In addition, we participated in and observed fishery-related meetings and other activities during the study and before and since. This included serving as a non-voting member and advisor representing California Sea Grant on the state’s Dungeness Crab Task Force and multiple site visits for this and other research projects. We used gray and refereed literature and other secondary sources to better understand other key environmental, regulatory and socioeconomic factors that have affected the fisheries in recent years, interacting with the focal DA event of 2015–16 and providing important context. In addition, we used the commercial fishery landings data to generate summaries of spatial and temporal patterns of participation in the crab and other fisheries within the state by those with Dungeness and/or rock crab fishery permits and the various types of fish business licenses. We used the resulting information to contextualize interview and observation data and help inform and evaluate our efforts to ensure coverage of a range of fishing and fish business operations.

Together these efforts provided a well-balanced approach for gathering data from a portion of the seafood supply system. However, it did not enable a full investigation of the seafood supply system beyond the range of seafood handlers, although we interviewed and engaged with some individuals involved in seafood handling through retail sales to consumers. Thus, information about the other seafood system sectors—specifically retailers, food service providers, and consumers—is based primarily on project participants’ reported experiences interfacing with these groups. Our approach also did not include systematic input from fishery participants south of Santa Barbara County, as this area was not directly impacted by the 2015–16 DA event and historically has experienced few DA events.

We used NVivo qualitative data analysis software to code interview transcripts as a foundation for thematic analyses to determine the social and economic impacts and implications of the fishery disaster and management measures, identify and evaluate mitigation strategies, and document concerns and ideas for the future. Thematic analysis afforded a flexible method for identifying patterns within and across our data to better understand the experiences and perspectives of study participants (Clarke and Braun, 2017; Braun and Clarke, 2022). We developed a preliminary codebook scheme based on initial project themes (per research objectives), refining and adding to it to enable the capture of new categories of information as the research progressed (Miles et al., 2018). From the codes and coded data, we identified emergent themes, such as practical and logistical considerations and power dynamics influencing impacts, ability to adopt practices to enable participation in the Dungeness and/or rock crab fisheries and food systems under various management measures, and access to the fishery, markets and products. The majority of the coding was done by a single person in close consultation with the principal investigator. We then used thematic analysis to identify patterns, commonalities and differences within and between the two fisheries and associated seafood systems as they pertain to access.

3 Results

We identified a range of realized and anticipated impacts and implications of DA management measures for the two crab fisheries and associated seafood systems (Table 1). Each management option had affected or was expected to affect the timing and location of fishing, handling and distribution of crab, and access to it throughout the seafood supply system. We found that maintaining seafood access for the defined groups would require fishing or obtaining crab from areas that remained open, as well as substantially adjusting their fishing, handling, selling and/or buying practices to provide or obtain eviscerated or depurated crab when those management measures were in place. Overall, most of those we interviewed—and others engaged during and since the 2015–16 event—expressed skepticism and/or concern about the feasibility and impacts of the various measures. A central theme in these conversations was what has been or would be required, in terms of resources and capacities, for each group in the seafood system to access crab under each management measure (Table 2).

3.1 Impacts on access

3.1.1 Area closures

Area closures directly and indirectly affected access throughout the seafood system, from fishermen’s access to fishing opportunities and markets, to seafood handlers’ access to the catch and markets, and retailers’, food service providers’ and consumers’ access to crab.

Fishermen: Area closures directly eliminated fishermen’s access to fishing opportunities for nearly 4 months and in some cases longer, depending on when an area was re-opened (Figure 1). The closure was immediate, requiring all rock crab fishing north of Ventura County, California to the Oregon border (roughly two-thirds of the state) to stop immediately. For both fisheries, the abrupt and unexpected closures occurred shortly before the winter holiday season, with no time to prepare and no certainty about when and where the fisheries would reopen. As one interviewee said, “I mean, fishermen were scrambling. All these guys that I helped train in fishing and worked with them for years, they were coming and going, ‘What do we do? That (fishing area) has domoic acid.”

The degree to which fishermen were impacted depended on their ability to shift their fishing operations to open areas. Whereas some rock crab fishermen with a Southern Rock Crab permit were able to access fishing opportunities south of the closed areas, those with a Northern Rock Crab permit and/or Dungeness Crab permit did not have access. Although both fisheries previously had experienced short-term disruptions due to poor weather and, in Dungeness crab, insufficient meat fill and price disputes, the extended closures had lasting impacts. Some captains and crew moved elsewhere to fish or took on shore-based work to maintain employment and income, while others collected unemployment insurance. As one crabber noted, “I did construction. I worked two jobs, one in the daytime at a shopping center doing construction, and I worked for the same contractor at night at a [different] building.”

However, the majority waited out the closure, not knowing how long it might be. As one fisherman explained to us, “It was more just, sit and wait for the date to go.” The foregone revenue impacted participants’ ability to cover fixed costs such as vessel payments, insurance and slip fees, along with their ability to pay and keep their crew:

Many crew were able to go on unemployment, at least for a time. Many other fishing operations have lost their crew. There’s the economic impact of gearing up, for example, in terms of gear preparation and planning for the season. There’s a financial outlay at that time and no income coming in.

Even as the fisheries began to re-open, these changes had long-lasting impacts on fishing operations.

[My] other crew member was an old crew member that I had for a long time that went back to Florida to be a construction worker, and he never flew [back] out. … I was going to fly him out to work for a month, and when it wasn’t happening, he never came and he had another job.

When the first area re-opened, there were expectations that other areas would soon follow. However, some areas remained closed for more than 8 months, and fishermen were prohibited from transiting closed areas with crab on board. As a result, only local fishermen and out-of-area fishermen able to move locations (often a significant distance from their home port) regained access to the fishery. For example, some fishermen from the Fort Bragg area in Northern California travelled to the San Francisco Bay area in Central California, which opened first, and were able to access the fishery. While mobility is common among larger fishing vessels and larger buyers in the Dungeness crab fishery (subject to the “fair start” rule³), it is not in the rock crab fishery. In addition, inflexible fisherman–buyer relationships prevented some fishermen who had moved to an open area from being able to sell their catch at a port within that area. Moreover, uncertainty about how long an area would remain closed complicated decisions to “wait it out” or move to an open area. Nonetheless, mobile fishermen tended to move to newly re-opened areas, at times resulting in conflict over access to fishing grounds with local fishermen who had waited for “their” area to re-open.

Seafood handlers: Shoreside seafood handlers likewise faced marked changes in access to crab caught by California fishermen and had to adjust. Dungeness crab handlers, especially those in the fishery’s Northern Management Area (NMA, Oregon border to the Sonoma–Mendocino county line), were somewhat better able to cope with the delays initially, as they had previously experienced delays of up to 8 weeks when crab had insufficient meat fill and thus were ill-suited to the market.⁴ Fishery-wide, seafood handlers as well as fishermen also had experienced shorter delays due to opening price disputes. In contrast, for the rock crab fishery, the impacts on seafood handlers were severe, as the supply of crab stopped abruptly when the closure order was issued. As one seafood handler who operated in both open and closed areas noted,

It was a blockade out of those zones. We were going, “oh shit.” And then we started losing markets. Luckily our Filipino market saved us. … Because our retail markets were 75% [of our business], and … only 25% of those markets were accepting [crab we were landing and selling]. So the other 50% of [those] markets were not available to us. I mean, we were eating it bad.

For larger businesses with operations in more than one location, the disruptions affected their facilities and associated staff within closed areas, but they could continue to receive crab and supply their customers through offloading facilities located in open areas. Others were able to contract with seafood handlers in open areas or use public offloading sites—although the availability of these varies among California ports. (See, e.g., Culver et al., 2007; Pomeroy et al., 2010; Speir et al. 2010, 2014). Overall, however, the closures affected these businesses in a variety of ways, with one buyer noting: “I laid off some of my dock workers that I could not afford to keep because we did not have that many boats fishing, and there just wasn’t enough to keep everybody working. And I take huge strides to not lay people off.” And as one fisherman noted, “For me, the buyers were greatly affected because they had no product until, you know, late in the spring. I do not know how they dealt with it. Not well. I know that some of the buyers were really struggling.”

Some seafood handlers were able to access crab from unaffected areas—south of the Santa Barbara–Ventura county line for rock crab and, for Dungeness crab, select areas off Oregon and Washington not experiencing concurrent DA closures. However, fishermen who sell some or all of their catch directly to retailers, food service or consumers in areas that were closed were doubly affected by the loss of access to the fishery and their inability to serve their local clientele.

Notably, the timing of the closures precluded access to winter holiday season markets, especially for Dungeness crab. Historically, the Dungeness crab fishery’s season openers afforded fishermen and seafood handlers access to lucrative, high-demand holiday markets for live and fresh cooked products. These products also were sold or donated to local groups hosting celebratory and/or fund-raising crab feeds. As one fisherman noted:

The later [in the season] you open, the harder it is to move live and fresh cooked product. Latter January, early February, there are crab feeds. Chinese New Year is a live market exclusively. But after that there isn’t a lot of demand for live or fresh cooked crab.

Retailers, food service providers and consumers: Area closures thus affected retailers’, food service providers’ and consumers’ access to crab during the winter holidays and beyond. Although they continued to have access to rock crab caught and landed at ports south of the closures, those located in areas where the fishery was closed lost access to local product. In the case of Dungeness crab, both in-state and international customers lost access not only to California crab products but also those from Oregon and Washington, which likewise had closed their fisheries due to elevated DA levels. Over time, as the California closures continued, some obtained frozen California product from the previous season or fresh product from areas of Oregon or Washington that opened sooner.

The closures during the holiday season contributed to increased consumer uncertainty about where and when to purchase ‘safe’ crab—or whether any of it was safe to eat.

Everyone was waiting for their Christmas crab or New Year's crab and all of a sudden, they hear they can't have it and they go, “Oh no!” and everyone's upset. Devastated. It's tradition—for 20 or 30 years—in their family. But then it came out in the news that it's because of domoic acid.

The closures also raised consumer awareness of DA and questions about the safety of crab products even after the fisheries reopened. Nonetheless, study participants reported that the impact on consumer confidence was not long-lasting, as people began buying crab as it became available.

3.1.2 Evisceration

Project participants expressed concerns about how evisceration orders could affect access to the fishery, the catch, and resulting products if and when implemented (Table 1), based on the anticipated requirements for participating in evisceration (Table 2).

Fishermen: For fishermen, dependence on crab sampling and testing along with access to a buyer, were at the forefront. Sampling and testing—with two consecutive negative results—would be needed to enable lifting the order. Testing aside, fishermen noted that access to fishing opportunities and markets would depend on whether they have access to a processor authorized to eviscerate crab. This was a concern for fishermen and seafood businesses that sell live or whole cooked crab direct to the public as well. With the vast majority of rock crab sold live and a small proportion cooked (whole or claws only), they said that such opportunities were limited. With considerably more processing capacity in the Dungeness crab fishery, at least some fishermen would be able to access the fishery and those buyers. However, several interviewees—both fishermen and seafood handlers—noted that an evisceration order would favor those fishermen and the few buyers with such capacities, redistributing access to the fishery, and leading to further consolidation and dominance by those buyers. Some said that they expected that added costs would largely be borne by fishermen.

There's just a few big companies that actually can eviscerate the crab and it basically closes down all the mom-and-pop shops across the board… I think that could probably be the worst thing that ever happens to the West Coast … [Those big companies] could manipulate the price, they can manipulate the quantity… you'd just see all these little coastal towns get eaten up by the big conglomerates of the crab industry.

Seafood handlers: Seafood buyers and handlers additionally indicated that nearly all rock crab handlers and most Dungeness crab handlers in California lack or have very limited capacity—space, infrastructure, trained personnel and required permits and plans—to eviscerate crab as required by state regulations. This is particularly the case for businesses that unload crab from fishermen at the docks to sell it live or cooked whole to restaurants and retailers or via their own retail outlets. Due to the short shelf life of crab meat once the animal is dead (e.g., following evisceration), handlers would need to cook or freeze the crab, in turn requiring water, waste disposal and cold storage, further adding to their costs. Shoreside handlers unable to eviscerate were concerned that they would be faced with becoming beholden to businesses that are able to, and losing access to fishermen with crab and to their customers. Some crab handlers with the capacity to eviscerate also would face access issues, as they too handle some product live or whole cooked and would not be able to meet demand for those products. They expected, too, that handling more crab for evisceration than they typically do – and potentially at different times during the season, would require additional time, with attendant costs. For businesses that handle other seafood products (e.g., groundfish, shrimp, salmon) as part of an annual round of activities, setting up and maintaining evisceration facilities and allocating staff time to evisceration was expected to be impractical. Still one seafood handler felt it could be a good option because they could control the safety of the product: “You can sell a product that you know you have processed and eviscerated and it’s [safe]. The last thing you’d ever want to do is make somebody sick.”

Fishermen and handlers both expected that evisceration orders would be infrequent and brief—no more than a few weeks at a time. While this could be advantageous in providing some access, one buyer pointed out that setting up and then breaking down an evisceration operation (where not already in place) would be costly. As a result, such businesses expected to lose access to their market at least temporarily. However, one small vertically integrated seafood handler reported that they would be well equipped to handle crab under an evisceration order, noting that they only buy from one to two smaller crab fishing operations, and they already produce and have customers who purchase a variety of crab products.

Retailers, food service providers and consumers: Given the constraints on fishing and handling under evisceration orders, retailers, food service providers and consumers are expected to have limited access to crab, in fewer product forms, and potentially at higher prices, depending on how additional handling costs are covered by processors. Some interviewees noted that for some consumers, especially those of East Asian heritage (e.g., Chinese, Korean, Taiwanese), eviscerated crab is not an acceptable substitute for live or whole crab.

3.1.3 Depuration

Overall, study participants indicated that depuration, if developed and offered as a management measure, would be impractical and costly (Table 2), requiring additional investment in feed, depuration systems, and repeated testing to determine when DA in live crab and/or products has fallen below the alert level, and is approved to move through the food system. With depuration, fishermen’s access to fishing opportunities likewise hinges on access to a buyer with the capacity to handle the catch. Buyers would need the space, infrastructure, personnel, and equipment to hold and feed crab in live tanks with reliable (DA-free) water and aeration for weeks at a time, along with water and waste disposal capacities. In addition, they expressed concern that consumers would perceive the product to be unsafe for consumption, regardless of test results indicating acceptable or non-detectable DA levels.

I don't know if [depuration] could work. Maybe on a really small scale. I don't know how long it would take for levels to come down. You would have high mortality. No one has the capacity to hold them. That would be quite a monetary risk. Crabs do go after one another in the tank. They bite each other. You can keep them cold so they’re more dormant, but still… I don’t think it would be practical on any scale similar to my business.

For retailers, food service providers and consumers—especially those who favor live or whole crab—depuration could provide access. Wholesale and retail prices likely would increase to reflect the additional costs associated with the depuration process, increased uncertainty of when crab would be available for purchase, and less product availability due to space and other capacity limitations for holding live product.

3.1.4 Advisories and education

In general, public health advisories and broader public education about DA do not directly affect access to the crab fisheries and seafood products for fishermen, seafood handlers, retail and food service, or consumers. However, some study participants highlighted nuances that have implications for access. For example, some noted that messaging about potential risks of consuming crab with elevated DA levels can lead to reduced consumer demand by raising concern about the product overall rather than encouraging consumption following safe handling. This can lead to seafood handlers’ reduced access to consumers and in turn, fishermen losing access to a buyer for their catch. It could affect seafood sales more broadly: “[Consumers] tend to paint everything with that broad brush in the sense of, they hear an advisory about domoic acid in crabs but they equate that to maybe all seafood … and people do that.” On the other hand, one interviewee noted, “I think people are receptive towards [advisories and education] for sure, rather than just not being able to get [crab] or eat it.”

None of those we spoke with mentioned a loss of consumer confidence and/or purchasing due to advisories issued by CDPH. Rather, they stated that area closures had—and evisceration orders and depuration requirements likely would—lead consumers to question the safety of the product. To mitigate this effect, they highlighted the importance of providing the public with accurate species-specific information about the risks of DA exposure and how to minimize them when preparing and consuming crab. One fisherman described developing a label to help educate customers on how to prepare crab during blooms in the mid 1990s and then worked with buyers to distribute it:

We made a form [with others] and the help of one of my buyers … in 10 different languages, so we took and put labels on the tanks in all our Asian stores and they would read it…So we said, okay, what we'll do is we'll just place it not on the tanks, [but] in the seafood window and let the seafood manager tell them, ‘Read first before you pay me.’ … It just says, don't eat the viscera.

More broadly, crab fishermen expressed that they clearly understand the health risks of consuming high levels of DA. However, several—particularly rock crab fishermen—also noted that crab had been sold during previous DA events and no deaths or illnesses had been tied to consumption of crab even at times when blooms were more intense than the 2015–16 event. Further, prior to the 2015–16 event, when crabs had been found to contain DA at levels exceeding the FDA action level, recreational crab fisheries in California remained open under a health advisory with no reports of illness or death from crab consumption.⁵ Some mentioned that while they understand that DA poisoning is hard for medical providers to distinguish from some other illnesses and it therefore may have gone unreported, the lack of a “major outbreak” associated with previous DA events and particular markets led many to question the risk to consumers from consuming crab with elevated DA levels. One fisherman commented, “… In all reality, I’m sure domoic acid has been around long before we [knew]. And I get it. I mean, you do not want [anyone] to get sick, but I think there’s a possibility that we are making a bigger deal out of it than it is.”

Some also noted that actions taken to address DA in crab have been similar to measures used to protect consumers from DA in bivalves (e.g., oysters, clams, mussels) and small filter-feeding fish (e.g., anchovies, sardines) despite key differences in how they are prepared and eaten. Many fishermen have questioned whether the sampling and testing methods accurately measure DA levels that consumers are exposed to from cooked crab. The approved FDA analysis methods used in California require each crab be wrapped in foil prior to boiling to minimize cross-contamination and enable analysis of DA in individual crabs. However, this added step has raised questions among fishery participants and others as to whether DA is being inadvertently retained in the sample crabs when it would otherwise be released into water. If this were the case, the sample analyses may be indicating a higher level of DA and thus a higher risk of exposure than would occur when crab is cooked (and the liquid is discarded) by consumers. An alternative view expressed by some focused on how public education to “normalize” evisceration and eviscerated products could help re-orient consumer expectations (as well as protect health), mitigating potential losses of market and consumer access to product.

3.2 Mitigation strategies

Study participants identified a number of strategies for reducing or offsetting the experienced and anticipated impacts of the various management measures (Table 3). These mitigation strategies ranged from addressing the uncertainty about the location, occurrence and duration of HAB events to improving opportunities to fish for crab or other species, to developing financial support options to address lost income. As participants noted, these strategies vary in their feasibility, practicality and implications for access.

3.2.1 DA testing and communications

Some study participants suggested enhanced DA testing and communication as ways to at least partially address the uncertainty about HAB events. As one Dungeness crab fisherman noted, DA in crab is markedly different from other sources of variability and uncertainty they are used to dealing with. The presence of whales and crab “quality” (meat fill) are readily observed and processes for monitoring, communicating, and taking management action are well established. By contrast, toxins are unpredictable and largely invisible, and several interviewees said that decision-making has not been transparent. Increased testing for DA entails increased costs for the fishermen (time, fuel, foregone revenue from other fisheries) who collect and provide crab samples to CDPH for DA analysis in order for a closed area to be considered for opening. Increased sampling, in turn, requires coordination among—and associated costs for—fishermen and the state agencies. Testing itself is costly ($100 per crab) and the state has limited budget and capacity (one lab) to carry out the required analyses and report results in a timely manner, potentially further delaying access to the fishery. Not all fishermen support the testing process, and pressure to not provide samples for testing was evident in some places, with negative impacts on the wellbeing of those participating in testing in those areas. Some fishermen also expressed concern about testing potentially leading to more frequent or widespread action to close or limit the fisheries.

3.2.2 Markets and Infrastructure

To help mitigate the, participants identified three potential strategies. First, they suggested research and development of new and expanded markets for eviscerated crab to help offset the loss of live crab markets, mindful of the increased costs and the likelihood that they along with consumers would bear these costs.

You can't process live crab without a permit, a building, hot water, a FDA (Hazard Analysis Critical Control Point, HACCP) plan. There’s not an alternative to live crab or live lobster. Markets (available) to process crustaceans, shrimp etc. are limited. If you have to cook, remove viscera… it's not cost-effective. Only a few customers would buy it. It would only be (HACCP-approved and equipped) seafood markets (that could do this). The rock crab—the rock crab fishermen—would go to Dungeness crab processors, but their markets are limited, too, because everybody, especially in the Asian communities, want full live animals.

Markets are limited for processed crustaceans—Asians and others want live crab; cooking and/or flash freezing is expensive, so you have to increase the price for something that has a limited market.

Second, they expressed interest in accessible infrastructure and training to enable fishermen and seafood handlers to provide eviscerated crab to consumers. Third, some suggested that the state (as well as the fishing community) enhance communication with consumers, to help them better understand the efficacy of eviscerating crab and encourage consumer confidence.

3.2.3 Permit/regulatory flexibility

Some suggested allowing permit flexibility to enable participation in other fisheries at times and locations not otherwise allowed to generate revenue, maintain their fishing operations, and minimize the disruption to ports and fishery-support businesses that depend on fishery activity. A fisherman permitted to participate in both crab fisheries noted:

For example, you can't fish rock crab 30 days before you fish Dungeness if you want to fish Dungeness for the first 30 days. Does that make sense? But now we don't know when Dungeness can open, so you have to stop fishing rock crab for who knows how long, right? Because you don't want to miss out on that Dungeness opener, but you still want to make a living. But you can't do it because you can't fish it 30 days before the opening. But they don't give us a 30-day notice, right? And we don't really want 30 days. And that's because we want to get out there as soon as possible.

Another idea discussed was access to “emergency” permits for other fisheries, set aside for pre-qualified fishermen, although it was noted that this would not necessarily help shoreside crab handlers, especially those with limited capacity to handle and/or access customers for alternative species. Allowing permitted (rock crab) fishermen and (Dungeness crab) vessels to temporarily participate in other fisheries would generate and distribute revenue throughout the seafood system as well as wharfage (to the ports that collect it). However, as some noted, shifting effort into alternative fisheries requires appropriate equipment, knowledge and market access, and can adversely affect those already permitted to participate in those fisheries.

3.2.4 Financial support and insurance

Study participants also identified mitigation strategies to address the impacts of lost revenue to fishermen, handlers and fishery-support businesses. Federal disaster relief funds helped fishermen and seafood handlers (i.e., first receivers of the catch but not others in the seafood supply system) cope with some of their losses, although as CDFW leadership noted, “could not make them whole.” Those funds represented only a fraction of what was lost, and were slow to arrive, with Congressional appropriation not occurring until three legislative sessions later and funds reaching fishery participants in late 2019, 4 years after the fishery closures were implemented (Marshak, 2020). To address this critical gap, study participants suggested establishing a dedicated fund for direct reimbursements and relief, with revenues from local or regional assessments for goods and services provided to seafood consumers (e.g., seafood restaurants, hotels). Some suggested fishery insurance, similar to crop insurance, which has garnered interest within and beyond the state (US GAO, 2025; Waite and Linsmayer, 2025; Herrmann et al., 2004). Participants also provided suggestions about ways to indirectly compensate their losses either financially or through enhanced opportunities to generate revenue. Fishermen highlighted the potential deferral or reduction of slip fees, as the Sonoma County Board of Supervisors did for both local and out-of-town fishermen at Bodega Bay at the request of the local fishermen’s association.

4 Discussion

Maintaining access to US fisheries and seafood while protecting human health during DA events is a critical balancing act that, until this study, has lacked attention to the critical connections between the fishery and food systems. Our research highlights a need to improve the connection between the current fishery resource management and food system paradigms and how they relate to one another, as suggested by Olson et al. (2014) for fisheries more broadly (see also Love et al., 2017; Lowitt et al., 2019). Doing so would provide a way to better address the impacts and implications of public health and resource management responses to HABs. Under a revised ‘fish as food’ management paradigm, current management measures likely still have a place in managing risk associated with crab consumption, but they would be accompanied by measures that address the impacts on the food system as indicated by our research results. As others have suggested, integrating mitigation strategies that provide resources, compensation, and increased opportunities for fishing communities to cope with and adapt to HAB events is needed (Moore et al., 2020; Free et al., 2022). Such strategies must be coordinated across the fishery management and food management systems to account for and more fully address the access issues highlighted here while still protecting human health.

As evidenced by our study and others (e.g., Ekstrom et al., 2020; Jardine et al., 2020), managing HABs through the use of area closures, the primary fishery management measure used in California, can have crippling economic, social and cultural impacts throughout the system. Area closures eliminate access to fishing in closed areas, which subsequently precludes seafood from entering and moving through the food system, directly impacting those who participate in or rely on it. Short- and long-term impacts are greatly influenced by the lead time, timing and duration of closures. Notably, access to rock crab during the 2015–16 event could have been even more limited and the losses more significant had the closure been authorized when elevated DA levels in crab were first detected in California. Although CDPH issued a warning in early June advising against consuming crab viscera, it wasn’t until early November, 6 months later and shortly before the opening of Dungeness crab season, that the bloom was fully recognized and management action to close the fisheries was taken. The continued access to rock crab during that interim period was typical of how previous DA events, some more intense than the 2015–16 one, had been managed. As such, the sudden closure of the fishery was unexpected and particularly disruptive to the rock crab seafood system. This experience highlights the need to improve—and enhance the transparency of—the processes for evaluating DA conditions, taking management action, and communicating proactively. Ekstrom et al. (2020) note that in Washington state, transparency, consistent with a history of trusting relationships and coordination among agencies and with the fishing industry, contributed to greater acceptance of DA-related management action compared to California. These improvements, some of which have been made in the aftermath of the 2015–16 event, would better enable fishermen, seafood businesses and others in the state to adjust their plans to minimize adverse impacts on access.

The area closures implemented in 2015–16 resulted in unintended consequences that have had lasting impacts on access to seafood for fishery participants and consumers alike. By delaying the opener and then permitting a few areas to open at a time, fishing was concentrated into areas where and when whales were migrating, exacerbating the emerging issue of whale entanglements in fishing gear (Santora et al., 2020). Every season since, California’s Dungeness crab season has been delayed to minimize the risk of whale entanglements, with the fishery not opening until after the holiday season when fishing effort and sales typically had been the strongest. The fishery also has faced early closures of about 3 months to reduce whale entanglement risk, amplifying the access issues stemming from DA management. This loss of access to the fishery has been mitigated some with CDFW’s March 2026 authorization of “pop-up” gear use from April through the end of the season in some areas that otherwise would be closed (California Fish and Game Commission, 2026).

Likewise, the state has refined the designation and use of area closures for HAB management since the 2015–16 event, although some of these actions can result in lost access to California seafood during HAB events. For example, prior to 2020, including during the 2015–16 HAB event, areas for management action typically were differentiated for coastal fishing grounds on a county-by-county basis for the state’s 15 coastal counties and relative to offshore islands (California Ocean Science Trust, 2016). Since 2020, the state has used a refined set of eight biotoxin management areas (BMAs) (covering more than 1,350 km of mainland coast), with one to four designated testing sites each for DA monitoring and decision-making for the two crab fisheries. Many of the new BMAs cover two counties rather than one, thereby increasing the area affected by a given management action. The southernmost BMA (BMA H) extends 605 km from Lopez Point in Monterey County south to the Mexican border, with a single testing site located in the northern quarter of the BMA. Moreover, this BMA coincides with the entirety of the area covered by the Southern Rock Crab fishery permit. By comparison, following changes made in response to the 2015–16 event, Oregon has 12 BMAs and monitoring sites (covering about 461 km) and Washington has four coastal BMAs and monitoring sites (covering about 250 km) (Free et al., 2022).

Increased testing may facilitate the use of area closures on smaller spatial scales, thereby increasing access opportunities during more localized HAB events (Carter et al., 2013). Conversely, as noted by Free et al. (2022) and some interviewees for this study, increased testing could lead to increased closures and further complicate access to the fishery. This outcome seems likely as many blooms undoubtedly have gone undetected, particularly in offshore areas where sampling is virtually nonexistent (Carter et al., 2013). Integrating offshore as well as benthic sampling may further improve detection, especially as these are areas where DA accumulates on the ocean floor, providing a prolonged source of toxin for crab and other bottom dwelling organisms after a bloom has dissipated (Sekula-Wood et al., 2009; Smith et al., 2021). Sampling logistics aside, the required testing and the capacity to conduct it remain major challenges in California. Currently testing can only be done at a single CDPH facility, which oversees testing of a wide range of products including dairy and baby food products, olive oils, candy and more. County environmental health departments have at times provided seafood-testing services, but they are not certified to do so for state regulatory purposes. Moreover, DA testing is expensive and time-consuming, further impacting CDPH’s limited budget and staff. Who pays for testing and when and how often it is done are important considerations especially as animals must be sacrificed to assess DA levels. Increasing capacity through certification of additional labs requires additional funding for services that are only needed sporadically. At present, testing of Dungeness crab is only required about a month before the November season opener, with repeated testing one to 2 weeks later only if initial test results exceed the action level (CDFW, 2020; Juhasz, 2020). Rock crab testing is done only if a HAB is detected in water and/or in bivalve samples that are more routinely taken throughout the state.⁶ Evaluating other states’ (especially Oregon and Washington’s) sampling protocols and those used for other foods with health risks that likewise can be virtually eliminated through proper handling could be beneficial for identifying a cost-effective and efficient way to monitor for DA.

The crab fishery closures in California highlighted the need to identify alternative management options to help mitigate their adverse impacts by providing conditional access to crab fishing. The state has since adopted regulations to allow the use of evisceration orders to enable areas to be opened under certain conditions during HAB events. However, evisceration orders are problematic because they redistribute and limit access to the fishery to those with (or with access to) the necessary skills and support to become authorized to eviscerate crab, in effect controlling fishermen’s access to buyers and the markets they supply. As a result, fishing communities in areas where little or no processing capacity currently exists in particular, would be hindered. In comparison, the few HACCP-approved crab processors in California with existing facilities, staff, and handling procedures would have a clear advantage. Seafood handlers and those who have developed direct-to-consumer markets would be impacted unless a process were developed to enable them to eviscerate at or before moving crab to their market site (e.g., fishermen’s markets, farmers markets). Setting up an evisceration certification program tailored to these types of operations coupled with financial support for required infrastructure would help address the current imbalance of access to crab among fishermen and seafood businesses during HABs.

Yet access to fishing under an evisceration order may be tempered by the markets, as not all consumers are willing to purchase eviscerated crab. For both rock crab and to a considerable extent Dungeness crab, consumers of many cultural backgrounds prefer (and in some cases only will buy) live crab, valuing it as a high quality and culturally important product. If consumers are unwilling to purchase eviscerated crab even in the absence of live crab, fishermen and buyers may lose access to some markets. Perhaps more significant is the potential impact of evisceration orders on consumer confidence. For Dungeness crab, the availability and marketing of processed as well as live product suggests that a shift to eviscerated product may be somewhat more acceptable to consumers than is the case for rock crab—although (Abken and Jardine, 2027) found that evisceration substantially eroded ex-vessel prices (the amount paid to fishermen) for Dungeness crab in Washington. Research on consumer knowledge, awareness, preferences, and crab handling practices is needed to further elucidate the impacts of crab evisceration on market demand and consumer confidence for both species. Investigations of food product modifications analogous to evisceration, how they have been managed, and how they have been received by consumers could provide useful insights as well.

Development of new markets for eviscerated crab regardless of whether a bloom is occurring also may help increase consumer acceptance and confidence. One smaller California retail seafood business, for example, now offers “live cleaned”—that is, eviscerated—crab that is held alive, then cleaned (eviscerated) on site when purchased. This approach is akin to how live fish is handled at some markets, from dockside markets to specialty grocery stores. As such, it may appeal to those wanting to see the live product before purchasing it and then receiving a ready-to-cook product, with the evisceration step taken care of by the vendor. It may help normalize eviscerated crab for consumers, as an interviewee suggested. Value-added products for rock crab like fresh or cooked, frozen and cleaned (eviscerated) crab sections or clusters, as is done with some Dungeness crab, may also provide opportunities to ‘normalize’ eviscerated crab. These strategies present opportunities to reframe the marketing narrative as one where evisceration reduces the time and tasks required of consumers while also addressing issues of potential exposure under HAB conditions.

Similar to evisceration, depuration as a management measure is anticipated to limit access to crab throughout the seafood system due to the costs and logistics of establishing, maintaining and operating a depuration system. Depurating DA from crabs requires larger and more complex holding facilities than for bivalves, as crabs are larger and more aggressive (particularly rock crabs) and they must feed on animal matter in order to depurate the DA toxin (Lund et al., 1997). Moreover, the efficacy of this management measure is questionable. Whereas purging waste (consumed food) from bivalves and crabs requires a day or two in a depuration system, purging a toxin (DA) takes weeks to months and depends on the initial DA level in the animal and feeding regimes used. Research on methods for increasing the excretion rate of DA from crabs, thereby decreasing the time required for depuration, is ongoing. Based on conversations with fishery participants, it is likely this process would have to take less than 10 days to be economically feasible. Should a shortened timeline prove feasible, an assessment of opportunities and costs of partnering with aquaculturists who have seawater tank systems and the skills for holding and testing marine organisms, similar to current purple sea urchin ranching in California and elsewhere, may help to address some of the infrastructure and personnel needs.

Various mitigation strategies may offer ways to avoid, reduce or offset the adverse impacts of DA management measures on fishery and seafood access. For example, increased testing may provide opportunities to minimize loss of access especially for blooms that occur on a small spatial scale, but as discussed above, it also could lead to more frequent closures along with increased costs and logistical challenges. Another example is the development of state and local government provisions for waiving or deferring permit, slip and shoreside lease-related fees, and other fishery-related costs, as Sonoma County did in this instance with slip fees at Bodega Bay. In a study by Moore et al. (2020), participants indicated that tax relief would be helpful. However, these and other concessions are not cost-free to those public or private entities that provide them.

Fishery insurance, structured by fishery, statewide or nationwide, has been suggested as a more timely mechanism for responding to and helping offset the impacts of HABs (Watson et al., 2023; Waite and Linsmayer, 2025). However, a funding source would be needed to establish and maintain such a program. Moreover, it is not clear whether and how it would complement or replace the current federal fishery disaster assistance program, which is used by affected states and fisheries to obtain federal relief funds through a special congressionally-approved appropriation. Although the State of California requested and received federal fishery disaster relief funds, which eventually were distributed among crab fishery permitholders and fish businesses impacted by the 2015–16 event, the program is not a reliable, long-term solution for offsetting the impacts of HABs and other events that are of highly variable duration. In addition, it is based only on direct revenue losses to fishing operations and fish businesses that purchase their catch, and provides only partial compensation for losses—and typically not for resulting job losses (Moore et al., 2024). Moreover, it relies on ad hoc Congressional appropriation of funds (US GAO, 2025) in response to timely action by NOAA staff, whose numbers have been cut significantly since early 2025, and the Secretary of Commerce.

Notably, a portion of disaster relief funds may be used to fund projects that improve resiliency in the affected fishery and mitigate the effects of future events (US Congress, 2022). Whereas the funds set aside for this purpose have been used for scientific research (including the work reported here), as our study highlights, they may be well spent on infrastructure and training to support broader engagement of fishery participants in evisceration, development of new markets for eviscerated crab, and enhanced public education focused on safe handling.

Permit flexibility has some potential to facilitate access to crab fishing opportunities when DA management measures are in place, provided some areas remain open (see, e.g., Miller and Munro, 2004; MacNeil et al., 2010; Chavez et al., 2017). This may be feasible for the rock crab fishery, which has two geographically-specific permits for Northern and Southern rock crab fishery participants. Northern Rock Crab permits are unrestricted, so that any licensed fisherman may acquire one, whereas Southern Rock Crab permits are restricted, and can only be acquired by state-approved transfer. Flexibility to allow permitted fishermen to move between the two rock crab fishery regions could help mitigate loss of access to the fishery. However, this option would not be useful for rock crab fishermen unable to secure a market or seafood handlers unable to receive the catch from fishermen who shift the location of their fishing operations. Within-fishery permit flexibility is moot for the Dungeness crab fishery, as permit holders are already allowed to operate throughout the fishery’s range, except as temporarily limited by the fishery’s fair start rules.

Beyond permit flexibility within crab fisheries, permit flexibility to allow temporary access to other fisheries has been suggested as a way to enable fishermen to adapt to shifts in species availability more broadly (Morrison and Termini, 2016) or other access challenges (Chavez et al., 2017), and could be a useful mitigation strategy for managing HABs and fisheries. With the loss of access to the live market, fishermen and seafood handlers could shift into other fisheries or markets (e.g., Smith et al., 2022) as possible. Chavez et al. (2017) note, however, that flexible permitting can pose risks including excessive effort and market saturation in the fishery crabbers move into, and entails information, equipment and operating costs along with the time and resources required to change and implement the policy.

A management option that remains a topic of debate is whether intensive public education could be used to manage risk of consumer exposure to DA during HAB events. Even though federal law prohibits the commercial sale of contaminated food, public education has been used to promote safe food handling practices by consumers in general and specifically to address concerns about biotoxins in crustacean viscera. Hence, some believe this should be done for DA and crabs (and other species) in a manner similar to that used for other episodic foodborne contaminants (e.g., salmonella) that are associated with food poisoning—and that have been highly publicized in the US. These campaigns have been shown to increase public awareness of safe handling practices for other foods (e.g., Fein et al., 2011), with behavioral change contingent on messaging informed by understanding of consumers’ food habits and beliefs (Ehiri and Morris, 1996). The use of this management option would require a shift from managing DA as a fisheries resource concern to a food concern, and could be used in combination with enhancements to California’s public health advisory notification system. Currently, advisories are posted on various websites, sent out to those who sign up to receive them, and provided as a recorded message to those who call in to the state’s Shellfish Biotoxin Information Line, all of which depend on consumers seeking out information. Studies similar to that conducted by Tan et al. (2011) for chemical contaminants are needed to evaluate methods for reaching the people most prone to DA exposure—including those who eat the internal organs, raw or cooked, or use them and/or the water they are cooked in for soups—as well as the public more generally. Findings from these types of studies could inform the adaptation of existing outreach materials (e.g., OEHHA, 2016) and development of appropriate new materials. Likewise, outreach materials could be distributed through more varied and effective channels (community newsletters, text messages, social media as well as seafood vendors) in partnership with others (Tan et al., 2011; Dinh et al., 2023).

With this approach, public health agencies would be better positioned to oversee directed educational campaigns. This outreach could be handled via expanded collaborations among industry members and resource and public health agencies to notify consumers and provide them with information about safe handling practices (Adesokan et al., 2015; Hicks, 2016). As part of this program, a recall system for live product would need to be integrated with the state’s food recall system (similar to that outlined in the state’s recently adopted regulations for evisceration), which is coordinated with the federal government’s Recall and Public Health Alert system, and then activated when there is a DA outbreak associated with the product, as is done for Escherichia coli and other food contaminants (see, e.g., California Department of Public Health (CDPH), 2025; US FDA, 2022). Another requirement would be integrating live crab into the National Shellfish Sanitation Program (NSSP) because, like molluscan shellfish, it is not considered by CDPH to be a food product because it is alive. The NSSP could be further expanded to address lobster and other harvested species that bioaccumulate DA and are sold live to consumers. Explaining and managing DA events similarly to other food contamination events may resonate with consumers as that system is more familiar to them, thereby enhancing knowledge about risks and benefits of seafood consumption (Adesokan et al., 2015; Bass et al., 2022).

Management and mitigation aside, a fundamental question brought to the fore during the 2015–16 DA event was whether DA management actions that eliminate or restrict access to crab fisheries are necessary to protect public health. No one questions that protecting consumers from exposure to DA is essential; fishery participants do not want consumers to get sick from eating crab or any type of seafood. But several wondered if the risk of DA exposure from consuming crab has been overstated. This is due in part to how the risks of consuming crab have been equated to those of eating bivalves and how crab is tested. Bivalves are prepared and consumed whole, including the organs that accumulate DA, with many often consumed during a single meal. Oysters, in particular, are often eaten raw, bypassing handling or cooking that would otherwise dilute the DA. In comparison, crabs most commonly are cooked—boiled or steamed—and many, but not all, consumers eat only the meat and not the organs of a single crab (Marien, 1996; Lefebvre and Robertson, 2010). As such, both how crab is prepared and cooked and how it is consumed can greatly reduce the risk of DA exposure, especially as compared to bivalves. The testing method of wrapping sampled crab in foil also may cause DA to be retained when it would otherwise be lost during typical boiling (cooking), thus leading to increased DA levels in test results. Investigations to better define the risks from consuming DA-exposed crab, including the amount of crab that would need to be consumed to cause adverse human health impacts at the various levels of DA seen in crab, would help improve understanding and, likely, support for DA management designed specifically for crab.

The fact that there have been no reported illnesses or deaths associated with DA toxins and crab consumption also continues to be a point of contention. This is particularly notable given there were continued commercial sales and recreational harvests of rock crab during all previous DA events in the state, suggesting that consumers likely have been exposed to DA. Moreover, consumers undoubtedly have been exposed to DA for at least brief periods given the lag between sampling and determination that a risk exists. Yet in contrast to experiences with other contaminated food that has reached consumers (e.g., lettuce with E. coli, meat and poultry products with salmonella), there have been no known cases or outbreaks of DA poisoning associated with consumption of crab, including in areas with substantial sales of DA-exposed rock crab.⁷ Reports of cumulative impacts of long-term low-level DA exposure on memory are also health concerns to consider, but thus far they have been linked only to heavy consumption of DA-containing razor clams, consumed whole, internal organs included (Roberts et al., 2016; Ferriss et al., 2017)—not crabs. Public health research to evaluate the occurrence of symptoms similar to those associated with DA poisoning in consumers may help address questions raised about the risks and whether DA-related illnesses have occurred and gone unreported. In particular, focusing on those who consume raw or cooked crab viscera may help determine whether they have been impacted—acutely or chronically—by DA.

Overall, our work suggests that the current approach to DA management raises many questions and poses numerous challenges related to access throughout the seafood system. It has been highly precautionary due to the very serious human health impacts experienced with mussel and clam consumption coupled with gaps in species-, fishery- and consumer-specific risk information. Closures, and to some extent evisceration orders and depuration requirements, reflect an effort to address many of the uncertainties in this situation. However, this approach oversimplifies the complexities of the two fisheries and seafood systems. Developing an effective management approach, one that also considers risks to fishing communities and the seafood system (Hilborn et al., 2001), requires directed research to fill information gaps and learning from efforts and experiences with DA and other food contaminants. Shifting from a fishery resource management approach to a food systems management one would provide access to established frameworks, systems and processes to better ensure food safety. It also would provide more holistic and relatable framing to enable consumers to (1) draw on and relate to other strategies for addressing food safety concerns, (2) access information about the potential risks and benefits of consuming crab, and (3) facilitate a cultural shift that normalizes handling and consumption practices that minimize risks of exposure to toxins in crabs, like other foods. Ultimately, our results indicate that such a ‘fish as food’ approach provides an opportunity to better mitigate impacts throughout the seafood system and define and address health risks, thereby offering a solution to this blooming dilemma.

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