Keeping Washington Shellfish Safe: Why Biotoxin Testing Is a Public Good

Shellfish beds exposed at low tide. Photo: Washington State Department of Health

Biotoxin testing protects public health and a $416 million shellfish industry. The cost should not fall on growers alone.

Washington's clams, oysters, mussels, and geoduck are filter feeders. During harmful algal blooms, they can accumulate naturally occurring toxins from the water, and cooking or freezing does not remove the danger. The state tests shellfish regularly and closes harvest areas when toxin levels rise.

Biotoxin testing is a public good. It protects public health, prevents illness, and promotes consumer confidence in seafood safety. The benefits reach the whole community, not just commercial shellfish operations. If everyone benefits, why should growers alone bear the cost? Greene Economics examined that question for the state.

Monitoring needs to keep pace with changing conditions

Biotoxin events can occur year-round. The Washington State Department of Health (DOH) conducts routine biotoxin testing every two weeks, with additional testing during biotoxin events. Puget Sound has warmed 0.5–1.0°C over the past century, with the largest increases in Hood Canal. As the water warms, the period when increased testing is needed has expanded to May through October, with DOH finding toxins in areas where they had not appeared before.

The effects are already showing up in harvest closures. In 2023, paralytic shellfish poisoning (PSP) closures in parts of Whatcom County extended into late November and resumed in May 2024, well beyond the historical June–September season. Similar closures occurred in other parts of the state, including Pierce County in 2025.

All Washington biotoxin testing runs through the DOH Public Health Laboratory in Shoreline. In 2024, the lab processed more than 3,400 samples spanning commercial, Tribal, and recreational testing.

The fee burden falls hardest on small farms

State law requires DOH to recover its regulatory costs through fees. In 2022, the department proposed doing exactly that with a full-cost-recovery schedule that would have raised base fees by 340 to 620 percent.

The increase would fall hardest on the operations least able to absorb it. Biotoxin testing alone would have averaged 42 percent of a producer's total base fees. Larger operations could likely absorb that increase. For the small farms that give the industry its character, that fixed cost can decide whether they stay in business. Full cost recovery could force out smaller operators, concentrate the market, and reduce the diversity that makes Washington's shellfish sector resilient — a sector that includes family farms, Tribal operations, and coastal communities with long-standing economic and cultural ties to the water.

It is also a burden almost no other shellfish-producing state imposes. Greene Economics' review of six other shellfish-producing states found that none recovers the cost of biotoxin testing through fees charged to the industry. Instead, they rely on general funds, grants, or other public revenue.

Biotoxin testing is a public good — so who should pay?

At the Legislature's direction, DOH retained Greene Economics to review its fee structure and funding options, including commercial licensing and biotoxin testing fees. Our analysis found that biotoxin sampling, testing, and monitoring meet the criteria for classification as a public good. The program protects public health and the industry's ability to sell and export shellfish. A single contamination event could cripple consumer trust and export markets and devastate the regional economy, making reliable, state-funded monitoring an essential economic safeguard.

We recommended that Washington adopt the proposed licensing-fee increases but fund biotoxin testing separately as a public good rather than through producer fees. We also recommended that the state help the Public Health Lab move to lower-cost testing methods, so monitoring capacity can keep pace as testing needs grow.

"Biotoxin testing protects everyone, not just shellfish farmers," says Bea Covington, Greene Economics sustainability director and principal economist. "It safeguards public health, supports industry stability, and ensures equity for Tribal and commercial operations, which is essential to keeping the entire sector viable."

Funding biotoxin testing costs about $674,000 a year — roughly 0.16 percent of the $416 million Washington's commercial shellfish sector contributes to the state's economy annually. That investment sustains the state's testing capacity, spreads the cost of safe shellfish across the public that benefits from it, and protects a diverse, resilient industry that Washington's coastal communities and economy depend on.

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This article was originally published in September 2025. In 2026, the Washington Legislature funded implementation of Greene Economics' recommendations and directed the Department of Health to develop fee structures that ease the strain on small commercial shellfish businesses. See our Washington Shellfish Fee Assessment case study or visit DOH's Shellfish Program Fees Rule Revision page for current information.