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Organic Aquaculture

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The Organic Foods Production Act (OFPA) of 1990 authorizes the National Organic Standards Board (NOSB) to advise the Secretary of Agriculture on production and handling standards for organically produced agricultural commodities. The Secretary draws upon the recommendations of the NOSB in developing the standards of the National Organic Program (NOP). By including “fish used for food” in the definition of livestock, the OFPA also requires that any fish used for food that is labeled as organic must be raised in accordance with NOP standards. Therefore, any producer labeling a fish as organically produced must comply with all applicable requirements and restrictions for livestock production in the OFPA and the NOSB is responsible for advising the Secretary on standards for the production and handling of fish. To clarify the meaning of the term “fish”, the NOP developed the term “aquatic animals” to refer to finfish and shellfish used for food either propagated in a selected, controlled environment (aquaculture) or taken from free ranging marine or fresh water populations (wild capture)..

In recent years there has been growing public interest in certification programs that address the production practices and environmental impacts related to the production of aquatic animals. As the OFPA authorizes the development of standards for aquatic animals, some of these certification programs have drawn upon organic practices and principles in developing their standards and several specifically identify the products they certify as organically produced. A number of individuals and organizations have presented testimony in support of organic standards for the production of aquatic animals at public meetings of the NOSB.

Simultaneously, the implementation of standards for terrestrial animals in the NOP final rule has brought greater clarity and consistency to the meaning of organic livestock management in its entirety. In September 2000, the NOSB named six of its members to an Aquatic Animal Task Force to evaluate aquaculture and wild capture aquatic animal operations and to assess the feasibility of developing organic production and handling standards for their certification..

STRUCTURE and PROCESS

The Task Force determined that aquaculture and wild capture production systems were sufficiently unique to warrant separate consideration in the review process. The Task Force also concluded that it needed additional expertise to undertake a thorough analysis of the diversity of aquatic animal production systems under consideration. To address these concerns, the Task Force empanelled independent Working Groups on aquaculture and wild harvest production operations that included experts from the fields of fisheries management, production, marketing, and aquatic systems ecology. The Working Groups also included representatives from organic certification and marketing organizations. Each member of the

Task Force was assigned to a Working Group and the chairs of the Working Groups were added to the Task Force. Recognizing that strongly divergent positions existed on numerous core issues, the Working Groups did not pursue consensus recommendations but opted for the fullest elaboration of alternative points of view. Beginning their deliberations in November 2000, the Working Groups engaged in an expansive dialogue over four months and presented their final reports at the NOSB meeting in Buena Park, CA in March 2001. The Task Force reviewed the Working Groups’ findings and narrowed their recommendations to those contained in this report..

The Task Force has also drawn upon the work of the NOP to solicit public comment on organic certification standards for the production of aquatic animals. The two proposed rules for implementing the NOP (62 FR 65850 and 65 FR 13512) elicited numerous public comments on the feasibility of certifying aquatic animal production. Given the absence of consensus in these preliminary comments, the NOP determined that a more focused analysis of the issues would be needed to facilitate the incorporation of standards into the NOP final rule. On March 13, 2000, AMS announced in the Federal Register plans to hold three public meetings to consider the certification of aquatic animal production.

The announcement included a series of questions pertaining to wild capture and aquaculture production systems. AMS convened public meetings on April 10, 2000 in Mobile, Alabama, April 12, 2000 in Anchorage, Alaska, and May 3, 2000 in Providence, Rhode Island and received a total of 71 written and oral comments. AMS also participated in an organic certification workshop for wild capture operations in Seattle, WA on April 9, 2000 and the National Organic Aquaculture Workshop held at the University of Minnesota on June 23 and 24, 2000. Members of the NOSB attended each of these public meetings and workshops.

Finally, the Task Force took into consideration existing guidelines and standards applicable to the certification of aquatic animal production. The Task Force noted that the Codex Alimentarius Commission for the Production, Processing, Labeling and Marketing of Organically Produced Foods of which the United States is a member has determined that the products of hunting or fishing wild animals shall not be considered livestock under their guidelines. The Task Force also reviewed numerous existing certification programs that contain standards for organically produced aquatic animals. The Working Groups and Task Force also benefited from and greatly appreciates the insight and expertise of numerous individuals who produce, market, or study aquatic animals. Knowledge of how existing aquatic animal production systems function was indispensable in developing pertinent recommendations..

The development of standards for the production of aquatic animals represents a unique dimension of certification that will require careful consideration of the fundamental principles of organic management. The unique physiological and behavioral characteristics of aquatic animals make it impractical to develop standards by extrapolating from the requirements and restrictions that apply to terrestrial production systems. The OFPA provides the authority to develop standards for the production of aquatic animals and identifies the elements of a livestock production system that must be addressed in every organic system plan – livestock origin, feed ration, health care, living conditions, and identification. However, the OFPA does not contain provisions specifically intended for aquatic animals or address how standards developed from and for terrestrial systems should be applied to aquatic environments. Our intent has been to recommend standards for the production of aquatic animals that reflect an innovative approach to organic certification while remaining fully consistent with the statutory requirements of the OFPA.

Discussion

The Organic Foods Production Act of 1990 (OFPA) is the statutory foundation for the certification of organic agricultural commodities. The Task Force developed its recommendations on aquatic animal standards for aquaculture and wild harvest production systems based on the ability of producers to comply with the livestock management requirements established in the OFPA. The requirements in the OFPA specific to livestock production are origin of livestock, feed ration, living conditions, health care, and identification.

AQUACULTURE

The production of aquatic animals in an aquaculture system begins with the introduction of juvenile life stages such as seed, gametes, fertilized eggs, fry, and smolts from one or more species. The Task Force concludes that the OFPA requires a producer to pro-actively select the animals that are organically managed on his or her operation. The Task Force recommends that juvenile life stages be brought under organic management no later than the second day of the animal's life. This "day old" standard is identical to the provision in the OFPA for using chicks from nonorganic operations in organic poultry production. Beyond the allowance for introducing day old animals reared on nonorganic operations, all juvenile life stages raised in hatcheries must be managed in compliance with organic standards. The intent of this recommendation is to allow the introduction of nonorganically managed aquatic animals but to require that they remain under continuous organic management beginning no later than the second day of life.

How to apply the OFPA’s feed ration requirements to the tremendous diversity of herbivorous, piscivorous (fish eating), and omnivorous diets found among aquatic animals was unquestionably the most challenging aspect of the deliberations on aquaculture. No other issue so clearly illustrates the practical difficulty of adapting a statute that was drafted for the traditional species raised in terrestrial livestock operations to aquaculture production. Section 6509(c)(1) of the OFPA requires that producers feed livestock “organically produced feed that meets the requirements of this title.” Under the NOP final rule for terrestrial livestock production, agricultural feed ingredients such as pasture, grains, and legumes must be organically produced. The OFPA's classification of aquatic animals as agricultural products necessitates that natural feed materials derived from them including fish meal and fish oil must also be organically produced. Since the Task Force is recommending against the certification of aquatic animals captured from wild capture systems, the vast majority of fish meal and fish oil that are currently used in aquaculture will be prohibited in organic production. The Task Force recognizes the consequences of this position for aquaculture operations that are dependent upon fish meal and fish oil but must adhere to an approach that is consistent with the OFPA and the final rule.

The Aquaculture Working Group gave extensive consideration to aquatic animal nutrition including the potential approaches to allowing fish meal and fish oil in organic production. The Working Group concluded that the fundamental requirement in organic feed management is to provide a balanced and complete feed ration exclusively composed of allowed materials that closely resembles the animal's natural dietary preferences. Applying this principle to piscivorous aquatic animals, they concluded that there is no allowable natural or synthetic alternative to a feed ration including appropriate amounts of protein derived from fish meal and fish oil. The Working Group determined that the complete substitution of protein derived from plants or terrestrial livestock for sources derived from aquatic animals is unacceptable for naturally piscivorous species. While agreeing up to this point, the Working Group split on the best way to address the inherent need for fish meal and fish oil in the diets of piscivorous species. One group supported creating a National List allowance for fish meal and fish oil in amounts appropriate to the dietary needs of a species provided that the feed material was produced from a sustainably managed fishery. The second group could not support an open-ended allowance for fish meal and fish oil but was open to allowing such materials as feed supplements provided that they did not exceed a certain percentage (5% was discussed) of the total feed ration.

The Task Force concurs that organic livestock producers must provide a complete, balanced, and naturally palatable diet and that this requirement mandates including fish meal or fish oil in the diets of piscivorous aquatic animals. While section 205.237 of the final rule requires agricultural components of the feed ration to be organically produced, it also allows nonsynthetic substances and synthetic substances included on the National List as feed additives and supplements. The Task Force recommends that up to 5% of the total feed ration may include nonorganic fish meal and fish oil as feed supplements to provide natural sources of amino acids and Omega 3 fatty acids. The Task Force recognizes that this recommendation will restrict the species of aquatic animals that can be raised organically. There is also potential for operations that manage algae blooms to raise herbivorous aquatic animals in a manner comparable to ruminants grazing on pasture. By-products of these herbivorous species raised on organic operations could provide a source of organic fish meal and fish oil for organically raised piscivorous species.

Health Care Management

The Task Force concludes that the preventive health care management principles outlined in the OFPA and reflected in the NOP final rule are readily transferable to aquatic production systems. Producers must document in their organic system plan that they have factored breed selection, feed ration, living conditions, and sanitation practices into a production environment that fosters pest and disease resistance among the aquatic animals they raise. The Task Force also supports the allowance for vaccines and veterinary biologics, natural therapeutic agents, and synthetic medications included to the National List in aquaculture production. Finally, the Task Force recommends allowing a producer to use temperature or pressure shock as a physical alteration to induce triploidy in aquatic animals

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Livestock Living Conditions

The Task Force identified three essential components in the requirements for livestock living conditions in organic aquaculture systems: the provision of a species appropriate production environment; the preservation of environmental quality in the surrounding ecosystem; and the continuous separation of organically and nonorganically managed populations of aquatic animals. The Task Force concludes that a producer must satisfy these requirements by maintaining a production system that restricts the movement of aquatic animals within fixed, recognized boundaries. These systems can include ponds, netpens, raceways, re-circulating systems, and other enclosed operations in which the producer is responsible for introducing the organisms and retains an active role in managing their development.

The determination of appropriate living conditions must be species-specific and the Task Force believes that the guidelines developed in the final rule for terrestrial species can be adapted to aquatic animals. Responsiveness to specie’s fundamental behavioral and physiological requirements must be the primary consideration in this determination. Evaluating the potential adverse environmental impacts of an organic aquaculture operation is both a species and site-specific determination. Of particular concern in aquatic systems is the potential for nutrients from undigested food and feces to move into the ecosystem. While it is preferable for systems to contain and recycle the nutrients they introduce in production, a completely closed loop is not possible on every operation, including terrestrial ones. The Task Force concludes that net pen systems that do not capture and contain excess nutrients may meet the requirements of an organic system if they do not exceed the capacity of adjacent waters to naturally cycle such nutrients. The Task Force also concludes that the potential for contact between prohibited substances and organically managed aquatic animals in open water netpen systems can be managed through monitoring included in the organic system plan. The prohibition on contact with prohibited substance, particularly those not intentionally introduced into the production process, contains some allowance for genuinely unavoidable and incidental contact. Finally, the Task Force concludes that livestock living conditions in organic aquaculture production must be adequately secure to prevent escape of aquatic animals to the wild or movement of nonorganically managed animals from the wild on to an operation producing a similar species.

Identification

The Task Force concludes that an aquaculture operation that complies with the recommended provisions for origin of livestock, feed ration, health care management, and living conditions can satisfy the identification and record keeping requirements in the OFPA.

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