FURTHER COMMENTS of the ORGANIC TRADE ASSOCIATION for the USDA-AMS-NOP hearings on Organic Production and Handling of Aquatic Animals to be Labeled as Organic
Docket Number TM-00-03
Providence, Rhode Island
Submitted by Tom Hutcheson,
Associate Policy Director
May 3, 2000
Thank you very much for this opportunity to comment.
1. How would the introduction of organic production and handling standards for aquatic animal operations affect consumer perception and acceptance of the organic certification process for other types of operations?
The organic industry has worked for 30 years to develop a set of stringent standards and to gain acceptability as a legitimate, viable agricultural practice. This development continues today, as members of the organic community debate such issues as animal health and welfare. To award the organic label to a aquatic species that are caught or farmed in an uncontrolled feeding environment would throw the perception of organic production back 30 years to when people believed that organic meant simply that “you don’t do anything to your land, or crops, or orchards, or animals.” “Organic” is not synonymous with “natural.” The definition of organic that has been refined over the past few decades is not simply “management by neglect.” In fact, there are natural products which are prohibited from use in organic production. Again, “organic” is not synonymous with “natural.” The principles of organic management are based on improving soil health, being an active participant in building soil diversity, and creating and maintaining ecological farm practices.
Organic certification for aquatic animals would adversely affect consumer perception. To certify wild-caught or farmed fish, the organic industry would have to bend its standards significantly in order to accommodate these fish, which could damage the whole industry. If wild-caught or farmed fish could be labeled organic, the organic consumer could lose faith in the organic label, rejecting not only the fish but other organic products as well. Aquatic standards would devalue the organic label.
Although OTA welcomes the addition of an industry which includes ecological considerations in its standards, the fundamental point is that any fish operation is a different kind of operation from organic production, not simply a different degree of operation. This different kind of operation requires a different kind of certification and labeling.
2. How would an organic label impact the marketing of aquatic animals?
Because OTA does not market any particular organic product, OTA has no specific comment on this question. However, it is certainly the case that the organic label has never been awarded based on any sector’s desire to have a marketing advantage. The label is based on principles arising from farmers’ treatment of land ecology.
3. What types of certification programs other than organic could provide consumers with useful information on the harvesting and processing or aquatic animals?
“Sustainable wild harvested,” used by Farm Verified Organic, is an excellent alternative label, as would be “sustainably grown” or “naturally grown.” It is already in use, and is one which seems to have just as stringent standards for seafood procurement as the organic industry has for crop production. OTA strongly supports the further development of appropriate standards and appropriate labels for seafood, including fin fish and shellfish, both wild and farmed, which could become as distinguished as the organic label is in agriculture.
4. How would AMS standards for the production and handling of aquatic animals relate to international regulation?
No international organization accepts the designation of wild fin fish as organic. This seems to be based on the three fundamental questions of control of the feeding environment, organic feed, and control of animal health and welfare. The most recent draft update of the basic standards for the International Federation of Organic Agriculture Movements (IFOAM) states that “organisms which are moving freely in open waters, an/or which are not inspectable according to general procedures for organic production, are not covered by these standards.” The Soil Association, a leading organic standards organization in Great Britain, has not accepted a standard for wild-caught fin fish, though they do have farmed fresh-water fin fish in controlled open waters in land-locked locations. The joint WHO/FAO Codex Alimentarius standards do not allow fished or hunted species to be certified as organic, and a recently-adopted European Union regulation on livestock also excludes fished and hunted species from being labeled as organic. The US would clearly be out of line with international regulations if wild-caught standards were adopted.
Aquatic Animal Operations
1. Which components of organic certification for crops and livestock are compatible with or similar to operations that produce aquatic animals?
None are compatible with wild-caught aquatic animals. “Wild” is not the same as “organic.” Neither the context--the control of the environment, or the content--the provision of organic feed and caring for the health and welfare of the animals, would be part of a wild-caught standard. It is a completely different system; there is no relationship. The livestock standards in the industry assume a farm- or soil-based system. If wild-caught standards do not relate to organic standards, then neither does the organic label relate to wild-caught fish. For farmed fish, either fin fish or shellfish, the requirements of control of the feeding environment, organic feed, and animal health care and welfare should be respected.
2. How can aquatic animal operations comply with the requirements of the OFPA which include: an organic system plan; wild crop harvesting; origin of slaughter stock; health care practices; living conditions; allowed and prohibited substances; feed requirements; post-harvest processing; and identification and record-keeping systems.
Very few if any of the requirements under OFPA can be met. Exceptions might include identification and record keeping systems, and maintaining strict requirements for any potentially non-organic aspects of the operation such as dyes.
One aspect of the lack of control over the environment is the reality of the infiltration of individual fish from non-tracked populations into harvested populations. Interbreeding between organic and non-organic animals would never be permitted on land. Living conditions are not controlled, so no health care can be offered to individual animals which may be suffering disease. Organic feed requirements are likewise impossible in a wild system: even though some salmon, for example, may be highly studied, the fish or any plants they may eat have not been so highly studied.
Organic processing could never be applied to a 100% non-organic ingredient, such as wild-caught fish. Processing is only an extension of an organic production system, and processing standards have been developed to maintain the integrity of organic food and fiber.
Wild Harvested Operations
1. What should be the criteria for determining the suitability of a wild harvest site for the production or organic aquatic animals? How should prevailing environmental factors such as water quality, the presence of prohibited substances, and human activity be incorporated into the site inspection and approval? How should the potential impact of the operation on the target species, non-target species, and the environment be addressed in the certification process?
Please refer to Farm Verified Organic’s “sustainable wild harvested” standards.
2. How can the population dynamics of the targeted species, including age distribution, reproductive capacity, and sustainable catch limits, be cumulatively addressed by the organic system plans of multiple operations?
This is clearly a challenge for those seeking to label their fish organic.
3. How can producers anticipate and certifying agents verify site conditions over time and across the production site in which wild harvest operations function?
The Organic Certifiers’ Council of OTA, representing the great majority of US private certifiers, and all of the larger private certifiers, has adopted the policy that wild harvested fish operations cannot at this time be considered or verified as organic.
4. How can the management practices of a fish hatchery that contributes to a wild harvest population of aquatic animals be incorporated into the organic system plan?
This is clearly another challenge for the wild-caught fish industry.
1. What should the criteria be for evaluating the suitability of a production site for an organic aquaculture operation? Specifically, how can standards be developed for the site of production to address nutrient concentration, the emergence and transfer of disease, the escape of captive species to the wild, and detrimental impacts on indigenous species?
The organic industry, in its American Organic Standards, does not have aquaculture standards as there is not a consensus in the industry that aquaculture is consistent with organic agriculture. While it is conceivable that there could at some time be standards for farmed fish, because that is a managed system, the time is still not yet ripe for the designation of this kind of operation as organic.
As mentioned above, the Soil Association in the United Kingdom does certify one operation which is a closed, land-locked system within which fish swim freely.
2. What characteristics of fish meal are pertinent to the requirement in the OFPA that producers supply livestock with organically produced feed that meets the requirements of the OFPA?
To have organic fish meal, the fish would have to be organic, including raised organically from birth. This could only be true of farmed fish which are fed certified organic food, and even then, only at such a time as other adequate standards were in place. Organic farm standards are decades old and are still evolving; again, the time is not yet ripe for organic fish meal. Raising vegetarian fish on organic feed for larger farmed fish would be one option.
3. What guidelines are needed to control practices used in aquaculture operations are consistent with organic principles?
The widespread lack of agreement on aquaculture is a clear indication that the relationship between aquaculture and organic production is not sufficiently defined for commercial practice.
4. Should the induction of triploidy in fish species be classified as an allowed or prohibited practice?
This is an example of the kind of problem which is unique to aquaculture operations for which the organic industry is clearly not ready to develop standards.
5. How should standards address the origin of livestock requirement for aquaculture operations that obtain stock or fry from wild populations?
This is yet another challenge for the wild-caught fish industry.