The Organic Aquaculture Quandary
By Dan Burden, content specialist, AgMRC, Iowa State University, email@example.com
Organic food markets are rapidly growing. Aquaculture and commercial fishing are attempting to create brand identities within or related to organic markets. According to The Washington Post (2009), organic food and beverage sales in America have risen from $1 billion in 1990 to about $20 billion in 2007. Sales of organic meat alone have grown from $33 million in 2002 to $364 million in 2007. If the USDA does decide to allow farm-raised fish into the ranks of USDA-certified organic products, this could open the door to a huge increase in profits for the aquaculture industry as well as give them a huge leg up over the commercial fishing industry.
Organic produce is grown without fertilizers, pesticides, herbicides and does not include genetically modified organisms (GMOs). Organic livestock is fed a completely organic diet, is antibiotic free and does not include animal GMOs. It is more difficult to determine an organic standard for fish than for produce and livestock. Fish that are vegetarian may require different standards than carnivorous fish, as will bottom feeders. Also, environmentalists believe that because farm-raised fish tend to live in cramped conditions more water pollution may occur. This may cause the fish to be unsustainable and unhealthy, so calling them organic misrepresents the product. Many fish farmers are of the view that the growing seafood demand and depletion of wild fisheries creates a favorable market for farm-raised seafood. They feel that a farm-raised product based on predominantly natural inputs should be certified organic or a close equivalent that strongly suggests “organic” and “natural.” Currently, adherents of strict application of organic agricultural standards to aquaculture hold that the principles of organic aquaculture must include:
• Careful selection of sites for aquaculture farms.
• Protection of adjacent ecosystems.
• Active avoidance of conflicts with other users of the aquatic resources (e.g., fishermen) .
• Prohibition of chemicals (e.g.. as anti-fouling agents in net pens) .
• Natural remedies and treatments in the case of disease.
• Feedstuff from organic agriculture.
• Fishmeal and -oil in feed derived from by-products of fish processed for human consumption (no dedicated "feed fishery").
• Prohibition of GMOs, neither in feedstuff, nor in the stock itself.
• Processing according to organic standards.
Debate on the topic of “organic aquaculture” began in 2000 when the United States Department of Agriculture (USDA) named a task-force advisory panel, National Organics Standards Board (NOSB), to the USDA's Agricultural Marketing Service to evaluate requests from fish farmers for organic eligibility. The task force ruled out the possibility that wild fish could be labeled organic on the grounds that catching wild animals isn’t agriculture. They did recommend that farm-raised fish could be labeled organic as long as their diets were almost entirely organic plant material. Herbivorous fish, e.g., carp, tilapia and some shellfish (mollusks and crustaceans) are far easier to categorize and certify with respect to organic standards. Feed for them is already being produced in accordance with the tenants of organic agriculture or can be produced using algae, sunlight and simple nutrients within a closed system.
Eventually, rules far less stringent than those for organic agriculture were proposed. These included three options for what “organic” fish could eat. Included: an entirely organic diet; non-organic fish during a seven-year transition period while fish farms shifted to organic fish meal; or non-organic fish meal from what were judged to be “wild-sustainable” fisheries. Sustainable fisheries are those where fish stocks may fluctuate but do not decline over time.
In November 2008 NOSB recommended the USDA certify some farm-raised fish as organic. This did exclude all wild-caught fish from eligibility. NOSB came under immediate fire for approving relaxed standards for organic labeling. Under the NSOB proposal, farmed fish could carry the label even if their diets included up to one-fourth wild-caught fish and fish bi-product, perhaps from non-sustainable fisheries, and included other animal and plant feeds not produced in accordance with organic agriculture principles, as long as none of this material was from endangered species.
This ruling was primarily the result of trying to develop an “organic” standard for carnivorous fish. Carnivorous fish pose a problem because the fish they eat usually are not farmed organically. Often times they are wild-harvest feed fish or a wild-harvest or animal-agriculture bi-product. The NOSB recommendation was met with opposition from environmentalists and the commercial fishing industry because the criteria for calling fish organic included feeding non-organic feed (currently, certified-organic livestock have to be fed 100% organic feed). Additionally, some farmed-fish fed wild-fish fishmeal has exhibited elevated dioxin, mercury and other toxin levels. Fish grown in open-water net pens are said to be a pollution (from concentrated waste), disease, parasite and potential genetic-pollution source for the water system and its wild-fish populations.
According to a Consumer Reports magazine food labeling poll, some 74 percent of consumers are concerned about environmental pollution from “organic” fish. The poll also showed that 91 percent of consumers want contaminants in fish to be absent or present only at very low levels. Of course, consumers vote with their dollars for the products that are most valuable to them. Will consumers be able to discern their product origin and content from sound descriptive labeling, including perhaps “organic”? The New York Times in "Free or Farmed, When Is a Fish Really Organic?" (2006) stated that for these and many other reasons, if the USDA does create a standard for organic fish, it may well be so controversial, challenged, appealed and counter-appealed, that it could be many years before fish labeled USDA-certified organic would be in local grocery stores.
At the center of the debate is the open-water net-pen salmon-farming industry. It is one of the most controversial areas of aquaculture, yet with dwindling wild stock, it is seen as a way to produce highly-valuable high-quality products on a cost-effective scale. Salmon farming is potentially very highly profitable especially if the fish command the premiums that result from USDA-organic certification. With the feed input accounting for the majority of material and energetic inputs and emissions, understanding its overall role in production sustainability and environmental impact is deemed central to understanding open-water net-pen salmon farming’s overall environmental impact and biophysical sustainability.
The world-wide use of wild-caught fishmeal and fish oil in aquaculture feeds for carnivorous fish (particular salmon and to a lesser extent trout) has been criticized as inherently unsustainable and a source of persistent organic pollutants (particularly PCBs and dioxins) by most environmental groups (New York Times; Choking on Growth? 2007). The aquaculture industry consumes approximately 46 percent and 81 percent of the global fishmeal and fish-oil supply, respectively. Furthermore, the ever-changing nature and complexity of global marine fisheries questions the sustainable use of fishmeal and oil and makes their substitution to animal-agriculture bi-product or vegetable proteins one of the greatest challenges facing the aquaculture industry in general and “organic” producers in particular.
A very thoughtful review of the issue from the standpoint of life-cycle analysis was presented by Pelletier and Tyedmers (2007) Feeding Farmed Salmon: Is Organic Better? In their paper, the researchers attempted to create a useful framework for feed producers and aqua culturists concerned with improving the biophysical sustainability of their products and policy makers responsible for certification, eco-labeling and consumer awareness programs. Pelletier and Tyedmers used life cycle assessment (with co-product allocation by gross energy content) to compare the cradle-to-mill-gate life-cycle energy use, biotic-resource use; and the global warming, acidification, eutrophication and aquatic toxicity impacts associated with producing ingredients for four hypothetical feeds for conventional and “organic” salmon aquaculture in order to assess the benefits, if any, associated with a transition to organic plant-derived protein feed use.
They found that fish and poultry-derived ingredients generated substantially greater impacts than crop-derived ingredients and that organic crop ingredients had remarkably lower life cycle impacts compared to equivalent conventional ingredients; however, substituting organic for conventional crop ingredients resulted in only minor reductions to the total impacts of feed production: the benefits of this substitution were effectively overwhelmed by the much larger impacts associated with animal-derived ingredients. Replacing fish meals and oils from dedicated reduction fisheries with fisheries by-product meals and oils markedly increased the environmental impacts of feed production, largely due to the higher energy intensity of fisheries for human consumption, and low meal and oil yields of fisheries by-products. Environmental impacts were lowest when feed composition contained less fish and poultry-derived ingredients.
Overall, the results indicated that current standards for “organic” salmon aquaculture, which stipulate the use of organic crop ingredients and fisheries by-product meals and oils, fail to reduce the environmental impacts of feed production for the suite of impact categories considered in the study. This seriously questions the validity of “organic” labeling if the production systems are held to the same standards as the organic agriculture industry.
The development of organics standards for mollusk shellfish has been equally problematic within the context of general aquaculture practices. Crustacean shell-fish farming (shrimp) is similar in many ways to finfish aquaculture. However, mollusk shellfish farming is unlike other fisheries operations in that mollusks are usually stationary sedentary organisms. The practices employed by shellfish farmers are more akin to vegetable crop production than to net-pen or pond-type aquaculture. Larval mollusks are planted on a substrate, then tended for an 18-month to five-year grow out (depending on species, location and environmental variables), then harvested much as a farmer would harvest an agronomic plant crop. Shellfish planted for grow-out graze strictly on the natural micro-algal content of the water column. Unlike agriculture or other forms of aquaculture, most shellfish do not use fertilizers, feed, antibiotics, vaccines, biologics or growth hormones. The rare exception to this would be if an antibiotic or fungicide were used when the shellfish were larval phase within the closed system of the hatchery. Current thinking is that organic production-certification regulations would be enforced from the point at which the larval “seed” organisms left the hatchery and were placed into the open-system environment.
Critics contend that basic organic tenants are compromised or violated for several reasons. One is that shellfish live within an environment that cannot be completely controlled and that they “graze” on naturally occurring microalgae. There is a parallel here with free-grazing terrestrial herbivores that graze in pastures. Terrestrial farmers cannot control acid rain, groundwater and particulates in the air or chemical drift. They can only manage the plot of land they have agreed to manage using organic principles. Similarly, shellfish growers cannot control currents, winds, storm events, rainfall or other environmental conditions that might cause drift of an unwanted substance into their growing area. The NOSB Final Rule addresses this by providing that the organic certifier has the ability to require residue testing. Another concern is that organic livestock must be fed 100 percent organic feed their entire lifespan. Shellfish filter-feed uncontrolled wild plank tonic material. This would have to be deemed sustainable and “naturally safe.” Also, some critics compare shellfish on substrate to net-pen fin-fish systems, although the two are extremely dissimilar due to the stationary nature of mollusks and the fact that growing areas have determined boundaries that are regularly monitored and managed, the similarities with terrestrial agriculture are a closer parallel.
Robin Downey, Executive Director Pacific Coast Shellfish Growers Association recommends that since one of the contentious issues surrounding finfish aquaculture in open water systems is the management of nutrients (waste). A simple solution would be to require shellfish beds to be set beside fin-fish net pens or to more completely integrate the systems. Ideally, the shellfish will feed on the nutrients expelled by organically produced finfish (feeding on what could reasonably be construed as organic nutrients) within a managed (controlled) system. The shellfish thrive on these organic nutrients, purifying the surrounding water and eliminating the potentially damaging effects of over-nitrification by neutralizing the finfish waste as it enters the environment. This is essentially an aquatic model of the terrestrial "partner farm" concept postulated by many horticulturalists as an ideal organic management system.
In a recent editorial, Paddy Doherty, Certified Organic Associations of British Columbia, Director of the British Columbia Salmon Farmers Association (BCSFA) pointed out that consumers purchase for different reasons, but that many buy organic because of the perceived environmental benefits of organic farming. When they purchase organic-labeled products, it is with the understanding that the product is fundamentally different from a non-organic counterpart. This creates a difficult situation for organic agriculture, whose adherents see the legal and political ramifications of wavering from strict organic-agriculture precepts to certify aquaculture systems and products based on non-sustainable feeds and controversial systems.
Doherty points out that, “Organic farming is uniquely organic farming, organic processing is uniquely organic processing and the consumer appreciates this... We have an unwritten contract with our consumers whereby they agree to pay considerably more (usually) for organic product based on their perceptions of our products.”
Many in the organic movement believe that there can be an organic certification for some seafood, but the process must satisfy the principles of organic farming, and it must be acceptable to the closest scrutiny of the industry’s detractors. Distinct product labeling where there are clear distinctions between similar products must be standardized and clear to the consumer to prevent skepticism, distrust and erosion of consumer “trust equity.” Ultimately, product integrity based on quality and production-system sustainability and post-harvest processing and handling food-safety considerations will define markets, as high-quality products have defined other markets. Some of these products will carry an organic label, others will not.
Sources and References
A European view on Organic Aquaculture.
Developing Organics Standards for Molluscan Shellfish
Feeding Farmed Salmon: Is Organic Better?, N. Pelletier and P. Tyedmers, 2007.
Free or Farmed, When is a Fish Really Organic?, The New York Times, 2006.
Organic Aquaculture Standards Shouldn't Be Fishy.
Organic Consumer's Association.
Organic Fish Farming, Audra E. Clark.
Organic Aquaculture and Fish Farming, P. Doherty, Certified Organic Association of British Columbia.
Pacific Coast Shellfish Growers Association.
Proposed Rules for Net Pens.
Proposed Rules for Aquaculture Feed.
Pure Salmon Campaign.
Purity of Federal 'Organic' Label Is Questioned, Washington Post.
USDA Book on Organic Aquaculture, 2005.
Written November 2009.