USDA Organic Standards for Seafood

In January 2006, a National Organic Standards Board (NOSB) taskforce submitted a proposal outlining the rules for how fish and other aquatic animals must be raised and handled in order to qualify for organic certification by the USDA. Since then, Food & Water Watch has submitted comments to the NOSB.

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March 21, 2007

Ms. Valerie Frances
National Organic Standards Board
USDA-AMS-TMP-NOP
1400 Independence Avenue, SW
Room 4008 - South Building
Ag Stop 0268
Washington, DC 20250-0268

RE: AMS-TM-07-0032-0001, National Organic Standards Board (NOSB) Aquaculture Standards

Food & Water Watch is pleased to comment further on the proposed organic aquaculture standards posted on the United States Department of Agriculture’s National Organic Standards Board (NOSB) web page. Food & Water Watch is a national non–profit consumer advocacy organization that seeks to ensure the health, nutritional and environmental integrity of our food and water.

Consumers want organic food because they value health and the environment. Only strong, consistent organic standards can give consumers confidence that such foods carry those benefits and values. The need for strong standards applies to seafood, as well.
We want the United States to avoid repeating a recent failure of organic standards in
Europe. A 2006 study published in Environmental Science and Technology found high
levels of PCBs in Norwegian farmed salmon labeled “organic.” ¹

With public health and environmental sustainability in mind, we at Food & Water Watch are supplementing our previous comments on organic standards for farmed fish with the most recent scientific studies.

First, please note that we strongly support the following edits that the Livestock Committee made to the Aquatic Animals Task Force’s Interim Final Report.

Net pen and cage culture must not be considered for organic certification
Organic standards must apply only to closed systems. Because of documented negative environmental effects, neither finfish raised in the open ocean nor any seafood raised in coastal net pens or cages should receive organic certification. Furthermore, land-based farms must adhere to strong environmental standards to ensure zero emissions of untreated effluent into the surrounding environment.

Open net pen aquaculture releases effluent directly into the ocean, lake or river. The waste includes uneaten feed and feces that contain nitrate, nitrite, ammonia, phosphate and, sometimes, heavy metals such as mercury, copper and zinc.² These excess nutrients can increase the growth of primary organisms, such as phytoplankton and reduce dissolved oxygen, both of which harm wild flora and fauna. The increased water turbidity blocks sunlight, which reduces photosynthesis by desirable aquatic plants.³ Suspended solids can damage the gills of wild fish, making them vulnerable to disease. Uneaten feed and feces also settle in the sediment below the cages, which changes the chemistry of the sediment, depletes oxygen, hinders the development of anaerobic bacterial mats, and smothers fish eggs and other small organisms living on the bottom. A 2007 study, conducted at Mediterranean Sea sites where the current moved swiftly, found 8 to 25 times more sediment under aquaculture cages than areas one kilometer away.⁴ The negative impacts increase with the size and concentration of the aquaculture operation.

Additionally, pollution from open aquaculture facilities may contaminate local wild fish populations. A 2006 study published in the journal Environmental Science and Technology found an increase in mercury concentrations in wild rockfish near salmon farms along the coast of British Columbia, as compared with rockfish that were not close to any net pens.⁵ The authors partially attribute this increase to high levels of mercury in the fish waste and uneaten feed in the sediment. They also emphasize that the oxygen depletion in the sediment allows anaerobic bacteria to convert inorganic mercury to bioavailable methyl mercury. This toxic form of mercury is then biomagnified as it passes up the food chain to the rockfish.

These environmental impacts are unacceptable for organic production. They also are unnecessary because waste can be managed appropriately in closed systems.
Wild fish and their products must not be used in feed for organic fish
Feeding wild fishmeal and fish oil to farmed fish is neither sustainable nor safe.

In terms of sustainability, capturing and removing smaller wild species from the open ocean to use as feed for farmed fish stresses larger wild fish populations because they then have less to eat.

This practice is not safe, either. Many scientists have concluded that fishmeal and fish oil produced from wild-caught fish is likely the primary route of entry for cancer–causing contaminants into the farmed fish. The latest studies confirm that feeding fishmeal from wild sources to farmed salmon increases the concentrations of persistent organic pollutants, such as dioxins, dioxin-like polychlorinated biphenyls (PCBs), polybrominated diphenylethers (PBDEs), toxaphene and organochlorine pesticides (OPs) such as DDT in their bodies. The levels of contamination are higher in the farmed salmon
than in wild caught salmon.6 Therefore, it is critical that wild fishmeal and fish oil not be used as feed for organic farm–raised aquatic animals.

These health and environmental concerns are unacceptable in certified organic food. Food & Water Watch recommends that any certified organic farmed fish not feed on wild–caught fish. Instead, all feed for organic aquatic species must itself be organically farm–raised. Live fish may be used as a food source, provided that the feed fish were raised in accordance with organic standards.
Slaughter by-products must not be used in feed for organic fish
Food & Water Watch opposes the use of by–products from the slaughter of terrestrial animals in organic aquaculture feed. Most consumers would not assume that organic fish had been fed such by-products, so this practice is deception by omission. Many of the consumers who eat fish but not meat could end up purchasing organic fish that had consumed animal by-products. On learning the truth, they might lose confidence in the organic standard, undermining its value to them, to producers and to the USDA.

Additionally, we are concerned about the potential for disease transfer from the animal by–products. Avian influenza virus could be spread to wild waterfowl through fecal or feed contamination in the water, which would create a public health risk.

Conclusions

Food & Water Watch appreciates the opportunity to comment further on the Interim Final Report of the Aquaculture Working Group. We hope that our recommendations are incorporated into the final standards in order to protect the integrity of organic labeling, thus offering a high level of confidence to American consumers. If you have any questions, or would like to request a copy of any of the referenced studies, please contact Andrianna Natsoulas at anatsoulas(at)fwwatch.org.

Sincerely,
Andrianna Natsoulas
Campaign Coordinator
Food & Water Watch