> ![](media/image1.png){width="1.667361111111111in"
> height="0.47638888888888886in"}

Ms. Valerie Frances

Executive Director

NOSB, USDA-AMS-TMD-NOP

1400  Independence Ave., SW.

Room 4008-So. Ag Stop 0268

Washington, DC  20250-0268  

March 16, 2007

***IFOAM Aquaculture Group Response to the National Organic Standards
Board Livestock Committee Recommendations for Organic Aquaculture***

Docket number AMS-TM-07-0032; TM-07-05.

Thank you for the opportunity to comment on the USDA NOSB Livestock
Committee's recommendations for organic aquaculture.

We, the International Federation of Organic Agriculture Movements
(IFOAM) Aquaculture Group, are a professional group of organic
aquaculture producers, certification bodies, researchers and other
interested parties with many years of experience and understanding in
organic aquaculture production and certification. Through a highly
democratic process, IFOAM's organic aquaculture standards were developed
by members and finalized in 2005 for inclusion in the IFOAM Basic
Standards.

IFOAM embraces organic production in all its diversity and recognizes
that the species raised and systems used must be appropriate for the
region and specific location of production. IFOAM does not place
restrictions on specific species or systems in organic aquaculture, but
instead places emphasis on how to produce species in a sustainable
manner taking into account all aspects of environmental, economic and
social dimensions of sustainability. IFOAM also recognizes that
different sectors of organic production are at different stages of
organic development. Because the organic aquaculture sector is still in
its infancy, it is not surprising that issues such as fishmeal and fish
oil sourcing and environmental impacts of net cage operations are
much-debated topics. We would like to address these issues and encourage
the NOSB to consider options that would encourage innovative research
thereby actively influencing more environmentally, economically and
socially sound organic aquaculture production.

**Sourcing Fishmeal and Fish Oil**

**[Current NOSB Livestock Committee Recommendations:]{.underline}**

**§ 205.252 Aquaculture feed*.***

\(a\) Feeds and feeding practices must meet the minimum nutritional
requirements of the

aquatic animal. However, fish meal and fish oil produced from wild fish
and other wild

aquatic animals that do not qualify as provided in this section cannot
be used in organic

production of aquatic animals.

\(b\) Use of fish meal and fish oil \* and minimize the environmental
impact of released nutrients on receiving waters and adjoining
ecosystems as documented in the Organic System

Plan.

\(c\) Aquatic animals must be provided with their natural foods
consistent with the need

to optimize health and growth of the aquatic animal. This includes live
foods and the

sources of ingredients in formulated feeds as allowed in the rule.

\(d\) Feeds for aquaculture products for human consumption may not
contain lipids from

sources other than fish oil or omega-3 fatty acids produced by organic
microorganisms or

plants, except that other lipids from organic sources may be provided in
feeds for aquatic

animals that have a specific dietary requirements for such ingredients
to the extent necessary

to meet the minimum requirement for that lipid in that aquatic animal.

\(e\) Aquaculture feeds must be composed of feed ingredients that are
certified organic,

except that nonsynthetic substances and synthetic substances allowed
under § 205.603

may be used as feed additives and supplements.

\(f\) Aquaculture feeds may include fish meal and fish oil derived from
organically raised

aquatic animals or algae without limitation according to an Organic
System Plan, providing

the meal and oil is produced from aquatic animals of a different genus
than the

aquatic animal being fed.

\(g\) Silage and lipids produced from organic fish that is
enzyme-processed, or produced

with acids and bases that are organically certified or approved in §
205.605 for fish emulsion

or other purposes, may be certified organic and incorporated into
organic aquaculture

feeds without limitation.

\(h\) Organic aquaculture feeds may include meals and oils containing
essential fatty acids

produced by processes allowed in organic production.

\(i\) Nutritional pigment compounds that have been produced and handled
in accordance

with organic requirements and allowed by the U.S. Food and Drug
Administration for inclusion in aquaculture feeds may be used.

\(j\) Manure from organic terrestrial animals that is composted in
compliance with §

205.203 may be used to fertilize aquaculture ponds in an organic
production system.

Composted manure must not be applied within 30 days of harvest of
aquatic products for

human consumption. Manure, whether composted or not, shall not be
applied to aquaculture

production systems other than ponds.

\(k\) The producer of organic aquatic animals shall not:

\(1\) incorporate or introduce any type of antibiotic or hormone in
feeds, the water

supply, or the environment;

\(2\) provide feed supplements or additives in amounts above those
needed for adequate

nutrition and health maintenance of the species at its specific stage of
life;

\(3\) feed by-products from mammalian or poultry slaughter;

\(4\) use feedstuffs extracted with synthetic solvents not approved on
the National

List;

\(5\) use feed, feed additives, and feed supplements in violation of the
U.S. Federal

Food, Drug, and Cosmetic Act; or

\(6\) use any genetically modified organism, or any organism produced by
any other

excluded method provided in § 205.2 Terms defined, or product thereof,
as a feed ingredient.

# IFOAM Aquaculture Group Suggested Revisions

Under the proposed standards:

§ 205.252 (b), It is not entirely clear what is meant here. Probably
better to replace fish meal and fish oil with the words "**aquatic
animal feeds**" since all feeds should have minimal impact on the
environment. A comparable recommendation in the IFOAM Basic Standards,
Aquatic Animal Nutrition Section 9.5 state "***Operators should feed
animals efficiently, with minimum losses to the environment**"*

§205.252 (c) 'Aquatic animals must be provided with their natural
foods*.......'* - **supports the use** **of fishmeal and oil** in feeds
for piscivorous livestock,

§205.252 (e*)* non-synthetic substances and synthetic substances allowed
under § 205.603 may be used as feed additives and supplements -
**permits the use** **of fishmeal and oil** in feeds for piscivorous
livestock,

and §205.252 (l)(2) The producer of organic aquatic animals shall not
.... provide feed supplements or additives in amounts above those needed
for adequate nutrition and health maintenance of the species at its
specific stage of life *-* **allows adequate levels of fishmeal and
oil** to satisfy the nutritional requirements of piscivorous livestock.

**[IFOAM Aquaculture Group Comments and Supporting
Documentation]{.underline}**

The debate over the use of fishmeal and oil in organic aquaculture
production has lasted over eight years starting when the first NOSB
Livestock Committee organic aquaculture recommendations were released
for comment in 1998. During that time, proponents and opponents of its
inclusion have tried to argue how fishmeal and oil from wild sources
could fall under the 100% organic feed rule for livestock in order for
the livestock to be considered organic. The debate should have ended in
2002 with the release of the USDA National Organic Program Final Rule
where the Preamble states:

> *"Nonagricultural Products as Livestock Feed Ingredients. Some
> commentators questioned whether non-synthetic, nonagricultural
> substances **such as fishmeal** and crushed oyster shell needed to be
> added to the National List to be used in livestock feed. Non-synthetic
> substances do not have to appear on the National List **and may be
> used in organic livestock feed**, provided that they are used in
> compliance with the FFDCA." (Department of Agriculture, Agriculture
> Marketing Service, 7 CFR Part 205, page 262)*

The IFOAM Basic Standards encourage sustainable use of resources and
recommend that "***Feed brought into the operation should be comprised
of by-products from organic and wild sources not otherwise suitable for
human consumption***" (IBS Section 9.5), for example from trimmings, and
cut-off wastes from aquatic species

caught and filleted for human consumption (locally sourced where
possible). We consider that converting these wastes into highly
nutritious food is a suitable use of this resource. Additionally, IFOAM
Basic Standards promote sustainability by recommending that
"***Operators should design systems so that the production area
comprises the entire food chain with minimal reliance on outside
sources***" (IBS Section 9.5). The IFOAM recommendation (IBS Section
9.5), "***Operators should design feed rations to supply most of the
nutritional needs of the animal from organic plants and animals
appropriate for the digestive system and metabolism of the species***"
supports the idea that feeds must be appropriate for the cultured
species' trophic level (for instance, organic low-food-chain species
should not be fed fishmeal and oil). The IFOAM Basic Standards do,
however, provide an option for the use of non-organic aquatic animal
protein and oil (if organic sources are not yet available), as needed
for piscivorous species that require it, however it is with restrictive
criteria. IBS Section 9.5.1.a. states that "***Operators may use
non-organic aquatic animal protein and oil sources provided they are
harvested from independently verified sustainable sources**.*" The
standards for the use of fishmeal and oil from wild fisheries for
organic aquaculture must ensure that harvesting will be sustainable and
not destructive to the environment.

The sustainable harvest of wild capture fisheries for fishmeal and oil
must take the same approach as sustainable harvest for fisheries for
direct human consumption. Much work has been done on this front and is
based on the United Nations Food and Agriculture Organization's Code of
Conduct for Responsible Fisheries. From this document, certification
bodies such as the Marine Stewardship Council, KRAV, Naturland and
others are developing sustainable fisheries harvesting standards.

A well-managed fishery is a renewable sustainable resource whose
appropriate harvest satisfies the philosophy behind the IFOAM Basic
Principles of Health, Ecology, Fairness and Care. We would also urge the
use of these resources to be put into perspective with existing
terrestrial organic livestock feeds. For example, in 2006 the United
States planted approximately 139 million acres of wheat, barley and corn
(US National Agricultural Statistics Service). Approximately 60% of this
grain is used in terrestrial livestock feeds. Therefore over 80 million
acres of United States land is cleared of almost all its plant and
animal life and ploughed back to the bare soil to grow crops to feed
livestock. This is the case whether the land and animals are organic or
non-organic.

Contaminants in feeds are another critical concern for organic
aquaculturists and consumers alike. Contaminants are ubiquitous in the
air, soil and water, and complete control over restricting the entrance
of prohibited substances is impossible and unrealistic in virtually
every setting imaginable. Through organic production, we hope to
minimize the exposure of our crops and livestock to contaminants by not
applying them to our fields or providing them through feed to our
animals. Sourcing wild (capture) fisheries for fishmeal and oil low in
contaminant levels is possible through 1) appropriate selection of
harvest location and 2) processes that fish meal and oil manufacturers
can now take to remove known contaminants (R. Nelson, Silvercup Feeds,
personal communication). As added insurance, the IFOAM Basic Standards,
Section 9.5.1.b. requires that "***Operators may use non-organic aquatic
animal protein and oil sources provided they are verified to have
contamination levels***

***below limits established by the standard-setting body***."

Feed formulation must address the nutritional and physiological
requirements of the individual species of farmed animal (which, for
example, leads to the allowance of fishmeal in organic poultry feeds).
We support the limiting of individual ingredients for individual species
where a rational case exists (for example limiting the fat or vegetable
content of salmon feeds), but arbitrary blanket limits on ingredients
such as the previously proposed 12% for fishmeal and oil serve no
purpose, encourage the use of higher levels of nutritionally inferior
ingredients, and risks negative impacts on animal welfare.

We would urge the NOSB to examine the IFOAM Basic Standards sections on
aquatic animal nutrition (IFOAM, 2005), to reconsider the use of
sustainable sources of fishmeal and oil, and to give a balanced
perspective to the reality of feeding any farmed animal.

**Open Water Net-cage\* Containment Systems**

***(\*Note: we recognize that the terms net-pen and net-cage are
increasingly used interchangeably, so for this document only, both terms
are referring only to floating systems.)***

**[Current NOSB Livestock Committee Recommendations:]{.underline}**

\(j\) Open water net-pens and enclosures are (not) permitted (at this
time.)

**[IFOAM Aquaculture Group Suggested Revisions:]{.underline}**

\(j\) Open water net-cages and enclosures are permitted where water
depth, current velocity, direction, and other factors act to adequately
disperse metabolic products in order to minimize accumulation of
discharged solids on the sediments under net-cages. However, water
currents should not cause fish to expend excessive energy to swim and be
unable to consume feed. Monitoring shall be employed to ensure that the
natural assimilative capacity at the site and adjoining waters is not
exceeded. Facility managers shall take all practical measures to prevent
transmission of diseases and parasites between cultured and wild aquatic
animals. Use of multiple species of aquatic plants and animals to
recycle nutrients must be included in every Organic System Plan for
net-cages. Except as may be provided in § 205.601 or § 205.602, chemical
treatment of biofouling organisms on nets is not allowed. Any open water
net-cage or enclosure site must not have prohibited substances, as
listed in § 205.105, applied for at least one year prior to beginning
organic management.

**[IFOAM Aquaculture Group Comments and Supporting
Documentation:]{.underline}**

The IFOAM Basic Standards do not make specific reference to net-cage
operations, instead relying on the General Principle 9.1 that
\..."***organic aquaculture production reflects the diversity of species
and production methods***." Still IFOAM Aquaculture Standards require
that "***Operators shall take adequate measures to prevent escapes of
introduced, or cultivated species and document any that are known to
occur***" (IBS Section: 9.2.2), and that "***Operators shall take
verifiable and effective measures to minimize the release of nutrients
and waste into the aquatic ecosystem"*** (IBS Section 9.2.3) as these
standards are relevant for any type of aquaculture system, not only
net-cage operations.

Like all food production systems, an open water net-cage system for
farmed fish clearly has an impact on the environment, but if
appropriately sited, managed and fallowed, the effects are minimal. A
report by the Scottish Executive on the Scottish salmon farming industry
concluded: *"impacts on the seabed are 'insignificant in terms of the
total coastal resource' and 'except in a few enclosed waters, enrichment
by fish farm nutrients is too little, relative to natural levels, to
have the alleged effects* *\[changes in the number, species or
toxicity's of phytoplankton blooms\]"*

Ref - Scottish Executive, 2002, Review and Synthesis of the
Environmental Impacts of Aquaculture

A comprehensive (five year) study by the Scottish Association for Marine
Science concluded: "*we were not able to detect any clear environmental
impact of medicine usage, or indeed any other farm activities, beyond
the local scale"*

Ref - Scottish Association for Marine Science. 2005. Ecological effects
of sea lice medicines in Scottish Sea Lochs. 222p

All farming systems are 'open'. A timely reminder is the ongoing global
alert for new cases of avian flu transported by migrating wild birds
(and the recent infection of one of the UK's most biosecure poultry
units). Terrestrial farms are open to wild animals, animal-borne and
airborne pests and diseases in exactly the same way as aquatic farms,
and can transfer diseases and parasites from wild to farmed animals and
vice-versa. Terrestrial farms are continually subjected to a cocktail of
chemicals from wet and dry deposition, and they also release large
amounts of solid, liquid and gaseous wastes into the surrounding
environment. There are concerns for the impact on wild salmonids from
sea lice and escapees. The risks are real, and this is the most
troublesome aspect of open-water systems. Whether they are acceptable
for an organic system or not must be judged against the impact of
terrestrial farms on terrestrial wildlife.

Major improvements in net cage operations in recent years suggest that
these systems, while still high risk, are worthy of considering for
organic aquaculture certification. At issue is a proven track record of
demonstrated environmental responsibility therefore, in addition,
implementing a conversion period (similar to required terrestrial crop
conversion periods) could possibly be used to demonstrate the operator's
commitment to environmental protection (including water quality, benthic
substrate, containment of cultured organisms, biodiversity protection)
of the site. The IFOAM Basic Standards Section 9.1.2 requires that
"***The conversion period of the production unit shall be at least one
life cycle of the organism or one year, whichever is shorter***" and IBS
Section 9.1.3 requires that "***Operators shall ensure that conversion
to organic aquaculture addresses environmental factors, and past use of
the site with respect to waste, sediments and water quality***."

Open-water net-cage farming systems are currently used for the organic
production of salmon, cod, tilapia, seabass, sea-bream, sea-trout, basa
catfish and cobia. If adequately sited and run at a defined intensity,
there is no clear reason that they should not qualify as organic
operations in the US as they do in Europe or elsewhere. With a push
toward increased offshore production of food fish in the US, these
systems are likely to continue to develop and improve. At the maximum
stocking density permitted by the existing European organic aquaculture
standards, the fish take up a maximum of 1% of the space in the pen (2%
for some species of fish). The pen floats in the fish's natural
environment. The biodiversity surrounding an open water fish farm is
much closer to pre-farm levels than that of a terrestrial farm, and
overall we consider that these systems are appropriate under the IFOAM
Basic Standards for Organic Production.

Respectfully submitted,

Deborah Brister

Chair, IFOAM Aquaculture Group