Please note: COABC's Aquaculture is currently not within the scope of the Canada Organic Standards, but members of the aquaculture industry, the Department of Fisheries and Oceans and Agriculture and Agri-Foods Canada are developing organic aquaculture standards. If you have comments (pro or con) with regards to the development of Organic Aquaculture Standards, please submit these to the forum .
White Paper: Developing Organics Standards for Molluscan Shellfish
The development of organics standards for molluscan shellfish has been problematic within the context of general aquaculture practices. Several topics which need to be considered differ significantly between these two distinct operating systems. The Aquaculture Working Group was unable, within the allotted time frame, to develop standards that addressed issues specific to shellfish. Shellfish aquaculture could comply with those sections in the Final Report that are relevant, but there are gaps that must be addressed specific to shellfish farming and areas of the report that have no bearing on the industry at all. This White Paper is intended to provide the NOSB with relevant information not contained in the Final Report, in the hope that organics standards for shellfish will be developed.
Background: How are shellfish farmed?
Molluscan shellfish farming is very unlike other fisheries operations in that mollusks tend to be stationary creatures. The practices employed by shellfish farmers and harvesters is in many ways more akin to vegetable crop production than to wild or aquaculture fisheries. Farmers plant or set oyster, clam, mussel, scallop or geoduck seed in a designated area, watch over their crops during grow out (18 months to 5 years, depending on the species, location and environmental variables) and then harvest their crops much as a farmer would harvest corn or soybeans. In some instances, shellfish may be moved at some point during maturation to another carefully demarcated area to optimize growth.
Shellfish planted for grow-out graze strictly on the microalgae found naturally in the water column. Shellfish differ from both finfish and vegetable crops in that fertilizers and feed are not used and antibiotics, vaccines, biologics and growth hormones are not used. The rare exception to this could occur occasionally in the hatchery (larval) phase when antibiotics may be used.
Increasingly growers are utilizing hatchery raised seed, rather than relying on wild-caught seed. In this case, antibiotics may, on rare occasion, be used in the earliest stages of larval development. This would be in all cases prior to what has been referred to in the Working Group as "spat," which has been defined as seed that has reached 10 mm. By this time, shellfish seed has been set out for growth, and the recommendations of the Working Group is that this is the point in time when the "organic's clock" would start ticking. In either event, the National Organics Program (NOP) Final Rule, Section 205.204 (a) (1) provides that "Non-organically produced, untreated seeds and planting stock may be used to produce an organic crop when an equivalent organically produced variety is not commercially available."
Food Safety: The Foundation for Organic Management
The public health regulations governing shellfish farming and harvesting are among the strictest imposed upon any food producer in the U.S., and pose an excellent foundation that aligns well with organics standards. Although the argument has been well presented that Organics Standards is about process, not food safety, the public health safety standards the shellfish industry operates under also lends itself well to developing organic management systems due in part to the boundaries that are required for farming in the open water.
The National Shellfish Sanitation Program (NSSP), under the auspice of the FDA, is the standard used in every shellfish producing and receiving state in the country. It requires that both farmed and "wild" harvest growing areas be distinctly demarcated. Each growing area must be tested for pathogens for several months or years (depending upon the environmental variables such as nearby shoreline homes and septic systems, industries, etc.) before they are classified.
Growing areas are classified according to water quality as determined by fecal coliforms which are the national indicator species used by the FDA to determine the presence of warm blooded animals, considered to be the most likely vector for potential pathogens. The Approved classification is reserved for areas with the highest level of water quality and allows harvest at all times; Conditionally approved areas include those areas where fecal coliforms levels spike above the maximum level during or after storm events. Harvest is therefore allowed only when there has not been a recent storm event. (Each area has a specific number of required closure days after a specific amount of rainfall which is uniquely developed according to environmental variables for each area); A Restricted classification applies to areas where fecal coliforms counts are routinely higher than the maximum level allowed by the NSSP and requires that product be relayed out to an Approved or Conditional area to purge for several months. Health regulators perform regular shoreline surveys to assure growing areas are not in proximity to sewer outfalls, marinas, industrial effluent discharge areas or other potential sources of contamination. Areas within these zones are disqualified for consideration as growing areas and classified as "Prohibited."
Under the NSSP, the shellfish industry is required to have fully implemented individual Hazard Analysis Critical Control Point (HACCP) plans that apply to the entire post-harvest period. It's up to each state's designated regulatory agency, in order to be in compliance with FDA, to inspect every commercial shellfish company annually. Surprise visits may also occur and do.
The NSSP requires harvesters to use tags on each container of shellfish which list the company name, harvest location and date. Wary consumers are advised to ask to see these tags prior to purchasing shellfish in restaurants or markets to assure they have been commercially produced. It is illegal to sell shellfish to the public without the proper commercial certification. Unfortunately, illegal purchase does occur. Shellfish illnesses are most often caused by product that has been recreationally harvested in areas that are off-limits, or purchased from non-commercial or foreign purveyors who lack NSSP certification and harvest from contaminated areas.
The Principles of Organic Agriculture as it Applies to Shellfish Farming:
The case for developing organics standards for shellfish is well founded on the principles as specified in the National Organics Food Production Act (OFPA) of 1990, the National Organics Program (NOP) Final Rule, the Federation of European Aquaculture Producers' Code of Conduct, the International Federation of Organic Agriculture Movements (IFOAM) and James Riddle's paper on "Organic Aquaculture - Meeting Fundamental Organic Certification Requirements: Similarities and Differences Between Terrestrial and Aquatic Organisms."
The Organic Food Production Act stipulates that to be certified organic, the farmed area must be managed and monitored within clearly marked boundaries. The OFPA also provides specifically for management of wild crops, (Section 6513) requiring that the areas: 1)be designated as to where crops will be gathered or harvested; 2)have a three year history showing no prohibited substances have been applied; 3)have a plan for harvesting the crops to guard against environmental destruction and assure sustainability in the growth and production of the wild crop.
The OFPA provides that the Board shall advise the Secretary concerning the testing of organically produced agricultural products for residues. Under General Requirements in OFPA, there is also a provision for requiring periodic residue testing.
NOP Final Rule: Organic Production and Handling Standards:
While the language under "Soil fertility and crop management practice standard" is written specific to terrestrial agriculture, similar principles of operations can be articulated specific to the benthic and epibenthic communities of the marine environment. The guiding principle behind this section is akin to the Environmental Codes of Practice currently being drafted by enclaves of shellfish growers across the country, the essence of which is to utilize cultivation methods which maintain or improve the physical, chemical and biological conditions of the marine ecosystem.
Code of Conduct for the Federation of European Aquaculture Producers (FEAP):
The tenets of these codes, which is to operate aquaculture operations in a sustainable manner that avoids negative impacts on the environment, parallels the Environmental Codes of Practice currently being developed and implemented by the shellfish industry.
IFOAM Basic Standards 6.8.1:
The IFOAM states that "Aquafeeds shall generally contain 100% certified organic components, or wild aquatic feed resources. When wild fish are used, the Code of Conduct for Responsible Fisheries (FAO, 1995) shall be followed." If this is an accepted standard for a large segment of the international organics community, is there a scientifically sound basis for disallowing a similar standard in the U.S.? Is it advisable to set standards in the U.S. that will put our producers at a disadvantage without sound science to justify it?
James Riddle's "Organic Aquaculture - Meeting Fundamental Organic Certification Requirements":
This guidance document states that: "Organic agriculture is based on holistic production management systems which promote and enhance agro-ecosystem health, including biodiversity, biological cycles and biological activity." Molluscan shellfish aquaculture meets each of these criteria. 1)Molluscan shellfish are not fed so there are no nutrients being added to the marine environment. Molluscan shellfish are biofilters which feed on phytoplankton which occurs naturally in the water. This biofiltering activity has the beneficial secondary effect of taking up nutrients and purifying the water column, thereby "enhancing ecosystem health." Shellfish also create habitat for other marine creatures. As three-dimensional structures, shellfish are host to flora and fauna which make their homes in shellfish beds. These beds also provide cover and forage for species such as salmonids during their juvenile out-migration stage, enhancing biodiversity, biological cycles and biological activities through the creation of critical habitat.
Mr. Riddle's paper concludes with "Unresolved Questions" which include "What water quality standards are appropriate?" and "Will aquaculture standards need to require that regular, periodic residue analysis and water quality monitoring be conducted?" The answer to both these questions has already been answered through the NSSP, as described above under the Safety considerations.
Concerns Raised Regarding Development of Organic Shellfish Standards:
1. Shellfish live within an environment that cannot be completely controlled, including "grazing" on naturally occurring microalgae.
There is a parallel between shellfish and terrestrial animals that are allowed to graze. Terrestrial farmers cannot control acid rain, groundwater, 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 NOP Final Rule addresses this by providing that the organics certifier has the ability to require residue testing.
2. Organic livestock must be fed 100% organic feed their entire lifespan.
If this is to be a requirement for organic certification, then how can terrestrial animals that graze qualify for certification? If this is the required standard, why does the OFPA and the Final NOP Rule allow for wild harvest when this requirement cannot be reasonably assured? Why are there exceptions for wild blueberries or for honey, where the bees' movements cannot be tracked with complete assurance?
3. Shellfish can pose health hazards because of contamination of naturally occurring pathogens in the water.
Organic standards are predicated on farming management principles, not safety issues. This fact notwithstanding, the NSSP provides a very reliable means for assuring consumer safety that statistically has proven more effective than consumer safety systems for other proteins such as chicken and beef. Furthermore, safety issues have not prevented other livestock from qualification for organic certification so this concern should not hamper shellfish certification.
The argument made by some that the Organics label should confer a higher level of safety and quality may not be consistent with the stated purpose and principles of an organic standards program, but it is interesting to note that IF shellfish were labeled organic, that would in fact be an assurance that they were sourced from a reasonably reliable commercial producer, as opposed to purchased from a shellfish pirate out of the back of his truck on a 95 degree day.
4. Open water molluscan shellfish aquaculture is akin to "wild" stock issues, therefore we must wait until a decision on the "wild" issue is determined before moving forward.
The open water debate does suggest a kinship with "wild" raised fish, but given the stationary nature of mollusks and the fact that growing areas have determined boundaries which are regularly monitored and managed, the similarities with terrestrial agriculture is a closer parallel.
The Underlying Philosophy:
Fred Kirschenmann has posed some critical questions in his paper "Philosophy Underlying Certification of Wild Harvested Organisms Used in Aquaculture" that was presented at the ISEES Organics Aquaculture Conference in Minneapolis in June 2000. These questions bear close examination as we determine how to develop standards for aquaculture, and may require a re-examination of some of the assumptions underlying terrestrial agriculture.
"Organic agriculture did not emerge as an effort to create these little enclaves of purity within a degraded environment," writes Kirschenmann. "They emerged as a way to do agriculture." He urges us to not get locked into a paradigm of creating enclaves of purity. How do we create whole systems that are ecologically vibrant with ecological integrity? How do we identify and restore healthy ecological neighborhoods?
These imperatives are instrinsic to growing shellfish. Commercial production requires a healthy watershed. As a result, growers have a long history as stewards of the ecosystems they depend upon and in many ways are a prototype - a kind of "poster child" - for sustainable and organic agricultural systems.
Ideally, as New Zealand mussel grower Bill Floyd articulates: "If huge volumes of food production met the organic philosophy - isn't that a good thing? Is an organic standard a failure if it doesn't create a price premium? Organics is about safeguarding Gaia . . . If an industry is intrinsically okay and it could be called organic without too many alterations, simply because it was never doing much wrong to start with, is that a bad thing?"
Given this kind of argument, questions have arisen regarding what makes organic growers different from conventional ones? In general, shellfish aquaculture principles and practices are, indeed, by the very nature of the business, akin to organic management. But this is not to say that growers interested in obtaining organic certification would not be required or willing to raise the bar higher through, for example, lot testing or regular residue testing beyond what is currently required of commercial growers. And there are certain to be farms that include practices that will not meet organic criteria and many others that will have no interest in applying for certification. But this is outside of the debate. The first question we need to answer is: Should organics standards for shellfish be developed? If the answer is "No," then we need to define, within the context of the OFPA and the NOP Rules, why shellfish are not a fit.
If the answer is "Yes, shellfish standards should be developed," then our next task is to determine what measures should be put into place to differentiate "organic" shellfish from "non-organic" shellfish.
Areas for consideration in establishing criteria and management plans for organic molluscan shellfish standards:
Note: It will be critical to consider these possible options carefully with the full involvement of the shellfish industry and organics experts to assure equitable and implementable standards are developed. These are presented merely to begin the discussion.
To obtain organic molluscan shellfish certification:
1 a) Require shellfish growing areas to be in the "Approved" classification status for three consecutive years and require periodic lot testing at intervals of 6 months. OR
1 b) For Conditionally Approved growing areas, and only during the "open" status, require lot testing once a month during "dry" weather periods or once a week during periods of intermittent rainfall. Following periods of closure due to rainfall, require testing on the first lot harvested once the areas achieves "open" status again.
Note: Testing for pathogens in shellfish growing areas will be conducted by an FDA certified laboratory, in accord with the NSSP.
2. Require shellfish growers to adopt Environmental Codes of Practice that include farm plans that explicitly describe their sustainable and conservation management farming and processing systems.
A Final Note For Consideration:
Borrowing from the concept of land-bank mitigation and the use of "pollution credits," consider the following:
One of the contentious issues surrounding finfish aquaculture in open water systems is the management of nutrients (waste). A simple solution is at hand. Require shellfish beds to be set beside net pens. The shellfish will feed on the nutrients expelled by organically produced finfish which means they will be feeding on what could reasonably be construed as organic nutrients within a managed controlled system. The shellfish get fat and happy on these organic nutrients while neutralizing the effects of the finfish waste, purifying the surrounding water and eliminating the potentially damaging effects of over-nutrification. A win-win for everyone. It's the aquatic model of the "partner farms" concept postulated in the Netherlands as ideal organics management.
Prepared by Robin Downey, Executive Director Pacific Coast Shellfish Growers Association
120 State Avenue NE PMB #142 Olympia, WA 98501, USA
360-754-2744 FAX: 360-754-2743
For further information on the National Shellfish Sanitation Program and the contact: Ken Moore, ISSC Executive Director at 803-788-7559 ISSC or via www.issc.org
Original material in this website may be reproduced in any form without permission on condition that it is accredited to Cyber-Help for Organic Farmers, with a link back to this site or, in the case of printed material, a clear indication of the site URL. We would appreciate being notified of such use. Although care has been taken in preparing the information contained in this web site, Cyber-Help for Organic Farmers does not and cannot guarantee the accuracy thereof. Anyone using the information does so at their own risk and shall be deemed to indemnify Cyber-Help for Organic Farmers, from any and all injury or damage arising from such use.