Most Americans surveyed opposed the lax requirements proposed for a USDA Organic label on farmed fish; we find deep nutritional and eco pitfalls in the proposals
by Craig Weatherby
A heated battle has raged for years over the rules that would govern issuance of a USDA Organic label for qualifying farmed fish.
We find it inherently absurd that the USDA is poised to allow an organic label on ocean-farmed fish… but not on wild fish.
After all, most wild fish would rival or surpass any “organic” ocean-farmed fish in terms of naturalness, purity, nutritional value, and health benefits… regardless of how the battle over the regulations proposed to govern organic fish farming turns out.
Sadly, that battle may end in compromises that deliver the worst of all possible worlds, as we’ll explain.
Panel set to allow unsustainable “organic” fish farming
The bad news starts with the regrettable decisions made last month by a USDA panel, which have been decried by consumer and conservation groups.
On November 21, 2008, the USDA’s National Organic Standards Board (NOSB) voted to approve proposed regulations that would free industrial fish farms from key principles and rules that govern production of organic meat and poultry.
The comment period closed after a November 17 hearing, after which the NOSB approved revised regulatory proposals for organic fish farming.
But it is not too late to influence the final regulations by writing to your congressional representatives.
This article summarizes some key concerns raised by the USDA board’s ill-considered rules for certifying farmed fish as “organic”.
The organic label implies a high standard of environmental sustainability and human healthfulness that farm-raised carnivorous fish—particularly farmed salmon—would remain very far from meeting under the proposed rules for labeling farmed fish “organic”.
Here’s the full story.
Proposed rules set organic principles and optimal nutrition in opposition
Critical comments submitted to the NOSB by various environmental and consumer groups reveal a contradiction inherent in the idea of farming carnivorous fish like salmon.
On one hand, existing U.S. organic food production law says that organically raised livestock can only be fed certified organic feed.
The organic advocates’ stance on feed for organic farmed fish flows from the principle—written into the U.S. organic food act—that organic livestock must be raised on organic grains grown without petrochemical fertilizers and pesticides.
Organic livestock feed is presumed to be purer and more sustainably produced than conventionally grown corn and cereal grains.
Judging by this standard, farmed fish should not be fed any wild fish, for two reasons:
- As a practical matter, wild fish cannot be certified as “organic feed” as that term is defined in existing U.S. law.
- Feeding wild fish to farmed fish is an inherently unsustainable practice that threatens wild fish stocks.
Those who criticize the USDA panel’s decision to allow wild fish to make up a portion of feed given to organic farmed fish point to the contamination potential involved.
As the USDA’s critics accurately state, conventional farmed salmon display levels of organic pollutants (e.g., dioxins and PCBs) much higher than wild salmon precisely because they are fed concentrated amounts of fatty wild fish of variable purity.
Dioxins, PCBs, and similar organic pollutants accumulate in fish fat. However, even the relatively high levels in farmed salmon are vanishingly small, compared to those that can promote cancer in animals. The even more minuscule amounts found in wild salmon—a few parts per trillion—are considered completely safe.
(Click here to see the relative PCB levels of various foods, including wild and farmed salmon.)
And if, to harmonize their feed standards with those set for organic livestock, organic farmed fish were not fed wild fish or fish oil, this would compromise the animals’ own health and their nutritional value to humans.
Let’s explore that conundrum further.
New proposals make “organic” farmed fish less healthful than wild fish
To mollify the critics with regard to use of wild fish in farmed fish feed, the USDA board took two steps in their revision of the recently approved regulatory draft.
Compromise #1 - Limited proportion of wild fish in organic fish feed
First, the recently approved draft rules would only allow the feed given to “organic” fish to contain 25 percent wild fish … and that proportion would gradually drop to a maximum of five percent wild fish 12 years after the proposed regulations become law.
Consequently, the remaining 75 to 95 percent of feed given to organic farmed carnivorous fish like salmon would be certified-organic grains, seeds, and seed oils.
These land-based plant foods are absent from the diets of wild fish, which evolved and thrive on marine-source diets of seaweed, aquatic plants, plankton, and prey fish.
By limiting the amount of wild fish allowed in their feed, the proposed rule would result in organic farmed fish that are as high in pro-inflammatory omega-6 fatty acids as their non-organic counterparts.
Why is this mandated dietary distinction—one inserted to meet the objections of people who don’t want wild fish fed to farmed fish—important?
Clinical research shows that people who eat farmed salmon raised on standard, grain-heavy chow display high levels of pro-inflammatory immune system chemicals in their blood: levels associated with higher cardiovascular risk (See “Farmed Fish Possess Unhealthful Fat Profiles.”)
In other words, the restriction on use of wild fish meal would make organic fish similar to standard, grain-fed beef and pork in terms of their pro-inflammatory potential in the body: hence, substantially less healthful than their wild counterparts.
Since most people perceive the “organic” label as signaling a healthier, more natural food, allowing the organic label on fish raised largely on grain would be highly misleading.
Compromise #2 - No more than one pound of wild fish for every pound of farmed fish
The second and more sensible compromise inserted in the newly approved proposals is that no more than one pound of wild fish could go into producing each pound of farmed fish… a so-called 1:1 feed-conversion ratio.
Since conventional farmed fish are typically fed three pounds of wild fish for every pound they weigh at harvest, this step seems to increase the sustainability of farming carnivorous species like salmon.
However, while the new proposed standards say that the wild fish fed to organic farmed fish must come from “sustainable” fisheries, they include no clear requirements for certifying these fisheries’ sustainability.
The USDA also claims that a required contaminant-testing program for organic feed would cover wild fish fed to organic farmed fish.
However, farms would only be subject to feed testing once every five years, which is clearly inadequate to catch polluted wild fish.
And it would not prevent desperate fish farms from illegally adding prohibited pesticides and antibiotics to fish feed in order to control the parasites and infections that commonly plague salmon farms and other fish raised in offshore net pens.
The NOSB says it would rely on conventional fishmeal production systems to self-regulate, and to separate sustainable and threatened species, but that will be very difficult to do and police.
Can organic fish come from polluting systems?
In a substantial shift from earlier drafts, the proposed rules would allow the use of open-water net pens and cages, whose mesh walls allow pollution, disease and parasites to flow freely into the ocean.
Net pens are used at all salmon farms, and their inability to contain waste, drug residues, and parasites threatens wild fish and the overall health of the oceans.
Consumers Union—the folks behind Consumer Reports magazine—criticized the permitted use of net pens for organic farmed fish as inherently incompatible with organic principles (key points underlined for emphasis):
- “The recommendation for net pens and related management issues should be rejected altogether. The use of open net pens is not only controversial in the discussions around organic fish standards but for conventional aquaculture production.
- “In fact, the use of open net pens is banned in California and Alaska precisely because of the widespread environmental damage from these systems.
- “Consumers Union concurs with comments from the Coastal Aquaculture Alliance and Food and Water Watch regarding the use of open net pens as environmentally destructive.
- “Again, our poll data shows that the overwhelming majority of Americans (more than 90%) do not want organic fish to come from polluting systems…” (CU 2008).
We agree that raising fish in open ocean net pens violates organic and sustainability principles very seriously.
The NOSB addresses this concern in its proposed rules, which say that open net pens would only be permitted “…in situations where water depth, current velocities and direction, stocking densities and other factors act to adequately disperse metabolic products in order to minimize any negative impacts on the environment in areas surrounding the pen locations.”
If enforced, this provision would mean that the only organic fish farms allowed to use net pens would be ones sited far from shore, in places where currents consistently disperse and dilute waste matter.
But the major backers of the proposed organic fish label are multi-billion-dollar industrial salmon farm companies using net pens sited close to shore, which are relatively cheap for the producers, but emit waste and parasites that can damage the ocean environment and wild fish badly.
The public record shows that open net salmon farms inevitably allow escapes that threaten the genetic integrity of their wild counterparts, and fuel the spread of sea lice and infectious diseases to wild fish.
(For more on the problems linked scientifically to net pen salmon farms, search our newsletter archive for “farm”.)
Industrial salmon farmers possess great economic and political power, and this leverage gravely undermines our confidence in the USDA’s ability to resist demands to permit problematic net pen systems at “organic” fish farms.
Consumer survey finds American oppose organic fish rules
A recent poll by Consumers Union revealed that most American consumers reject the lax rules proposed by the NOSB for organic fish (CFS 2008):
- Nine in 10 respondents said that fish labeled “organic” should be produced by 100 percent certified-organic feed, like all other organic livestock.
- Nine in 10 respondents also agreed that “organic” fish farms should be required to recover waste and not pollute the environment, and 57 percent are concerned about ocean pollution caused by “organic” fish farms.
The NOSB proposals were criticized in comments submitted by Urvashi Rangan, PhD, Senior Scientist at Consumers Union, “It’s a disservice to the organic program and to consumers that the NOSB is ready to undermine the organic marketplace which relies on a higher bar for environmental health practices being met” (CFS/CU 2008).
“These recommendations do not meet the same bar for other organic livestock production practice and in fact lower the bar, which if enacted will compromise organic quality, value, and undermine consumer confidence—not only in the organic fish that they buy but in organic foods on the whole” (CU 2008).
Collectively, Consumers Union, the Center for Food Safety, and Food & Water Watch gathered nearly 30,000 signatures in favor of maintaining strong standards for the organic label for fish.
“Consumer trust in the integrity of the organic label is at stake,” said Patty Lovera of Food & Water Watch. “But unfortunately, the NOSB wants to allow the farmed salmon industry to cash in on the organic label without meeting the basic tenets of organic production” (CFS/CU 2008).
Conservation groups reject organic fish rules
Last year, a broad coalition of concerned advocates from 44 organizations—collectively representing more than one million stakeholders and concerned citizens—voiced urgent concern that the NOSB not weaken the standards embodied in the laws governing organic food production.
The co-signing organizations concluded that only one kind of fish farming—onshore farming of herbivorous (plant-eating) finfish in enclosed containment ponds—could meet existing organic livestock standards.
But they all agreed that the farming of carnivorous finfish—such as salmon—in open net cage systems is inherently incompatible with current organic standards and the principles upon which they are based.
“Allowing net pens to be used on fish farms certified as ‘organic’ weakens the incentive for producers to use innovative technologies like closed containment”, said Shauna MacKinnon of Living Oceans Society, a member of the Coastal Alliance for Aquaculture Reform. “The industry needs technology that controls impacts, not standards that endorse the status quo” (CFS/CU 2008).
We agree that the USDA’s National Organic Standards Board should limit the organic label to fish that eat 100% organic feed and are produced in closed, controlled production systems where waste is not flushed into the environment.
Otherwise, the Board should recommend that farmed fish and seafood cannot meet the current bar for organic standards and are therefore ineligible for an “organic” label.
Given the power of the aquaculture industry, it will take steady public pressure on Congress to reverse the USDA’s unwise moves.
Organic-fish rules may preclude non-native species
Depending on how you read the rather vague language in the regulations the NOSB approved last month, it could effectively disqualify non-native species raised in open ocean net pens.
That means the overwhelming majority of fish produced by salmon farmers in British Columbia and Chile would not qualify for the USDA’s organic label.
Atlantic salmon account for most of the salmon produced in Western Canada’s $350-million aquaculture industry, and 90 percent of those fish are shipped to the United States.
Atlantic salmon are alien to the Pacific Ocean, and were brought to the West Coast only because they have proven cheaper and easier to grow in captivity than indigenous species such as King (Chinook) and Silver (Coho) salmon.
Sockeye Salmon have so far proved impossible to farm-raise successfully.
- Center for Food Safety (CFS). New poll reveals that proposed organic standards for fish will fail to meet consumer expectations. November 13, 2008. Accessed online November 23, 2008 at http://www.centerforfoodsafety.org/NOSBaquaPR11_13_08.cfm
- Consumers Union (CU). Comment to National Organic Standards Board on Aquaculture Recommendations; Submitted by Urvashi Rangan, Ph.D., Senior Scientist and Policy Analyst, on behalf of Consumers Union, non-profit publisher Consumer Reports. November 18, 2008. Accessed online November 23, 2008 at http://www.greenerchoices.org/pdf/Public%20Comment%20Submission%20to%20National%20Organic%20Standards%20Board%20on%20Aquaculture%20Recommendations.pdf
- Consumers Union (CU). New Poll Reveals That Proposed "Organic" Standards for Fish Will Fail to Meet Consumer Expectations. November 13, 2008. Accessed online November 23, 2008 at http://www.consumersunion.org/pub/core_food_safety/006297.html
- Living on Earth/World Media Foundation. Down on the (Organic) Fish Farm. Accessed online November 23, 2008 at http://www.loe.org/shows/segments.htm?programID=08-P13-00047&segmentID=4
- National Organic Standards Board (NOSB) Livestock Committee. Proposed organic aquaculture standards: Net Pens and Related Management Issues. September 28, 2008. Accessed online November 23, 2008 at http://www.ams.usda.gov/AMSv1.0/getfile?dDocName=STELPRDC5072722
- Simpson S. Organic label may elude B.C. salmon farmers. Vancouver Sun. Saturday, November 22, 2008. Accessed online November 23, 2008 at http://www.canada.com/vancouversun/news/business/story.html?id=2f6c02d3-c224-4a59-8c17-c95601841f54