USDA organic standards for fish feed

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USDA organic standards for fish feed

• Becky Goldburg
• Environmental Defense

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USDA organic standards

• Mandate from 1990 Farm Bill -- OFPA
• Based on considerable experience of organic
  farmers
• Helped create booming organic marketplace
• Gold standard for consumers

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USDA Aquatic Animal Task Force, 2001
Recommendations

• Organic certification not appropriate for wild
  fish
• Fishing not consistent with principles of organic
  production
• Certification appropriate for at least some types
  of organic production

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Marine Stewardship Council
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Organic seafood abroad

• Farmed fish already certified abroad
• Wild fish not certified organic

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Organic farmed seafood in the US

• Standards may not be consistent with expectations
  of US organic consumers
• California legislation bans sale
• Some US retailers will not sell until US
  standards established

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USDA Aquaculture Working Group

• Established in 2005
• Draft organic standards for most aquatic species
• NOSB recommended most provisions in revised draft
  to USDA in March 2007
• Draft standards for molluscs, July 2007

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There is no history of organic aquaculture to
inform standards
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And organic standards not created
with aquaculture in mind
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Key controversial issues for US organic standards

• Feed - US standards require 100 organic feed
  ingredients for livestock.
• Policy issue - Can organic fish be fed diets
  containing substantial amounts of fish meal and
  oil made from wild caught fish, which are not
  organic?

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Legal background natural substances

• Under OFPA, only natural substances may be used
  in organic production, unless synthetic
  substances are specifically named on the
  "National List" as eligible for use in certain
  types of organic production (e.g. for crops).

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Legal background feed

• Feed supplements are defined in US organic
  standards as a combination of feed nutrients
  added to livestock feed to improve the nutrient
  balance or performance of the total ration and
  are intended to be
• Diluted with other feeds when fed to livestock
• Offered free choice with other parts of the
  ration if separately available or
• Further diluted and mixed to produce a complete
  feed.
• Feed supplements must be organic or natural
  substances, except for non-synthetic substances
  specifically allowed as part of the National
  List.

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Arcane legal complication Senator Stevens 2003
appropriations rider

• Amended OFPA to specify that organic standards
  can be developed for wild fish.
• Legal Implication Wild fish are legally
  agricultural products, which must be organic in
  feed.
• Unclear Given that wild fish are agricultural,
  is it legal to allow wild fish in feeds as
  natural substances in the absence of organic
  standards?

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Legal background feeds

• In 2005, USDA clarified that fish meal is a
  natural substance as long as it has not been
  treated with synthetic preservatives or other
  substances, and may be used in livestock feeds
  including potentially fish feeds -- as a feed
  additive or supplement.

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Possible resolution

• Limited quantities of fish meal and oil from
  certain types of sources will be allowed in
  organic feeds during a transition period, after
  which none will be allowed.
• Question Should byproducts from organic poultry
  or meat production be allowed in organic fish
  feeds?

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Process to resolve issues

• NOSB Aquaculture Symposium, November 27, 2007
• NOSB recommendations on outstanding issues,
  likely spring 2007
• USDA then promulgates organic standards

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Organic standards incentive for innovation

• Organic price premium creates financial incentive
  for innovation to meet standards
• May be only opportunity in marketplace for such
  strong incentives