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ECCAP WG13 Aquaculture draft for contributions 1

Energy Flow, Environment & the Ethical

Implications of Aquatic Meat Production

Preliminary Draft and Outline calling for contributions

to the second report of ECCAP Working Group 13

Ethics and Climate Change in Asia and the Pacific (ECCAP) Project, RUSHSAP,UNESCO, Bangkok

Preliminary Contributors in alphabetical order:Gerard Foley, Robert Kanaly (*), Lea Ivy O. Manzanero (*)

(27 August 2011)

Please email to:Dr. R. Kanaly (Email: [email protected]);Ms. Lea Ivy Manzanero (Email: [email protected])

Dr. Darryl Macer (Email: [email protected])

* Co-chairs

PrefaceThis report will follow the first publication of WG13: Energy Flow, Environment andEthical Implications for Meat Production (Robert A. Kanaly, Lea Ivy O. Manzanero,Gerard Foley, Sivanandam Panneerselvam and Darryl Macer; RUSHSAP, UNESCO

Bangkok, 2010), which focused on industrial style agriculture with land animals. Thissecond report will examine similar issues from the expanding use of aquaculture.Submissions of case studies from different communities are requested, along with generalcontributions to the relevant sections listed below.


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Draft Outline

I. Background information on aquaculture in general and intensive aquatic meatproduction.

II. Intensive aquatic meat production as it relates to harvesting wild stocks (includingintensification in open sea capture fisheries).

III. Past and future trends in global consumption and production of aquatic meat.

IV. Forces that are driving increases in demand for aquatic meat.

V. General explanation of energy flows and economics in aquatic meat production.

VI. Impacts of climate change on intensive aquatic meat production and vice versa

VII. Discussion that highlights some of the major sectors of intensive aquatic meatproduction, including inputs and outputs in each sector and negative cost externalizations.Issues that may be explored in regard to negative cost externalization include:

1. Coastal and deep sea pollution, ecosystem deterioration, mangrove destruction.2. Fate and consequences of the production of multi-antibiotic-resistant bacteria throughthe heavy use of pharmaceuticals.3. Effects of escaped farmed fish from enclosures: interbreeding with the naturalpopulations, eating or displacing them including issues of genetic modification.4. The relationship of aquatic meat production to avian influenza and the potential forcausing regional and global infectious disease pandemics.5. As is the case for intensive land-based meat production, there are disease issues thatare a direct result of growing animals in high density, severely crowded conditions wherethe animals are already under a high amount of stress:

(a) Sea lice infestation(b) Infectious salmon anemia virus(c) Bacterial kidney disease(d) Vibrio salmonicida(e) Enteric septicemia(f) Salmon rickettsial disease(g) Vibrio species in penaeid aquaculture (which contributed to collapse in

aquaculture industry)6. Protein consumption versus production: Large finfish must eat many smaller fish forevery kilogram of finfish.7. Socioeconomics.8. Retail aquatic meat labeling and product traceability9. Contamination of aquatic meat with heavy metals.10. Contamination of aquatic meat with persistent organic pollutants.11. Hormone administration.12. Fish feed production and application from intensive land-animal meat production


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systems - Rendered meat and bone meal (MBM).13. Prions14. Considering issues related to radiosotopes in the aquatic meat food chain15. Lack of testing and/or release of data to the public.

VII. Ethical worldviews and their influence on the decisions related to the consumptionof intensively produced aquatic meat.

VIII. Experiences and/or case studies from countries that use/have used such systems.

IX. Current policy and regulatory frameworks and policy options.


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I. Background information on aquaculture in general and intensive aquatic meat

production.Aquaculture is defined by FAO (2007) as the farming of aquatic organisms,

including fish, mollusks, crustaceans and aquatic plants. Farming implies some form of

intervention in the rearing process to enhance production, such as regular stocking,feeding, protection from predators, etc. Aquaculture differs from capture fisheries byhaving some control of the natural environment such as stocking, feeding, and watermanagement (BFAR-PHILMINAQ, 2007).

Aquaculture grew faster than any other food-producing sector and if sustained,will continue to augment capture fisheries production in response to global demand,

supplying more than 50 per cent of aquatic food consumption by 2015 (Bostock et al.2010). Aquaculture produces one third of all fish with almost half of all fish eaten (FAO,2007) and is also one of the fastest growing food production sectors in the world(Fishsite, undated). In 2008, FAO reported that aquaculture reached 142 million tonnes.Annual growth rate is at 6.2 percent from 38.9 million tonnes in 2003 to 52.5 million

tonnes in 2008 while total global capture production on the other hand stayed very steadyat about 89.8 million tonnes (FAO, 2008).ASEAN is a globally important aquaculture region (Worldfish and Primex, 2007)

with China generating 62 percent of world aquaculture production of fish, crustaceansand mollusks at 32.7 million tones (FAO, 2008). India produced 3.5 million tonnes, VietNam at 2.5 million tones, Indonesia at 1.7 million tonnes, Thailand at 1.4 million tonnesand Bangladesh at 1 million tonnes (FAO, 2008). Aquaculture production in thePhilippines reached 2,407,698 metric tonnes in 2008 (BAS, 2009). The volume ofproduction in aquaculture doubled with 1,220,456 metric tonnes in 2001 to 2,545,967metric tonnes in 2010 (BAS, 2011).

Species utilized in aquaculture production include carp for China and the rest ofAsia, while salmonids in Europe and South America. Prawns and shrimps, catfish,bivalves and salmonids dominate North American production (Worldfish and Primex,2007). Philippine aquaculture statistics indicate that at least 18 species are currentlybeing utilized with only 6 commodity groups or species namely seaweeds, milkfish,tilapia, penaeid shrimps (primarily the black tiger shrimpPenaeusmonodon, mussels andmud crabs (Scylla spp)contributing substantially either by volume or value (FAO, 2007)

China is by far the main exporting country followed by Norway, Thailand andDenmark. Developing countries play a major role in such exports, with the top nineexporters accounting for two-thirds of the developing country total by value (FAO,2008).


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II. Intensive aquatic meat production as it relates to harvesting wild stocks

(including intensification in open sea capture fisheries)IAM production can be defined as the high density production of aquatic animals

in a controlled environment for all or parts of their lifecycles. Examples include finfishsuch as catfish, trout, salmon, carp, and tilapia; mollusks such as clams, mussels, abalone,

scallops and oysters; nonfood species such as ornamental fish and baitfish; and otherssuch as alligators, turtles, and frogs. At the same time, the industry is continuouslyexamining the potential production of other aquatic species (Harvey, 1998).

In economic terms, externalities are third-party effects arising from the productionand consumption of goods and services for which no appropriate compensation is made.Externalities may cause market distortions if the price mechanisms do not take intoaccount the social costs and benefits of production and consumption. Negativeexternalities occur when production and/or consumption impose external costs on thirdparties outside of the market for which no appropriate compensation is made. IAMproduction methods result in various negative externalizations and they may takedifferent forms depending upon the type of production, location, environmental policy

and the degrees of enforcement and compliance among many other factors.A well-documented negative externality of IAM production is ecosystemdeterioration. Many forms of ecosystem deterioration as a result of IAM production havebeen reported over the last 30 years in many different regions around the world includingfrom both developed and developing countries (Dierberg and Kiattisimkul, 1996; Barbierand Cox, 2002; Paez-Osuna et al., 2003; Cao et al., 2007; Stokstad, 2007; Rosenberg,2008; Azad et al., 2009; Mayor and Solan, 2011) and the extents and types ofdeterioration are dependent upon many factors. Ecosystem deterioration may occurthrough the application and subsequent release of large amounts of chemical pollutantsthrough IAM production processes, through the production of large amounts of untreatedbiological waste materials or by direct and indirect effects on native species as a result ofIAM production practices for example (Graslund and Bengtsson, 2001; Stokstad, 2007;Rosenberg, 2008; Bendell, 2011).

Some of the potential risks and negative externalities of IAM production underconsideration are: (1) Ecosystem deterioration, coastal and deep sea pollution andmangrove destruction, (2) Consequences of the production of antibiotic-resistant andmulti- antibiotic-resistant microorganisms through heavy application of pharmaceuticals,(3) Effects of escaped farmed species from enclosures and potential for interbreedingwith the natural populations, and/or eating or displacing them, (4) The relationship ofIAM production to avian influenza and the potential for causing regional and globalinfectious disease pandemics, (5) The consequences of using fish feeds derived fromwild-caught species, (6) Contamination of aquatic meat with heavy metals and persistentorganic pollutants, (7) Contamination of aquatic meat with hormone and pharmaceuticalresidues, (8) Potential consequences of using rendered meat and bone meal (MBM) infish feeds originating from intensive land-animal meat production systems and (9) thepotential effects of IAM production practices on native species.


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III. Past and future trends in global consumption and production of aquatic meat. By 2008, worldwide aquatic meat production, often times called aquaculture,

exceeded 50 million tons and this represented a more than tripling of production whencompared to 1990. Additionally, the proportional contribution of aquatic meat productionto total food fisheries output increased from approximately 4% in 1970 to almost 43% in

2008. FAO projections indicate that total annual global fish harvesting, including wildand farmed species, is expected to increase from 129 million tons in 2000 to over 170million tons by 2015, and included in this assessment is the fact that aquatic meatproduction may account for greater than 70% of the total increase (FAO, 2011; Sapkotaet al., 2008). In 2008, China accounted for greater than 70% of total worldwide aquaticmeat production and overall, Asian countries accounted for greater than 90% of totalglobal production (Sapkota et al., 2008).

Current trends indicate that the majority of the increase in global production to2030 will come from South and Southeast Asia where India, Indonesia and Thailandprojected to become larger producers (Fishsite, undated). Major producer countries suchas China and Vietnam will continue their drive towards export to European and North

American markets.

IV. Forces that are driving increases in demand for aquatic meat

a) Market demandsIncreasing prosperity and urbanization are the key factors driving demand for animal

protein, including fish. Another factor is the relative price of other protein sources andincreased awareness of health benefits. The global biogeography of aquatic resources hasensured long-standing and varied patterns of consumption and trade throughout history(Young & Muir 2002a) while the recent globalization has been characterized by a declinein the costs of cross-border trade in farm and other products by reductions ingovernmental distortions to agricultural production, consumption and trade (Anderson,2001). Demand for fish in line with other protein foods will increase especially in parts ofEast and South Asia in which there is strong preference and majority of this extra demandwill be met by aquaculture (Garcia and Rosenberg, 2010).

b) Ethical concernThe ASEAN demand for meat is increasing which is already having impacts on the

environment (Worldfish and Primex, 2007). Ethical concerns may play an increasing rolein affecting the production and consumption of livestock products (Thorton, 2010). In

this respect, fish has an important advantage compared to livestock in terms of foodconversion efficiency since fish relatively score well in the way they convert a higherpercentage of the food they eat into consumable protein. This efficiency is attributed tothe low energy required to maintain a high body temperature. Compared with livestockwhich needs extensive skeleton, fish provides more portions available as food. On theaverage, it takes 3 kg of grain to produce 1 kg of meat, given that part of the production isbased on other sources of feed, rangeland and organic waste (FAO, 2006).


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c) Environmental sustainabilityAquaculture has some advantages over other types of animal source food production

for human consumption. On average, fish have a lower potential to cause eutrophicationthan pork or beef (Worldfish and Primex, 20070). Evidence also suggests thataquaculture contributes less to global emissions of nitrogen and phosphorus thanproduction of pork and beef (FAO, 2007). Aquaculture use of water is variable and can,in fact be lower than other animal production systems (Worldfish and Primex, 2007). Forexample, coastal aquaculture makes use of sea water rather than fresh. Inland aquacultureponds are drained and filled on a periodic basis but the water is often a form of waterstorage and seepage losses from ponds represent an ecosystem service, serving torecharge groundwater reserves (Worldfish and Primex, 2007).

V. General explanation of energy flows and economics in aquatic meat production.Aquaculture production is market-driven (Muir, 2005). More than 10 years ago

Naylor et al. (2000) reported that although aquatic meat production may be considered asa means to relieve pressure on ocean fisheries, the effects of some intensive productionmodels have opposite effects and this is due to the requirements for massive amounts ofwild caught species that are used in the fish feeds for intensively-produced carnivorousspecies. This outcome is one of various negative externalities that arise as a result ofintensive aquatic meat (IAM) production practices.

In the future, many developed countries will see a continuing trend in whichlivestock breeding focuses on other attributes in addition to production and productivity,such as product quality, increasing animal welfare, disease resistance and reducingenvironmental impact (Thorton, 2010) and with this, greater consideration of the impactof fishing at the ecosystem level, and not only on individual species, will be an importantpart of improving fisheries management (Pikitch et al. 2004)

VI. A. Impacts of intensive aquatic meat production

1. Environmental ImpactWhile producing food, employment, livelihood and wealth, fisheries can also

generate a significant level of environmental impact on target and non-target resources aswell as on sensitive habitats (NRC, 2002). In European Community waters, more than 80per cent of stocks are overexploited or depleted (European Commission, 2007). Central tothese concerns are the demands that aquaculture places on biophysical resources and thedemands placed on the environment from wastes (Worldfish and Primex, 2007).

Globally inland pond culture is the predominant production system and contributes

the greatest impact (Worldfish and Primex, 2007). Concerns of overfishing of marineecosystems also arise with a growing demand for fishmeal and fish oil from capture

fisheries.

2. Dependence on raw (trash) fish and fish mealFeed for aquaculture is a major bottleneck due to the limitations to the available oil

and fish for aquaculture feed (FAO, 2008). These materials are generally derived from


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shoaling marine pelagic species such as anchovy and sand eels, with the majority ofworld production originating in South America. World production remains fairly constant(67 mt/yr) in the face of rapidly increasing use in aquaculture, particularly for salmon,sea bass and sea bream, and shrimp (FAO, 2008)

Marine fishes appear to require high levels of mainly marine lipids. Fishmeals have

long been the protein source of choice, for reasons including their protein concentration,quality in terms of essential amino acid balance and digestibility, palatability, freedomfrom toxin and/or anti-nutritional factors which is a common problem with feedstuffs ofplant origin and their competitive cost per unit of protein (Hardy & Tacon 2002).

Reliance on high protein, fishmeal-based feed for carnivorous species often requiresmany pounds of wild fish to produce one pound of edible aquaculture product. There isan extreme dependence of cultured fish on wild-caught fish. Fish oil and fish meal, whichare essential ingredients of feeds, ultimately come from wild stocks. Tacon & Barg(1998) estimated that in 1995, global production of farmed carnivorous fishes andcrustacean, just over 3 mt, were fed with 1.5 mt of fishmeal, equivalent to some 5 mt of

small pelagic fishes. It has been estimated that aquaculture now uses some 20% ofcurrent world fishmeal production. It has also moved towards using higher grades ofmeal, made from the freshest fish and processed at low temperatures, as these offerimproved protein digestibility and palatability, leading to faster growth and lower FCRs(kilograms of food required per kilogram produced) (Pike & Barlow 2003). It has beenestimated that for every hectare of intensive salmon production, some 40 000 to 50 000ha of sea area are required for feed supply and waste processing (Folke & Kautsky 1992,1996).

Studies have shown that one-third of all wild-caught fish is used to make feed foraquaculture. It takes 10 to 22 kg of feed to produce 1 kg of tuna and takes 5-12 kg of feedto produce 1 kg of finfish such as grouper, snapper, and seabass using wet fish diets(WWF, undated) and 2 to 4kg of wild fish using dry diets. About 160,000 tons ofwildfish/feeds are wasted in tilapia pens, cages, and ponds while more than 180,000 tonsare wasted for bangus culture (BFAR-PHILMINAQ, 2007). In 2008, approximately 90per cent of the fish oil available worldwide, and 71 per cent of the fish meal, wasconsumed in aquaculture practices (Tacon & Metian, 2009).

Highlighted in part by ecological critiques of the development of modern intensiveaquaculture (Naylor et al. 1998, 2000) there is also increased pressure from conservationgroups and consumer interests to limit industrial fishing for meal and oil. While theaquaculture sector competes on global markets with other livestock producers, itsmarginal value per unit of fishmeal, or more critically fish oil, has tended to be greaterand it has remained a highly competitive purchaser and may ensure acceptable levels offuture market access to raw materials (Barlow & Pike 1997). Unless alternative highervalue markets develop, aquaculture will continue to consume the majority of fish mealand oil produced but this will not be sufficient to meet ever-increasing demands foraquafeed ingredients (Bostocket al, 2010)

3) Socio-economic ImpactThough many agencies understand aquaculture to contribute to development aims,

public sector investment has often supported export production and foreign currency


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earnings for justified structural adjustment and for targeted potential beneficiaries but donot always benefited poorer groups (Muir, 2005). Heavy investment, both local andinternational, has flowed into more obviously profitable areas of aquaculture especially inshrimp and marine fish and often at some cost to local resources and environments (Gujja& Finger-Stich 1996; Primavera 1997). Fishery dependent communities may face

increased vulnerability in terms of less stable livelihoods and loss of already insecureentitlements (Garcia and Rosenberg, 2010).

Environmental impacts of aquaculture

1) Biological, chemical and physical impacts of aquaculture on the environmenta) Biological impacts of aquaculture may include fecal discharge of fish, waste

food, and impacts on genetics and biodiversity. In intensive aquaculture,

increased deposition of organic wastes such as uneaten food, faeces, andexcreta increases biochemical oxygen demand, nitrates and phosphates inreceiving waters.

b) Chemical impacts include oxygen depletion and eutrophication which arecaused by the production of nutrient-loaded effluents, presence of antifoulantsused in boats and nets, industrial wastes and medications and treatments forfish, shellfish, and seaweeds (although minimal chemical used for seaweedculture) which can harm wildlife and the environment, and may lead toantibiotic resistance.

c) Physical impacts range from the aesthetics to altering critical habitats such aswetlands and mangroves. Alteration of physical environment happens whennets of cages, pens, and associated moorings prevent efficient water exchangeand changing the current patterns caused by friction to the water currents.Friction from the nets can alter the residence time of water in a bay.Sometimes these structures can also cause obstruction to navigation routes andmigration paths of different species of fish.

2) Habitat loss and modificationAquaculture affects sensitive coastal environments either by conversion like in the

case of mangroves, or habitat alteration such as in coral reef, seagrass and benthicsubstrates where fish pens and cages are located. In the Philippines, more than300,000 hectares of mangroves have been converted to fish ponds, salt beds,agriculture, and industrial and commercial establishments (BFAR-PHILMINAQ,2007). 3 00,000 hectares of mangroves were converted to give way to fish and shrimpponds, salt beds, agriculture, and industrial/commercial establishments in thePhilippines (Primavera, 1995).

3) Spread of pests and diseases


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Intensive aquaculture potentially has several adverse effects on wild species,including disease transmission, escape, and capture for broodstock or rearing.Diseases and parasites from outside the farm can easily be introduced by transportingfry/fingerlings from other parts of the country and by importing fish from abroad withproper quarantine procedures.

The introduction of species or strains into productive habitats for aquaculture, forstock enhancement, or for culture-based fisheries can have significant implicationsfor biodiversity (Beveridge et al. 1994). Exotic species may also have adverse effectson aquaculture and wild species, either through introduction of new diseases orcompetition with native species (BFAR-PHILMINAQ, 2007). The Philippineaquaculture relies on alien species, particularly in freshwater systems such as Niletilapia which is a major farmed freshwater fish and most of the lesser farmedfreshwater species including bighead carp, African catfish, common carp andfreshwater aquarium species which are actually alien species (BFAR-PHILMINAQ,2007).

VI. B. Impacts of climate change in intensive aquatic meat productionThe vulnerability of fishers and fishing systems to climate change would bedetermined by three factors: their exposure to a specific change; their sensitivity to thatchange; and their ability to respond to impacts or take advantage of opportunities (Garciaand Rosenberg, 2010). Natural climatic oscillations, particularly those at medium(decadal) scale, have always affected fisheries as well as their management performance.The impact of global climate change on ocean capture fisheries will be important for theavailability, distribution and resilience of resources as well as for the sector structure andperformance. Climate change impacts will likely be as varied as the changes themselvesand will be felt through changes in fishing opportunities (resources available andentitlements), operational costs (in production and marketing) and sales prices, withincreased risks of damage or loss of infrastructure and housing (Garcia and Rosenberg,2010)

VI. C. Impacts of intensive aquatic meat production in climate change

Impact of aquaculture packaging and labeling materials in climate changeThe global supply chain developed together with the development of packaging

and enabled the transfer of products even to far-flung areas. Since goods travel greatdistances, they are usually made durable to protect the product. Nowadays, packaging hasan important role in the marketing of the product and in conveying information requiredby law to the consumers. Another role of packaging is to respond to customersconvenience by minimizing the amount of effort required to prepare and serve food suchas oven-safe trays, boil in the bag and microwaveable packaging which allow customersto cook an entire meal without virtually any preparation.

In the UK, 30 million tonnes of household waste is generated annually and thereis now a pressure on brand owners and producers both governments and consumers tocurb the level of waste generated from packaging products. According to the Waste andResources Action Programme (WRAP of UK), 40 percent of this waste eventually endsin landfill. Production and sale of packaging has implications in terms of competitiveness


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for the manufacturer since weight reductions made that do not compromise the structuralstrength of the packaging also reduce costs, not only in terms of raw materials used, butalso with regard to fuel, logistics and overall production costs. Some of the wastes comefrom food wastage which better packaging can help address.

Plastics are inexpensive, lightweight and durable materials, which can readily be

moulded into a variety of products that find use in a wide range of applications. As aconsequence, the production of plastics has increased markedly over the last 60 years.However, current levels of their usage and disposal generate several environmentalproblems. Around 4 per cent of world oil and gas production, a non-renewable resource,is used as feedstock for plastics and a further 34% is expended to provide energy fortheir manufacture (Hopewell et al, 2010). A lot of disposable items of packaging or othershort-lived products produced each year are made up of plastic which are discardedwithin a year of manufacture. It is an indicator that current use of plastics is notsustainable.

Usage of plastic is increasing and annual production is likely to exceed 300million tonnes by 2010 (Thompson et al., 2009). Lots of discarded end-of-life plastics are

accumulating as debris in landfills and in natural habitats worldwide. (Barnes, et al.,2009) mentioned that the longevity of plastic is estimated to be hundreds to thousands ofyears, but is likely to be far longer in deep sea and non-surface polar environments.Another issue associated with plastic involves physical problems for wildlife resultingfrom ingestion or entanglement in plastic, the leaching of chemicals from plastic productsand the potential for plastics to transfer chemicals to wildlife and humans (Thompson etal., 2009). Barnes, et al. in 2009 also added that plastic debris poses considerable threatdistributing non-native and potentially harmful organisms and degrading to micro-plastics that may subsequently be ingested and the environmental consequences of suchmicroscopic debris are still poorly understood.

According to Hopewell et al. (2010) around 4 per cent of world oil production isused as a feedstock to make plastics and a similar amount is used as energy in theprocess. Yet over a third of current production is used to make items of packaging, whichare then rapidly discarded. Given our declining reserves of fossil fuels, and finite capacityfor disposal of waste to landfill, this linear use of hydrocarbons, via packaging and othershort-lived applications of plastic, is simply not sustainable.

Mega- and macro-plastics have accumulated in the highest densities in theNorthern Hemisphere, adjacent to urban centers, in enclosed seas and at waterconvergences or fronts. Remote island shores and in the continental shelf seabed havelower densities and lowest densities in the deep sea and Southern Ocean (Barnes, et al .,2009). Hickman (2007) added that existing regulations were too weak in EU due to thePackaging (Essential Requirements) Regulations of 2003 wherein large amounts ofpackaging is allowed if there is consumer acceptance or it is judged necessary formarketing. Trading standards depots have the power to prosecute companies that useexcessive packaging (Hickman, 2007). The government will set the ideal weight fordifferent classes of packaging to prevent waste of resources and transportation pollutionand to increase the target for the recycling of packaging from the current 60 per cent.

VII. Discussion that highlights some of the major sectors of intensive aquatic meat

production, including inputs and outputs in each sector and negative cost


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externalizations. Issues that may be explored in regard to negative cost

externalization include:

Responses of key players in aquaculture productionThe emerging increase in aquaculture production is also coupled with the

increasing demand from consumers for safe aquaculture products produced in asustainable and ethical manner Science and technology together with an environmentallysensitive and ethical set of policies and procedures which meet demands of consumersafety need careful consideration in order to address the intensification of aquacultureproduction. To continue to expand their market at a pace beyond just the rate ofpopulation growth, the seafood industry, including aquaculture producers will have todevelop ways of making their products more appealing to consumers to gain a largershare of total protein consumption (Aquaculture Outlook Report, 2004). Another concernof aquaculture industry is maintaining ecological integrity to ensure that environmentaldegradation does not lead to decrease in production and retail consumer throughawareness such as from certification schemes and purchasing preferences.

Government agencies from all over the world which bear the responsibility oflooking after the environment by means of regulatory standards and protecting theconsumers poses a challenge amid the backdrop of intensifying aquaculture production.Intensification in meat production has already been reported to have negativeexternalities in the environment and intensification in capture fisheries and aquaculture isanother area that needs careful attention.

Food safety standardsGlobal concern on feed and food safety and quality led to the establishment of

Codes of Good Practices, Quality Assurance Programs, Herd Health SurveillancePrograms, and education programs as important part of good husbandry as well asaquaculture practices.

Food Safety is defined by Codex Alimentarius as the assurance that food will notcause harm to the consumer when it is prepared and/or eaten according to its intendeduse. For food to be safe, it must be free from hazards to health, categorized as biologicalhazards which may come from pathogenic bacteria, virus, parasites, worms and others;chemical hazards such as natural toxins, agricultural chemicals, environmentalcontaminants, food additives, and others; and physical hazards such as presence ofstones, metal fragments, bone shards, and others.

Government response to assuring food safety standards focus on implementingregulations for mandatory compliance of companies. Some government of countriesbecome signatories in WTO and adopted CODEX Alimentarius.

1) PhilippinesIn relation to national and international trade through CODEX, Administrative Order

No. 13 Series of 2009 Designates FDC of the NFA as the official Laboratory of the DAfor the analysis of contaminants in agricultural, fisheries and animal foods and foodproducts in order to strengthen market confidence in agricultural, animal and fisheriesfoods and product exports; to consolidate trace level analysis of residues in all


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agricultural, animal, fisheries foods and food products in one single laboratory; and toensure strengthening of food safety and food security policies.

Moreover the Bureau of Fisheries and Aquatic Resources (BFAR) also implementsinspection system for import and export of fishery/aquatic products and fish processingestablishments consistent with international standards to ensure product quality and

safety. The Department of Agriculture (DA) in 2001 banned the importation and cultureof live shrimp and prawns in the country to protect the local shrimp industry fromcontamination by the Taura virus that had nearly wiped out shrimp farms in various partsof Asia. The administrative order states that the brood stock must come only from theeight brood stock facilities in the United States that are known to have the capacity toproduce brood stock that are specific pathogen-free or specific pathogen-resistant. Theeight brood stock facilities are High Health Aquaculture, Inc. (Hawaii), Kona Bay MarineResources (Hawaii), Molokai Sea Farms International (Hawaii), Rainbow Hawaii Farms(Hawaii), Shrimp Production Hawaii, Inc. (Hawaii), Shrimp Improvement Systems, Inc.(Florida), Harlingen Shrimp Farms, Ltd. (Texas) and SyAqua USA (Kentucky) to ensurethat the feed supplies are safe and food are compliant with Maximum Residue Levels

(MRLs).The BFAR Fish Health Section is involved in disease control and food safety throughits residue monitoring program. In a Memorandum of Agreement executed by BFAR andthe BAI, the Fish Health Section of BFAR is recognized as having the capability for themonitoring of feeds, veterinary drugs, and biologics in aquaculture. Together with theDepartment of Health (DOH), BFAR implements regular activities to identify/ban certainsubstances proven harmful to fish health (GAIN Report, 2007)

Among the banned substances per DA-DOH Administrative Orders No. 61 and 90,Series of 1990, and DA-DOH AO. No. 2, series of 2000 include antibiotics such aschlocramphenicol and nitruforans due to its carcinogenic, mutagenic and genotoxicproperties. The use of Cloramphenicol in food animals may lead to residue build up inanimal tissues which may lead to aplastic anemia and/or resistance when ingested byhumans, considering that it is valued as an antibiotic for life-threatening infections inhumans; while Carbadox, lanquinox and Nitrofurans have been recognized as mutagenicand carcinogenic drugs possessing genotoxic potentials; use of these are banned in foodanimals such as livestock, poultry and aquaculture production whether through feeds orwater or other means. Also, beta-agonist drugs such as but not limited to Clenbuterol,Salbutamol, Tributalin and Pirbuterol which are being used as tocolytic agents forhumans but used as lean meat-enhancing agents in animals promoting reduction in bodyfats are banned for use in food animals whether through feeds, water or other meansconsidering that thee safety profile of these products have not been established. Presenceand residues of banned veterinary and beta-agonist drugs in meat, fishery products, milk,eggs have been detected, analyzed and identified.

In relation to GMOs, the Rules and Regulations for the Importation and Release intothe Environment of Plants and Plant Products Derived from the Use of ModernBiotechnology (AO8) was signed into law in 2003 and became effective on July 1, 2003.Under this, all GE plant varieties must be evaluated by a third party panel of Philippinescientists for food, feed and environmental safety prior to entering the Philippines. Anycommodity or food containing an unapproved variety regardless of country of origin willbe prohibited from entering the Philippines. However, in China, achievements have also


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been made in animal biotechnology R&D. China is leading the research on transgenicfishes and the technology is ready for large-scale commercial production. Chinesescientists have successfully cloned carp, goats, cattle and rats, and have the capability ofproducing medicinal proteins from transgenic animals. China's animal cloning techniquesare now among the most advanced in the world (Chenet al., 2007)

2) USThe safety of food and drugs in fish and fish products is regulated by FDA while meat

and poultry and egg products which are regulated by USDA (FAO, 2008). However,veterinary biologics are regulated by APHIS's Center for Veterinary Biologics accordingto statutory guidelines in the Virus-Serum-Toxin Act.

Manufacturing, processing, packing, or holding fish for consumption in the UnitedStates of America is also governed by FDA. A voluntary fee-for-service SeafoodInspection Program, managed by NOAA, ensures food safety by offering inspectionservices to the seafood industry, and providing assurances for products in compliancewith food safety regulations. NOAA authorizes the use of official federal seals (such asU.S. Grade A) to production facilities that are compliant with applicable food standards.The Seafood Inspection Program does not replace FDA inspections, or exempt a seafoodprocessor from regular FDA inspections. The seal is used only to demonstrate that qualityof the product meets applicable food standards.

Hazard Analysis Critical Control Point (HACCP)All seafood processors must comply with FDA Fish and Fishery Products

HACCP regulation. The FDA HACCP program focuses on food safety hazardsassociated with fish species and processes. The federal HACCP plan must list the foodsafety hazards associated with fish species and processes that are likely to occur, andidentify the conditions that must be controlled for each type of fish.

3)UKThe Food Safety Act of 1990 covers Great Britain and also provides the framework

for all food legislation. In 2000, the Food Standards Act (1999) and the UK FoodStandards Agency (FSA), was established to protect the public's health and consumerinterests in relation to food. The Food Standards Agency Scotland (FSAS) alsoestablished in 2000 handles issues in Scotland involving food quality and food safety,including fish and shellfish and also the regulation of animal feeding stuffs.

The Fish Health Regulations (1997) applies to Great Britain and implement CouncilDirective prohibiting the placing on the market of aquaculture animals and products

unless certain requirements relating to their health status are met. The Regulations aremade under the Food Safety Act and the European Communities Act (1972).

At present there are two parallel systems for the approval and control of pesticides inthe United Kingdom. The first system operates under the Control of PesticidesRegulations (COPR, 1997). These regulations implement the objectives of the Food andEnvironment Protection Act (1985). This system of control is at a national level andapplies to agricultural and non-agricultural use of pesticides. The second system of


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legislation has been introduced to enable the development of a common market for pestcontrol products across all EU member states in Europe.

1. Coastal and deep sea pollution, ecosystem deterioration, mangrove destruction.

2. Fate and consequences of the production of multi-antibiotic-resistant bacteria

through the heavy use of pharmaceuticals.

Anti-microbial resistance

Antibiotics/antimicrobials may be defined as drugs of either natural/synthetic origin thathave the ability to kill or to inhibit the growth of microorganisms. According to FAO,antibiotics are agents that are sufficiently non-toxic to the host and used aschemotherapeutic agents in the treatment of infectious diseases of humans, animals andplants. The role of antibiotics has been one of the greatest contributors to health inmodern medicine. However, there has been both a resurgence of older infectious diseasesand an emergence of new diseases over the last couple of decades. One of the main

factors for this new prevalence of disease is that disease-causing micro-organisms aredeveloping a tolerance for antibiotics. This phenomenon is termed antibiotic-resistance.For the most part, this resistance stems from the misuse and abuse of antibiotics. Thesemicro-organisms undergo rapid and prolific growth, allowing them to adapt to theirenvironment very quickly. When they are over-exposed to antibiotics, they are allowedthe evolutionary space to adapt and develop resistance to them.

The threat of antibiotic resistance is summarized in this quote from the Institute ofMedicine,Antibiotic resistance as a phenomenon is, in itself, not surprising. Nor is it new. It is

however, newly worrying because it is accumulating and accelerating, while the worldstools for combating it decrease in power and number.

While the use of antimicrobials and the associated anti-microbial resistance are wellrecognized as a growing concern in public health worldwide, it is more difficult tomeasure, and therefore harder to assess, the impact of their use in aquaculture. The trendof increasing resistance against antimicrobials can be attributed in large part to humanmedicine, and also to their usage in industrial-scale animal meat production facilities.Although aquaculture has to date received less attention, this area may yet prove to be animportant factor in antimicrobial resistance. The quality and quantity of data available forthe use of antimicrobials in aquaculture is limited, and few countries have definiterecords. In addition there is a lack of regulation and guidance on their use in manydeveloping countries.

It has been shown in many investigations that the particular genes conferringresistance in organisms can be extremely similar (Kruse et al., 1994; Rhodes et al., 2000),therefore one of the main concerns is that of gene transfer. The intensive application ofantimicrobials in aquaculture, as in animal production, can lead to selective geneticpressure. Antibiotic-resistance as a result of drug use in aquaculture has already beenassociated with several strains of bacteria, including Yersinia rukeri (DeGrandis et al.,1985), A. Salmonicida (Aoki et al., 1971), Aeromonas hydrophila (Akashi et al, 1986)


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and V. Salmonicida (Husevag et al., 1991). There is then the possibility that genesconferring resistance in aquatic pathogens could transfer over to human pathogensdirectly, or stepwise via different bacterial hosts (horizontal gene transfer).

Some of the more common bacterial infections found in aquaculture includeblood septicemia, diarrhea and various skin conditions. The bacteria responsible for these

infections are very closely related to their human equivalents. It is common that the sameanti-microbials used in human medicine are also used in aquaculture, such asormethoprim and oxytetracycline. Also, the trend of using antimicrobials as growthpromoters in food production is of great concern as they often bypass veterinaryprescription and regulation. By administering the drugs at sub-therapeutic levels and overprolonged periods of time, the potential for pathogens developing resistance increaseswithin the fish species, can disseminate into the environment and ultimately lead tohuman exposure.

With the increasing expansion of aquaculture, the improved distribution networksand transportation systems for bringing fish to market both nationally and internationallyhave also vastly improved. Just like other areas of food production, this creates a situation

whereby potential health risks are increasingly of concern. In one experiment (Kruse etal., 1994), it was investigated how easily resistance genes could be transferred from a fishpathogen to human Escherichia coli on a cutting board where salmon was prepared atroom temperature. They found that the frequency of gene transfer between bacteria wasalmost identical to that seen in growth media in laboratories. This example went on toshow the extent of transferability of resistance from aquatic bacteria to human bacteria,and that this may serve as an important potential reservoir for increasing anti-microbialresistance in human medicine.

In another study, an investigation into the prevalence of anti-microbial resistancein ready-to-eat shrimp was performed (Duran et al., 2005). Taking 13 different samplesof ready-to-eat shrimp from 4 countries, over 160 species of bacteria were isolated andidentified. Of those bacteria, it was found that approximately 80% displayed anti-microbial resistance. Furthermore, the fact that ready-to-eat shrimp does not requirecooking increases the likelihood of introducing these resistant strains into the micro-floraof the human gut. Again, this would serve as a potential reservoir of resistance genes thatcould be horizontally transferred to human bacteria.

The environmental impact of anti-microbial use in aquaculture has received lessassessment than other areas of animal food production thus far. Although the currenttrend of large-scale fish production is in closed pens and tanks, open-sea aquaculture isincreasing and therefore the potential impact on the environment will also increase. Themost common routes of antibiotic administration in aquaculture are either by directlyadding the drugs to water, or by using medicated feed. This type of drug administrationpoints towards whole batches of fish being treated at once. Therefore, following theharvest of one fish batch, generally the pens/tanks are not drained which then exposes thenew fish batch to residual anti-microbials. This may lead to bio-accumulation, increasingthe likelihood of resistance. In a report by FAO (FAO, 1997), concern was expressedover the use of natural waters in aquaculture (such as fjords) and the potential impact ofdrug use on the environment at large. As an example of this impact, in a stream thatreceived effluent run-off from a trout aquaculture facility, it was found that resistance to acertain anti-microbial (a quinolone) was increased 10-fold (Guardabassi et al., 2000).


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Furthermore, in another FAO report (Hernandez et al., 2005), research indicates thatbetween 70% and 80% of certain drugs used in aquaculture ends up in the environment.Authors of a survey into the dissemination of antibiotics in areas surrounding shrimpaquaculture farms in Vietnam found that much higher concentrations of the drugs werepresent and concluded that they posed a potential ecological hazard (Le et al., 2004)

As an example of the lack of regulation and guidance on antibiotic use in IAMproduction, one may look to a study performed by Graslund et al (2004). Here it wasreported that of the large amounts of antibiotics used in Thai aquaculture as a whole, 74%of farmers in shrimp production used these drug agents. It was also noted that more than13 different types of antibiotic were used, and in some cases were used on a daily basis inprophylaxis. More stringent regulation policy and practice is required in this area of foodproduction, and recently has been garnering more attention. For example new policy hasbeen introduced in India regarding the administration, food-labelling and over-the-counter availability of antibiotics used in aquaculture. Whether these new policies will betransformed into actionable practice remains to be seen however.

Although there is a growing trend towards the use of vaccines over antibiotics in

parts of the world (particularly Europe and Latin America), the issue of antimicrobialresistance cannot be put to one side. Aquaculture is an industry that is undergoing rapidgrowth in many parts of the world, and with the intensive use of antimicrobials thephenomenon of antibiotic resistance is also growing and gaining more attention. As withother areas, such as terrestrial animal food production and human medicine, there is anincreasing need to develop, regulate and maintain a full strategy for the responsible use ofdrugs in aquaculture in order to protect human health. With a more controlled and guideduse of antibiotics in aquaculture, this would result in a more positive effect not only onhuman health as a whole, but also the individual facilities, their workers and the naturalecosystem at large.

3. Effects of escaped farmed fish from enclosures: interbreeding with the natural

populations, eating or displacing them including issues of genetic modification.

4. The relationship of aquatic meat production to avian influenza and the potential

for causing regional and global infectious disease pandemics.

5. As is the case for intensive land-based meat production, there are disease issues

that are a direct result of growing animals in high density, severely crowded

conditions where the animals are already under a high amount of stress:

(a) Sea lice infestation

(b) Infectious salmon anemia virus

(c) Bacterial kidney disease

(d) Vibrio salmonicida

(e) Enteric septicemia

(f) Salmon rickettsial disease

(g) Vibrio species in penaeid aquaculture (which contributed to collapse in

aquaculture industry)

6. Protein consumption versus production: Large finfish must eat many smaller fish

for every kilogram of finfish.


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7. Socioeconomics.

8. Retail aquatic meat labeling and product traceability

LabelingLabels in packaging have important roles in the marketing of the product such asthe name of manufacturer and product as well as weight or volume and pertinentinformation required by law to the consumer such as nutritional information, ingredients,presence of allergens.

Labeling laws in relation to food safety

1) PhilippinesThe state shall enforce compulsory labeling and fair packaging to enable consumer to

obtain accurate information as to the nature, quality and quantity of the contents of

consumer products and to facilitate his comparison of the value of such product.The Republic Act No. 3720 or the Food, Drug and Cosmetics Act 1963 wasenacted to ensure the safety and purity of foods, drugs and cosmetics made available tothe public. Under the Food Act, the Food and Drugs Administration (FDA) was createdunder the DOH Executive Order No. 175 (EO 175) to ensure the safety, proper handling,efficacy, purity and quality of processed foods, drugs, diagnostic reagents, medicaldevices, cosmetics and hazardous household substances. It also oversees the control ofthe manufacture and sale of processed foods, where the major concerns are adulterationand mislabeling of food products. It is responsible for the surveillance of imported foodproducts at legal ports of entry.

Under Republic Act No. 8435 or the Agriculture Fisheries and Modernization Actthe Bureau of Agriculture and Fisheries Standards (BAFPS) was established in 1997 inorder to formulate and enforce standards of quality in the processing, preservation,packaging, labeling, importation, exportation, distribution and advertising of fresh andprimary agricultural and fisheries products. BAFPS also provides assistance inestablishing the scientific basis for food safety, trade standards and codes of practice andharmonizes them with internationally accepted standards and practices. BAFPS serves asthe National Enquiry Point for Codex Alimentarius and other food safety and standardsregulatory bodies.

Labeling Requirements in the Philippines according to BFAD AO No. 88-B (1994)should include:

a) Name of the food; List of ingredients used in the product (in decreasing order ofproportion), including additives, flavorings and preservatives used;b) Net contents and drained weight;c) Name and address of manufacturer/packer or distributor, including country oforigin for imported products and name and the address of Philippineimporter/distributor;d) Lot identification.


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Codex Alimentarius and USFDA regulations serve as the Philippine BFADs mainreference guidelines for policy pertaining to good manufacturing practices and suitabilityof packaging materials for food use. Compliance with Codex and/or U.S. regulations forpackaged foods will almost always assure compliance with Philippine regulations.

Currently, there is however no labeling for biotechnology or organic products

required by the Philippine government.In relation to importation, the Fisheries Code Administrative Order 195 allowfresh/chilled/frozen fish and fishery/aquatic when certified as necessary by the Secretaryof Agriculture as well as to achieve food security taking into consideration public welfareand safety.. All importation must satisfy the Hazard Analysis and Critical Control Point(HACCP) standards as provided under Section 67 of RA 8550.

All fish and fishery/aquatic products imported into the Philippines intended fordistribution and further processing must be accompanied by an International HealthCertificate issued by the authorized or competent regulatory agency from the country oforigin which met the following criteria:

a) Fish and fishery/aquatic products which meet the quality of fresh fish prior to

freezing and be graded accordingly to size;b) Fishery products must be handled and processed hygienically in processing plantsand/or freezer vessels;

c) Frozen fishery products must be kept and maintained at -18C or lower duringtransport;d) Fish and fishery/aquatic products must be subject to visual inspection for parasite

check. Fish infested with parasites, must be removed from the batch;e) Total viable count 10/gram E. coli 10 to 100/gram;f) Salmonella absent in 25 gram sample; andg) Shigella and Vibrio cholerae absent.

Fishery/aquatic products must be packed under hygienic condition to preventcontamination from lubricants, oils, fuels or any hazardous substances. The followinginformation should appear on the packaging and on the accompanying documents: thecountry of origin written out in full; species of fish/fishery products weight and content;address of supplier; and BFAR Inspection stamp mark. Frozen fishery/aquatic productsimported in bulk intended for further processing are not covered by this requirement.

GMOsThe Rules and Regulations for the Importation and Release into the Environment ofPlants and Plant Products Derived from the Use of Modern Biotechnology (AO8) tookeffect on July 1, 2003. Under AO8, all GE plant varieties (regulated article) must beevaluated by a third party panel of Philippine scientists for food, feed and environmentalsafety prior to entering the Philippines. Any commodity or food containing anunapproved variety regardless of country of origin will be prohibited from entering thePhilippines.

2) U.S.A.Farm Bill 2000 Public Law 107-171


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This law directs the U.S. Department of Agriculture to develop regulations thatwould require U.S. retailers to provide country-of-origin labels (COOL) for red meats(beef, lamb, and pork), fish and shellfish, fresh and frozen fruits and vegetables, andpeanuts. In addition, fish and shellfish must be identified as either wild or farm-raised.The purpose of the requirements is to provide consumers with greater information when

purchasing seafood. The rule defines covered commodities as wild and farm-raised fishand shellfish, including fillets, steaks, nuggets, and any other seafood flesh. Thus, the rulecovers fish such as salmon, trout, tuna, cod, and other species whether they are farm-raised trout from Idaho or wild harvest cod from Iceland. The rule also covers shellfishand mollusks such as shrimp, crawfish, oysters, clams, scallops, and mussels.

Businesses affected by this rule are retail food stores and their suppliers, from fishfarmers and harvesters through processors and wholesalers. Under the law, retailersrequired to provide country of origin and method of production information are thosedefined as retailers under the Perishable Agricultural Commodities Act. Thus, retailersaffected by the rule are chiefly supermarkets, and most fish markets would be exempt.

Food service establishments are exempt from the requirements of the law. This

basically would be seafood sales through restaurants and similar establishments. The rulealso defines food service establishments to include food service facilities within retailstores. An example would be a deli in a retail store that sells ready-to-eat foods to beconsumed either on or off the retailers premises.

Products that are exempt from the rule are those defined as ingredients in aprocessed food item. An ingredient is a component, either in part or in full, of a finishedretail food product. A processed food item is defined as seafood products that havechanged in character through specific processing or has combined with another coveredcommodity or other substantive food component. There are numerous examples ofprocessed items such as canned tuna, fish stews, smoked salmon, and breaded catfishfillets (USDA, undated).

HACCP is a mandatory program for seafood processors under the U.S. Food andDrug Administration and with additional authority for seafood processors.

Under the Oceanic and Atmospheric Administration, there is a program requiringthe analysis and management of critical processing variables that impact upon thehealthiness and safety of seafood products. As a result of the proposed step-wisereduction of oil in feed as well as the sourcing of oil from fisheries with the lowest levelsof contaminants and treating oil to remove contaminants (supported by 2107(a)(6) periodic residue testing), there will be more farmed fish with substantially reduced levelsof contaminants relative to wild or conventionally produced fish.For US standards, the marks are: US Grade A, Processed Under Federal Inspection

(PUFI), Lot Inspection Mark, Retail Mark and HACCP Mark. HACCP principles are alsoemployed to certify products.

3) EUThe Fish Labeling (Scotland) Regulations (2003), which extend to Scotland only,

make provision on the markets in fishery and aquaculture products and implement rulesgoverning informing consumers about fishery and aquaculture products. CouncilRegulation (EC) 104/2000 imposes inter alia requirements regarding the provision ofinformation about the commercial designation, production method and catch area of


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certain fishery and aquaculture products offered for retail sale to the final consumer(FAO, 2008).

The Animal and Animal Products (Examination for residues and Maximum ResidueLimits (1997) applies to aquaculture animals and establishes community procedures forfixing maximum limits for veterinary drug residues in foodstuffs of animal origin. The

Regulations prohibit the sale, possession or administration to animals of specifiedunauthorized substances, prohibit the possession, slaughter or processing the meat of,animals intended for human consumption which contain, or which have beenadministered with, specified unauthorized substances

GMOsThere are presently two main areas of potential application of GMO technologies in

aquaculture. The first is the use of GMO vegetable products in fish feed and the use ofGMOs in medicines and pharmaceuticals, and the second application is the use of GMOtechnologies more specifically, transgenics in breeding fish for commercial aquacultureuse. The use of GMOs plays no part in Scottish commercial aquaculture production yet.

The application of genetic techniques may be expected to play some role in the future.However, Scottish research institutions supporting the industry continue to develop theirknowledge and any proposal to use transgenic fish would require the consent of theScottish Ministers. If granted, approval would be based on the advice of the AdvisoryCommittee on Releases to the Environment (ACRE) and would also take into accountadvice from other relevant agencies such as the FSA and Scottish Natural Heritage.ACRE is a statutory advisory committee appointed under the Environmental ProtectionAct to provide advice to the government regarding the release and marketing ofgenetically modified organisms.

The Genetically Modified Organisms (Deliberate Release) (Scotland Regulations of2002 implements the Directive 2001/18/EC of the European Parliament and of thecouncil on the deliberate release into the environment of genetically modifiedorganisms. The amendment in 2004 covered the areas of genetically modified food andanimal feed. The Council Regulation has as its objective the facilitation of accuratelabeling, monitoring of effects on the environment and on health as well as theimplementation of the appropriate risk management measures including withdrawal ofproducts

Mislabeling case

In Ireland and UK, cod is the most popular imported whitefish consumed anddemand remains high even though local Atlantic cod stocks have largely been depleted.There were mislabeled smoked, breaded or battered cod products which were actuallyless expensive fish species substituted for cod and sold to consumers at premium price.Another more subtle form of mislabeling is when cod products were mislabeled tospecifically match a demand for more sustainable seafood choices according to DrMariani (Fishsite, undated).


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TraceabilityWith the intensification of aquaculture and stiff competition, knowing where the

fish, shellfish or crustaceans originate is becoming more important. As news of problemswith fish diseases in some fish farms becomes more publicly known, consumers wantassurance that the products they are eating are safe. Safety assurance left to individual

countries while industries set their own transparent standards to develop their ownstrategies. Traceability is used more as a marketing tool rather than a designation ofquality and safety.

Comparing with meat industry which had quality assurance and traceabilitysystems for a long time, with most dating back to the outbreak of BSE in the UK in themid '90s, the fish and shellfish industries had been lagging behind, according to ChrisHarris, Senior Editor for TheFishSite. Traceability has been burdened with difficultiessince most fish in the past comes from the wild. However, in Scotland, the GeneticallyModified Organisms (Traceability and Labeling) (Scotland) Regulations of 2004 makeprovision for the execution and enforcement of the European Parliament and of theCouncil concerning the traceability and labeling of genetically modified organisms and

the traceability of food and feed products produced from genetically modified organisms.The Council Regulation provides a framework for the traceability of products consistingof or containing genetically modified organisms and food and feed produced fromgenetically modified organisms. The Council Regulation has as its objective thefacilitation of accurate labeling, monitoring of effects on the environment and on healthas well as the implementation of the appropriate risk management measures includingwithdrawal of products.

On the same line, the Marine Stewardship Council (MSC) works with partners totransform the world's seafood markets on a sustainable basis. It has developed standardsfor sustainable fishing and seafood traceability and also affirms that MSC-labeledseafood comes from sustainable fishery and can be traced back. However, its certificationprocess is not traceable and food safety is not assured since certification is more forenvironmental and ecological assurance.

Other countries and authorities are out to start setting full fish and seafoodinspection and control procedures that employ traditional traceability measures andaudited quality assurance systems such as the ministry of fisheries in Viet Nam which hasa National Fisheries Quality Assurance and Veterinary Directorate (NAFIQAVED).Thailand's Department of Fisheries also has developed a Fish Inspection and ControlSystem and the entire processing industry is monitored under the General Principle onFood Hygiene and Good Manufacturing Practices under HACCP systems. Thailands

DOF has a computerized traceability system for shrimp which allows every step ofraising, production and processing of the shrimp to be monitored and recorded. Thesystem is open to the shrimp farmer and harvester, processor and feed manufacturer.

Mostly, national authorities from various countries set out regulations that willcover the fish and seafood when it enters into a processing plant. As with most foodprocessing establishments, the fish being prepared for the retailer, wholesaler orfoodservice outlet will have to be processed under strict safety regulations and under thetraditional HACCP (Hazard Analysis and Critical Control Point) criteria. Thegovernment authorities also lay down strict food safety criteria for the import of fish and


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seafood products, but do not necessarily constitute full assurance and traceabilitycertification.

Challenges associated with traceabilitya) Faulty assignment of lot code since most companies, the lot code can only

immediately trace the date of production and not the production batchb) Inadequate production records in relation to documentation and personnel trainingneeds

c) Inadequate dispatch record since many companies do not tract the lot code ofdeliveries to customers so in the event of recall it would be difficult to zero in onspecific areas that would have been affected

d) Illegible markings because with frozen goods lot labels used are not alwayswaterproof

e) No written protocol for recall procedure which poses a challenge since the foodsafety problems of the food industry can occur at any stage of the food chain andat any of the steps during the processing of the product

Eco-labeling in fisheries productsFor most food products a label will give a fairly accurate account of how it was

produced, in turn this gives the consumer the insight to choose those that are sourced inan ethically appropriate manner. Aquaculture had a delayed introduction to this race.Only recently has the idea of organic aquaculture been taken seriously on a global scale.The goal of eco-labeling is to harness the power of the market to achieve environmentalgoals according to Roheim and Sutenen (2006). When offered a choice between an eco-labeled product and a non-eco-labeled product, some consumers might prefer the eco-labeled product (e.g. seafood from sustainable fisheries).

The farming method can affect seafood's sustainability. Some methods are lowimpact, such as growing mussels on suspended ropes, whereas others, such as certaintypes of prawn or salmon farming, can be notably more damaging to the environment.The MCS has since created a supermarket league in the UK to praise those supermarketsthat do the most to support ethical fish companies and add pressure on those that don't.But for all the effort of organizations and supermarkets, the farmers and the trawlers atthe end of the day it is the consumer, who has the real power to change. By being awareof the issues involved and knowing what the labels means, choosing which supermarketsto shop at and what products to buy.

Seafood eco-labeling may not only apply to fisheries, but may also apply toaquaculture. This might lead to things such as a price premium for the eco-labeledproduct and/or increased market shares. It might also allow access to markets to whichproducts from certified fisheries previously did not have access. A significant portion ofseafood exports are coming from the developing world and are being exported to threemajor markets: the European Union (EU), the United States of America (USA) andJapan.

For all the organic labels on the market, there is still no globally recognizedorganic model but the sustainable seafood movement is active in the USA and the EU


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and in the small markets of Canada, Australia and New Zealand. The sustainable seafoodmovement uses the market, via consumers, chefs and the supply chain, to influencedemand for seafood in an effort to affect ultimately management of either fisheries oraquaculture of a variety of species. Generally, these movements are initiated and run byenvironmental non-governmental organizations (NGOs), or at least private non-profit

organizations. Among the tools being used are: boycotts, consumer guides to sustainableseafood (such as wallet cards), and labeling. A detailed analysis of the costs and benefitsof each approach appears in Roheim and Sutinen (2006).

How ethical is eco-labeling and who benefits?

a) CorporationWhat is motivating major corporations to sign up to procuring sustainable seafood?

What are some of the things that are driving these companies to supply eco-labeledproducts, most particularly MSC-labeled products from MSC-certified fisheries?

On their side of the fence, it is a minimization of supply risk because if fisheriescontinued to be overfished, the company would not have anything to supply to theircustomers. In Europe, there have been some issues related to purchase of illegally-caughtfish which made its way into the supply chain of well respected processors and brands(Leigh and Evans, 2006). So companies are now requiring increased traceability in thesupply chain and demanding that boats provide proof that they caught their fish in a legaland sustainable manner.

Price premiums are what most people focus on as the measure by which they wish toquantify success of certification. If we look specifically at the MSC, MSC-labeledproducts are sold in more than 25 countries worldwide (MSC, 2006). Retail sales, in USdollar terms, showed a 76 percent increase between 2004/2005 and 2005/2006, toUS$236 million. From this, it can be seen that there is a market arising from theparticipation of these companies or corporations and they would not want to be left out.

b) EnvironmentThe purpose of eco-labeling is not to just provide a market benefit but it is intended to

provide an environmental benefit. The point is to improve the environment, to createsustainable fisheries if they do not already exist or to reward those that do exist. TheMSC recently posted an environmental benefits conducted by Marine ResourcesAssessment Group (MRAG) (Agnew et al., 2006). This study looked at theenvironmental benefits generated from certification of fisheries. Results show that therehas been a reduction in seal mortality as a result of the assessments in the case of theWestern Australian rock lobster fishery. There has been a reduction in hooks that havebeen discarded and a reduction in albatross mortality in the Patagonian toothfish fisheryof South Georgia.

Eco-labeling is also about providing market incentives to improve fisheries that donot currently meet the standards such as the case of the Alaska pollock and had increasedmarket access into markets that it did not have previously. The entry of the RussianPollock fishery into pre-assessment which would require making changes to their fisherymanagement institutions and policies to improve their practices, is the incentives createdby losing high-value markets to the Alaskans post-certification (Rogers, 2007).


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c) Animal WelfareCompared to the livestock sector, fish have not been receiving much attention on

welfare grounds. However, things are now set to change after a torrent of researchconcluded that fish have the same feelings of pain and suffering as birds and animals do.Consumers are increasingly concerned about the characteristics of the products that they

purchase and, in the context of farm animal welfare, increasing numbers are looking tobuy those with a stated welfare provenance (FAWC, 2006). Ocean mammals also sufferin the event of trawler fishing operations, so dolphin and turtle friendly labels have beenapplied to fish caught with advanced nets. In response to ocean problems, someconsumers have turned to fish produced by farming, but there are still large and oftenmisunderstood repercussions for fish farms both inland and offshore.

Some questions which consumers try to answer include: Is the species threatened or endangered? Where was the fish caught? How was the fish caught? Is it the right time of the year to buy this fish?If consumers are provided with adequate information to enable them to act on their

animal welfare preferences and purchase the animal welfare attributes that they desire,producers will have a powerful incentive to produce welfare friendly products andretailers to source them. The market may then encourage producers to adopt higherwelfare production practices, thus improving the welfare of farm animals.

Welfare encompasses the animals health and general physical condition, itspsychological state and its ability to cope with any adverse effects of the environment inwhich it is kept. Consumers make purchasing decisions based on the information theyhave about the attributes or characteristics of alternative products that they might buy.The satisfaction that consumers derive from a food product depends on its different

attributes such as taste, nutritional value, appearance, convenience and animal welfareprovenance. The better, and more informed, the purchasing decision, the greater thebenefit derived from the purchase. At the present time there is a scarcity of appropriateinformation for consumers concerning the animal welfare attributes and consumerswishing to purchase products with high animal welfare attributes face a difficult andtime-consuming task in sourcing these products. Thus, the transaction costs for suchconsumers are, in many cases, prohibitively high for them to locate and purchase theproducts that they would like.

On the contrary, the absence of a welfare label may lead to an uninformed orunintended choice by the concerned consumer. People cannot make purchasing decisionswhich maximize the benefit they might derive from their expenditure if they are not

provided with adequate information to make a rational choice. Markets also cannotfunction efficiently without enough information available to both buyers and sellers. Theprovision of appropriate information can therefore help improve market efficiency; helpconsumers make informed choices and improve customer satisfaction; and help producersto better understand the market and their customers and so potentially benefit the wholeof society.


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The European Commission, Special Eurobarometer 229 on Attitudes of consumers

towards the welfare of farmed animals (June 2005) classified product characteristics intothree broad groups depending on how consumers get to know about them:

a)Search characteristics are those that are largely self-evident, i.e. ones that theconsumer can discover, verify and validate against personal preferences beforepurchase;

b)Experience characteristics are mostly those that are not evident prior to purchasebut are discovered during consumption. Information is then available to guidesubsequent purchases;

c)Credence characteristics cover animal welfare origin, production method,biological safety, best-before dates, etc. They can only form the basis of choice iflabeling in some form is used.

The EC proposal on animal welfare and trade in agriculture (2000) viewed animalwelfare as being at the crossroads of economic, ethical, animal health, public health, food

production and legal issues. Whilst the existing WTO Agreements provide a basis on whichsome of the issues related to animal welfare can be discussed, the EU has pressed for animalwelfare to be addressed globally in a consistent manner within the WTO framework. Withinthis context appropriate labeling, compulsory or voluntary, could facilitate the wish ofconsumers to make an informed choice as regards the animal welfare provenance of foodproducts, whether domestically produced or imported.

Quality characteristics of food which fall into the class of credence are characteristics asthe products environmental provenance, location of origin and the animal welfare standardsunder which it was produced. While many consumers may be indifferent to these particularattributes, to others they are real and important elements. They count strongly in thepreferences, and is fundamental component of the satisfaction gained from consumption. Inorder to meet this preference, information about those characteristics should be evident priorto purchase, specifically attached to the food product, and in a form that is accessible,understandable, meaningful, accurate, certified and dependable.

The World Organization for Animal Health (OIE) 2 is establishing guidelines oninternational welfare standards. There is a strong consensus regarding the benefits ofrecognizing high animal welfare standards and communicating them to consumers. In May2005, the 167 members of the OIE adopted guidelines on sea and air transport of animals, onslaughter of animals for human consumption, and on killing animals for disease control. Thisrepresents an important achievement for animal welfare: an agreement on global animaltransport and slaughter.

Organic Labeling

. The damaging and unethical aspects of intensification in livestock influence therise of the organic movement as a public response. When sustainable practices areacknowledged such as organic aquaculture farming, it gives the organic product marketpower and the potential to increase the value of its product and of the industry as a whole.

The same concerns are now arising in the aquaculture industry. According to a UnitedStates Department of Agriculture (USDA) report, the market potential for organicaquaculture seems to be promising in Europe as well as in the U.S.


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1) Organic Labeling in U.S.One of the aspects included in the U.S. proposed organic aquaculture standards (2008)

is on fish feed which recognizes he nutritional needs of aquatic animals for fish meal and fishoil but looks at other feed alternatives which have potential of becoming certified organic.

However, the commercial availability of such alternatives is currently an open question.Certified organic fish meal and fish oil would be expected to become increasingly availablein the future as the certified organic aquaculture industry grows (NOSB, 2008).

The producer of organic aquatic animals shall not:a. incorporate or introduce any type of antibiotic or hormone in feeds, the water

supply, or the environment;b. provide feed supplements or additives in amounts above those needed for

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

c. feed by-products from mammalian or poultry slaughter products to aquaticanimals;

d.

use feedstuffs extracted with synthetic solvents not approved ;e. use feed, feed additives, and feed supplements in violation of the U.S. FederalFood, Drug, and Cosmetic Act; or

f. use any genetically modified organism, or any organism produced by any otherexcluded method, or product thereof, as a feed ingredient.

Another provision on fish meal or fish oil is that it should not be sourced from anyfishery classified by relevant state/provincial, national, or international fisheries authorities asat risk of reduced reproductive capacity; suffering reduced reproductive capacity;

harvested outside precautionary limits; over-exploited; depleted; overfished;overfishing is occurring; or at significant risk of those conditions within the nextrecruitment cycle. All fish meal and fish oil must be monitored for heavy metal levels andpersistent organic pollutants including persistent bioaccumulative toxins (PBTs) andmercury, cadmium, lead, arsenic and tin.

Standards in Organic Labelinga) Products sold, labeled, or represented as 100 percent organic

A raw or processed agricultural product sold, labeled, or represented as 100percent organic must contain (by weight or fluid volume, excluding water andsalt) 100 percent organically produced ingredients.

b) Products sold, labeled, or represented as organicA raw or processed agricultural product sold, labeled, or represented as organicmust contain (by weight or fluid volume, excluding water and salt) not less than95 percent organically produced raw or processed agricultural products. Anyremaining product ingredients must be organically produced, unless notcommercially available in organic form, or must be nonagricultural substances ornon-organically produced agricultural products. Aquatic animals (and theirproducts) that have been fed wild caught sustainable fish meal or oil as a feedsupplement pursuant and that are used as ingredients, must indicate (Fedsustainably-sourced wild fish) next to the name of the fish.


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2) Common standards for organic aquaculture on EUCertification in the Member States used to be based on private standards or national

specification and only Denmark and France have national laws on organic aquaculture.Ireland drafted legislation in 2007 but left it dormant pending adoption of the European text.

The new regulation on organic aquaculture animal which covers fish, mollusks, andcrustaceans and seaweed production imposes minimum criteria to be used in all countries ofthe European Union. This was enforced on 1 July 2010 and a logo of the Euro -leaf isaffixed to pre-packaged organic aquaculture products produced in the EU. Under this singlelogo, it is possible to market pre-packaged organic aquaculture products throughout the EUinternal market. The existence of a common standard based on minimum criteria will helpimprove the identification of organic aquaculture animals and minimize costs of multipleaudits for exports and at the same time guarantee the production of wholesome and highquality foods while reducing to a minimum the impact on the aquatic environment.

To guarantee that organic fish farms remain as close to nature as possible, the Regulationprohibits the use of hormones and has a major impact on certain farms which previously used

hormonal induction for fish reproduction. This is the case for carp produced mainly inHungary, Slovakia, Czech Republic and Poland. The ban will also affect the production ofsturgeon in Spain and France as well as tilapia, a fish found in a number of organic fish farmsin the Netherlands. Here too, however, fish farm operators have three years to develop areproduction process that meets the new criteria (2).

Adaptation periods for EU give organic fish farms until 2013 to meet the criteria incertain cases spelled out by the Regulation. Any new organic farm will have to comply withthe European specifications immediately. The new rules apply on a progressive basis suchthat 80 per cent of juveniles can still be non-organic in 2010 and 50 per cent in 2013. It is notuntil 2015 that all juveniles will have to be organic.

9. Contamination of aquatic meat with heavy metals.

10. Contamination of aquatic meat with persistent organic pollutants.

11. Hormone administration.

12. Fish feed production and application from intensive land-animal meat

production systems - Rendered meat and bone meal (MBM).

13. PrionsPrions are considered a special class of infectious agent. Prions are defined as

proteinaceous infectious particles, and they are known to be the causative agent of fatalneurodegenerative diseases in both humans and animals. Among these diseases areincluded Creutzfeldt-Jacob Disease (CJD) in humans, Scrapie in sheep, and BovineSpongiform Encephalitis (BSE) in Cattle. As compared with bacterial or viral infectiousagents, prions have an unusually high resistance to thermal and chemical inactivation(Casolari, 1998, Danner, 1991). It is this resistance that is believed to have been the maincontributing factor to the BSE outbreak in cattle in the UK. It was found that scrapieprions from sheep which were subsequently fed to cattle in meat-and-bone meal were not


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inactivated through the as-then-standard physical and chemical treatments (Nathanson etal., 1997). Prions can be found in all body tissue of dead animals, however they are in farhigher concentrations in tissue belonging to the central nervous system (Smith et al.,2003, GAO, 2002). These parts of the animal are termed SRMs (Specified RiskMaterials) and include brain, segments of spinal cord and eyes. These SRMs are now

prohibited from use in animal feed in the EC and the USA, although there is lack of suchregulation in other parts of the world.The feeding practices used in IAM production are similar to that of animal

practice. In many cases fishmeal, constituted from the likes of fish and animal offal,trash fish (fish of no real commercial value) are re-fed to fish in production facilities.Although there has not been any reported instance of prion-related disease in fish to date,there are fish molecules homologous to animal prions which have been found in variousspecies (Gibbs et al., 1997, Miesbauer et al., 2006, Madison et al., 2005, Oidtmann et al.,2003). Considering that prion proteins are extremely stable and not easily degraded ordenatured, this could lead to amplification/bioaccumulation in aquaculture species. Inaddition, offal from terrestrial sources is also sometimes used in fishmeal including those

of bovine and porcine origin. The available literature on prion-related disease is stillgrowing, but is particularly scant with regard to fish. The species barrier between humansand fish is substantial however and in one study it was reported that the tra

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