My recent trip to Austin for the Organic Trade Association's "All Things Organic" event brought the issue of organic aquaculture back into focus. Finally we have an answer from USDA on whether or not certifiers may certify wild caught or farmed fish. But the answer has stirred controversy and confusion.
The National Organic Program (NOP), in its Policy Statement on National Organic Program Scope, states:
"Producers and handlers of any agricultural commodity or product, whether raw or processed, including any commodity or product derived from livestock, that is marketed in the United States for human or livestock consumption may seek certification under the National Organic Program as an organic producer or handler."
What this means is that a lot more can be certified than most of us originally thought -- and fish, wild caught or farmed, is one of them. You may remember the previous conflicting articles on wild-caught fish in this publication. (See "Is Wild Organic?" in CG #89, July-August 2000.) The NOP statement does little to make either side particularly happy, since it does not provide any clarity on fish production itself.
Unfortunately, at this time there are no specific NOP standards for aquaculture production or handling. Current livestock standards take into consideration some species-specific needs. The NOP expects certifiers to interpret the existing regulations and make them applicable to aquaculture. Applying standards that were written with cows, hogs and chickens to animals that swim may create lucrative advantages for certifiers as well as producers.
It is impossible to ensure that wild caught fish are fed 100% organic feed and are not contaminated with prohibited substances.
Good news? Maybe. Challenging? Definitely. To qualify for certification, the producer or handler must comply with all applicable regulations under the NOP, and to label a product as "100 percent organic," "organic," or "made with organic (specified ingredients)" the producer or handler must be certified by an accredited certifying agent. What will this mean for fish?
Fish, used for food, are considered livestock and therefore must be produced in accordance with the livestock regulations. At this time it seems unlikely that a certifier will be able to approve an "organic system plan" for wild caught fish, since it is impossible to ensure that they are fed 100% organic feed and are not contaminated with prohibited substances. Whereas there may be some wild fish that are eligible, the fish that really got the aquaculture argument started--the Alaskan salmon--certainly doesn't seem a likely candidate for certification under the current regulations. How certifiers will respond when applications come in from aquaculturists, however, is anybody's guess.
The National Organic Standards Board (NOSB) has long opposed the certification of wild-caught fish, despite lengthy input by representatives of Alaska as well as a federally funded study of aquaculture in the US. After years of work by the past and present board, their position on this issue never wavered. Frustrated and disappointed, NOSB member and Tufts University professor, Willie Lockertz, resigned from the NOSB after the release of the Policy Statement. In a letter to Agriculture Secretary Ann Veneman, he wrote: "Once I saw a pattern emerging in which NOP almost never acted in accordance with NOSB's policy recommendations, I found it impossible to justify my participating in NOSB." Willie's expertise and involvement will be missed, and NOP is seeking candidates to replace him.
Whereas there is controversy over the certification of wild-caught fish, most people agree that it is possible to certify farm-raised fish and some certifiers have been doing so for several years. Concerns over the quality of our ocean, river and lake waters; of over-fishing, heavy metal contamination, and damage to endangered species, have led many a fish lover to abstain from any wild-caught seafood. (In July, the EPA warned that pregnant women should avoid consuming tuna more than twice weekly, due to mercury buildup in that ocean species. In addition, two recent studies showed that non-organic farmed salmon -- raised in net pens -- actually had up to ten times the level of pollutants as its wild cousins, since the farm fish were fed from industrial harvest of ocean catch that was then concentrated in pellets. --Ed.)
Fish farming is a viable alternative; it produces a quality-controlled, protein-rich product and has helped many farmers find a sustainable diversification for their operations. Some fish farms are wonderful examples of diversity themselves. Some are modified greenhouses with in-ground tanks whose wastewater is used to irrigate and fertilize trays of greens or salad mixes, others are ponds that are located well within the boundaries of an organic farm. While they may take on many shapes and sizes, the message from NOP is that the one thing that must remain consistent for them to be "organic" is compliance with the USDA Organic Rule.
How consistent things will actually be remains to be seen. Information and updates on the regulations are available on the NOP website, which refers people with questions about the aquaculture standard to the NOSB recommendation, yet makes the disclaimer that while serving as guidance these are not regulations (standards) until formally implemented by NOP. The site, at http://www.ams.usda.gov/nop, contains a wealth of information about the organic rule.
Not just fish...
Aquaculture is not the only new item that will bring more controversy and questions as time goes on. The policy will add to the range of organic products you'll be seeing in the near future. Look forward to the following organic products coming to you as soon as certifiers get ready to handle them: pet foods; fabrics; cosmetics; body care products; over-the-counter medications; dietary supplements; fertilizers; soil amendments; and products from greenhouse, apiculture, and hydroponic systems. Meanwhile, we'll keep you updated on the issues surrounding each one.