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National Aquaculture Association
Policies and Resolutions

NAA Policies: Consensus , Bird Depredation , NAA Aquatic Animal Welfare , NAA Environmental Stewardship Policy , NAA Quality Assurance , NAA Aquatic Animal Therapeutant , Chemical and Vaccine Policy , National Aquatic Animal Health Management Program , Negotiations , Lacey Act , Non-Indigenous Aquatic Species , Lead Agency , Aquaculture Research , Genetically Engineered Aquatic Organisms

NAA Resolutions: Management of Depredating Migratory Birds

Consensus

Decision Process

Background

The NAA Board of Directors must at times make decisions regarding controversial issues. These decisions could have significant impact on the aquaculture industry’s the NAA represents or on individual aquaculture enterprises. Differences of opinion within the aquaculture community and within the NAA Board of Directors may occur.

Several different decision making processes might be selected. Consensus and majority vote are most commonly used and each has advantages. Consensus, while not necessarily making all parties happy because of compromises that must be made, prevents rejection of minority views thus preventing fractionation of the association. Consensus however requires considerable time and effort. Majority vote allows more forceful, timely decisions but can alienate minority views.

Policy:

The NAA:

  1. Will strive for consensus. Consensus will be defined by a 100 % agreement of the NAA Board of Directors.
  2. Will attempt to obtain consensus by careful wording of resolutions or motions.
  3. Will resort to a majority vote if, the presiding officer determines consensus cannot be reached in a timely fashion.
  4. If majority vote is used, both majority and minority positions will be identified and communicated to membership, regulatory bodies and others as appropriate.
  5. If a super majority is not achieved, the NAA Board of Directors will not take a position.

Approved 8.19.01

Bird Depredation

Background

Piscivorous birds can cause significant predation on farm raised fish and shellfish. Several bird species (e.g. blue heron, black crowned night heron, pelican, cormorant and kingfisher) can consume considerable quantities of these animals. Fish not consumed may be physically damaged during attempted predation. Birds may also serve as disease vectors spreading pathogens amongst fish farms or transferring pathogens from the wild to a fish farm.

Control of piscivorous birds can be difficult and expensive. All piscivorous birds are federally protected. Depredation permits can be obtained but these are not usually issued in a timely manner. Bird dissuasion devices (e.g. cannons and/or other scare devices) are of limited success. Exclusion devices such as cages that cover the entire rearing area are expensive, interfere with routine fish rearing activities, and may not readily withstand the rigors of winter weather (i.e. ice and snow). Considerable need exists to develop improved bird management techniques.

NAA Recommends:

1) The U.S. Fish and Wildlife Service manage migratory bird numbers on basis of wild food supply. Where bird numbers exceed wild food supplies, hence allowing for excessive farmed fish depredation, these numbers must be reduced.

2) The USDA Wildlife Services program should be encouraged to actively develop additional control measures.

3) Cumbersome regulatory processes that impede bird control efforts should be removed.

4) Depredation permits should be readily available on a timely basis and should be administered equally by all U.S. Fish and Wildlife regions.

5) Standing depredation orders should be issued for certain species (e.g. double crested cormorant) when requested by the USDA as opposed to the issuance of numerous individual depredation permits.

NAA Aquatic Animal Welfare

Background

Successful aquatic animal husbandry demands these animals are held in healthy environments and fed a healthy diet. Because of their environmental sensitivity to pollutants, aquatic animals are used in biomedical and toxicological studies. These studies help ensure a healthy human environment is maintained or improved.

Aquatic animal farming helps provide an increasing human population with a wholesome, nutritious, consistent quality food and sport fish. To achieve this quality, farm raised aquatic animals are raised under optimal conditions using humane practices. Aquatic animal for slaughter are quickly and humanely euthanized for rapid processing. Aquatic animal reared for stocking in public waters must be transported under good environmental conditions if the fish are to survive. Successful producers routinely follow good production practices. Animal rights or welfare organizations form a diverse group. Some organizations use legitimate legal and political practices to sway public opinion. Some individuals or organizations may not use legal means to achieve their goals. Animal "liberationists" may violate state or federal law, destroy personal or public property, and cause immediate harm to animals or the environment.

Policy : The NAA -

1. Supports the right of aquatic animal farms to use humane husbandry practices in the propagation of finfish and shellfish.

2. Supports the right of all people to use legitimate, legal means to voice their opinions or determine public policy.

3. Opposes individuals or organizations who illegally destroy public or private property.

4. Supports legislation prohibiting dissemination of false information that adversely affects aquaculture product marketability or public opinion about aquacultured products.

NAA Environmental Stewardship Policy

Background

Sustainable aquatic animal and plant production requires good resource management. Water received for production should be of suitable quantity and quality for effective production of aquatic organisms.

Environmental stewardship is the responsibility of each aquatic organism producer. Aquatic animal production does have the potential to contribute plant nutrients, settleable and suspended solids, and therapeutants to effluent streams. The impact of these discharges on the receiving stream is highly variable.

Regulatory decisions must be based on credible science and risk assessment. A thorough understanding of aquaculture farm effluent impact must be evaluated relative to upriver conditions, water quality standards, and beneficial uses.

Considerable research is being directed at aquaculture waste management. These efforts are being conducted by U.S.D.A., universities and the commercial industry. Improvements can be expected in feed formulation, solids collections and disposal, water reuse and multiple use.

Policy

The NAA:

1. Encourages environmental stewardship by all aquaculturists.

2. Encourages regulatory decisions on basis of credible science.

3. Encourages risk assessment that includes cost-benefit analysis.

4. Encourages effluent regulation based on site-specific watershed                        needs.

5. Encourages regulatory decisions that account for beneficial uses and physico-chemical conditions of receiving waters.

6. Encourages efforts that result in development of improved waste management practices.

NAA Quality Assurance

Background

Wholesome aquatic animal and plant products are the cornerstone of success for the US aquaculture industry. Farm raised organisms are nutritious and of high quality. There is general consumer perception that farm raised aquatic animals are wholesome, high quality products. However, consumer perceptions can be readily influenced by misinformation or a breakdown in product quality. Quality assurance programs can help ensure continued production of wholesome products and enhance consumer perceptions. Quality assurance programs can also discredit misinformation.

The NAA has helped develop a voluntary, producer focused quality assurance program for finfish and for shellfish. These programs emphasize integrated health management. The NAA Quality Assurance Programs integrate well into the US Food and Drug Administration mandatory seafood processors safety program.

Processors, distributors and retailers must work cooperatively to ensure product wholesomeness.

Policy

NAA encourages:

1. Participation in a finfish or shellfish producers quality assurance program by all producers.

2. Consumer education.

National Aquatic Animal Health Management Program

Background

Global trade and the possibility of transporting exotic aquatic animal pathogens highlight the need for an effective national aquatic animal health management program. The European Union (EU) is already instituting restrictive programs that will limit the opportunity for aquatic animal pathogen spread. A "competent authority" must be identified in the US if aquaculture animal producers are to participate in EU trade.

State jurisdiction over fish pathogens and the interstate transport of live aquatic animals and aquatic animal products complicates commerce. Conflicting certification requirements and discordant application between public and private aquaculturists may impede commerce. There is a need for greater uniformity.

The development of a national aquatic animal health management program requires participation of commercial, public, and regulatory interests. Food fish, bait fish, and ornamental fishes should be included in program development. Because pathogen inspection programs are expensive, a focus should be placed on user friendly, cost-effective alternatives. A careful risk-analysis for each aquatic animal pathogen should be considered in designing the management program.

National aquatic animal health management programs should encompass all aquaculture interests and take into consideration the developmental stage of respective programs as well as the fact that transfer of pathogens across species is possible. Since all aquatic interests are to be considered for inclusion in this management program, representatives from such groups should be invited to participate in the development process, and in program implementation.

Policy

It is the policy of the NAA:

1. To encourage development of a cost-effective, scientifically sound National Aquatic Animal Health Management Program.

2. To encourage broad and early participation by all interest groups in development of a national plan.

3. To foster a program that prevents introduction or spread of adverse pathogens.

4. To encourage a national program which utilizes a risk based inspection process.

5. To encourage APHIS to serve as the lead agency for certification permits and other import/export requirements for aquacultured fish or products.

6. To encourage harmonization of interstate and international transport health certification requirements.

Negotiations

Background

The NAA is frequently involved in legislative, governmental (regulatory), and national policy discussions. Specific legislation may be developed as a consequence of NAA policy requirements. Additionally, NAA is involved in conjunctive programs with other aquaculture groups or interests. Some negotiations require NAA financial commitment.

Several different negotiation approaches may be used. Winner-take-all approaches can compromise future relationships (short and long term).

NAA Policy:

1) NAA will strive to negotiate legislative actions and other policy issues on the basis of mutual gain.

2) NAA will probe to clarify all interests.

3) Various options for consideration will be developed and presented to all parties.

4) NAA will use objective criteria to support NAA positions.

Lacey Act

Background

The Lacey Act was passed to prohibit the international and interstate trafficking of illegally obtained wildlife and fish or parts thereof. A violation of the Lacey Act may constitute a federal felony offense and under federal sentencing guidelines the penalties for even minor infractions can be quite severe.

Interstate transportation of wildlife, fish, or parts thereof that violates a state law in the receiving state or the state shipped from, is a Lacey Act violation. Thus, what may be a misdemeanor state violation in both of the two states involved, is immediately elevated to a federal felony offense, simply because state boundaries were crossed.

The U.S. Fish and Wildlife Service is the agency that enforces the Lacey Act and their Enforcement Division has historically applied this act to the international and interstate movement of private aquacultural products. In part this is because the U.S. Fish and Wildlife Service does not recognize the private ownership of aquacultural products.

The U.S. Fish and Wildlife Service Director’s Order Number 27 placed a low priority on using the Lacey Act against aquacultural producers except in instances where disease transmission or non-indigenous fish species are involved. Unfortunately, various Regional Directors are interpreting this order differently complicating interstate transport. This order does not address private ownership of aquacultural products.

Policy:

The NAA

1) Supports legislation to exempt private aquacultural products from the Lacey Act.

2) Supports the U.S. Fish and Wildlife Service acknowledgment that aquaculture products, legitimately reared in private culture, are PRIVATE property, not public. We further support efforts that recognize aquacultured products as private property in federal and state laws and regulations.

3) Supports efforts by the U.S. Fish and Wildlife Service and the USDA to compile and disseminate annually a list of all state and federal regulations that pertain to aquaculture.

Non-Indigenous Aquatic Species

Background

As national and international travel and trade has grown, so has the intentional and non-intentional movement of plants and animals. Not only have many native species been moved around within our own country but more than 30,000 new species have been introduced as well. Many of these species have been intentionally introduced for a wide variety of beneficial purposes such as food and fiber production, vaccine and drug development, companion animals for recreation and plants for landscaping. The movement and trade of non-indigenous species are an essential part of our economy and well being. In fact, researchers recently estimated that fully 98% of the U.S. food supply, valued at over $500 billion annually, now comes from introduced non-indigenous plants and animals.

The USGS has recently compiled a database with over 17,000 entries documenting the introduction of over 500 non-indigenous fish species in the U.S. Three hundred seventeen (317) of these species are native to the U.S. but have been introduced outside of their native ranges. Included in this listing are many highly valuable aquacultured species such as rainbow trout, brook trout, arctic char, channel catfish, striped bass, various Pacific salmon, Atlantic salmon, and ornamental fish. One hundred eighty five (185) non-indigenous fish species have been brought in from foreign countries and 22 of the non-indigenous fish species are due to hybridization. Of the 185 fish species brought in from foreign countries, 71 species have either already established self-sustaining populations in open waters or are believed able to do so. In addition to finfish, numerous species of oysters, clams and mussels and other shellfish, crustaceans, aquatic plants and algae are non-indigenous but highly valued, commercially cultured and economically important.

Not all introductions have been intentional or beneficial. Everything from rats to English sparrows and purple loosestrife to Dutch elm disease continue to have damaging biologic and economic effects. It was recently estimated that harmful introduced species now cost our country $123 billion a year in economic losses. Aquatic plants and animals are no exception to this problem. It was recently estimated that over $5 billion dollars in economic losses can be attributed to the adverse effects of introduced aquatic organisms such as the zebra mussel, Asiatic clam, green crab, and various species of fish.

Public awareness of economic and biologic impact of the zebra mussel became so great that it prompted Congress to enact the "Non-indigenous Aquatic Nuisance Prevention and Control Act" in 1990. This act not only provided the mechanism to address the zebra mussel problem but also provided opportunity to examine other non-indigenous aquatic species. Current resources and activities are primarily focused on such issues as ballast water dumping and other mechanisms of non-intentional introductions, but intentional introductions related to commercial aquaculture are also under consideration. A Presidential Executive Order was recently issued requiring Federal agencies to work collaboratively through an Invasive Species Council to reduce the risk of bio-invaders. The Council will develop a National Invasive Species Management Plan.

Policy

NAA:

  1. Strongly supports the reasonable and unencumbered movement of beneficial aquatic species. Such movement is essential to the sustainability and growth of aquaculture industries.
  2. Recognizes that the introduction of some aquatic organisms may have undesirable or damaging effects, in some instances, even on established aquaculture industries themselves.
  3. Supports the design and implementation of any reasonable plan or effort to minimize the risk of introduction or dissemination of unknown or clearly undesirable aquatic nuisance species.
  4. Demands that any measure or determination of desirability or beneficial value of an aquatic species be based on findings of fact and objective science and that any decisions be based on unbiased assessment of the real and proven risks relative to the potential value and benefits of the introduction or movement.
  5. Demands that laws, regulations or policies designed and implemented to prevent the introduction or dissemination of unknown and undesirable non-indigenous aquatic species neither supplant current laws and regulations which provide for the free and essential movement of aquaculture products nor be allowed to be used for the covert purpose of restricting or eliminating commercial aquaculture.
  6. Is opposed to any extension of non-indigenous species regulations that attempt to include pathogenic parasites, bacteria or viruses of aquatic animals.  Laws, regulations and policies are already established and working on a regional, state, national and international level to address pathogens.

Lead Agency

Policy

The NAA, since its inception, has maintained that aquaculture is agriculture and therefore believes that the US Department of Agriculture should be the lead agency for aquaculture in all matters.

Aquaculture Research

Background

Continued growth, new innovations and competitiveness in aquaculture depend upon focused research programs. Public funds expended on aquaculture research should strive to keep American farmers profitable and competitive in the culture of safe and nutritious food, bait, recreational fish, ornamentals, and other aquatic crops.

Publicly supported researchers and their institutions are facing many challenges in maintaining adequate funding support. They are increasingly looking to supplement grant funding through innovative methods and partnerships including private contracts, joint ventures, licensing of intellectual properties, foreign sources and personal consulting. This approach may help make research institutions more self-sufficient, however, it conflicts with the basic mission and ideals of the land grant institutions to carry out research and provide practical information to American farmers. The function of these institutions must be to continue to find solutions to problems and create, but not control, technology thereby helping maintain the competitiveness of our farmers.

One strength of American aquatic farmers is due to our strong publicly supported research programs. Farmers need to have a stronger role in determining their aquaculture research needs, demonstrating technology or carrying out on-farm research, and being the prime recipients of the results and benefits of publicly supported research. Congress should relieve university researchers from liability issues when collaborating with a farmer or group of farmers so long as there is a level playing field as well as develop mechanisms for farmers to share ideas with universities which may lead to advancements in aquaculture technology.

Policy.

NAA:

  1. Recommends a publicly supported increase in aquaculture research, demonstration and development funding.
  2. Supports direct participation of aquatic farmers and private industry stakeholders in all levels of research planning, carrying out of research programs, and dissemination of results. This includes strong participation by farmer advisory committees within USDA, land grant institutions, and other government agencies and research programs.
  3. Encourages improved aquaculture research coordination within the federal government.
  4. Supports the ideal that the primary beneficiaries of publicly funded aquaculture research should be American farmers.
  5. Encourages Congress to establish methods for farmers to develop their research ideas with the universities in such a manner that the farmer will benefit, the university benefit, and other farmers will benefit without the fear of liability issues.
  6. Supports University research that focuses on domestic aquaculture.
  7. Encourages federal funding that helps integrate aquaculture with traditional agricultural practices, water reuse, and water management and conservation.

Genetically Engineered Aquatic Organisms

Background

Genetically modified organisms (GMO’s) may be defined for various purposes. The NAA defines GMO’s as organisms that have been genetically modified by integration of foreign DNA into their genomes using various gene transfer technologies including microinjection, electroporation, transposon integration, or viral infection. Any natural sexual reproduction of organisms causes genetic modification of organisms but these are not ordinarily regarded as a GMO. Natural mating and/or natural recombination does not create a GMO. Selective breeding, hybridization and polyploidy are natural processes and would not be considered a GMO. For the purposes of NAA, a GMO will be defined as those organisms that have had their normal genetic makeup altered by molecular methods of selective gene isolation, characterization, and modification.

Genetically engineered or modified (GMO) aquatic organisms could significantly increase production efficiencies and reduce the environmental impacts of aquaculture with proper containment procedures. Faster growing animals could ultimately increase harvestable fish supplies for human consumption and reduce the use of water, a limited natural resource. This increased production could occur while decreasing the amount of feed fed per fish for each pound of gain. Thus, feed conversion efficiencies could potentially be improved. This would reduce dependence on natural fish meal supplies which might reduce exploitation of wild fish stocks. Other attributes of the fish such as immune system function could also be improved. The consumer might also directly benefit from such modifications by enhancing the nutritional and health benefits of aquatic organisms, increasing carcass yield and other desirable market traits, all with lower costs to the consumer.

Commercialization of genetically engineered aquatic organisms is also highly controversial. Various interests groups propose that genetically engineered aquatic organisms are a threat to the environment, a threat to various endangered species and a threat to human health following consumption. However, there is little scientific data to conclude genetically engineered organisms are harmful to the environment or to human health. Conversely, there is little scientific data to prove genetically engineered aquatic organisms are safe for the environment or human health. There is little scientific data with which to conduct environmental risk analysis making an informed decision difficult.

Policy

NAA:

  1. Encourages a thorough scientifically based investigation into human food safety of genetically engineered aquatic organisms.
  2. Encourages a thorough scientifically based investigation into the environmental safety of genetically engineered aquatic organisms.
  3. Encourages sound, scientifically based risk analysis by the federal regulatory community.
  4. Encourages various continued and vigorous scientific investigations into ways to improve aquatic organism production efficiencies and product quality for consumer’s benefit including the use of genetically engineered aquatic organisms.

Approved 8.18.01

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