Mark Schuessler
Standards Division
Canadian General Standards Board

Dear Mr. Schuessler,

May 31, 2011

On behalf of PCC Natural Markets in Seattle, Wash., I’m writing to express concern about Fisheries and Oceans Canada’s impending approval of “organic” farmed fish.

PCC is one of the oldest, largest natural foods cooperatives in the United States, with nine state-of-the-art retail stores in the Puget Sound area and more than 45,000 member-owners. We’ve submitted comments to the U.S. Department of Agriculture (USDA) about its own proposed standards for organic aquaculture, and recently we testified before the National Organic Standards Board to advocate stronger standards.

Like the U.S. proposal, the proposed Canadian standard does not reflect the basic principles of organics that consumers expect. The United States — and Seattle especially, given our proximity — likely will be a large target market for so-called “organic” fish from Canada. That’s why we feel it’s important that you consider our perspective about the types of seafood and types of aquaculture operations we believe are compatible with organic production.

The proposed standard is inadequate for many reasons, including its failure to address the following:

Impacts on marine environment
A main tenet of organics is that they protect the environment, minimize marine environment degradation, erosion and water quality degradation, decrease pollution, and optimize biological productivity.

The proposed Canadian organic aquaculture standard, however, would allow open net-cage production of farmed salmon, despite significant scientific evidence linking open-ocean salmon farming to wild salmon declines, the spread of disease and sea lice, escapes, pollution, and other impacts on the marine environment. The proposed standard also includes no specific safeguards to reduce open-ocean net-cage impacts. It relies on general recommendations to “minimize” impacts, which is no different than existing regulations.

The proposed standard also allows top-of-the-food-chain, carnivorous fish such as salmon to be certified organic — despite the fact that salmon consume much more wild fish in their feed than the amount of farmed fish produced. Allowing limitless amounts of wild fish to feed farmed fish results in an unsustainable net loss of protein.

Another problem with the proposed standard is that it includes no buffers for wild salmon migratory routes as a measure to protect juvenile wild fish.

Waste management
The proposed standard requires aquaculture companies to develop a plan to manage waste, but there are no performance measures included, nor is there a requirement to recapture farm waste that could be used to produce energy or fertilizer. A prudent standard would include this requirement.

Chemicals and pesticides
The draft Canadian organic aquaculture standard allows for use of synthetic paraciticides, such as highly toxic SLICE, to combat sea lice infestation on certified organic farms. It also allows for up to 100 percent of fishmeal feed to be from non-organic sources, allowing toxins and pollutants that may be contained in wild fish, which can contain toxins such as PCBs, heavy metals, and dioxins.
The proposed standard allows for the use of antibiotics in the production of “certified organic” farmed fish. It also does not require closed containment production, which may prevent the need for antibiotics.

These practices are unacceptable to organic consumers. Alternative feeds and closed containment systems can successfully reduce toxins in feed and reduce the use of chemical treatments.

Open-ocean aquaculture operations that produce carnivorous fish such as salmon cannot meet the standards organic consumers expect. If the Canadian government moves forward with certifying organic fish, the organic standard must reflect practices that address the concerns raised above.

A good place to start would be to certify fish with plant-based diets, such as tilapia and catfish, which are raised in inland, closed-system ponds that recirculate water and collect waste for fertilizer. Closed-system aquaculture operations would minimize if not eliminate entirely many of the environmental problems associated with open net-cage fish farms, such as escapes and the spread of sea lice.

This is the approach we have recommended the USDA’s National Organic Program adopt, and we encourage you to do the same.

Sincerely,

Eli Penberthy
Public Affairs Specialist
PCC Natural Markets
Seattle, Wash., USA

Mark Schuessler
Standards Division
Canadian General Standards Board

Dear Mr. Schuessler,

May 31, 2011

On behalf of PCC Natural Markets in Seattle, Wash., I’m writing to express concern about Fisheries and Oceans Canada’s impending approval of “organic” farmed fish.

PCC is one of the oldest, largest natural foods cooperatives in the United States, with nine state-of-the-art retail stores in the Puget Sound area and more than 45,000 member-owners. We’ve submitted comments to the U.S. Department of Agriculture (USDA) about its own proposed standards for organic aquaculture, and recently we testified before the National Organic Standards Board to advocate stronger standards.

Like the U.S. proposal, the proposed Canadian standard does not reflect the basic principles of organics that consumers expect. The United States — and Seattle especially, given our proximity — likely will be a large target market for so-called “organic” fish from Canada. That’s why we feel it’s important that you consider our perspective about the types of seafood and types of aquaculture operations we believe are compatible with organic production.

The proposed standard is inadequate for many reasons, including its failure to address the following:

Impacts on marine environment
A main tenet of organics is that they protect the environment, minimize marine environment degradation, erosion and water quality degradation, decrease pollution, and optimize biological productivity.

The proposed Canadian organic aquaculture standard, however, would allow open net-cage production of farmed salmon, despite significant scientific evidence linking open-ocean salmon farming to wild salmon declines, the spread of disease and sea lice, escapes, pollution, and other impacts on the marine environment. The proposed standard also includes no specific safeguards to reduce open-ocean net-cage impacts. It relies on general recommendations to “minimize” impacts, which is no different than existing regulations.

The proposed standard also allows top-of-the-food-chain, carnivorous fish such as salmon to be certified organic — despite the fact that salmon consume much more wild fish in their feed than the amount of farmed fish produced. Allowing limitless amounts of wild fish to feed farmed fish results in an unsustainable net loss of protein.

Another problem with the proposed standard is that it includes no buffers for wild salmon migratory routes as a measure to protect juvenile wild fish.

Waste management
The proposed standard requires aquaculture companies to develop a plan to manage waste, but there are no performance measures included, nor is there a requirement to recapture farm waste that could be used to produce energy or fertilizer. A prudent standard would include this requirement.

Chemicals and pesticides
The draft Canadian organic aquaculture standard allows for use of synthetic paraciticides, such as highly toxic SLICE, to combat sea lice infestation on certified organic farms. It also allows for up to 100 percent of fishmeal feed to be from non-organic sources, allowing toxins and pollutants that may be contained in wild fish, which can contain toxins such as PCBs, heavy metals, and dioxins. The proposed standard allows for the use of antibiotics in the production of “certified organic” farmed fish. It also does not require closed containment production, which may prevent the need for antibiotics.

These practices are unacceptable to organic consumers. Alternative feeds and closed containment systems can successfully reduce toxins in feed and reduce the use of chemical treatments.

Open-ocean aquaculture operations that produce carnivorous fish such as salmon cannot meet the standards organic consumers expect. If the Canadian government moves forward with certifying organic fish, the organic standard must reflect practices that address the concerns raised above.

A good place to start would be to certify fish with plant-based diets, such as tilapia and catfish, which are raised in inland, closed-system ponds that recirculate water and collect waste for fertilizer. Closed-system aquaculture operations would minimize if not eliminate entirely many of the environmental problems associated with open net-cage fish farms, such as escapes and the spread of sea lice.

This is the approach we have recommended the USDA’s National Organic Program adopt, and we encourage you to do the same.

Sincerely,

Eli Penberthy
Public Affairs Specialist
PCC Natural Markets
Seattle, Wash., USA