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OCA Files Open Letter to the NOSB on Organic Fish Standards

National Organic Standards Board
United States Department of Agriculture
Room 4008 - South Building
1400 Independence Ave., SW
Washington, DC 20250-0001

 Dear NOSB Member:

I am writing on behalf of the Organic Consumers Association, a national organization representing the interest of over 850 000 members. Our work as a watchdog organization focuses on issue surrounding justice, health and sustainability.

The integrity of organic standards has been consistently jeopardized by industry and special interest group pressure and consumers need to know that organic standards do not bend to meet the any special interest.  We look to the expertise of the NOSB to continually support the principles of organic standards. We are aware that the National Organic Standards Board Livestock Committee has recommended that fish raised in open-net cages and those using wild caught fish in their diets be excluded from national organic standards for aquaculture.  We are in support of this decision, but extend our opposition to the development of national organic standards that include carnivorous fish species such as salmon raised in open and closed systems.

Our concerns and reasons why the use of carnivorous finfish used in aquaculture (including open and closed systems) are inconsistent organic principles, include:

”¢    In open net-pen and closed systems, the use of fish meal and fish oil to grow carnivores supports the ecologically unsustainable practice of over-fishing forage fisheries that are one of the most important foundations of healthy marine ecosystems;      ”¢    Open and closed systems prohibit the innate migratory behavior of species such as salmon is inconsistent with providing the animal living conditions that accommodate health and natural behaviors of the animal;    

”¢    Altering carnivorous fish diet to include plant based foods in aquaculture practices violates the principle of adhering to the natural diet of the species;

”¢    Open net-cage systems cannot control inputs into the system nor do they maintain or improve biodiversity and ecological integrity in the areas where they operate;

”¢    The use of open net-pens in carnivorous aquaculture production has been responsible for the death of thousands of seals and sea lions. This is in direct violation organic principles.

”¢    Use of open net-pens and other open systems allow escaped farmed species into the marine environment where they can cause significant declines on native populations;

”¢    Open water net-pens and other open systems do not minimize the occurrence and spread of diseases and parasites but rather facilitate their transfer from farmed to wild species;      ”¢    Use of open net-pens and other open systems do not foster the cycling of resources and instead allow indiscriminate and unmanaged waste dispersal into the marine environment;

”¢    Contrary to organic consumer expectations, studies have consistently shown that the use of fishmeal in open net-pen systems significantly increases the levels of environmental contaminants, such as PCBs, in farm-raised fish when compared to wild caught fish.

”¢    Efforts by the aquaculture industry to become more sustainable should be applauded, however increasing sustainability in "food" production does not necessarily mean that systems qualifies as organic.

We urge the NOSB to uphold the principles of organic standards and to continue to exclude carnivorous finfish from the organic realm.   It is imperative that the organic name continues to be a meaningful production standard and meet high consumer expectation.


Organic Consumers Association