Organic aquaculture.
April 2008
Comments to coming EU legislation.
Fie Graugaard, Hanegal A/S, Denmark
Organic aquaculture in Denmark is presently solely focused on trout species, but worldwide
many other fish species are produced organically, and according to differing legislation.
Much indicates that future EU-laws concerning organic aquaculture will have considerable
influence on the development of worldwide legislation.
It is therefore very important how main strategies in any new EU legislation are formed, as
they will create precedence for the growing international market.
Fish feeds.
Both the Danish Research Centre for Organic Agriculture and Food Systems (Forskningscenter for
Økologisk Jordbrug og Fødevaresystemer – FØJO) and the Danish Fisheries Institute (DFI)
conclude that fish feeds are the largest challenge in organic aquaculture.
A recent DFI report argues for a significantly higher content of plant proteins in fish feeds, and
DKr7mill has been granted to a 4-year project to research possibilities.
There are however, several reasons why a significantly higher content of plant proteins in fish feeds
should not be encouraged.
1. Predatory fish, such as trout, have a natural need for ‘fish’ proteins, and if fed excessive
levels of plant proteins with a disproportionate amino acid composition and low
digestibility, there is a definite risk that fish immune defence levels will be reduced, while
much protein will not be utilised optimally. This could also result in increased disease
pressure and pollution with nutrient discharge to the environment.
2. With the increasing world human population, the need for increased protein crop production
for human consumption will continue to increase. By increasing land areas for the
production of organic fish feeds, this will contribute to limiting the area available for human
food production. The same problem exists with the present increased production of bio
fuels, which has contributed to rises in food prices and cereal shortages.
3. In addition there is also the fact that global human consumption of meat and associated
products is also increasing. The amount of crop protein suitable for human consumption is
greatly reduced when plant protein is fed to cattle and pigs. Only 10-20% is passed on as
utilisable protein in the form of meat. An increasing human consumption of meat therefore
increases the demands on crop production, without resulting in increased available protein
as human food – on the contrary. However, proteins to aquaculture fish are much better
utilised with a conversion rate of 80-90%.
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Presently 66% of world fishmeal production is fed to terrestrial livestock, especially pigs and
poultry! It would be more optimal and natural if farm livestock production was based mainly
on plant proteins, leaving marine proteins to fish!
The objectives of the above-mentioned Danish research project and the EU Commission
regarding aquaculture are to maximise the level of plant proteins in fish feed.
I do not believe that this should be an objective in organic aquaculture.
Phosphorus content in fish feeds and low-temperature fishmeal.
In Denmark phosphorus levels in fish feeds – conventional and organic - are not legally permitted to
exceed 1%, in order to minimise discharges to the environment.
For the same reason, organic fish feeds can only incorporate low-temperature fishmeal.
Low-temperature fishmeal is processed more gently, and has both higher quality and digestibility
compared with other fishmeal. Fish can therefore utilise a much greater proportion of nutrients,
such that losses to the environment are minimised.
The level of phosphorus in trout is 0.45% of live weight, and must been seen as a guideline as to
dietary requirements for fish. A maximum level of 1% in fish feeds is therefore adequate.
In other EU countries environmental legislation is less restrictive than in Denmark. With respect
especially to water environments and ground water supplies in the future, there are many good
reasons that the whole of Europe should have environmental objectives equal to those in Denmark.
Organic aquaculture is an obvious force in the improvement of water environments. In all
circumstances it will be problematic if organic production contributes to a deterioration of water
environments.
It is therefore recommended that EU laws require that all fishmeal in organic fish feeds is
low-temperature processed, and that phosphorus levels are maximum 1-2%.
(Presently, the majority of conventional aquaculture in Northern Europe actually feed lowtemperature fishmeal!)
Astaxanthin
Using colour-pigments in organic products, also in feed for animals, is against the general aims in
producing organic food. Nevertheless astaxanthin is used to colour the flesh in especially salmon.
Astaxanthin are naturally occurring carotenoids in ex. shrimp shells and algae, and when fish are
living in the wild, this feed will make the fishflesh pink.
When trouts and salmon are farm raised, there will be no astaxanthin in the fishfeed unless it is
added to the feed as artificially colour.
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Many studies have shown that carotenes from natural fruit and vegetable are protective, but
synthetic carotenes gives contradictory results!
Most consumers who buy organic products, feel safe that there is no unnecessary additives in the
food. It is a matter of trust - and there is no technological need for using colour.
EFSA, the european food safety authority, has concluded that the existing documentation to judge
the ecological consequence of using astaxanthin, is not enough.
Astaxanthin should not be allowed in organic fishfeed in concentrations that colour the flesh.
Management.
Different species have different nutritional requirements, which are also dependent upon age in the
specific species. It is imperative that this fact is taken into consideration in the legal formulation of
EU production rules. Inadequate or incorrect feeding of fish can result in low feed utilisation, low
fish welfare, increased disease levels and the discharge of nutrients to the environment.
Organic trout in Denmark - irrespective of age - are presently fed with 2 sizes of pellet-feed, but
which contain identical nutrient content. This is not optimal.
Additionally, no special feed is available for fry, which therefore excludes the production and
supplies of fry for producers. This is due to the fact that organic aquaculture is new in Denmark,
and therefore feed production is presently very limited. However, internationally a much larger
variation of organic fish feed is presently produced.
It is important that optimal feeding of fish according to species, and age, is acknowledged.
Fish stocking densities.
Fish stocking densities must at all times permit natural behaviour for specific species, and
prevent disease outbreaks and aggressive behaviour.
Excessive stocking densities can rapidly result in increased disease frequency and associated poor
fish welfare. Fish stocking densities should not however, be defined by the numbers/m3 of water.
Fish react very differently to varying stocking densities dependent upon production- and
environmental conditions.
Observations of fish behaviour, and water parameters that have influence on fish behaviour,
must therefore be recorded daily in producers’ logbooks. Any observed serious behavioural
deviation should result in direct action, so that harmony and normal behavioural patterns can
be restored.
Fish welfare is very dependent upon water quality. The most important parameters are the
concentrations of oxygen, carbon dioxide and nitrogenous compounds. Additionally many
parameters are influenced by water temperature.
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The primary factor for good fish welfare is water oxygen concentration. However amongst different
fish species, a large variation of oxygen sensitivity has been recorded.
Farmed trout are optimally reared at an oxygen concentration of between 65-100% (watertemperature dependent), which is required by Danish legislation. Other fish species in warmer
waters, can however thrive at much lower oxygen concentrations.
Requirements for water oxygen concentration should therefore be species specific.
Feeding rates, feeding techniques, temperature, fish stocking density, plant growth, time of day and
the presence of other gases in water, all play a part in determining water oxygen concentration.
Many factors can influence water oxygen concentration, and as oxygen concentration is such
an important parameter for fish welfare and the prevention of problems, it is imperative that
legislation requires that daily measurements of water oxygen concentration must be recorded
i) at the water inlet, ii) in the vicinity of fish, and iii) at the water outlet.
In systems where fish are reared in cages in still water, oxygen concentration should be
measured close to the fish.
Different technical possibilities of increasing water oxygen concentration exist. It is necessary that
any production should have the technical possibility of increasing water oxygen concentration in
critical periods. However this should not be common practice, as constant necessity to increase
water oxygen concentration is a clear indication of unbalance between water quality, fish stocking
density and feeding level.
Aquaculture production and fish stocking densities that constantly require energy-consuming
artificial oxygen supplies should not be permitted.
Artificial concrete water-recirculation aquaculture?
On the one hand, it seems sensible to be able to supply large amounts of fish as a healthy food, and
as an alternative to beef, pork and chicken. In geographical areas where there are no natural
waterways, it could therefore appear logical to establish artificial aquaculture production – in the
same way housing facilities are built for other organic animal production.
On the other hand, it is unclear “how distant” from natural surroundings it is organicallydefendable to rear fish. How organic is a fish that has been reared in a sterile and energy-requiring
cement environment, without interaction with plants, soil and micro-organisms that live in soilbased water environments??
Experience with conventional pig production in sterile intensive housing has proved that it is
impossible to maintain the exclusion of diseases, despite the fact that this was the original intention.
On the contrary, pigs raised in sterile conditions often are subject to more violent disease attacks,
and have a poorer immune defence than pigs reared in an environment with access to soil, plants
and fresh air.
Pigs are intelligent animals and living conditions have a large influence on their welfare.
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Fish, on the other hand, are not intelligent, and probably do not feel pain? After all probability it is
not necessary to feel sorry for fish! However, that does not justify the rearing of fish in systems that
encourage disease, and force us to adopt chemical and medical solutions to prevent disease.
Weakened and unhealthy creatures are not part of the organic objective.
The subject of artificial water-recirculation aquaculture, based in concrete systems, must not
be excluded and has to be discussed. Present Danish legislation does not exclude this
possibility.
Possible limiting parameters that could be used in permitting organic fish production in
artificial rearing concrete-systems could be based on partial sustainable energy sources, with
maximum permissible utilisation levels of other energy sources as well as a maximum of
chemicals and medicine.
Conversion and Inspection
It has to be very clear to the farmer, to the consumer and to the inspector – what is controlled
organic production and what is not! There must be no doubt on the borderline between organic and
conventional production.
Organic production is now interesting commercial business. One of the biggest risk in the future,
will be to loose the credibility from the consumers. It is more important than ever to educate and
train the inspectors in the different conditions of organic production and in the basics of organic
production. The matters in fish-production is far from the matters in egg-production, ex.!
The inspectors must be trained to judge the conditions in the specific production.
The pay of the inspectors must not be dependent on the approval of any farmer or producer.
The farmer has to submit a conversion plan of the organic production for a period of
maximum 5 years. This plan must include a drawing of the entire organic farm. The distance
to conventional farms must be at least 500m.
The converted area must be physically separated from conventional farms in a way that
prevents contaminated water flow from penetrating the organic farm area.
CV/ Fie Graugaard:
Owner and chairman in the 25 year old and pure organic company, Hanegal A/S, in Denmark.
Chairman for the Danish organic pic-producers in 7 years.
Pioneer - also in marketing organic fish-products into the Danish market.
www.Hanegal.dk
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