TO: US Aquaculture Community and Parties Interested in USDA Organic
Standards for Farmed Aquatic Foods
FR: Gary Jensen, National Program Leader for Aquaculture, CSREES-USDA
_____________________________________________
This communiqué provides a summary overview of significant
milestones leading to the recent posting of an Interim Final
Report by the Aquaculture Working Group of the National
Organic Standards Board and a request for your critical
review and submission of comments on this Report no later
than April 1. This report can be accessed at:
http://www.ams.usda.gov/nop/TodaysNews.html under the heading
of February 7.
The expression of your interest and participation via a
public comment process is an important step to advance
approval of organic standards by USDA for certification of
farmed aquatic species in our markets. Please take some time
to review this Report and respond to as many of the questions
listed by the National Organic Standards Board to assist them
in their deliberation on recommendations for organic
standards to the Secretary of Agriculture and subsequent
rulemaking procedures. As you will clearly note, much work
has been done to reach this stage. Now your support and
assistance are needed to move the process forward in a
positive direction and outcome.
As some of you may know, there have been periodic efforts
over the past years to develop organic standards for farmed
aquatic species certified under the USDA National Organic
Program by accredited certifiers. You may also read about the
increasing interest in this topic globally with conferences
on organic aquaculture held in many countries. The USDA
National Organic Program conducted several public meetings as
far back as 2000 concerning potential certification of wild
caught and farmed aquatic animals. Subsequent to these public
meetings, the National Organic Standards Board (NOSB) created
an Aquatic Animal Task Force which completed a report to the
NOSB in 2001 with recommendations on operations that produce
aquatic animals. The report can be reviewed at:
http://www.ams.usda.gov/nosb/FinalRecommendations/Oct01/AquaticTaskForce.html
The NOSB accepted the report and approved several
recommendations that can be reviewed at:
http://www.ams.usda.gov/nosb/FinalRecommendations/Oct01/AquaticNOSB.pdf
The University of Minnesota took the lead with a National
Organic Aquaculture Conference in 2000 followed by an
International Organic Aquaculture Workshop in 2003. Also, in
2003 the National Organic Aquaculture Workgroup (NOAWG)
formed as a spontaneous ad-hoc group of persons interested in
advancing organic aquaculture in the US and also in response
to renewed interest by the USDA National Organic Program
(NOP) on standards for farmed aquatic species. NOAWG
submitted a White Paper to USDA in 2005 on Proposed National
Organic Standards for Farmed-Aquatic Animals (Aquaculture)
with Supporting Documentation and Information. You may also
know that aquatic products are being marketed legally in
the US under organic standards certified by international
bodies. Current regulations prohibit use of the USDA organic
seal in these cases because of the lack of approved
standards.
So why is it important for the USDA to develop national
organic standards for farmed aquatic species?
· With national standards, all products marketed in
the US will comply with the same consistent standards under
USDA accredited certifiers, thus avoiding the current system
whereby products are marketed under various international
standards. This will create a level-playing field for all
products certified under USDA standards whether produced
domestically or imported.
· The recent decision by the State of California to
ban the sales of any aquatic food product with an organic
label claim until national USDA standards are promulgated
into law is one example of the confusion with the current
situation. California is likely a strong market for organic
certified foods, yet aquatic foods cannot have access to this
market under current state law.
· Of the major food categories and recommendations by
federal agencies regarding a healthy diet for the American
public, aquatic foods is the only major food category not
eligible under the current USDA regulations for organic
agriculture because of specific language that excludes fish
under the definition of livestock. The situation denies
consumers from this choice or preference in the market and
also prohibits aquaculturists from considering organic
farming in their business planning using USDA nationally
recognized standards.
· Recent studies (United States Market for Organic
Seafood) on consumer perceptions and preferences on organic
seafood indicate a strong interest in purchasing these
products if they are available and current consumer
misunderstanding and confusion were evidenced by consumer
responses on lack of credible standards as an important
reason for not wanting to purchase organic seafood. This new
information provides useful insights into the issues and
opportunities associated with this market option. To review
a copy of the full report go to: www.jerseyseafood.nj.gov
With this background, what is the current status of gaining
USDA approval and what can persons do who have a vested
interest or desire for standards to be approved?
Today, the prospects for approval are greater than ever
before because of the decision by the National Organic
Standards Board in 2004 to form a Task Force on Standards for
Aquatic Animals. Nominations for membership were solicited
via an open public process through a Federal Register notice.
In May, 2005, the NOP named 12 diverse and experienced
individuals, with backgrounds in aquaculture production and
nutrition, environmental science, and organic principles, to
the Aquaculture Working Group of the Aquatic Animal Task
Force. Members for the wild-caught working group have not yet
been named, because of a low response to the call for
nominations. On January 13, 2006 the National Organic Program
received the Interim Final Report of the Aquaculture Working
Group for the production and handling of organic aquaculture
products. The NOP has submitted the interim final report to
the NOSB for review and acceptance at its April 17-19, 2006,
NOSB meeting in Pennsylvania. After acceptance of the report
by the NOSB, the NOSB's Livestock Committee will commence
work on developing a recommendation for the full NOSB to
consider as a recommendation to the Secretary of Agriculture.
The 22-page Interim Final Report of the Aquaculture Working
Group is posted on the NOSB web site under February 7 and can
be accessed at: http://www.ams.usda.gov/nop/TodaysNews.html
What is critically needed now to move this process forward is
for persons to take time to carefully and thoughtfully review
this Report and provide comments directly to the National
Organic Standards Board via the following options:
· Mail: Persons may submit comments on listed Board
recommendations by mail to: The
National Organic Standards Board; c/o Valerie Frances; Room
4008 - SouthBuilding;
1400 and Independence Avenue, SW;Washington, D.C.20250-0001.
· E-mail: Comments may be sent via internet
to NOSB.Livestock@usda.gov.
·Fax: Comments may be submitted by fax to (202) 205-7808.
The NOSB requests that in reviewing and commenting on the
Aquaculture Working Group's Interim Final Report, you
consider responding to as many of the following criteria:
Do the recommended standards:
1. Communicate effectively?
2. Provide clear and adequate context of scope, product
coverage, and production systems?
3. Identify and address key stakeholders and their concerns
and challenges?
4. Include vision and strategy for achieving consistency with
organic principles demonstrated in the Organic Foods
Production Act of 1990 and its implementing regulations?
5. Present measurable objectives that are enforceable?
6. Present a clear expectation of targets and goals?
7. Suggest a system of production that reduces or minimizes
the need for off-farm inputs?
Clearly indicate if you are for or against the recommended
standards or some part of it and why.
Include recommended wording changes as appropriate. Include a
copy of articles or other
references that support your comments. Only relevant material
should be submitted.
Although the posted guidance indicates a deadline of April 10
to submit comments, I suggest you submit comments no later
than April 1 if at all possible to allow adequate time for
your comments to be posted on the Internet and more time for
comments to be reviewed by others prior to the April 17-19
NOSB meeting. We are at a critical turning point because
support for these standards has broadened over the past 5
years across many segments of the organic community although
skeptics and opponents likely persist. As a stakeholder in
the US aquaculture community, this is one of those occasions
in which your voice and words are needed to achieve a
challenging objective.
I urge you to take action on behalf of US consumers and our
diverse national aquaculture industry.
Gary Jensen, National Program Leader for Aquaculture
CSREES-USDA
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