U.S. Trout Farmers Association Policies
Piscivorous birds can cause significant predation on farm raised trout. Several bird species (e.g. blue heron, black crowned night heron, pelican, cormorant and kingfisher) can consume considerable quantities of fish. Fish not consumed may be physically damaged during attempted predation. Birds may serve as pathogen 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 timely or effective. Bird dissuasion devices (e.g. cannons and/or other scare devices) are of limited success. Exclusion devices such as cages that cover the entire fish rearing area are expensive and may not readily withstand the rigors of winter weather (i.e. ice and snow). Considerable need exists to develop improved bird management techniques.
- The U.S. Fish & Wildlife Service manage bird numbers on basis of wild food supply. Where bird numbers exceed wild food supplies, hence allowing for excessive farmed trout depredation, these numbers must be reduced.
- The USDA Animal Control program should be encouraged to actively develop non-lethal control measures.
- Cumbersome regulatory processes that impede bird control efforts should be removed.
- Depredation permits should be readily available on a timely basis.
Sustainable trout production requires good resource management. Water received for production must be of suitable quantity and quality so trout can be economically produced. Adequate water quality is also important for ensuring financially successful production.
Environmental stewardship is the responsibility of each trout producer. Trout production does have the potential to contribute plant nutrients, settleable and suspended solids, and drugs to effluent streams. The impact of these pollutants on the receiving stream is highly variable.
Regulatory decisions must be based on credible science and risk assessment. A thorough understanding of trout effluent impact must be evaluated relative to upriver conditions and biological response. Risk assessment must account for socio-economic, health and biological impact. Considerable research is being directed at aquaculture waste management. These efforts are being conducted by USDA, universities and the commercial industry. Improvements can be expected in feed formulation, solids collections and disposal.
- Encourages environmental stewardship by all trout producers.
- Encourages regulatory decisions on basis of credible science.
- Encourages risk assessment that includes cost-benefit analysis.
- Encourages effluent regulation based on site-specific watershed needs.
- Encourages regulatory decisions that account for beneficial uses and physico-chemical conditions of receiving waters.
- Encourages efforts that result in development of improved waste management practices.
FISH DRUGS, CHEMICALS AND VACCINES
Good fish health management is essential for successful trout production and must be based on integrated health management practices. These practices emphasize disease prevention and include the management of host, pathogen and environment. Vaccines can be a useful tool to prevent disease. To help maintain a healthy environment, water treatment chemicals may be used. Disease may nevertheless occur. Drugs may be used to alleviate animal suffering and help treat disease.
The number of drugs or vaccines federally approved for use in trout production is limited. The U.S. trout industry is relatively small. Programs must be developed that encourages vaccine and drug development.
Wholesome trout products are essential to continued consumer acceptance. Use of federally approved drugs and water treatment chemicals are essential.
- Use of only federally approved vaccines, drugs (including low regulatory drugs) and water treatment chemicals by all trout producers.
- Adoption of the USTFA Trout Producers Quality Assurance Program by all trout producers.
- Cooperative approaches to obtaining additional vaccine, drug or water treatment approvals for use in trout production.
- Educational programs that inform trout producers about fish health management practices and proper use of drugs to treat fish disease.
- Development of preventive measures (e.g. vaccines) to diminish the needs for disease treatments.
- Development and approval of drugs that are efficacious, environmentally safe and economical.
NATIONAL FISH HEALTH MANAGEMENT PROGRAM
Global trade and the possibility of transporting exotic fish pathogens highlight the need for an effective national fish health management program. The European Union (EU) is already instituting restrictive programs that will limit the opportunity for fish pathogen spread. A Acompetent authority@ must be identified in the US if trout producers are to participate in EU trade.
State jurisdiction over fish pathogens and the interstate transport of live fish and fish products complicates commerce. Conflicting certification requirements and the discordant application between public and private aquaculturists may impede commerce. There is a need for grater uniformity.
The development of a national fish health management program requires participation of commercial, public, and regulatory interests. Sport fishing groups have a legitimate interest and should be included in program development. Pathogen inspection programs are expensive. User friendly, cost-effective programs should be developed. A careful risk-analysis for each fish pathogen should be conducted when designing the management program.
National fish health management programs should consider all aquaculture species and recognize the developmental stage of each aquaculture program. Transfer of pathogens across species is possible however, risk-benefit must be considered. Since all aquatic species would be considered for inclusion in a national fish health management program, representative from all species groups should be invited to participate in program development.
It is the policy of USTFA:
- To encourage development of a cost-effective, National Fish Health Management Program;
- To encourage broad and early participation by all interest groups in development of a national plan;
- To foster a program that prevents introduction or spread of exotic pathogens; and
- To encourage a national program which utilizes a risk based inspection process and rewards consistent producer compliance.
Wholesome trout products are the cornerstone of success for the US trout industry. Farm raised trout are nutritious and of high quality. There is general consumer perception that trout 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 USTFA has developed a voluntary, producer focussed quality assurance program. This program emphasizes integrated fish health management. Financial savings by trout producers can occur through implementation of the USTFA Quality Assurance Program. The USTFA Quality Assurance Program integrates well into the U.S. Food and Drug Administration mandatory seafood processors safety program.
Processors, distributors and retailers must work cooperatively to ensure trout product wholesomeness.
Universal adoption of the USTFA Trout Producers Quality Assurance Program by all trout producers; and
Historical observations suggest whirling disease, caused by Myxobolus Cerebralis, does not cause significant detrimental impacts on wild fish populations and that in fish hatcheries,
M. cerebralis impacts can be well controlled. Recent observations suggest wild fish populations could be adversely impacted by M. cerebralis. Factors accounting for this negative impact are not understood. Several possibilites exist including changes in pathogen virulence, changed environmental conditions adversely impacting fish or changes in fish sensitivity to the parasite.
Considerable controbersy exists as to how to manage the disease or the parasite. Management decisions by fishery agencies can have a significant impact on commercial trout producers. Consumers and resource users may be misled by poor and unsubstantiated information. Management decisions and information transfer must be based on sound science.
Research to determine the most cost-effective management practices must be conducted. The commercial trout industry can play a significant role in discovery. Collaborative efforts between user groups would optimize research dollars.
- The USTFA recommends that all user and producer groups be involved and work collaborativly in the determination of management strategies.
- The USTFA recommends that scientifically justified information be used to determine management options.
- The USTFA insists that only substantiated information be presented in the lay press and that incorrect information be withdrawn.
- The USTFA recommends that research be supported that better defines the impact of M. cerebralis on wild fish populations, the distribution of the parasite and possible treatment or preventive measures.
TROUT HEALTH CERTIFICATION
The European Union and other countries are developing fish pathogen import requirements that stipulate a Acompetent authority@ certify the specific pathogen free status of fish. Additionally, individual states may require fish health certification for interstate movement of trout. Certification requirements may vary from state to state.
A variety of agencies and individuals have historically been responsible for fish health certification in the U.S. These include the USFWS, NMFS, USDA-APHIS, state fish pathologists, AFS-FHS certified fish pathologists or inspectors, USFWS-Title 50 inspectors and licensed veterinarians. Many of these groups license, certify or otherwise ensure inspections are objective and performed by a competent authority. Certified AFS-FHS inspectors can have their certification revoked by a Board of Certification, for example. Testing procedures often vary.
- Supports USDA-APHIS as the lead agency ultimately responsible for the health certification of fish and fish products for international export;
- Supports a collaborative program amongst all federal and state agencies that recognizes AFS-FHS fish pathologists, fish health inspectors, licensed veterinarians, and Title 50 inspectors as competent, under the authority of APHIS to certify trout and trout products for export or interstate transport;
- Encourages the harmonization of interstate certification requirements.
AQUACULTURE IS AGRICULTURE
Aquaculture by definition, is the husbandry or cultivation of aquatic animals and plants. This cultivation occurs to produce food for consumers or to produce fish for stocking into private or public waters. Production may occur for commercial purposes or as part of public policy and resource management.
Farm raised trout and trout eggs are purchased from private sources, are held in confinement on private property are used in interstate commerce, and are considered private property for tax purposes. Further, aquaculture was recognized as agriculture in the Agriculture Act of 1980.
- Insists that all agencies with jurisdiction over trout aquaculture regard aquaculture as agriculture;
- Insists that commercially aquacultured trout be regarded as private property, able to be traded in interstate commerce; and
- Insists that trout be regarded as livestock for fish health management purposes.