The world wildlife trust (WWF) has been campaigning for standards in pangasius production since 2007, when the Pangasius Aquaculture Dialogue (PAD) was established. The Dialogue consists of over 400 pangalisius farmers, processors, exporters, traders, retailers, feed and chemical manufacturers, seed suppliers, government agency representatives, non-governmental organisation and researchers.
Draft principles, criteria, indicators and standards were developed by Technical Working Groups that began meeting in the spring of 2008. The first draft of principles, criteria, indicators and standards was posted in April for the first of two 60-day public comment periods. Feedback received during that period was discussed at the last meeting of the Dialogue, held in August in Vietnam, and used to revise the document. The second draft of the standards document was posted for public comment on November 20, 2009. Feedback is required by January 20, 2010. The standards are expected to be finalised during the first quarter of 2010.
When finalised, the standards will be given to a new organisation, the Aquaculture Stewardship Council, which will be co-founded by WWF. The Council will be responsible for working with independent, third party entities to certify farms that are in compliance with the standards.
The proposed standards are as follows.
Pangasius aquaculture operations must respect and adhere to national and local laws, the standards propose 100 per cent compliance with the following:
- permits and registration requirements set by local and national authorities;
- all taxes;
- local and national legal regulation on water discharge;
- local and national legal regulations on planning.
Land and water use
The responsible use of land and water resources is fundamental to sustainable pangasius aquaculture. A number of countries have introduced land and water use plans to prevent pangasius farms having a negative impact on other resource users and the environment. The Dialogue has identified that responsible pangasius aquaculture should not result in the loss of wetland habitat or affect the hydrological regime in the area of farm operations.
In order to comply with official development plans, the standards say that farms must be constructed in an area that complies with any approved aquaculture development plans effective in the area. To conserve the wetlands and other ecosystems, it will also stress that farms can only be established by converting agricultural or aquaculture land.
To prevent distress to other resource users, farms must:
- not impede navigation, aquatic animals or water movement;
- allow that water bodies are connected through a path, across the whole water column, that covers the width of at least 50 per cent of the water body;
- not occupy more than 20 per cent of the width of the water body calculated when the water body level/ width is at its minimum;
- in the case of pens, not have more than two contiguous pens at the time and only if a stretch of river bank of the length of the two pens is left free from farms on both sides of the pens.
With regard to water use, farms shall comply with water allocation limits (if available), as set by local authorities or a reputable independent institution. The standards also propose that water intake shall not lead to a reduction of 10 per cent in the water levels. Groundwater can only be abstracted from surficial aquifiers that are regularly recharged and for which there is no evidence of depletion. On top of this, the ration of water abstracted must not exceed 5,000m3 per tonne of fish produced for a given culture period.
Water pollution and waste management
Excess effluents and nutrients in pond sediments can have a detrimental effect on water quality. Recognising that it is difficult to farm pangasius commercially without some impact on the water used, the Dialogue have created standards to control ammonia, nitrogen and phosphorus levels in the water. The standards include maximum levels of nutrients in the water, as well as a minimum level of dissolved oxygen concentration in water discharged. Total phosphorus must not exceed 16.5kg of total phosphorus per tonne of fish produced, total nitrogen must not be greater than 58.1kg per tonne of fish produced.
Waste management is closely related to water pollution issues. Sludge must be disposed of properly, not in public water bodies or natural ecosystems. Evidence of a sludge repository must be available. Dead fish must be disposed of appropriately, for example through burial or incineration.
Pangasius aquaculture raises a number of important issues in relation to genetics, such as impacts on indigenous species when introduced as an exotic species, the importance of preventing escapes, the need to maintain genetic diversity, and the potential problems of Genetically Modified Organisms (GMOs) and hybridisation.
In order to minimise the impact that pangasius aquaculture has on habitats and/or the genetic integrity of local pangasius populations, the standards state that farming shall only occur in locations where the farmed species is indigenous or has a self-recruiting stock established.
Pangasius, in its natural habitat, has a complex population structure, and captive breeding may result in the mixing of genetically distinct stocks. Because it is not sustainable to base pangasius aquaculture on wild-caught fry or broodstock, minimising escapes of captive-bred fish is essential to preventing the genetic perturbation of wild populations.
Pangasius escapees may also have an effect on local non-catfish biodiversity, but the PAD TWG working on this issue has not been able to obtain data on the impacts and to develop reliable metrics to measure this phenomenon. The standards in place to prevent these impacts include Better Management Practices (BMPs). The following BMPs are mandatory:
- Inlets and outlets to culture systems and all confinements are to be equipped with net mesh or grills appropriately sized to retain the stocks in culture.
- Regular, timely inspections and repairs are performed, and recorded in a permanent register (available for inspection).
- Bund height above high water/flood levels.
- Traps on water outlets to catch/kill escapes (e.g., juvenile fish, chemical treatment of effluent ponds) and data are recorded.
While a range of techniques and practices are available to prevent escapes, no foolproof system has been developed. Therefore, it is important to approach escapee management from the perspective of minimisation rather than hypothetical elimination. Escape reduction also is a good business practice, as there are economic incentives to prevent escapes.
The standards say that seeds shall be sourced from pangasius populations already established in the river system and that no wild-caught seed shall be used for on-growing. Also to prevent issues surrounding genetic pollution and impacts on farm stocks and wild populations, no GMO or hybrid seed shall be used.
“Feed” refers to all feeds or feed items, regardless of where or how they are produced, and applies to all farms applying for PAD certification. It is irrelevant whether feed is made on site or by a commercial feed mill.
It is likely in the future that separate feed standards may be developed.
Where the farm produces feed for its own use and has control over the sourcing of ingredients used in that feed, the farm will be required to demonstrate its compliance with the same ingredient-sourcing requirements and standards for feed.
The use of fishmeal and fish oil in pangasius aquaculture, as in other forms of aquaculture, is a key issue.. Concerns centre around the sustainability of fishmeal and fish oil sources as well as ensuring that the amount of fish used to produce fishmeal and oil for farmed pangasius does not exceed the amount of pangasius that are produced on the farm.
Also, the practice of feeding locally sourced fish directly to pangasius can impact the environment and biodiversity. The direct use of fish and fish products (including what is commonly referred to as “trash fish”) to feed pangasius is an unacceptable practice. If these ingredients are to be used to manufacture feed, they should be from legal, reported and regulated fisheries that respect the United Nations Food and Agriculture Organisation’s “Code of Conduct for Responsible Fisheries;” be from a certified sustainable source; not be from a fishery where unacceptable levels of by-catch are caught; and not pose a threat to endangered species that may be inadvertently included in the by-catch. Feed suppliers can ensure that the amount and sources of fish products used in feed, or used as feed, are from sustainable sources.
- Have been sourced from fisheries certified as compliant to standards by an ISEAL member;
- Are from a fishery with a fisheries score of 6 or above on all Fish Source Scores (www.fishsource.org), or
- Have been sourced from fisheries certified as compliant to International Fishmeal and Fish Oil Organisation (IFFO) standards
Good feed management on the farm is essential to achieving efficient use of available feed resources and minimising waste. Fish Feed Equivalence Ratio (FFER) and economic Feed Conversion Ratio (eFCR) provide useful means to measure whether fish product use is being managed and wastes are being minimised. The weighted average of the eFCR must be less than 1.75 for the complete production cycle. The maximum eFCR for each individual pond during the period under consideration for certification must not exceed 2, and must be within 15 per cent of the weighted average. The FFER must be less that 0.5.
Health management, veterinary medicines and chemicals
Managing the health of farmed pangasius stocks depends on the overall management of the farm, including the reasonable, responsible use of veterinary medicines and chemicals. This must be undertaken in a manner that focuses on ensuring fish health and maintaining food safety and quality, while also minimising the impacts to human health and the environment.
A key measure of fish health is survival during the grow-out period. This can be addressed through a comprehensive health management plan. Such plans should promote preventative, proactive treatments over chemical and veterinary medicine use. Regular monitoring of fish for stress or disease and the proper removal and disposal of mortalities are important components of implementing a plan to ensure optimal fish health and reducing the impact of diseases on other farms and the environment. The standards state that real percentage mortality from stocking to harvest, shall not exceed 20 per cent, on average.
Veterinary medicines and chemicals can play an important role in maintaining fish health and survival. Veterinary medicine and chemical use should be restricted to those approved for aquaculture applications by the country of production and those which are not banned for use in food fish by the importing country. Also, the use of antibiotics considered critical for human medicine by World Health Organisation shall not be allowed.
- Only be prescribed by aquatic animal health specialists, and must be applied, handled and stored how specialist indicates;
- Respect the withdrawal period or apply a period of 750 degree-days for those without documented withdrawal times;
- Never be used as growth promoters or for preventive treatment.
Fish stocking density is an important element of maintaining fish health and welfare. There is always a need to find the right balance between space efficiency, farming performance, disease control and fish welfare. Guidance on maximum fish densities for ponds and cages, at any time during production, is an important tool for maintaining fish health. The growth rate shall be higher than 3.85 g/day and the maximum fishing density at any time shall not exceed 38 kg/m2 for ponds and pens and 80 kg/m3.
Social responsibility and user conflict
Pangasius aquaculture should be done in a socially responsible manner that ensures the operations benefit farm workers and local communities.
The labour rights of pangasius workers are important and farm workers should be treated fairly, paid fairly and have the ability to have a reasonable work/life balance, in spite of the need for work hours to be flexible. Appropriate farm conditions include no child labour (under 15 years of age), no forced labour and no discrimination.
Complaint procedures and protection for whistle blowers are critical to achieving and maintaining fair and equitable working conditions. A responsible pangasius farm ensures worker health and welfare through safe and hygienic working conditions and relevant training for workers and managers. Although the standards do not specifically refer to compliance with labour laws, it is implicit that labour laws in the country producing pangasius should always be obeyed.
The people who live near and around pangasius farms are an integral part of the larger pangasius aquaculture “community.” Regular communication and consultation can build trusting relationships between the farm operators and local communities, and prevent or minimise conflicts between them. Job vacancies should be advertised locally. The farms should contribute to poverty alleviation and food security so that there are net benefits to the local community.
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