Aquaculture Standards Interpretation Committee

1.  Is cyro-preserved milt permitted for use in organic aquaculture systems?

2.  We have a challenge with the use of some chemicals additives as calcium chloride and anti-foam emulsion (attachment). These products are sometimes use for fish transportation. Also, I would like to propose to a few companies (fish farms), whose water is deficient in calcium, calcium chloride. CaCl2 is a product that does not modify the pH of the water. This is to improve the calcium content in fish scales. Calcium is absorbed mainly in water for salmonids. The scales provide protection against pathogens. I don’t see this product in the list of products that can be used in organic aquaculture. However, it is found in CAN/CGB-32.311-2015, but must be food grade. Can you guide me on the possibility of using calcium chloride and anti-foam Emulsion in aquaculture?

3.  Can products produced in other countries be certified under 32.312?

4.  If someone is manufacturing and marketing aquaculture livestock feed, this cannot [be] certified under 32.312 since this is “preparation”. Also, it must fall under section 9 of 32.310. Section 9 d) referencing Livestock Feed was not written with 32.312 in mind. Furthermore, 32.312 states that “Feeds for both terrestrial and aquatic livestock are governed by the same laws and regulations, enforced by the animal feed division of the CFIA”. If we were to follow only 32.312 for the certification of organic aquaculture livestock feed, there are no guidelines as to how much organic content would be required. It could in theory be possible to certify feed as organic with no actual organic ingredients.

Questions:

1) Can livestock aquaculture feed be certified under 32.310 Section 8 and 9?
2) If yes, under which section does it fall under? Just trying to understand the exception of the aquaculture feed. “Therefore, aquaculture products, with the exception of aquaculture feed are treated as though they were agricultural products for the purposes of this section of the standard.

5.  I have a question regarding wild fish in organic products. I understand that wild fish itself cannot be certified organic, and per the Organic Aquaculture Standards 32-312, wild fish is not included in the definition of livestock from aquaculture. I am wondering then if there are prohibitions to making a “contains X% organic ingredients” claim for a product that contains wild fish. For example, would it be permitted for a product containing 70% organic content and 30% wild fish to claim “contains 70% organic ingredients” on the label?
I ask this question because 9.2.2, 32-310. indicates that an organic product with 70-95% organic content may include up to 30% of “a) non-organic agricultural ingredient subject to the requirements in 1.4 a), 1.4 c), and 1.4 h)”, among other non-organic ingredients and processing aids. If wild animals are not included in the definition of agricultural and aquaculture livestock, does that mean it is not possible to make any organic claim for a product that contains wild animals, even if the product does contain at least 70% organic content?

6.  With the CAN/CGSB-32.312-2018 regulations going into full force with Aquaculture products we have run into some difficulties with the auditing bodies over some interpretations of some sections, particularly how fish meal and fish oil can be applied in the calculation of organic percentage of aquaculture livestock feed.
The sections of direct concern are 6.6.4 and 6.6.6, we are unable to source a sufficient quantity of organic fish meals and oils, as they are the bulk of our organic products, our previous certifier had interpreted section 6.6.4 to mean that meals and oils that comply with section 6.6.7 could be used as part of the organic calculation or be exempt from the calculation similar to water. The certifier we are currently working with said that our product will not be certified organic as it contains non organic fish meals and oils.
As one of the largest feed manufacturers in the world we have excellent sourcing ability and we cannot source this much organic meal and oil, we are unsure how other companies would be able to either. Can you please clarify this section for us? Without being able to use these ingredients as organic (as wild caught products should be, they are the closest thing to natural) we will likely need to cease producing this product, which will have downstream consequences to the organic supply chain (our customers) further reducing the amount of organic materials available.
We hope that this is just an interpretation issue on the part of the certifier as we understand these regulations are just newly enforced. We are hoping you can give us clarity so we can decide to move forward with organic certification or not.

7.  One of my clients has asked whether or not he needs to use potable SDR pipping instead of the usual SDR pipping for his organic aquaponic fish farm using trout.

8.  Is there any specific regulation for stocking densities for species not listed in COR, e.g., Tilapia? (I can only see stocking densities for salmon and shrimp).

9.  How is “slaughter livestock” defined? This is in context with clause 6.7.14: The operator of an organic livestock operation shall not administer b) synthetic parasiticides to slaughter livestock, except as provided in 6.7.15; c) antibiotics to slaughter livestock. Does it refer to aquaculture livestock, that is soon to be slaughtered (referring to a certain lifetime before slaughter, e.g. 4 weeks), or does it apply in general to animals that are produced to be slaughtered and consumed (in contrary for example to breeder animals). I assume the first is applicable, because the COR says, not to administer antibiotics to slaughter livestock (6.7.14 c). It would be surprising if antibiotics would be prohibited for aquaculture animals in general (those to be slaughtered and consumed).

10.  Can I use nanobubble technology to treat my fish sludge before it is used as a fertiliser for my organic plants in my decoupled aquaponic facility?

11.  6.10.8.3 prohibits the use of polystyrene as a flotation devise for new installations and replacement purposes. Are polystyrene flotation devices that are covered in plastic (no exposed polystyrene) permitted?

12.  For invertebrate production, if it is not possible for the operation to produce seed (under 6.10.2) in accordance with 32.312 and organic or wild seed is not commercially available, can the operation produce its own seed using conventional methods as long as 95% of the final biomass of the final product was produced under organic management (as stated under 6.10.2.3)?

13.  Is sodium nitrate permitted as a feed for the production of organic plankton?

14.  Is the use of PVP-Iodine (Polyvinylpyrrolidone) permitted for disinfecting organic salmonid eggs? The manufacturer indicates it is a formulation of elemental iodine and a carrier (to keep it stable and safe for the salmonid eggs); however, the SDS only lists PVP-Iodine.

15.  32.312 clause 5 Crop production specifically requests a once-off biomass estimate of seaweed at the outset (5.1.3). Does this requirement apply to only cultivated seaweeds or does it also include wild crop seaweeds (7.2)?. It does seem to reason that a biomass calculation be required at the outset of wild crop harvest of seaweed to demonstrate sustainable harvest of the resource and should be included as a requirement under 7.2. Furthermore the calculation should be conducted annually to demonstrate 7.2.3 requirements. If the clause refers only to cultivated seaweed, what is the purpose of estimating a yield/biomass once and not annually? It is my opinion that the biomass calculation is needed annually, and for wild crop seaweed. If seaweed is cultivated per 5 Crop production, then an annual projected yield should be required.

16.  32.312 clause 7.2 Wild crops indicates the need for documented evidence that prohibited substances have not been used for at least 36 months before harvest (7.2.1). Does the term 'used' indicate by the operator only? If 'used' means by anyone, is this purposeful use, or accidental contamination? If the need is to demonstrate that the water environment has not been subject to prohibited substances for a period of 36 months prior to harvest; do test results for pathogens and residues (heavy metals, pesticides) from a composite sample from each season's harvest suffice, or should such tests be conducted regularly throughout a harvest season? 7.2.4 also suggests the need for documentary evidence to demonstrate production zones are situated in locations not subject to contamination by prohibited substances. Please indicate what documentary evidence is required of the operator to demonstrate that the water environment is indeed free of prohibited substances.

17.  32.312 7.2.2.a) indicates wild crops harvested from shared or common areas need measures, and records to demonstrate total harvest complies with the standard. How does a single operator measure the sustainability of harvest or resource management when multiple operators (organic or not) harvest from a common area? If such documentary evidence does not exist, does this negate the ability to certify the seaweeds as organic?

18.  Saponin (and rotenone) shall be referred as allowed cleaners, or as pest control substance in aquaculture. In our case, Saponin is used to control predator (Fishes in ponds should be considered as predator but not pest). Kindly let us know whether Saponin and Rotenone can be used or not in shrimp farming.

19.  An operator registered for COR production of salmon has a proposed scenario for which they need the interpretation in this context of: 1) “continuous organic management” in CAN/CGSB-32.312-2018 standard 6.4.6; and of 2) “existing livestock” in CAN/CGSB-32.312-2018 standard 6.2.1. The operator has already completed its 15 month post-application period for sales as organic (SFRC, 344(3)(d)). It has since entered new sites into COR transition periods. While under the operator’s control, the feed and all other aspects of their management are compliant with the standard. For this batch, the operator proposes: 1) The young fish are sourced without COR status and moved to the first growing site – at least the final 90% of biomass gain happens under the operator’s management; 2) The first growing site entered its transition period before this batch of fish arrived, and will complete its transition while these fish are there; 3) The fish will subsequently move to the second growing site undergoing transition, but will be moved to the third site prior to the end of the second site’s transition period; 4) The fish will arrive at the third growing site which has already completed its transition period, and this is where they will be harvested. By the time the proposed batch of fish is harvested, all three sites will have completed their transition periods. The operator needs to know whether the batch of fish will have COR status.

20.  Is there an official definition of “production cycle” to determine transition period. E.g. in Salmon the freshwater stage (eyed-egg to smolt) is about 12-13 months. The salt water the grow-out (smolt to adult) is about 11 months. Should the production cycle include both stages of production or just the grow out stage?

21.  In certain countries the law e.g. Chile, require use of anesthetic on a monthly basis for Caligus (sea lice). However Canadian Organic Standards allows use anesthetic could be use only twice a year. Are there provisions within Canadian Organic Standards to comply with local laws?