NAA Public Policies
The NAA has written a number of policy statements on several topics pertinent to aquaculture. Please click the link below to download the policy document.
Continued growth, new innovations and competitiveness in aquaculture depend upon focused research programs. Public funds expended on aquaculture research should strive to keep American farmers profitable and competitive in the culture of safe and nutritious food, bait, recreational fish, ornamentals, and other aquatic crops. Publicly supported researchers and their institutions are facing many challenges in maintaining adequate funding support. They are increasingly looking to supplement grant funding through innovative methods and partnerships including private contracts, joint ventures, licensing of intellectual properties, foreign sources and personal consulting. This approach may help make research institutions more self-sufficient, however, it conflicts with the basic mission and ideas of the land grant institutions to carry out research and provide practical information to American farmers. The continued function of these institutions must be to find solutions to problems and create, but not control, technology thereby helping maintain the competitiveness of our farmers. American aquatic farmers benefit from their strong, publicly supported research programs. Farmers need to have a larger role in determining their aquaculture research needs, demonstrating technology or carrying out on-farm research, and being the prime recipients of the results and benefits of publicly supported research. Congress should relieve university researchers from liability issues when collaborating with a farmer or group of farmers. Congress should also develop incentives and/or mechanisms for farmers to share ideas with universities which may lead to advancements in aquaculture technology.
1. Recommends a publicly supported increase in aquaculture research, demonstration and development funding.
2. Supports direct participation of aquatic farmers and private industry stakeholders in all levels of research planning, carrying out of research programs, and dissemination of results. This includes strong participation by farmer advisory committees within USDA, land grant institutions, and other government agencies and research programs.
3. Encourages improved aquaculture research coordination within the federal government.
4. Supports the ideal that the primary beneficiaries of publicly funded aquaculture research should be American farmers.
5. Encourages Congress to establish methods for farmers to develop their research ideas with the universities in such a manner that the farmer will benefit, the university will benefit, and other farmers will benefit without the fear of liability issues.
6. Supports University research that focuses on domestic aquaculture.
7. Encourages federal funding that helps integrate aquaculture with traditional agricultural practices, water reuse, and water management and conservation.
Good aquatic animal health management is essential for successful aquatic animal production and should 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. Therapeutants may be used to alleviate animal stress and help treat disease. The number of therapeutants or vaccines federally approved for use in aquatic animal production is limited. The U.S. aquaculture industry is relatively small. Programs must be developed that encourage vaccine and therapeutant development.
1. Use of federally approved vaccines, therapeutants, and water treatment chemicals by all aquatic animal producers.
2. Cooperative approaches to obtaining additional vaccine, therapeutants, or water treatment approvals for use in production and maintenance of aquatic species.
3. Educational programs that inform producers about fish health management practices and proper use of therapeutants and other aquatic animal remedies to treat aquatic animal disease.
4. Development of preventive measures (e.g. vaccines, improved breeding practices and management practices) to diminish the needs for disease treatments.
5. Development and approval of therapeutants that are efficacious, environmentally safe and economical.
Successful aquaculture demands that animal husbandry is optimized. Aquaculture husbandry practices demand that animals are held in healthy environments, fed a balanced and complete diet, protected from predators, and monitored throughout their life to insure their general quality and health. Aquaculture helps provide an increasing human population with a supply of wholesome, nutritious, consistent quality food, sport fish, and ornamental species. To achieve this quality, farm raised aquatic animals are raised under optimal conditions using humane practices. Aquatic animals for food are slaughtered quickly and humanely for rapid processing, which enhances the quality of farm-raised aquatic animals. Aquatic animals reared for stocking in public waters, or ornamental uses, must be transported under optimal environmental conditions if the fish are to survive, and maintain their quality. Successful producers routinely follow good production practices. Animal welfare issues are legitimate concerns for a society, and therefore aquaculture. However, use of anthropomorphic standards should be avoided when addressing aquatic animal welfare, especially in the fields of emotional response, including pain, and cognitive ability. Animal rights or welfare organizations form a diverse group. Some organizations use legitimate legal and political practices to sway public opinion, and have assisted in developing husbandry practices which have led to improvements in animal health and quality. Animal "liberationists" believe that any form of “captivity” or use of animals by humans is wrong, and have been known to disseminate false information, violate state or federal law, destroy personal or public property, and cause immediate harm to animals or the environment in an effort to promote their beliefs.
1. Believes that successful aquaculture demands that husbandry is optimized, that legitimate welfare issues are addressed by demands of the industry, and supports the rights of aquaculture in the propagation and marketing of aquatic animals. (cont.) Revised 1/28/2015 Page Two NAA Policy on Aquatic Animal Welfare
2. Supports continued improvements in animal husbandry when appropriate, but opposes the use of anthropomorphic values to determine stocking densities, husbandry practices, or slaughter techniques.
3. Supports the right of all people to use legitimate, legal means to voice their opinions or determine public policy.
4. Opposes individuals and organizations who are opposed to any form of animal captivity, or who illegally destroy public or private property.
5. Supports legislation prohibiting dissemination of false information concerning animal welfare that adversely affects aquaculture product marketability or public opinion about aquacultured products.
Piscivorous birds, otters, aquatic reptiles, and other wildlife can cause significant predation on farm raised fish and shellfish. Piscivorous wildlife can consume large quantities of fish, and fish not consumed may be physically damaged during attempted predation. Birds and reptiles may also serve as disease vectors spreading pathogens amongst fish farms or transferring pathogens from the wild to a fish farm. Control of depredating wildlife can be difficult and expensive. For example, all piscivorous birds are federally protected. Depredation permits can be obtained, but these are not usually issued in a timely manner. Dissuasion devices (e.g. cannons and/or other scare devices) are of limited success. Exclusion devices such as cages that cover the entire rearing area are expensive, interfere with routine fish rearing activities, and may not readily withstand the rigors of winter weather (i.e. ice and snow). Considerable need exists to develop improved management techniques.
1. The U.S. Fish and Wildlife Service manage migratory bird numbers on basis of wild food supply. Where bird numbers exceed wild food supplies, hence allowing for excessive farmed fish depredation, these numbers must be reduced.
2. The USDA Wildlife Services program should be encouraged to actively develop additional control measures.
3. Cumbersome regulatory processes that impede control efforts should be removed.
4. Depredation permits should be readily available on a timely basis and should be administered equally by all U.S. Fish and Wildlife regions.
5. Standing depredation orders should be issued for certain species (e.g. double crested cormorant) when requested by the USDA as opposed to the issuance of numerous individual depredation permits.
Sustainable aquatic animal and plant production requires good resource management. Water received for production should be of suitable quantity and quality for effective production of aquatic organisms. Environmental stewardship is the responsibility of each aquatic organism producer. Aquatic animal production does have the potential to contribute plant nutrients, settleable and suspended solids, and therapeutants to effluent streams. The impact of these discharges on the receiving stream is highly variable. Regulatory decisions must be based on credible science and risk assessment. A thorough understanding of aquaculture farm effluent impact must be evaluated relative to influent conditions, water quality standards, and beneficial uses. 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, water reuse, and multiple use.
1. Encourages environmental stewardship by all aquaculturists.
2. Encourages regulatory decisions on the basis of credible science.
3. Encourages risk assessment that includes cost-benefit analysis.
4. Encourages effluent regulation based on site-specific watershed needs.
5. Encourages regulatory decisions that account for beneficial uses and physicochemical conditions of receiving waters.
6. Encourages efforts that result in development of improved waste management practices.
Genetically modified organisms (GMO’s) are defined as organisms (i.e. plants, animals or microorganisms) in which the genetic material (DNA) has been altered in a way that does not occur naturally by mating and/or natural recombination. There are at least 19 species of GMO plants (alfalfa, apple, canola, chicory, corn, cotton, creeping bentgrass, flax, melon, papaya, plum, potato, rice, rose, soybean, squash, sugar beet, tobacco, and tomato) that have been federally approved for use in the United States. There is one GMO food animal, a salmon, and several GMO ornamental fish (zebra danio, long fin tetra, tiger barb, silver shark) which have been federally approved for use in the United States. These GMO plants and animals have received rigorous scientific federal scrutiny to ensure they will not adversely impact public health or the environment. GMO microorganisms produce a myriad of products currently used in the pharmaceutical (e.g. human insulin), chemical, and food (renin to produce cheese) industries. GMO plants are often used as feedstuffs in domestic and international livestock populations. No scientific studies have revealed any adverse impacts of feeding GMO plants to livestock health, productivity, nutrition profile or allergenic potential. Because DNA and protein are normal components of the diet and are digested, there are no detectable or reliably quantifiable traces of GMO components in animal milk, flesh, and eggs following consumption of GMO feed.
State required specific labeling of GMO products and even the labeling of animals that have consumed GMO feed ingredients is highly controversial. Argument is made that the public has a right-to-know if the product is a GMO or was fed GMO ingredients. Argument is made that, consistent with the Federal Food, Drug and Cosmetic Act, if the GMO product is equivalent to a non-GMO product, there are no food safety or public health concerns and hence, no need to specifically label these products. State specific labeling requirements would create a hodgepodge of labeling standards that would in practice be difficult and cumbersome to comply with. Congress is currently considering establishing a broadly applied national statute dealing with this issue.
1. Encourages a thorough scientifically based investigation into human food safety of genetically modified aquatic organisms.
2. Encourages a thorough scientifically based investigation into the environmental safety of genetically modified aquatic organisms.
3. Encourages sound, scientifically based risk analysis by the federal regulatory agencies.
4. Encourages various continued and vigorous scientific investigations into ways to improve aquatic organism production efficiencies and product quality for consumer’s benefit including the use of genetically modified aquatic organisms.
5. Discourages policies, decisions, and regulations of genetically modified organisms that are not supported by scientifically based investigation.
6. Supports federal legislation that would create a uniform labeling program.
The detection of deoxyribonucleic acid in the environment (eDNA) through the use of polymerase chain reaction (PCR) techniques is being used for animal research and monitoring purposes (Barnes and Turner, 2016), and has been proposed as a tool for regulation (Collins et al. 2013; Jerde et al. 2013). An increasing number of research studies on various applications for eDNA are being published, ranging from invasive and endangered species detection, to estimating fish biomass, disease organism detection, and for food habit studies. eDNA methods are currently being used for monitoring purposes, for example, to check for Asian carps in the upper Mississippi and Chicago Area Waterway, and for detection of zebra and quagga mussels in western reservoirs. Bait shops have also been checked for Asian carps using eDNA. At least one state department of natural resources has proposed using eDNA to test aquaculture farms and hauling trucks for prohibited species.
Given harsh penalties are possible, the National Aquaculture Association is concerned about the premature use of eDNA for regulatory purposes. Three major concerns are: 1) detection of eDNA does not mean that a live organism is present; 2) false positives are to be expected, 3) detection assays should first be standardized and validated, and 4) laboratories should be accredited and laboratory performance testing should take place.
Research results have highlighted the existence of numerous possible sources of eDNA other than live aquatic animals (Merkes et al. 2014) and the necessity to implement quality assurance, quality control protocols (Goldberg et al. 2016). This means that positive eDNA results do not always mean that live organisms are present. Rates of false positives and negatives must be considered. One concern is the false positive paradox: when eDNA is used for detecting very rare organisms, even highly specific DNA-based methods can give misleading results when the detection rate is near or below the false positive rate.
The Invasive Species Advisory Committee (ISAC), a team of nonfederal experts and stakeholders who provide advice to federal agencies through the inter-agency National Invasive Species Council (NISC), published a white paper on PCR-based assays for eDNA detection of aquatic invasive species (ISAC 2012). The white paper recommendations to NISC were:
1. Encourage and develop funding for the National Academy of Sciences to undertake a review of the reliability and effectiveness of PCR and other DNAbased applications for detecting aquatic invasive species (AIS), focusing on establishment of appropriate validation processes and a framework and standards for this new and potentially invaluable tool in the early detection, eradication, prevention and control of AIS.
2. Establish and fund an ongoing independent performance testing program for laboratories utilizing DNA-based AIS detection methodologies such as that recently undertaken for evaluating laboratory performance in PCR detection of dreissenid mussel larvae (Frischer et al. 2012). Testing results should be made public so that managers may make informed decisions about the accuracy and reliability of a laboratory's performance when including an eDNA component in an AIS monitoring and early detection system.
3. Utilize lessons learned in establishing a laboratory performance testing system to fully develop a validation/accreditation program(s) for other invasive species eDNA methodologies and laboratories.
In summary, eDNA has tremendous potential as a research tool, and with appropriate safeguards, for monitoring purposes. However, research demonstrates the potential for positive eDNA results when live organisms are not present, and unknown rates of false positives and negatives. Therefore, before eDNA is used for regulatory purposes, methods should be standardized, test assays validated, and laboratories accredited and subject to independent performance testing.
1. Supports the development of eDNA tools for scientific research to advance commercial aquaculture.
2. Supports the recommendations of the Invasive Species Advisory Committee to the National Invasive Species Council presented in the white paper “Validation of PCR-based assays and Laboratory Accreditation for Environmental Detection of Aquatic Invasive Species”.
3. Recommends that similar protocols (e.g., chain of custody) to those that must be followed for forensic testing of human DNA for law enforcement purposes should be required if eDNA testing is used for natural resource agency enforcement/regulatory purposes.
The Lacey Act was passed in 1900 to prohibit the international and interstate trafficking of illegally obtained wildlife and fish or parts thereof. A violation of the Lacey Act may constitute a federal felony offense and under federal sentencing guidelines, the penalties for even minor infractions can be quite severe.
Interstate transportation of wildlife, fish, or parts thereof that violates a state law in the receiving state or the state shipped from, is a Lacey Act violation. Thus, what may be a misdemeanor state violation in both of the two states involved, is immediately elevated to a federal felony offense, simply because state boundaries were crossed.
The U.S. Fish and Wildlife Service is one of the agencies that enforce the Lacey Act and their Enforcement Division has historically applied this act to the international and interstate movement of private aquacultural products. In part this is because the U.S. Fish and Wildlife Service does not recognize the private ownership of aquacultural products.
It has been proposed that aquatic animal diseases be considered for listing as injurious species under the Lacey Act. Such listing, coupled with increasingly sensitive testing methods, could place aquaculture producers and shippers of aquaculture products under increased risk of Lacey Act prosecution for inadvertent or unintentional possession or shipment of unavoidable or unviable “evidence” of disease organisms.
1. Supports legislation to exempt commercial aquacultural products from the Lacey Act while continuing to protect fish and wildlife produced by public or private entities to restock species for recreational use or for the recovery of state or federally listed species. The United States Code, Title 16 Conservation, Chapter 53 Control of Illegally Taken Fish and Wildlife, Section 3371 Definitions, should be amended to read as shown below:
(a) Fish and Wildlife.—
(1) IN GENERAL.—The terms “fish” and “wildlife” means any wild animal, whether alive or dead, including without limitation any wild mammal, bird, reptile, amphibian, fish, mollusk, crustacean, arthropod, coelenterate, or other invertebrate. (cont.) Revised 10/22/2015 Approved 10/30/2015 Page Two NAA Policy on The Lacey Act
(2) EXCLUSION.—The term “fish” excludes— (A) all aquatic animals, alive or dead, while under the control of persons engaged in aquaculture production and distribution of such aquatic animals.
(3) EXCEPTIONS TO APPLICATION OF THE EXCLUSION.—The exclusion made by subparagraph (A) of paragraph (2) does not apply if the fish is listed— (A) in an appendix to the Convention on International Trade in Endangered Species of Wild Fauna and Flora; (B) as an endangered or threatened species under the Endangered Species Act of 1973; or (C) pursuant to any State law that provides for the conservation of species that are indigenous to the State and are threatened with extinction.
Until such an exemption occurs, the NAA:
1. Supports reducing the extreme penalties that are assessed with a Lacey Act violation; increasing the market value from $350.00 to $50,000.00 to trigger the felony provisions of the Lacey Act; changing the current language in the Lacey Act from “knowingly” to “willingly” or “purposely”; and exempting farmers and farms from warrantless arrest and search and seizure.
2. Supports the U.S. Fish and Wildlife Service acknowledgment that aquaculture products, legitimately reared in private culture, are PRIVATE property, not public. We further support efforts that recognize aquacultured products as private property in federal and state laws and regulations.
3. Supports efforts by the U.S. Fish and Wildlife Service and the USDA to compile and disseminate annually a list of all state and federal regulations that pertain to aquaculture.
4. Opposes the listing of aquatic animal diseases as injurious species under the Lacey Act. The NAA supports the National Aquatic Animal Health Plan and the Commercial Aquaculture Health Program Standards in regard to federal, state and production activities regulating or managing aquatic animal diseases.
5. Supports amendment of the Lacey Act so that federal penalties assessed for violation of regulations involving privately owned aquatic animals do not exceed the maximum penalty for the violation for the state in which the violation occurred.
The NAA, since its inception, has maintained that aquaculture is agriculture and therefore believes that the U.S. Department of Agriculture should be the lead agency for aquaculture in all matters.
Global trade and the possibility of transporting exotic aquatic animal pathogens highlight the need for an effective national aquatic animal health management program. The European Union (EU) is already instituting restrictive programs that will limit the opportunity for aquatic animal pathogen spread. A “competent authority” must be identified in the US if aquaculture animal producers are to participate in EU trade. State jurisdiction over fish pathogens and the interstate transport of live aquatic animals and aquatic animal products complicates commerce. Conflicting certification requirements and discordant application between public and private aquaculturists may impede commerce. There is a need for greater uniformity.
The development of a national aquatic animal health management program requires participation of commercial, public, and regulatory interests. Food fish, bait fish, and ornamental fishes should be included in program development. Because pathogen inspection programs are expensive, a focus should be placed on user friendly, costeffective alternatives. A careful risk-analysis for each aquatic animal pathogen should be considered in designing the management program.
National aquatic animal health management programs should encompass all aquaculture interests and take into consideration the developmental stage of respective programs as well as the fact that transfer of pathogens across species is possible. Since all aquatic interests are to be considered for inclusion in this management program, representatives from such groups should be invited to participate in the development process, and in program implementation.
It is the policy of the NAA:
1. To encourage development of a cost-effective, scientifically-sound National Aquatic Animal Health Management Program.
2. To encourage broad and early participation by all interest groups in development of a national plan.
3. To foster a program that prevents introduction or spread of adverse pathogens.
4. To encourage a national program which utilizes a risk-based inspection process.
5. To encourage APHIS to serve as the lead agency for certification permits and other import/export requirements for aquacultured fish or products.
6. To encourage harmonization of interstate and international transport health certification requirements.
Non-indigenous species are those that are present outside of their normal, native range. Introduced species are those non-indigenous species that have become established outside of their native range. Invasive species are non-indigenous species which once introduced have caused ecological and/or economic harm.
Aquaculture in the United States often relies on the production of non-indigenous species, those from foreign waters, and those cultured outside of their native ranges within this country. The success of aquaculture depends upon the continued, legal movement of non-indigenous species into, out of, and throughout our nation.
While it is a very small minority of non-indigenous species which have become introduced, and an even smaller percentage which have become invasive, the aquaculture community is aware of the need for vigilance and caution when dealing with non-indigenous species.
1. Strongly supports the reasonable and unencumbered movement of beneficial aquatic species. Such movement is essential to the sustainability and growth of U.S. aquaculture industries.
2. Recognizes that the introduction of some aquatic organisms may have undesirable or damaging effects, in some instances, even on established aquaculture industries themselves.
3. Supports the design and implementation of any reasonable plan or effort to minimize the risk of introduction or dissemination of clearly undesirable aquatic species.
4. Demands that any measure or determination of desirability or beneficial value of an aquatic species be based on findings of fact and objective science and that any decisions be based on unbiased assessment of the real and proven risks relative to the potential value and benefits.
5. Demands that laws, regulations, or policies designed and implemented to prevent the introduction or dissemination of unknown and undesirable nonindigenous aquatic species neither supplant current laws and regulations which provide for the free and essential movement of aquaculture products nor be allowed to be used for the covert purpose of restricting or eliminating commercial aquaculture.
6. Is opposed to any extension of non-indigenous species regulations that attempt to include pathogenic parasites, bacteria or viruses of aquatic animals. Laws, regulations and policies are already established and working on a regional, state, national and international level to address pathogens.
Background Plastics are in widespread use in the world today, including in aquaculture. Plastics have replaced wood, cotton, manila hemp, glass, steel, iron, tin, and copper for aquaculture production equipment such as netting, lines, bags, buoys, baskets, buckets, and cages, and are components of a wide variety of hand tools, boat and motor parts, or protective coatings.
Plastic alternatives to traditional materials are effective, durable, flexible, light, adaptable, and generally low-cost and recyclable. Plastic does not readily breakdown or decompose, has a long working life, is typically easier to maintain and use, and is ultimately far more cost effective than metals, glass, plant fibers, or wood. If plastic materials are lost or discarded into the environment, they remain there for thousands of years, will breakdown through abrasion and sunlight to form smaller particles – micro- and nanoplastics - all of which can impact freshwater and marine ecosystems which aquaculturists depend upon.
The ubiquity of microplastic and nanoplastic particles have been reported in foods and beverages, air, water (freshwater and marine surface waters), groundwater drinking water sources, and have been found in fish and shellfish. They have been identified wherever they have been investigated. Microplastics enter the human body via food, water, and air. Research to assess the relative risks of micro and nanoplastics to humans and the world around us is inconclusive at best and the risks associated with micro-and nano-organic and inorganic particles have not been comprehensively assessed for their contribution to the overall risk. Initial microplastic assessments suggest risks are unlikely for human health, marine organisms, aquaculture, and the environment (Adam et al. 2021; Gouin 2020; Lusher and Welden 2020; Vethaak and Legler 2021). Nonetheless, it behooves the aquaculture farming community to manage the use and disposal of plastics to reduce impacts on the environment.
NAA and its membership encourages the following actions:
1. REDUCE: Consider the function and utility of each component of aquaculture production gear. Single-use plastic equipment, such as zip-ties, can often be replaced with a biodegradable alternative without adding costs.
2. REUSE: Examine whether single-use products are appropriate economically and environmentally over the long term. Choose products that can be used more than once with proper care or consider natural alternative materials.
3. RECOVER and RECYCLE: When equipment wears out or is no longer needed, recover it and dispose of it properly. Many plastic items can be recycled instead of dumped into a local landfill where they can decrease the lifespan and functional decomposition of landfill processes.
4. RESPOND: Ensure plastic gear is well secured on farms so it does not escape and contribute to marine debris. Respond to reports of escaped gear, periodically patrol adjacent areas for escaped gear and participate in or create community efforts to cleanup plastics and other debris in the environment as part of a larger effort, International Coastal Cleanup, or by self-organizing community cleanups.
5. RESEARCH: Support applied research to:
a. standardize micro- and nano-plastic sampling, analysis, and reporting,
b. conduct comparable environmental and human risk analyses,
c. develop biodegradable plastics that avoid environmental and human health risks;
d. characterize degradation characteristics of the various plastics and ropes used in US aquaculture to ensure the farming community is using the most durable materials and retiring them before they start to breakdown: and,
e. describe new plastic recycling technologies to recover, reuse and remanufacture.
Adam, V. A. von Wyl and B. Nowack. 2021. Probabilistic environmental risk assessment of microplastics in the marine habitats. Aquatic Toxicology. 230:1-10. (https://doi.org/10.1016/j.aquatox.2020.105689 accessed February 19, 2021).
Gouin, T. 2020. Toward an improved understanding of the ingestion and tropic transfer of microplastic particles: Critical review and implications for future research. Environmental Toxicology and Chemistry 39(6):1119-1137.
Lusher A.L. and N.A.C. Welden. 2020. Microplastic Impacts in Fisheries and Aquaculture. In: Rocha-Santos T., Costa M., Mouneyrac C. (eds) Handbook of Microplastics in the Environment. Springer, Cham. https://doi.org/10.1007/978-3030-10618-8_30-1
Vethaak, A.D. and J. Legler. 2021. Microplastics and human health. Science 371(6530): 672-674
Wholesome domestically farmed aquatic animal products are the cornerstone of success for the US aquaculture industry. Farm raised organisms are nutritious and of high quality. There is general consumer perception that domestically farm raised aquatic animals are wholesome, high quality products. However, consumer perceptions can be readily influenced by misinformation or a breakdown in product safety. Aquatic animal producer participation in quality assurance programs can help ensure continued production of wholesome products and enhance consumer perceptions. Quality assurance programs can also be used to discredit misinformation.
Hazard Analysis Critical Control Point (HACCP) plans are key to systematically identifying biological, chemical, and physical hazards that might impact food safety. The US Food and Drug Administration and the US Department of Agriculture Food Safety Inspection Service (FSIS) rely heavily on HACCP in managing seafood safety (quality assurance) at the processor level. Development of and compliance with a HACCP plan is required of seafood processors both domestically and internationally if they are to market seafood in the US. Several aquatic animal species associations have also developed voluntary producer/ production focused quality assurance plans based on the HACCP approach. These can be incorporated into a processors HACCP plan or used by those marketing live seafood for consumption or for recreation. Among other things, quality assurance plans should emphasize integrated aquatic animal health management and the importance of compliance with the US Food, Drug and Cosmetic Act.
Ultimately, producers, processors, distributors, and retailers must work cooperatively to ensure product wholesomeness.
The NAA encourages:
1. Participation in a finfish or shellfish producer quality assurance program by all producers of aquatic animals that might be consumed by people or other animals.
2. Individualized HACCP plan development and compliance by all domestic and international seafood processors.
3. Consumer education utilizing credible information about domestically produced seafood safety.
Seafood provides key nutrients, lean protein, is low in saturated fat, and has been linked to a wide array of health benefits for the developing fetus, infants, and adults. Diet quality is not only important for reducing nutrient deficiency, but is now regarded as essential for preventing chronic diseases such as obesity, type 2 diabetes, hypertension, coronary artery disease and cancers. Seafood can supply 50% or more of high quality protein, niacin, zinc, and vitamin B6 and at least 10% of vitamins E and B12, thiamin, riboflavin, phosphorus, magnesium, iron, copper, potassium and linoleic acid needed in a healthy diet. Seafood is the primary source for omega-3 fatty acids in human diets. Consumption of omega-3 fatty acids is, among other things, associated with reduced cardiovascular disease and chronic obstructive pulmonary disease. Seafood is lower in saturated fats compared to other animal proteins. Reduced consumption of saturated fats has been associated with reduction in cardiovascular disease and diabetes. Overall, by providing a good source of animal protein containing all essential amino acids, essential fatty acids, vitamins, and minerals, seafood can contribute to a healthy diet and reduce the risks of malnutrition and disease. The 2015 USDA Dietary Guidelines for American’s recommends that a healthy diet should include ample consumption of seafood. Domestic farm raised seafood provides a safe, wholesome and great tasting source of lean protein for Americans.
Over 90% of the US seafood supply comes from international sources. Even if all US fisheries exports were consumed domestically, the US would still remain approximately 1 million metric tons short of fulfilling current domestic demand for seafood. With a rising seafood trade deficit of more than $14 billion, this reliance on imports moves potential seafood jobs overseas (NOAA 2016). A country that cannot feed itself, that relies on foreign supplies for a vitally important feedstuff, is not a secure country. Nevertheless, domestic aquaculture contributes significantly to our total and local food supply. Domestic aquaculture is subject to federal and state environmental control, and this helps ensure that domestically raised seafood supply is sustainable. With the global human population anticipated to increase from the current 7 billion to 9-10 billion by 2050 and most wild fish capture fisheries at maximum sustainable yield, aquaculture production in the US will need to significantly increase if fish supplies are to adequately meet demand by mid-century.
Domestic aquaculture is also an important source of individual and national wealth. The farming of seafood occurs throughout the US, in freshwater and saltwater. Currently, the US produces a relatively small amount of its seafood from aquaculture—only $1.4 billion, weighing approximately 300,000 metric tons (661 million pounds) in 2013. Domestic aquaculture only makes up about 6 percent of total US seafood production by volume and 20 percent by value. The US marine aquaculture sector produced $403 million worth of seafood weighing approximately 49,000 metric tons (108 million pounds) and is significantly smaller than the US freshwater sector. While US freshwater production has declined in recent years, US marine aquaculture production has been increasing at a rate of 5 percent a year on average for the 5-year period ending in 2013 (NOAA 2016).
All consumers expect seafood to be safe and wholesome, and of good quality. Domestic seafood grown in US waters is subject to rigorous food safety requirements of the state and federal governments. Seafood processing in the US has been subject to US Food and Drug Administration mandated Hazard Analysis Critical Control (HACCP) food safety requirements since 1984. The recently enacted U.S. Food Safety Modernization Act (FSMA) is modeled after the seafood HACCP program. In 2016, the USDA Food Safety Inspection Service (FSIS) instituted a seafood safety program exclusively for all types of catfish. This inspection program should ensure all imported catfish meet the same food safety standards that domestic catfish have always had.
It is the policy of the National Aquaculture Association that:
1. The US should encourage continued development of domestic aquaculture through federal policy and investment.
2. US farm-raised seafood is a best choice for US consumers.
3. Efforts should be continually directed at encouraging domestic consumption of US produced seafood.
4. Internationally grown seafood should meet the same food safety and sustainability standards as required of US producers.
NAA Operational Policies
The NAA has written a number of policy statements that govern the operations of the Association.
Federal anti-trust laws (Sherman Act, Clayton Act, Robinson-Patman Act, and Federal Trade Commission Act) are designed to protect competition and maintain free and open markets for the benefit of consumers. These laws prohibit conduct that reduces competition or involves competition by unfair means. Unfair competition can arise if there are agreements among competitors to fix prices, to reduce price competition by allocating customers or markets, to refuse to deal with certain suppliers or customers, or to exclude other competitors from the market. Unfair and deceptive acts and practices include false or unsubstantiated advertising, fraudulent marketing, and other practices designed to trick or deceive suppliers or customers.
The National Aquaculture Association (NAA) is a US producer-based association dedicated to the establishment of national programs that further the common interest of our membership.
The NAA (through its officers and directors):
1. Will not facilitate discussion among sellers on the following subjects: prices, discounts or other terms or conditions of sale, what constitutes a fair price level, warranties, costs, cost coverage, margins, or profits, sales territories or customers, and their marketing practices.
2. Will not remain at meetings in which items identified in 1 (above) are discussed.
3. Will conduct Board of Directors meetings that are strictly related to its mission, the establishment of national programs that further the common interest of its membership.
4. Will conduct Board of Directors meetings in accordance with a written agenda made available to its membership on the NAA Website.
A fundamental precept of the National Aquaculture Association (NAA) is to be representative of US aquaculture that encompasses the 1500 to 1600 species, hybrids, and varieties cultured throughout the United States by approximately 3000 farms located in every state and territory. The NAA was founded by aquaculture producers and is producer oriented. The NAA strives to represent all of this diverse aquaculture industry and seeks information and opinion from a wide variety of sources. Committees have been formed to address specific areas of interest or issues to help gain as much information as possible to arrive at consensus NAA decisions, opinions, positions, and policies.
1. The President, at his discretion, appoints or dismisses committee chairs to address particular topics or issues. Committee chairs shall be a member of the NAA Board of Directors or, if not a member of the NAA Board of Directors, shall be approved by the NAA Board of Directors.
2. The President, at his discretion and after consultation with the committee chair, appoints or dismisses committee members. Committee members shall be NAA members in good standing and shall be briefed by the committee chair or by the Executive Director or provided written materials describing NAA policies and principles including this policy on Committee Structure and Function.
3. NAA members interested in committee membership should express their interest to the Committee Chair, the President, or the Executive Director.
4. The Executive Director will serve on all committees to provide administrative support.
1. Committees serve in an advisory capacity to the Board of Directors for the purposes of identifying and summarizing issues of importance to US aquaculture; drafting letters, position papers, or opinion pieces for consideration by the Executive Committee and/or Board of Directors; and submitting an activity report for each Board of Directors meeting.
2. Committee members who represent a state or species association to the NAA should provide input to the committee from the perspective of that association.
3. To help ensure and encourage input from a variety of perspectives and opinions, and giving consideration to the fact that only the Board of Directors can approve a formal policy or position of the NAA, the specific comments or opinions of others as exchanged in committee discussion and debate, either verbal or written, should remain confidential. 4. Committee members represent NAA and serve to further NAA interests and are expected to be discrete and respectful of NAA and its members. 5. Committee members should be familiar with and committees shall follow the NAA Policy on Decision Process for Establishing Policies, Resolutions, and Written Public Position Statements.
The NAA Board of Directors must at times make decisions regarding controversial issues. These decisions could have significant impact on the aquaculture industries that NAA represents or on individual aquaculture enterprises. Differences of opinion within the aquaculture community and within the NAA Board of Directors may occur.
Several different decision-making processes might be selected. Consensus and majority vote are most commonly used and each has advantages. Consensus, while not necessarily making all parties happy because of compromises that must be made, prevents rejection of minority views thus preventing fractionation of the association. Consensus however requires considerable time and effort. Majority vote allows more forceful, timely decisions but can alienate minority views.
1. Will strive for consensus. Consensus will be defined by a 100 percent agreement of the NAA Board of Directors.
2. Will attempt to obtain consensus by careful wording of resolutions or motions.
3. Will resort to a majority vote if, the presiding officer determines consensus cannot be reached in a timely fashion.
4. If majority vote is used, both majority and minority positions will be identified and communicated to membership, regulatory bodies and others as appropriate.
The NAA is frequently involved in legislative, governmental (regulatory), and national policy discussions. Specific legislation may be developed as a consequence of NAA policy requirements. Additionally, NAA is involved in conjunctive programs with other aquaculture groups or interests. Some negotiations require NAA financial commitment. Several different negotiation approaches may be used. Winner-take-all approaches can compromise future relationships (short and long term).
1. NAA will strive to negotiate legislative actions and other policy issues on the basis of mutual gain.
2. NAA will probe to clarify all interests.
3. Various options for consideration will be developed and presented to all parties. NAA will use objective criteria to support NAA positions.