Alaska hatchery salmon & feeds: Of ‘Sustainability’ (2008)

ARE ALL the right questions asked on the sustainability of Alaska ‘wild’ salmon fisheries? PARTS 1-3 (2008 investigation)

Seafood Intelligence starts on March 3rd 2009 the serialisation of parts of an unpublished report carried out the previous year on the ‘sustainability and traceability of fish feeds used in Alaska’s ‘wild’ salmon hatchery programmes’. Our interest for this issue was prompted by three events: 1) the 2007 melamine-in-feed food safety crisis (the largest in the FDA’s history), which impacted (albeit only slightly) the farmed salmon industry in British Columbia… and ‘wild’ (or rather ‘ranched’) Alaskan salmon; 2) the June 2007 ruling by a US federal court judge in Washington that “a healthy hatchery [salmon] population is not necessarily an indication of a healthy natural population.” [Thus that hatchery salmon cannot “necessarily” be considered as ‘wild’ when it comes to seeking protection for the species under the US Endangered Species Act (ESA)]; and 3) the WWF-initiated ‘Stinky Fish’ campaign, which was scaled-down only days following its launch after creating a huge ‘stink’ and being criticised for its bias.

We thus questionned AK salmon fisheries stakeholders, from the Marine Stewardship Council (MSC) – which eco-certified the salmon fisheries – to fishing industry organisations, the AK Department of Fish & Game, and national & international environmental NGOs. It is noteworthy that many fishermen’s organisations failed to anwser our questions; so did many of the staunch critics of salmon farming in the Pacific Northwest, as we challenged the very notion of Pacific salmon’s wilderness…

Different conceptions/definitions of what a ‘wild’ salmon is…

As ‘aquaculture’ and ‘fish farming’ are political hot potatoes (there has been a moratorium on finfish aquaculture for years in Alaska) other technical terms are used: “MSC views wild capture fisheries that have a component of catch originating from culture activities as ‘enhanced fisheries’,” writesDr Daniel Hoggarth, Fisheries Director at the Marine Stewardship Council (MSC), in his detailed response to Seafood Intelligence. “The State of Alaska considers all Alaska fish to be wild,” wrote Laura Fleming, Director of the Alaska Salmon Marketing Institute (ASMI). “The salmon that originate in Alaska hatcheries benefit from reduced juvenile mortality; the hatchery gives juvenile salmon a “jump start”…

Meawhile, the Management of the WWF Global Marine Programme told SeafoodIntelligence that… “In Alaska, hatchery fish are carefully differentiated from farmed fish and are promoted as wild even though they are not ‘truly wild’. […] The only ‘truly wild’ salmon is one that hatched from an egg in a gravel bed of a river.”…

See the detailed responses below:

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Response by the Marine Stewardship Council (MSC) – [Dr Daniel Hoggarth, Fisheries Director]

(See below for set of questions sent)

Bertrand Charron

SeafoodIntelligence.com

Sent by email

06 March 2008

Dear Mr Charron,

Thank you for your email of 27 February 2008 and for providing the MSC an opportunity to comment on the questions you raise relating to the stocking of hatchery-reared juvenile fish in the MSC-certified Alaska salmon fishery. Please find below our responses to each of your numbered questions. MSC welcomes your proposal for a transparent, multi-stakeholder, science-based discussion of this issue, and I look forward to seeing your analysis at SeafoodIntelligence.com in due course. Please do not hesitate to get back to me with any further questions.

1) How does the MSC view the Alaska salmon originating from hatcheries; are they ‘truly wild’? Or best described as ‘ranched’?

MSC views wild capture fisheries that have a component of catch originating from culture activities as ‘enhanced fisheries’. Enhanced fisheries can represent a wide range of circumstances with respect to factors such as the magnitude of the harvest originating from the culture activity, the type and duration of culture activities, and the management measures that are taken to conserve the biodiversity and productivity of wild populations of the species. The Alaska salmon fisheries are enhanced fisheries in that they use fish stocking to supplement natural catches. Salmon hatcheries have been utilised in some parts of Alaska in order to maintain harvests during years of low salmon runs, and to minimize fluctuations in the economic value of the fishery. Eight of the 16 fishery units considered in the MSC Alaska salmon assessment do contain significant inputs from hatchery releases. These fish, however, spend the majority of their life in freedom in natural ecosystems, where they gain almost their entire adult weight. Against this background, the state’s comprehensive salmon management policies and approaches are designed to conserve and sustain Alaska’s wild salmon populations. The state’s management system and its outcomes in meeting these important objectives were fully assessed during the MSC assessment process, and contributed to the fisheries’ successful certification.

2) As 2007’s melamine-in-feed incidents showed (the melamine incident was the largest recall ever undertaken by the FDA), even Alaska salmon were potentially tainted (some were certainly fed with ‘suspect’ batches – ADF&G May 17th 2007 briefing); The same issues that farmed salmon is finding itself scrutinised for (re. feed and feed safety) can thus also apply to AK ‘wild’ salmon. What is MSC’s comment? What would MSC advise Alaska salmon fisheries decision-makers to do to prevent this from happening again?

As much as incidents such as melamine-in-feed are not desirable it is not within the scope of the MSC standard to take into account quality and food safety aspects. The MSC standard is an environmental standard only and quality issues are subject to existing food safety laws.ww.msc.org Marine Stewardship Council

3) Does the MSC consider that Alaska hatchery-raised fish released in the wild should be considered differently from non-hatchery raised fish?

In terms of the certified product, and considering the relatively short duration of the hatchery phase, there seems little justification in giving separate consideration to wild and hatcherybred fish. As noted in the answer to question 1 above, the management of the hatchery programs and the potential impact of the releases of hatchery-reared fish on wild populations are fully assessed through the MSC process.

4) Should the hatchery-origined Alaska salmon be labelled accordingly once reaching the market/consumers IF this was possible (DNA tracing could in the future make this possible, e.g. the Cooke Aquaculture – New Brunswick project), as each individual fish can theoretically be traced/DNA-identified?

Consistent with the answers for 1. and 3. above, MSC does not at this point regard this as necessary. If such separation was determined as necessary for any reason, it is understood that micro-tagging could also be used to distinguish between wild and hatchery reared fish (please see the Public Certification Report at http://www.msc.org/html/content_485.htm, page 198).

5) Has the MSC addressed the issue of the sustainability of the feed which was/is fed to those billions (there are several year-generations currently at sea) of MSC-ecolabelled Alaska salmon?

MSC thus far has addressed the topic of sustainability of fish food by encouraging wild capture fisheries that supply meal components to fish food manufacturers to enter the MSC assessment process and become certified. As such feed fisheries pass sustainability assessments, the certified fishery products they produce may come to provide an important contribution to the sustainability ratings of any enhancement fisheries and aquaculture operations that make use of them.

MSC does not take a position on the relative benefits of capture fisheries and aquaculture, but instead provides a mechanism for measuring whether a fishery is ‘sustainable and well managed’ according to defined Principles and Criteria. As you are aware, aquaculture remains excluded from the scope of the MSC programme, not least because aquaculture involves activities and issues that are not adequately covered by our existing Principles and Criteria.

MSC is also at this time conducting an internal study to determine the levels and characteristics of fish stocking and other types of ‘enhancement’ that can reasonably be accommodated within the scope of MSC’s current assessment programme. Clearly, very intensive levels of ‘enhancement’ may place some fisheries closer to aquaculture than wild fisheries. While the Alaska fishery has set a precedent regarding this issue for salmon, this study will produce a clear set of ‘filters’ by which the eligibility of other enhanced fisheries can be transparently assessed.

6) [PS: I tried to find those answers but couldn’t, in the re-certification Final Report] Is the above issue/concern (Q5) mentionned anywhere in the Alaska salmon MSC certification documentation? If so, where?

No – the MSC assessment evaluates the sustainability of Alaska’s wild capture fishery (including its management system) in the context of its impact on wild salmon populations and their ecosystems. It is not an assessment of the sustainability of fish feeds, the contents of which derive from a variety of sources.

Regarding the MSC focus areas, we presume that you had seen the sections of the Public Certification Report that consider the management of fish hatcheries and the protection of wild genetic stocks (please see commentary on Performance Indicators 1.1.1.5, 2.2.2, and 3.1.10, and the further comments on page 214).

7) Since the feeding of up to a third of ‘wild’ Alaskan salmon found in the wild depends on commercial feeds (to see them through their hatchery time), can a salmon fishery based in part on the harvest of commercial-feed-fed-juveniles be truly considered as ‘sustainable’ from MSC’s perspective? (and since ‘it is indeed’, please give your justification).

The question of sustainability in fish feeds obviously exists and needs to be addressed regardless of how such fish feeds are used. MSC is promoting an important aspect of ‘feed sustainability’ within its organizational mission by promoting assessment and certification of those fisheries providing products for feed manufacture (please see also answer to question 5).

8) Have you evaluated the amount of fish feed (tonnes) & fishmeal/fish oil and respective wild fishery catches (in tonnes) necessary to feed all State-hatchery Alaska salmon?

MSC has not made detailed evaluations on this subject. Actual figures on the annual feed inputs used in Alaska could presumably be made available by the ADF&G. Some simple calculations (see following question) suggest that the amount used will be far less than is used in the captive salmon farming industry. Clearly, the scale of feeding required to raise a 1g juvenile for release from a hatchery is very different to that for a captive-reared 5.5 kg adult salmon.

9) If so; what are your findings & where do those fish (used to make the fishmeal and fish oil used in the juvenile salmon feed) come from? (Do do any come from MSC-certified fisheries?)

Assuming that those 1.6 billion fry were released from Alaska’s hatcheries at an average size of 1g1 in weight, and further assuming a feed conversion ratio of 25%, the feed required by Alaska’s hatcheries might be in the order of 6,400 metric tons (t) per year. In comparison, with the annual world culture production of captive salmon and trout currently at about 1,900,000 t 2, the feed input required might be 7,600,000 t per year, assuming the same 25% conversion ratio. Clearly, while these are ‘back of an envelope’ calculations, they do suggest that Alaska’s hatchery feed requirements are relatively small in comparison to the magnitude of global fisheries that supply fish meal and the scale of salmon aquaculture. For both of the calculations above, we note that required feed inputs may be higher if mortality during production is included in the estimation. Your figures, however, suggest only 6% mortality between the 1.7 billion salmon eggs collected and the 1.6 billion fry released. MSC does not have information on the sources or quantities of fishmeal or fish oil used in juvenile salmon feed in Alaska.

1 The release profiles for juvenile salmon can range from unfed fry to some level of feeding for a short portion of the fish’s total life cycle and adult weight. In BC, sockeye and pink salmon fry are released at sizes smaller than 1g, while other salmon species are reared to larger sizes (see MacKinley et al, 2004, Pacific Salmon Hatcheries in British Columbia. American Fisheries Society Symposium 44:57–75).

2 Knapp, G., C. Roheim and J. Anderson. 2007. The Great Salmon Run: Competition Between Wild and Farmed Salmon. TRAFFIC North America. Washington D.C.: World Wildlife Fund

10) If not, a) why not? and b) do you plan to?

Given the likely, relatively small absolute magnitude of feed and fish meal used for hatchery releases that contribute to MSC-certified salmon fisheries, the MSC feels its limited staff resources can be more strategically used to promote sustainable management of fisheries used for fish meal, whatever its intended use.

11) Have you been/Are you addressing these issues (the issue of the sustainability of the Alaska salmon fisheries based on State hatchery/aquaculture programmes; re. feed in particular) with the relevant US/Alaska fisheries state bodies and fishermen’s organisations?

The MSC programme has not yet considered in depth the feed-related aspects of enhancement fisheries. MSC’s current strategy regarding the sustainability of fish food sources for the culture industry is to encourage such reduction fisheries to enter the MSC assessment process and become certified. In these assessments, the important role of these ‘forage’ species as the prey of other species higher up the food web would need to be fully taken into account.

As noted in previous questions MSC is confident that the recent assessment did a credible job of evaluating the management of Alaska’s hatchery programs in the context of their effects on the sustainability of wild salmon. As you will have noticed, the recent MSC certification of the Alaska salmon fishery included several conditions relating to the hatchery programme, particularly on the issue of the ‘straying’ of hatchery-reared fish and the potential impacts on the wild stocks. Such conditions must be met by the fishery if its certified status is to be maintained. Progress in these areas will be fully monitored by the certifier and MSC looks forward to the seeing the surveillance reports due on this fishery later this year.

12) If so, what has been their response (please be specific) and what do you intent to do about the topic?

As explained above, MSC has not held specific discussions on this topic. We nevertheless understand that the ADF&G are committed to ensuring the sustainability of their hatchery programme wherever possible.

I hope that these quick responses will assist you in understanding MSC’s position on this topic. I look forward to seeing the wider analysis on SeafoodIntelligence.com in due course.

Yours sincerely,

Dr Daniel Hoggarth

MSC Fisheries Director

Cc: MSC: Rupert Howes, Chris Ninnes, Brad Ack, Jim Humphreys, Jessica Wenban-

Smith, Marnie Bammert, James Simpson

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Here are the questions we asked the key relevant authorities, NGOs and fisheries associations re. the sustainability, food safety & traceability of fish feed ingredients used in ‘wild’ Alaska salmon hatchery programmes.

TEMPLATE OF LETTER SENT to the various entities:

Dear [Sir/Madam],

We are at www.SeafoodIntelligence.com – as you may be aware – very interested in all aspects relating to the fisheries & aquaculture sectors, and seafood in general; particularly so if they relate to a sustainable agenda. Recently, WWF’s ‘Stinky Fish’ campaign has created quite a stir in the seafood industry with some of the initial comments and – resulting from this – it has made us want to investigate further some of the issues relating to sustainable fisheries and aquaculture practices. Throughout the Stinky Fish campaign the WWF promotes the consumption of seafood from MSC-certified fisheries.

In the case of the Alaska salmon fisheries certified by the Marine Stewardship Council (MSC re-certified in 2007 for 5 years), we have become interested in the fact that the AK salmon commercial harvest is the result of the Alaska salmon plan hatched in the 1970’s till now and which hinges substantially on the use of hatchery fish (or in other terms, aquaculture for salmon juveniles, then released in the wild).

Figures quoted on p24 of SCS’s [MSC’s] October 2007 MSC Final Re-Assessment Final Report (on the MSC website) states:

In 2004, over 1.7 billion salmon eggs were collected by Alaskan salmon operators, over 1.6 billion fish were released, and over 20 million salmon originating from Alaskan hatcheries were harvested in common property commercial salmon fisheries as a result of the Alaska salmon hatchery program.” & [P25/26] “[…] Budget support for the commercial salmon management program peaked in the 1980’s and payoff from better management, improved stock assessment tools and prior investments in the Alaska salmon hatchery program combined to result in another significant increase in sustained harvest levels.”

There is a clear acknowledgement that the Alaska hatcheries/aquaculture operations play a vital role in the current salmon harvest levels sustained in Alaska; thus the following questions from SeafoodIntelligence to the [name of organisation queried] (we are asking the same questions to other NGOs and North American/AK organisations and will publish soon the responses [and/or lack of]; we’ll also highlight those who ignore the issue and keep a tally of how long they do so for…):

1) How does the [name of organisation queried] view the Alaska salmon originating from hatcheries: are they ‘truly wild’? Or best described as ‘ranched’?

2) As 2007’s melamine-in-feed incidents showed (the melamine incident was the largest recall ever undertaken by the FDA), even Alaska salmon were potentially tainted (some were certainly fed with ‘suspect’ batches – re. ADF&G May 17th 2007 briefing); The same issues that farmed salmon is finding itself scrutinised for (re. sustainability of feeds and feed safety) can thus to some extent also apply to Alaska salmon. What is [name of organisation queried]’s comment? What would the [name of organisation queried] advise Alaska salmon fisheries decision-makers to do to prevent this from happening again?

3) Does the [name of organisation queried] consider that Alaska hatchery-raised fish released in the wild should be considered differently from non-hatchery raised fish?

4) Does the [name of organisation queried] believe that hatchery-origined Alaska salmon should be labelled accordingly once reaching the market/consumers IF this was possible (DNA tracing could in the future make this possible, e.g. the Cooke Aquaculture – New Brunswick project), aseach individual fish can theoretically be traced/DNA-identified?

5) Has the [name of organisation queried] addressed the issue of the sustainability of the feed which was/is fed to those billions (there are several year-generations currently at sea) of MSC-ecolabelled Alaska salmon?

6) [PS: I tried to find those answers but couldn’t, in the re-certification Final Report] Is the above issue/concern (Q5) mentionned anywhere in the Alaska salmon MSC certification documentation? If so, where?

7) Since the feeding of up to a third of ‘wild’ Alaskan salmon – and many salmon fished in Canadian waters as well – found in the wild depends on commercial feeds (often produced by the same supplier that provide commercial salmon farmer; in Oregon & British Columbia for instance) to see them through their hatchery time, can a salmon fishery based in part on the harvest of commercial-feed-fed-juveniles be truly considered as ‘sustainable’ from the [name of organisation queried] perspective? (please give your justification).

8) Has the [name of organisation queried] evaluated the amount of fish feed (tonnes) & fishmeal/fish oil and respective wild fishery catches (in tonnes) necessary to feed all State-hatchery Alaska salmon annually?

9) If so; what are your findings & where do those fish (used to make the fishmeal and fish oil used in the juvenile salmon feed) come from? (please give figures)  [8′) Do any come from MSC-certified fisheries?]

10) If not, a) why not? and b) do you plan to?

11) Have you been/Are you addressing these issues (the issue of the sustainability of the Alaska salmon/’wild’ fisheries based on State hatchery/aquaculture programmes; re. feed in particular) with the relevant US/Alaska fisheries state bodies and fishermen’s organisations?

12) If so, what has been their response (please be specific) and what do you intent to do about the topic?

I look forward to your responses to the questions above.

Yours sincerely,

Bertrand Charron,

SeafoodIntelligence Editor

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Letter & questions sent to 12 organisations

Responses were received from:

  1. Alaska Salmon Marketing Institute(ASMI) [Laura Fleming, Director]
  2. WWF-USA[Jill Schwartz, in charge of issues relating to aquaculture]
  3. WWF International[Sarah Bladen; Communications Manager Global Marine Programme]
  4. National Fisheries Institute(NFI) [John Connelly, President; Gavin Gibbons]
  5. Marine Stewardship Council(MSC) [Dr Daniel Hoggarth, Fisheries Director]

NO responses were received from the following organisations [and individuals to whom the queries were sent], despite reminders:

1 – Pure Salmon [Don Staniford]

2 – Suzuki Foundation [Ian Hanington, Communications Specialist & Dominic Ali]

3 – Greenpeace International [Patrizia Cuonzo, Press Officer]

4 – Pew Environment Group [Dave Bard]

5 – Southeast Alaska Seiners Association (SEAS) [Director]

6 – United Fishermen of Alaska (UFA) [Mark Vinsel, Executive Director]

7 – United Salmon Association (USA) [Thom Wischer, Chairman, USA/Kodiak]

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Background, PREVIOUSLY on SeafoodIntelligence’s Database:

Read more news on Offshore Aquaculture, ‘Wild vs. farmed’, or Sustainable Fisheries from the SeafoodIntelligence.com News Database, among others).

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Response (un-edited) received from the Alaska Salmon Marketing Institute (ASMI) [Laura Fleming, Director] to the questions sent by Seafood Intelligence:

Read also:

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Dear Bertrand:

Greetings, and thank you for your reminder about responding to your inquiries regarding Alaska salmon, in particular concerning the role of hatcheries and the feed used for juvenile salmon at private non-profit hatcheries in Alaska.

The State of Alaska considers all Alaska fish to be wild, living in some of the world’s cleanest marine and freshwater habitats. Finfish farming is prohibited in Alaska. Alaska uses conservative management, habitat protection, and the latest science to ensure the long-term health of the salmon ecosystem.

Alaska has used hatcheries to enhance its salmon fisheries, and strengthen runs that had suffered from overfishing prior to Alaska statehood. Right now Alaska is celebrating the 50th anniversary of Alaska statehood, and that is also a celebration of gaining control of the state’s marine resources, salmon in particular. The framers of the Alaska Constitution were so determined to have the resources sustainably managed they enshrined the concept in an Article of the Constitution.

The salmon that originate in Alaska hatcheries benefit from reduced juvenile mortality; the hatchery gives juvenile salmon a “jump start” by protecting them from predation, allowing them to mature from eggs (from local wild stock) before being released into the wild as either tiny one-inch-long salmon “fry,” or for some species as “smolt” (about the size of a human finger). Following their release they live the entire rest of their life cycle in the wild: one year to five years, depending on the species—the majority of their lives. In the wild they mature to adulthood, feed on natural marine organisms, grow large, and eventually migrate back to their starting point. Of course, the Alaska salmon that start life in a hatchery do not escape predation: far from it: about 90% are subject to predation at sea.

With farmed salmon it is fairly straightforward to obtain a ratio of weight of feed to weight of finished product. Alaska salmon that begin life in a hatchery are not analogous: they are fed commercial feed for a short period of time (about 5 million pounds of fishfeed in 2007, consumed by 98% of the fish), are released as fry or smolt, and spend most of their life feeding and growing in the wild. But then only 10% return, and about 90% enrich the ecosystem. Commercial, sport, subsistence and personal use harvesters all derive benefit from that 10%. Usually the contribution of these fish to the commercial fishery is usually between 25% and 30% in terms of numbers of fish: the vast majority of them pink salmon, with chum salmon in second place, some sockeye, and a sprinkling of cohos, a dash of chinooks.

By way of responding to the inquiry about the ratio of feed weight to adult fish weight, we can look at a couple of examples of how much commercial feed by weight is fed to juveniles and compare that to estimated weight of returning adults. If there are a total of 98,627,706 juveniles and they are predominately pink and chum, and prior to release the total weight of the fish feed used is 201,434 pounds, and the estimated weight of returning adults (subject to survival rates) is 14,824,659 pounds, then the ratio of feed weight to adult fish weight could be calculated as being 1 to 76. A second example would be if there are a total of 3,747,258 juveniles and they are predominately sockeye, with some coho and some chinook, and prior to release the total weight of the fish feed used is 21,999 pounds, and the estimated weight of returning adults (subject to survival rates) is 1,231,263 pounds, then the ratio of feed weight to adult fish weight could be calculated as being 1 to 56.

In your inquiry you refer to the sustainability of feeds and feed safety, which are a subset of the larger issue of food safety. The U.S. Food and Drug Administration has been the news a great deal lately as the Congress is moving to expand the agency’s authority to inspect overseas plants to ensure the safety of the U.S. food supply, and in fact FDA officials were in China last week to inspect some facilities. In the case of animal feeds, the FDA provides industry import alert notices, and if there are concerns, products can be detained until the product is safe to use.

In 2007, when FDA testing found a very low level of melamine in ingredients used by a fish feed manufacturer in the U.S., the state of Alaska took immediate action to investigate the matter, and inform the public by posting a briefing paper on the Alaska Dept. of Fish and Game website, including the U.S. Food and Drug Administration’s statement that melamine doesn’t accumulate in tissue and didn’t pose a food safety risk to humans. Further, the briefing paper stated, “Unlike heavy metals such as mercury, melamine does not remain in an animal’s body for a significant length of time. Information from the FDA suggests melamine is excreted from an animal within 10 – 15 days after ingestion.” Any melamine that could have found its way into the fishfeed fed to juvenile Alaska salmon would have been in trace amounts and measured in parts per billion. Since the average weight of an adult salmon is approximately one thousand times that of the salmon fry and/or smolt released into the wild, this growth would further dilute the measurement to parts per trillion in any adult salmon that may have been exposed to melamine. No adult salmon in Alaska were affected by the contaminated fish feed: there was not reason to believe that any salmon mature enough to be eaten by people would contain any melamine. Of course, testing was conducted by ADFG and Dept. of Environmental Conservation (DEC), and DEC tests for a variety of contaminants as part of its ongoing monitoring of Alaska seafood, to help ensure that Alaska salmon and other fish are a pure and healthy.

There are two main suppliers of fish feed to Alaska’s private non-profit hatcheries. One, which was not involved in the melamine issue, does not purchase proteins from China (2007 melamine source), and tests for a number of contaminants, including melamine. They also have full traceability of their ingredients. The other company took actions to minimize risk of any future issues relating to non-protein nitrogen addition to vegetable protein raw materials, including requiring verifiable guarantees of product purity, new testing regimes, strengthening of auditing raw materials suppliers, and revised quality assurance procedures to ensure supplier compliance to updated purchasing guidelines.

Alaska is fortunate to have the world’s healthiest, most robust and best managed wild salmon fisheries. Every facet of our fisheries has been strictly regulated, closely monitored and the limits on fishing strictly enforced for nearly fifty years. We are proud to be a model of sustainable fisheries management, guided by the best science and the precautionary principle. The world’s most forward thinking markets are moving toward improved traceability of all food products, and there is no question, the European Union is setting the pace. It is a process that will not happen overnight, but there seems to be encouraging progress on many fronts, and the Alaska industry with its many key customers in Europe and Asia works very hard to exceed customer expectations in this regard. Customers want to know about conservation and management methods, fisheries policy and allocation, regulatory regimes and enforcement power, not just for salmon, but for all Alaska seafood. Their interests, as evinced during the recent European Seafood Exposition, are wide ranging, and include the State of Alaska’s sustainable management of the salmon fishery, international treaties governing Pacific salmon harvests, international conservation regimes for Pacific halibut, the hard “TAC” or total allowable catch — strictly enforced limits to the harvests in federally managed fisheries such as the Alaska pollock fishery, and the “rationalization” of the crab fisheries. Alaska fisheries can be viewed favorably in light of the international standards set by the Code of Conduct for Responsible Fisheries established by the Food and Agriculture Organization of the United Nations.

Part 3 – WWF International response (un-edited)

received from Sarah Bladen; Communications Manager Global Marine Programme, to the questions sent to Dr. Simon Cripps, former WWF Global Marine Programme Director by Seafood Intelligence:

1) How does the WWF view the Alaska salmon originating from hatcheries: are they ‘truly wild’? Or best described as ‘ranched’?

In Alaska, hatchery fish are carefully differentiated from farmed fish and are promoted as wild even though they are not ‘truly wild’. In essence, hatcheries provide an advantage to juvenile salmon by reducing mortality, providing protection from predation, and allowing them to mature from eggs before being released into the wild. Upon being released as fry or smolts, hatchery salmon live their entire lives in the wild. Nonetheless, you will often see the nuances in advertisements that refer to them as ‘wild caught’ or ‘ocean harvested’. However, most people in the fisheries profession refer to hatchery stocks as “enhanced” or “ranched,” particularly those that are harvested in terminal fisheries. ‘Ranched’ would be the most correct descriptor to use for those stocks that are released as fingerlings and return to a natural habitat to be harvested. The only ‘truly wild’ salmon is one that hatched from an egg in a gravel bed of a river.

2) As 2007’s melamine-in-feed incidents showed (the melamine incident was the largest recall ever undertaken by the FDA), even Alaska salmon were potentially tainted (some were certainly fed with ‘suspect’ batches – re. ADF&G May 17th 2007 briefing); The same issues that farmed salmon is finding itself scrutinised for (re. sustainability of feeds and feed safety) can thus also apply to AK ‘wild’ salmon. What is WWF’s comment? What would WWF advise Alaska salmon fisheries decision-makers to do to prevent this from happening again?

See response below to the three issues raised here: (A) melamine; (B) sustainability of reduction fisheries; and (C) what Alaska should do.

(A) The melamine distinction is a matter of scale between hatchery and farmed fish. Hatchery fish would be fed comparatively small amounts of tainted feed compared to farmed fish as they are released at small sizes and subject to far less bioaccumulation and bioconcentration than farmed fish. Any melamine present in feed provided to Alaska hatchery salmon in 2007 would have been in trace amounts and measured in parts per billion based on fish size and feed consumption rates. Moreover, according to FDA reports, melamine is excreted within 10-15 days. Hatchery salmon that may have been fed the contaminated food will not be eaten until 2-5 years later. Because the average weight of an adult salmon is approximately one thousand times that of the salmon fry and/or salmon smolt released into the wild, this growth would further reduce melamine concentrations to non-detectible levels on the order of parts per trillion in any adult salmon. In contrast, farmed salmon may have been fed contaminated feed: (a) at much higher rates over a longer period of time; and (b) less than 10 days before processing and introduction to the market for consumption, thus increasing the risk to humans.

(B) The sustainability of reduction fisheries are a very serious concern. However, much less feed is used for a shorter period of time to produce hatchery fish whereas farmed fish require a continued supply of feed throughout their lifecycle. Feeding hatchery fish requires very small amounts of food – for fry and smolt it’s roughly 3-5% of individual body weight at 0.1-5.0g over a 60-90 day period depending on the species. The Alaska Department of Fish and Game (ADF&G) calculates approximately 5,000,000 pounds (~2300 metric tons) of feed used in hatchery operations in Alaska. Based on approximate percentages of 40% fish meal and 25% fish oil used in standard feeds, this amounts to roughly 1500 metric tons of reduced fish. In contrast, over 5 million metric tons of feed are produced from fish sources annually, with the processed feed used in Alaska amounting to less than one half of one percent of that value.1Thus, hatchery fish in Alaska are a relatively minor contributor to any problem of unsustainable reduction fisheries compared to other contributions such as livestock feed, production aquaculture feeds, and other products for human use.

(C) Alaska’s fisheries decision makers should insist upon better monitoring and testing of all animal feeds by federal authorities or shift to producing feed in the U.S. under more stringent environmental standards to prevent food safety issues like the melamine scare.

3) Does the WWF consider that Alaska hatchery-raised fish released in the wild should be considered differently from non-hatchery raised fish?

Yes. There is a considerable body of science that shows that hatchery fish are indeed different from non-hatchery fish in behavior, physiology, and genetics. The U.S. courts have also ruled that they should be considered differently. Our priority should be to maintain wild stocks and the habitat they depend on. Hatcheries should generally only be used/promoted as an option to replenish diminished runs. That said, the hatchery program in Alaska is one of the most well-managed and ecologically sensitive hatchery operations in existence. Strict genetic controls and procedures for preventing competition with wild stocks are employed to maintain the integrity of wild stocks while providing enhanced economic opportunities for commercial fishermen.

4) Does WWF believe that hatchery-origined Alaska salmon should be labelled accordingly once reaching the market/consumers IF this was possible (DNA tracing could in the future make this possible, e.g. the Cooke Aquaculture – New Brunswick project), as each individual fish can theoretically be traced/DNA-identified?

WWF does not have a position on this issue and no immediate plans to develop one. We would consider our position when we feel it necessary to review the issue.

5) Has the WWF addressed the issue of the sustainability of the feed which was/is fed to those billions (there are several year-generations currently at sea) of MSC-ecolabelled Alaska salmon?

Yes. Sustainability of feed sources was considered by WWF in the publication “Food for Thought: The Use of Marine Resources in Fish Feed”2 as well as the publication “The Great Salmon Run.”3

Carnivorous species such as salmon are grown on fish feed containing large proportions of fishmeal and fish oil derived from wild caught fish. The largest sources of fishmeal and fish oil are anchovy, sardine, and mackerel primarily caught in the Pacific Ocean off South America. Heavy over-fishing of South American pilchard has caused a serious decline in the stock from 6.5 million tons in 1985 to around 60,000 tons in 2001. In the North Sea, blue whiting is widely used in the fish-feed industry. In 2001, North Sea coastal states caught 1,800,000 tons, which is double the recommended quota from the International Council of Exploration of the Seas (ICES). WWF recommends producers of fish feed to ask for documentation that any fishmeal and fish oil used only originates from healthy and well managed sustainable fish stocks, preferably certified to equal Marine Stewardship Council (MSC) standards.

Nonetheless, the amount of fish feed, and the raw reduced fish products it incorporates, used in hatchery operations is insignificant compared to other activities sourcing from reduction fisheries.

The above updates the answer already provided by Jill Schwartz, WWF-US, to SeafoodIntelligence – Through the Salmon Aquaculture Dialogue, we address the issue of sustainability of salmon feed as a whole and we work with feed companies. There isn’t a difference between feed going to hatcheries for salmon released into the wild and feed going to hatcheries for farmed salmon. That said, we have not studied this issue in detail.

6) Since the feeding of up to a third of ‘wild’ Alaskan salmon – and perhaps many salmon fished in Canadian waters as well – found in the wild depends on commercial feeds (to see them through their hatchery time), can a salmon fishery based in part on the harvest of commercial-feed-fed-juveniles be truly considered as ‘sustainable’ from WWF’s perspective? (please give your justification).

This answer was already provided by Jill Schwartz, WWF-US, to SeafoodIntelligence;

Receiving feed as juveniles doesn’t necessarily make that fish unsustainable. Feeding fish to other fish is not necessarily unsustainable, though it certainly can be. The two key issues are the source of the feed fish (whether they come from a healthy wild stock) and the amount used (the percentage of fishmeal and oil in the feed, and the ratio of fish protein produced to fish protein consumed). Therefore, traceability in fisheries becomes paramount to ensuring that reduction feeds are sourced from sustainable fisheries.

7) Has WWF evaluated the amount of fish feed (tonnes) & fishmeal/fish oil and respective wild fishery catches (in tonnes) necessary to feed all State-hatchery Alaska salmon?

We have not, but ADF&G has. Based on their calculations the amount of feed used in hatchery programs annually amounts to about 5,000,000 pounds or 2300 metric tons. (See response to Question 2 above)

8) If so; what are your findings & where do those fish (used to make the fishmeal and fish oil used in the juvenile salmon feed) come from? (please give figures) [8-b) Do any come from MSC-certified fisheries?]

Feed used in the Alaska salmon hatchery programs comes from the companies Skretting (a division of Nutreco) and EWOS. Skretting claims that, “Documentation of ingredients from source to finished feed ensures full traceability of products delivered to fish farms and these systems are under constant development to meet the latest requirements. Skretting’s purchasing policy, therefore, requires fish meal and fish oil to be sourced only from managed and sustainable fisheries. These are all subject to monitoring and management regimes implemented by the national governmental fisheries.”4 Less information is readily available from EWOS.5

WWF has not researched specifically where raw fish is sourced from for use in the feeds used in Alaska’s hatchery operations. Therefore, we currently do not know if raw fish used in hatchery feeds is derived from MSC-certified fisheries. We recommend you contact those feed suppliers to determine the origin of fish resources used in their feed production processes.

9) If not, a) why not? and b) do you plan to?

Because Alaska salmon hatcheries are such a small contributor to fish feed demands and production, the need to determine sourcing for feed used in hatchery operations did not and does not rise to a level of priority necessitating further research. However, if you are interested we would encourage you to seek further information from Skretting and EWOS regarding their raw material sourcing and sustainability platforms.

10) Have you been/Are you addressing these issues (the issue of the sustainability of the Alaska salmon/’wild’ fisheries based on State hatchery/aquaculture programmes; re. feed in particular) with the relevant US/Alaska fisheries state bodies and fishermen’s organisations?

We are constantly addressing the sustainability of Alaska wild fisheries and work very closely with Alaskan fishermen’s groups and the ADF&G. We have not spent significant time addressing the issue of feed used in the hatchery program as it has not been the most pressing concern with respect to the sustainability of Alaska’s fisheries.

11) If so, what has been their response (please be specific) and what do you intent to do about the topic?

WWF maintains a very positive and productive relationship with fishermen and fisheries managers in Alaska. We have supported measures in Alaska to improve the sustainability of Alaska’s salmon resources including the conservation of critical habitat as well as the MSC-certification of Alaska salmon. We will continue to address issues of sustainability and ecosystem concerns as these issues arise. However, the amount of feed used in hatchery operations in Alaska does not rise to the level of significance to impose an urgent need to address the issue. Thus, WWF does not intend to address this issue any further at this time.

 

1 International Fisheries and Fish Oil Organization. http://www.iffo.net/default.asp?fname=1&sWebIdiomas=1&url=110

2 Food for Thought: the Use of Marine Resources in Fish Feed. http://assets.panda.org/downloads/foodforthoug.pdf.

3 The Great Salmon Run. http://www.worldwildlife.org/trade/salmonreprt.cfm .

4 Outstanding Services and Nutrition from Skretting.http://www.skretting.ca/web/SkrettingCanada/InterWeb.nsf/wprid/5A0DDAF8240F0CFE882571A4007DB77A/$file/skrettingcanadacatalogue2006.pdf

5 http://www.ewos.com/ca/

 

Read a sample of ‘wild’ vs. ‘farmed’ AK salmon articles on the SeafoodIntelligence.com News Database:

 

etc…

 

Sustainable Seafood Intelligence, News & Consultancy for Stakeholders of the Global Seafood, Fisheries & Aquaculture sectors with a focus on issues re. industry Transparency (#Top35Salmon #Top100Seafood), Economic, Social and Environment Sustainability, Ethics (#SeafoodEthics #SustainableSeafood #TransformSeafood #ResponsibleSeafood #SeafoodIntelligence), CSR/RSE & Politics… Perceptions of issues (negative & positive) impacting industry’s Social License to Operate (SLO) and acceptance. Farmed salmon & global seafood industry Sustainability Reporting benchmarks…. Multi-stakeholder sustainability thinking & analysis applied to seafood…