Prospects for organic aquaculture in the US; an appeal for immediate action

George Lockwood, the Chair of the Aquaculture Working Group advising the USDA on organic aquaculture standards, has written a letter urging industry stakeholders to reach out to USDA Undersecrtary Greg Ibach in support of organic aquaculture. \"Our request of him is simple: please publish the USDA proposed Final Rule for organic aquaculture for public comment without further delay.\"
January 18, 2018

George Lockwood, the Chair of the Aquaculture Working Group advising the USDA on organic aquaculture standards, has written a letter urging industry stakeholders to reach out to USDA Undersecrtary Greg Ibach in support of organic aquaculture.

Mr. Lockwood is a pioneer fish farmer, former president of the World Aquaculture Society, and a drafter of the National Aquaculture Act of 1980. His recent book “AQUACULTURE: Will it rise to its potential to feed the world?” addresses many federal policies that have restrained the development of aquaculture in the United States. This book has a full chapter on organic aquaculture in the US.

 The following is Mr. Lockwood\'s letter:

Prospects for Organic Aquaculture in the US; An appeal for immediate action

For many years now, an appointed group of aquaculture experts called the Aquaculture Working Group has been advising the United States Department of Agriculture on the development of standards for organic aquaculture. Our Aquaculture Working Group was appointed in 2005, and I was appointed to be the Chair.

In 2010, after a major collaborative effort with AWG, the National Organic Standards Board recommended standards for organic aquaculture to the USDA National Organic Program for inclusion in the USDA Final Rule for organic food production that was authorized by the Organic Food Production Act of 1990.

Very slow progress. The next step was for the USDA to advance the AWG/NOSB recommendations into Final Rulemaking as require under US laws in order for them to become effective. For many reasons within USDA, little happened with the NOSB recommendations for a long time. Finally, in August 2016 with congressional and public urging, the USDA sent their proposed Final Rule to the US Office of Management and Budget to obtain their required consent to publish their proposal for a Final Rule for organic aquaculture for public comment.

Usually it takes 90 days for OMB to conclude such reviews. However, in our case approval to publish was not granted until December 2017, sixteen months after submission. However, in spite of approval from OMB, USDA chose to not publish their proposed Final Rule for organic aquaculture before the change in administration on January 20, 2017. This was a major setback.

No progress under the new administration. Since the new administration has been in office our proposed rule has been on the USDA regulatory \"inactive\" list. It will take action by the Office of the Secretary of Agriculture Sonny Perdue to move the proposed Final Rule for organic aquaculture from the USDA inactive list to their active regulatory agenda. So far the Secretary has not been responsive to requests of their AWG to move forward and publish.

The reason our rule is on hold is that within the USDA there is an uninformed belief that there is no need for organic aquaculture products. They believe that nobody wants organic aquaculture products: Not consumers, not producers, not retailers, not restaurant owners. We are told “No one is interested and no one cares.”

Need to communicate. We know differently, however, and we need to communicate the need for organic aquaculture to the Secretary and his staff in a major way. The adverse attitude within the USDA can only be changed by public, congressional and inter-agency communications with Secretary Perdue and his immediate staff.

Of particular importance is the very recent appointment of Greg Ibach as the Under Secretary of Agriculture for Marketing and Regulatory Programs. Although new to federal government service, I am informed that he is open minded and wants to hear from the public on important matters. Our request of him is simple: please publish the USDA proposed Final Rule for organic aquaculture for public comment without further delay.

The mailing address for Under Secretary Ibach is:
Hon. Greg Ibach, Under Secretary of Agriculture for Marketing and Regulatory Programs, U.S. Department of Agriculture
1400 Independence Ave., S.W., Washington, DC 20250

In your correspondence, I suggest that you include:

  • Your position in aquaculture and seafood (consumer, retailer, producer, etc.). 
  • That you and others in the American public care and want organic aquaculture products. 
  • A statement on why organic certification for aquaculture is important (see below). 
  • Any other reasons (see below). 
  • Your request to “Please publish the USDA proposed Final Rule for organic aquaculture for public comment as soon as possible.”

The need for organic aquaculture standards. Our Aquaculture Working group of twelve professional aquaculture experts has been working with USDA since 2005 for the adoption of good organic aquaculture standards. We excepted this responsibility and have responded in good faith to do a good job. Over many years we have had the support of the aquaculture community: consumers, retail grocers, restaurant owners, fish farmers, etc. We need our good faith efforts to be honored by USDA.

Organic aquaculture products are the only food group that does not have access to the valuable USDA Organic label. Yet the USDA and our Health and Human Services Administration recommend that Americans eat two portions of seafood per week.

Large amounts of farmed seafood such as salmon, shrimp, mussels, etc. are now imported in the US and sold under organic labels of the EU, Canada and foreign private certifiers. American consumers are buying large amounts of organic aquaculture products that are foreign grown by foreign farmers by foreign agriculture workers.

With the availability of the USDA Organic label for aquaculture, US fish farmers can earn premium prices and be able to successfully compete with foreign producers. New farms to serve new demand would be established employing American workers. Foreign-grown aquaculture products bearing foreign organic labels would be barred from the US marketplace. The domestic aquaculture industry will grow to fill this large market as well as create new consumption. The present situation is unfair to our domestic farmers and unfair to American consumers who are demanding USDA Organic certification for farmed fish and shellfish.

The USDA completed work on their proposed standards for organic aquaculture over one year ago after many years of delays and slow progress. The new administration is attempting to reduce bad, unnecessary and costly regulations for good reason. However, our proposed organic aquaculture regulation imposes no new costs on anyone and provides for the development of new markets with premium prices for American farmed fish grown by American workers

Communicate directly with Under Secretary Ibach. In order for this administration to move forward with our good rule it is necessary for many people write Undersecretary Gary Ibach soon. He needs to receive letters requesting immediate publication of the USDA proposed Final Rule for organic aquaculture from consumers and consumer groups; grocery retailers; food distributors; restaurant chefs and owners; individual fish farmers; aquaculture suppliers; various state aquaculture and species associations; members of congress and the staffs of congressional committees.

Mr. Ibach also needs letters and other communication from our Federal Inter-agency Aquaculture Working Group as a body and from its individual members; the aquaculture staffs and the chain of command in the USDA, Department of Commerce, Department of Interior; plus multiple other departments and agencies in our federal government including our many Sea Grant and extension agents throughout the country; state aquaculture coordinators; the aquaculture press; and others. 

Aquaculture scientists who are federal and state government employees, and grant beneficiaries of federal aquaculture programs, are urged to write as interested individuals.

Time is of the essence! A large number of people need to be heard from now with the message that there is a strong need for organic aquaculture standards in the US. If we cannot dislodge this important rule, over thirteen years of determined efforts by many people will be lost and domestic consumers and farmers will lose this opportunity.

We need your help. Now is the time to act. Please write to Undersecretary Greg Ibach now! Please urge others to write as well.

George Lockwood