Canada’s first-ever Code of Practice for fish is open for public comment
Fish farming (also know as ‘aquaculture’) has increased in recent decades, and so has the concern about welfare issues that result from keeping fish in crowded pens and subjecting them to procedures that cause pain and stress, not unlike other farmed animals.
We encourage you to submit official comments to NFACC to demonstrate that Canadians care about the care and treatment of fish.
Top picture: A wild salmon swimming upstream. Salmon are migratory and would naturally swim great distances at sea.
Although researchers still don't agree as to the level and complexity with which fish feel pain, many believe we have an obligation to treat them ethically (this is called the "precautionary approach"). And, as new evidence emerges, it becomes harder to deny that fish are intelligent with at least some capacity to feel pain and suffer. Fish are sentient beings and consumers are becoming more concerned about how these animals are treated by humans, especially when killed for food. It is important that strong standards are in place to protect them from conditions and practices that cause stress and pain.
Initiating the development of Canada’s first Code of Practice for Farmed Salmonids (salmon, trout, charr)
As a result of increasing public concern, and the growing recognition of this concern by the aquaculture industry, the National Farm Animal Care Council (NFACC) is developing Canada’s first ever Code of Practice for Farmed Salmonids (salmon is the most farmed species in Canada). Every code development committee has representatives from different stakeholder groups, including an animal welfare representative. As a member of NFACC, World Animal Protection represented the animal welfare perspective for this Code.
As in every NFACC Code of Practice, key welfare issues have been identified by the Code’s Scientific Committee based on the latest research and expertise in fish health, behaviour and welfare. The Code outlines recommendations and requirements for the aquaculture industry in the areas of husbandry, health/disease measures, the impact of sea lice on fish welfare, fasting/feed withdrawal, stock density, water quality issues, lighting and photoperiods, slaughter methods, as well as other topics.
As every code is a balance between economic, industry and welfare interests, there may be some requirements or guidance that are not as strong as we wanted. But every NFACC Code is opened to Canadians for official comment; this is an opportunity to have your say about the treatment of fish on Canadian farms and help strengthen industry requirements for how fish are treated.
Welfare issues in fish farming
In the wild, salmon travel huge distances (some travel over 3,000 kilometers) to migrate, and their natural behaviours reflect the large ranges they are used to traveling. But in captivity, salmon have a small fraction of this space. At the very least, farmed salmon should be provided with room to swim around (no crowding) and be given with opportunities for exercise. This can be done by providing areas with a faster current to allow fish to swim.
Stocking densities (also called ‘bio-density’) on fish farms are variable and can depend on the system (land-based vs open water), tidal range and other factors. However, stocking density is an important welfare consideration and research shows when tanks are too crowded, injuries can result, such as pelvic fin damage and cataracts. There are production impacts to overcrowding as well – some research has shown lower feed intake when stock density is high.
Fish are regularly handled in the aquaculture industry for procedures such as vaccination and grading. Handling is stressful for fish, and they are more susceptible to injuries depending on their age, health or because of environmental factors. These conditions need to be considered when setting a standard for fish welfare during handling.
Like other farmed animals, fish may face unnecessary stress and suffering before and during slaughter. The most humane method is to render the animals unconscious prior. CO2 is a commonly used method, but it is widely considered inhumane because it is a very painful and slow method of slaughter for fish. In parts of Canada, ice-slurry slaughter is another inhumane method still used where fish are placed on ice fully conscious to slowly asphyxiate.
The most humane method is the process of electrical stunning where an electrical current is passed through the water causing death almost instantly.
Salmon are typically denied food on farms prior to husbandry procedures and slaughter for welfare reasons (such as reduced injury and mortality) and for food hygiene reasons. In the wild, salmon can experience short periods of food deprivation and have adapted to this. However, longer periods cause stress. Thus, salmon should not be subject to more than 48 hours of food deprivation. This is generally considered acceptable from a welfare perspective. The Code, however, permits up to seven days of food deprivation which is unacceptable.
Some fish farms use 24-hour lighting which is associated with many negative welfare effects including neurological development issues, lowered bone strength, poor smolt quality, failed smoltification, and failed spawning. Higher welfare systems should have lighting systems in place that gradually change in light intensity. However, the Code only requires this for newly built systems not existing systems; it should apply retroactively to existing fish farms.
Sea lice has been an important environmental concern with fish farms for many years, but it is also a welfare issue, as infestation can cause pain and suffering. While the recommendations and requirements in the code focus on the removal of sea lice and monitoring sea lice levels in the population, there is no mention of what personnel should do when they come across an individual fish or a number of fish that are covered in sea lice and are thus likely experiencing pain or suffering. For example, the RSPCA welfare standards for farmed Atlantic salmon states that “any fish with severe physical damage caused by sea lice grazing must be removed and dispatched humanely without delay”. There should be a similar statement in this Code.
Take action – submit your comments on the draft fish Code of Practice
The first-ever Code is open for public comment until January 7, 2021. We encourage you to submit official comments to NFACC to demonstrate that Canadians care about the care and treatment of fish. Like all farmed animals, fish should not suffer needlessly, and this should be reflected in the Codes of Practice. Below are some specific areas where the Code standards could be stronger, but feel free to include other comments on issues important to you:
Fish farmers should be required to ensure that stocking density aligns with animal welfare needs.
The Code stipulates “aim for a biodensity that produces outcomes in alignment with the green column of Appendix E – Welfare Indicators of Farmed Salmonids”. This is currently a recommendation, but it should be a requirement.
Essentially, fish farmers should be required to ensure that stocking density aligns with animal welfare needs – fish should not be crowded and have room to swim around.
The Code includes several recommendations that should be made into requirements as producers typically only follow the requirements in the Codes. These recommendations include:
Have sufficient personnel to perform procedures in a timely manner and any necessary tools/equipment ready before fish are handled.
Strive to return fish to the water in less than 30 seconds.
Whenever possible, run water over the gills when handling fish out of water.
Ensure any gloves worn while handling fish minimize slipping and mucous loss and prevent scale loss.
As of January 1, 2024, ice slurry slaughter must not be used as the sole means of slaughtering fish. This is cruel slaughter method. Ask the Code committee to shorten this time frame to 2022. One year should be enough time to adopt this change.
It should also be stated in the requirements that the use of carbon dioxide is not acceptable.
All sites, including older sites that are not planning on renovating, should be required to use lighting systems that gradually change the intensity of light. Constant 24-hour lighting is not acceptable. Abrupt changes in light can result in injury, mortality, or suffocation of fish. Thus, this needs to be a requirement of all facilities and should be phased in over the course of the next 1-2 years.
The code currently specifies up to seven days is allowable for feed withdrawal, but this is much too long. The maximum time should be stated for feed withdrawal in the requirements and should state maximum feed withdrawal time should not exceed 48 hours, in keeping with other welfare standards.
The code should follow the RSPCA fish welfare standard for humanely euthanizing fish detrimentally impacted by sea lice infestation: “any fish with severe physical damage caused by sea lice grazing must be removed and dispatched humanely without delay.”