A Day on the Fish Farm: FDA and the Regulation of Aquaculture
By Graham M. Wilson
INTRODUCTION
Aquaculture is the art of rearing aquatic organisms. Although fish farming is over 3,500 years old,2 the industry only came to the United States during the 1950s. Since that time, the practice of industrial aquaculture has exploded in this country and around the world. Aquaculture is the fastest growing area of agriculture in the U.S. and exists in every state. However, despite the current prevalence and economic importance of the industry, there are still many neglected questions concerning aquaculture regulation. Issues such as monitoring antibiotic resistance, reducing environmental impact and determining the appropriate role of genetic technologies have garnered a great deal of regulatory scrutiny with regard to agriculture generally, yet seem to be neglected in the realm of fish farming. The set of federal agencies involved in creating and implementing policies that govern aquaculture includes the United States Department of Agriculture (USDA), the Environmental Protection Agency (EPA), the National Marine and Fisheries Service (NMFS) and the Fish and Wildlife Service (FWS). But perhaps the most interesting regulatory questions currently facing the industry must be answered by the Food and Drug Administration (FDA).
This note examines certain human health and environmental concerns currently faced by aquaculture, evaluates the FDA's current regulatory practices and considers possible policy changes for the future. Throughout this note, aquaculture will refer to the practice of raising fish as food for human consumption in open water netpens. Part II addresses the increase in antibiotic resistance arising from aquaculture practices, illustrates why aquaculture medication practices should be of concern, explains how the FDA currently regulates the use of antibiotics in aquaculture and evaluates the latest proposal for the approval of new antimicrobial animal drugs. Part III looks at how the FDA should regulate the use of genetic engineering techniques in aquaculture facilities, specifically focusing on a recent request to market a transgenic salmon.
This section discusses the use of genetically modified organisms (GMOs) in agriculture, illuminates concerns about genetic engineering, outlines how the FDA regulates genetically modified (GM) products, describes how these regulatory practices would be applied to a transgenic salmon and inquires whether or not the FDA's current policy is sufficient to protect human health and the environment. Part IV explores policy considerations the FDA should consider in evaluating transgenic salmon products, recommends that the FDA require product labeling for foods derived from transgenic fish, explains why a labeling requirement could be statutorily justified, documents a wide scope of concerns regarding current industrial aquaculture techniques and exhorts the FDA to exercise diligence in its regulatory activity in order to keep human health and environmental problems from getting out of control.
Aquaculture is the art of rearing aquatic organisms. Although fish farming is over 3,500 years old,2 the industry only came to the United States during the 1950s. Since that time, the practice of industrial aquaculture has exploded in this country and around the world. Aquaculture is the fastest growing area of agriculture in the U.S. and exists in every state. However, despite the current prevalence and economic importance of the industry, there are still many neglected questions concerning aquaculture regulation. Issues such as monitoring antibiotic resistance, reducing environmental impact and determining the appropriate role of genetic technologies have garnered a great deal of regulatory scrutiny with regard to agriculture generally, yet seem to be neglected in the realm of fish farming. The set of federal agencies involved in creating and implementing policies that govern aquaculture includes the United States Department of Agriculture (USDA), the Environmental Protection Agency (EPA), the National Marine and Fisheries Service (NMFS) and the Fish and Wildlife Service (FWS). But perhaps the most interesting regulatory questions currently facing the industry must be answered by the Food and Drug Administration (FDA).
This note examines certain human health and environmental concerns currently faced by aquaculture, evaluates the FDA's current regulatory practices and considers possible policy changes for the future. Throughout this note, aquaculture will refer to the practice of raising fish as food for human consumption in open water netpens. Part II addresses the increase in antibiotic resistance arising from aquaculture practices, illustrates why aquaculture medication practices should be of concern, explains how the FDA currently regulates the use of antibiotics in aquaculture and evaluates the latest proposal for the approval of new antimicrobial animal drugs. Part III looks at how the FDA should regulate the use of genetic engineering techniques in aquaculture facilities, specifically focusing on a recent request to market a transgenic salmon.
This section discusses the use of genetically modified organisms (GMOs) in agriculture, illuminates concerns about genetic engineering, outlines how the FDA regulates genetically modified (GM) products, describes how these regulatory practices would be applied to a transgenic salmon and inquires whether or not the FDA's current policy is sufficient to protect human health and the environment. Part IV explores policy considerations the FDA should consider in evaluating transgenic salmon products, recommends that the FDA require product labeling for foods derived from transgenic fish, explains why a labeling requirement could be statutorily justified, documents a wide scope of concerns regarding current industrial aquaculture techniques and exhorts the FDA to exercise diligence in its regulatory activity in order to keep human health and environmental problems from getting out of control.
