Comment on Canada's First-Ever Code of Practice for Fish

Comment on Canada’s First-Ever Code of Practice for Fish

For the first time ever, the National Farm Animal Care Council (NFACC) has released a draft Code of Practice for farmed salmon (the most farmed species of fish in Canada). As usual, the code development committee is industry-heavy with just one conservative animal advocacy organization represented.

The draft Code is now open for public comment. This is our one and only chance to weigh the favour back towards the animals themselves, so we are asking you to take a minute to submit comments advocating for stronger industry guidelines. As you know, the Codes are not legally-binding and no inspections are conducted for compliance, but they are unfortunately the best we have available to protect farmed animals in Canada today.

Below are our suggested responses for each section. We have drawn some of our responses from recommendations by The Aquatic Animal Alliance (AAA), a coalition of international animal protection organizations which advocate for change within the aquaculture industry. More specifically, we have incorporated AAA’s  Key Aquatic Animal Welfare Recommendations for Aquaculture (which can be found here).

Please click here to submit your comments. The period for public comment closes January 7, 2021.

Suggested Responses

Where no additional text is indicated, please state: “Make all recommended practices requirements.”

2.Rearing Units

      2.4 Lighting

  • 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 should be explicitly forbidden. 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 next 1-2 years.

      2.5 Biodensity

  • Maintain species and life stage appropriate spacing to avoid negative physical, psychological, and behavioral impacts.
  • Action should be taken at the first signs of poor welfare or weight loss.

3.Husbandry Practices

      3.2 Handling

  • Where handling is absolutely necessary, it should be carried out with minimum stress and disturbance for both the aquatic animals handled and any other aquatic animal present (for example, cleaner fish).
  • Handling should occur for the shortest time possible, and anaesthetic must be applied if handling is expected to exceed a few seconds.
  • There should be a requirement for maximum time out of water for all handling procedures.

     3.2.1 Sedating and Anesthetizing Fish

  • When vaccination is necessary, it should be done with minimal distress and with the animal anesthetized, performed only by certified veterinarians or adequately trained animal health professionals.

4. Feeding Management

      4.1 Quality and Safety of Feed  

  • Reduce the amount of wild-caught animals required for aquaculture feed by researching alternative feed sources and improving feed conversion ratios.
  • Strive for the most optimal feeding times and quantities and forbid starvation periods exceeding 48 hours. 

     4.3.3 Feed Withdrawal

  • Maximum feed withdrawal time should forbid starvation beyond 48 hours, in keeping with other welfare standards.

5. Sea Lice

  • Effective prevention strategies should always represent a first line of defence against disease and parasites.
  • The methods used for removal of parasites must conform to rigorous scientific welfare documentation, and steps must be taken to reduce the adverse effects on the welfare of all animals used in this process (for instance, the welfare of cleaner fish used for the treatment of sea lice).
  • The code should follow the Royal Society for the Prevention of Cruelty to Animals 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.”

6. Euthanasia, Slaughter, and Mass Depopulation

  • In all new facilities, slaughter must occur on site to reduce transportation and handling. Where this is not possible, transport and handling prior to slaughter must be as limited as possible.
  • Effectively stun all animals before slaughter, minimize the time elapsed between stunning and slaughter to lower the risk of consciousness being recovered.
  • Change the date for when ice slurry slaughter is to be banned to two years earlier (January 1, 2022).
  • Carbon Dioxide and manually applied blunt force trauma are not acceptable forms of slaughter for fish and should therefore be prohibited.

7. Transportation

  • A maximum transport time must be established.
  • Loading density must not exceed 40 kg/m3.