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Organic Standards and Shrimp Farming


Lorenzo Juarez ( I’m looking for organic standards for shrimp farming.


Daniel Gruenberg ( Lorenzo, Naturland, Euroleaf, Biosuisse and the Soil Association have standards for organic shrimp farming.


Gianluigi Negroni ( Lorenzo, I have a study done some years ago that contains all the organic standards for aquaculture.  In the European Union, we call them “biological” standards.


Marlene Stewart ( Here is a statement from the United States Department of Agriculture (USDA) on its organic standards.


USDA does not currently have organic standards for aquaculture, but its National Organic Program (NOP) is in the process of developing them.  Specific labeling guidance will be detailed after the standards are implemented.  Certification of aquatic animals will not be available until the new standards are complete.


You may be able to get an “organic input” certification for aquaculture production that contains no chemical residues.


Daniel Gruenberg ( NOP is such a perfect name for this program that has been “in process” for nearly two decades.  It’s the biggest embarrassment and most massive failure in the organic certification world.  NOP we ain’t gonna make organic seafood!


Marlene Stewart ( I believe many in this group are smart enough to produce organic seafood without the guidance of NOP.  Clifford Morris at Florida Organic Aquaculture did it.


Why don’t we make a list of all the factors that need to be considered in an organic standards policy for aquaculture and then have everyone comment on it?


Dallas Weaver ( In the USA, organic agriculture standards have evolved into an unscientific, political marketing game.


For example, you can’t use synthetic ammonia or even natural NaNO3 in organic culture, including algae culture, but you can use manure from cattle, pigs and chickens that were fed corn, fertilized with ammonia to provide the nitrogen and phosphate.  By regulation, you can’t produce organic algae without a ton of organic junk in the water.  Of course this creates biosecurity issues and several of our largest food poisonings resulted from organic agriculture products.


Also, USDA organic standards don’t allow genetically modified organisms as we approach a time when we will be introducing genes for disease resistance into our animals, like shrimp, using modern genetic technology.


Marlene Stewart ( Dallas, everything in the USA is a major marketing game.  It’s a wild and crazy mess.  But we humans keep trying to make better products.  If no one tried to innovate, create and define safe organic standards, you wouldn’t be able to rely on any food labeling, and you would probably get horrible food.  That’s why I have a keen appreciation for those innovators who have advanced recirculating aquaculture systems (RASs) and photo bio reactors (PBRs) that use light to grow algae and other phototrophic microorganisms around the world.


At times, people I respect, like you, associate food poisoning with some poorly managed organic operations, but I wouldn’t throw the baby out with the bath water.  New successful organic production methods use science and highly controlled inputs.  Food producers are being forced to do so by food safety agencies around the world that inspect, test and mandate food safety.  Food recalls are serious business for any company.  If an organic food company poisons people, they can be put out of business or even put in jail.  Food is tracked from farm to fork.  As all of you know, shrimp shipments to the USA are being rejected for antibiotic residues.


More and more organic food and feed are being marketed around the world.


Daniel Gruenberg ( Marlene, I worked hard to create organic methods for shrimp farming, and my farms were certified by Naturland, Euroleaf, BioSuisse and the Aquaculture Steward Council, but eventually I gave up producing organic shrimp because the organic standards were holding us back with totally illogical conditions.


For example, in all their wisdom Naturland decided that organic Penaeus monodon feed should be limited to 20% protein.  I argued that it isn’t the business of the certification agency to determine how much protein I put in my feed.  If I have a feed with 20% protein and another with 45% and one gets a feed conversion rate of 3 and other of 1.5 (real numbers), which one is better for sustainability?


Regarding all of the machinations of USDA’s NOP, where do I start?  It’s an absolute travesty for producers, consumers and tax payers alike.


I used to think Naturland was bad until I started to follow the development of the NOP standards.  They are very very bad.


As with many of the organic standards, the NOP standards fail to recognize the differences between aquatic and soil-based farming.  If I use a nitrogen or phosphorus source that is full of shit from antibiotic, anticoccidial, anti-fungal, hormone-pumped chickens, full of coliform, E. Coli and all kinds of other human pathogens, I bias my system in favor of bacteria and away from diatoms and algae and create an unstable system.  Is that supposed to produce “superior” shrimp?


On top of all of that, so many special interests are involved in the development of organic standards that the USDA has not come to any decisions after more than a decade of deliberations.


There is no bigger joke in the food world than NOP.


Ramon Macaraig ( Earlier Marlene asked us to make a list of things that needed to be considered for moving organic aquaculture standards forward.  Here is my list of things that need to be considered from the perspective of farming and marketing organic shrimp from our open-pond, biofloc-based production system.


Disinfection: We have no problem with organic standards for our disinfection method, washing the ponds with freshwater, liming with calcite and sun-drying for 40-50 days.  After that, based on total ammonia nitrogen levels, we flood the ponds with 30 centimeters of seawater and then add photosynthetic bacteria and molasses.  Here organic standards may specify a list of “allowed” bacteria.  Next, we produce a green algae, dominated by Nannochloropsis species and fertilized with urea, diammonium phosphate and molasses.  Here we are in conflict with the natural fertilizers specified by organic standards.


Pond Preparation: Organic standards allow us to produce rotifers from trash fish.  The rotifers need green algae to thrive, but the natural fertilizers allowed by the organic standards don’t produce enough green algae to feed the rotifers.  We can’t grow enough green algae cost effectively without mineral fertilizers like urea and phosphates.  Organic sources like chicken manure and guano require tons of volume and carry the complicated chemotherapeutants for growing chickens that certifiers do not allow.  All these complications lead to more costs.


After stocking, if we opt for diatom production as natural food, where do we get the required “organic” silicates because seawater does not have them in the concentrations high enough for sustaining diatom growth?


Aeration: We maintain oxygen levels at 3.5 parts per million (or higher) in our biofloc ponds to support a biomass of ten metric tons per hectare, which requires 35 to 40 horsepower per hectare, which organic certifiers frown on.


Feeds: The natural food that we produce right after stocking is not enough to sustain our high production levels.  We have to use commercial feeds.  A total natural-food based system is not practical for open ponds, and cost-effective organic feeds are not available in the quantities that we need.


Conclusion: With all the complexities of our system, organic farming does not seem feasible.


Marlene Stewart ( Dallas’s answer highlights my point that organic standards for aquaculture need to be developed by aquaculture experts.  Daniel’s point about protein levels in feed illustrates that.  At the end of the day, for organic standards to work, the product must be safe, tasty, nutritious and affordable.


Dallas Weaver ( Marlene, I contend that the problem is not one of picking experts who know what they are doing.  The problem is that no one is smart enough to do the job!  I know that there are more things that are or may become relevant in the future that I can know or understand.  I could not write organic standards or regulations that apply to all future cases.  Knowing I could not do it and believing that I am as smart as other people, they can’t do it either.


The complexity of what appears to be simple to outsiders can box you into poor solutions in the future.  For example, when the internet protocols and standards were written, they boxed themselves in regarding some present-day network security issues.  Different protocols would make internet security a lot easier today.


Once you have standards in place, you block future innovation and adaptation to changing conditions.  That is the nature and complexity of the real world, which means that the fewer standards and regulations, the better and more robust systems become.


With my recirculation systems and Daniel’s natural pond approach that’s dependent on microbiological ecologies, we just have to look at the real complexity of those systems to know that a bunch of activists and bureaucrats could never construct a rational set of standards for them.


Marlene Stewart ( Dallas, well put, but it seems like a broad set of standards covering chemical residues like antibiotics, hormones or other harmful chemicals might work.  There has to be some way to stop the tide of poisonous food being sold to the public.


USDA’s NOP standards are dynamic and constantly changing.  They do attempt to protect the integrity of food so that you can believe that what you see on the label is what you are getting.  They are prosecuting and putting people in jail for faking labels.  They are also attempting to promote and facilitate more farming operations in the USA, no matter how bureaucratic it seems.


Michael Mogollon ( Marlene, I’m with you.  I believe that there needs to be a fairly simple way to accomplish what most consumers want—food that doesn’t contain antibiotics and other harmful chemicals.  Consumers want clean food.  That’s not too complicated.  If we could center our efforts on that guiding principle, I believe we would be able to create organic standards that work for shrimp farming.


Standards that set out to cover all situations for all people will probably end up like the NOP standards—completely bogged down.  Currently, too many issues that are being addressed at the same time, like density, algae culture, electrical usage and animal welfare.  That approach has bogged down the develop of organic standards.  Rather than getting something straight forward and simple, we end up with nothing.  Keep pushing.  Sometimes we fail at accomplishing the good for the sake of the perfect.


Sources: 1. The Shrimp List (a mailing list for shrimp farmers).  Subject: Organic Standards.  August 11 to August 18, 2017.  2. Bob Rosenberry, Shrimp News International, October 8, 2017.


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