Fish welfare - a key issue for organic system standards 1

Pino Lembo (COISPA Tecnologia & Ricerca, ICEA - Institute for Ethics and
Environmental Certification)
and Walter Zupa (COISPA Tecnologia & Ricerca)

From the public and from governments, there is
nowadays an increasing interest in the welfare
of farmed fish; among farmers, there is growing
awareness that good welfare equates to
increased success of production activities.
Recital 10 of Regulation (EC) No 710/2009
states, “Organic aquaculture animal production
should ensure that species-specific needs of
animals are met. In this regard husbandry
practices, management systems and
containment systems should satisfy the welfare
needs of animals. *…+ To minimise pests and
parasites and for reason of high animal welfare
and health, maximum stocking density should
be laid down.”
Stress and welfare
In view of these legislative requirements, it is
essential to achieve a better understanding of
what welfare represents for farmed fish. In
general, welfare refers to the physical and
mental state of the animal as it interacts with
its environment and responds to environmental
variations (Chandroo et al., 2004). A more
anthropocentric interpretation says that the
most important factor is the possession and
state of certain cognitive capabilities (Duncan,
1996). In aquaculture facilities, however, it is
important to consider not only psychological
and physiological health of the organism, but
also the degree of stress it faces (Ashley, 2007;
Huntingford et al., 2006). Thus, a more
comprehensive definition of welfare would
include the fish’s capability (physiological and
psychological) to cope with its environment.
There is abundant literature on the
physiological and behavioural responses of fish
to a wide variety of physical, chemical and
biological stressors, including those typical in
aquaculture (Barton, 2002; Conte, 2004; FSBI,
2002; Wendelaar Bonga, 1997).
Stress responses are useful as indicators of the
impairment of the normal welfare conditions
because they represent a natural reaction to
adverse environmental conditions.
Notwithstanding, physiological responses to
stress are not necessarily indicative of suffering
or of compromised welfare (Huntingford et al.,
2006). Stress and its associated responses must
be regarded, first and foremost, as an adaptive
condition of the organism that has the
fundamental function of preserving life.
The welfare indicators of farmed fish selected
for Regulation (EC) No 889/2008 include “fin
damage, other injuries, growth rate, behaviour
expressed, overall health and the water
quality” (Article 25f.2). All these are among the
most common indicators (see table below)
used to assess impairment of each one of the
Five Freedoms (FAWC, 1979), which have
become an accepted framework for evaluating
suffering of land-based animals and farmed fish
(Ellis et al., 2002). The framework recognises
that animal welfare is complex, reflected in
many physiological and behavioural traits, and
therefore that combining different indicators
offers a much more useful assessment than
relying on a single indicator (FSBI, 2002).

1
This is an extended version of the article published in the IFOAM EU Group dossier: “Organic Aquaculture. EU
Regulations (EC) 834/2007, (EC) 889/2008, (EC) 710/2009. BACKGROUND, ASSESSMENT, INTERPRETATION.”
Whole publication is available at: http://www.ifoam-eu.org/positions/publications/aquaculture/.
Table: The Five Freedoms of Animal Welfare (FAWC, 1979) and the indicators used to assess welfare
impairment (Fish Welfare, 2009).

Five Freedoms of Animal Indicators

Welfare
1 Freedom from hunger and thirst
2 Freedom from discomfort
3 Freedom from pain, injury or
disease
4 Freedom to express normal
behaviour
5 Freedom from fear and distress
Feed intake, growth rates, condition factor
 Physical damage: fin condition, cataracts, lesions
 Immune responses (e.g. lysozyme activity, respiratory
burst activity, phagocytic activity)
 Environmental monitoring: water quality monitoring
(dissolved oxygen, ammonia, pH, carbon dioxide,
suspended solids)
 Targeted sampling of fish: gill condition and checking for
parasite infestation
Abnormal behaviour: swimming and feeding behaviour,
distribution of the fish within a system (eg. clumping around
inflows), response of fish to an approaching farmer
Measuring primary and secondary stress responses: plasma,
cortisol, glucose, lactate, muscular activity

Water quality and environmental conditions Feeding and food quality

Water is the medium in which farmed fish have
to meet both their physiological and spatial
needs. Changes in water parameters, over
acceptable ranges, can reduce growth and
cause stress that increases the incidence of
disease, which is detrimental for fish welfare
and might even be lethal. Water quality could
be influenced by different factors such as the
production system, rearing densities and the
amount and quality of food. Water quality
refers to chemical parameters such as
concentrations of dissolved oxygen, carbon
dioxide, un-ionized ammonia nitrogen, nitrite-
nitrogen, alkalinity and calcium hardness
(Conte, 2004). Nitrate concentration, pH and
chloride levels are also important.
Theoretically, increasing rearing density will
decrease water quality because of the oxygen
consumption, metabolite accumulation and the
increased amount of suspended solids (Ellis et
al., 2002). The latter are caused by the greater
faecal production and the increased fish
movement. Thus, the presence of faeces and
food waste are probably the most critical
aspects of the environment for fish welfare
(Ellis et al., 2002).
Inappropriate composition and timing of
feeding regimes could cause the impairment of
fish welfare. Feed distribution in a small area
could generate competition and increased
aggression among fish that in turn could lead to
growth variations reinforcing dominance
hierarchies (Stevenson, 2007). Aggression can
cause injury in farmed fish, especially when
competition for food is strong (Greaves et al.,
2001). Feed composition too is important for
preserving welfare. Diets lacking in critical
micronutrients impair welfare, causing
morphological abnormalities, poor immune
function, abnormal behaviour and slow growth
(Huntingford et al., 2006). Insufficient levels of
high polyunsaturated fatty acids have a
negative impact on the immune system and
reproductive functions (Poli, 2009), and
therefore fish meal and oil are considered
essential components of feed used in
aquaculture. The problem is that feeding wild
fish to farmed fish puts wild fisheries under
unsustainable pressure (Lymbery, 2002). For
this reason plant protein and oil have been
used to partially replace fish meal and oil, but
over a certain level in the diet, plant sources
often show anti-nutritional factors and/or
unsuitable content of amino acids and essential
fatty acids that could impair fish welfare. The
levels of vitamins, trace minerals and
antioxidants also play a crucial role in the
functioning of the immune system and the
capability of fish to response to stressful
aquaculture events (Ashley, 2007).
The specific rules on feeds for carnivorous
animals in the organic aquaculture
implementing rules give first priority to the
sustainable exploitation of fisheries, using
ingredients of fish origin derived from
trimmings of fish. Other considerations include
“animal health, high product quality, including
the nutritional composition, which shall ensure
high quality of the final edible product, and low
environmental impact” (Article 25j). However,
fish meal exclusively derived from trimmings is
rather poor of amino acids and essential fatty
acids, as well as produces a greater catabolites
accumulation. The most challenging problem is,
therefore, to identify the proportion of
trimmings which achieves the optimum trade-
off between, the high quality of the final
consumer product, a low environmental impact
and the sustainable exploitation of fisheries.
Stocking density
Fish live and move in a three-dimensional
medium that is vital for both their survival and
the expression of their full range of natural
behaviours; this makes the concept of
minimum space for fish more complex than for
terrestrial animals. Furthermore, among fish,
there are many interspecific differences in
space needs and tolerance of stocking density.
In general, high density conditions may
increase swimming activity and behavioural
interactions between fish, leading to a rise in
energetic expenditures up to levels that could
be detrimental for physiological processes.
Particularly, higher swimming activity can result
in a higher use of the anaerobic metabolism,
which represents reserve energy used in a
situation of stress (Lembo et al., 2007). Less
availability of this reserve might cause reduced
ability of the fish to react to other stresses in
their environment (Carbonara et al., 2008).
Phenomena generally associated with high
density (including decreased growth, poor
nutritional status, increased food conversion
rate, fin erosion and mortality) are caused by
both behaviour (increased competition,
aggression, physical injury and cannibalism) and
water quality deterioration (Ellis et al., 2001).
Indeed, density-related problems are often
associated with intensive cultures when water
supply, aeration or oxygenation systems fail.
Hence, it can be understood that stocking
density is an important factor for fish welfare,
but cannot be considered in isolation from
other environmental factors.
Dealing with this last consideration, Regulation
(EC) No 889/2008 states that stocking density
should be set according to species or species
group and the effects of stocking density on the
welfare of farmed fish are monitored
considering both the condition of the fish and
the water quality (Article 25f.2). The stocking
densities indicated in Annex XIIIa represent an
attempt to balance consideration for welfare,
high quality and profitability. If duly justified, a
possible revision of these limits might be
introduced after July 2013, depending on on-
farm experiences.
Disease and parasites
Wild fish have evolved behavioural patterns to
avoid or to limit exposure to infective parasites,
such as escaping habitats with high parasite
densities and rejecting potential sexual
partners with directly detectable infections.
Fish reared in captivity cannot express these
behaviours (Barber, 2007). When fish live in
poor welfare conditions, stress events reduce
their ability to fight disease. Indeed, various
severe health problems are associated with
intensive fish farming, such as cataracts, post-
immunisation peritonitis, skeletal deformities,
soft tissue malformations, viral disease and
wound or skin ulcers (Poppe et al., 2002). The
occurrence of these conditions in aquaculture
may impact the ability of fish to undertake
normal respiration, feeding and reproductive
behaviours, also resulting in poor production
performances (Ersdal et al., 2001). The actual
incidence of several diseases that had been a
major problem in aquaculture in the recent
past has been, to some extent, reduced by the
employment of vaccination practices, although
such measures have also been shown to be
stressful for fish (Ashley, 2007). Further
improvement of welfare standards can
conceivably be achieved through more
investigation into the effects of handling,
transport, and feeding on stress physiology;
research on the effects of interactions between
environmental, physiological and behavioural
parameters; and studies at production scale,
which would put laboratory findings into an
industry context.
Regulation (EC) No 889/2008 states that animal
health management should be primarily based
on the prevention of disease. But when, despite
this, health problems arise, veterinary
treatments may be used with a limit of two
courses of allopathic treatment per year or, in
the cases of a production cycle of less than a
year (i.e. invertebrates), with a limit of one
treatment. In this last point there is the sole
significant difference with the IFOAM basic
standards, which state a prohibition of any
treatment for invertebrates.
Pre-slaughter and slaughter
An optimal slaughter method should render
fish unconscious until death, without avoidable
excitement, pain or suffering prior to killing.
Welfare evaluation at time of slaughter is
difficult to measure because it requires a
multidisciplinary approach examining various
indicators such as brain functions, endocrine
responses, behaviour, and post-mortem tissue
biochemical condition (Poli et al., 2005).
Behaviour can be a good and non-invasive
indicator of fish welfare at the time of
slaughter, because it rapidly responds to
environmental changes. The most frequent
behavioural observations are related to the
strength and the persistence of the swimming
motility and gill ventilation. However,
observation of behaviour alone cannot be an
exhaustive indicator as it does not allow for the
assessment of unconscious fish pre-slaughter
(van de Vis et al., 2003). While it is understood
that fish should be unconscious at the moment
of slaughter, it is important to study slaughter
methods for occasions when the instantaneous
induction of insensibility is not possible (Poli,
2009). Furthermore, the biochemistry of the
muscle post-mortem and the onset of rigor are
influenced by the method used in pre-slaughter
handling, stunning and killing of fish (EFSA,
2009; Lowe et al., 1993) which, in turn, can
compromise the organoleptic qualities and
marketability of the final product.
Regulation (EC) No 889/2008 affirms that
slaughter techniques should render fish
immediately unconscious and insensible to
pain, but does not provide specific indication of
the most suitable techniques. This might result
in different application of the principle in
different countries. In any case, scientific and
technological understanding in this field should
be further expanded, particularly in an on-farm
context.
Conclusions
Just as do other animals, fish require proper
consideration for their welfare in management,
and this is reflected both in the organic
principles and in European regulations. To this
purpose, organic fish farming procedures
should consider, as a priority, how to minimise
unnecessary stress and keep under control the
whole life cycle of farmed fish. The
improvement of rearing conditions will benefit
fish welfare as well as aquaculture profitability.
Welfare concerns are interconnected: water
quality, stocking density, feeding, nutritional
condition and management procedures all have
a direct effect on fish stress levels, subsequent
stress tolerance, health and overall welfare, so
care for the whole requires conscientious
attention to each individual part.
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