AFS Fish Culture Section
Summer 2010
Fish Culture Section of the American Fisheries Society PRESIDENT’S MESSAGE Inside this issue: Workshops…..3-4 MTS Journal..5-6 Alligator Gar….7 Fish News......8-9 Policy Statement
……....11-12 FCS Meeting ..12 FDA Boilerplates
…...….14-23
BY
JESSE TRUSHENSKI
Howdy, fish culturists! As I sit down to write this issue’s President’s Message, I realize, with mixed feelings, the 2010 AFS meeting in Pittsburgh is just around the corner. On the one hand, I’m really looking forward to the trip…bragging just a little about our Section and the good work we’ve done together over the past year, watching my students give the presentations they’ve been tweaking and practicing, sitting in on the FCS‐ sponsored symposium on American Shad and river herring restoration (the largest symposium at the meeting— nicely done, Programming Chair Jim Bowker!), and seeing good friends during and after the meeting. On the other hand…well, I’ve got a lot of work to do between now and then! And that, dear FCSers, is why I’m asking for your help.
So calling all students and teachers, employees and employers, inlaws and outlaws—what are we doing well to educate our future fish culturists, and what can we be doing better?
This year, the AFS Governing Board has turned its attention to fisheries education, and I have been asked to give a presentation at this year’s retreat to discuss the state of education opportunities for fish culturists. Even over my short career as an educator, I have seen changes to academic programs in aquaculture. While a few programs are growing, more are contracting with retirements and budget cuts. As administrators and bean counters pick up their carving knives, pieces of aquaculture training programs are carved away and tossed into the gaping maw of budget shortfalls and efforts to create new programs in emerging fields. Of those programs that remain, there is great variation in training and what constitutes the ‘core competencies.’ Obviously, every educator and institution is going to have its own focus—catfish are going to get more playing time than salmonids down on the Mississippi Delta and vice versa out in the Pacific Northwest. But aren’t there basic husbandry skills that every culturist should have? Are far as I’m concerned, nobody should leave the Fisheries and Illinois Aquaculture Center (Continued on page 2)
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President’s Message (continued)
While you’re on our fancy new Facebook site, do a little exploring and add to the page—it’s there as a forum for our membership, so make your mark.
without learning about water chemistry, feed management, disease diagnostics, and the basics of tank vs. pond culture. Hopefully they pick up a few other tips and tricks along the way. But that’s just one person’s opinion—the other day, I was skimming the most recent edition of a popular aquaculture textbook, and found that of the 31 chapters, none were dedicated to water quality. That this most basic and crucial tenet of fish culture had been overlooked in an introductory text got me thinking. What were other educators leaving out? What was I leaving out? And what do our students—and their employers—wish that they are learned before they left our classrooms? If we are concerned with the next generation of fish culturists and making sure they are ready to meet the modern challenge of raising more with fewer resources—I don’t know about you, but I’d like to be able to retire at some point in the distant future—this is a dialogue that we need to start. So calling all students and teachers, employees and employers, inlaws and outlaws—what are we doing well to educate our future fish culturists, and what can we be doing better? Drop me a line at
[email protected] or better yet, join the discussion on our new Facebook page . While you’re on our fancy new Facebook site, do a little exploring and add to the page—it’s there as a forum for our membership, so make your mark. Upload some photos, add some links, add your comments to ongoing discussions. And tell a friend! I’m happy to report that Jim Bowker, Steve Cooke, Dave Erdahl, Tom Bell, Randy MacMillan, Roy Yanong, Jeff Hill, Mary Fabrizio, Chris Guy, Jim Garvey, Steve Sharon, and I have finished drafting an “AFS Policy Statement Regarding the Need
f o r a n I m m e d i a t e ‐ R e l e a s e Anesthetic/Sedative for Use in the Fisheries Disciplines.” As you’ll recall, we began writing this document to outline the inadequacy of current sedative/anesthetic options for fisheries and the consequences of not having access to an approved compound for immediate release. Our goal in writing this document was to create a sound, science‐based argument for the approval of one of the candidate immediate‐release sedatives (benzocaine or eugenol) in an expedient manner. Currently, the draft is being reviewed by the AFS Resource Policy Committee, and will likely come before the entire AFS membership for review later this Fall. But as privileged FCS members, you don’t have to wait that long—the draft Policy Statement Executive Summary is available right now on pages 11‐12 of this newsletter. Read the document, and provide your feedback at—yup, you guessed it—the discussions page on our Facebook site! Log on today and let us know what you think. Upon further reflection, I don’t have mixed feelings about the meeting in Pittsburgh—it’s going to be a busy meeting, but I can’t wait to go and fly the FCS flag high. Hope to see you at the FCS Business Meeting from 4:30‐6:30 on Sunday, Sept 12th (Westin)! Best, Jesse Trushenski
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2010 WDAFS Student Colloquium The Palouse student subunit of the American Fisheries Society at the University of Idaho is proud to host the 3rd Annual Western Division of the American Fisheries Society Student Colloquium from Thursday, October 14th to Saturday, October 16th. Moscow, ID will be the site of research presentations, an insightful field trip, and networking in an all-student environment. Thursday, October 14th: Welcome Social featuring food and drinks at the 1912 Center in Moscow, ID, from 6-9 pm. Professionals will be invited to enhance your networking opportunities. Friday, October 15th: A full day jet boat tour of Hell’s Canyon. Transportation, breakfast and lunch will be covered. Saturday, October 16th: Student only oral presentations at the University of Idaho followed by a tour of the campus aquaculture facilities. A business lunch will be provided. Closing social will be held from 6-9 p.m. at EcoAnalysts, Inc. and will include food and beverages. Sunday, October 17th (Optional): Opportunity to fly fish for Steelhead. You will need to bring your own gear and purchase an Idaho fishing license. Our experts can take you to some of the best fishing spots in the area. For more details, contact Tim Caldwell (
[email protected]) Registration: To register, please email Jeff Reader (
[email protected]) the following information: Name, phone number, AFS/School affiliation, when you will be arriving and departing, and whether you are presenting. Cost: $35/student before Friday, September 24h, and $45/person after September 25th. Presentations: If you are presenting (everyone is encouraged to present!), please submit a 200 word abstract by Friday, October 2nd to Amy Long (
[email protected]). Abstract formatting guidelines are posted on our website. We look forward to seeing everyone in Moscow! --University of Idaho Palouse student subunit of AFS Questions? Contact Kelly Stockton at
[email protected] or at 970-217-2245 Visit PUAFS online at http://www.cnr.uidaho.edu/afs/
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MTS Journal MTS Store Marine Technology Society
MTS Journal Looks at Marine Aquaculture Technology and Issues in the U.S. "With earth’s burgeoning human population to feed we must turn to the sea with understanding and new technology. We need to farm it as we farm the land." --Jacques Cousteau
What is the state of technology for open ocean fish farming? How are U.S. policies and programs helping or hindering the inevitable movement toward sustainable aquaculture in the open ocean? These and a host of other questions are addressed in the May/June issue of the Marine Technology Society Journal, Vol. 44, No. 3. Edited by John S. Corbin, President of Aquaculture Planning and Advocacy LLC and former Manager of the Hawaii Aquaculture Development Program, this timely issue gives historical perspective, describes the current state of affairs, and unveils the technologies of the future. Here are brief overviews of the peer-reviewed papers:
Sustainable U.S. Marine Aquaculture Expansion, A Nece ssity - In his overview, John Corbin sets the stage for this special issue by providing detailed background information on U.S. seafood consumption, supply, and projected needs. He looks at the potential for future disruption of seafood imports and reviews the status and potential for the development of the expansive and diverse U.S. Exclusive Economic Zone. Site Selection Criteria for Open Ocean Aquaculture - Daniel Benetti, of the University of Miami, and his coauthors focus on site selection criteria for open ocean aquaculture, not only practical considerations like ocean conditions, materials and manpower, but also socioeconomic and political issues. Among other things, they address lessons that aquaculture operations can learn from the Deepwater Horizon oil spill in the Gulf of Mexico. A Ca se Study of an Offshore SeaStation Sea Farm - Gary Loverich discusses the SeaStation cage his company , Ocean Spar LLC, has been developing since 1994, presenting a review of a large commercial cage system operating off Keahole Point, Kona, Hawaii. His paper describes the features that make the cages unique, as well as the challenges that arise when multiple cages are deployed to grow fish at commercial scale . Technology Needs for Improved Efficiency of Open Ocean Cage Culture - Richard Langan, University of New Hampshire, explores the status of aquaculture support systems capable of autonomous operation in the open ocean. Successful farming will require nec essary tasks, such as feeding, maintenance, and observation of stock and the environment to be carried out routinely, even when harsh conditions may keep vessels and personnel on shore. Shellfish Culture in the Open Ocean: Lessons Learned for Offshore Expansion - Daniel Cheney, of the Pacific Shellfish Institute, joins his fellow authors for a look at the state of the art, as well as future prospects and challenges, in shellfish aquaculture, providing three case examples to illustrate the extent and types of open ocean shellfish farming underway. What Can U.S. Open Ocean Aquaculture Learn from Salmon Farming? - The U.S. imported 83% of its seafood needs in 2008. In this paper, John Forster, of Forster Consulting, Inc., explores the history of farmed salmon, which he has been involved with since the late 1960s. He discusses why other countries have been successful and the lessons for the U.S., noting that for open ocean aquaculture to succeed, containment systems must be easily deployed and operated, and governments must create space in their coastal waters.
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Deep Ocean Water Resource s in the 21st Century - Brandon Yoza, University of Hawaii, and his co-authors from Norway, Japan and Hawaii, discuss some cutting edge, large-scale concepts for using deep ocean water for energy generation and offshore aquaculture. They explain how “artificial upwelling”--bringing deep ocean water to the surface mechanically--could enhanc e the ocean food web and restore depleted marine life at all trophic levels. Sustainable Ecological Aquaculture Systems: The Need for a New Social Contract for Aquaculture Development - Barry Costa-Pierc e, University of Rhode Island, describes ecological aquaculture, an emerging, new paradigm for global aquac ulture planning, policy, and development. He argues that policymakers should consider this approach to foster environmentally, economically, and socially responsible aquacult ure. Marine Stock Enhancement, a Valuable Extension of Expanded U.S. Marine Aquaculture Guest editor John Corbin provides a brief comment ary on the history and current status of U.S. marine stock enhanc ement as a valuable tool for coastal fisheries managem ent. He discusses the need for increased research funding, greater infrastructure planning and development, and inclusion of marine stock enhancement in current national oc ean policy and marine spatial planning efforts. U.S. Open Ocean Fish Farming: Are We There Yet? - Randy Cates, of Cates International, Inc., and Hukilau Foods LLC, provides a commercial, offs hore fish farmer's hard-won insights into the state of the technology as well as the status of emerging federal support policies and programs. From his perspective of 10 years of research and commercial experienc e, Cates discusses research needs for open ocean fish farming and highlights areas for innovation that could help successfully establish commercial farming in the U.S. Exclusive Economic Zone.
To Get Your Copy of Thi s I ssue Purchase Vol. 44, No. 3 of the MTS Journal through the MTS Store. or by calling (410) 884-5330 during business hours on the East Coast.
QUESTIONS? Please e-mail or call Susan Branting or Suzanne Voelker at (410) 884-5330. The Marine Technology Society is a 501(c )(3) not -for-profit professional society comprising oc ean engineers, technologists, policy makers and educators. Incorporated in 1963, it provides the oc ean community with forums for the exchange of information and ideas through its peer-reviewed MTS Journal, conferences, newsletters and website (www.mtsociety.org).
Contributions to the Hall of Fame endowment can be made out to the Fish Culture Section and sent directly to the South Dakota Community Foundation 207 East Capitol - Box 296 Pierre, SD 57501
Each donor, regardless of size, will receive a receipt in letter form that the contribution is tax deductible.
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Alligator Gar Who Do You Think You Are? —Justin Wilkens The Mississippi Department of Wildlife, Fisheries and Parks (MDWFP), North Mississippi Fish Hatchery (NMFH), in cooperation with the U.S. Fish and Wildlife Service (USFWS), Private John Allen National Fish Hatchery, produce alligator gar in Mississippi. Alligator gar native to the Mississippi River Basin are collected by the USFWS to be used as broodstock. The fish are transferred to their hatchery where they are stocked into tanks supplied with temperature controlled water. The male and female fish each receives a hormone injection to induce spawning. The eggs are collected by manually spawning the fish or by letting the fish tank spawn. A female weighing over 100 lb may have several hundred thousand eggs. After hatch out a portion of the young gar are transferred to NMFH where they are stocked into a raceway and trained to accept a formulated diet. After 90‐120 days the fish have grown to 8‐10 inches. Before stocking each fish receives a coded micro wire tag supplied by the USFWS. When or if the fish is collected later, the tag can be removed and read. By monitoring stocked populations biologists can determine the ability of hatchery fish to survive after released and fill in the missing information about the alligator gar’s life history.
In Mississippi, alligator gar occurs in coastal drainages including the Pascagoula and Pearl River drainages. It also occurs in the Yazoo River drainage of the Mississippi River Basin. The alligator gar is now very rare or does not occur in the northern part of their range north of the coastal drainages. Anecdotal evidence suggests that populations are self sustaining in coastal drainages but have also declined over time. The alligator gar is listed by the state of Mississippi and the American Fisheries Society as a species of “Special Concern”. The Mississippi Comprehensive Wildlife Conservation Plan lists the alligator gar as a species of greatest conservation need. Like other states throughout the gar’s native range MDWFP recognizes the need to conserve and augment declining populations of alligator gar in historical habitat. A management plan is currently being written to help provide direction for future actions.
Justin Wilkens is the hatchery manager at North Mississippi Fish Hatchery and can be reached via email (
[email protected]) for more information regarding this story. The photo was taken by Laura Dobbins, office assistant, Pvt. John Allen NFH.
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CHICAGO – July 13, 2010. Governor Pat Quinn today announced a new initiative to stop the spread of invasive Asian carp species into the Great Lakes. Illinois is entering into a public‐private partnership that will reduce Asian carp populations where they have been discovered in Illinois waters. This first‐of‐ its‐kind partnership will help enhance the commercial fishing industry, create approximately 180 jobs and relieve pressure on the U.S. Army Corps of Engineers Electric Barrier System designed to stop fish from moving further towards Lake Michigan. “Protecting the Great Lakes is vital to millions of people from Illinois and throughout the Midwest who rely on these waterways for their livelihoods,” said Governor Quinn. “Today’s agreement is one of the most aggressive efforts to address the Asian carp problem, and is a critical step to long‐term economic sustainability and the success of the commercial fishing industry.” Illinois is entering into an agreement with Chinese meat processing company Beijing Zhuochen Animal Husbandry Company and Big River Fisheries located in Pearl, Ill. to harvest 30 million pounds of carp from Illinois rivers. Big River will process, package and ship the fish to Zhuochen for resale in international markets where the fish is a delicacy. The company is expected to harvest at least 30 million pounds of fish for the purpose of this agreement by the end of 2011. The state, through the Illinois Department of
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Commerce and Economic Opportunity, will invest $2 million in capital funds to help Big River retrofit its existing facility, increase its processing capacity and expand to new production facilities in Pittsfield, which will create 61 new jobs and 120 indirect jobs. Commercial fishermen, contracted by the Illinois Department of Natural Resources, have already started removing Asian carp in the Illinois River where populations exist. “The high quality and taste of the wild Asian carp from Big River Fish far exceeded our expectations. We see a tremendous market in China for the wild Asian carp,” said Mr. Liang Chang, Chairman, Beijing Zhuochen Animal Husbandry. “As Big River Fish's production capacity increases, we will be able to expand our marketing efforts in China.” “Big River Fish can now retrofit and expand its facilities to meet our production commitment to Zhuochen,” said Mr. Rick Smith, President, Big River Fish Corp. “The Asian carp can become an economic engine for Illinois rather than a threat, and we thank Governor Quinn for his support of our efforts.” Today’s announcement builds on the state’s existing efforts to stop the spread of Asian carp. The Illinois Department of Natural Resources, in conjunction with the Asian Carp Regional Coordinating Committee (ACRCC), has established an Asian Carp Control Strategy Framework, which includes both short‐ and long‐term actions intended to keep Asian (Continued on page 9)
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carp from establishing populations in the Great Lakes. These measures include: • Operations to reduce propagule pressure on barriers • Increased fish collection efforts and population suppression • Evaluation of current suppression tools, as well as future fish suppression activities • Emergency measures to prevent bypass of fish between the Des Plaines River and the Chicago Sanitary and Ship Canal (CSSC), as well as between the Illinois &Michigan Canal and the CSSC during flood events • Increased biological control efforts
• Construction of a third electric barrier To view the entire control framework, or to learn more about the efforts of the ACRCC, visit www.asiancarp.org. In June, a Bighead Asian carp was found in Lake Calumet along the Chicago Area Waterway System (CAWS). This is the first physical specimen that has been found in the CAWS above the Electric Barrier System. Since the find, Illinois along with the U.S. Fish and Wildlife Service and commercial fishermen have intensely sampled both Lake Calumet and the Calumet River leading to Lake Michigan. No other Asian carp have been found in the Chicago area waterway system to date.
Photo credit: USFWS
GENETICALLY ALTERED SALMON MOVING CLOSER TO MARKET Source: www.thefishsite.com
June 30, 2010
US ‐ The Food and Drug Administration (FDA) is seriously considering whether to approve the first genetically engineered animal that people would eat: salmon that can grow at twice the normal rate.
weather. But the pout’s on‐switch keeps production of the hormone going year round. The result is salmon that can grow to market size in 16 to 18 months instead of three years, though the company says the modified salmon will not end up any bigger than a conventional The developer of the salmon has been trying to get approval fish. for a decade, but the company now seems to have submitted most or all of the data the FDA needs to analyse “You don’t get salmon the size of the Hindenburg,” said whether the salmon are safe to eat, nutritionally equivalent Ronald L. Stotish, the chief executive of AquaBounty. to other salmon and safe for the environment, according to “You can get to those target weights in a shorter time” government and biotechnology industry officials. he said, adding that the benefit of the fast‐growing salmon would be to help supply the world’s food needs A public meeting to discuss the salmon may be held as early using fewer resources. as this fall. AquaBounty told The New York Times last week, that According to The New York Times, some consumer and the FDA had signed off on five of the seven sets of data environmental groups are likely to raise objections to required to demonstrate that the fish was safe for approval. Even within the FDA, there has been a debate consumption and for the environment. It said it about whether the salmon should be labelled as genetically demonstrated, for instance, that the inserted gene did engineered (genetically engineered crops are not labelled). not change through multiple generations and that the The salmon was developed by the company AquaBounty genetic engineering did not harm the animals. Technologies and would be raised in fish farms. It is an “Perhaps in the next few months, we expect to see a Atlantic salmon that contains a growth hormone gene from a final approval,” Mr Stotish said. Chinook salmon as well as a genetic on‐switch from the However, he said it would take two or three years after ocean pout, a distant relative of the salmon. approval for the salmon to reach supermarkets. Normally, salmon do not make growth hormone in cold
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Don’t miss out on all that’s going on within the FCS, attend the ANNUAL BUSINESS MEETING!
—-and visit us on FACEBOOK!!
September 12, 2010 4:30-6:00 Allegheny 3 (Westin) Pittsburg, PA
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http://www.fisheries.org/afs10/index.php
http://www.midwest2010.org/index.php
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Public Comment Period Open for Veterinary Feed Directive (VFD) Regulations Help Streamline Regulation of VFD Drug Use in Aquaculture The U. S. Food and Drug Administration’s (FDA) Veterinary Feed Directive (VFD) regulations established requirements relating to the distribution and use of VFD drugs and animal feeds containing such drugs. There is currently one VFD drug in aquaculture, specifically Aquaflor® (florfenicol), which is approved for use in catfish and freshwater-reared salmonids to control mortality due to several diseases. VFD drugs are approved for use in animal feed only if these medicated feeds are administered under a veterinarian’s order and professional oversight. FDA has received a number of informal comments that characterize the current mechanism of accessing and using VFD drugs as being overly burdensome. There is also concern that the procedures for accessing and using VFD drugs will become increasingly problematic as the number of approved VFD drugs increases. Currently, the FDA is undertaking a review of their current VFD regulations in an effort to identify possible changes to the regulations to improve efficiency, and is requesting public comments on all aspects of the VFD regulations. This is your opportunity as a fish culturist to have your voice heard, and to help streamline regulation of VFD drug use in the future. Below is a series of comments on current VFD regulations which have been developed by the Fish Culture Section Working Group on Aquaculture Drugs, Chemicals, and Biologics (WGADCB). Co-chaired by representatives from industry, academia, and federal and state agencies, the mission of the WGADCB is “to enhance the health and production of aquatic animals cultured in the United States through support of the development, and safe and legal use of aquaculture drugs, chemicals and biologics.” To this end, the WGADCB co-chairs will be providing these comments to the FDA. Additionally, the WGADCB is making their comments available as ‘boiler-plate’ text which can be modified or used directly by any individuals or groups in providing their own comments to FDA. If you agree with what is outlined below, please join us in providing FDA with this important feedback. There are several ways to submit your comments to FDA: Electronic comments can be submitted via the Federal eRulemaking Portal. Go to http://www.regulations.gov and follow the instructions for submitting comments. Written submissions can be faxed (301-827-6870) or mailed (for paper, disk, or CD-ROM submissions) to the Division of Dockets Management (HFA-305), Food and Drug Administration, 5630 Fishers Lane, Room 1061, Rockville, MD 20852
All submissions received must include the agency name (U.S. Food and Drug Administration) and docket number for this rule making (FDA-2010-N-0155).
Provide FDA with your comments by August 26th, 2010!
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Comments regarding Veterinary Feed Directive regulations submitted to the U. S. Food and Drug Administration by: Fish Culture Section of the American Fisheries Society, Working Group on Aquaculture Drugs, Chemicals, and Biologics 21CFR Parts 510, 514, and 558 Docket No. FDA-2010-N-0155 The U. S. Food and Drug Administration’s (FDA) Veterinary Feed Directive (VFD), which became effective in January, 2001, established requirements relating to the distribution and use of VFD drugs and animal feeds containing such drugs. FDA is undertaking a review of these requirements in an effort to identify possible changes to improve efficiency, and is requesting public comments on all aspects of the VFD regulations. FDA reaffirmed that certain new animal drugs should be approved for use in animal feed only if these medicated feeds are administered under a veterinarian’s order and professional oversight. Veterinary oversight is important for assuring the safe and appropriate use of certain new animal drugs. FDA has received a number of informal comments that characterize the current mechanism of accessing and using VFD drugs as being overly burdensome. Additionally, there are concerns that the process, in its current form, will become increasingly problematic to administer in the future as the number of approved VFD drugs increases. Comments are to be organized by the major categories listed below. Comments on issues outside one of the categories listed below are to be categorized as G. “Other” A. Conditions that must be met by veterinarians issuing a VFD a. A provision should be made to allow broad discretion for veterinarians to allow use of a VFD drug over an extended period of time at large facilities with many fish rearing units (e.g., provide more leeway in the Date of Treatment, and, if different, date of prescribing the VFD drug; or Number of refills (reorders) if necessary and permitted by the approval). i. Hatcheries that rear fish for stock enhancement may have fewer than 100 fish rearing units. On the other hand, large commercial hatcheries may have several hundred fish rearing units. In either case, some flexibility would allow the veterinarian to write one VFD order to cover the facility in the event the disease event occurs in successive rearing units. At many hatcheries, one rearing unit of sick fish is often an indication that other rearing units of fish will soon become sick from the same pathogen. Such a provision might allow use of a VFD drug (e.g., AQUAFLOR®) on fish at a facility for the duration of the disease period once the disease for which it is approved (e.g., furunculosis in freshwater-reared salmonids) is diagnosed. There might also be a greater possibility of creating antibiotic resistance as the delay would most likely increase the probability of sub-optimal doses. Appropriate diagnosis of the disease in each rearing unit would of course need to be made. ii. Involvement of a veterinarian increases the time to get VFD-medicated feed shipped by 24 – 48 hrs. Relatively few aquaculture programs have the luxury of having a veterinarian who is a practicing fish health biologist on staff and is available to expedite this process. It is our belief that in many cases, the veterinarian comes from a large animal practice and is acting as a third party; even in the context of a valid veterinarian-patient-client relationship, wherein the veterinarian is actively engaged in the diagnostic process, the fish health biologist will likely have had more training and practical experience related to fish diseases. Hence, in practice the fish health biologist often performs the diagnosis, and based on their experience at the hatchery, provides the appropriate treatment recommendation to a veterinarian. The veterinarian is then required to verify (Continued on page 16)
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this information, complete the paperwork, and provide the paperwork to the feed mill hatchery staff, and then hatchery staff can then order the feed. The delay from diagnosis to shipment of VFD -medicated feeds has decreased as those involved become more familiar with the process, but there is still a delay. Rather than face a delay to deliver the antibiotic delivered through a VFD perhaps of several days and watch fish die, a fish culturist often may use a less effective antibiotic that is approved as an “over-the-counter” drug. Ultimately this approach may result in greater mortalities if the over-the-counter antibiotic treatment is ineffective. Not only would there be greater mortalities, but application of an ineffective antibiotic needlessly increases the potential, however small, for antimicrobial resistance to develop. b. Extra-label use of a VFD drug should be permitted. Such use is strictly prohibited under current regulation. At present, AQUAFLOR®, the first new antibiotic approved for use in fish in 20 years, is the only VFD drug approved by FDA. The sponsor (Intervet/Schering Plough) and many fish health biologists and veterinarians think it likely that this product is effective for non-labeled uses (i.e., this drug is being used under an INAD and the information suggests that it is effective in controlling mortality caused by other pathogens in other fish species). A veterinarian should be able to write a “prescription” for extra-label use to allow VFD products to be used more broadly when available information suggests it would be effective (e.g., from peer-reviewed literature, grey literature, and INAD data). As presently applied, the VFD regulations put veterinarians at a disadvantage as they strive to provide adequate animal care to fish. This is particularly the case because approved treatment options for fish, which is considered a minor species, are currently very limited. While the objectives of the VFD process are laudable, present application of these regulations to only one drug that is only applied to a minor species gives the regulation the appearance of an impediment to the aquaculture industry rather than a mechanism to extend the effective life of the drug, reduce antimicrobial resistance, and promote human health. i. This approach is an extension of the discretion currently given to veterinarians who may prescribe non-VFD drugs for extra-label use. The latitude granted to veterinarians for prescribing drugs for extra-label use, including use of drugs in feed, is based on their knowledge and experience of diagnosing and treating diseases; it is not based on the specific nature of the drugs or the application method. B. What must I do with the VFD if I am a veterinarian?
a. No comments C. What are the VFD recordkeeping requirements?
a. No comments D. What are the notification requirements if I am a distributor of animal feed containing a VFD drug? a. Excluding the catfish industry, virtually all fish culturists/fish health biologists complain that they can’t get VFD-medicated feed (i.e., AQUAFLOR®) in small batch sizes or in a timely manner. Often the feed mill will not have AQUAFLOR®-medicated feed in various feed sizes in stock. Establishment of informal (i.e., intra-agency) VFD drug distribution centers has helped to alleviate this situation. Such centers can “stockpile” bags of medicated feed in various sizes and provide such feed to fish culturists upon receipt of a VFD form from the veterinarian. i. FDA should take a proactive approach to help establish VFD distribution centers throughout the country. All such centers should be set up and operate in a consistent manner. ii. A provision should be established to allow the VFD distribution center to top-coat small batchers of feed (e.g., 1 – 5 bags of feed) in a manner similar to that allowed by a VFD feed mill. In addition to helping end-users gain access to the medicated feeds they need in a timely manner, this approach will also help to minimize the length of time a medicated feed is stored prior to use (“shelf-life”), which may be a concern in large distribution centers. iii. Virtually all studies conducted to evaluate the effectiveness and safety of VFD drugs for use in aquaculture have been conducted using top-coated feed. Furthermore, top-coating is recognized (Continued on page 17)
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as an effective procedure for applying other drugs to feed in aquaculture. E. What are the additional recordkeeping requirements if I am a distributor?
a. No comments F. What cautionary statements are required for VFD drugs and animal feeds containing VFD drugs? a. Such labeling is unnecessary because VFD drugs can’t be ordered or purchased without a VFD issued from a veterinarian. It’s redundant, and because this additional labeling is an added expense and logistical hurdle, it’s a disincentive to the sponsor. G. Other a. Make a provision to simplify the ordering process, and thereby minimizing delays in ordering and receiving VFD-medicated feed, by considering one or more of the following: i. Phone-in orders (after initial documentation has been provided by the veterinarian to the VFD licensed feed mill; perhaps a unique code would need to be proved by the feed mill to veterinarians wishing to order VFD medicated feed by phone. ii. Allow electronic signature so orders could be emailed. iii. Make a provision so that faxed copies could be acceptable VFD-medicated feed ordering documents. b. Allow veterinarians to dispense VFD drug premix to allow hatchery staff to top-coat feed for use (rather than purchase VFD-medicated feed from a feed mill or VFD medicated feed distributor). Dispensing VFD drug for top-coat would be done after VFD issuing paperwork has been completed by the veterinarian. c. For application in fish, a minor species, a provision should be established to allow the senior fish health biologist (or designee) responsible for a particular fish culture facility to recommend treatment and inform the veterinarian when treatment with a VFD drug should be initiated. Reasons for this recommendation include: i. There is a lack of qualified veterinarians with fish experience to ensure that a valid veterinarianpatient-client relationship can be established for every fish culture facility. The AVMA and FDA have recognized this need and have engaged in professional development and literacy campaigns to increase awareness of aquaculture among veterinarians and the public (http://fda.gov/download/AnimalVeterinary/ResourcesforYou/AnimalHealthLiteracy/UCM2141 89.pdf; http://www.avma.org/reference/jtua/aquatic_veterinarians_booklet.pdf), however, it is unlikely that these efforts will result in an increase in the number of veterinarians with relevant experience in fish diseases in the near future. ii. Historically, diagnosis of fish health issues in private and public aquaculture have been done by qualified fish health biologists. . Fish health labs are often equipped to perform fish necropsy, bacteriology, virology, parasitology, histology, and disease confirmation procedures ranging from classical morphometric and biochemical tests to advanced polymerase chain reaction and fluorescent antibody tests. Fish health staffs receive formal and informal training over their career to utilize appropriate methodologies to properly diagnose fish diseases and, if necessary, recommend appropriate therapeutic treatment. In most cases, senior fish health biologists are members of fish health sections of professional fisheries societies (e.g., American Fisheries Society, Fish Health Section) and follow procedures described in manuals such as the AFS Blue Book. Fish health biologists involved in fish culture are extremely familiar with the fish and potential disease conditions at facilities that fall under their responsibility and are often in a good position to guide the veterinarian with sound advice and access to facilities and equipment. iii. It is recommended that FDA review VFD regulations and acknowledge that a veterinarian relationship with aquaculture is vastly different than a veterinarian relationship with terrestrial animals, and that perhaps “one size does not fit all.” (Continued on page 18)
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iv. In most cases, only veterinarians employed by a state or federal agency (e.g., U. S. Fish and Wildlife Service Olympia Fish Health Lab, Idaho Department of Fish and Game Eagle Fish Health Lab), large tribal group (e.g, Northwest Indian Fish Commission, Olympia WA), or private contract lab (e.g., Washington Animal Disease Diagnostic Laboratory, Pullman WA) have the resources to perform fish health procedures described above. However, this does not preclude other veterinarians to develop partnerships with those with such resources. d. In many cases, veterinarians issuing a VFD rely on professional fish health biologists to diagnosis disease in fish. For fish, a minor species, FDA should allow the establishment of a valid veterinarian-fish health biologist relationship to allow rapid disease diagnosis and application of the VFD drug. e. Veterinarians cannot get VFD medicated feed orders filled in a timely manner. In some cases it takes 7 – 14 d to get the medicated from feeds in Canada (e.g., BioOregon). This is an unacceptable period of time. It often forces the veterinarian to tell the fish culturist to buy feed from a different feed mill (switching feed type administered to fish is not an advisable practice). The longer the fish culturist must wait for VFD issue feed to be delivered means more dead fish. Because fish often stop feeding as a disease progresses, the “window of opportunity” for a medicated feed to be effective is limited. If end users have to wait a protracted period of time, not only will more fish die while they wait, but the remaining fish may be “too far gone”, i.e., off feed, and the medicated feed will be useless. i. A provision should be made to allow feed to be top-coated with a VFD drug so that it can be made available to feed to sick fish in a timely manner. ii. Major fish losses can be avoided if FDA will consider allowing a VFD medicated feed distributorship, working closely with a veterinarian, to top-coat starter feeds in small aliquots. Doing so would allow the distributorship to have several sizes of small feed on-hand that could be top-coated and shipped to the hatchery in a timely manner. f. Typically, salmonids are treated when they are small (as opposed to catfish, which may be treated when they are near-market size, when disease outbreaks are more common in this industry) and very little medicated feed is required. This is particularly the case with coldwater disease, which typically affects small salmonids (including swim-up fry). Most feed mills make medicated feed in batches of 2,000 lbs and offer feed in 20-kg or 50-lb bags. In virtually all cases, more medicated feed is manufactured and purchased than is needed and a considerable amount will be discarded (either the feed mill or hatchery will “eat the cost” of discarding uneaten feed). Veterinarians should be allowed to issue a VFD which allows the fish culturist to use all the medicated feed purchased within a specified period of time (i.e., throughout the “disease season” of the disease for which the VFD was originally issued) under the initial VFD issued by the veterinarian.
Signatures Jesse Trushenski, WGADCB Co-chair Jim Bowker, WGADCB Co-chair Steve Sharon, WGADCB Co-chair John (Randy) MacMillan, WGADCB Co-chair Mark P. Gaikowski, WGADCB Co-chair
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Newsletter of the Fish Culture Section of the American Fisheries Society October 2009 President............................................Jesse Trushenski Immediate Past-President.................Curry Woods President-elect...................................Jim Bowker Secretary-Treasurer...........................Donna Muhm Committee Chairpersons (Standing): Auditing................................................................................Alan Johnson Hall of Fame.........................................................................Curry Woods Membership.........................................................................Jesse Trushenski Newsletter............................................................................Heidi Lewis Nominating.............................................................,............Curry Woods Program................................................................................Jim Bowker Committee Chairpersons (Ad Hoc): Continuing Education.........................................................Alf Haukenes Student Awards...................................................................Steve Lochmann Student.................................................................................Bonnie Mulligan President’s Appointees: FCS Representative to PFIRM............................................Vince Mudrak FCS Representative to Triennial Program Committee.....Mike Frinsko FCS Representative to Triennial Steering Committee…..John Nickum (‘10) Curry Woods (‘13) FCS Liaison to USAS...........................................................Max Mayeaux FCS Webmaster...................................................................Cortney Ohs Contact Information: Jesse Trushenski.......................................................saluski@siu.edu Curry Woods............................................................curry@umd.edu Jim Bowker………………………………………
[email protected] Donna Muhm..........................................................donna.muhm@dnr.iowa.gov Alan Johnson...........................................................alan.johnson@dnr.iowa.gov Heidi Lewis..............................................................hal7e7@siu.edu Alf Haukenes………………………………………
[email protected] Steve Lochmann......................................................slochmann@uaex.edu Bonnie Mulligan…………………………………
[email protected] Vince Mudrak..........................................................Vincent.Mudrak@fws.gov