Approach & Structure

This assessment of the U.S. aquaculture management system is based on the availability of evidence indicating conformance to the “Minimum Substantive Criteria” of the FAO Aquaculture Guidelines.  The FAO Aquaculture Guidelines were established in 2011 to provide guidance on developing, organizing, and implementing credible aquaculture certification schemes in order to advance sustainable development and improved management of the aquaculture sector. The Aquaculture Guidelines were developed at the request of Member Nations by the Committee on Fisheries - Sub-Committee on Aquaculture through a thorough consultative process with major stakeholders from governments, industry, and civil society. The Aquaculture Guidelines provide “Minimum Substantive Criteria” that address: a) animal health and welfare; b) food safety; c) environmental integrity, and d) socio-economic aspects associated with aquaculture. The Aquaculture Guidelines also embody principles outlined within “Article 9. Aquaculture Development” of the FAO Code of Conduct for Responsible Fisheries [8].  Given broadscale international participation in creation of the document through the United Nations process, the FAO Aquaculture Guidelines are widely accepted guidance for the sustainable management and development of aquaculture.

The FAO Aquaculture Guidelines present a number of benchmark indicators that address both “Institutional and Procedural Requirements” and “Minimum Substantive Criteria.” “Institutional and Procedural Requirements” address structural requirements for certification schemes, while “Minimum Substantive Criteria” address those factors that deal with the sustainability of aquaculture operations.  In this conformance assessment, we do not consider the “Institutional and Procedural Requirements” since we are not evaluating the structure of a certification scheme (most management systems are not certification schemes). Rather, we focus on the “Minimum Substantive Criteria” as a proxy for baseline sustainable practice.  Thus, our methodology focuses on conformance of the overall U.S. aquaculture management system to the 39 benchmark indicators described in the “Minimum Substantive Criteria”. 

Our methodology brings a systems approach to evaluating the sustainability of aquaculture in the United States.  Currently, the sustainability of cultured fish and fish products generally are gauged on a farm-by-farm basis by certification organizations like Aquaculture Stewardship Council, Global Aquaculture Alliance Best Aquaculture Practices, or Good Agricultural Practices GLOBALG.A.P.  A small, though growing, proportion of world aquaculture production (4.6%) is currently certified.  The main aquaculture schemes provide only a narrow take on sustainability at the farm level.  Environmental costs of distribution and transportation, or the cumulative impact and role of aquaculture in the context of surrounding ecosystems, landscapes, other development activities are rarely effectively considered [9].  However, certification schemes serve to play an important role as a differentiator between aquaculture producers in global geographies where management (governance) systems are weak and do not conform to international guidelines.

We propose that overall industry sustainability is the result of a well-designed and implemented management (governance) system and can be best gauged by assessing management systems rather a sole assessment of individual farm operations. A systems assessment provides a broader perspective to gauge the sustainability of operations within national management programs.  Systems assessments form the basis of the National Aeronautics and Space Administration (NASA) programs and constitute the global shift in how seafood safety is evaluated: from individual end-product inspections to the Hazard Analysis & Critical Control Points (HACCP) system.  HACCP is a science-based, systematic process that identifies specific hazards and control points in seafood production to ensure the safety of food.  HACCP is a tool to assess the entire food production process and establish measures that focus on prevention rather than relying mainly on end-product evaluation.  Based on a risk-assessment of the system, HACCP promotes efficiency (by both industry and government) in the establishment and audit of safe food production processes. The HACCP method provides flexibility for product control and has been successful in meeting the objectives of ensuring safe seafood acceptable to food control agencies [10]. 

Like the HACCP approach to food safety, our assessment takes a systems approach to sustainability rather than an “end product inspection” on the status of an individual farm and its products.  Our approach is based on recommendations from a series of international forums on “Science and Sustainability” which concluded that the sustainability of fisheries is assessed better by focusing on the overarching management system, not on a snapshot of the status of a stock or fishing level at any one point in time, nor of one fishery in isolation, but rather on the capacity of the system to respond to changes in stock levels or impacts via management measures in all fisheries under its jurisdiction [11], [12].  We assert that similarly aquaculture management systems which conform to internationally accepted sustainability guidelines will produce sustainable products and will provide an efficient mechanism for assessing aquaculture sustainability.

Assessments of research and management programs are commonly accepted techniques used to review the performance of programs within NOAA Fisheries and the FAO Fisheries and Aquaculture Department.  NOAA began a systematic peer review in 2013 of all six regional science centers and the headquarters Office of Science and Technology. Experts from within and outside the agency examined the science programs to improve integration, identify best practices, and share successes and challenges within its science enterprise [13].

At the international level, FAO conducts performance reviews of regional fishery bodies including regional fisheries management organizations under its jurisdiction in terms of their fisheries governance and conformance to the implementation of the 1993 FAO Agreement to Promote Compliance with International Conservation and Management Measures by Fishing Vessels on the High Seas [14], the 1995 FAO Code of Conduct for Responsible Fisheries [15], and the 1995 United Nations Fish Stocks Agreement [16], as well as other recently concluded international fisheries instruments.  In 2012, FAO released the first set of performance reviews that assessed management programs of the Commission of Antarctic Marine Living Resources, the Commission for the Conservation of Southern Bluefin Tuna, the International Commission for the Conservation of Atlantic Tunas, the Indian Ocean Tuna Commission, the Northwest Atlantic Fisheries Organization, the North Atlantic Salmon Conservation Organization, and the North East Atlantic Fisheries Commission [17].  The performance reviews and recommendations are shared as potential best practices for future management consideration. Additional performance reviews have been conducted on additional regional fishery bodies that include the General Fisheries Commission for the Mediterranean, the Inter-American Tropical Tuna Commission, the South East Atlantic Fisheries Organization, the South Pacific Regional Fishery Management Organization, and the Western and Central Pacific Fisheries Commission.

The FAO Aquaculture Guidelines are written in such a way that makes systematic scoring of conformance difficult, as noted similarly for FAO’s Code of Conduct for Responsible Fisheries [18] as well as FAO’s Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries [19]. Similar to the approach Walsh et al. [19] implemented for assessing fishery management systems, the conformance assessment tool in this project identifies “Topics of Pertinence” which are key concepts and principles derived directly from the Aquaculture Guidelines (Table 1). This assessment extends the approach developed and applied by Walsh et a al. [19] for marine-capture fishery management systems to aquaculture management systems. This project follows a similar assessment structure and process to gauge U.S. aquaculture management conformance to the FAO Aquaculture Guidelines.

Following these precedents, we present an assessment of the U.S. aquaculture management system to evaluate conformance to international criteria for sustainable aquaculture. In evaluating conformance, we take a qualitative approach by consolidating key concepts and principles from the “Minimum Substantive Criteria” section of the FAO Aquaculture Guidelines into “Topics of Pertinence,” which are tracked throughout the assessment. The structured rubric we use enables evaluation of the U.S. aquaculture management system, identification of any gaps between systems and FAO criteria, and development of considerations to address areas of non- or low conformance. 

For each “Topic of Pertinence” we take the following four steps:

1.    Outline relevant statutes, regulations, policies, and guidance that are applicable to aquaculture under the system's jurisdiction. 

2.     Provide evidence of conformance (three types, described below), i.e., how well the “Topic of Pertinence” is being addressed by the management system.

3.     Rate conformance via a symbol system (described below).

4.     Provide future considerations on how the management system may mitigate gaps or weaknesses in conformance.

The description of applicable statutes, regulations, policies, and guidance is followed by a discussion section that further describes how aquaculture programs are managed in conformance with the FAO Aquaculture Guidelines. Additional evidence and examples are provided to document what the U.S. management system says they do and to track evidence of open and transparent performance to those assertions. This assessment applies three types of evidence derived from the FAO 2010 Report of the Expert Consultation to Develop an FAO Evaluation Framework to Assess the Conformity of Public and Private Ecolabelling Schemes with the FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries (Evaluation Framework) [20], which provides a process to determine conformance with FAO Guidelines. The FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries [21] includes a very large number of benchmark indicators of conformance that address both “Minimum Substantive Criteria” and “Institutional and Procedural Requirements”.  While the Evaluation Framework does not provide specific guidance on how evaluators should make a determination of conformance to FAO Guidelines, it does discuss the types of objective evidence that might be used.  In undertaking an evaluation using benchmark indicators, evaluators are encouraged to identify the evidence used. In this regard, the Expert Consultation envisaged three categories of evidence that might be used to assess conformance [20]: 

1.     internal evidence (i.e., the scheme says it does something); 

2.     outcome evidence (i.e., the scheme demonstrably does what it says it does); and 

3.     independent evidence (i.e., an independent expert has determined that the scheme does what it says it does). 

Like the FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries, the FAO Technical Guidelines for Aquaculture Certification also include a very large number of benchmark indicators of conformance which address both “Minimum Substantive Criteria” and “Institutional and Procedural Requirements”.  Our assessment methodology follows the same FAO recommendation to identify three categories of evidence that might be used to assess conformance with benchmark indicators for Minimum Substantive Criteria that address animal health and welfare, food safety, environmental integrity, and socio-economic aspects. 

To assess conformance of the U.S. aquaculture management system to the FAO Aquaculture Guidelines, we provide the following examples of evidence we identified to illustrate how well each Topic of Pertinence is being addressed by the U.S. aquaculture management system:

1.     internal evidence – the management system says it does something (e.g., the Constitution, applicable statutes, legislation, regulation, standards, strategic plans, guidance, data collection manuals and protocols, etc.; the system states that certain actions will be taken that conform to the Aquaculture Guidelines).

2.     outcome evidence – the management system demonstrably does what it says it does (e.g., data are collected, assessments are conducted, agencies take management action, laws are enforced, etc.; system exhibits conformance with the Aquaculture Guidelines as illustrated with examples from aquaculture operations managed under the system).

3.     independent evidence – an independent entity has determined that the management system does what it says it does (e.g., courts have made rulings through the judicial process, open-access evidence is available that can be confirmed by the general public, performance is verified by an independent body, etc.).

Conformance of the management system with each Topic of Pertinence is rated via a symbol (Step 3) for each form of evidence (i.e., internal evidence, outcome evidence, and independent evidence).  Solid symbols (●) indicate strong evidence for all aquaculture operations under the jurisdiction of the management system. Semi-solid symbols (◒) indicate conformance with variable evidence among regions or aquaculture sectors (e.g., strong evidence for some but not for others). An empty symbol (○) indicates a gap between the management system and the Aquaculture Guidelines. An empty symbol does not confirm nonconformance; it simply demonstrates a lack of evidence available to verify or refute conformance within the management system.  

The resultant rating for each Topic of Pertinence can serve to identify gaps between the management system and the FAO Aquaculture Guidelines. A discussion section for each Topic of Pertinence illustrates how aquaculture is managed and provides evidence that corroborates conformance or identifies gaps in conformance. To lay the foundation for further improvement, we provide future considerations for aquaculture management. In some instances, these future considerations are based on areas of weaker conformance evidence identified by the rubric. These suggestions could be provided in a manner that would promote higher conformance on a subsequent assessment. In other instances, especially for Topics of Pertinence that have scored three solid black symbols, future considerations are provided beyond the scope of FAO Guidelines, since sustainability may be better envisioned as an ongoing process and not a definitive endpoint.  The provided future considerations are not exhaustive, but rather supply some potential examples for moving U.S. aquaculture management forward. The most constructive future considerations are those that are applicable, clear, and concrete in nature. 

The “Topics of Pertinence” approach provides a straightforward assessment strategy against the broader language of FAO documents − decreasing the likelihood that evidence for claims of ‘in conformance with the FAO Guidelines’ will be hidden in the details of the overarching text, an issue identified in a recent FAO briefing document on utilization of the Evaluation Framework [22]. Our assessment provides an efficient process without losing the substance of the benchmark indicators or guidelines. Like the Evaluation Framework, the current methodology does not weight benchmark indicators; “Topics of Pertinence” are regarded equally in the evaluation of conformance.   

This assessment process may foster management systems that are proactive and preventative in regard to issues affecting sustainability rather than reactive and recuperative. We view this assessment process as a very significant tool for aquaculture management systems to systematically evaluate, communicate, and guide the sustainability of their operations. The structure of this assessment of aquaculture management systems is unique in that it: (1) provides a systems-based approach to sustainability versus a single-operation approach, and (2) establishes a methodological tool that can be applied at multiple levels of the management system within a political entity or country (i.e., from a local or district level to the federal level) and could be applied to other countries in addition to the United States.  It also may be used as a way to synchronize efforts within an aquaculture sector or to normalize variability in management processes.

An eight-person steering committee was created to guide the development of this assessment.  Steering committee members were identified by the authors based on their expertise in U.S. aquaculture across the diversity of sustainability issues considered in the FAO Guidelines: animal health and welfare, food safety, environmental integrity, and socio-economic aspects.  In addition to topical knowledge, the make-up of the steering committee was designed to represent a diversity of perspectives in U.S. aquaculture by including individuals from federal agencies, individuals with experience working with state agencies, individuals representing aquaculture industries, individuals with expertise in sustainable seafood policies and certification systems, individuals from non-governmental organizations, and individuals from the academic community.  

The steering committee played an important role in serving to review the methodology for the study, ensuring necessary and pertinent information regarding the U.S. management system was compiled and available for the analysis, and rating the U.S. management system for aquaculture. Bi-annual meetings of the steering committee were held between November 2016 and August 2019, including two in-person workshops in June 2018 and August 2019. 

During the August 2019 workshop, the steering committee and authors met to review compiled information on the U.S. management system and assess conformance for internal, outcome, and independent evidence for each Topic of Pertinence.  The steering committee and authors discussed, debated, and voted on how to rate each Topic of Pertinence individually.  Consensus was sought and achieved in each case.  In cases where the ratings were subject to debate and not clear-cut, key caveats and dissenting arguments are captured in the discussion section of the assessment of conformance for each Topic of Pertinence in the Full Assessment.   

The steering committee and authors agreed that outcome and independent evidence would be rated based upon the scope of internal evidence identified. In cases where there was insufficient evidence to justify a filled circle for internal evidence for a Topic of Pertinence, a full circle could still be possible for outcome or independent evidence for that Topic of Pertinence given that for whatever the management system says it does, there is adequate outcome and independent evidence available to verify that it is actually done.

[8] FAO. 2011. Code of Conduct for Responsible Fisheries. Food and Agriculture Organization of the United Nations. Rome, Italy. 91 p. http://www.fao.org/3/i1900e/i1900e.pdf 

[9] Bush, S. R., B. Belton, D. Hall, P. Vandergeest, F. J. Murray, S. Ponte, P. Oosterveer, M. S. Islam, A. P .J. Mol, M. Hatanaka, F. Kruijssen, T. T. T. Ha, D. C. Little, and R. Kusumawati. 2013. Certify sustainable aquaculture? Science 341 (September) 9-10.

[10] Sperber, H. and R. F. Stier. 2010. “Happy 50th Birthday to HACCP: Retrospective and Prospective.” Food Safety magazine. December 2009-January 2010. pp. 42, 44-46. www.foodsafetymagazine.com/magazine-archive1/december-2009january-2010/happy-50th-birthday-to-haccp-retrospective-and-prospective/  

[11] Sullivan, K. 2010. "Sustainable Fishing in New Zealand". Oral presentation. Science and Sustainability Forum. Clearwater Beach, FL.

[12] Lassen, T. and S. Cadrin. 2012. Making Sense of Sustainability: Ocean Trust and the American Institute of Fishery Research Biologists pull together key scientists from around the world to more clearly define sustainability.  Science and Sustainability Forum, Arlington, VA.

[13] NOAA Fisheries Science Program Review. National Oceanic And Atmospheric Administration. U.S. Department Of Commerce. https://www.fisheries.noaa.gov/national/about-us/noaa-fisheries-science-program-review  Last updated by Office of Science and Technology on 04/30/2021.

[14] FAO. 1995. Agreement to Promote Compliance with International Conservation and Management Measures by Fishing Vessels on the High Seas. Food and Agriculture Organization of the United Nations. Rome, Italy. 75 p. ISBN: 9251038341. http://www.fao.org/documents/card/en/c/8cb30770-3145-55ed-a0db-315cbbb722a6 

[15] FAO. 1995. Code of Conduct for Responsible Fisheries. Food and Agriculture Organization of the United Nations. Rome, Italy. 42 p. ISBN: 9251038345. http://www.fao.org/3/v9878e/V9878E.pdf 

[16] UN. 1995. Agreement for the Implementation of the Provisions of the United Nations Convention on the Law of the Sea of 10 December 1982 relating to the Conservation and Management of Straddling Fish Stocks and Highly Migratory Fish Stocks. United Nations Conference on Straddling Fish Stocks and Highly Migratory Fish Stocks. Sixth session. New York, 24 July-4 August 1995. 40 p. A/CONF.164/37. 8 September 1995. https://www.un.org/Depts/los/convention_agreements/convention_overview_fish_stocks.htm 

[17] Ceo, M., S. Fagnani, J. Swan, K. Tamada, and H. Watanabe. 2012. Performance Reviews by Regional Fishery Bodies: Introduction, Summaries, Synthesis and Best Practices, Volume I: CCAMLR, CCSBT, ICCAT, IOTC, NAFO, NASCO, NEAFC. FAO Fisheries and Aquaculture Circular. No.1072. Rome, FAO. 92 pp.

[18] Caddy, J. F. 1996. A checklist for fisheries resource management issues seen from the perspective of the FAO Code of Conduct for Responsible Fisheries. FAO Fisheries Circular. No. 917. W3140/E. Food and Agriculture Organization of the United Nations. Rome, Italy. 22 p. http://www.fao.org/3/W3140E/W3140E00.htm 

[19] Walsh, M. L., G. R. Tromble, W. S. Patrick, & W. E. Morrison. 2015. Comparative Analysis of U.S. Federal Fishery Management to the FAO Ecolabelling Guidelines: A Self-Assessment. NOAA Tech. Mem. NMFS-OSF-1. https://repository.library.noaa.gov/view/noaa/9062 

[20] FAO. 2010. Report of the Expert Consultation to Develop an FAO Evaluation Framework to Assess the Conformity of Public and Private Ecolabelling Schemes with the FAO Guidelines for the Ecolabelling of Fish and Fishery Products from Marine Capture Fisheries. 24–26 November 2010. FAO Fisheries and Aquaculture Report No. 958. Food and Agriculture Organization of the United Nations. Rome, Italy. 51 pp. http://www.fao.org/3/i2021e/i2021e00.htm 

[21] FAO. 2009. Guidelines for the ecolabelling of fish and fishery products from marine capture fisheries.  Food and Agriculture Organization of the United Nations. Version adopted by the 28th Session of the Committee on Fisheries (COFI), Rome. Italy. 2–6 March 2009. 98 pp. ISBN: 978-92-5-006405-5. http://www.fao.org/3/i1119t/i1119t.pdf 

[22] FAO. 2013. Evidence on utilization of the FAO Draft Evaluation Framework and the economic impact from ecolabelling on returns to the fisheries sector. Briefing document for Sub-Committee on Fish Trade. Committee on Fisheries. Food and Agriculture Organization of the United Nations. Bergen, Norway, 24–28 February 2014.  COFI:FT/XIV/2014/Inf.9 http://www.fao.org/3/a-bc431e.pdf