Conclusions of ACAF on the feeding of fish meal to farmed animals

Tuesday 15 May 2001

To be read in conjunction with the acting Chairman's letter of 15 May 2001

The Committee acknowledges that the feeding of fish meal to farmed animals would probably be regarded as unacceptable by many people. This point was made clearly in consultation, not only supporting the Food Standards Agency and those committees advocating a ban on own-species feeding but also seeking to avoid feeding fish and animal material to herbivores.

The Committee believed it important however that any controls have to be justified in terms of the risks they seek to address and of the costs and benefits of such action. The Committee is aware of no specific risks to animal or fish health from the inclusion of fish meal in animal or fish feed, provided that no fish meal produced as a by-product of aquaculture is recycled in fish. In this respect, ACAF shares the views of the Spongiform Encephalopathy Advisory Committee (SEAC) and the Food Standards Agency in its review of BSE Controls that in general intra-species recycling of material should cease. The Committee was informed that the trimmings of farmed fish had not been used for the past five years in fish meal used in aquaculture. Moreover, it noted that a provision on these lines had been drafted into a new Fish Meal Assurance Scheme, a joint United Kingdom Agricultural Supply Trade Association (UKASTA) and United Kingdom Association of Fish Meal Manufacturers (UKAFMM) Certification Scheme Standard for Fish Meal used in Animal Feed. This states that "raw materials from farmed fish shall not be used for producing Fish Meal intended for aquaculture." The Committee would prefer to see such a control embodied in law, and compliance monitored if at all practicable.

The Committee considered whether it was justifiable to ban fish meal from ruminant or other animal feeds for BSE-related reasons due to the risks of cross-contamination or adulteration with meat and bone meal (MBM). First, mammalian MBM has been banned from feed for farmed animals in the UK since 1996. Moreover, fish meal is produced and transported in this country separately from other materials used in animal feed. This situation, plus the imminent introduction of the Fish Meal Assurance Scheme mentioned earlier, provides important protection against the risks of contamination.

Such contamination is capable of detection: the ELISA detection test as developed and used in the UK is capable of detecting the presence of mammalian MBM in fish meal, whilst the Microscopic Analyst Test (MAT) is widely used in other EC countries. The ELISA test is currently being tested with collaborators in other countries and is known to be sensitive to materials rendered at 130° c at 2-7 bar pressure for 30 minutes. The MAT on the other hand has benefits when applied to material rendered at higher temperatures. This test is employed by the Veterinary Laboratories Agency in the UK.

The Committee considered the risks of cross-contamination by MBM of imported fish meal. It had no experience or evidence of circumstances in other European countries although it was aware that the European Commission had been assessing the position. The Committee could not therefore consider the risks. However, neither cross-contamination nor adulteration were considered likely where material arriving in the UK direct from South American fish meal plants was concerned. Any additional steps in the distribution chain, including transshipment, would increase the risk of problems.

The ability to be able to trace fish meal at all stages of its journey to processing plants to the feeding of animals is most important. The Committee noted that legislation was in place regulating fish meal exported to the EU from non-EU countries. This requires origin in approved processing plants, animal health certification and checks on imports. As part of a broader concern, ACAF members felt that breeches of this legislation and that banning MBM from animal feed should be rigorously enforced with high penalties for any guilty parties. Any assurance schemes, whether on a UK or wider basis, needed to be subject to a stringent audit to underline traceability of material, and the results of such audits should be made publicly available. Such traceability systems should relate to an absence of any contact with MBM or other contaminating material. Results of relevant analyses need to be available.

There are clear nutritional and animal welfare benefits from using fish meal in animal feed, particularly for hill ewes which are pregnant or lactating. Fish meal has benefits for poultry and pigs too and fish meal and oil are essential components of feed for carnivorous farmed fish. The total removal of fish from these diets would not be justified in terms of any human or animal health risks. Moreover, the risk of cross-contamination of fish meal by MBM, and the attendant BSE risk, would not warrant a ban provided existing rules on the use of MBM were fully adhered to and there was an assured and protected production and supply chain for fish meal, whatever its origin. This would require full traceability and safeguards against accidental cross-contamination. Any scheme should be properly policed and audited, with public accountability.