Scientific Hatcheries

Introduction:

At the present time we are importing on the order of 10,000 boxes of live ornamental fish per week via air freight from at least 20 different countries and 500+ different source locations or farms. Along with all these desirable animals, there are bound to be undesirable organisms such as parasites, pathogenic bacteria and viral diseases. The existing inspection system by the Customs Department, Fish and Wildlife, and the local Fish and Game Commission (in California) does not have the technical expertise even to identify the species of fish relative to what is on the bill of lading, let alone to inspect for microscopic disease organisms.

The time elapsed between when a fish is imported and when it is for sale in a major pet shop chain is less than 48 hrs. Imported animals carrying disease organisms can come into this country and be sold to the final consumer, well before any disease would become apparent. To compound this problem, typical tropical fish wholesalers and retailers have no bio-security procedures. They utilize common recycle water systems, with inadequate or improperly maintained UV's, which spread organisms to all uninfected animals. The typical wholesaler uses antibiotics and other treatments in an attempt to keep the fish alive long enough to sell to the retailers who often also use various treatments.

It is clear that this existing distribution system contains significant elements of risk. These risks should be examined to determine if they are acceptable risks.

Risk Analysis:

The risks associated with the existing ornamental fish importation system can be broken into the following categories according to the group which will be impacted:

Risks to the ornamental fish industry

Risks to the aquaculture industry from imported diseases

Risks to the aquatic environment from imported diseases

Risks to the public health and animal health from imported anti-biotic resistances associated with the diseases.

Ornamental Industry Risks:

The tropical fish industry has been unsuccessfully dealing with the imported disease problems for at least 25 years. In the late 60's and early 70's, angel fish (Pterolphyllum scalare) were the dominant imported fish and enjoyed wide popularity. A disease spread from Asian imports to the US producers and customers and virtually eliminated angel fish from the market place. To this day, it is only possible to obtain "clean" angels from private breeders and wholesalers who keep them in isolation tanks in an effort to prevent infection. The identity of the actual infectious agent is not clear and we don't have any tests to determine if a stock is "clean". Domestic breeders come and go as they start new systems and do well for a few years and then everything dies. The disease from Asia has destroyed a multi-million-dollar part of the pet business.

In the mid 80's, fancy male guppies were a very major product. Every wholesaler carried 10 to 30 strains of these beautiful fish, with most retailers having several tanks and a wide variety. Most of these fish were imported from Singapore and other Asian sources. In the late 80's to early 90's, the mortality rate increased, and it became clear that they were carrying an infectious agent which would spread to domestic produced guppies with lethal consequences. Exposure of healthy domestic produced guppies to Singapore fancy guppies resulted in near total mortality within a few days. No treatments seemed to be effective, and the problem continued to get worse with the imported guppies. It became impossible for a wholesaler or retailer to carry Asian guppies in the same system with domestic produced guppies without the domestic guppies becoming infected and experiencing almost total mortality (the Asian guppies had high but not total mortality and appeared to have some resistance to the unknown agent). As a result, the domestically produced guppies were excluded from the market, and major pet retailers dropped items like common guppies and feeder guppies.

The guppy disease problem continued to worsen until it got to the point that importers could not get fancy guppies from Asia to the US alive, and the wholesalers could not keep them alive for even 48 hrs. At this point, fancy guppies ceased to be a viable product and were no longer imported in significant numbers. Meanwhile, the quality of Florida-produced guppies decreased creating high mortality problems at the retail level. This mortality problem has prevented the domestic producers from filling the market. Whether the problems with the Florida guppies came from and are the same as thoes associated with the Singapore guppies has not been proven.

In the early 90's, many of the Asian produced Gouramies began to exhibit mortality problems at the wholesale and retail levels. This was identified as an iridovirus. Some countries, such as Australia, tightened their quarantine of imported Asian Gouramies (three weeks without medication). There were no restrictions on the US importation, and within a few years, several very major Florida Gouramie producers failed due to high mortality problems caused by an iridovirus. Without DNA analysis, it is not known that this is the same strain and that it was transferred to the Florida producers from imported animals. However, the timing makes one suspicious of the imported animals as the source.

All these problems are internal to the pet industry and create problems directly for a number of relatively small businesses. However, the overall industry is also hurt by the loss of customers who can't keep the fish alive and quit trying. These phenomena may account for the apparent slow sales in the industry.
 
 

Aquaculture risk from imported ornamental fish:

There is an obvious risk that one of the imported diseases could infect some aquaculture species. Most of the imported bacterial diseases from Asia have multiple anti-biotic resistances and are totally immune to any of the legal treatments allowed by the FDA. How real is this risk that a disease of imported ornamental fish could reach the commercial food fish industry?

Apparently an iridovirus created a problem for some tilipia producers in Idaho. This problem was traced back to Florida fingerling producers. Is this the same strain that destroyed Florida's Gouramies producers and the Asian Gouramies producers? We don't know at this time. However, it is a distinct possibility.

We do know that Yersinia ruckeri (enteric redmouth in trout - ERM) has been identified in Florida in Gouramies that originated in Asia. There was no conformation of this analysis and the fish were destroyed, in an attempt to protect the rest of the hatchery. Verbal reports indicate that ERM was also identified in trout in Scotland and traced back to Gouramies from Asia in the ornamental trade.

Multiple anti-biotic resistant strains of Edwardsiella tarda have been reported in imported ornamental fish (B. Dixon). This pathogen is known to infect catfish along with many other aquaculture species (J. Plumb). One of the imported strains of E. tarda could relatively easily get started in the catfish industry. Given the size of the catfish industry, the relative significance of this industry in Mississippi and Arkansas and the present political leadership, the risk of a political reaction leading to the shutting down of all imports and ornamental fish movement is real. Bio-security in the catfish industry is not high enough to stop the distribution via birds and equipment. This risk is real for both the catfish industry and the ornamental industry.

Clearly some of the same analyses and diseases apply to the stripped bass and tilipia industries. However, they aren't as politically powerful as the catfish industry. The impact of a disease being traced to ornamental fish would not be as significant to the ornamental fish industry. Individual aquaculture producers may be destroyed, since they would have no legal means of treating the anti-biotic resistant diseases.

In summary, imported ornamental fish present a significant risk to aquaculture.
 
 

Environmental risk from imported diseases:

The risk to the environment associated with iridovirus in Asian produced Gouramies was one of the prime driving forces behind the tighter quarantine being applied to Gouramies in Australia. The risk to wild stocks from some of these imported diseases is significant.

If something did cause an environmental problem, the environment will pay the price.
 
 

Hunan health risk:

The FDA has used the risk of development of anti-biotic resistance to block the use or possible use of flouroquinolone on fish. The FDA's theory is that the use of this class of drugs by aquaculture and ornamental fish producers could result in the target bacteria developing resistance. This resistance could than be transferred to human pathogenic bacteria thereby eliminating one of our last lines of defense against these human pathogenic bacteria.

The ban on flouroquinolone in this country will have no impact on Asian fish producers. It is understood that several countries are using flouroquinoloneís without limitations on ornamental fish. If the FDA's analysis is correct, the ban on flouroquinolone will not solve the problems, which will be imported along with the ornamental fish.
 
 

Cost and impacts of various risk minimization alternatives:

Various approaches can be taken to decrease the previously covered risks. An obvious approach would be to ban all imported aquatic livestock. However, a ban would result in a significant decrease in the variety of fish being sold and could decrease the customer base. This action would favor the large pet shop chain which only carry the basic high volume fish, most of which are also produced in the US. The lack of variety would hurt the small and specialized ornamental fish store, which would no longer be able to carry products that the chains don't carry. There would probably be a minor price increase to the final customer as the higher cost US producers fill the market that is now controlled by the Asian producers. With the farm gate price of ornamental fish being only about 10% of the retail price, a large increase in the farm gate price would not necessarily cause a large retail increase.

A preferable approach would be to impose a mandatory quarantine on imported ornamental fish. This approach is used in most of the world, with the US being the exception. Australia and New Zealand both have quarantine requirements for all imported ornamental fish. Considering the 10,000 boxes of fish that are imported every week, we are only talking about 10 tons of actual fish per week. If we required holding for 3 weeks, we would only have to hold 30 tons of fish. Since we aren't growing the fish, they would only be feed about 300 kg/day. Relative to any large commercial aquaculture facility, this is an insignificant amount of fish or feed. The cost of a 3 week quarantine would not be excessive, especially when you consider that the producer has already held the fish for 20 to 30 weeks. In terms of time, we are adding about 10% to the time to sale for a fish, which will only add a similar percentage to the wholesale price of the fish. If the fish can not be held for 3 weeks in the distribution system, the quality isnít good enough to sell to the final customer.We expect the final customer, with even less knowledge than the wholesaler, to keep the fish alive for 50+ weeks.

Heath documentation approaches have been used with imported food animals. These control systems require inspection in the exporting country for specific disease organisms and ban the importation of animals infected with these specific organisms. On paper, this would be a less costly and very effective approach to the problem. However, unlike salmon, ornamental fish come from many less developed countries where a few dollars can get any type of documentation desired, independent of the real health status of the animals. Source country documentation wonít work in the ornamental industry. This approach only works with known and well defined diseases and has trouble controlling a very virulent strain of a common pathogen which would not be one of the reportable organisms or organisms of concern.