By Ramya Honnegowda
In recent years the popularity of seafood has grown among consumers due to its health benefits. Nevertheless, due to overfishing and environmental diminution the dependency on farmed raised fishes has amplified. However, when consuming farm-raised fish, consumers may not be conscious that with every bite they are getting a dose of antibiotics, hormones, pesticides and/or other chemicals which known to cause cancer or other harmful effects on human health. As intake of farm-raised fish grows, consumers need to be aware of the risk involved with eating it and feeding it to their children, who are eating the drugs, chemicals and contaminants found in aquaculture products.
Most of the Countries have enacted Rules and Regulations that are primarily responsible for ensuring that both domestic and imported seafood is safe for consumers. Fish feed regulations is deliberated to be important as it keeps the entire society healthy. The primary purpose of feed regulation is to make sure that the fish feed is:
- Pure and wholesome
- Produced under clean conditions
- Free of harmful substances
- Labeled appropriately and truthfully
As a case study, I have briefly enumerated the Feed Regulations in California for a better understanding of what essentially is feed regulation:
State of California
Rich in agriculture, California’s Department of Food & Agriculture (CDFA) is tasked with shaping, implementing, and enforcing feed regulations in the state. “The amount of animal feed commodities used in California has increased substantially over the past decade, making California the largest manufacturer of animal feed in the U.S.” CDFA’s Safe Animal Feed Education Program (SAFE) conducts outreach, education, and voluntary feed quality assurance audits for manufacturers of commercial feed. Because the number of on-farm feed production has risen in the state, SAFE also targets efforts towards these producers of feed.
The relevant code sections dealing with Commercial Feed are enumerated under Chapter 6 of California’s Food & Agriculture Code (the Code). The Code establishes a Feed Inspection Advisory Board under Article 4, generally responsible for serving the industry for the benefit of consumers. The Code specifies the regulations for licensing, labeling, standards and tolerances, inspections and analyses, mislabeling, adulteration, inspection tonnage tax, violations, procedure for prosecution, and complaints.
Analogous to the California law, is the California Code of Regulations (Plant Industry), under Title 3 from Section 2675 to 2803. This part of the Code goes into the specifics on what is permitted and prohibited in commercial animal feed. It also provides the definitions relating to feed and the precise limits for various chemicals, minerals, and other substances added to, and/or present, in feed. It is important to note that when analyzing California’s commercial animal feed regulations, reference must be made to both the Food & Agriculture Code and the California Code of Regulations (Title 3).
With some exceptions, “every lot, parcel, or package of commercial feed distributed within this state shall have affixed to it, or be accompanied by, a label.” Contents of the label must include “legible and plainly printed statement which certifies all of the following:
(a) The net weight or volume of the contents of the lot or parcel unless accompanied by a certified certificate of weights and measures.
(b) The product name, brand name, or trademark.
(c) The name and principal address of the manufacturer or person that is responsible for placing the commodity on the market.
(d) The guaranteed analysis stated in such terms as the secretary specifies by regulation.
(e) The recognized official name, as specified by the secretary, of each ingredient. The secretary may by regulation permit the use of a collective term for a group of ingredients which performs a similar function. The secretary may exempt a commercial feed, or any combination of commercial feeds from labeling requirements if he finds the listing is not necessary to comply with the intent of this chapter.
(f) Adequate directions, warnings and caution statements that may be necessary for the safe use of any feed.”
There are also code sections covering labeling feed mixes, claims of guarantees on labels, and exemptions from labeling for feed produced or distributed at a location under the same ownership as the manufacturer. In the corresponding section of the California Code of Regulations (Title 3), the remainder of laws on commercial feed labeling range from section 2683 to 2698 and provide the details on all of the label laws only briefly discussed in the Food & Agriculture Code. Two notable sections provide the special labeling rules pertaining to feeds containing drugs or medications and for drug and food additive guarantees.
Inspection and Analysis:
California law mandates inspections, at reasonable times, for all aspects of the commercial feed industry and gives inspectors the right to take samples and conduct analysis. Other rules for inspections include requiring government reports of their results. The results are to be provided to the relevant parties and the law prohibits the use of government analysis or reports in advertising the product (feed).
Mislabeling, Misbranding, Adulteration, and Damaged Feed:
Commercial feed is deemed mislabeled if any of the following are found:
(a) Its labeling is false or misleading in any particular.
(b) It is not labeled as required by this chapter.
(c) Any word, statement, or other information required pursuant to this chapter to appear on the label is not prominently placed thereon with such conspicuousness, as compared with other words, statements, designs, or devices in the labeling and in such terms as to render it likely to be read and understood under customary conditions of purchase and use.
Misbranding is when a product is labeled as a different brand than it really is or if it purports to contain some ingredient(s) that it does not. California also prohibits misleading advertising and has detailed rules on adulteration. Feed is damaged and deemed adulterated and unlawful for sale if “it or any ingredient has been affected by smoke, heat, water, mold, or contamination by any foreign substance to such an extent as to affect the nutritive value, therapeutic value, palatability, or wholesomeness of the feed.” The code goes on to require notifying authorities when the product may be damaged and holding sales until the State tests samples and approves further sale or orders the product destroyed.
CDFA’s Feed, Fertilizer, and Livestock Drugs Regulatory Services Branch issues licenses for commercial feed and offers guidance to the industry on complying with the requirements. The current commercial feed license has an annual cost of $300.00 and includes an exemption for retail stores selling bagged or packaged commercial feed, which must be properly labeled by a licensed feed manufacturer. In the corresponding licensing section of the Code of Agriculture, another exemption to the commercial license requirement is for a “person who manufactures commercial feed exclusively for feeding his or her own animals.”
There are also special licenses set forth in their respective sections under the Code of Regulations. For example, in the code section titled Processed Animal Waste Products, there are additional licensing requirements, including requiring the submission of a complete description of the facilities involved and protocols observed by the license applicant. The authorities then review the application, determine whether to endorse the facility, and even if they approve a license, the government retains the right to summarily suspend it if they find the procedures are not being followed or if pathogens may be present in the product.
Residues, Medicated Feed, Food Additives, and Harmful Substances:
The Code of Regulations provides the definitions and details of various ingredients commonly found in feed, from plant products to marine products to animal products, as well as discusses different indigestible residues and their limits or rules within the commercial feed context. With regards to medicated feed, it is unlawful to use such feed except in compliance with the directions on the tag or label. The safety and efficacy of medications and additives are discussed in the Code of Regulations, incorporating federal statutes pertaining to rules on drugs in food. Lastly, the law reserves the right of the secretary of state to “require the percentage listing of any material which he finds to be of minimal nutritional value.”
California also prohibits the use or sale of poisonous or deleterious substances, including anything that “may impair the health of the animal being fed or result in an illegal or harmful residue or constituent in or on human food.” The code section on pesticide residue in commercial feed incorporates federal regulations.
The seafood consumed could be made much safer if:
- The regulatory organizations were to follow the best practices in complying with the statutory requirements. The regulatory organization of every country works towards tightening standards reduce the use of antibiotics in aquaculture by withholding new approvals of antibiotics for such us.
- Consumers can also act to ensure that they are purchasing the healthiest seafood for themselves and their families. They should also look for the labels to guarantee and distinguish between farmed raised or wild fish. Request the local markets to carry seafood that does not contain antibiotics.
 California Department of Food & Agriculture, SAFE Website Homepage: http://www.cdfa.ca.gov/is/ffldrs/safe.html
Reference Note: A link to a .pdf version of both sections can be found at the California DFA website (under the heading, “Feed, Fertilizer, Livestock Drugs” and under the link, “Feed Laws and Regulations”). Available at http://www.cdfa.ca.gov/is/regulations.html
 Cal. Food & Agric. Code §14991
 Cal. Food & Agric. Code §14992
 Id. at §14993-14996.
 Cal. Code Regs. tit. 3, §2701
 Cal. Code Regs. tit. 3, §2702
 Cal. Food & Agric. Code §15021
 Cal. Code Regs. tit. 3, §2717 – § 2719
Cal. Food & Agric. Code §15031
 Cal. Code Regs. tit. 3, § 2733
 Cal. Code Regs. tit. 3, §2712
 Cal. Food & Agric. Code §15041
 Cal. Code Regs. tit. 3, §2760(a)
 Id at § 2760(b-e)
 Id at § 2751(b)
 Id at § 2751(a)
 Cal. Food & Agric. Code §15051(c)(2)
 Cal. Code Regs. tit. 3, § 2774.5
 Id at §2774.5(a)(2)
 For example see, Id at §22774, §2788 and §2790
 Id at § 2766
 Id, at§2676
 Id, at§2706
 Cal. Code Regs. tit. 3, at §2677
 Id, at§2678