Doug Waley on the lives of farmed fish and how we can help them

Long overdue conversation on the important topic of fish this week with the lead for fish at Eurogroup for Animals, Doug Waley. Doug’s expertise lies in working for fish at the EU level however most of the episode is filled with important information relevant to fish farming across the globe. 

It’s a technical one but really insightful as we explore the everyday life of a farmed fish, the challenges they face and what can be done to secure meaningful wins for the billions of fish farmed each year. 

As always please check out the episode on youtube if you’d prefer or listen in, it’s a great episode! 

Relevant links to things mentioned throughout the show:

• Gautier Riberolles - Welfarm
• Dyrenes Beskytellse
• Humany Pokrok - Live carp campaign
• Aquatic Life Institute 
• Eurogroup for Animals
• EU Research Centre and Consortium: Animal welfare in aquaculture 
• Gaia in Belgium on stopping RAS aquaculutre in local systems
• Do fish feel pain? - Victoria Braithwate
• What a fish knows - Jonathan Balcombe
• Uncovering the horrific reality of octopus farming - CIWF and Eurogroup Report

00:00:00:00 | Intro 
00:02:09:21 | Inspiring figures in the movement
00:04:29:11 | Fish welfare
00:06:06:03 | Origin of imported fish
00:07:29:06 | Fish farming conditions
00:15:37:03 | Importance of water quality
00:19:39:07 | Welfare challenges
00:27:04:03 | How many fish are farmed?
00:32:56:03 | Fish confinement
00:35:44:16 | Priorities for helping fish
00:41:28:09 | Motivation for producers to improve mortality rates
00:43:55:04 | The state of fish advocacy
00:47:42:21 | Quality of certifications
00:50:17:08 | The next step in collaborating with producers
00:52:01:02 | Work on EU legislation
01:01:16:21 | Closing questions

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Transcript

Doug: I suspect that a serious cause of chronic stress in aquaculture is the confinement and lack of stimulation for fish. And I think that chronic stress is creating these huge mortality rates. So maybe – I don't know if technocratic or behavioural, maybe they're sharing half and half – but I framed it as behavioural and positive welfare for a positive mental experience, which is what we'd like to aim at. But I think it's also really rooted and connected to survival. But it's only in these more engineering and technical solutions that we can say, now we've got something proven, and we've got something tangible. 

Amy: Hi, my name is Amy. 

James: And my name is James. 

Amy: And this is How I Learn to Love Shrimp, a podcast about promising ways to help animals and build the animal advocacy movement. A long overdue conversation on the important topic of fish this week, with the Lead for Fish at Eurogroup for Animals, Doug Whaley. Doug's expertise lies in working for fish at the EU-level. However, most of the episode is filled with important information relevant to fish farming across the globe. It's a technical one, but really insightful as we explore the everyday life of a farmed fish, the challenges they face and what can be done to secure meaningful wins for the billions of fish farmed each year. As always, please check out the episode on YouTube if you'd prefer. It's a great episode. 

Amy: Hi everyone, we're joined today by Doug Whaley, who's been leading fish welfare work at Eurogroup for animals for the last seven years, lobbying for better regulations at the EU-level and for applying non-legislative instruments to raising fish welfare standards. He also has a role in supporting and coordinating communications and lobby work among Eurogroup's 99 member organisations. Amazing. Welcome, Doug!

Doug: Hi there. Thanks very much for having me, great to be here!

Amy: What a bio! It's very extensive and I'm sure we'll get into all of that in detail later on. But opening question then: who is someone in the movement that people might not know about but that you find particularly inspiring? 

Doug: Yeah, somebody who inspires me, and I'd like to take the chance to shine this spotlight on is Gautier Riberolles at Welfarm and the LFDA in France. He's got so deeply engaged with the literature and has just brought that all into our busy working group of members who, as we have really done a process of defining what is fish welfare, what is important, what should we be asking – he's kind of had a standout role in keeping us right and being rigorously correct and not missing anything. And with that, he's been connecting it to production systems, taking it out of just the academic field, and he's expanded; he's come up with new ideas, expanded ideas of what we could provide to fishing and how we could do it. I'm inspired by what he's done with the knowledge and he's involved in campaign work, strategic campaign work as well. But he's brought technical knowledge into our work. 

James: Nice. So, he's an academic, is that correct? 

Doug: He has an academic background, but he's full-time with the NGO Welfarm and I think also associated with LFDA in France. Yeah, academic background, but full-time advocate, but with quite a focus on the technical knowledge. 

Amy: That must be so invaluable because I imagine there's just so few people in the movement, in the world probably, that have really gone deep into the literature and are able to practically apply that to fish welfare work. We know there's so many different species, so many welfare challenges there. So, yeah, I imagine that's quite a unique position for somebody to have and maybe saves you a bit of time having to dig into the weeds on a lot of that work. 

Doug: Yes, absolutely. And from my perspective, there's been a bit of a transition in my time in the role when seven years ago, a lot of organizations were looking to me and looking to us to say: “What is this?” And by now it's not like that anymore at all. There's much more expertise amongst advocacy and member organizations who are now coming in and telling us what's what and what to do with it. 

Amy: Nice. 

James: Our plan for today is – basically, it'll be our first ever episode on conversation around fish welfare. So, it's no pressure [laughing] but I think this is a super important time because obviously there's literally trillions of fish, either wild caught or farmed each year for food. And obviously it's a huge topic within animal advocacy that's only growing, I think, over the past few years, as you kind of noted as well. So, I guess we'd just be very curious the kind of cover the broad landscape. And we can initially start with just, you know, where are most farmed fish globally? And what kinds of conditions? What kind of species are farmed most. There's lots of questions there, but maybe we can start with, you know, geographically, where do they exist currently in terms of the problem? 

Doug: Around 85-90% of farmed fish are farmed in East Asia, and about 65% of that, I think, is in China. And the region is both a huge supplier to the world market but most of it is also consumed in East Asia. Absolutely favoured food product, and especially as incomes rise in East Asia, I think seafood consumption has been rising 35% a year. So, Asia and East Asia are really a hotspot for production. Also, Chile and Norway are really standout: huge producers of both salmon and trout. Then there's Nigeria and Egypt and Africa who really stand out as big producers, especially catfish in tilapia, respectively. Brazil: huge producer in South America. But really, everybody farms some fish. There's some stand-out, bigger producers. And yeah, the short answer to your question is Asia. 

James: In terms of most of the fish that we consume in US and Europe, or kind of richer countries, so to speak, is that mostly being imported from East Asia, or is imported from all these countries you mentioned, like Brazil and Nigeria and Egypt or – yeah, how does that kind of look in terms of the fish people in the global north tend to consume? 

Doug: I know Europe better, and I can say something about North America as well. And so more than half the fish we eat in Europe is imported, and the EU is the most valuable seafood market in the world. So, it's a huge story of trade in the EU and a big chunk of that is salmon and wild-caught fish from Norway. A huge chunk of that is probably the number one item. Then there is tinned tuna, imported mostly from East Asia. Farmed shrimp are right up there as well. And then we would be looking at species that are farmed in the EU, especially sea bass, sea bree, Mediterranean species, and trout, and a lot of that produced in the EU, but also from neighbouring Turkey and Norway. 
North America, I think, less domestic aquaculture production and more farmed fish and fishery imports in Tilapia from Central and South America; shrimp from Central/South America, and again, everything from Asia. 

Amy: And in terms of the conditions there: so, I remember when I first learned a little bit more about how fish are bred and raised for consumption, there's different kind of farming systems. We've got tanks on land which are fairly self-explanatory. We've got some kind of basket sitting in open waters, like in the sea, like you were saying in Norway, and then also fish that is wild-caught, which is like trawlers going out and trawling for fish. Is that kind of accurate in terms of the descriptions of where those animals are typically raised? And then within those, what are the kinds of conditions that the fish are kept within? 

Doug: The diversity of aquaculture production systems and wild-caught or fishery methods is enormous, and we could spend an hour definitely describing them all, and so I will focus on some major ones. So, you touched on what we'll call cages or net pens, you know, that holding unit which is in a river or a lake or the sea and it's exposed to all the water. Those are used everywhere in the world, big ones and small ones. They will often be in a more…for more intensive production systems. And stocking densities are often significantly high. They're often using commercial feeds and adding a lot of feed that has been sourced from often quite unsustainable sources. 

Maybe also the other most common production system would be earthen ponds. Maybe a bit in Europe, but in Asia, a lot of the fish are grown in earthen ponds and they will often be at a lower stocking density and have an element of natural feed. And they're using the feed that's in the water. 

Water quality in both of those examples, hugely variable by location. You know, where rivers have cage systems: whatever is happening in an upstream cage system very soon turns up in the downstream cage system and then the next cage system further down. And so, in terms of health issues and pollutants and water quality, a hugely variable picture. 

James: When you say earthen ponds, you mean farmers will kind of dig out these large, almost like pools within the earth? And then that would be the basis and there'd be like, no walls and such? It'll just be that the dirt and mud form the walls of the farm? 

Doug: That's exactly right, yeah. And you can get a few examples of concrete ponds in the biggest and most intensive systems. Shrimp will be in a lined pond where they've done that and then lined it with plastic. But the vast majority, yep, just earth bottom and earth walls. 

James: How big do these ponds tend to be? Both the net pens in the sea and also on land? 

Doug: A Tilapia net pen could be three metres across, and a salmon net pen could be 50 meters across. 

James: Okay. 

Amy: And how many would you typically hold in those? 

Doug: 50,000 salmon in a net pen, I think. 

James: Wow. 

Amy: And it's hard, isn't it, because they don't measure them by individual lives. It's often on tonnage. So actually, getting figures and understanding fish farmed en masse is very challenging, particularly in animal advocacy, because we're not talking about individual animals and individual animal lives, we're talking about tons of flesh, essentially. 

Doug: Yeah, a standout sector amongst animal production sectors is that they do not count the number of animals and they do not publish data on how many mortalities there are and how many survive. Yeah, it's a big data black hole. 

Amy: And then in terms of conditions in the wild-caught fish, what are some of the challenges? Because I guess people would think that is, you know, perhaps more sustainable or more environmentally friendly. There'll often be like challenges with communicating the issues of the fish that are wild-caught. What are some of the challenges that those fish present in terms of sustainability?

Doug: You know, there's a huge issue with overfishing, and core to that is that fishing boats are quite out of sight and out of mind. And it's really difficult to implement rules on anything in fisheries. And from a welfare perspective, it's equally difficult to bring rules in. They're unfamiliar. So that hasn't made much ground there because they live free life until they're caught. So, there's an obvious standout difference and presumably benefit for the fish until they're caught. But when it comes to being caught: there is a very long and extended capture process. There may be some kind of net dragging them to exhaustion; crushed at the back of the net, pressure changes and the body ruptures; as they're brought up to the water, they may be alive. When they're brought up onto the boat, they are thrown around out of water, put through equipment. Very often there's no killing methods. They might be gutted alive. They might be put on ice alive. They will likely be alive and out of water and suffering for at least quite a few minutes. And then certainly some species, they'll be still alive 10-12 hours after capture. But in a crate of ice. 

James: That sounds bleak, yeah. In terms of, like, advocacy work, obviously what you described is like an extremely cruel and intense end-of-life process. And in terms of people working on fish advocacy, how do you or others think about, you know, weighing up? Like you said, they have a free life for most of their life (the wild-caught fish that is). And at the end, they potentially have quite a traumatic and severe experience as they die compared to fish that are raised in confined conditions in kind of these farms throughout their life. And, yeah, I guess how do you trade-off the relative kind of tractability of working on them, but also the overall wellbeing they experience throughout their life? 

Doug: Of course, you can make more impact on the life of a farm fish than you can on a wild fish. So, there's a big reason to put most energy into that. And that's what we do; we put most energy into farmed fish. But then amongst our top priority is getting higher standards of slaughter for farmed fish. And it's equally applicable in wild-capture fisheries. 

Another thing is that when we look at tractability, most of our work is legislation-focused, and there is farmed animal welfare legislation, and immediately and automatically farmed fish slot in there in a way that wild capture fish just don't. So, there's much more of an opportunity for us there. 

There's also much more of an evidence base to come and put on people's desks and say: “Look at all of that. That is what you need to work with.” Wild capture fisheries are really – it's got far fewer proven best practices that you can then try to have implemented. 

So, our approach on wild-capture fisheries is more about getting recognition for the issue and getting foundations in place in policy documents and policy objectives, so that can stimulate things like research, market recognition through quality labelling schemes or sustainability labelling information. Because there are boats with higher welfare practices, but they've been so out of sight, the topic’s been so out of sight, that these things that are normally there to help, have not been put in place for fishers. So, we're looking to stimulate research and these sorts of market support measures now. And we've had some success at that. And on farmed fish, we're much more focused on getting specific provisions and specific best practices required,

Amy: And touching on those best practices: so, you spoke before about stocking density, which is just how many fish are farmed in one specific area. You talked about the water quality. Could you go into that in a little more depth to describe what the fish need in terms of the quality of the water and why not having those levels where they need them to be, provides challenges for the fish. 

Doug: Water quality is a big topic, and it's chemistry, really. And there does come a point when I'll struggle, but I can try. There's a long list of parameters that are relevant. And really, we're still discovering more. They're really just understanding how the mucus layer over the skin of fish works and how it interacts with microbiome in the water. And there's just – it's complicated and there's a lot. But also, we should recognize that we're still discovering more. But generally, people recognize oxygen, ammonia, carbon dioxide, pH, and temperature as the most critical aspects for fish welfare. 

If they don't have those things, well, in terms of oxygen, many of the effects we would recognize from ourselves, actually, or other animals. If you have not enough oxygen, a fish will have the same problems. Then just the other side of that coin is too much carbon dioxide, it will poison you. And it's exactly the same in a fish as it is in you. 

And I think ammonia is highly toxic. We get rid of it in our waste products. And I think, you know, an issue here is that in a terrestrial environment, your waste products will at least fall on the floor. And it's quite easy to design things so they drain away, and you can control that. But when you pee into water, it just joins you all around, and it's going through your gills, and it's, you know, it's become part of your environment that you're breathing. And so, there's much higher risk of poisoning. 
With pH, again, it is similar to us, it's acidic. But again, the water around the fish is playing so much of a role in its life and balancing salt levels. There's so many interactions and things going on that are affected if the pH isn't right. 

And temperature, yeah, I'll say it's the same as us. Again, maybe fish have variation from species by species, but they maybe have a lower temperature range that they can be sort of comfortable and operable in than we are. And fish are cold blooded, so they cannot, almost all of them cannot do anything to adjust their body temperature. So, they're just dependent on their environment. And that can mean that they're dependent on moving location to get warmer water or cooler water if they need it, which is what they do. But they can't do that in a fish farm without pain. 

James: In terms of understanding the kind of the markers of stress or poor welfare in fish, where does that come from? I feel like in terrestrial animals, maybe you can measure cortisol, you can measure stress in other ways, or whether it's body temperature. How would you actually understand what causes poor welfare in fish. 

Doug: It is actually measured in terms of hormones and chemistry, really all the same ways as with a terrestrial animal where we look at cortisol and others. A massive challenge we face is the behavioural aspects and understanding how fish behaviours change when they are stressed. Whilst we can look for that in other animals, we don't have the knowledge yet to know when a fish is behaving stressed. We're getting some examples, for sure. But in general, our knowledge on that is very thin. And we're often left to observe for a change from the normal behaviour or a change from the expected behaviour. Fish farmers use that, and that will indicate to them that something's not right. But we're not well equipped with that toolkit. 

Amy: So we've spoken a bit about conditions during their life. And then, of course, there is a capture and slaughter or death process. Can you talk us through some of the welfare challenges through actually draining the fish from these ponds, and then also through to how they eventually kill and process the fish for transporting them through to consumption? 

Doug: Several days before harvest, they'll start to withhold feed from the fish for two reasons. That's done not just at harvest, but before handling procedures, or treatments, or other reasons that fish are collected and moved, or done something to, or transported. So, farmers hold back food for several days so that their gut and intestines are clear, so that there's no food processing through them. And that is because they're going to be confined in small amounts of water, they're going to be put in a tank to dry, or they're going to be held here so you can do something to them, and it's so that their metabolism drops and their energy and activity levels drop, and they're not excreting ammonia into the environment. So, first of all, after getting fed regularly to fatten them up and get them to eat as much as possible, they suddenly get their food withheld for several days.

And then they'll be crowded. And depending on the shape of the pond or another common production system – especially in Europe there is something which we call a raceway. It's a long, thin, concrete pond. And then you put something like a net or a grid in and you move it along, and the holes are smaller than the fish. So, you crowd the fish into a small space, and then you can either pump them out of there or you they use nets to lift them out. So, then the crowding process is, you know, you can see the fish respond to this. The more tightly they're packed, they'll change their swimming behaviour. 
So, normally they'll perhaps be swimming and as a group, depending on what species it is. And then at a certain density, that'll break up, and they just start independently doing their own thing. And then the swimming speed increases, and some of them start to roll and you see their backs rolling out the surface. And then it gets more and more frenzied until it is, it looks like boiling water, and it is sort of vigorous escape attempts, we would say. And there's really no need to crowd fish as tightly as that. It's one of these sort of low-hanging-fruit, easy changes we'd like to see: less crowding and taking the fish out without reaching that stress level. 

Amy: And why are they crowding the fish? What's the benefit? Just to have them so it's easier for them to extract them from the pond? 

Doug: Absolutely, yeah, exactly that. So, whether you're using a net or a pump that takes water and fish at the same time, you know, you need to bring them all into one place so that you can do that operation and lift them out. Yeah. And when they use nets, usually there's no water in the net, the fish at the bottom are very crushed, they're getting injuries from the knots in the net and abrasions. And a fish is used to having its body weight supported in water. And when it comes out into air, just the sort of pressure from just that will be such a different environment. And then you get all these other fish heaped on top of you. Definitely not a good welfare experience. It's much better to pump them in water, but you need to take a lot of care to use a design of pump that doesn't cause physical injuries to the fish. 

And then you may be transported or brought straight into a processing plant. And, well, it varies by species but the most common killing methods are asphyxiation in air or on ice, or evisceration and cutting out an artery or the gut of a live fish. Those are the most common killing methods. The salmon producers have adopted stunning technology over the last 20 years. It's really standard. So those fish, they'll have all the same procedures until they come into whatever the facility where they're going to be slaughtered is. And then there are electrical stunning systems, and there are percussive stunning systems, automated, and they do large numbers of fish. And there are also sort of manual approaches. Some trout sectors do that. There are a few other examples where that technology is used. But certainly, the vast majority of farmed fish die from asphyxiation. 

James: How long do the fish tend to live in these farms? What is the average span of time to actually go from birth to slaughter for maybe a few of the common species? 

Doug: Great question, because it's much longer than for a lot of terrestrial animals. A small trout could be as young as a year old. It could easily be a two-year-old fish. A salmon will often be four years old. It could be older. A lot of salmon are four years old when they're harvested. 

James: Is that just because it takes them that long to reach their full adult stage and full slaughter weight? 

Doug: So, slaughter weight, yes, but not adult stage. Most farmed fish are harvested as teenagers: biological juveniles, pre-sexual maturation. Usually, the fish farmers will seek that because it's using a lot of energy to do biological processes other than growing flesh. So, there's all kinds of tricks and manipulations to keep the fish juveniles. I think it would be hard to think of any that are under a year old. I think two years is probably a good average. In warmer countries, where the water's warmer, fish will grow a bit faster. And again, you might be back to one-year-old again. 

Amy: Such a mammoth topic, and, you know, not only just so many different species, but then so many different, very complex seeming challenges that they face. Even just one of the sections of water quality alone, you know, very challenging. Not a lot of information, I assume. As you were saying, we're only really just starting to look more in depth into this topic. For fish, do those conditions that you've described, differ much across species or generally, are those sort of the main bulk of challenges that most fish will face within their lifetime? 

Doug: Unfortunately, the answer is that there is huge diversity. A fish in an earthen pond could be quite close to a natural environment. You touched earlier on tanks, indoor tanks, and these are often recirculating aquaculture systems, where the water is almost chemically sterilized, the environment is completely sterile and it’s just flat surfaces and water in a cage. The fish are then exposed to whatever the environment just passes through the cage. But yeah, the diversity we often talk about between species, I've just exampled between systems there, and, you know, species have different needs whilst systems have different challenges. Systems are used to produce more than one species, hugely complicated, hugely quickly. 

Amy: Can you just give us an understanding and perhaps an overview of the number? And I know that will be difficult, but how many fish are farmed? Whether you have that context in just like the EU or globally, how many fish are farmed for consumption? 

Doug: Sure. I don't have it on the top of my head, but thankfully I can look up fishcount.org.uk very fast, who've done a great job of estimating this over the years. Between 50 and 170 billion farmed fish slaughtered for food globally every year. And it's sometimes a bit unhelpful terminology, but we talk about how many are slaughtered every year. And because of exactly what we just discussed: that they're maybe four-year-old fish, or maybe on two years old. If you want to know how many fish are on a farm at any one time, it's maybe double that. 

Amy: And because so many are killed in the production cycle, I think I heard somewhere it was like maybe half of the stock won't make it through to slaughter. Is that correct and do those numbers you mentioned include those fish that are killed accidentally or due to poor water quality or other things during the process? 

Doug: There is only relatively poor data on this and there's really not a lot of transparency over mortality rates in agriculture, but some reference points that come to mind are the big salmon producers who publish their mortality data in Norway in recent years, and typically I think it's been around 15 or closer to 20% have died during a production cycle. But that is once they're on the main farm but there'll be a separate hatchery. And, Dyrenes Alliance and an NGO in Norway had a good look into the hatchery sector and found about the same percentage was dying in hatchery before they got onto farms. So that's a huge number. There are publications on sea bream in the Mediterranean that, again, had sort of 15-20% mortality rates. The Aquaculture Stewardship Council have got a consultation open at the moment on standards, and they looked at putting thresholds on how much mortality would be allowed on a species-specific basis. And they came up with a number for only one species, but it was Pangasius, and they said that they put a limit on 20% to be certified as, I guess, a high-quality sustainable producer. 

Amy
The numbers just seem crazy, considering how many are actually being farmed. And then we're allowing like, 20% of that to potentially not even make it to the consumer. Completely incomprehensible numbers. 

Doug: And that could be a fish that you've fed every day for two years or other fish that you caught out at sea and then it never even gets harvested. It's pretty incredible. 

James: The public, I think, aren't necessarily aware of that. Some of these fish are carnivorous. I think salmon is a good example. And so, like any carnivorous animal the feed efficiency isn't always perfect, so they need to eat, like, several orders more of other animals to have, like, a kilo of gain for themselves. So, I guess there's lots of – wild caught fish are being also fed to farmed fish, like farmed salmon. Is that right? 

Doug: So almost all farmed aquatic animals are carnivores, and the aquatic environment has lots of carnivores that are low trophic species, and we really need to do a lot to move towards them. Carp's a low trophic species through shellfish, but – farming carnivorous species comes with problem after problem. But even before we touch more on that, these fish (because they are carnivores) normally want to chase other animals and catch them, and so they have all kinds of body strength and behaviours around that, and just so many problems with containing them in a unit and so there's a lot of different reference points for these figures, but, yeah, basically, a fish has to eat a lot of fish to produce one kilo of fish. 
It's a very expensive input for producers, and the industry has spent a lot of money and focus on trying to get that fish, those fish products, out of the feeds. And when a species comes into aquaculture, it'll be a major research focus, and their feed formulation will change over the years. But that has come with all kinds of problems. Salmon's one of the most advanced, technically advanced systems, and so a lot of examples are coming from here, but there were a lot of problems with malnutrition causing deformities and growth issues because these new feeds they were formulating were just not meeting the needs of the fish. And you may not be feeding them fish out of the sea anymore at the end of that process, but you need a very high-quality vegetable protein to produce something that is an equivalent or replacement to animal product. So, you have to grow a lot of soy and you have to use a lot of energy to really refine it and produce these feeds out of it. So, yeah, it's really not helpful. 

Amy: It's the same challenge we know for raising a cow, right. For every kilogram or so of beef, the amount of soy or other plant product that's gone into that animal just to produce and kill them could be feeding others. It's the same.

Doug: Yeah, it's the same. But then that cow's low trophic: it eats grass. It would be the equivalent to farming lions and feeding them cows. 

Amy: Yeah. So, touching on something you said before about the animals being confined and then them having these kind of predatory characteristics, obviously carnivores. Is there the same kind of challenge that we see with hens where they're confined and stressed, and then they start feather pecking and sort of attacking other birds? Is it those same challenges in the environments for fish? 

Doug: So I'm not familiar with the hen pecking example, but as you describe it, yes, absolutely. That's happening in aquaculture. And so, in terms of predatory behaviour, a lot of species are or can be cannibalistic. And something that's completely standard for many aquaculture species is that they repeatedly size-grade the fish. So, they crowd them, take them out of water, they put them maybe through a machine, and they're keeping fish of the same size in units to prevent that behaviour, because if within a species, the fish will try and establish dominance hierarchies, depending on how much space they've got. And yeah, it's completely standard to break all social relationships and hierarchies by repeatedly changing and moving the fish so that you don't have these size disparities. 
Other examples can be found in salmon aquaculture, where cleaner fish, another species, are stocked in with the salmon to form functional eating parasites; the salmon will predate on the Cleaner fish and Cleaner fish are really, I think, an interesting example where aquaculture wanted not the flesh of a fish, but they wanted the behaviour of a fish. And they pretty quickly managed to do a lot of research into what environmental enrichment that fish needed to live happily and behave like. So now these cleaner fish get hides, get fake seaweed, and they get this, and they get that. So, it's interesting to see. 

Amy: So, it's possible, when it's of a benefit to the farmers and what they need that environment to be, but they're not as interested in an environment beneficial to healthy behaviour when it's just about the welfare of the fish that they're breeding, right?

Doug: Absolutely. Yep. Also, with salmon and trout, there's often been issues with damage to fins and sometimes that's probably aggression. Maybe when too similarly sized or they are feeling like they don't have – they're getting territorial and they will attack, bite. It's actually not unusual to see physical damage. If you see a whole trout in supermarkets, it's not unusual to see bites out of the fin or other lesions on the body. 

James: You've spoken about the various different issues that we have with fish welfare, whether that's water quality, which itself is made up of a few things like oxygen and carbon dioxide and ammonia, and also stocking density. But I guess out of that, do you, or do we have a good sense of what are the top priorities in terms of how do we actually help fish? So, if there is an equivalent of cages for hens, or breed for broiler chickens and anything of that sort.

Doug: We need to start by just touching on something I commented on before, which is that the knowledge gaps we still have are enormous, and that's especially true when it comes around the behaviours of the animal and how to provide a positive experience for them. So, I'm going to answer some top priorities out of the knowledge base that we have, but I think we have to remember that probably the most important things to achieve for adults to have a good life. We're just getting glimmering insights and we've got a way to go. Before we could define and describe how to provide a good life for fish on a farm. 

Amy: I think that's actually really interesting, Doug, because a lot of what we talk about with fish is like just getting them to the point of survival, right? We're not like – they're not things that would help them to thrive like enrichments or I think like colouring the tanks or the lighting, or maybe pockets for them to be able to hide and express these more kind of natural behaviours. Like all we're talking about at the moment and within sort of fish welfare is those real basics of just like staying alive through to the point that they're going to be slaughtered. So, I think that's such an important point that we're really so far from understanding all of these different species and their needs. 

Doug: Yeah. And I will connect the positive to survival as well. I think maybe we have quite a focus on technocratic things we can do. They're engineering solutions or they're familiar and we can draw quite direct connections from them to maybe health outcomes or other measures. With fish, their immune systems are much more vulnerable to stress than most terrestrial animals. And them meeting their behavioural needs can equally stress them as mishandling them or an environmental issue. We've got something that you should be doing. And amongst that, you know, we've touched on water quality and stocking density. And I'll say again, I think handling is a real low hanging fruit where changing attitudes, redesigning equipment just because you're now thinking about reducing the chances of fish getting injured or damaged or minimizing the time out of water. 
There's so much that can be done. Breeding programs can have so much impact. And I think it's somewhere where we could put more focus to having stronger and more robust fish in production systems. I think there's been a lot of focus on producing fast-growing fish. And I'm especially concerned that recycling aquaculture systems are taking over the hatchery sector and increasingly producing juveniles for all other sectors. And that's happened mostly in the salmon sector. And what we're now seeing there is they're keeping those fish and growing them larger on land before they put them out at sea because they need to reduce the time they're out to sea because they can't cope and they're just dying. So, producing robust fish should be more of a focus. 

And slaughter – I mean the technology is there, it's technically proven; there's large companies selling the equipment; it's completely available; we've done economic analysis; the European Commission has done economic analysis, completely affordable. There really shouldn't be any challenges to improving slaughter practices in terms of the cost of equipment, at least through production in western countries and for western markets. But then there's also cheap and manual methods for effectively stunning fish. So, slaughter, yeah. 

Amy: So, in terms of the real kind of challenges of advocacy with fish, we've spoken about just the real lack of the literature on this topic. Obviously, such breadth of species, the amount of individuals that we're talking about, the conditions being difficult…What, in your opinion, are those kind of main challenges of working on fish from an advocacy perspective? 

Doug: An overarching issue is that it's a very crowded field for people's attention and people's affections. And that goes, I think it probably goes amongst advocates, it goes amongst civil society, it goes amongst retailers. I guess as yet, perhaps civil society has not shown itself so actively and has not demonstrated how important it is to advance on the topic. 

James: You kind of mean something like, most animal groups or retailers will only focus on one key issue at any one time, whether that's something like cage-free for layer hens, is that kind of what you mean? So, there's almost some kind of like, people can only have one major issue in their mind at some time or focus on one major issue. And that means it's hard to work on other things that are not that…

Doug: Not necessarily one issue, but a limited capacity for issues. And so, we'll have to prioritize. There's the change in the last years about the recognition of fish welfare in civil society and amongst producers and it is like night and day. Seven years ago, it was not necessarily considered a very legitimate topic in lots of circles. And now I think there's genuine awareness and recognition of the importance. So, I don't doubt that it's coming, and things are moving fast, but it's definitely a challenge. 

Amy: It surprises me with those high mortality numbers that you touched upon previously, that there isn't more motivation from the industry and from producers to improve the lives of fish just basically based on numbers and, you know, losing stock, essentially. Is it just kind of standard practice that's just a write off and a part and parcel of raising fish? Or do you think there is some helpful motivation there that producers would also like to improve those mortality rates? 

Doug: Certainly, fish farming is a high-risk endeavour and when you go to Asia where maybe there's more smaller producers – or maybe that's just some experience I've had for a smaller producer: it's a common experience that unfortunately they have a mortality event and then to be the end of the business, they owed a lot of money for the feed, so that is a normal risk they have taken and it goes wrong for lots of people all the time. And yeah, so standard practice.

James: By mortality event you mean like all the fish in a pond will die or what does that mean? 

Doug: Yeah, so as mortality rates then, I've had in mind sort of sector-level and averages over production. But in that example, I mean, you know, it's not uncommon for a whole pond or a whole production cycle to die. I also think relevant here is how young and recent the aquaculture sector is; that a lot of species that we're farming now weren't even being farmed 15-20 years ago. The cages are changing, the way of controlling water is changing – that constant change and evolution is what is in the mindset of a fish farmer. They are often risk takers and innovators and engineers and biologists and chemists. I think those are mindsets of: “We're building and we're creating things here. We're making an omelette and we're smashing eggs all over the place and that's how you make omelettes.” Probably they're motivated to improve and there is a drive to improve but also a recognition that they're keeping undomesticated animals in a system they invented themselves. There's a quote that somebody might regret giving, that you have to kill a million fish before you know how to operate a recirculating aquaculture system, that was just so joyously said to demonstrate the knowledge, generation and rate of progress. 

James: In terms of some of the kind of promising interventions or ways that advocates are helping fish now, or that could kind of help fish in the future, what does the landscape look like? Because I'm aware of a few different things, whether it's working with producers maybe more collaboratively to help implement some of these high-welfare practices; there is working with certifiers; there’s the work you do, which is more legislative, obviously; there's also corporate pressure campaigns potentially. Do you have a sense of, within these, what's working well and how it's been going over the past few years? 

Doug: Basically, when I think of a sort of a traditional corporate campaigning approach, the work that Humanny Pokrok has done on having live carp sales ended in retailers in Slovakia stand out as that sort of corporate campaigning model of having successes. I think there's maybe more examples of not necessarily campaign work, but collaborations where NGO's found interested parties. And I guess the RSPCA standard stands out as a long-standing project of that sort of approach. And there were the standards produced in Spain as a collaboration between NGOs there, the sector, and ministry in Spain of taking this more collaborative approach, which is perhaps limited in ambition or scope. But I think maybe at the stage where we're at, where we're trying to establish shared factors so that with producers and retailers we can – even before defining what would be priorities, at least we can start to define what the issues are. I think that there's a lot happening and a lot can be done in that collaborative way. 

One of the side challenges we face due to the knowledge gaps is that perhaps many places where we do have knowledge, it's laboratory-based or from one location. And there's a lack of case studies or examples and disseminating of how to put that into practice. So, something I would like to see a lot more of, is collaborations with producers who already have some good practices and producing case studies describing that, that would be a great resource. Dyrenes Beskyttelse in Denmark have been busy –  

James: It's a tough name. We're gonna have to link that below because I don't know what you just said. [Laughing].

Doug: Sure, I'll happily provide a link and yeah, my pronunciation of it isn't good, I know that [Laughing]. But they're an NGO in Denmark and they've had a long conversation with producers there and with political parties and they've just had fish welfare commitments included in an all party-political manifesto. 

James: Wow! 

Doug: So, there was a process underway for domestic, legislative renewal there and here's this: all parties saying this is what we're going to pursue together. We've seen Gaia and Belgium recently making oppositions to local licensing applications for new fish farms, specifically recirculating agriculture systems and one of those has now been rejected. So, that's really interesting to see. I know we're talking, or at least mostly talking fish, but I don't know…I think you've had the Shrimp Welfare Project on another podcast and they're a really standout case of going from “dare I say nowhere” to “hard knowledge and implementation in production systems on the ground at such a high pace.” 

Amy: So, you touched briefly on the RSPCA standards, and I think I've definitely seen a rise over the last probably sort of ten years; seeing that fish is now being labelled certified this, certified that; there is consumer want for certification or to know that it's come from a sustainable source. How much of those kind of certification schemes would you think go far enough to really address those challenges that you've spoken about in terms of the fish welfare? And are they – I know there's specifically when it comes to farming chickens, there's quite a lot of criticism actually of the RSPCA kind of system not going far enough or being much more on the industry side than the advocate side. How does that work in the fish sector? What's your opinion on that? 

Doug: If things go far enough, we'll have to have different definitions of what's far enough. As we've discussed, we don't have the knowledge yet to say that certain fish that are having a good life. But if we were to say you're really implementing all the knowledge that we have, then RSPCA is at least close to that. It is probably the GAP standard and the Friends-of-the-Sea standard that are – especially probably the Gap One – are at a much higher welfare level, but perhaps too ambitious there. I think they're not actually available on the market. 

James: Oh, wow. 

Amy: Okay. 

Doug: Maybe there's election here and trade-off and somewhere about where to draw the line. And then there are more established aquaculture labels that are not introducing welfare criteria and are not welfare-specific. And then they are sort of at different levels from each other, but they are a lower level of making best use of the science, you could say. 

James: Yeah, I think the Aquatic Life Institute does some good work here. I think I mentioned previously they have like a certified benchmarking scheme, and I think GAP are the first, the only certified to actually not use insect feed within feed for aquaculture systems. But yeah, I think working with certifiers seems to be a good way of ratcheting up kind of the best practices and kind of highlighting what the best thing should be. So, I'm kind of glad they're doing that work and hope it's going well. 

Doug: Basically, they've been – many of these labels, or several labels have existed for several years, and so they have established place and recognition amongst producers and demand from retailers. And so, they may have a very limited approach to pulling criteria and information into their standards, but what they pull in – they’re quite good at getting actions. 

James: Doug, you spoke about the limitation of maybe working collaboratively with producers in terms of that that’s a place where you can’t have too much ambition because you’re constrained by what the industry is willing to offer and what’s within their reasonable profits margin. Do you think we're at the stage where asking or trying to do more bold, ambitious things is not quite ready yet for fish? And actually, we should just take the little wins where we can work with producers, or low hanging fruit you mentioned around handling and stunning, or do you think there is some space where a group can do something that's a bit more ambitious in terms of what they ask for. 

Doug: I think of RSPCA again, who have huge market coverage, but it's just in one country. Just your comment made me think about the role that they have. Brand recognition in the country has really brought them leverage to push farmers further than other schemes have been headed. So, there's not really an option for a really high welfare fish. So, there's definitely scope to create that and have that somewhere. I think in terms of moving whole sectors or larger volumes of production, then, yeah, I think there's a lot of work to do with bridging the gap from knowledge to what that really means on a fish farm site and getting it implemented. And I think there's quite a few fish farmers who are genuinely interested in that. I think with working with them we can make a lot of progress on what's feasibly possible. I don't think we could do it now with a paper exercise, but we're well on the way to it. And I think there's definitely scope to hands and much higher welfare options around in the fairly near future. 

Amy: Pivoting then to some of your EU legislative work, and you said in your bio, having a role in supporting and coordinating communications for lobby work with 99 member organizations, which I certainly don't envy. That sounds like a huge headache and a lot of work to try and get people aligned on specific legislative topics within such a large group of organisations. But can you talk a bit about your role there and the EU legislation work that you've been doing most recently? 

Doug: We're a very happy family, 99 organizations and it's been such an emergent topic that we've just all been learning together and have come along in a fairly similar direction. Some other topics are maybe a bit more – organizations have come in with established objectives and hopes, expectations and things. So maybe on this topic it's been easier to always – or it's been easier to quickly come to the point where we're all sort of at the same point. So, the EU, it makes rules by – there's three main institutions that, this is where I'm at jargon risk here – so three main institutions, the European Parliament and the European Council, which is all of the separate member country governments together, and the European Commission, which is like a mix between civil service and cabinet, if that makes sense. So, they each have different roles and to produce rules, they all have the chance to edit the rules and they all have to agree to it before it becomes a final rule. So, to be a lobbyist in Brussels, we're always trying to get each of the three institutions to sing from the same sheet and to have the same sort of objectives and to try to have their processes line up. And that means meeting with MEPs in the parliament and they'll come to us with requests for information, or we'll identify relevant files and go talk to them and about what it could do and provide information that they can use. Similar, really, with the other institutions. 
The commission is quite technocratic, and it produces quite a lot of technical documents and it also has the role of drafting legislation in the first place and operating all kinds of agencies and mechanisms that support that. And again, it's about having meetings with them and letting them know what we want, sharing information with them. And it can also be about joining the dots between institutions, because as well planned as everything is, you know, the world's complicated and systems aren't perfect, and dots don't always get joined. And so just being in amongst the system can be very valuable. And the member states are really the most powerful of the institutions in the EU. So, if you can get them singing on a collective hymn sheet, it's kind of the most powerful thing you can do. 

James: Eurogroup is a kind of a coalition of these 99 member organizations. So essentially, are you trying to understand the priorities and what these groups want in terms of fish welfare? And then you kind of convey that to the various people you're meeting with, whether it's in the commission or the parliament? Is that kind of how your role looks? 

Doug: Yes, that's right. And I'll also twist and tweak it into whatever the policymakers are working on, because they may be doing – they may not have realized the relevance of welfare, possibly to something they're working on, or they – it's partly about deciding our own priorities and pushing them out there, but it's also about sometimes reframing them and chopping them up to pursue different bits and different places and making it fit the political priorities that have momentum and energy and focus where we can get things going. 

James: That's very topical with – in terms of political priorities, I guess, obviously the EU had this very ambitious bit of legislation for farmed animals and fish, and obviously this seems like it's not happening currently. And I guess, how do you feel about this setback in terms of progress, in terms of legislative work? And what do you see happening over the next couple of years in terms of maybe bringing this back or achieving something else? 

Doug: Personally, a bit disappointed. Seven years, step by step where it went up the graph and things were building and, you know, they've written a new slaughter regulation specifically for aquaculture and it's sitting in a bottom drawer somewhere. So, you know, it's so disappointing to have gone so far in the process, but it's. Yeah, it's in a bottom drawer, it's not in a bin. [Laughing]. So, it’s really – there's EU elections coming up in June and that sets a whole new political environment. And unfortunately, we're not overly optimistic about the political environment in Europe. And there's a lot more populism. There's a lot of attention going for the farming community at the moment. And so, it doesn't give us a huge amount of optimism. 

But the EU has gone a long way, as part of the EU's identity, almost as a standout animal welfare performer. In the four years of work where they've drafted a lot more than just a fish slaughter regulation, they did a lot of analysis of the old rules; they've done a lot of analysis of the economic impacts of making changes; they've done a lot of work on what those changes need to be; they've got official reports everywhere saying that the existing legislation is not being implemented properly, it has been work, it's not world-leading, it's 20 years old. So, there's a big challenge, a hot potato sitting there. We know that animal welfare is going to be an issue in the election and, yeah, we do need to wait and see what comes out of it. But it's hard to think that there will be more activity. 

Amy: When you say it's an issue for the election, as in it's going to be a topic that would have to be discussed based on the people that are elected or an issue as in perhaps that's going to set things back again because of these new people coming into power? 

Doug: I mean, I think it'll be significant to a significant number of voters. It's an important topic to quite a lot of people and it's pretty exposed how low some welfare standards are in European farming. I think I expect to see it come through from that perspective. It will be important to citizens and that will carry it to the new representatives. 

James: How do you balance that with – you mentioned this rising wave of populism, but also all these farmer protests have spread across Europe and they're also now in the UK and it seems like there's also lots of discontent there. They've done pretty well politically in some places, like in the Netherlands, I guess. Do you also feel that could kind of swamp some of the animal welfare concerns that most citizens do have. Just because farmers are a small but powerful part of the public, you know. 

Doug: So there's a sort of rise of the right and they've also traditionally been quite pro animal welfare groups. So, although we don't like the populism aspects and we're not feeling that there will be no animal welfare supporters coming into the parliament, you know, the problems that farmers are expressing and challenges that they are expressing are not really resolvable by existing framework; the common agriculture policy or the approach even to treating agriculture production as an isolated thing that can be looked after by itself. So, I don't expect to see the same pandering to the established and interests and funding and technical systems. I think that the demand for change that's a bit more systemic will be – it's just unavoidable. 

Amy: Thanks for that, Doug. I think that's been a really insightful episode. I know it's so much of a huge topic to cover, as you rightly said. I think we could have been here multiple hours talking about all the intricacies of the space and the advocacy efforts towards trying to help fish have these increased welfare standards. Yeah, hopefully it's been easy enough for everyone to follow, but I would encourage everyone to read up on the various resources that we link below from Doug and also some of the topics and organisations that we've spoken about in this podcast, checking out their fish work and supporting that as best as everybody can. 

But just to wrap up for today, so we'd love to know one bit of news that you're grateful for or excited about recently. 

Doug: Okay, I'm going to be greedy and take two, but I'll make them short. So, the EU has just set up, it's called Animal Welfare Reference Centre for aquatic animals. So, it is a consortium of universities and their job, and it's set up for seven years, their job will be to do technical work to support the implementation of legislation for welfare in agriculture. It was announced related to the legislative review and then the legislation was put on hold, but they went forward and established this centre anyway. So, I’m really delighted that that is now in the process of being set up and it will be busy for seven years. 

And another one on the common fisheries policy: nobody wanted to talk about welfare in that context and officials were refusing us meetings on it and we really worked hard and had in the end the member states saying that welfare has to come into the Common Fisheries Policy. And the parliament has now also officially said welfare has to come into Common Fisheries Policy and so has the commission that is responsible. So that's – it's groundwork stuff, but it will start to make a change. And so that's things that really keep me motivated and make me happy that things are progressing. 

Amy: Yeah, excellent!

James: Great, that's huge wind! I think despite some legislation not being passed, I wasn't aware there's still some things that just managed to get through anyway. So, I think that's a great win. And I think given your kind of thoughts and how little research there is, having this research consortium set up seems particularly valuable. So that's super cool!

Doug: And they're really – they're focused on connecting knowledge to implementation. 

James: Very cool. And in terms of recommendations you'd have for listeners, whether it's books, articles, videos, people to maybe either learn more about your work or just understand the world of fish welfare advocacy, or just anything you want to share; is there anything that comes to mind?

Doug: These will be no surprise to anyone in the field, but two books that are really fundamental and really helpful: Do Fish Feel Pain? by Victoria Braithwaite. It really goes through the fundamentals of how we came to know that fish were sentient and why we're so sure that they're sentient and what that means. And it really is a very accessible, enjoyable read. 

And then What A Fish Knows by Jonathan Balcombe is an incredible collection of intelligent and varied and different things fish do. So, for just inspiring stories and examples of what the world of 33,000 different fish species can do. And it's really a great read. 

And finally, I'll shamelessly do a bit of self-promotion, but there's a report that we produced together with Compassion in World Farming called Uncovering the Horrific Reality of Octopus Farming. And it is an expose because we got hold of the licensing application of the octopus farm that a company would like to develop in the Canary Isles, Spain. And we've talked about how fast aquaculture is evolving and some of the fundamental issues. And this is a real warning of how fast things can go in the wrong direction if welfare isn't made more prominent, you know. You can read in there about the sort of behaviours and farming conditions and how thin the knowledge base is to pursue a farming system like that. So, it's a warning of how important it is that we work hard and fast because aquaculture is developing hard and fast. 

Amy: And apart from reading that article, how can people get more involved in your work? Can you still apply to be a Eurogroup member? Do you have any volunteers that work or any open positions?

Doug
At the moment our members are all NGOs. Hop on our website, find our list of members and find the NGO local to yourself and in your country and join them. That's how you can join us, so to speak. Most of our members are in the EU. We do have a few more globally and if we don't have a member organization in your country, join your local NGOs. We're not recruiting for any positions at the moment, but if you would like to volunteer with us, please get in touch, send a CV and a note on your interests or what you might be able to do or something that helps us match you up to a bit of work we've got. We would be very pleased to hear from you!

James: This has been such an interesting conversation, Doug! I think we covered a lot and like you said, Amy, could have spent hours just on the details of earthen ponds versus recycled systems versus whatever. So, I think it's amazing we managed to cover as much as we did and we'll definitely link people to these resources you mentioned for further information. But, so to say, thank you for your work and seven years, a long time to be working on things and I guess we're all waiting, fingers crossed, hopefully when things will be revitalized for EU legislation. But yeah, thank you for your great work!

Doug: Well, thanks very much for the conversation and for all the topics you're getting out on the podcast.