HomeMy WebLinkAboutCOM 1145.123 2012-2014COUNTY CLERK
COUNTY OF HAWAII
RECEIVED
Timer -lif PAI By
Date /%y
& QLAZUL
SAVING NEMO:
MARICULTURE AND MARKET -BASED SOLUTIONS TO
REFORM THE MARINE ORNAMENTAL TRADE
Bren School of Environmental Science & Management
University of California, Santa Barbara
A group project submitted in partial satisfaction of the degree
requirements for the Master of Environmental Science & Management
Team Members
Clara Cartwright Stephanie Horii I Niki Mazaroli
Amanda Nelson ( Kate Nixon I Ariadne Reynolds
Faculty Advisor
Steve Gaines
March 2012
Comm. Nr� - 123_
Ref. To: GV
Ref. Date 019 761
Y 4.w
sample size, we would be 95% confident that our estimate of the amount of money
that the total population of fish owners spent last year on fish was accurate within
$100.
( 1.96 x Q 12
ri — \Margin of error /
n = (1.96 x 724.27 2 224.39
l 7_
loo )
We continued collecting data until we gathered at least 225 survey responses. Our
final number of survey responses was 232. The survey can be found in Appendix C.
Results for consumer survey
Our consumer survey analyzed U.S. consumer preferences and willingness to pay for
captive- raised or wild - caught marine ornamental fish. We used the results from our
survey to explore the potential for a mandatory warranty, which would be a novel
economic strategy that might reform the supply chain.
Warranty analysis
Cyanide fishing has been widely documented as a common fishing practice in the
Coral Triangle, and it has been estimated that at least 70% of fishes sold for marine
aquariums were caught using cyanide (Mak et al 2005). Fish exposed to, cyanide
suffered from chronic toxicity due to exposure (Mak et al 2005). Many of the effects
of cyanide were irreversible, so even if a fish was given the best possible care after it
was caught, cyanide- induced mortality might be unavoidable (Mak et a12005).
Additionally, fish faced other stressors from the supply chain that increased mortality,
including variable temperatures, salinity, oxygen, and pH levels, being jostled during
transport, and being shipped in overcrowded packing materials.
Based on the information gathered from our survey, approximately 80% of mortality
that occurred after fish had been purchased could be attributed to problems in the
supply chain. Reducing these sources of mortality could reduce the number of fish
needed to meet consumer demand, therefore reducing the number of fish harvested
from the reef. Additionally, according to our survey, 28% of all fish sold were
replacements for fish that had died within a year. In the marine aquarium trade, a
significant amount of sales have been made because customers were unknowingly
buying a damaged product.
As the market currently stands, stores (and suppliers) have no incentive to change
their practices, because each level of the supply chain is profiting from customers
25
buying fish to replace a significant number of fish that die in home aquaria. Stores
suffer fish losses before the fish are sold, but the profits made from customers buying
replacement fish are high enough that stores do not have incentive to purchase
healthy fish to avoid fishes dying in stores. One option for a simple, top down
legislative solution to reform the marine aquarium trade would be to implement a
mandatory warranty for all vendors in the United States.
A warranty would address two problems:
1. A warranty would provide consumer protection against buying (and then
paying again to replace) an inferior product.
2. A warranty would provide a simple, top down solution to motivate stores to
only purchase from suppliers that do not use harmful collection or handling
practices throughout the supply chain.
A warranty would only be an effective tool if stores lost money with a warranty in
place. When facing an expected loss in profits, stores would have an incentive to look
for alternative ways to make money. Stores could regain some of their losses if they
reduced the number of fish dying in customers' homes by purchasing sustainably
sourced fish. If a mandatory warranty provided a financial incentive for stores to
reform their supply chain, a warranty could be a simple, effective tool to promote
change.
Methods for warranty analysis
To run a warranty analysis, we first had to consider the current state of the market and
how the revenue and costs would change if a mandatory warranty were implemented.
For this analysis, we only included costs and revenues directly related to fish sales.
We did not include fixed costs of maintaining and running a store, which we assumed
were constant and not directly related to fish sales. After analyzing how a store's
costs and revenues would change with the implementation of a mandatory warranty
under current practices, the final step was to calculate how the costs and revenues
would change under a mandatory warranty if all fish supplied to stores were
sustainably sourced.
In order to run this analysis, we used the following equation to represent the revenues
and costs of fish - related sales for U.S. stores:
Total Profits Related to Fish Sales =
Customer purchase price — Store's initial investment in fish +
Expected future replacement sales — Costs of in -store mortality
With a warranty, we could use the same equation except stores could charge a price
premium for a warranty, and stores would have to pay the costs of replacing fish
26
We were interested in detennining how many fish are expected to die after two weeks
(the amount of time we assumed fish stay in stores before they are sold) from
problems in the supply chain. In order to determine the mortality due to supply chain
error, we ran an analysis using only responses from "experts," (survey respondents
with five or more years of experience) to find the cumulative mortality over time due
to problems in the supply chain. To find the mortality rates per day, we used the
following equation for each separate time interval (0 -3 days, 4 -7 days, 8 -14 days, 15-
30 days, 31 -180 days):
Dt =1 —` 1 —Mt
Mt = mortality rate at day t
Dt = mortality rate per day at day t
We then used the per -day mortality rates to find the cumulative mortality through 14
days using the following equation:
I: 1,14Dt * (1 - Dt -1)
We found that 11.3% of fish are expected to die within 14 days due to problems in the
supply chain. Stores make an initial investment of $0.3774 for each dollar's worth of
expected fish sales, so the overall losses to stores are 11.3% X $0.3774 = $0.0427. We
realize that in -store mortality may vary greatly from store to store, and for this
analysis we chose to assume that fish remain in stores for two weeks on average
before they are sold. See Appendix F for a chart of possible losses to stores under
varying turnover rate scenarios, including a range from a 1 -day turnover to a 2 -month
turnover. We now had a complete picture of all revenues and costs related to profits
from fish sales under the current market.
32
Appendix G
Species used in supply chain analysis
Species
Common name(s)
A budejduf vai iensis
Common sergeant / Sergeant major damselfish
Acanthurus leucosternon
Powderblue sur eonfish / Powder blue tan
Acanthurus lineatus
Lined sur eonfish / Clown tan
Acanthurus maculice s
Sot -face surgeon / Maculice s tan
Acanthurus ni ricans
Whitecheek surgeonfish / velvet surgeon / Powder brown tan
Acanthurus olivaceus
Orange-blotch surgeon / Oran eband surgeon / Orange shoulder tan
Acanthurus vro erus
Mimic sur eonfish / Chocolate tan
Am hi rion clarkii
Yellow -tail clownfish / Clarks clown
Am hi rion ephippium
Red saddleback anemonefish / Saddle anemone
Am hi rion ocellaris
Clown anenomefish / Ocellaris clown
Am hi rion percula
Orange clownfish / Percula clownfish
Am hi rion polymnus
Saddleback clownfish / Black saddle clown
Am hi rion sandaracinos
Orange anemonefish / Orange skunk clown
A olemichthys trimaculatus
Threes of angelfish / Fla fin angel
Bodianus diana
Diana's ho fish
Bodianus mesothorax
Mesothorax ho fish / Black belt ho fish / Eclipse ho fish
Centro v e bicolor
Bicolor angelfish
Centro e e bis inosus
Coral beauty angelfish
Centro v e eibli
Eibl's angelfish
Centropyge loriculus
Flame angelfish
Centro v e nox
Midnight angelfish
Centropyge tibicen
Keyhole an elfish
Centropyge vroliki
Pearl scalleed angelfish / Half black angel
Ce halopholis cyanosti ma
Blues potted hind / Blue spotted grouper
Cetoscarus bicolor
Bicolor Parrotfish
Chaetodon auri a
Threadfin butterfl fish
Chaetodon bur essi
Cirton butterfl fish / Burgess butterfly
Chaetodon kleini
Brown butterfl fisb / Klein's butterfly
Chaetodon lunula
Raccoon butterfl fish
Chaetodon melanotus
Blackback butterfl fish
Chaetodon meveri
Scrawled butterfl fish / Meyer's butterfly fish
Chaetodon raj Ilesi
Latticed butterfl fish / Rafflesi butterfly
Chaetodon reticulatus
Reticulated butterfl fish s)
Chaetodon reticulatus
Reticulatid butterfl fish m
Chaetodon tri ascialis
Chevroned butterfl fish
Chaetodonto lus melanosoma
Black velvet angelfish / Grey oma
Chelmon rostratus
Chelmon butterfly fish / Copperband butterfly
Chromis margaritifer
Half & half puller / Bicolor chromis
Chrysi tera cyanea
Sapphire devil / Blue damsel
Chr si tera parasema
Goldtail demoiselle / Yellowtail blue damselfish
136
Chrysi tera talboti
Talbots damsel
Cirrhilabrus cyanopleura
Red-eyed wrasse / Blue sided fairy wrasse
Coris qvgula
Clown coris
Coris gaimard
Yellowtail coris / Canary wrasse / Gaimard wrasse / Red coris wrasse
Dasc llus trimaculatus
Three of dasc llus / Domino damsel
Dor rham hus dactvlio horus
Ringed pipefish / Banded pipefish
Forci i er lon irostris
Longnose butterfl ish / Yellow lon nose butterfl fish
Gom hosus varius
Bird nose wrasse /Bird wrasse / Brown bird wrasse
G mnomuraena zebra
Zebra mores
Hemi vmnus melts terus
Half & half wrasse
Hemitaurichth s potylepis
Pyramid butterfly-yellow
Hippocampus erectus
Lined seahorse
Labroides dimidiatus
Bicolor cleaner wrasse
Meiacanthus atrodorsalis
Forktail blenn
Naso ele ans
Naso unicorn / Blonde naso tan
Naso lituratus
Oran es ine / Orange-spine unicornfish / Naso tan
Naso unicornis
Shortnose Unieornfish / Unicorn tan
Nemateleotris ma ni ica
Fire goby / Firefish goby
Novaculichth s taeniourus
Dragon wrasse
Odonus ni er
Redtoothead tri erfish / Niger trigger
Ostracion cubicus
Yellow boxfish / Yellow cubicus
O momacanthus lon irostris
Harlequin filefish / Orange spot file
Paracanthurus he atus
Blue tan
Para Ivphidodon melas
Royal damsel (m) / Bluefin damsel
Paru eneus c clostomus
Yellowsaddle goatfish / Yellow goatfish
Platax pinnatus
Pinnatus batfish
Plectorhinchus chaetodonoides
Spotted grunt sweetli s / Harlequin sweetli s ! Spotted sweetli s
Plectorhinchus orientalis
Oriental sweetli s
Plectroglyphidodon lacrymatus
Jewel damsel
Pomacanthus im erator
Em pc angelfish / Im erator angel
Pomacanthus navarchus
Majestic angel
Pomacanthus semicirculatus
Semicircle angelfish { Koran angel
Pomacanthus xanthometo on
Blue -faced angelfish f Blueface angel
Premnas biaculeatus
S inecheek anemonefish / Maroon anemonefish / Maroon clown
Pseudanihias pascalus
Purple queen / Purple queen anthias
Ptera o on kauderni
Banggai cardinalfish
Ptereleotris evides
Blackfin dartfish / Scissortail goby
Pterois antennata
Broadbarret firefish / Antennata lion
Pterois radiates
Radial firefish / Radiata lion
Pterois volitans
Lionfish / Red lonfish / Volitan lion
Pv o lites diacanthus
Regal angelfish
Rhinecanthus aculeatus
Blackbar tri erfish / Humu humu trigger
Zebrasoma des'ardinii
Palette sur eonfisb / Des'ardinii sailfin tan
Zebrasoma avescens
Yellow Tan
Zebrasoma veli erum
Sailfin tan
137
§711 -1109 Cruelty to animals in the second degree. (1) A person commits
the offense of cruelty to animals in the second degree if the person
intentionally, knowingly, or recklessly:
(a) Overdrives, overloads, tortures, torments, beats, causes substantial bodily injury to, or starves any animal, or
causes the overdriving, overloading, torture, torment, beating, or starving of any animal;
(b) Deprives a pet animal of necessary sustenance or causes such deprivation;
(c) Mutilates, poisons, or kills without need any animal other than insects, vermin, or other pests; provided that the
handling or extermination of any insect, vermin, or other pest is conducted in accordance with standard and acceptable
pest control practices and all applicable laws and regulations;
(d) Keeps, uses, or in any way is connected with or interested in the management of, or receives money for the
admission of any person to, any place kept or used for the purpose of fighting or baiting any bull, bear, cock, or other
animal, and includes every person who encourages, aids, or assists therein, or who permits or suffers any place to be so
kept or used;
(e) Carries or causes to be carried, in or upon any vehicle or other conveyance, any animal in a cruel or inhumane
manner;
(f) Confines or causes to be confined, in a kennel or cage, any pet animal in a cruel or inhumane manner;
(g) Tethers, fastens, ties, or restrains a dog to a doghouse, tree, fence, or any other stationary object by means of a
choke collar, pinch collar, or prong collar; provided that a person is not prohibited from using such restraints when
walking a dog with a hand -held leash or while a dog is engaged in a supervised activity; or
(h) Assists another in the commission of any act specified in subsections (1)(a) through (1)(g).
(2) Subsection (1)(a), (b), (c), (e), (f), (g), and (h) shall not apply
to:
(a) Accepted veterinary practices;
(b) Activities carried on for scientific research governed by standards of accepted educational or medicinal practices;
or
(c) Pest control operations conducted pursuant to chapter 149A by a pest control operator licensed pursuant to
chapter 460J, if the pest control is performed under a written contract.
(3) Whenever any animal is so severely injured that there is no reasonable
probability that its life or usefulness can be saved, the animal may be
immediately destroyed without creating any offense under this section.
(4) Cruelty to animals in the second degree is a misdemeanor, except where
the offense involves ten or more pet animals in any one instance which is a
class C felony. [L 1972, c 9, pt of §1; am L 1986, c 192, § §1, 2; am L 1998, c
173, §2; am L 2007, c 114, §4; am L 2009, c 160, §1; am L 2011, c 226, §1; am L
2013, c 210, §2]
Law Journals and Reviews
Cruelty to Animals: Recognizing Violence Against Nonhuman Victims. 23 UH L.
Rev. 307 (2000).
Case Notes
Constitutionality upheld. 61 H. 136, 597 P.2d 590.
.w.... / /__.__.__......:a../ A ntnTAI noee rtmon'7> > IF imo ^"A A Inn La.__fl i 1117/1hnt A n.nc.en A un
'f�it>r
WA Live Animals Regulations
2. PREPARATIONS BEFORE DISPATCH
There must be one species per bag
The inner bag must be filled with water to approximately
1/3 of its capacity, The remaining 213 of the container is
to be filled with oxygen Use of ice cubes or chemicals
such as methylene blue volume of water and the
amount of fish in the container are the shipper's
responsibility Carriers will not re- oxygenate fish ship-
ments unless by special prearranged agreement.
d Seahorses can be shipped in plastic bags as long as
they can anchor themselves to something in order to
minimize stress An anchoring substrate must be a
PVCmesh or similar substrate with multiple grasping
surfaces for the seahorse, placed inside the bag and
weighed down to the bottom of the plastic bag with
non - leaded weights_ The anchoring substrate must be
sufficiently weighted so that it remains in contact with the
bag bottom and does not move easily during transport.
Anchoring to another seahorse or any f e- floating
substrate is not acceptable. A recommended maxi-
mum of three animals of a length of 60 mm (or four of
45 mm) can be packed in a 250 -380 mm bag. If
shipment goes from warm to cold climate, it is suggested
to add a heat pack. Conversely, it seahorses are
shipped from cold to tropical climate. ice packs should
be used.
Aquatic amphibians can be shipped in the same manner
as fish, but as some of them are able to breath air and
will do so, the airspace above the water should consist
Of 50% pure oxygen and 50% normal air like in air
breathing fish. Pure oxygen can be detrimental to lung
tissue. Aquatic amphibians are not to be fed 2 days prior
of shipment to avoid fouling of the water.
The condition of fish and amphibians is directly affected
by.
310
the density, i,e the number of fish or amphibians
according to size in a given quantity of water,
temperature of water,
For tropical fish insulation must be provided by the
shipper within each unit to ensure a suitable temperate
of 20 °C (68 °F) for the longest possible period
Some species must be individually packed due to ther
sensitive reactions or aggressive tendencies.
Shippers must pack fish to survive unattended for sit
least 48 hours from time of acceptance by the airline
Mote:
For aquatic amphib /ans from tropical regions Irke Pi
p&
Typhlonectes, the temperatures should &
about 20T (68'F) For other species like Axoft, New
and Salamandar larvae, Andrus and Crypto&anchu.&
the temperature should not exceed 15°C (59 °F)
The shipper must clearly mark on the container the loss
time and the date at which the animals were packed
The shipper must indicate the acceptable temperature
range fin Celsius and Fahrenheit) on the outside of the'
box in which the animals can be stored.
3. GENERAL CARE AND LOADING (see Chapters S
and 10)
Animals must be held in areas where the ambient ear
temperature reduces the heat transfer to the absolute
minimum.
No consignment of fish must be accepted if the planned
ioumey exceeds 48 hours (unless life support is aval-
able) Consignments of live fish must be treated as
Perishable items and handled accordingly.
For the purpose of providing life support for aquatic
species during transport. a cylinder containing oxygen,
(compressed), UN 1072, packed in accordance with the
IATA Dangerous Goods Regulations, may be earned to
oxygenate the water with the approval of the appropriate
authority of the States of origin destination and of the
operator Refer to CR59 and CR60.
se annvk oerowR 2o,2
CONTAINER REQUIREMENT 51
The illustrations shown in this Container Require-
ment are examples only. Containers that conform to
the principle of written guidelines but kook slightly
different will still meet the IATA standards.
ppticable to:
Aquatic Amphibians
Cut-ul
Fish, n.o.s. (unless arrangements made for specialized
packing)
Goldfish
Octopus
Seahorses
Tropical fish
Water snail
OPERATOR VARIATIONS: JL -01, LH -02, QF -01
I. CONTAINER CONSTRUCTION
Materials
Water - resistant fibreboard, insulating material. ptastic or
wood, expanded polystyrene or styrofoam.
Principles of Design
The following principles of design must be met in
addition to the General Container Requirements outlined
at the beginning of this chapter
Outer Container
The outer container can be constructed of fibroiboard,
wood, wood products or any plastic material of adequate
strength. Purpose -built containers made of expanded
polystyrene or styrofoam must be of adequate strength
EXAMPLE:
Evan
Outer c
iz
Labels may I)e
imprinted on box
Contai r Requirements
Care must be taken to ensure no sharp edges or stapled
closings on the outer container punctures the inner
plastic bag, which expands from change in altitude.
Inner Container
Strong plastic (polyethylene) bag.
The bags are fastened by twisting the top and folding the
twisted part so that it can be sealed with elastic bands.
The bags may also be heat sealed
Warning: Neat- seated bags cannot be re- oxygenated in
the event of the consignment being delayed.
It is preferable that each bag is placed in an outer bag of
similar size to prevent leakage of water
Note:
States may require the physical inspection of the Carl-
tents of shipments tendered by shippers meeting a
specific state mandated criteria as determined by the
transporting carrier.
Spiny fish must be placed in an inner container of hard
plastic within a polyethylene bag or they may be
contained in an inner polyethylene bag separated by
several layers of paper from an outer polyethylene bag.
In such cases, both bags must be adequately sealed.
Insulation /Cushioning
Expanded polystyrene container or expanded poly-
styrene sheets on all sides including top and bottom. is
recommended. Alternatively, compressed newspaper,
woodwool or approximately 0.6 cm (% in) thickness of
newspaper or other fibrous material sandwiched
between two sheets of kraft paper.
Top wasted
and loo Plastic bag
(polyethylene)
inner container
Elastic bands — -►
yy Bap to contain
� 14 water
Fibreboard
outer container
of
insulation
sides, tup
and bottom labels may be
imprinted on box
1
61
SPC Live Reef Fish Information Bulletin #13 - January 2005 13
Monitoring the chain of custody to reduce delayed
mortality of net - caught fish in the aquarium trade
Peter J. Rubec' and Ferdinand P. Cruz2
Abstract
Information obtained from hobby magazines and from informants in the aquarium trade during the mid -
1980s indicated that marine aquarium fish had high acute mortality (50 %) on the reef due to capture with
cyanide, and had 30% mortality on average at each step of the chain of custody — from the village level,
through export facilities, to import facilities, and to retailers in North America. More recent data show there
is some reduction, although there continues to be high rates of mortality in the marine aquarium trade. The
scientific literature also demonstrates that fish experience cumulative stress from being netted, bagged,
crowded, and exposed to changes in pH, temperature, salinity, dissolved oxygen, light, and from the accu-
mulation of ammonium ion in the bags (which becomes toxic un- ionised ammonia when the bags are
opened). It is believed that with better capture methods (e.g. nets), as well as better handling and shipping
practices, it is possible to reduce the mortality at each step of the chain of custody.
It is difficult to obtain accurate marine fish mortality information regarding cyanide- caught fish because
those involved fear regulation and /or prosecution for dealing in fish captured by illegal means. Research
is needed (with marine fishes held in sealed plastic bags) to determine the range of environmental condi-
tions encountered during transport from exporting to importing countries. Research with freshwater fishes
has been successful in prolonging survival in shipping bags by adding chemical additives to inhibit the
proliferation of bacteria, neutralize excreted ammonia, buffer pH, and by sedating the fish to reduce their
metabolism. Similar research is needed with marine aquarium fish. We hope to demonstrate that with bet-
ter post - harvest care and handling it is possible to markedly reduce mortality rates of marine ornamental
fish during collection and transport.
Introduction
Plastic bags were first used by tropical fish
importers to package aquarium fish for trans-
port by air and /or in motorized vehicles in the
early 1950s (Miller 1956). Marine aquarium fish
were exported by Earl Kennedy from the
Philippines in plastic bags starting in 1958
(Robinson 1985). In 1962, Kennedy noticed
greater mortalities of marine aquarium fish in
his export facility associated with fish obtained
from collectors on Lubang Island, south of
Manila. He learned that the fish were being col-
lected with sodium cyanide. The marine aquar-
ium trade expanded in the 1970s, fuelled by an
abundant supply of cheap fish caught with
cyanide. Kennedy left the trade in disgust after
he accompanied air shipments and witnessed
high mortalities of the fish after their arrival in
the US. Dempster and Donaldson (1974), at the
Steinhart Aquarium, conducted histological
studies during the mid -1960s on marine fish
obtained from California waters that were
experimentally exposed to sodium cyanide. They
found damage to internal organs such as the liver,
kidney, spleen and brain. The tissue damage
matched that found in marine aquarium fish
imported from the Philippines.
Rubec (1986,1987a) summarized information from
various aquarium hobby magazines and from
sources in the industry concerning mortality rates
for marine aquarium fish in the aquarium trade. It
was estimated that 50% of the fish targeted with
cyanide died from acute doses on the reef, and that
there was on average 30% delayed mortality at
each step of the chain of custody. It was estimated
that the cumulative mortality through the four
steps of the chain of custody (from villages, to
export, import, and then to retail facilities) was
greater than 80 %, if one excluded the acute mortal-
ity on the reef (Rubec 1987b). Including the mortal-
ity on the reef, the cumulative mortality from reef
to retailers was estimated to be greater than 90 %
(Rubec and Soundararajan 1991). The papers sum-
marized evidence showing that delayed mortalities
1. International Marinelife Alliance, 28004th Street North, Suite 123, St. Petersburg, Florida, U.S.A. Tel: +1727- 327 -9226. Email: peter -
rubec @cs.com
2. East Asian Seas Initiative, Suite 205, CRS Tower, 1535 Perdigon St., Quirino Avenue, Plaza Dilao Paco, Manila, Philippines. Tel: +63
2- 561 -8335 loc 205. Email: ferdiecruz @i- manila.com.ph
4 SPC Live Reef Fish Information Bulletin #13 - January 2005
were associated with cellular damage and physio-
logicaI impairments resulting from exposure to
cyanide ( Rubec 1986,1987a).
However, there are those in the aquarium trade
who have maintained that the problem is not
cyanide, but that it is all "stress, stress, stress"
(Goldstein 1997). Goldstein cited a scientific study
by Hall and Bellwood (1995) in which damselfish
were experimentally exposed to 10 milligrams per
litre (mg L -1) cyanide for 90 seconds. He asserted
that high mortalities were associated with stress
and that the highest mortalities were associated
with fish that were both stressed and starved. He
stated that there was no evidence that anaesthetic
doses of cyanide caused either gut epithelial
changes or more mortality than occurred with net -
caught fish. Another assertion in Goldstein's (1997)
magazine article was that, based on the evidence to
date, net collecting did not deliver healthier fish
than collecting with cyanide. No evidence was pre-
sented. Rubec et al. (2001) discussed mortalities in
the aquarium trade and acknowledged that high
delayed mortalities of marine fish were probably
associated with a variety of factors, including
cyanide, stress, ammonia, oxygen depletion, dis-
ease, and starvation. It is necessary to consider all
factors influencing the fish in order to reduce mor-
talities occurring in the aquarium trade.
There are many factors that lead to mortalities of
marine aquarium fishes, including physical dam-
age and the use of chemicals such as sodium
cyanide during collection, inferior water quality,
poor handling, disease, and stress at all stages dur-
ing collection and transport (Wood 2001; Wabnitz
et al. 2003). Sadovy and Vincent (2002) stated that
mortality levels in both the live food and live
aquarium fish trades range from a few per cent to
80% or more for cyanide- caught fish and /or where
poor capture, handling and maintenance practices
produce stressed animals. The source of the mor-
tality, however, is not always clear.
The problems that must be overcome for the suc-
cessful transportation of live fish are many and
diverse (Norris et al. 1960; Fry and Norris 1962).
The primary problem arises from the water's low
capacity for oxygen, together with its low capa-
bility to dissipate the end products of fish
metabolism. The secondary problem is that of
handling. In delicate species, abrasion needs only
to remove the mucus from a fraction of the area of
the skin in order to rob the fish of essential pro-
tection from osmotic stress. In addition, many
fish are so stimulated by handling that they read-
ily accumulate dangerous levels of lactic acid in
their blood. Excessive changes in temperature are
also deleterious.
Scientipc studies to determine factors causftu
mortality
Hanawa et al. (1989) studied the response of hum-
bug damselfish (Dascyllus aruanus) to cyanide.
Groups of 10 humbug damselfish were dipped into
several concentrations (25 or 50 mg L-9 of cyanide
ion (CN -) for either 10, 60 or 120 seconds (s); mortal-
ity was measured within 96 hours. Test damselfish
exhibited no mortality after being dipped in 25 mg
L-1 CN- for either 10 s or 60 s. There was 60% mor-
tality after exposure to 25 mg L-1 CN- for 120 s.
Likewise, there was no mortality after exposure to
50 mg L-1 for either 10 or 60 s; but 100% mortality
occurred within 96 hours (h) after CN- exposure for
120 s. Under stressed conditions (being bagged) pre-
viously non -lethal exposures (50 mg L-1 CN- for 60
s) were 100% lethal. Hence, both stress and cyanide
resulted in higher mortality after exposure to CN-
for a shorter time period. There was impairment of
oxygen consumption by the liver tissue of test fish
documented 2.5 weeks post- exposure. Hanawa et al.
(1989) concluded that handling stress in combina-
tion with anaesthetic doses of CN- could in part
explain the delayed mortality associated with CN-
use in the tropical fish trade.
Hall and Bellwood (1995) assessed delayed mortal-
ities of groups (16 per group) of damselfish
(Pomacentris coelestis) exposed to cyanide, stress
and starvation, alone and in various combinations,
over a 13-day period. With each factor separate, the
cyanide -only exposure (which also involved han-
dling) resulted in the highest delayed mortality
(37.5 %), followed by stress -only (25 %) and starva-
tion -only (0 %). Among the paired combinations,
stress +starvation produced the highest mortality
(66.7 %). The stress -only condition and the han-
dling control both had 25% mortality, indicating
that those conditions were stressful to the fish. The
results demonstrated that cyanide influenced the
delayed mortality both alone and in combination
with the other factors. While starvation -only did
not produce mortality during the experimental
period, the percent mortalities for cyanide +starva -
tion and stress +starvation indicate the importance
of starvation in combination with the other factors.
Concurrent conditions
During shipping, several environmental parameters
(pH, dissolved oxygen, carbon dioxide, ammonia,
temperature) change concurrently in sealed
polyethylene plastic bags (McFarland and Norris
1958; Fry and Norris 1962). This makes it difficult to
infer which environmental parameters may have
killed the fish. A study by Chow et al. (1994) is the
only one that has separately determined levels of
each environmental parameter inducing 50% mor-
Rationale for 1 gallon /fish includes research showing that bagging a fish for ten minutes
in %Z gallon of water (to simulate transport) contributes to fish mortality via increased
stress.
Hanasaa et al (1998):
At this point, the literature is unclear about the long -term effects cyanide has on fishes if they survive
initial exposure to the drug. The Hanawa et al paper sought to clarify both the acute and long -term
effects of cyanide exposure. Additionally, they studied the impact cyanide has in light of research that
had been conducted on rainbow trout exposed to sub - chronic levels of a cyanide derivative. These
trout "displayed marked anemia." The hypothesis was that fishes exposed to cyanide would have lower
hemoglobin concentrations and a lower blood oxygen content. Specifically, they wanted to look at the
oxygen consumption rate in the liver as they hypothesized that it would be impaired in fishes exposed
to cyanide.
They conducted a series of experiments exposing 6o fishes (DascylIus aruanus) to cyanide treatments
of 25 and 50 ppm for io, 6o and 120 seconds; there were ten fishes in each group. They found that
exposure at 25 ppm for 120 seconds caused 6o96 mortality and 50 ppm for 12o seconds caused l00%
mortality 96 hours after exposure. All other groups (which had shorter exposure times) experienced
no mortalities after 96 hours.
Next, they conducted a second series of experiments in which fishes were exposed to 25 or 5o ppm
cyanide, but all groups (again, ten fish per group) ivere treated for only 60 seconds. They added some
stressors to some of these groups of fishes to see -.% ,hat results, if any, would occur. There were two
. on o sv�Q ov.Y, 1 to 9r nnm white the other so nom_ but npithPi had
any additional stress imposed. Another two groups of 25 and 50 ppm exposed fishes were bagged in
two liters of sea-mater for ten minutes before being returned to their aquariums, to simulate transport.
I He final Two groups were intentionally cnased WIM a Hand nex in fneir ME ior To minutes Two ana
one half weeks after exposure, simulating a retail experience (although, speaking as a former local fish
be handed your %alking papers). Done of the groups experienced any mortalities except for the group
exposed at 5o ppm for 6o seconds that was bagged. All of those fishes died.
November 17, 2014
TO: Honorable Chair and Members of the Hawaii County Council
"Section 1. Findings" of Hawaii Bill number 318, has NO basis in fact, in actual
practice, scientific data or research, to support these proposed requirements for
the transport and handling of tropical fish, and is highly discriminatory. I strongly
oppose it for these reasons.
IATA, the International Air Transport Association, requires shippers to
"responsibly pack specimens to survive 48 hours in transit ". Feeding fish prior to
shipment causes shipping water to become fouled. Ammonia, a product of fish
waste, is toxic to fish and would insure high mortality rates during transit. So, in
order to meet the IATA 48 hour rule, withholding food is "essential to clear the
gut of food to minimize the fouling of transport containers ".
The IATA live animal regulations, known as LARS, contains detailed criteria and
recommendations and guidelines which has been developed over decades of
experience involving the transport of hundreds of millions of live animal
shipments. The IATA LARS are the GLOBAL adopted standard and incorporated in
national laws, and prescribed by one or more United Nation's Treaties. Bill 318
would require shippers to violate these regulations, which have long been the
practiced standard in the pet industry.
The Convention on International Trade in Endangered Species of Wild Flora and
Fauna, referred to as CITES, has now adopted the IATA LARS as a substitute for its
own guidelines.
Fish are cold blooded and do NOT require daily feeding. They do, however,
require clean water and oxygen.
It is important to keep metabolic rates of fish at a low level prior to shipping so
that less oxygen will be consumed. This is accomplished by reducing
temperature, combined with cessation of feeding for several days prior to
shipping. These are guidelines from the APEC Fisheries Working Group, January
1999.
Water requirements for shipping is not a "one size fits all" situation, but varies by
species, pre- shipment conditioning, age, size, and length of transit.
The passage of this legislation will not only limit a fully sustainable trade, but
would prevent the normal and ethical transport between facilities under the best
standards of practical care.
I encourage you to carefully review the written submission of the Pet Advisory
Council.
This bill does NOT support the ethical treatment of aquatic life. In fact, it actually
will have the impact of insuring high mortality rates, and therefore must not
seriously be considered for passage.
Respectfully submitted,
Sma+l business owner and Kailua Kona resident for 37 years.
November 18, 2014
Chairperson Wiley and Committee Members,
I am opposed to Bill 318. 1 am a full time commercial fisherman for aquarium fish. These fish
are shipped interisland and out of state in an enclosed bag of water with oxygen. While
providing food 24 hours before shipping may seem well intentioned, it will in fact be very
detrimental to their survival.
If fish are fed 24 hours before shipping, toxic metabolic wastes, bacteria, and basic excretions
will be introduced into this bag of water by normal digestive processes. These substances will
cause disease, tissue damage, and possible death to any fish subject to such conditions for an
extended period of time.
Increasing the volume of water to one gallon minimum will not mitigate the harmful effects of
fish waste. It would be better to minimize the introduction of the waste products instead.
Please do not pass Bill 318. Thank you.
Dennis Yamaguchi
The preparation and shipping of live animals is not conducted in a vacuum.
ASSOCIATION REPRESENTATIVES
Jim Boschee (WPA)
• ■JAC
PET INDUSTRY JOINT
shippers nor airlines dealing with live animal transport prosper economically by
ADVISORY COUNCIL
1146 19" Street, N.W., Suite 350
transporting sick, dying or dead animals.
Washington, DC 20036
Tel: 202-452-1525
Fax: 202- 452 --452- 15151 6
As a preliminary comment, we find It most interesting that the subject Bill
CHAIRMAN
Testimony of the
Ken Oh
Pet Industry Joint Advisory Council
W F Young, Inc., East Longmeadow, MA
On
FIRST VICE - CHAIRMAN
raises interesting questions of the true intent of a bill ostensibly designed to
Jeff Sutherland
County of Hawai' i
Animal Supply Company, Federal Way, WA
Bill No. 318 An Ordinance Amending Chapter 4
g p
SECOND VICE- CHAIRMAN
"animal welfare." Such rank discrimination raises interesting questions why
Greg Cyr
November 15, 2014
Central Garden and Pet, Walnut Creek, CA
State and non -State regulated fisheries! sterner
sheries! Good governance is made of steer
g g
SECRETARY/TREASURER
To Whom It May Concern:
Andy Ponte
United Pet Group, Cincinnati, OH
DIRECTORS
The following comments are submitted on behalf of the Pet Industry Joint
Ryan Boyle
Advisory Council ( PIJAC), the world's largest pet trade association representing
unte
The Hunto Corporation, Goodman, MO
the interests of all segments of the pet industry. For more than 40years, PIJAC
Tom , DVM
Petco Animal Supplies, San Diego, CA
has promoted best practices for handling and care of live animals. For many
Bruce Flantzer
decades, PIJAC has been engaged in all aspects of regulating the movement of
MiracleCorp Inc., Dayton, OH
live animals via all modes of transport.
Il
Chris Fleming
Pinnacle
Pet, Neosho, MO
PIJAC has actively participated in the deliberations of the International Air
Heather Govea
Natural Balance Pet Foods, Burbank, CA
Transport Association's Live Animals and Perishables Board leading to the
Rolf Hagen
publication of the IATA Live Animal Regulations, the globally accepted
Rolf C. Hagen Inc., Baie D'urfe, Quebec
standards for transporting animals of all types.
p g Yp
John Mack, Reptiles By Mack
Xenia, OH
Michael Peterson
I chair the IATA Live Animal Board's Advisory Committee that is responsible
The Pet Group, Carlsbad, CA
for ensuring that the Regulations' standards for and shipping live
Laura "Peach" Reid
preparing
animals reflect up -to -date animal welfare and veterinary husbandry practices
Fish Mart West Haven, CT
Inc., In
applicable to the preparation/conditioning of the animals pre- shipment, shipping
Jim S nd
Pet World, Inc., Rochester, NY
containers, and handling during transport. Portions of Federal regulations as
Joe Watson
well as the Convention on International Trade in Endangered Species (CITES)
Petland Inc., Chillicothe, OH
mandate compliance with the IATA Regulations when shipping covered species.
Marcie Whichard
Petco Animal Supplies Inc., San Diego, CA
The preparation and shipping of live animals is not conducted in a vacuum.
ASSOCIATION REPRESENTATIVES
Jim Boschee (WPA)
Contrary to some beliefs of anti -trade activists supporting Bill 318, neither
Calabasas, CA
shippers nor airlines dealing with live animal transport prosper economically by
Kevin Fick (
Worldwise, San Rafael, CA
transporting sick, dying or dead animals.
Steve King (PIDA)
Pet Industry Distributors Assoc., Abingdon, MD
As a preliminary comment, we find It most interesting that the subject Bill
Sandra Moore (FTFFA)
targets only certain aspects of activities involving aquatic life to wit aquarium
Segrest Farms, Gibsonton, FL
life destined onl for uarium use outside of the county, Such discriminato
y q `J • �
PAST CHAIRMEN
James Heim
treatment of a highly, if not the most highly regulated Hawaiian in -shore fishery
Walnut Creek, CA
raises interesting questions of the true intent of a bill ostensibly designed to
Frank Koch
ensure humane care when in fact it is designed to shut down interstate and
Pacoima, CA
international trade involving fish destined for "aquarium use" under the guise of
Allan Levey
New York City, NY
"animal welfare." Such rank discrimination raises interesting questions why
Alexandre Perrinelle '
similar restrictions are not imposed upon all fonns of aquatic activities, both
Los Angeles, CA
State and non -State regulated fisheries! sterner
sheries! Good governance is made of steer
g g
Segrest
Gibso
ibsonton, FL
stuff!
PRESIDENT/CEO
Edwin Sayres
Quite simply there are no science -based studies substantiating a One Gallon rule or limiting the
withholding of food for no more than 24 hours.
IATA's guidelines covering feeding and watering are based on the documented premise that
feeding and watering requirements must vary by species as well as by individual specimens
within a species, mainly due to age, size, pre- shipment conditioning, length of haul, etc.
Fundamental to IATA's approach, therefore, is shippers have the responsibility of utilizing the
generally accepted animal husbandry and veterinary care practices when preparing their animals
for shipment via air.
IATA's Regulations provide that shippers are to responsibly pack the specimens to survive for
48 hours in transit. In order to meet the IATA 48 -hour rule, withholding food is essential to clear
the gut of food to minimize the fouling of transport containers. Absent such pre- shipment
protocols, the fish could be subjected to unacceptable toxic ammonia levels or other wastes
resulting in poor water quality, which in turn is an undesirable stressor that could lead to death or
serious morbidity. That is why customary practices as indicated by the Association of Zoos and
Aquariums, as well as information provided below, notes that a "2 -10 day fast is routinely done
as a matter of professional practice." Such pre- shipment conditioning reflects acceptable
veterinary husbandry practices.
For example, the Convention on International Trade in Endangered Species of Wild Fauna and
Flora (CITES) Transport Guidelines at page 73 provided, in pertinent part, that fish shipments
should be packed "in order to minimize pollution of the water, fishes should not be fed for 24
hours prior to shipment." In crafting their Guidelines, CITES relied upon not only the IATA
LARs of 1980, but also recommendations from leading researchers from around the globe from a
number of zoos, aquariums, research institutions, and humane societies. CITES, at its
Conference of the Parties in March 2013, adopted a resolution containing language applying
IATA LARs along with several special rules unique to ground transport when transporting
CITES- listed species by air or surface transport modes.
The IATA LARs have long recognized that the withholding of food prior to shipment of aquatic
organisms is a globally accepted practice not only within the ornamental fish trade, but also in
the live food fish trade. The withholding of food prior to transport decreases the amount of
excreta from the fish, reduces the metabolic rates, and thus reduces water pollution; pollution
that could counter IATA's 48 -hour in- transit rule for tropical fish shipments. Withholding food
also has been shown to reduce stress responses to handling and thus reduces unnecessary loss
during packaging and transport.
The IATA guidelines are based on not only years of empirical experience, but also from the
literature. A 2010 publication of the University of Florida recommended
"Withholding food from the [tropical] fish for at least 24 hours just before shipment
allows them to purge their digestive tracts, which greatly reduces the buildup of wastes
during shipping. It also takes longer for larger fish to completely empty their guts. "
Watson, Craig A., Shipping Fish in Boxes, SRAC Publication No. 3903 (2010)(Emphasis
1 In recent years, CITES has adopted the IATA LARs as a substitute for its 1981 Guidelines.
supplied)
Approximately 10 years earlier at a University of Alaska Sea Grant Conference, it was reported
that
"All live seafood items should be starved for at least 24 hours before they are packed to
avoid the inevitable occurrence of vomiting undigested food... " Post, Brian C., Rice,
Allison A., et. al. editors, Marketing and Shipping ofLive Aquatic Products, Proceedings
of the Second International Conference and Exhibition, University of Alaska Sea Grant
Program, Seattle, Washington, page 197 (1999). (Emphasis supplied)
And from the NOAA website, one can find the APEC statement at page 18:
"Diurnal rhythms also affect oxygen demand. Handling and packing
procedures sriould be designed to keep metabolic rates at a low level. In most cases, this
can be accomplished by reducing temperature and eliminating feeding for several days
prior to shipping. The optimal time to cease feeding varies depending upon the species.
Feed reduction schemes should consider product weight loss in order to ensure that the
product condition remains prime. " Air Shipment of Live and Fresh & Seafood
Guidelines, APEC Fisheries Working Group, January 1999. (Emphasis supplied)
In an Hawaii based report on shipping ornamentals, Drs. Cole, Tamaru, Bailey, Brown, and Ako
found:
"Feeding should be withheld for a minimum of two days and up to five days, depending
on species, " Cole, B., Tamaru, C., Bailey, R., Brown, C., and Ako, H., Shipping
Practices in the Ornamental Fish Industry; Center for Tropical and Subtropical
Aquaculture Publication Number 131, (February 1999: Hawaii NOAA Sea -Grant project)
(Emphasis supplied)
Thus, it is clear from the literature that a specific 24 -hour limitation is not sacrosanct. As one
would expect, the fecding requirements will vary not only among species, but also with
specimens within a species depending on age, size, pre- transport conditioning, similar to what
human primates experience. Quite simply, shipping fish without fasting appropriate for the .
species can be dangerous and run counter to the desired mandatory standards being proposed.
As noted in numerous papers regarding the preparation and shipment of fish destined for
"aquarium use," no one has presented any science -based data substantiating the appropriateness
of a One Fish/One Gallon minimum requirement when shipping fish destined for the aquarium
trade, let alone any other use such as for food fish or non - commercial activities as exempted in
the proposed Bill.
While PIJAC supports humane transport standards, such standards must be non - discriminatory,
science - based, and not a knee jerk reaction to activists attempting to misuse a county ordinance
to effectively ban a state regulated industry that they historically have attempted to ban.
The underlying justification for the Ordinance's "findings" coupled with misinformation floating
around the Internet regarding unsubstantiated "loss," "the normal lifespan of aquatic life, "
conflicting statements as well as reliance on several articles which deal with the Philippines or
other remote fisheries, not the Hawaiian experience, reflects inulti- faceted analytical infirmities
hardly supportive of the proposed Ordinance. It should not be overlooked that the Hawaiian
aquarium fishery is a long- established, well - regulated industry by the State's Department of
Land and Natural Resources.2
Thank you for the opportunity to submit our comments with respect to the proposed Ordinance.
As an attorney having been intimately involved with the aquarium trade since the late 1960s3, I
look forward to working with the Council to ensure that all regulated fisheries are managed and
regulated pursuant to the International Union for the Conservation of Nature's (IUCN) Principles
and Guidelines for the Sustainable Use of Biodiversity by promoting both conservation and
livelihoods through enhancing equitable and sustainable use of wild species and their associated
ecosystems.
Respectfully submitted
Pet Industry Joint Advisory Council
N. Marshall Meyers
Seiiior Advisor
The most recent round of amendments to the State's West Hawai'i fishery rules provide a number of
improvements to the regulatory mechanism. These reflect the results of years of research, committee meetings and
community discussions. As before, permit holders are required to "to keep all aquatic life taken under the permit
alive and in reasonable health" as well as "maintain the proper operation of facilities designed to keep fish alive
and in reasonable health.
3 Over the years, my practice has involved representing the largest all -cargo airline, The Flying Tiger Line (now
FedEx), as well as the pet industry, and a number of zoos, public aquariums, biomedical facilities and individual
shippers.
To the council members in regards to bill 318
I strongly oppose this bill
I am a diver, wholesale distributor and exporter of Hawaiian reef fish
with over 20 years experience and once again were having to defend
ourselves from individuals making statements on subjects they have no
actual experience with individuals willing to say anything whether it be
hearsay or outright fabrications to shut down our industry because of
their personal feelings.
We wouldn't be able to stay in business shipping fish that don't survive.
I'm not going to ask you to take my statement at face value but I would
ask you to talk with wholesalers that we ship to, I am more than willing
to give you contact information and I'm sure other wholesalers will
also.
Thank you for your time and consideration.
Scott Brien
Forbidden Bounty tropical Fish
sbrien @hawaiiantel.net
Testimony concerning County Council Bill 318
My name is Bertha Basabe, I am against Bill 318.
I ask you all to please review the written testimony that was submitted
earlier, including that from PIJAC, which is the Pet Industry Joint
Advisory Council. You need to be aware of both sides of this issue. The
PIJAC testimony clarifies why the two aspects of Bill 318 are very
flawed.
To change the present, and very successful transporting practices
would actually be detrimental to the health and humane care of
saltwater fish.
Bill 318 appears to be targeting only the tropical fish aspect, why not
the entire ornamental fish industry?
I want to thank you all for your precious time, hopefully this issue won't
waste much more of it.
Aloha County Council Members
My name is David Dart
This testimony is in opposition to Bill 318 regarding aquarium fish treatment.
I am here specifically to address mistaken beliefs that there is high mortality in shipping AQ fish from
the Big Island. There is not a single bit of evidence that this is the case. There are zero scientific studies
to back this up. There is, however, independent scientific studies done showing 100% survivability in
shipping from Hawaii County.
Beware of self proclaimed "reef fish experts" with no fishery degree and biologists who have not done
any published studies with peer review and are closely associated with the opposition. What have they
done in Hawaii County? On shipping off the Big Island? Ask them.
No doubt the opposition here will come up with some study showing shipping mortality. No doubt it
will be dated and show problems in shipping from a third world country where cyanide and destructive
methods were used for collection. What about a Big Island study? Let's look at a recent two year
independent Washington State thesis study done by Emily Munday, under the direction of Dr. Brian
Tossot, a world renown reef fish expert, done right here in Hawaii county. Ms. Munday collected fish with
local collectors using standard operation procedures. 60 yellow tang were separated out of the load
and transferred to a local export shop where they were held, purged and then shipped to Portland in
standard shipping bags. Sixty days later there were zero deaths. In fact 2 1/2 years later they are doing
fine in an exhibit at the Oregon State University's Hatfield Marine Center. This exhibit highlights the
sustainability of the Hawaii aquarium trade.
Shipping one fish in a gallon of water is nonsensical. Some of our fish are 2" fish while others may be
12 ". There is no credible science behind one size fits all. Our fish are packed according to size of
fish and duration of flights. Experts know that it is the oxygen in a shipping bag that is the most important
variable not water. Our outstanding success in West Hawaii providing quality, sustainable fish to world
wide dealers is well known.
Kole and yellow tang comprise over 93% of the catch. According to DAR biologist Dr. Walsh, since
the Fish Replenishment Areas were implemented, there are 1.3 million more yellow tang and 3 million
more kole in West Hawaii. As he said, "clearly, resource management is working in West Hawaii ".
This bill does not recognize or cite any scientific study that would warrant such a drastic change from
current best and proven practices. Mahalo
Ok „...., a
November 18, 2014
To: Hawaii County Council Committee on Agriculture, Water and Energy Sustainability
Re: Bill 318 in SUPPORT
Aloha Chair Wille, Vice Chair Poindexter and Committee Members,
Thank you for this opportunity. My name is Rene Umberger, I am the founder of For the Fishes and the
co- founder of Reef Rescue Alliance, and a consultant to Humane Society International, all working to
protect coral reef wildlife from harmful aquarium trade practices.
The provisions in Bill 318 would address the mortalies for fish captured and shipped from Hawaii.
Evidence shows deaths within the supply chain from reef to retail are likely over 100,000 fish. It shows
that deaths range from 1% to 11% at each step in the supply chain and that these deaths can be
mitigated with better handling and shipping procedures. The starvation prohibition and water volume
requirement in this bill would address this need and reduce this loss of wildlife.
Catch reports, industry surveys and studies all document these rates.
Supply chain mortality for Hawaii fish in 2012:
378,430 — 3% (11,352) = 367,077 Collector to HI wholesaler (per DLNR catch report)*
367,077 —1% (3,671) = 363,406 At HI wholesaler (estimate per Cesar, 2002)
363,406 — 3% (10,902) = 352,504 HI wholesaler to LAX: DOA = 10,902 (industry self- reporting and Lim, et al 2003)
352,504 — 5% (17,625) = 334,879 w /in 7 days at LA wholesaler (industry self- reporting and Lim, et al 2003)
334,879 — 3% (10,046) = 324,833 LA to East Coast: DOA (same as above)
324,833 — 5% (16,242) = 308,591 w /in 7 days at East Coast wholesaler (same as above)
308,591 -11% (33,945) = 274,646 w /in 2 weeks at retailer (Cartwright, et al., 2012)
Total Dead = 102,176
The highest mortalities are transport related with an industry standard of "acceptable losses” at 5% per
shipment. Shipments from Hawaii may be lower, at 3 %, but that's unacceptably high.
P.O. Box 1894, Kihei, HI 96753
ReneortheFishes.org * 808.283.7225
The trade claims there's no amount of water that will adequately dilute the fouling. But many
examples show otherwise:
A prominent aquaculture facility ships their captive -bred fish in adequate water after one
feeding is withheld — their DOA's average far less than %2 %; and,
The United Air Cargo Kona station manager states that the fish they accept for shipment were
captured on the day prior to shipment and have not been starved. So at least one aquarium
business is already doing this practice.
It's time to end wildlife sacrifice for economy.
10 years ago a $20 million reform effort by experts in the global aquarium trade tried to address the
high death rates. It required a 1% threshold for deaths at each step in the supply chain. A vocal
opposition wanted the threshold set at 5 %, some argued for 10 %. The trade knew that if they couldn't
regulate themselves, legislation would follow, and yet they rejected the 1% death threshold and
reform effort.
The time for legislation is now.
Thank you for your time and consideration,
Rene Umberger
P.S. I don't know how many people will testify in public today, but each one of them should be
thanked for having the courage to do so. For every person who's here, a handful of others declined,
wanting to avoid the insult, intimidation and worse, this trade is known for.
* Per DLNR, the reported difference between what was captured and sold reflects the mortality. In 2012 it was 3 %, or over
11,000 fish. This is higher than reported by Cesar in 2002, who asked aquarium trade members to estimate mortality rates
for their trade. At the collector to wholesaler level they estimated 0 —1% mortality. Looking at collection reports since
2000, the actual range is 1 %— 3 %.
P.O. Box 1894, Kihei, HI 96753
Rene FortheFishes.org * 808.283.7225