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HomeMy WebLinkAboutCOM 0140.085 2014-2016Letter from animal husbandry experts to Hawaii County Council in support of Bill 318: limiting pre -shipment starvation time to 24 hours for aquarium life; and, increasing transport water volume to a minimum one gaY CLERK . Feb. 17. 2015 COUNTY OF HAWAV I REC,E1iVED ��-- Time �"''►► By Dear Hawaii County Council Members: Date !v We, the undersigned, strongly support Bill 318 and we present our perspectives on the welfare of coral reef wildlife captured in Hawaii and shipped out as pets in the marine aquarium trade. We believe that under the aquarium trade's current practices, transport -related mortality from the supply chain to home aquariums is unacceptably high and warrants reform. The marine aquarium trade's acceptable loss standard on arrival (DOA) is 5% (OS). Shippers compensate customers only when DOA's exceed that standard. Mortality rates for other pets shipped via air cargo are reported below .01% (.0001). The aquarium trade's predictably high mortality is evidence of inadequate standards to meet the basic needs of wildlife in transport. The industry claims that Hawaii's DOA rate is lower than rates from Indonesia or the Philippines. Even if this unverified claim is accurate, it does not apply in Hawaii. We feel strongly that Hawaii reef wildlife warrants a true value standard. The aquarium trade "acceptable loss" standard should be rejected, and Hawaii Revised Statutes should instead provide the foundation. HRS 711-1109 prohibits, among other things, starving and transporting or causing to be transported any animal in a cruel or inhumane manner. Practices and conditions leading to the predictable deaths of tens of thousands of reef animals can only be defined as inhumane, not humane. Only institutionalized poor treatment creates a high level of mortality as a noun rather than an exception. Bill 318 addresses obvious gaps between reef wildlife needs and the care they receive. Appropriate husbandry in holding and transport would be indicated by a mortality standard much lower than 3 — 5%. The need to reduce supply chain mortality has long been discussed in the trade. A multi-million dollar, multi - stakeholder reform and certification scheme was attempted over a decade ago by the Marine Aquarium Council, an international effort based in Honolulu. It began in the late 1990's when experts expressed an urgency in the trade's destruction of reef habitat and species and coastal communities. They set a 1 % mortality threshold at each step in the supply chain. The trade revolted at the mortality limit and other requirements, and the voluntary reform effort ended after just 3.5 years with funding terminated for failure to achieve the goals. That failure a decade ago underscores the need for irmnediate legislative action on adequate standards. As captive longevity is extended, demand for replacements will decrease. More reef wildlife will remain on Hawaii reefs where they belong. All claims that current practices do not cause undue transport mortality are false, and so is the claim that Bill 318 would do more harm. The attached document shows: stress, starvation, minimal water and crowding in transport are implicated in reef wildlife mortality. Reducing starvation and increasing water will help. Metabolized waste and oxygen issues are easily resolved. As a community of animal welfare experts who share a strong concern for Hawaii reef wildlife in the aquarium trade, we support Bill 318, as written, and urge you to maintain, not weaken, the animal protection components contained therein. Sincerely, Diane Shepherd, DVM, Immediate Past -President Hawaii Veterinary Medical Association t qO. Teresa M. Telecky, PhD, Director, Wildlife Department, Humane Society International Comm. No. Ref. To: PSC Heather Dawn Rally, DVM, Wildlife Veterinarian Ref. Dote FE3 17 2015 Hawaii County Bill 318: correcting misconceptions and misstatements made by the AZA, PIJAC, etc. 1) "The provisions of Bill 318 will not improve the standards for animal welfare; rather they will have the opposite effect leading to higher rates of mortality." "It would become impossible to ship fish and aquatic invertebrates in a safe and humane manner..." FALSE Facts: • In Dec. 2014, Ocean Rider Seahorse Farm received a shipment of small Weedy Seadragons from Australia. Each 4" Seadragon was shipped in at least 2 gallons of water.' o Seadragons are rare and expensive. When survival really matters, more water is used. • Under current practices, animal welfare is sacrificed for economy. 2 3 4 o Extended pre -shipment starvation serves one purpose: to facilitate shipment in minimal water and thereby reduce transport costs. • Studies cite the need for supply side reform in handling and transport to improve fish welfare.s e o Fish welfare is enhanced by decreased starvation time and increased water volume. o Metabolic waste management and proper oxygen level maintenance is easily achieved. 2) "Contrary to some beliefs of anti -trade activists supporting Bill 318, neither shippers nor airlines dealing with live animal transport prosper economically by transporting sick, dying or dead animals." FALSE Facts: • "in the marine aquarium trade, a significant amount of sales have been made because customers were unknowingly buying a damaged product... Each level of the supply chain is profiting from customers buying fish to replace a significant number of fish that die in home aquaria."' • Cargo carriers do profit from transporting sick, dying and dead animals: they transport a high number of fish that die enroute or within 7 days of air transport (with no liability for animal deaths). They also transport replacements for fish that died in the supply chain and in home aquariums. 3) Fasting/starvation is being prohibited. FALSE Fact: starvation would be limited to 24 hours, not prohibited. 4) An IATA LARs requirement is that fish are not to be fed for a number of days prior to shipment to avoid fouling of the water. FALSE Facts: • In the applicable IATA LARs container requirement, only aquatic amphibians (e.g. frogs, newts, salamanders) are identified for the withholding of food, and it is very specific, requiring food to be withheld for 2 days. The requirement to withhold food does not exist for shipping tropical fish.8 5) Starving for more than 24 hours is the only way to address metabolic waste build-up during shipping. FALSE Facts: • PIJAC's own testimony supports 24 hour pre -shipment starvation, quoting CITES fish transport guidelines that recommend "fishes should not be fed for 24 hours prior to shipment." • Bishop Museum's Sr. Ichthyologist Emeritus testified in 2010, "it is necessary to stop feeding for 12 hours before shipping a fish. If not, it will foul the water in which it is shipped."9 • There is no evidence that a day(s) of minimal feeding followed by starving for 24 hours would not adequately address the waste issue. • Reducing harmful levels of waste is also achieved with dilution (i.e. more water). 6) "There are few fish species that cannot be safely fasted." "Starving fish does not harm them." 2 — 10 day pre - shipment starvation reflects acceptable veterinary husbandry practices. FALSE Facts: • Starvation increases fishes' susceptibility to handling, shipping and other stressors which leads to higher mortality rates.10 • Nearly all the fishes in the Hawaii aquarium trade are herbivores with digestive systems matched to their dietary and feeding habits. Those of you who have seen these fish on Hawaii reefs may recall their constant grazing throughout the day. • Reduced starvation time will help maintain healthy and functioning digestive tracts in fishes during the transport period where food may not available for 48 hours or more. 7) Even small amounts of waste cannot be safely diluted with increased water. FALSE Facts: • Waste is diluted by water. • Dilution is well-known and regularly used in the aquarium trade and hobby. • Reduced water volume can lead to build-up of waste." • Increased water volume dilutes wastes and facilitates fish well-being. 8) Reduced starvation time will harm fish by reducing oxygen levels during shipping (e.g. by increasing fouling and increasing demand for oxygen). FALSE Facts: • Oxygen levels can easily be increased in the bag/water during packing to ensure fish well-being. • Dissolved oxygen is also increased by decreasing the biomass of the fish in the bag (e.g. by increasing water volume )12 9) The proposed water volume is arbitrary/not based on science. FALSE Facts: • There is no science showing that current/low water volume is best or better than the proposed. • There is ample evidence that current/low water volume is based solely on economics and is potentially lethal .13 is • There is ample evidence that quality and temperature in higher water volumes is easier to maintain and better supports fish well-being." 1617 • The 1 gallon requirement is modest considering it is 1% of the space needed for well-being according to trade websites and articles. 10) The studies cited are based on fish sourced in the Philippines and Indonesia, not Hawaii. FALSE Fact: • Yellow tangs, 100% of whom are likely sourced in Hawaii, were prominently featured in three aspects of the study that concluded the trade is profiting from sales of damaged fish and their replacements.18 11) The law would prevent transport between zoological facilities under the best standards of practical care. FALSE Fact: educational and public display uses are exempt Photos courtesy of Ocean Rider Seahorse Farm, Kona, HI 2 "Economy dictates that water weight should be reduced in the shipping container. However, reducing water amounts can lead to inherent problems such as: Insufficient oxygen...; Carbon dioxide build-up; Detrimental changes in pH level; Detrimental temperature changes, Build-up offish discharges, loss of finfish surface mucus; Physical damage and/or mortality." APEC Fisheries Working Group, 1999. APEC Air Shipment of Live and Fresh Fish & Seafood Guidelines. 3 "Crowding offish into confined conditions during shipping and holding at import or export facilities is a potentially significant contributor to wildlife stress and mortality. Reducing crowding by stocking fewer fish per container would alleviate this problem, but would increase costs and space requirements (Rubec and Cruz 2005)." Thornhill, D, 2012. Ecological Impacts and Practices of the Coral Reef Wildlife Trade. Defenders of Wildlife ° "During transport, the water in these closed containers may become oxygen -depleted, and may accumulate excessive carbon dioxide and consequently undergo a reduction in pH. Metabolic activity may also lead to elevated ammonia levels in the water, which can be damaging to fish health, or become lethal in extreme cases. A densely -packed shipping container increases these risks but reduces the cost of transportation - a critical cost in the delivery of product at competitive prices." Cole, et al., 1999. Shipping Practices in the Ornamental Fish Industry; Center for Tropical and Subtropical Aquaculture Publication Number 131; Hawaii NOAH Sea -Grant project 5 "There is insufficient attention to enhancement of the stress resistance of the fish, which would enable the fish to overcome the stressful conditions during transportation better." Recent developments and improvements in ornamental fish packaging systems for air transport. Lim, et al., Aquaculture Research, 2002, 34, 923-935 6 "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 buying fish to replace a significant number offish 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." Saving Nemo: mariculture and market-based solutions to reform the marine aquarium trade. Cartwright, et al., March 2012. Bren School of Environmental Science & Management, UCSB, for Olazul. 7 Ibid. 8 International Air Transport Association, 2013. Container Requirement 51, Applicable to Tropical Fish. Live Animal Regulations, 391h Edition 9 Randall, J, 2010. Testimony Re: PS -25 Aquatic Life Animal Control before Maui County Council Public Services Committee io Hall and Bellwood (1995) also examined the effects of starvation on fish mortality. Starvation alone did not cause P. coelestis to die (Hall and Bellwood 1995). However, starvation increased the fishes' susceptibility to other stressors (e.g., handling stress, cyanide) leading to higher rates of death (Hall and Bellwood 1995). For instance, starvation and handling stress combined resulted in 66.7916' mortality, the highest mortality rate observed among the experimental treatments of Hall and Bellwood (1995)." Thornhill, D, 2012. Ecological Impacts and Practices of the Coral Reef Wildlife Trade. Defenders of Wildlife 11 "Economy dictates that water weight should be reduced in the shipping container. However, reducing water amounts can lead to inherent problems such as: Insufficient oxygen...; Carbon dioxide build-up; Detrimental changes in pH level, Detrimental temperature changes, Build-up offish discharges; Loss of finfish surface mucus, Physical damage and/or mortality." APEC Fisheries Working Group, 1999. APEC Air Shipment of Live and Fresh Fish & Seafood Guidelines. 12 " it is essential to maximize the amount of oxygen available during shipment. The main ways to achieve this are to reduce the biomass offish in the bag, increase the amount of oxygen in the bag..." Watson, C, Shipping Fish in Boxes, 2010. SRAC Publication No. 3903 13 ,Economy dictates that water weight should be reduced in the shipping container. However, reducing water amounts can lead to inherent problems such as: Insufficient oxygen...; Carbon dioxide build-up; Detrimental changes in pH level, Detrimental temperature changes; Build-up offish discharges; Loss of finfish surface mucus; Physical damage and/or mortality." APEC Fisheries Working Group, 1999. APEC Air Shipment of Live and Fresh Fish & Seafood Guidelines. 14 Fish held in half the water volume required in Bill 318 for just 10 minutes died in a study that measured the results of certain stressors (transport or being chased) on fish already stressed from cyanide poisoning. "...all fish exposed to a 50 mgl' cyanide solution for 60 s survived. The addition of a stress immediately on recoveryfrom anaesthesia (in this case being placed in o plastic bag for 10 min to mimic conditions during transport) killed all the fish." Hanawa, M, 1998. Effects of cyanide exposure on Dascyllus aruanus, a tropical marine fish species: lethality, anaesthesia and physiological effects. Aquarium Sciences and Conservation, 2, 21-34 15 "When stocking nano systems, the issues of water quality are... at the forefront of our minds, as the reduced water volume significantly limits the dilution of organic wastes (the usual suspects of ammonia, nitrite, nitrate and phosphates). Smaller water volumes also suffer from decreased resistance to change compared to larger volumes.... Temperature fluctuations.. are a main factor to guard against .... A small tank in a hot room will overheat very quickly compared to o large one..,"Aspinall, R, 2012. Keeping Sexy Shrimp, Tropical Fish Hobbyist Magazine 16 "The vast majority of health issues with tongs come down to issues with environment and/or nutrition. I've gone on and on here regarding these fishes' need for space and what this includes: dilution of metabolites/wastes, high levels of dissolved oxygen, and room for mental well-being." Fenner, R, 2013. Tangs: Acanthurids for the aquarium — and some best left in the sea. Coral—the Reef & Marine Aquarium Magazine. 17 Space/water volume requirements for captive yellow tangs ranges from 75 — 100 gallons/ per fish. Petco.com, LiveAquaria.com, BlueZooAquatics.com, FreshMarine.com etc... 18 "Yellow tang" occurs in the supply chain analysis, stated preference survey and Facebook survey ads on 6 different pages in Saving Nemo: mariculture and market-based solutions to reform the marine aquarium trade. Cartwright, et al., March 2012. Bren School of Environmental Science & Management, UCSB, for Olazul.