New CFIA Aquatic Import Regulations

[RD.]

I never said that it would work.

What I said was:

That alone would at least assist in keeping most exporters somewhat honest, or risk being banned from further imports into Canada.

Of course it wouldn't be effective, I don't think that AB even has a CFIA DVM.

My permits are stamped by a CFIA DVM based in Surrey BC, which is routed to him via the CFIA office in Calgary. Random checks would be purely hit & miss, but would be better than no checks at all. (maybe?)

I don't think a system such as CITES would work either, for the same reasons, not enough manpower to handle the work load. As it is now a CITES permit for a handful of Asian aros can take 3-6 weeks to process. Imagine how smoothly things would go with thousands of ornamental (and native) species involved.

IMO the CFIA's role in all of this seems clear enough. Support species conservation, and sustainable resource management. Unless it somehow directly affects those areas, I doubt that the ornamental fish trade is ever going to become a priority. At least that's how it looks & sounds to me, especially after viewing the Susceptible Species list, and the Proposed List of Diseases. Those lists are very specific, targeting specific diseases, and specific aquatic animals known to frequently carry 1 or more of those diseases.

I'm still at a loss as to how discus ended up on the list?

[Evolution]

The growth and globalization of international trade in aquatic animals has expanded rapidly over the last decade.

That means it's broader than Canada, it's world wide. That means that other countries import fish into their countries too. Some of those countries import 10,000 time more fish into their country than we do into Canada. Those countries already have systems in place. Systems that Canada will be benefiting from. We have a system that works for terrestrial animals and plants, which is going to be the same system used for fish, that systems works with other countries systems. I'm willing to bet that 75% fish that come into this country come in via the US or a US transshipper. That means the US transhipper already has a network in place that meets all the US health requirements and those requirements likely exceeds the Canadian requirements.

The CFIA has a long history of regulating the importation of terrestrial animals and animal products. As part of the new aquatic animal health program within CFIA, the proposed amendments to the Health of Animals Regulations will result in the inclusion of aquatic animals.

How will that system work for fish?

Where possible, the aquatic animal import program will build on existing program infrastructure and operational networks. Consultation with regulated parties on regulatory change has been ongoing since 2005 and will continue as formal regulatory processes proceed.

That means that the structure used for terrestrial animals and plants, that works, will be used for fish.

If anyone can prove that the existing program used for mammal, birds, sreptile, amphibians and plants is a sham then I suggest you do so, if not then your arguement is baseless and holds no ground.

Edited September 13, 2010 by Evolution

[RD.]

I'm willing to bet that 75% fish that come into this country come in via the US or a US transshipper. That means the US transhipper already has a network in place that meets all the US health requirements and those requirements likely exceeds the Canadian requirements.

.....previously you stated;

Do you have any idea how many diseased fish are transhipped into Calgary every week and require be hit with insane amounts of drugs to prevent the spread and wipeout of enormous fishrooms?

I believe that you have already answered your own question.

[Evolution]

The point is everyone is responsible for the role they play. The global ecconomy is going to have some scammers about trying to make a fast buck without regard to anyone or anything other than themselves. The CFIA is not a sham and the dissension you've express in this thread for the CFIA appears to be a personal issue and not anything founding on actual facts. Most everything you've said is emotional, imagined and speculated.

I believe the CFIA is doing what it knows to be the right thing for Canada, and the very real and certified science team on staff at the CFIA knows what they are doing and how things work. If you have factual information (other then your experience with the paper work getting you product over the boarder) regarding this regulation as a CFIA sham, then I think you need to call the appropriate authorites. If not, then I think it is wise to stop spreading the discordance.

[RD.]

IMO the CFIA's role in all of this seems clear enough. Support species conservation, and sustainable resource management. Unless it somehow directly affects those areas, I doubt that the ornamental fish trade is ever going to become a priority. At least that's how it looks & sounds to me, especially after viewing the Susceptible Species list, and the Proposed List of Diseases. Those lists are very specific, targeting specific diseases, and specific aquatic animals known to frequently carry 1 or more of those diseases.

I'm still at a loss as to how discus ended up on the list?

My reason for starting this thread was simple, to inform those who might otherwise not be aware of the new regulations, and to see if anyone could answer my question as to why discus ended up on this list, and/or which specific disease discus fish had been associated with.

Seeing as I don't import fish from out of the country, I don't even have a dog in this fight, so I'm certainly not getting emotional over this discussion. lol

Of course I'm speculating as to how this will all play out, just as you are. And your point is?

As mentioned a number of times in this discussion; I am not against the regulation of animals & animal products being imported into Canada, I'm actually all for it.

I just found it ironic that previously you stated;

Do you have any idea how many diseased fish are transhipped into Calgary every week and require be hit with insane amounts of drugs to prevent the spread and wipeout of enormous fishrooms?

.........and suddenly now have done a complete 360, and now state:

I'm willing to bet that 75% fish that come into this country come in via the US or a US transshipper. That means the US transhipper already has a network in place that meets all the US health requirements and those requirements likely exceeds the Canadian requirements.

And yet you somehow feel that anyone with a differing opinion, is baseless, and holds no ground? Or anyone with a differing opinion is spreading discordance, and expressing dissension.

After tossing this around for a few days, and taking a closer look at the new regs, and what's behind them, I personally don't believe that that the ornamental fish trade is ever going to become a priority with regards to these new regulations. The lists are very specific, targeting specific diseases, and specific aquatic animals known to frequently carry these diseases. Which I already stated above.

I suspect that at the end of the day there will be thousands of ornamental tropical fish species entering Canada just like they always have, no permit required.

I guess time will tell.

For now, if anyone figures out the discus fish connection, and what specific disease they have been targeted for, please share.

Cheers

Edited September 13, 2010 by RD.

[Evolution]

It's not that I've turn a 360, but that the threats CFIA focus on, monitors and tracks and the threats importers face are different types of threats requiring different types of management. The many threats a fishroom faces are limited to effecting the fishroom and will not or cannot jump to the food chain or wild populations, but there are exceptions and that is what CFIA is regulating. Also, a species can be regulated if it is suspected of a potential threat, it doesn't have to be a known direct threat. I'm more interested in what S. discus carries that S. aquafaciatus does not and is considered or known as a threat. Is the threat from wild S.A. populations or is this something coming up and out of grow out tanks and ponds?

Edited September 13, 2010 by Evolution

[RD.]

The many threats a fishroom faces are limited to effecting the fishroom and will not or cannot jump to the food chain or wild populations, but there are exceptions and that is what CFIA is regulating.

No argument there, but I think that they key is the CFIA is going to attempt to regulate this, and this attempt is going to be based entirely on a good faith system, and not much more.

That's what bothers me about how this new regulation has been designed.

I have very little trust or faith in a system that is already failing, where both importers & exporters clearly have misidentified many species of aquatic animals. In many cases these may very well be honest mistakes, but they are mistakes just the same.

The CFIA is concerned about an EU strain of crayfish plague, hence the reason for some of the various crayfish species going on their list, but the reality is most importers cannot differentiate between the various species of crayfish, and mistakes are already being made in this area as well. Many exporters use old school generic trade names to describe their stock, and nothing more. "Electric Blue Lobster" is a generic trade name used to describe several different species of crayfish.

Perhaps these new regs will force exporters & importers to change this bad habit (using generic trade names), but even still, unless there is someone at the border crossing who can identify the difference between juvenile Cherax quadricarinatus, and juvenile Procambarus alleni, or a Symphysodon discus, from a Symphysodon aequifasciatus, I don't see how all the lists in the world are going to stop any known or perceived threat to the human food chain, or native wild populations in Canada.

Personally I see a lot of potential problems within the very short list that has already been created. I'm not trying to come across as being cynical, I'm simply being realistic about something that is clearly already taking place within the aquatic industry.

[Evolution]

I think that they key is the CFIA is going to attempt to regulate this, and this attempt is going to be based entirely on a good faith system, and not much more.

I disagree, not entirely, but I disagree. There is a globalized network with the ornamental fish trade that has governments, farmers, jobers, exporters and importers alike all working together. No one wants to screw anyone, because one bad link in the chain weakens it and breaks it. The system CFIA has set up helps to keep that chain stronger.

What you are saying sounds like the CFIA would have to police the entire global network with the appropriate scientists to make their regulations work. It would be like an inspector standing at a NLS mixing vat checking every ingredient going into it. It is not possible. CFIA has to put some trust in NLS, that the ingredients listed are the ones being used to make the food, it's the law. Just like NLS puts trust in their suppliers that the product coming into their facilaty is what they asked for. CFIA can put trust into NLS because of the regulatory system in place in the US; the US has rules too, rules that are compatible to ours. And a good 75% of the fish coming into Canada either comes from the US or comes via the US. CFIA can now focus the majority of their energy and resourses at the real problem. The west coast and all the stuff coming in over there under the wire, undetected.

As for the use of taxonomy when purchasing fish for import, it is in place. When Daljeet Imports brings in electric blue crayfish from Whale Tail International they have a list to choose from. The list consists of both the nomencature of the fish and a common name. You scope the list for electric blue crayfish and beside the comon name will be the taxonomy. The list of crayfish will at any given time consist of 10-30 different availiblities of the same species to choose from. Daljeet gets to choose from about 4 different countries of origin and about 3-4 different sizes in each. The CFIA knows all this and yes, they do have faith in both these companies for obviously very good reason.

The market in Canada is small compared to the US and EU, but Whale Tail International doesn't want to loose the million $ worth of fish they sell up here every year, so they keep their side of the fence as clean as possible. The farms producing the electric blue crayfish know exactly what they are producing and they list it as exactly what it is. If they didn't, their crayfish sales would plummet. This system has been like this for 25 plus years, it isn't new.

But Jimbo's Non Business Tax Paying Back Yard Fish Imports and Silver Fish Fish Store is another story. Because Whale Tail International will not sell to them and no one in Whale's network of properly regulated fish farms and jobers will either, Jimbo and Silver are forced to use suppliers that are not inspected, monitored and regulated by governing bodies. And that is where the real problem lies. It is these guy who are likely to bring in things under the wire and cause problems for everyone else. The CFIA is going to be hard on them when they can and rightfully so. Does this mean Jimbo and Silver are going to be screwed? No, they both need to respect the rules and laws and establish themselves as trustworthy importers into Canada and then CFIA will show them the respect they earned.

[RD.]

CFIA has to put some trust in NLS, that the ingredients listed are the ones being used to make the food, it's the law. Just like NLS puts trust in their suppliers that the product coming into their facilaty is what they asked for. CFIA can put trust into NLS because of the regulatory system in place in the US; the US has rules too, rules that are compatible to ours.

Yes, and no. NLS can verify their own ingredients, just as some countries in turn analyze & verify what NLS states on their labels. Yes, the USDA/APHIS system does have rules, some rather strict ones, but only when one begins to export to EU countries do you begin to realize how carefully some countries inspect their imported products. Many of those countries do not just rely on "good faith", and actually analyze & inspect pet food products before being allowed into their country for resale. They make Canada's inspection & approval process seem like a trip to Disneyland.

As an example, Turkey tests for GMO in pet food, and due to their outdated testing equipment that is used, any positive reading at all can be enough to stop the import of the product. (even as little as .0025%) You simply get a pos or a neg reading, and a pos reading means a no go. In the UK, where more sophisticated and modern equipment is used they can verify the exact percentage, with 0.9% being the threshold for a "Contains GMO" required label.

So in some countries, even the slightest bit of GMO residue can trigger a red flag at their border. Is this a problem in Canada, or the USA? Nope, not as far as importing goes. Apparently the North American market isn't concerned about GMO products entering into the food chain, be it human, or pet. Some fun reading on that subject from Agriculture Canada. http://www.ats.agr.gc.ca/eur/4328-eng.htm

An interesting comment from that link .......

The underlying cause of consumer concern

Underlying the GM debate across Europe is the plethora of food safety alerts, including salmonella in eggs, BSE in cattle, Sudan 1 and dioxin in the poultry sector, all of which contributed to further consumer concerns about modern food production and the monitoring of food safety. All these examples highlighted historic weaknesses in both food production processes and the ability of the official organisations to monitor and communicate an appropriate response to such incidents. Following these incidents, many consumers lost faith in the "official voice" and were drawn to question its messages.

Getting back to the original subject .........

As for the use of taxonomy when purchasing fish for import, it is in place.

Yes & no. Even large scale distributors within Canada use common trade names on their wholesale lists, I've seen some of those lists, as I have seen many wholesale lists from outside of North America. Quite frankly, some of the worst distributors for using old school trade names are those based in the USA. Right now I'm holding a wholesale list from a US based exporter that has "Haplochromis Ahli" listed, when the reality is those fish are actually Sciaenochromis fryeri. The true S. "ahli" is almost non existent in the hobby. Some wholesale lists will have nothing more than "Electric Blue Hap" on their list, describing that same species.

And these aren't Non Business Tax Paying Back Yard Fish Importers or exporters, in some cases these are well known wholesalers that have been supplying the hobby trade for decades.

While I realize that many of the larger wholesalers will have the correct common and scientific names listed for their aquatic animals, as of right now there are major pet chain stores in Canada that have the incorrect nomenclature listed for their "blue crayfish", or as they have them listed "Electric Blue Lobster". These aren't little stores, that buy from backyard breeders, yet on one of those wholesale distribution lists it simply states "Electric Blue Lobster". With nothing more than a generic trade name to go off of, the fish dept. manager places the same generic trade name on their tanks.

And round & round it goes.

What you stated is simply not always the reality of what is currently taking place, or has taken place, for the past 25 years. Somewhere along the line, the ball can, and often does get dropped.

As an example, Petsmart typically sells "Electric Blue Lobster" listed in fine print as Cherax Tenuimanus, which is definitely not the case, those crays are actually C. quadricarinatus, or from what is currently being sold here locally, P. alleni. I just confirmed that with their supplier, so there's no guesswork on my part. The problem is twofold, one a supplier that uses only a generic common name on their wholesale list, and two, stores that don't insist on the correct latin name to describe what they are purchasing. The result - the consumer is not getting what they are paying for, even if the cute young gal at Petsmart insists that "they will get as big as a lobster".

You've been in this game long enough to know that aquatic animals are often misidentified, described incorrectly, or simply listed with generic common names. It doesn't just happen with small scale exporters, importers, or distributors. Then factor in the retail outlets that go outside the local distributors, and import their own fish, and things can become even more complicated. We are no longer talking about a "few" major importers, and their long term well established suppliers, but hundreds/thousands of Canadian vendors, who are dealing with suppliers from around the globe.

This has already created a weak link in the CFIA's armor with regards to the pet food trade in Canada, and IMO it will have the same effect on the livestock trade. These new regulations can & will work, but only to a degree. This is not just an opinion, but is based on what I have already personally seen take place since the pet food regs rolled out last year. As fast as one hole gets plugged up, another emerges to replace it. And I'm not pointing a finger at just the CFIA, the CBSA (Canada Border Services Agency) plays just as large a role (if not more) in all of this as the CFIA does. My issue with the CFIA is that in some instances they appear to have turned a blind eye and deaf ears as to what is taking place.

CFIA can now focus the majority of their energy and resourses at the real problem. The west coast and all the stuff coming in over there under the wire, undetected.

Take it from someone who spent his formative years on a major Canada/US border on the East coast, this is not just a West coast problem. There are those in the aquatic industry on the east coast that seemingly smuggle in illegal contraband (as in sans proper permits) on a daily/weekly basis, and apparently, get away with it.

I don't know what the answer is, and again I'm not trying to be cynical, I'm simply being realistic. You can have all the rules & regs in the world, but those regulations will only be as strong as those who have been put in place to enforce them.

[Evolution]

I'm argued out. I've listened to what you've said and we'll see what happens.