EL ESTUDIO LINGÜÍSTICO DEL TEXTO LITERARIO

For some aquaculturists, participation in third-party eco-labeling may not be desirable. Shellfish aquaculturists who still wish to engage in environmentally friendly practices or ensure their operations are sustainable, may choose to assess their practices against industry created guidelines. These guidelines are often voluntary and free to use. In many cases, shellfish growers tend to be fervent advocates for environmental quality because they own or lease the land on which they farm (Dewey et al., 2011). Unlike fishing that can takes place in open-access or poorly enforced waters, stock ownership and farm sites are clearly defined in aquaculture, providing farmers with an incentive to invest in the long-term viability of the operation (Lee, 2008). Even some federal programs acknowledge shellfish growers as environmental stewards. For example, the National Sanitation Shellfish Program encourages shellfish growers to become advocates for water quality, since the quality of their product depends on good

water quality (Dewey et al., 2011). This commitment to stewardship causes industry groups to form best management practices and perform self-regulation.

The shellfish mariculture industry in the United States has been extremely active in self-regulation through the use of industry created best management practices (BMP), also called codes of practices or performance standards. Best management practices are protocols or procedures that provide guidance and instructions for a range of construction, operation, and management practices in aquaculture

(Hargreaves, 2011). The use of best management practices (BMPs) can help to relieve perceived and real negative impacts of shellfish aquaculture.

The manuals and codes created by industry can consist of either management standards or performance standards, or a combination of the two. Management standards specify the methods producers must use to achieve a given standard, while performance standards specify the goals (Hargreaves, 2011). For example, a

management practice would command that an operation have a particular technology in place to improve water quality, while a performance standard would set a level for water quality and allow the producers to use whatever technology necessary to meet that standard. Performance standards tend to encourage innovation because they allow the producer to meet a standard whatever way they wish. However, best management standards may be easier to verify from an enforcement perspective. For example, it is easier to verify that an operation uses a particular technology but it is more expensive and time consuming to actually test the water quality.

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2.6.1 East Coast Shellfish Growers’ Best Management Practices

The East Coast Shellfish Growers Association (ECSGA) is an industry-formed association for growers along the US east coast, whose purpose is to “promote

responsible commercial shellfish aquaculture through market research and promotion, active involvement in public education, [and] participation in policy formation” (ECSGA, 2010). Benefits of membership include listing on ECSGA’s website for growers, dealers, and hatcheries, advertising for suppliers in ESCGA’s newsletters, representation to federal agencies, and immediate response to press inquiries and shellfish illness reports (ESCGA, 2011). In June 2010, ECSGA created a set of Best Management Practices. The ECSGA does not report on its website if any growers have tried to meet or use the BMP yet (ESCGA, 2011). ECSGA members pay annual membership dues, based on their annual gross sales (ECSGA, 2011). Members are permitted and encouraged to adopt the BMPs in the manual with no additional costs for using the manual. This manual is also available online so other growers not in ECSGA could also potentially use these guidelines. Since there are Rhode Island growers in the ECSGA (ECSGA, 2011), it is important to consider that RI growers may use or begin to use these BMPs.

The ECSGA Best Management Practices Manual instructs the farm to create their own farm-specific BMP based on the suggested BMP statements in the

document, instructs the farm to incorporate whatever elements they choose to include, and gives the farm freedom to modify the BMPs as they wish (Flimlin et al., 2010). The ECSGA Code of Conduct for Molluscan Shellfish Culture in the Eastern US is composed of common sense principles that most shellfish growers would instinctively

follow as environmental stewards (Flimlin et al., 2010). This code of conduct is meant to be incorporated into the farm’s BMP. The main elements of the BMP manual include the permitting process, site selection, a good neighbor policy, sourcing of seed, operational/ maintenance issues, the handling and reporting of disease,

considerations of protected species and habitat, shellfish sanitation and its relevance to protection of human health, and record keeping (Flimlin et al., 2010). The BMP manual includes a blank farm-level BMP template that members of the ECSGA can modify and fill out based on their goals and specifics about their farm. The ECSGA program does not require that a third-party auditor ensures that the guidelines are met, but just recommends how aquaculturists should conduct their practices.

Industry standards are sometimes criticized for not being impartial and for allowing industry to include standards that are simple or inexpensive to meet. The Food and Agriculture Organization of the United Nations (FAO) created standards for creating aquaculture certification programs to ensure credibility of aquaculture

standards. In these guidelines, FAO requires that “the accreditation body or entity should be independent and impartial… [by being] independent from vested interests [and] be free from any commercial, financial, and other pressures that might influence the results of the accreditation process” (p. 21, FAO, 2010). FAO also requires that the certification body not have any conflict of interest and should not have any interest in the aquaculture operation other than for its certification services (FAO, 2010). For this reason of impartiality, third-party certifiers, such as Aquaculture Stewardship Council or Food Alliance, may be preferable to industry set standards.

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