This post explores our strategy to advance fish welfare policy change in India, detailing our multipronged approach.
FWI India's Managing Director, Karthik Pulugurtha, at an aquaculture farm in Andhra Pradesh.
Through our policy and government work in the third quarter of 2022, we have identified four promising avenues to help fishes in India by:
Advocating for the government's guidelines becoming law in an attempt to help over a million fish.
Urging the apex animal welfare body, the Animal Welfare Board of India, to release fish welfare advisories and circulars.
Addressing the welfare gaps in state policy through advocacy.
Working with the Bureau of Indian Standards to develop more ethical standards for fish.
Though each avenue has its merits and limitations, we are excited to pursue these in the coming months. This blog post covers details about Fish Welfare Initiative (FWI) India’s learnings in the third quarter of 2022 and the opportunities they provide to work with governments, statutory authorities, and bodies for fish welfare policies and standards.
A Move That Can Help Over a Million Fish: Advocating for the Government's Guidelines Becoming Law
An Alliance for Responsible Aquaculture farm in West Godavari, Andhra Pradesh.
An opportunity to help farmed fish was identified through some of our secondary research. We learned that some states like Uttarakhand and Maharashtra have advice on best aquaculture practices on their state fisheries departments’ websites. The interesting thing about these standards is that they urge farmers to take better care of their fish. While some of these provisions are not ideal for fish welfare most of the advice coincides with practices that promote fish welfare.
Currently, this information is listed as aspirational guidelines or good-to-know information for fish farmers. They lack legal backing and implementation capacity because they are not formally notified by the respective state fisheries departments by way of a Government Order/s (G.O.), or a similar legal notification process.
India’s quasi-federalism gives its different states the power to enact laws that fall under the state list. Fisheries is a subject under the state list; new laws related to fisheries and aquaculture in a particular state are passed by the respective state government.
Strategy: We plan to work with state fisheries departments to legally notify higher welfare aquaculture guidelines as mandatory practices. Once state fisheries departments legally notify higher welfare aquaculture practices it would make them enforceable. All aquaculture farmers in the respective states would have to abide by the notified standards and would even be liable for non-compliance.
Path to Impact:
Despite being fraught with challenges, India’s commitment towards policy intervention and enforcement connected to animal farming improves. For Instance, based on advice from environmental and animal protection organizations the Central Pollution Control Board of the Indian government has re-categorized large dairy and poultry facilities as major polluters requiring greater compliances and scrutiny. This policy move introduces a host of checks and balances that make it harder to set-up and run factory farms.
What is more, citizens trained by animal protection organizations like People For Animals, through a fellowship program, are increasingly becoming part of the state animal welfare infrastructure and policy wings of animal protection organizations. This will ensure that there is greater scrutiny in favor of enforcing animal welfare policies. Fish welfare policy would have a greater opportunity to thrive as this policy ecosystem develops and takes root.
Having said the above, the crucial benefits that animal welfare legislation brings is the legitimacy it adds to concerned citizens and animal protection organizations. When there are laws, bureaucrats and authorities are made responsible for their enforcement and concerned groups will be able to work with these officers to implement change on the ground.
Working with the Apex Animal Welfare Body to Introduce Fish Welfare
A mrigal carp in an aquaculture pond. Mrigal is one of the three Indian major carp species that are commonly farmed in India.
India, unlike many other countries, has a host of animal protection laws and institutions. The prominent among these is the Animal Welfare Board of India (AWBI) which is the central statutory advisory body on Animal Welfare Laws and promotes animal welfare in India. From ensuring that animal welfare laws are followed, providing grants to animal welfare organizations, and advising the Government on animal welfare issues, the Board has been the face of the animal welfare movement in the country for the last 50 years. The Prevention of Cruelty to Animals Act, 1960, of which the AWBI is custodian, includes, in its definition of an ‘Animal’ fishes too. However, the AWBI has not yet stated its position on the welfare of fish.
Relying on a 2013 advisory of the AWBI stating that the use of gestation crates to hold pigs violates The Prevention of Cruelty to Animals Act, 1960, our partner organization Mercy for Animals recently campaigned to ban the use of gestation crates. The governments of six significant states—Delhi, Uttar Pradesh, Mizoram, Manipur, Uttarakhand, and Gujarat—prohibited using gestation crates to hold pigs after appeals from Mercy For Animals India. MFA’s success inspired us to approach the AWBI to endorse higher welfare aquaculture practices.
Strategy: We plan to work with the AWBI to issue advisories for welfare oriented aquaculture practices and dos and don'ts in line with The Prevention of Cruelty to Animals Act, 1960. This exercise will be executed systematically by:
First, tackling the most critical welfare issues like dissolved oxygen, stocking density, and pH levels for Indian major carp (IMC) by submitting draft standards for the AWBI to endorse.
Second, we plan to submit a letter to the AWBI to advise fish farmers, sellers, and consumers not to indulge in cruel practices like live fish descaling or recreational fishing.
Third, once we confidently develop our higher-welfare standards for IMC through learnings via our farm-level interventions in our Alliance for Responsible Aquaculture, we plan to request AWBI to endorse them via SOPs or farmer booklets/manuals.
Path to Impact: AWBI advisories and circulars have good credibility with the courts, government departments and statutory bodies. AWBI advisories or circulars endorsing welfare oriented aquaculture and fishing practices would serve as foundational documents for us to rely on in our advocacy efforts with different state governments. The efforts to implement the AWBI advisories can be further bolstered by collaborating with the animal protection advocates and organizations in various states.
Addressing the Welfare Gaps in State Policy
Through our research and communication with state fisheries departments we learned that most states have not issued orders for stocking density of Indian major carp (IMC). Almost all state departments of fisheries confirmed that they have not issued any orders for permissible dissolved oxygen (DO) levels and pH levels for IMC.
Strategy: To begin, we plan to take this opportunity to fill policy gaps and advocate with the state fisheries departments to issue orders for stocking density, DO, and pH levels for IMC from a higher welfare standpoint.
Our site visits to fish markets revealed poor water quality and welfare in the housing and transport of live fish. By submitting reports and advocating with the marketing boards, committees and the government we have identified the below strategy to address the welfare, heath and food safety concerns from farms to markets.
Improve welfare of live fishes by working with the government to upgrade housing, water quality and transport of live fishes.
Capacity building of government marketing departments, fish farmers and vendors about fish welfare through workshops and info-graphic posters.
Path to Impact: These opportunities would help us make interventions from the farms to the markets and even transit. Capacity building with the government, farmers and vendors would increase sensitivity to fish welfare issues. We would be able to work with the government to improve policies for aquaculture and fisheries and their implementation in various states.
Contributing to the Development of More Ethical Standards for Fish Through the Bureau of Indian Standards (BIS)
The BIS is the National Standard Body of India established under the BIS Act, 2016, for the harmonious development of standardization, marking, and quality certification of goods, products, and testing. BIS has a Food and Agriculture Department (FAD) and many committees within it. FAD 12 is the Fish, fisheries, and Aquaculture Sectional Committee.
Fish Welfare Initiative India Foundation has been in touch with the Member Secretary of the FAD-12 and requested them to add FWI India to the committee’s mailing list. Regular follow-ups with the bureau have recently confirmed our addition to their mailing list, which is a valuable win for our work in the country.
FWI India will now have the opportunity to provide comments, objections, technical inputs, and working drafts from a higher-welfare aquaculture standpoint for standards developed by the BIS in the fields of:
Fisheries and Aquaculture including, but not limited to, terminology, technical specifications for equipment, operations, characterization of aquaculture sites, environmental monitoring, data reporting, traceability, waste disposal, code of transport, and maintenance of appropriate physical, chemical, and biological conditions.
Fresh, processed, and packaged fish; fisheries and aquaculture products and by-products.
Fish feed and feed ingredients.
Physical, chemical, microbiological and organoleptic methods of test pertaining to this committee.
Path to Impact: BIS standards are enforceable when mandated by court, the legislature or through government orders, they also serve as aspirational standards for businesses and producers. Working for the BIS on aquaculture and fisheries standards is a novel opportunity for FWI India as the BIS has no standards in these categories as of now. We will also be able to build credibility as a research and implementation organization with governments and departments.
We look forward to pursuing these possibilities in the fourth quarter of 2022 and through 2023. Working with state fisheries departments, governments and statutory authorities responsible for aquaculture and fisheries operations and standards puts the work of FWI India in a unique and pioneering space, allowing us to spearhead fish welfare policy in the country.