Increasing demands for fish welfare

EM5 19 AQ animal welfareObjective evaluation criteria still lacking for many fish species

People keep animals for various reasons. Pets can be companions, they can play a part in hobbies or pastimes, or they can serve as test organisms in the laboratory. And of course – as farm animals – they are used for food purposes. In affluent countries, a change in values is currently taking place that is fundamentally questioning the right to use and exploit animals. Animal welfare is an increasingly significant aspect of successful marketing.


This article was featured in EUROFISH Magazine 5/2019.


With increasing prosperity social and legal acceptance of the ways animals are treated is changing. Usage issues are moving more into the background while animal protection, animal "rights" and species-appropriate husbandry are gaining importance. This development trend, which culminates in veganism – the complete renunciation of all animal products – is increasingly influencing how fishes are kept, treated and used. Although love of animals or concern for living creatures is generally regarded as one of the main reasons for the increased interest in animal welfare individual likes and dislikes vary considerably. People tend to have positive feelings about cuddly animals that have a soft coat and big eyes, especially baby animals. On the other hand, animal species that sting, scratch or bite, that are naked, cold, smooth or even slimy are much less popular. Fish are a special case here in that they can cover the entire spectrum. While Nemo, the cute little animated clownfish, boosted worldwide interest in and demand for the colourful coral inhabitants, pushing the fish species to the brink of extinction, Spielberg's white shark triggered quite the opposite feeling… a good example of the ambivalence of human perceptions. Whereas warnings and unsightly photos printed on cigarette packets hardly stop persistent smokers from continuing to indulge their vice and risk premature death the oversized rubber shark in the film ensured that millions of over-anxious, frightened people no longer swim in the sea but prefer to stay in hotel pools.

The shift towards increased animal protection originated from the use of animal organisms such as fish, mice or monkeys for medical, cosmetic and toxicological tests. This basic concern is probably shared intuitively by many people and only rejected in a few individual cases. In many industrialized countries the use of real animal skins and furs is now also prohibited. Anyone who opposes this collectively articulated norm risks social condemnation and isolation. Animal protection organisations have discovered the huge activation potential of animal welfare for broad sections of the public. The topic can be presented easily and effectively in the media so that it triggers strong emotions. If a situation seems suitable, animal protection activists will often organise targeted campaigns around it. And in the process they sometimes don’t shrink from biased, exaggerated, provocative, and occasionally even defamatory statements. Once the campaigns against laboratory and fur-bearing animals had proved effective, the agenda was broadened to include zoo and circus animals and, shortly afterwards, the animal protection and welfare debate reached farm animals and the conditions under which they are kept.

Animal welfare is also called for in the fish sector

It was to be expected that the debate would not bypass fisheries and aquaculture. It is a known fact that sports fishermen have had to defend themselves for a long time against attacks from animal welfare and animal rights activists. This is not only about gill nets or certain fishing practices such as catch & release but is often enough due more to a fundamental rejection of this leisure activity which is then branded as "cruelty to animals". Similar accusations have also been made against commercial fishing because the fish are not immediately slaughtered on board the fishing vessel in a humane manner and so often have to die a distressful death through suffocation. Despite numerous attempts to explain that – given the size of the catches that occur during trawling – individual slaughter is not technically feasible at present, the subject is by no means off the table.

The debate on animal welfare is particularly heated and controversial in the aquaculture sector. The numerous points of criticism range from “factory farming”, allegedly too confined fish tanks and net enclosures in which the fish are constantly subjected to stress and thus unable to

pursue their normal behavioural activities, to the feed they are given and handling on the farm. Sorting and moving the fish often disturbed the group’s social structure.

Attempts on the part of aquaculture experts to explain the necessity of such practices are often questioned or even ignored by animal welfare activists. This is probably due to the special constellation of the debate in which ambitious laymen and specialists face each other quasi on an equal footing. While laymen often lack the expertise required to substantiate their accusations and so mainly use emotional arguments to justify their demands representatives from aquaculture try to correct faulty allegations with objective justification of the criticised aspects of fish farming. But it is not easy to counter emotionally influenced accusations with rational statements which can then often appear "schoolmasterly" and unconvincing… which does not, however, mean they are wrong.

It’s not easy for representatives of aquaculture to argue their case because what animal welfare activists implicitly demand – that the fishes should be able to live their lives as in nature – is for several reasons impossible in "function-oriented" aquaculture facilities. The walls of the enclosures or tanks limit their living space and in this artificially reduced environment they do not have a free choice of food and cannot live out their natural behaviours. Of course their basic needs are met, otherwise the fish would not be healthy and grow well. And that is one of the decisive prerequisites for the economic success of any aquaculture business. Animal welfare is therefore in the farmers’ own interests, as they like to point out because they only make money if their fish are healthy. So it’s a win-win situation. That sounds logical, but this reasoning does not convince everyone because animal welfare is generally understood differently by conservationists and aquaculture producers. For many animal welfare activists, health, vitality, a stress-free life or good growth are not convincing signs of a fish's well-being.

Whether fish feel pain is controversial

Differences in the understanding of animal welfare do not only result from varying "perceptions" of the opposing parties. They in fact go much deeper. The controversy is particularly evident when it comes to the question of whether fish can actually feel pain and whether they have a "capacity for experience" comparable to that of humans… which would enable them to learn, remember or make associations. Those who believe this to be the case must also believe that fishes have an awareness of some sort that enables them to feel emotions such as affection, joy or fear and, ultimately, also to "suffer". A serious, unambiguous answer to these questions is currently not possible for even scientists argue about whether fish actually feel pain or are capable of such feelings. Ardent anglers like to counter the idea of the fish feeling pain as it struggles on the hook with the flippant remark that the animal will always fight to the end. It would hardly do that if the hook were the torture that opponents of fishing claim it to be. For comparison: a bull will allow itself to be led by the ring in its nose to avoid the pain it would experience if it did not succumb.

The opinion that a fish does not feel pain is supported by scientists who deny fishes a sense of consciousness and pain perception due to their special anatomy. A fish’s brain has neither a neocortex (cerebral cortex) nor a limbic system which is responsible for consciousness and intellectual performance as a "seat of emotions" in the brain of humans. Other researchers, however, disagree, presuming that other brain structures may have taken over these functions. Fishes had highly developed senses, could taste, smell, see and perceive tactile stimuli and were therefore quite able to suffer and feel pain and psychological stress.

This is a moot point because in the absence of sound scientific evidence the assumption that a fish’s pain perception may be located in other parts of the brain is for the time being purely speculative. In addition, the perception of external stimuli must be more precisely distinguished from the perception of pain. It is undisputed that fish can perceive external stimuli but the question remains as to how these are further processed by the organism. According to the pain definition of the International Association for the Study of Pain external, "nociceptively" registered stimuli can only be "interpreted" as pain with a high level of awareness. This connection can be explained by the anaesthetic used during an operation. Although it would be very painful when the scalpel makes an incision in the flesh the patient does not feel it because his consciousness has been “switched off” by the anaesthetic.

If fish do not have the brain structures that are usually responsible for consciousness we can also assume that according to the current state of our knowledge they cannot feel pain. Responding to a stimulus alone is not enough to prove an ability to perceive pain or suffering because the ability to react to stimuli is one of the universal characteristics of animal life. It is already present in unicellular organisms that don’t have a nervous system or in invertebrates that don’t have a real brain. Escape and avoidance behaviour can be inborn or the result of unconscious associative learning processes. However, they are not clear evidence of a pain experience. Be that as it may, aquaculture producers should follow the "benefit-of-the-doubt" approach and treat their fish as if they could feel pain because even the most modern research results could never explain what a fish really "feels" or how it perceives the world.

For hard-core animal rights activists, however, such lines of thought are little more than academic hair-splitting. Which does not, however, stop them from often dominating the public debate. And that’s not so hard because even in this area "postfactual" times have dawned and subjective feelings and emotions are often felt to be of more value than scientifically founded, objectively provable facts. Instead of attempting to understand scientific analyses many people resort to catchy and easily understandable anthropomorphisms, transferring human characteristics to fish, something which makes the debate about animal welfare even more difficult.

Not everything that seems desirable is feasible.

Anyone involved in aquaculture knows that environmental factors such as temperature, oxygen and pH value are far more important to a fish’s well-being than some of the other variables that outsiders might consider essential. If the water quality is right and meets the species’ needs fishes in aquaculture can easily tolerate much higher densities than in natural waters. This can be a problem for fish producers because they have to find the right balance, i.e. a compromise between what is biologically necessary, ethically desirable and economically feasible. It is often difficult for laymen to understand why it is seldom possible to keep more than 5 to 10 kg trout per cubic metre in an unventilated pond where the water is renewed three to five times a day, but it is possible to keep 30 to 150 kg trout in sufficiently ventilated flow channels and tanks without the fish necessarily suffering any negative effects from these high densities!

In addition, benchmarks and standards cannot be transferred from one fish species to another or from one type of installation to the next. What is feasible in a flow-through or recirculation system would often be impossible in open systems such as net enclosures. Accusing fish producers of "factory farming", as some critics of aquaculture do, shows their lack of expertise. Not every fish from aquaculture can be assigned to schooling fishes that are known to form groups "voluntarily" in nature, but even these non-schooling species tolerate socialization much more easily than generally assumed. It is often even the case that higher densities reduce a fish’s stress because the fishes become "territorial" at low densities, occupying and defending their patch against intruders. However, since water quality can deteriorate with higher densities and susceptibility to the spread of diseases will then increase, it will be in the fish farmers’ own interests to take care not to exceed the limits of what is feasible. Some countries even issue regulations laying down the permitted maximum stock densities, for example in salmon farming in Norway and Chile.

These rearing conditions already fulfil essential criteria listed in the concept of the "five freedoms", the first version of which was published by the British Farm Animal Welfare Council (FAWC) in 1979 and confirmed by its successor organisation, the Animal Welfare Committee, in 2011. In addition to freedom from pain, injury or disease, freedom from discomfort by providing an appropriate environment including shelter, freedom from fear and distress, and freedom to express normal behaviour, the freedom from hunger and thirst is also particularly emphasised. Fish reared in aquaculture are today mostly fed formulated feeds which meet the fish’s specific needs in different phases of its life. In contrast to life in the wild, where animals often have to compete for the available food, aquaculture feeds are dosed according to stock, age and environment so that all the fishes get their share. An exception to this general rule is the period immediately before slaughter and processing when the fish are no longer fed so as to empty their intestines. Although this measure makes sense for hygiene reasons and is often even necessary to prevent bacterial contamination of the carcass it is repeatedly criticised by animal welfare activists as not being animal-friendly and thus a violation of animal welfare.

This example shows that the concept of the five freedoms can offer no more than an orientation aid for assessing animal welfare in practice and must not be understood as a dogma. Some technical measures in the handling of fish are viewed highly critically by the general public and are often even rejected. This is in many cases mainly due to a lack of knowledge and understanding of the necessity of the procedures involved. The fish pumps that are used for transporting fish are a good illustration of this. A lot of consumers are appalled by the idea of pumps and find it cruel, although in fact the pumps are gentler and more animal-friendly than traditional nets. What disturbs people is probably the thought that the fishes are sucked up like thick sludge and then have to pass through a pump. It’s perhaps not generally known that the pumps only generate a stream of water in which the fish swim comfortably and largely stress-free from one place to another.

What is sometimes needed to defuse criticism or to help people to a better understanding of certain work processes is a clearer explanation of what is actually going on. Because not everything that is considered "good technical practice" in aquaculture is viewed and accepted without contradiction by people who have different views of the world and of life. There are still considerable gaps in the European and international legal framework for animal welfare. Some directives and regulations offer orientation but there is a lack of clear requirements. EU Directive 98/58/EC lays down minimum requirements for the protection of animals kept for farming purposes, including fish. In 2005 the Council of Europe published its "Recommendation on the welfare of farmed fish" and in 2008 the World Organisation for Animal Health (OIE) published its "Guiding principles for fish welfare". In the same year, EFSA's Panel on Animal Health and Welfare assessed housing facilities for important farmed fish species (salmon, trout, eel, sea bass, gilthead, carp) in the EU, also addressing animal welfare aspects. One thing of which everyone in the fish industry should be aware is that animal welfare is likely to be the next "hot topic" after HACCP, traceability and sustainability.