Tilapia health inspections
Tilapia are under the authority of the FDA not the USDA. The FDA neither preforms nor requires health inspections. It would be nice if a select handful of elected and appointed state officials understood this fact before dreaming up requirements that are impossible to achieve.
The truth about inspections
The Federal Government of the United States does NOT require tilapia health inspections. In fact, there aren't even any US Government standards for testing tilapia. The under-staffed FDA inspects one species per year at the farm level, however they aren't looking at the health of the fish. Instead, they are looking for the use of banned substances. For the FDA, 2015 was the year of the tilapia, and now that those inspections are behind us, we probably won't be seeing them again within our lifetimes.
The handful of state bureaucrats who have attempted to write statutes or set policies requiring tilapia health inspections, have done so without understanding aquaculture industry practices. In at least one case, the actual task of legal writing was handed down to a junior staffer who took for granted that there was some kind of inspection system already in place. The net result of these misguided attempts to regulating an industry that they don't understand have only served to punish their citizenry and stifle aquaculture within their borders. Ironically, these very same bureaucrats unknowingly allow un-inspected foreign seafood into their state with opens arms. Fortunately for most of us, this appears to be isolated to just a few states.
The buyer determines the need for inspections
Even though the Federal Government doesn't require tilapia health inspections, grocery stores, processors, and distributors may be required to obtain health inspection certificates from the farmer as a condition of their own insurance, or as part of their FDA certified HACCP program. A health inspection certificate would also be very handy to have in a civil lawsuit to prove that everything was done to ensure the health of the complainant. So just to be perfectly clear, we aren't saying that tilapia health inspections don't exist, we are saying that the need for them is determined by the particular requirements of the company purchasing the fully grown tilapia from the farmer.
Important point: HACCP (pronounced hassip) is a food safety program developed by each individual company that processes seafood like tilapia. These programs are not reviewed or approved by the FDA. The FDA does however, certify certain individuals who have received special training to develop HACCP programs. Every company has a different program to suit its particular needs. Tilapia hatcheries and farmers that sell whole tilapia, dead or alive, are not required to establish HACCP programs because they only apply to tilapia that is being cut or processed in some fashion.
When should tilapia be inspected?
Tilapia spend four to eight months growing to a harvestable size in relatively close quarters. During this time they can contract any number of diseases and infections. A tilapia farmer striving for excellence, will send a few fish off to a lab for evaluation prior to selling or processing them. If correctable problem is detected, the necessary action is taken, and the tilapia are re-tested before harvesting. On the other hand, a dishonest or desperate tilapia farmer may attempt to hide tilapia health problems to avoid financial loss. Whatever the case may be, it is the buyers responsibility to ask for, and the farmers duty to provide, documentation that the tilapia were free from any health problems as close to the processing or sale date as practical.
Who does the inspecting?
Tilapia health inspections are performed by private labs and universities that offer these services for a fee. The procedures for each lab can vary, but generally they ask that you hire a veterinarian to collect 150 or more specimens and send them to the lab. If you need help finding a veterinarian who knows how to pack and ship fish, you might try asking the lab doing the testing, or you can call the USDA Animal And Plant Health Inspection Service (APHIS) and see if they know of anyone in your area. Remember, that the USDA does not regulate or inspect tilapia, so don't take it out on them if they aren't able to assist you.
What are they testing for?
The lab works for you, they will test for whatever you want. But herein lies another problem with states that require tilapia inspections. They ask to see a tilapia health inspection report, but they rarely specify for what diseases the tilapia are to be tested. It's like having them ask for a license, without specifying what kind of license they want to see (drivers, pilots, fishing, marriage, etc). You must find out what the buyer wants your tilapia to be tested for, before you hire a lab to do the work. Some of these tests can be costly, so you'll want to get it right the first time.
What about tilapia hatchery inspections
Tilapia hatcheries have two things: brood stock and baby fish. The brood stock are permanent residents. The baby fish are there from four to six weeks. Since tilapia health inspections involve killing and dissecting the fish, having brood stock inspected would render a hatchery nonexistent. As for the baby fish, forget the fact that they aren't developed enough to be properly examined, they aren't at the hatchery long enough to develop diseases in the first place.
Having a disease-free hatchery is self-evident. If the brood stock had any diseases, they would die. Even if they didn't die right away, it's very unlikely that they would spawn. In the very unlikely event that they spawned, the offspring would be dead on arrival. Tilapia eggs and fry are extremely delicate and will die if you look at them wrong. The notion that an egg or a fry, which hasn't even developed fins or scales to protect it, can somehow contract a disease and survive is a fantasy.
Hatcheries can also have labs test for bacteria inside the guts of tilapia fry, which may indicate unsanitary conditions, however there are two problems with this: One, bacteria is not a disease and is not reported on most state-required health certificate, and two, most tilapia hatcheries isolate the water used to hatch from the water used for fry. In our own hatchery, we have several isolated water systems. So testing fish from one system, provides no useful information about the rest of the hatchery. These tests are typically ordered by the hatchery itself to trouble-shoot particular problems by ruling-out possible causes.
State government officials please read this: None of you have ever visited a tilapia hatchery. They are not set up how you imagine. Every single breeding colony and fry tank is isolated from the next. Systems do not share the same water. The veterinarians collecting the specimens for inspection are private citizens without any oath or obligation and are paid a fee or gratuity by the hatchery operator for their services. The testing labs are private for-profit operations that are only required to report a handful of diseases to the Federal Government, none of which are found in tilapia.
These testing labs derive their income from customers like Lakeway Tilapia and will do whatever we ask with the results. Hatcheries can order two kinds of inspections: internal and regulatory. If a regulatory inspection returns a negative result, it is simply used internally and not reported. A hatchery operator gets to pick the fish that are submitted for examination and can exclude fish in any system from being tested or re-tested.
Finally, testing requires that the fish be dissected. We are required to kill them at the hatchery before the veterinarian ships the dead fish to the lab. This makes it impossible for our customers in your state to get the fish that were actually tested. For the sake of the people you serve, stop pretending that testing a handful of two-week-old tilapia fry from a single clean stand-alone aquarium will tell you anything about the overall conditions at a hatchery or prevent any disease from getting into your waterways.
The Internet origins of the hatchery health inspection myth
The relatively recent idea that tilapia hatchery health inspections provide credible information about the conditions in a hatchery, or are even available on a national level, was first concocted in 2012 by a full-time medical staffing representative and amateur aquaponics gardener. He boldly claimed on his new website that "all states require that hatchery stock be inspected according to OIE/AFS standards by a properly credentialed Doctor of Veterinary Medicine". Adding to this marketing claim, he stated that "you could be held personally liable". Well, as you probably guessed, he used all of this rhetoric to lead the reader to only one conclusion: that purchasing tilapia fingerlings out of his Missouri-based IBC totes was the only legal option.
So what is OIE/AFS anyway?
OIE stands for Office International des Epizooties, a foreign entity that publishes the International Aquatic Animal Health Code and Diagnostic Manual for Aquatic Animal Diseases. AFS stands for the American Fisheries Society, a private club that publishes a Fish Health “Bluebook”. It's important to note that the AFS is not a government agency. Neither the OIE or the AFS has any regulative, legislative, or enforcement authority in the United States. The US Fish and Wildlife Service does however maintain a Fish Health Database, and recognizes the literature published by the AFS and the OIE as being useful in diagnosing fish diseases.
Tilapia importation permits
Of the few states that do require tilapia health inspections, most do it in conjunction with an importation permit. This has nothing to do with public health and everything to do with politics. In several states, corporate and private interests have found very creative ways to block outside competition or impose their will by way of environmentalists and environmentalist groups. In some cases, the State's Department Of Natural Resources, an agency typically managed by environmentalists who care more about beaver dams than human life, have been put in charge over aquaculture and even certain aspects of agriculture. Politicians, who know nothing about farming, give these non-elected appointees sweeping powers to set policies and impose their personal beliefs.
The singular focus of every environmentalists is to stifle or eliminate foreign species into their state, and the importation permit is their favorite tool. Fortunately for the rest of us, most state DNR's are nothing more than paper tigers with no real enforcement authority. They may be able to take your fishing pole if you don't have a fishing permit, but they can't take you to jail or charge you with a crime. They make a lot of rules that aren't laws, and have clerks who don't understand the difference. Fortunately in most cases, simply saying that you got your fish from someone local on Craig's List will end any point of discussion they have.
Important point: Do not be intimidated by your state's fish and game department. They are not a law-making body. They are only allowed to enforce the actual laws enacted by the state legislature, which may be vague. The clerks answering the phones do not know the difference between laws and policies. In order for someone to be punished for a crime, there must first be a law that defines the crime. Policies are established in part to aid in the enforcement of vague laws, but far too often these agencies over-step their authority and over-reach their policies outside the bounds of the law. There are laws for everything down to the crime and punishment for not stopping at a red light. Demand that they provide you the actual state statute that they are enforcing.
Hall of shame: New Mexico
In 2015 the Government of the State of New Mexico gave the people what they wanted: the ability to raise tilapia legally ...or so they thought. Before the ink was even dry, their environmentalist-controlled Department of Game and Fish (DGF) was scurrying to circumvent the newly passed law. Under the guise of protecting their state's indigenous species, they immediately made a rule that all tilapia raised within their state must be all-male or triploid (sterile). They also made a rule that anyone who "imports" fish into New Mexico must be on an "approved senders" list. To fix this oxymoron, they re-defined "importer" to include the definition for "exporter". These two rules alone have completely reversed the will of the people, who've petitioned their elected officials for years for the right to raise tilapia for their families.
In case it's not obvious, or even better, if you are an elected official in the state of New Mexico that has been directed to this page. Let me explain how New Mexico's DGF has made a mockery of their state's new law. By making a rule that all tilapia raised within their state be all-male, they have doomed everyone in New Mexico to importing fingerlings. All-male tilapia cannot breed, and no female brood stock are allowed. They also disallowed species that naturally produce all-male offspring, specifically Wami hybrids, so that the only all-male tilapia that can be imported must first be treated using sex-reversal hormones. A practice that is nearly non-existent in United States. The same goes for creating sterile tilapia.
After making the rules, and probably patting themselves on the back, they realized that hatcheries located outside of their borders, like Lakeway Tilapia, would not give a second thought to sending tilapia into New Mexico. After all, as far as definitions go, we are located in Tennessee, and therefore an "exporter". So the environmentalists did one more goofy thing, they re-defined "importer" to include the language used to define "exporter", excluding the shipping companies and the post office of course. Currently there are no hatcheries on their "approved senders list".
The last smug rule, as if to thrust a middle finger upwards, made it perfectly legal for their own officials to import any tilapia and raise it as they see fit. Apparently the general consensus of New Mexico's DGF is that they are the only people qualified to keep fish in an aquarium, and out of lakes and rivers. Shame on them.