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In the early 1970s, the Fish Processing Operations Liquid Effluent Guidelines were promulgated under the Canada Fisheries Act as a stop-gap measure to provide some measure of control over the effects of fish plant operations along the coast. In the immediate wake of the announcement of these voluntary measures, workshops and training sessions were held across Canada to outline the issues and to recommend the application of the Guidelines and other measures for the sake of nearby receiving environments. At the time, little thought was given to potential human health impacts, though these have certainly arisen in subsequent years. Over the years, some provinces have also stipulated standards of this nature in their licensing requirements for fish plants but they have invariably drawn heavily upon the federal guidelines to avoid inconsistency.
Since that time, little has been done to either assess the individual and cumulative impact of fish plant operations or to identify suitable standards for their effluents and measures to achieve these standards. In the meantime, virtually every other land-based source of marine pollution has fallen under increasingly strict controls. At the federal legislative level, examples include mandatory regulations governing the food processing sector, pulp and paper mills, mines and milling operations, all made pursuant to the Canada Fisheries Act. There are also stringent control measures of a more general nature under the Canadian Environmental Protection Act and the Canadian Environmental Assessment Act. Similar safeguards exist at the provincial level in most jurisdictions.
One can speculate on the reasons for this obvious oversight in the federal regulatory net. Fish plant effluents are largely organic in nature and the traditional view has been that returning to the ocean what came from the ocean could do no harm. Then there was the now discredited belief that the oceans are vast and have an unlimited capacity to absorb any amount of organic waste material. These explanations, based as they were upon inherent misunderstandings of the potential environmental consequences of fish plant effluents, only serve to strengthen the need to take action without further delay.
In the absence of regulations to guide and control the industry, incidents that have arisen have required taking legal action after the fact under the provisions of Section 36 (Deposit of Deleterious Substances) and Section 35 (Harmful Alteration, Disruption or Destruction of Fish Habitat). Such remedies are never satisfactory for anyone concerned because, by the time such action is taken, the environment is already harmed. Moreover, regardless of the court decision in the legal action, any subsequent improvement in the status quo is not a certainty. Restoring damaged habitat is a great deal more difficult and costly than preventing the damage in the first place.
Ideally, it should be possible to work with the industry to prevent such problems from occurring. Often times, the stumbling block is not technical but economic. There are numerous commercially available technologies that remove particulates, Total Suspended Solids (TSS), and nutrients (Phosphorous- and Nitrogen-based compounds), and to reduce Biological and Chemical Oxygen Demand (BOD/COD). Generally speaking, more than one method is needed to treat the effluent to acceptable standards (levels that will lead to an improvement in the condition of the receiving environment). For example, one commonly recommended method, Dissolved Air Flotation (DAF), is relatively inexpensive and is highly effective at removal of TSS and BOD/COD, but does little to reduce levels of ammonia and nitrates and other nutrients that can lead to oxygen depletion in the receiving environment. Biological treatment systems designed to remove the excess nutrient loading are a great deal more expensive and technically more complex than a DAF system.
The cumulative cost of installing multi-stage treatment systems that deal with all elements of concern in a large-scale fish plant operation can be equivalent to the cost of installing tertiary sewage treatment for a small town. Such costs are prohibitive for many plant operators. As a rule, fish plants in Canada sell most of their product abroad and compete, therefore, with processors in countries where labour costs are lower and environmental controls may be negligible or non-existent. To ask them to absorb such costs could put them at a competitive disadvantage that might require them to move their Canadian operations elsewhere. Furthermore, consistency of treatment within Canada is imperative if one plant operation is not to be left at a competitive disadvantage compared to others.
All of these issues demand a solution that goes beyond simply changing laws and regulations. This needs to be done in the long term to be sure. But any new regulations need to provide for control measures that are realistic from an economic standpoint and effective from the environmental standpoint. This will require further work to identify low cost improvements that can be implemented immediately. New, unconventional and low-technology methods may be practical, once proven in pilot scale testing. Ideally, such methods should begin by recovering as much of the product as possible and then exploiting the remaining waste stream as a nutrient raw material to produce fish meal or other secondary products, thus returning savings to the operation through sale of additional product.
A number of possibilities have been explored in hypothetical or academic terms but have not been commercially proven. Other potential solutions exist in Canada and other parts of the world, but have not been tested in Atlantic Canada. A starting point is the development and application of locally appropriate best management practices (BMPs), something that has not been undertaken to date. This requires careful examination of the tools available and their applicability in the local context. Going beyond that, there is a need to examine more innovative ideas which may include:
The list of potential solutions is a good deal longer than the few examples cited above. The concept needs to be fleshed out further through debate among fish plant operators, environmental control consultants, academics and scientists in both university and government. Not to be forgotten in this dialogue is the voice of the community itself. Not only do they have the most to gain from improvements of this kind, but they may also have ideas that could lead to unconventional solutions.
In 1986, DFO's Gulf Region was searching for solutions to what was already being recognised as a growing problem of fish waste disposal in the region. Martec Limited, the Canadian Institute of Fisheries Technology at the Technical University of Nova Scotia (now part of Dalhousie University), and DPA Group co-operated with staff of the Gulf Region to co-author a study on the magnitude of the problem and potential solutions.
This study was not limited to the issue of liquid effluents but looked at the entire processing chain to develop a better understanding of the overall quantity of fish wastes not being utilised for primary or secondary products. The focus was, however, on the solid waste from fish and shellfish processing. The results were staggering to say the least. At the time, it was estimated that 33,000 metric tonnes of solid fish waste were being generated in eastern New Brunswick alone, with two thirds of that figure arising from seafood processing operations in the northeast. Over half the quantity of solid waste generated was a result of shellfish processing. Only 60% was utilised in the production of fish meal, the rest either being landfilled, spread on agricultural fields or dumped at sea.
The study went on to examine additional opportunities for making use of this valuable raw material. The most promising alternatives included production of chitin and chitosan from shellfish waste and fish silage from finfish waste. But other less regionally familiar options, including fish protein hydrolysate and concentrate, surimi, aquaculture and agriculture feeds, zoo and pet food, glue and gelatin, insulin and other pharmaceuticals and nutraceuticals, pearl essence, marine animal leather and a variety of non-edible uses of fish oils were also examined.
A version of the Fish Waste Disposal Practices and Options for Eastern New Brunswick (1986) is available in PDF format. To download a PDF copy (2,315 kb) click on the image.
It was against this backdrop that the idea evolved to hold a workshop, focussing initially on a specific environment of the Gulf coast of New Brunswick, in order to identify techniques worthy of further research and pilot scale testing. Participants would need to include representatives from the fish processing industry, government, environmental consulting and technologies, community groups, environmental non-governmental organisations, and centres for research and development and higher education.
With this objective in mind, Fisheries and Oceans Canada, Environment Canada, the New Brunswick Department of Environment and Local Government, and the New Brunswick Department of Agriculture Fisheries and Aquaculture decided to organise this workshop as the first step. The goal was to identify solutions for improved in-plant processes and effluent controls in the fish plants of New Brunswick's Gulf coast. The full list of the workshop co-ordinating committee is found in Appendix D. In addition to the four government departments named above (which each provided either a co-champion or staff support) it included representatives of the New Brunswick Seafood Processors Association, the University of Moncton (Shippagan Campus), the University of New Brunswick, the National Research Council's Industrial Research Assistance Programme (IRAP), and the Marine Products Research and Development Centre Inc. (MPRDC) in Shippagan. The agenda of the workshop is included as Appendix E.
Not entirely by coincidence, the regional working group of the National Programme of Action (NPA) for the Protection of the Marine Environment from Land-Based Activities had just begun a programme of studies aimed at combating the nutrient enrichment problems associated with fish plants. And so it became an obvious liaison that the two processes should work in partnership and a representative of that group was invited to give the first technical presentation of the workshop.
A version of the FISH PLANT EFFLUENTS: A WORKSHOP ON SUSTAINABILITY follows. It represents the results of that workshop. To download a PDF copy (1,132 kb) click on the image.
To receive a printed copy Contact Us.
Three things stood out as being essential if we are to carry on the significant progress begun by this workshop.
First was the necessity of creating a working group, rather than a more formal task force. The initial geographic focus would be the Gulf shore of New Brunswick but only as a starting point, because these problems and the opportunities to resolve them are common throughout the region. It was obvious that industry, regulatory organisations, academic and research bodies, communities and environmental NGOs should all be invited to participate. The motivator could be the Canada Fisheries Act, though that would be the heavy-handed approach and the interest and concern demonstrated by those representing the industry at this workshop also indicate that such an approach is not needed. On the other hand, a meaningful time frame is needed to sharpen the interest of everyone involved in the problem. It was also reasoned that we should look at the scale of the problem from the point of view of sources to be contained and controlled; for example it seems evident that we should also be looking at including the effluent from fishing vessels as an issue to be addressed.
The second concept that the workshop concluded should be pursued in tandem with the first is promoting basic best management practices (BMP) and pollution prevention (P2) in fish plants. There are many techniques that can and should be pursued right away. Up until this time we did not have guidelines for New Brunswick like those produced in British Columbia by the Fraser River Action Plan (FRAP), but borrowing ideas from what has already been done there and elsewhere makes this task somewhat more tractable. An important part of this is that the plant workers and supervisors need to be educated to the benefits in instituting and adhering to such procedures. Ultimately it may be worthwhile to make these guidelines part of the approval to operate, but they will be better and more effective if they are adopted voluntarily by the industry as a whole.
The third idea that emerged from the workshop is the concept of instituting a series of pilot projects. This is needed because of the complexity of effluent streams in the many kinds of fish plants and process lines employed in New Brunswick. Techniques like Dissolved Air Flotation (DAF) utilising food-grade flocculants to remove solids that can be used for secondary products need to be tested and proven in realistic circumstances before being implemented at full scale. Ultimately it may be useful to consider building on the existing capacity at the new Coastal Zones Research Institute at the University of Moncton (Shippagan) to create a permanent test laboratory like the ice centre at Memorial University in St. John's, Newfoundland.
This proposed Working Group was indeed formed and met for the first time in Miramichi, New Brunswick in April, 2003. Since the group has met, either in face to face meetings or via teleconference, on average every 4 to 6 weeks. They first of all established their Terms of Reference, and completed the List of Members to ensure a representative group but one that is at the same time small enough to make rapid progress. Through subsequent meetings they set about to follow-up on and flesh out the objectives set at the Workshop. The first tangible product of their efforts is the Best Management Practices that had been called for at the workshop (see below) and they continue to work toward a plan of pilot projects that will lead to innovative solutions in the industry approach to management of water, product and effluents. Details of their work plans and progress will be posted on this site as things develop.
This guide was developed to address marine products processing activities that are found in New Brunswick. This industrial activity constitutes a very important component of the provincial economy. In 2002, the 133 seafood processing plants having a processing permit issued by the provincial department of Agriculture, Fisheries and Aquaculture processed slightly more than 103,000 metric tons of marine products and the exports reached a value of nearly 900 million dollars. Most of these plants are located in rural areas, where they provide work to thousands of local residents. The size and mode of operation of these processing plants varies considerably. Some plants are seasonal while others operate all year long. Some plants process large volumes of marine products, others process more modest volumes. Some plants process more than one marine species whereas others orient their activities towards a sole species.
The processing of marine products requires large volumes of potable water, an increasingly limited resource whose cost could increase in the future. The use of large volumes of water, in addition to causing a significant loss of raw product, has as a direct consequence the generation of large volumes of effluents. These effluents can be particularly rich in residual organic matter (fats, protein). Furthermore, their characteristics can be quite variable from one plant to the other, because they are closely linked to the different types of production. The discharge of these effluents, in harbours and bays, remains a constant source of concern in terms of environmental impact and public health. Their high organic matter content frequently contributes to the pollution of coastal waters near marine products processing plants. This pollution is characterised by a significant multiplication of algae. The presence of algae in excessive quantities can lead to an extreme reduction of the oxygen level in the water, sufficient to create a "dead zone" where marine organisms cannot survive. This type of organic pollution generates increasingly strong reaction from the public, and also constitutes a factor limiting the use of coastal areas for other purposes, including economic development, recreation and tourism.
Consequently, some environmental standards according to which processing plants are authorised to operate, are on the verge of being tightened. Almost certainly, seafood processors will soon have to adopt best management practices (BMP) aimed at better controlling the quantity of water used as well as that of effluents generated in-plant, and/or to equip themselves with technologies to treat effluents that are adapted to both their needs and their budget.
It should be noted that the present guide is exclusively centred on the implementation of best management practices for the raw product, water and effluents of processing plants, and that it will not deal with technologies for the treatment of effluents. The implementation of such best management industrial practices effectively represents a logical approach for any processor interested in obtaining a tool that is both simple and relatively inexpensive, aimed at reducing the impact caused by the discharge of the effluents of his plant in the environment, and to conform to current regulations. The implementation of these BMP guidelines might even be sufficient to allow the processing plant to meet the existing environmental standards without the need for further investments in technologies to treat effluents, not to mention the operating costs linked to them. Moreover, the implementation of such practices often leads to an increase in the yield in the plant, which represents another quite appreciable financial incentive for any processor.
Undertaking such an exercise may however be intimidating, at first glance, for any marine products processing plant. This is why the proposed approach is based upon a step by step procedure that all processors have learned to master during recent years, that is the Hazard Analysis Critical Control Point (HACCP) system. At the same time, it is extremely important that the implementation of best management practices of the raw product, water and effluents in the plant is in complete conformance with the standards of the HACCP and of any other quality management program (QMP) already in place.
Reading this guide will help you to discover the benefits that your seafood processing plant can gain, in terms of both environmental and economic performance, by the adoption of BMP for the raw product, water and effluents.
At the same time that the Working Group in New Brunswick was being constituted and embarking on its own workplan, a parallel development was taking place at the Atlantic region scale.
The National Program of Action for the Protection of the Marine Environment from Land-Based Activities (NPA) is a federal/provincial/territorial agreement to work together to combat the negative effects of land-based activities in the coastal zone. These include both the effects of contaminants and physical disturbance of aquatic habitat. The NPA, which was introduced in 2000, sets priorities for each of a long list of contaminants and physical impacting activities. These national priorities are further refined at the regional scale through consultations and ongoing assessments led by a federal/provincial team. The NPA Atlantic Regional Team identified nutrient over-enrichment as one of the foremost problems in this region and recognised that seafood processing operations ought to be made a priority. This was as much because of their relatively unregulated nature as it was the overall contribution that they make to the problem. With the exception of some localised problems, that contribution is actually relatively small when compared to the principal sources of nutrient enrichment in coastal waters, that being atmospheric fallout and agricultural runoff.
In order to gain a greater understanding of this problem, especially in view of the long time that had passed since the industries effluent profile was characterised in the 1970s and 1980s, the first step to take was to commission a study to describe the current state of the situation. This report, entitled Management of Wastes from Atlantic Seafood Processing Operations (pdf 948 kb) was prepared by AMEC Earth and Environmental Limited in co-operation with the members of the NPA Regional Team and was published in both official languages in December 2003. Dissemination of the report in paper form has been through the membership of the NPA Regional Team and the numbers of copies thus distributed is relatively small. However, in April of 2004 the electronic versions of these reports were made available on the website of the Atlantic Coastal Zone Information Steering Committee (http://www.dal.ca/aczisc/) and it has been report that since that time well over 4000 "hits" have been generated by this publication, far more than any other document ever placed on the website for public dissemination.
This study revealed some astounding facts. For one thing, it was found that the number of seafood processing plants, far from declining after the collapse of groundfish stocks, had actually increased in number almost threefold since the late 1960s to well over 800 at the present time. Moreover, the quantity of production has not significantly diminished over these years because of diversification in species harvested and processed as well as an increased tendency to import raw fish for processing. As a consequence the value of seafood production continues to rise and industry is healthy and viable. However, for much the same reasons, this means that the industry has become a more significant contributor to coastal nutrification than it was in past decades, especially in areas where the industry is heavily concentrated or located in enclosed embayments where natural flushing is limited.
Another observation that came as a surprise to many was the difficulty encountered in accessing detailed information on waste production from seafood processing plants in Atlantic Canada. This is because there are generally very few legal requirements to accumulate such information and, in the absence of such requirements, the companies themselves have no incentive to monitor their own waste profile and make corrections as deemed advisable.
Since the completion and publication of the NPA study, Dalhousie University's Centre for Water Resource Studies has completed a study that goes far to filling some of the information gaps identified in the NPA study. In this soon to be published study, entitled Preliminary Assessment of Effluents Generated by Seafood Processors in the Atlantic Region, the regulatory regime addressing seafood processing across Canada and in other major seafood producing countries around the world is compared and contrasted. Also a more in-depth analysis to the waste profile of seafood processing plants in Atlantic Canada was carried out through site surveys and questionnaires. Finally, technologies that are already employed to reduce wastes from seafood processing operations elsewhere in the world or that hold promise in this application were reviewed with recommendations on their applicability to the situation in Atlantic Canada. It is hoped that this valuable contribution to the state of our knowledge will be made available here or in other locations in the near future.
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