Jeopardy for $200:

“The Mermaids’ Cotillion.

What is, “Where one goes to learn aquaculture?”

One can also learn about aquaculture regulation at the Department of Agriculture. How many of you knew the state vet’s office was responsible for aquaculture regulation? We have a handful of rules that are based on about a dozen statutes which start by defining aquaculture thusly…

“Aquaculture” or “aquaculture facility” means the controlled propagation, growth and harvest of aquatic animals or plants, including fish, amphibians, shellfish, mollusks, crustaceans, algae and vascular plants.

Yep, even the algae-based bio-diesel folks are under our jurisdiction. It’s a good thing brand laws don’t apply to tilapia!

For the most part though, things “fishy” fall to our counterparts at Arizona Game and Fish Department. One of their folks, Rob Bettaso, kindly wrote up a bit about some of their work in the fish world. Here it is; and my thanks to Rob and the folks at AZGFD.

When it comes to livestock, “Home, Home on the Range” perhaps best qualifies as the soundtrack for the American West. However, another type of stock has become increasingly common, and important, to the overall protein production of the United States – namely, various fish species, be they trout, catfish, or tilapia.

In recent decades, aquatic animals (shellfish, finfish, bullfrogs, and alligators) have become an increasingly lucrative crop for those who grow food under the science known as “aquaculture” (as distinguished from agriculture). While this trend has been common in many parts of Asia for centuries, it has only relatively recently become common in other parts of the world.

There are two primary reasons for this shift: 1) the health benefits of a diet rich in seafood are now well documented, and 2) as the human population grows, it only makes sense that we would seek to grow food in as many places as possible, and especially in the 3 dimensional world of water.

Fish farming is the term used for growing fish under captive conditions including fish hatchery “raceways” as well as in tanks, earthen ponds, or in pens and cages used in lakes, estuaries, and bays. “Fish ranching” is a term sometimes used for raising the eggs and/or broodstock of certain fishes, and then the fry and fingerlings of which are allowed to migrate to open waters (large lakes as well as seas and oceans) where they can live and grow for years prior to being rounded up (or migrating back to the place of their birth) for harvest.

Regardless of the techniques used, all properly managed aquacultural operations need to address issues of fish health. As with terrestrial husbandry, aquatic animals need two major types of health work – diagnostic actions and health inspections for certification purposes. In the State of Arizona (as with virtually all States) multiple entities may be involved in these efforts including the Arizona Department of Agriculture (ADA), Arizona Game and Fish Department, Department of Environmental Quality, the Animal and Plant Health Inspection Service, the Fish and Wildlife Service, and various local agencies.

Because Arizona is primarily a desert/arid State, we have significantly less aquaculture than many other States. All commercial aquaculture must obtain permits from the ADA for various aspects of aquaculture including the import/export of aquacultured products, aquatic animal transport, and the actual growing of aquatic organisms. All commercial operations are also required to have annual certifications confirming that they have undergone a fish health inspection within a 12 month period and that they have tested negative for State and federally recognized reportable pathogens (that are the cause of infectious diseases between certain aquatic species; none of which are communicable from any aquatic species to humans).

As with agriculture, sound health management is not only vital to the well-being of our aquatic natural resources, but it is vital to the national economy and to any given grower’s financial bottom line. So, the next time you hear or read of an epizootic, don’t forget that it may not be hoof and mouth disease, but may be case of fin rot, furunculosis, or fish lice….

A Simple Question

Hey Perry!
Got a quick question for you. What type of laws are in place for livestock housing conditions? Obviously food and water must be provided, but anything else? shelter? shade?

— H.C., CVT, VDT

A colleague that I worked with in years past, Dan Dhuyvetter, often quoted one of his profs thusly, “For every simple question there’s a simple answer. And it’s wrong.” I really do like that one; and H.C.’s email brings it to mind.

“Keep it simple” is also a favorite. But like most tools, it has it’s limitations. (Or was that, “A man’s got to know his limitations”?)

For example, the KISS principle will never get a student through an exam on the Krebs Cycle in cellular biology. And without that – ultimately there will be no vet school in that student’s future. (Also there will be no understanding of what generates energy for the organism – and whether what you might be thinking of treating that animal with could be beneficial or detrimental. Nature can get complicated.)

You would think I could give a simple answer to HC’s question. And I can – to a point. As far as the state in respect to ARS Title 3 (Agriculture) is concerned there is no law in place relating to housing conditions.

But that would be wrong. Because…

As far as the state in respect to ARS 13 (Criminal Code) is concerned, it’s “necessary food, water and shelter” to avoid charges of cruel neglect. In that same article is language about space requirements specifically for “any pig during pregnancy or any calf raised for veal”. So that’s another perspective (or layer).

You might also want to take a look into ARS 11 (Counties) as well as ARS 28 (Transportation) because I’m aware of language in those 2 Titles that address some issues with animals; plus there’s a lot more language in those that I don’t know.

Now that we have the state covered (which is from a certain perspective kind of the middle of the mess I’m dragging y’all through) let’s turn our attention to the broader scope – the federal level of regulation.

Most likely if HC falls under federal regulatory purview it would be USDA APHIS Animal Care.

However, given that I know more than a passing amount about the questioner’s operation, I should also point out that the CDC&P, NIH, DOE and possibly even FDA-CVM could have a hand in the pot.

Oh and don’t forget the DOJ – DEA because of what might also be housed in the facility with these critters – which reminds me that the state pharmacy board might also need to be consulted.

Yes I did condense that part because my fingers are getting sore and I’ve still got to cover the “close-up regulatory levels” – those would be the county, municipal and community levels.

Depending on whether you’re inside a municipal boundary you may have county or city animal control and/or public health & sanitation departments to deal with. (Crap! Literally! I forgot to add the EPA to the list of folks that may be involved from the federal level.)

Then there’s what I refer to as the community level (think HOA-type situations) that may bear. Those are generally contractual, not regulatory per se, but you may be party to the contract.

Did you get all that? Are you sure you wanted to get into this?

I remember reading many years ago now, an excerpt from a speech given by a retiring federal judge (the episode actually having occurred a few decades before the time I came across the excerpt.) He bemoaned how law and regulation had grown overwhelming in its scope during his tenure and how far astray that had taken society from the premise of individual liberty.

If anyone recalls something similar and can quote chapter and verse, I’d appreciate it if you’d send that to me. Potter Stewart is the name that comes to mind, but I’m not certain on that.

And for those who would like a reality check, if you’re in Washington, D.C. visit the Library of Congress and observe just 2 documents – the U.S. Code and the Code of Federal Regulations. Given the size of those 2 documents alone, I’m fairly certain that we have gone far into a world where “ignorance of the law” should be a very apt defense.

Now. Did that answer your question?

Goals, Targets & Action Levels (GTAL)

Some of you might be inclined to see the title of this post and say to yourself, “Goals, targets and action levels – GuTahl”?

No, that’s not Klingon for knocking heads to inspire people to perform better. But it does make you think, doesn’t it?


I can still hear Dr. Harvey Hilley plowing through his lecture defining the differences between goals, targets, and action levels and the significance of those differences. And that was in the late 1980s! Somethings do get hammered into even a head as hard as mine.

He was talking swine production. But the system he was describing is applicable in many situations that require adherence to performance. I suspect most of us agree that we do get a little wiser with age and can often see (better) what some folks were trying to tell us many years earlier. And in how many different ways that knowledge can be applied. Case in point with Dr. Hilley.


Anyone who was in school prior to the 1970s knows that numerically speaking, 100 on a test was the goal you were shooting for. That was effectively, in that day, perfection. But we also knew that wasn’t the target.


Up until the ’70s (I know I saw things change after that anyway; maybe you did before then) 100 was the goal on a test in school. But the target was to obtain an “A”. And at least in those days that meant you had some room – all the way down to 93.

Some folks had more leeway in the target area. In their cases and in that day a “C” was a passing grade and still within the target range (which cut off below 77); that was some students’ target. It was also every parent’s Action Level.

Action Levels

Or put another way, “where the fertilizer impacts the ventilation system.”

In most Manage By Exception management systems, Action Level equates to the negative consequences of poor performance. It could just as easily and it should also equate to positive consequences (i.e. rewards). Either way though – and this is the critical point – there was consequential action brought to bear, swiftly and decidedly.

Implementing GTAL (as opposed to simply talking about it) in cultures where there has been none for any length of time equates to a serious PITA for those charged with delivering performance results in an organization (and the implementer might be tempted to look upon that type of situation from a Klingon-like perspective.)

But for GTAL to be effective in changing a culture and its members’ performance, those in charge must move down the road of implementation with patience and persistence and make sure it is applied equally. Doesn’t that sound an awful lot like the concept of equal application of the law?