8100

• UCREFRP Catalog Number: 8100
• Author: American Fisheries Society.
• Title: Proceedings of the 22nd Annual Meeting, Colorado - Wyoming Chapter, American Fisheries Society.
• USFW Year: 1987.
• USFW - Doc Type: March 11-12, 1987.
• Copyright Material: NO

agencies (Federal Register 1984a, b; as cited by Schnick et al. 1986).

These laws (formally known as The Federal Insecticide, Fungicide, and
Rodenticide Act and Amendments; and The Federal Food, Drug and Cosmetic Act and
Amendments) stipulated that the use of drugs and chemicals in fish culture and
fisheries management is illegal unless they have been reqistered or approved by
the EPA or the FDA for that purpose. A reqi stered compound is a product whi ch
has an EPA or FDA 1 abe 1 speci fyi ng its all owed uses. An approved product does
not necessarily have an EPA or FDA label because some other classification may
allow its use in aquatic situations. Examples of approved products are acetic
acid, carbon dioxide and salt (Schnick et al. 1986). Many approved products are
also classified as "GRAS" (generally recognized as safe) by the FDA.

In order for a compound to become registered it must undergo very extensive
and costly testing. Required data includes: (1) efficacy, (2) toxicity to the
test animal and the environment, (3) residues, metabolites and assay methods
used, (4) residue persistence in test animal and water effluents, (5) residue
tolerance level (level permitted in food eaten by humans), and (6) withdrawal
time (period required between termination of treatment and marketing or release
as stocked fish). The registration of only one compound requires several years
of work and about $500,000 (R.A. Schnick, personal communication). The fishery
use, or potential fi shery use, of apart i cul ar drug or chemi ca 1 is often mi nor
compared to its use in non-fishery activity. If the market value is relatively
low, pri vate industry sponsors may not spend thei r money and time to obtain a
registered status for that compound. Because of these problems, the u.s. Fish
and Wildlife Services' (USFWS) National Fishery Research Laboratory in La Crosse,
Wisconsin, is very active in registration activities (Meyer et al. 1976; Schnick
et ar. 1979).

Both the EPA and FDA have recently increased their activity to enforce the
laws that regulate the use of drugs and chemicals in fish culture. Inspecting
agents have vi sited hatcheri es to quest ion personnel about the use of certa in
products. If the use is not covered with an approved label, or some other form
of approval, the user is subject to disciplinary action (Schnick et al. 1986;
R.A. Schnick, personal communication; D.E. Anderson, personal communication).

Another problem involves attempts by fish culturists to save costs by
purchasing unregistered forms of a drug or chemical. For example, one commonly
used parasiticide can be purchased for one-half to one-third the cost of the
registered form of the compound, but the unregistered form may contain impurities
and could cause toxicity problems. More importantly, the sponsor/supplier of the
approved product might not recover costs of registering the product. This could
cause the sponsor to remove the product from the market, resulting in the
unavailability of an effective legal compound.

On malachite qreen

On checking any current list (Tables 1 & 2) of registered or approved drugs
or chemicals used to treat fish diseases, you will note a very obvious omission.
Malachite green, the most effective fungicide known in fish culture, is not
1 i sted! Thi s compound has long been used as the treatment of choi ce for fungus
infections on fish eggs. It has also been used in combination with formalin for

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