Standards for Triploid Grass Carp Producers
Revised vice Memorandum of Agreement 2010, Amended August 2010
- The USFWS only provides the Inspection and Certification service to producers that want to cooperate and sign a Memorandum of Agreement.
- The Grass Carp Producer, prior to the inspection date, will examine the checklist “Verification Checklist for Triploid Grass Carp Inspections (97 KB)” to ensure that the inspection procedures are followed according to the standards. (i.e., available diploid controls, a working Coulter Counter, etc.). Penalties: 3C, 4C, 2B
- Producers must have a fully operational particle sizer (such as the Coulter Counter) with channelizer, and trained personnel available to process fish for the Inspection. A fully operational particle sizer shall be defined as one where the modal peak for triploid screened fish is at least one channel to the right of a 2.8 micron bead modal peak. Penalties: 2B
- All grass carp, in an identified lot, will be individually tested by the producer using the particle sizer technique prior to the inspection. The USFWS Inspection consists of a retesting by the producer, in the presence of the Inspector, 120 fish randomly selected by the Inspector from the identified lot of alleged 100 percent producer tested triploid grass carp.
- Upon the arrival of the inspector, the producer will provide the inspector with the “Verification Checklist for Triploid Grass Carp Inspections (97 KB)” with the table of tank locations and number of alleged 100 percent triploid fish groups present along with the completed pre-inspection requirements. The producer will randomly select 120 fish under the supervision of the inspector. The producer may not pre select 120 fish prior to the arrival of the inspector. Penalty: 7D
- The Grass Carp Producer will maintain the isolated lot(s) of alleged 100 percent individually producer tested triploid grass carp in containment units at least 100-ft. away from production ponds and at least 6-ft. away from tanks holding untested/diploid grass carp to reduce the chance of inadvertent mixing of triploids and diploids. Penalties: 3C, 4C
- All tanks in the containment facility will be clearly labeled as either untested, diploid, producer tested triploid or USFWS certified triploids. Penalties: 4C
- Containment units must be provisioned with water that is clear enough to allow the isolated fish population to be viewed by the USFWS Inspector for the purposes of visually estimating fish numbers and confirming the absence of other species whose presence would indicate potential adulteration of screened fish. In the event the water in the holding tanks is not clear enough due to a unique weather event or temporary equipment malfunction, the inspector will offer to work with the producer to find an acceptable alternative method of determining the number of fish in the containment unit. Penalty: 8D
- The Grass Carp Producer will provide the diploid grass carp control fish. The fish will be the same relative age/size as the group of fish that are to be certified for triploidy. As an option, 2.8 micron polystyrene beads may be used to verify the testing equipment when diploids are unavailable at the time of the inspection.
- The grass carp producer will analyze diploid controls or beads on their particle sizer under the supervision of the inspector to ensure that their particle sizer is fully functional prior to conducting an inspection.
- The grass carp producer will then individually retest all 120 randomly selected fish from the alleged 100 percent individually producer tested triploid grass carp lot under the supervision of the inspector. Each sample will be channelized under the direction of the inspector. The channelizer reading from at least every tenth sample will be manually recorded by the inspector on the “Checklist.” Each individual fish will be secured in an identifiable location for possible retesting if suspected of being diploid. The fish can be released to the general triploid population after the inspector confirms the ploidy status of all 120 fish. Penalty: 6D
- If a blood sample results in a questionable reading when it is channelized the producer will follow the facility protocol for screening a suspect sample under the direction of the inspector. At the very least the protocol will contain the following elements:
- Pour original sample into new, clean cuvette and retested up to two times. If okay continue with inspection.
- When suspect sample is present producer stops the testing without communicating the location of fish to the blood collection personnel.
- Inspector notes location of suspect fish and retrieves all suspect fish in a containment unit (e.g. two fish in a net) and returns to the sample stand.
- Collect a new blood sample in a new, clean, cuvette(s) from all fish in the group up to two times.
- Run samples and make determination of ploidy of new blood samples.
- Penalty: 6D
- If the inspector observes any non-triploid fish during testing the inspection will fail. This is a type (A failure-a diploid is found during testing of the 120 fish sample). The inspection process is stopped and the lot cannot be certified. All fish in this lot must be individually retested, by the producer, before another date and time can be scheduled for inspection. A letter of warning/concern will be issued by the inspector or supervisor via US Postal Service within 3 business days. The producer will address the letter and identify the course of action that will be taken to correct the problem via return letter to the USFWS. Penalty: 1A
- In the event of a type B, C or D failure, the standard for which the producer was out of compliance must be corrected prior to scheduling another inspection. The inspector must indicate in writing using the standardized letter addressing the standard(s) resulting in the failure so that the producer can correct the problem. The producer will identify the course of action that will be taken to correct the problem via return letter to the USFWS.
- A lot is defined as the number of fish recently individually screened by the producer to remove non triploid fish and held in isolation that may potentially be shipped within six calendar days. The inspector will determine the number of fish permitted to be certified and sold in this lot from the producer’s shipment orders at the time of inspection. The inspector records the total number of fish on the “Verification Checklist for Triploid Grass Carp Inspections (97 KB).” An arbitrary maximum number of 6,000 fish per lot is being assigned until empirical data on actual diploid incidence rates in failed lots can be reviewed and a more accurate statistical model applied to establish higher or lower lot sizes based on the 120 fish sampling protocol. Multiple inspections can be performed in a day to accommodate larger orders greater than 6,000 fish. Larger groups of fish will be segregated into multiple lots with a maximum of 6,000 fish per lot. The lots will be inspected and certified independently.
- The certified lot of fish derived from the inspection is held in isolation. Certificates may be issued by the inspector for up to 6 calendar days on fish sold from the certified lot. If any fish are added to the certified lot after the certification inspection the remaining fish from the inspected lot are null and void. All fish in the respective lot must pass re-inspection before they can be certified and sold. If the inspector receives a request for additional certificates he/she should maintain a copy of the “Verification Checklist for Triploid Grass Carp Inspections (97 KB)” to ensure certificates are not issued for more than the number of fish in the lot. Certificates issued will be documented on the “Verification Checklist for Triploid Grass Carp Inspections” and will be cross referenced with the Producer’s “Verification Checklist for Triploid Grass Carp Inspections“ at the next inspection.
- Any fish from the certified lot not sold within six calendar days of inspection must be re-certified before new certificates can be issued for sale and shipment. Unsold fish from the previous certified lot(s) may be submitted for re-certification with alleged 100% individually producer tested triploid fish to form a new lot for USFWS inspection.
- Additional certificates associated with a certified lot can be provided for subsequent sales at the discretion of the local inspector after the inspector leaves the producer’s site on the day of the inspection. Upon agreement of this request the inspector will inform the producer of their options for delivery of the certificates at a mutually acceptable time. The producer is responsible for organizing delivery of certificates written after the inspector leaves the producer’s site on the day of the inspection. This can be accomplished depending on the urgency of the request (1) sent by regular mail, (2) sent via courier service using the producer’s account number, or (3) picked up by the producer at a location convenient for the inspector. Certificate(s) will be sent on the day requested provided the request is made during business hours and before the deadline for pickup of the courier. Certificates can be issued by another USFWS Inspector at the request of original Inspector.
- If visual examination by the Inspector identifies some phenotypic anomaly, further scrutiny and investigation would not be the responsibility of the Inspector under the Grass Carp Program. If such work is desired by the Grass Carp Producer, it should be directed to a fish veterinarian, a certified fish health specialist, or a fish pathologist.
- Grass Carp Producers will retain records of their Certification transactions for 7 Years and provide original, embossed, Certificates to truck drivers, and others, delivering the fish to the place of destination. Penalty: 10E
- The USFWS provides triploidy certification; it is the obligation of the producer to comply with laws, regulations, and guidelines of the States.
- Fees for service will be handled by check, issued to the Inspector at the time of the Inspection or by other agreed terms, and made payable to the U.S. Fish and Wildlife Service for the number of fish Certified to be shipped. Penalty: 15E
- The Grass Carp Producer will not directly participate in the selling of grass carp as USFWS certified triploid grass carp in intrastate and interstate shipments without valid USFWS certificates. Penalty: 10E, 13E
- The Grass Carp Producer must not be convicted of a felony Lacey Act violation related to the triploid grass carp business. Penalty: 14E
- The Grass Carp Producer will not falsify any certificates or documents. Penalty: 10E
- The number of fish on the certificate must match number of fish on the invoice/bill of lading. Penalty: 9E