MSC Certification Fail! St Helena pole & line and rod & line tuna fisheries

The MSC accredited certifying body (CB) Food Certification International Ltd based in Inverness, Scotland, has given the St Helena Island pole & line and rod & line tuna fisheries for albacore, bigeye, yellowfin and skipjack tuna a failing grade for MSC certification as a sustainable fishery.  The assessment was carried out using the qualitative Risk Based Assessment approach developed by MSC for data-poor stocks.  The CB failed the fisheries on all four tuna stocks under Principle 1: Sustainability of Exploited Stock.

Should the St Helena fishery wish to still pursue certification, it is required by the CB to ensure that a number of improvement are carried out in order to achieve a passing score under Principle 1.  These include the development and implementation of target and limit reference points as well as harvest strategies incorporating harvest control rules that respond to the state of the stock relative to the reference points.

Other fisheries have in the past been certified by MSC as sustainable while having conditions applied requiring improvements in these areas.  This is only the second fishery that has entered full MSC certification to not reach a successful conclusion (the other was apparently a UK lobster fishery some time ago).  Does this "fail" indicate a new approach by MSC in response to mounting public criticism that "conditionally sustainable" does not make sense (a fishery should meet all sustainability conditions before it is certified sustainable)?  Or is it just the result of a consulting company that lacks the business savvy of successful certifying bodies such as Moody Marine Ltd?

MSC’s ball – the eco-certification game

The recent Pew Environmental Group criticisms and email campaign directed at the controversial certification of the Southeast North Atlantic swordfish, yellowfin and bigeye tuna fisheries based in Florida drew a strong defence from Jim Humphreys, MSC Fisheries, Regional Director Americas, in a posting on the MSC website. 

Humphrey’s posting was picked up by Natalia Real in a FIS.com editorial  20 August 2010 (“Pew's email campaign misleading: MSC”), prompting Lee Crockett, Director of Federal Fisheries Policy for the Pew Environment Group (PEG), to submit a response to FIS.com in the form of an opinion piece.

Humphreys defends the independence of the certification process arguing that “The MSC does not conduct the fishery assessment and the MSC remains impartial throughout the process, which is crucial to preserving the trust and reliability that come from an independent, third-party assessment, and maintaining the global credibility of the MSC certification program.”

According to Crockett, MSC elaborated on its “independence” in correspondence with him, stating that “the assessment of the fishery is independent of the MSC - the MSC doesn't take part in the scoring and determination of a fishery assessment.”  The implication seems to be that the MSC is absolved of any blame when an assessment ends up drawing public criticism.  Simply put, “Don’t blame me hey, I didn’t do it!” Non est mea culpa! The finger should rather be pointed at the consulting company (accredited to the MSC Standard) that undertook the assessment.

Crocket quite rightly takes issue with this claim: “In fact, MSC developed the entire assessment process and the criteria used for the assessment. Moreover, after a fishery is certified, it is eligible to display the MSC label, not the logo of the company that conducted the assessment, in this case MRAG Americas. To use a sports analogy, the fishery applying for and paying for certification plays the entire game on the MSC’s field, using the MSC’s ball, the MSC’s rules, in order to receive the MSC’s prize. The MSC is clearly not a disinterested third party.”

Not only that, any public objection to the sustainability determination is also played on the MSC’s field with the MSC’s ball, with an MSC salaried “referee”, the Independent Adjudicator!  Objectors to controversial sustainability determinations have yet to win a game.  

Ross Sea Toothfish Fishery Certified Sustainable

A controversial fishery in the pristine Ross Sea has been certified as sustainable by the Marine Stewardship Council (MSC) based on very little scientific evidence.  

The MSC's "Independent Adjudicator", Michael Lodge, has overturned public objections to the certification based on the assurances of a private consulting company, Moody Marine Ltd, contracted by by a group of fishing companies to prove that their portion of  the exploratory Ross Sea fishery is sustainable and worthy of the MSC eco-label.  Note that other nations involved in this fishery not covered by the certification have previously been identified as being involved in pirate fishing leading to the collapse of other toothfish stocks.  

Scientists claim that too little is known about the population dynamics of Ross Sea toothfish and the potential impact of catches to properly determine what would constitute a sustainable fishery.  Toothfish are highly vulnerable to overfishing as demonstrated by the collapse of a number of stocks.  

With this ruling MSC further lowers the bar (see other controversial certifications) on the evidence required to determine sustainability against it's standard.  It provides support to the perverse notion of "fish now and do the science later" - the antithesis of a sustainable approach.  

Consumers should exercise caution in accepting the MSC eco-label as evidence of a sustainably managed fishery and in particular avoid all toothfish or sea bass products.

BC Spiny Dogfish – Sustainable Fishery or Species at Risk?

Will BC Spiny Dogfish be the first shark fishery to be deemed sustainable by the Marine Stewardship Council? Or will it become another species on the growing COSEWIC Species At Risk list? 

MSC accredited certifying body, Moody Marine Ltd, is part way through a sustainability determination and COSEWIC is presently reviewing the extinction risks.

IUCN previously assessed the Spiny Dogfish as near threatened globally.  A proposal by Germany in 2004 to list Spiny Dogfish under CITES Appendix II tabled at a pre-CITES meeting was rejected by European member states.

The MSC assessment process started in 2008 under another private consulting company, TAVEL, which has subsequently been taken over by rival Moody.

Things moved very slowly on the MSC dogfish assessment and on 2 March 2010 Moody announced that it would be using the MSC “default assessment tree”.  In other words, the full-blow sustainability determination with multiple criteria under three Principles as given in “Marine Stewardship Council Fisheries Assessment Methodology and Guidance to Certification Bodies”.

However, once the Moody assessment team started to dig into the available data on this fishery, they found that it was very data-poor.  The last time the federal Department of Fisheries and Oceans (DFO) had attempted to assess the status of the stock was back in 1987, so Moody had very little that was current to work with.  Moody and other MSC accredited consulting companies typically “borrow” extensively from the latest government or RFMO scientific assessment in order to arrive at their sustainability determination.

DFO dutifully commissioned a new stock assessment for BC spiny dogfish held May 17, 2010 in Nanaimo, BC.  The ensuing DFO report, “Science Advisory Report 2010/057 – Assessment  of Spiny Dogfish (Squalus acanthius) in British Columbia in 2010” has yet to see the light of day with regard to the general public.  However, one must assume that Moody got a sneak preview and didn’t like what it saw, because on 8 October 2010 they announced that they had changed their mind and rather than apply the default assessment tree, they are opting for the alternate back-door route to certification by applying the MSC “Risk Based Framework” (RBF).

The RBF was developed by MSC as an alternative assessment approach for data-deficient situations; particularly for Principles 1 and 2 (in other words, the important stuff like stock status, management strategy and ecosystem impacts).  Initially the motivation for such an approach was the idea that the default assessment tree favoured large scale fisheries in developed nations and that smaller fisheries in under-developed countries would be at an economic disadvantage because of a lack of the appropriate information and infrastructure, even though these fisheries might have a track record of being sustainable over a number of years.

This notion of giving a break to under-developed countries seems to have fallen by the way, and RBF is now being applied to fisheries for which there is no excuse for not having a state-of-the-art assessment of the sustainability of a fishery.  Case to point – a British Columbia fishery – one of the wealthiest provinces in one of the wealthiest countries with super-abundant resources to collect the information required to determine whether a fishery is sustainable.

RBF methods are much more subjective than the standard approach under the default assessment tree.  Methods range in complexity and data requirements from a system based on expert judgment (Scale Intensity Consequence Analysis- SICA), to a semi-quantitative analysis to assess potential risk (Productivity Susceptibility Analysis - PSA).  PSA examines attributes of each species that contribute to or reflect its productivity or susceptibility.   Pacific Spiny Dogfish has both a very low productivity and a high susceptibility to fishing gear.  They are long-lived, only maturing at about 35 years of age.  Females typically give birth once every two years and produce around 6 pups after a gestation period of 22-24 months – the longest of any known vertebrate. 

There has been a commercial fishery for Spiny Dogfish in Pacific waters since 1870 with landings peaking landing of over 30,000 tons in the 1940s.  Landings have been much lower, between 5,000 and 7,000 tons, in the Canadian Pacific fishery in recent years presumably because of lower abundance.  The fishery is pursued by both hook-and-line and trawl gear.  Although trawl catches have been relatively stable recently, landings and discards in the hook-and-line fleet have been steadily increasing over the last eight years.  Catch rate and survey trends are either flat or decreasing.  The size of the population relative to virgin levels is not known.  The fishery is managed by quota, currently set at about 15,000 tons.  It is not clear whether this is an adequate measure to ensure a sustainable population in the long-term or whether a more conservative approach is required.

It will be very interesting to see what comes out of the parallel MSC and COSEWIC processes with regard to sustainability vs. extinction risks.  Either way, we need more up-to-date information and a conservation-minded harvesting strategy if the fishery is to be truly sustainably managed such that there is a very low risk of future declines, collapses or even extinction.