Overfished and overfishing are the new sustainable?

In a multi-authored article (22 authors) published online in the open access journal PLOS in August 2012, the claim is made that fisheries certified by the Marine Stewardship council are in better shape than those that are not as well as those that failed the MSC confidential pre-assessment  process. 

Two initial observations: (i) About half of the authors are directly or indirectly associated with MSC.  (ii) Data on those stocks that failed pre-assessment are not available for scrutiny because of a confidentiality agreement.

There are currently 132 MSC certified fisheries, yet the authors of the paper only examine the state of 74 of these (56%).  The required data were not available for the other 58 stocks. This constitutes a potentially biased sample of certified stocks.  It seems likely that those stocks without adequate data could be in worse shape, or at best their status is more uncertain.

      

Of 74 stocks examined only 32 (43%) had a stock assessment adequate for determining whether overfishing was taking place (fishing mortality or exploitation rate higher than that which would result in maximum sustainable yield or MSY) or whether the stock was overfished (below 50% of the biomass that generates MSY).  It is of considerable concern that fisheries are certified as sustainable on stocks for which such basic information regarding sustainability is lacking.

In addition to the 32 stocks, the authors were able to fit a Schaefer surplus production model to the data, or to combine a Schaefer surplus production model with the existing stock assessment model to estimate MSY related information for 13 additional stocks.  The methods used to fit the model have previously been published.   However, for a number of reasons it is unlikely that their approach would garner support through a peer review process on individual stock assessments; otherwise it would surely already be in use in these assessments.

 

Of the 32+13=45 stocks for which overfishing and overfished status could be determined, 8 MSC certified stocks are currently subject to overfishing while 4 certified stocks are overfished.  One could thus conclude that the MSC certification definition of sustainable fisheries  includes overfishing and overfished stocks.
 

Of the 4 overfished MSC certified stocks, only one has had its certification suspended.  The authors point out that the other three are above their respective biomass limit reference point, and therefore above the level where serious and possibly irreversible harm to the stock productivity is considered to occur.  It is arguable whether merely having the stock above the biomass level where serious and potentially irreversible harm occurs is sufficient grounds to consider a fishery sustainable.

Of the MSC certified stocks where overfishing is taking place, 4 are above the biomass that gives MSY which the authors consider to be less of a concern than overfishing on the other 4  certified stocks which have a biomass below the MSY level.   One of these stocks of concern is the South African Deep Water Hake, “poster-child” for a recent MSC-produce dvideo.  North Sea Saithe continues to be certified by MSC even though it is overfished and overfishing is continuing.

Although the authors find that MSC certified fisheries are healthier than those that are not certified or that failed confidential MSC pre-assessment for certification, they also note that this divergence was largely established before MSC certification commenced in 1999.  It is therefore not a consequence of certification.

The main criticism of MSC certification by environmental groups and informed members of the general public is that it sets the sustainability bar too low in some cases.  Stocks on which fisheries are certified as sustainable should be near or above the MSY biomass and should be exploited below the MSY exploitation rate.  They should not include fisheries in which the stock is currently overfished, or where overfishing is taking place, even if it is anticipated that overfishing will cease at some point so that the stock will recover to the MSY level in the future.

Consumer confidence in the MSC brand will be diminished if fisheries are certified in cases where the stock is overfished or overfishing is occurring , or where there are insufficient data to reliably make such a determination.

What is a sustainable fishery?

It seems that nobody has the answer.  At least not an answer that is widely supported by environmentalists, fisheries managers, fisheries scientists, third party certifiers and the fishing industry.

A clear, succinct and widely adopted definition of a sustainable fishery would provide a benchmark against which individual fisheries could be compared.  It would cut down on the wiggle room jargon of “conditionally sustainable”, “on the road to being sustainable” and “more sustainable than it was”.  Simply put, a fishery would be deemed currently either “sustainable” or “not sustainable” based on a few carefully chosen and measurable conditions.

Currently MSC requires 23 criteria to be addressed under three principles in order to determine whether or not a fishery is sustainable.  Each of these criteria has one or more sub-criteria, each with an associated performance indicator that has to be scored and added together to determine a pass or fail.   It is a complex system which allows depleted fisheries, data poor fisheries and fisheries with collateral environmental damage to be certified conditionally sustainable provided a plan is proposed to ameliorate these flaws.  This leaves the public confused and environmental groups shaking their heads.  

Unfortunately scientific experts do not agree on a definition of a sustainable fishery. 

In the “Comments” section of the Washing Post related to the article “Some question whether sustainable seafood delivers on its promise” (by Juliet Eilperin, Published: April 22 2012),  Ray Hilborn of the University of Washington draws the distinction between sustainability as a state of a stock, and sustainability as a process. He believes that “sustainability is clearly the result of a process, stocks can be overfished, by anyone's definition, and still be sustainable if the management system responds to changes in abundance and reduces fishing pressure allowing stocks to rebuild”.

The notion, that a fishery on a stock in a depleted state can be considered “sustainable” provided there is a management process in place to reduce fishing pressure and allow the stock to rebuild in the future, is highly controversial.

In contrast, many would argue that a sustainable fishery is one in which overfishing is not taking place and the stock is not overfished at the present time.  In other words the “process” should have already led to the stock being rebuilt before the fishery on that stock can be termed “sustainable”.

Translated into fisheries science jargon, a sustainable fishery is one in which fishing mortality is on average below Fmsy (no overfishing) and spawning biomass is on average above Bmsy (not overfished) at the present time. 

Here Fmsy is the fishing mortality that gives maximum sustainable yield on average and Bmsy is the average spawning stock biomass that results from fishing at Fmsy.  

Secondary but important considerations include a societally acceptable low level of collateral  damage through ecosystem alteration, bycatch impacts and habitat destruction.  

Is sustainable seafood really sustainable?

A recently published paper in the journal Marine Policy by German scientists Rainer Froese and Alexander Proelss has attracted the attention of the Washington Post and other media. 

The paper takes issue with sustainability certifications of marine fisheries by the Marine Stewardship Council and the Friends of the Sea.

 

They examined the most recent estimates of current biomass, (B) biomass at maximum sustainable yield (Bmsy), current fishing mortality (F) and fishing mortality at MSY (Fmsy) from national or international fisheries bodies and published papers for 71 MSC certified stocks for which they could find such information.

 

For 11% of these stocks the information was insufficient to make a judgement about stock status or exploitation levels.  31% of the stocks with sufficient information were overfished and were currently subject to overfishing.

 

They define “overfished” as those stocks where B is less than Bmsy and "overfishing" as taking place when F exceeds Fmsy.  They allow some latitude in that if the ratio B/Bmsy is  greater than 0.9 or F/Fmsy is less than1.1 it is not included in the percentage total of overfished and overfishing.

National fisheries agencies and international fisheries organizations tend to be somewhat coy regarding their specific definition of sustainability with respect to marine fisheries.
  

The US, under the Magnuson–Stevens Act, is an exception in this regard although the criteria may vary somewhat on a stock by stock basis.  Commonly the US definition of “overfishing” is the same as that adopted by Froese and Proelss (F>Fmsy) but the US tends to be more tolerant with regard to the definition of overfished, commonly requiring the stock to  be above 50% of Bmsy or 50% of maximum spawner potential (spawner per recruit).

Under Principle 1 of their standard, MSC ideally requires that fisheries are managed so that they fluctuate around Bmsy or higher although stocks can still be certified under this criterion if they are above 50%Bmsy.  Of course there are many MSC loopholes around this that allow fisheries to be certified even where there are no reliable estimates of where the stock is relative to these levels.  Fmsy does not factor directly into the MSC certification standard, so that it is feasible that fisheries in which overfishing is taking place, such that the stock will be depleted over time, can still be certified as sustainable.

While Froese and Proelss may raise the bar a little too high, stocks that are consistently below Bmsy or are being fished consistently above Fmsy should not be given sustainable fishery labels.  Also, data poor fisheries cannot be assumed to be sustainably managed based on vague and subjective notions.  The fact that overfished stocks subject to overfishing, as well as data-poor stocks, are being certified as “sustainable” brings into question current standards.

National fishery agencies and international organizations would serve us well by developing clear globally accepted and simply applied standards for what constitutes a sustainable fishery. Fisheries that are shown to meet such standards through scientific peer review of assessment of stock status would not be in need of further sustainability accreditation.

Da Fishy Code – Interpreting the MSC eco-label

So what does the MSC eco-label tell you?  Not a lot it turns out.  You have to do a lot of digging.  My example is a package of MSC certified “Wild Albacore Tuna Portions” purchased from a national grocery chain in Canada (Sobeys/Loblaws).  

The front of the package has the blue MSC logo and provides information that the content is “Certified sustainable and responsibly caught seafood”.  The back of the package also displays the MSC logo and has a little more information:  “This product comes from a fishery that has been independently certified to the Marine Stewardship Council’s standard for a well-managed and sustainable fishery.  www.msc.org”    Under the MSC logo there is also a number, SF-C-1245.

A Google for MSC SF-C-1245 gives a several relevant hits, none of which are for the MSC website.  The highest ranking hits are all for fishchoice.com which tells us that this is the MSC Certificate Code.  Including these key words together with the code still gives no MSC related hits.  If MSC has a website linking information on certified fisheries to certificate codes, I could not find it using Google.  The MSC website does however assure us that the blue logo means that buyers can have confidence that the fish we are buying can be traced back to a fishery that meets the MSC environmental standard for sustainable fishing.  It’s all about trusting the brand!

FishChoice.com is a free resource connecting businesses that buy and/or sell sustainable seafood.  Using the MSC certificate as the link to the product, FishChoice tells us that the package contains steaks of Thunnus alalunga, wild caught off British Columbia Canada.  It also notes that its partner organizations Seafood Watch, SeaChoice, Blue Ocean Institute, FishWise and Ocean Wise, as well as MSC, all give it the “green thumbs up” as a best choice in terms of sustainable seafood.  Fishchoice states that it adds to its directory only seafood products that meet the minimum sustainability threshold of its partner organizations.  It anticipates that seafood buyers will search FishChoice for environmentally preferable seafood products and then contact suppliers to make their purchases.

Next steps would be to research the BC albacore fishery certification on the MSC website.  MSC tells us that the unit of certification is the “Canadian Highly Migratory Species Foundation (CHMSF) British Columbia albacore tuna North Pacific”, that it is caught by troll and jig by about 198 vessels and was certified by MSC in March 2010.  Perusing the consultant’s assessment of the fishery on the MSC website, one can note that there is little or no bycatch and any ETP (endangered, threatened, protected) species can easily be returned to the sea unharmed because of the use of barbless hooks.  That’s good.
 

One can also note that a number of conditions have been placed on the fishery regarding things that need to be fixed within the current certification period to ensure ongoing certification.  Prominent among these is the need to determine the appropriateness of the current management targets and to develop limits to fishing.  This may be difficult to achieve given the highly migratory nature of the species and the complexities of the organizations involved.  The Canada/US Management Authorities are Fisheries and Ocean Canada (DFO) and the Pacific Fishery Management Council (PFMC).  International management of the North Pacific albacore resource is shared by two international fisheries commissions: the Inter American Tropical Tuna Commission (IATTC) and the Western and Central Pacific Fisheries Commission (WCPFC).  The International Scientific Committee for Tuna and Tuna-like Species in the North Pacific Ocean also plays some role in this process.

One might be a little concerned that the BC Albacore fishery is provisionally certified sustainable by MSC without well-established fisheries management targets and limits, but that might be unfair given the greater shortcomings in a number of other MSC certified fisheries.

What else is on the Albacore packaging?  The top right has a round label that challenges us to “Trace this Fish…From Ocean to Table” and tells us to “see back for code”.  There is also a QR barcode that you can scan into your smartphone.  They both lead ultimately to the same place.  The back of the package tells you to visit thisfish.info where you can type in the “Trace this Fish” code C001025.  When you do this you learn a whole lot more about the fishery.  You learn that “Your Albacore Tuna was caught by Korey Sundstrum off Barkley Sound and landed frozen-at-sea in Ucluelet, BC on Jul 25, 2011.  Who processed it?  Pasco Seafood Enterprises Inc. in BC.”  Neat eh?

Thisfish.info is a project of Ecotrust Canada.  Ecotrust Canada is an enterprising nonprofit whose purpose is to build the conservation economy. They work at the intersection of conservation and community economic development promoting innovation and providing services for communities, First Nations and enterprises to green and grow their local economies.    They have partnered with fish harvesters and seafood businesses to provide “Ocean to Table” information.  Information is uploaded by fishermen and thus far thisfish.info has more than 250,000 records in its database.

DFO is supposedly also launching a program to trace seafood “from ocean to plate,” giving consumers what DFO claims will be accurate and timely information on the seafood they eat.  Thus far there is nothing to show in the public domain so I wouldn’t hold your breath.

Time to grill that albacore steak!

Former MSC head spills the fish guts on the Alaskan salmon pullout

A former head of the MSC has commented publicly on the pullout from the certification scheme by the Alaskan salmon industry.  He questions whether it is a kamikaze move or a considered action.   He notes that nobody expected a stalwart of the MSC certification scheme to abandon ship at the height of the eco-certification bubble.  

But maybe that bubble is about to burst?   Has the asymptote been reached?  Have the cumulative cases of questionable MSC certifications finally reached the point where the brand is beginning to lose value? 

Brendan May gives us a rare peak into the dilemma that MSC faces on a daily basis trying to play environmental groups off against commercial enterprises.  He recounts the hours spent by MSC figuring out how to kick a fishery out of the programme so Greenpeace and others might stop thinking they were a front for the industry or a satanic incarnation.  But very few fisheries have been kicked out.

The MSC certification of the Canadian longline swordfish fishery a few days ago further weakens the MSC brand.  Despite the objection of environmental groups, MSC has certified a fishery in which, it is claimed, two sharks die are cuaght for every swordfish caught (some percentage of which survive on release) and which causes 200- 500 endangered sea turtles to breathe their last every year.

As environmental groups have been quick to point out, not many people would be happy to sit down to a meal of MSC certified longline swordfish knowing that it comes with a side dish of endangered turtle and shark.

Alaskan salmon processors dump MSC

This is already old news, but it may be instructive to look at the reasons given by the Alaska salmon industry for dumping  MSC after more than a decade, and the response from MSC, now that the fish guts have settled somewhat, so to speak.

Among the reasons given by the Alaskan salmon industry, the Alaskan Fisheries Development Foundation and the Alaskan government, as reported by http://thefishsite.com and other media, is that MSC certification does not, in itself, make Alaskan salmon sustainable.  They consider the salmon fishery to already be sustainable because it meets State and Federal constitutional mandates for sustained yield, a commitment to scientific research and the need serve public good.   

According to http://www.upi.com/ the industry were also frustrated with the increasing complexity of MSC certification.  No doubt cost is also a factor – not only for the certification itself, but also for annual audits and the right to display the eco-label.  Although a non-profit, MSC has been able to fund considerable global expansion over the last decade through fixed annual fees and variable royalties based on how much MSC-labelled seafood is sold, as well as through donations.

MSC has not welcomed being dumped and has been quick to express its chagrin.  It considers that whatever alternative certification and eco-labelling scheme the industry comes up with, it will be inferior with regard to independence, transparency, traceablity and quality, attributes MSC has put forward to establish global brand identity.

Is the Alaskan salmon industry in the vanguard of a swing away from MSC certification? There is no doubt that MSC certification is highly complex and expensive.  Is MSC certification necessary for a fishery to be considered sustainable?

It all depends.  Nations like the United States and New Zealand have clear standards embodied in policy and legislation regarding when overfishing is taking place or when a stock is overfished.  If a fishery does not meet both of these standards then it is, by definition, not a sustainable fishery.  This is typically determined by federal or state scientific stock assessments through an independent peer review process in a transparent manner.  Provided the providence of products from sustainable fisheries is made clear in the labelling by indicating the fishery geographic stock location, scientific species name and capture gear type, the consumer has sufficient information to make an informed decision.

Typically MSC accredited consulting companies do no new analysis in reaching their sustainability determination.  Rather, they piggy-back on the federal or state scientific assessment, adding additional qualitative insights regarding ecological impact of the fishery and governance considerations.  In an MSC assessment a fishery on an overfished stock or a fishery that is overfishing the stock can be granted “conditional” sustainability certification and can carry the MSC eco-label provided it has plans to become sustainable with regard to the MSC standard within a prescribed period.  Thus a fishery can be deemed provisionally sustainable under MSC while considered unsustainable under USA or NZ federal standards.

Does the MSC label provide sufficient information for the consumer to make a wise choice?  Typically it does not.   There are 5 choices of text that MSC provides to accompany their blue eco-label.  None of these contain any information on the geographic stock location of the fishery, the scientific name of the species, or the fishing gear used.  There is also nothing to distinguish fisheries that have conditional sustainability certification from those that meet all the MSC criteria.  Consumers must take the MSC eco-label on faith or visit the MSC website and do their own research to determine these important details.

Marine fish stocks are a public resource and it is the responsibility of governments to manage this resource for long term public good.  Nations like the USA and NZ are well advanced in this regard and don’t have need of third party eco-certification to augment their own legislation, policy and procedures.  They only need to work on improving the communication of this information to the public.  Detailed product labelling, including whether or not the product meets both sustainability criteria (not overfished and overfishing not taking place), would allow consumers to make wise choices on sustainable seafood.