Marine Stewardship Council - Acceptable time frames for rebuilding depleted fish stocks

In the fall of 2010 MSC consulted with partners and stakeholders on acceptable rebuilding timeframes for certification of depleted stocks.  MSC defines a depleted stock as one which has a biomass below BMSY (the biomass that gives maximum sustainable yield) or equivalent target level, but is still above a precautionary limit level. Fisheries on stocks which are depleted can become MSC certified, however certification of such fisheries requires that there be a rebuilding plan in place which leads to the recovery of the stock within a specified timeframe.

The MSC Fisheries Assessment Methodology addresses rebuilding under Performance Indicator PI 1.1.3.  Currently, a conditional pass score of SG60 merely requires “reasonable expectation of success” with regard to rebuilding to the target biomass of BMSY within a specified timeframe.  

An unconditional pass of SG80 requires evidence that rebuilding strategies “are rebuilding stocks, or it is highly likely based on simulation modelling or previous performance that they will be able to rebuild the stock within a specified timeframe”.

A perfect score of SG100 requires that “strategies are demonstrated to be rebuilding stocks continuously and there is strong evidence that rebuilding will be complete within the shortest practicable timeframe”.

It is good that MSC is considering revising its methodology with regard to depleted stocks; however the consultation document only addresses a clearer definition of the timeframes for rebuilding to be associated with each of the three scores.

MSC certification of fisheries on depleted stocks as “sustainable” is highly controversial.  See for example the ongoing saga of the conditional certification of the fishery on the collapsed offshore South African hake stock. 

It can be argued that the current SG100 requirement should be the minimum required in order for a fishery to be considered for a conditional pass score (SG60) and that an unconditional pass score (SG80 or 100) should only be given to a fishery on stock that has already rebuilt and is fluctuating around BMSY or above under a fishing mortality of FMSY or lower (the fishing mortality rate consistent with maintaining the stock at BMSY or above).

A fishery on a depleted stock should never be considered sustainable.   

MSC Surveillance audit – South African hake trawl fishery

It is one year into the recertification of the South African hake trawl fishery.  Moody Marine Ltd has sent a team to South Africa to undertake the first surveillance audit of the fishery as required under the MSC eco-certification procedure.

The recertification the South African hake trawl fishery was not plain sailing for Moody.  The unit of certification includes an inshore and an offshore fishery component on different species.  The offshore hake, Merluccius paradoxus, is the main contributor to the fishery.  It is in a collapsed state and did not improve during the previous certification period.

One of the independent reviewers of the Moody recertification strongly argued against calling a fishery “sustainable” when one of the components remains in a severely depleted state.  This was overruled by Moody in their assessment, but did lead to “Condition 1” in the certification – a requirement that a recovery trend be demonstrated in M. paradoxus within the certification period.

So is there evidence that M. paradoxus is recovering?  It is hard to tell.  The last public-domain stock assessment document is a 2008 paper by Rademeyer and colleagues at the MARAM consulting company based in the Mathematics Department of the University of Cape Town.  This assessment showed the spawning biomass trajectory up to 1999 and there is no evidence of rebuilding. 

The Moody 2010 certification report provides the public with a rare look at the assessment process and the state of the stock. According to the report “models developed and implemented by MCM and its contractors are subjected to various reviews and debates through MCM’s Demersal Working Group. Industry, through their consultants, participate in the debates of the Working Group and have been influential in guiding the research.”

MCM is the South African federal government department of Marine and Coastal Management.  MCM is a bit of a black hole.  Nothing in the way of useful information is released to the public.  The “contractor” to MCM is MARAM.  MARAM developed the assessment model and also carry out the assessments using the model, apparently because of a lack of quantitative expertise at MCM.  MARAM is also responsible for the development of the Operational Management Procedure which is used by MCM to manage the stock.  MARAM does not produce public documents related to its contracts with MCM.

The assessment in the Moody certification report extends the spawner biomass series to 2007.  Spawning Stock Biomass continues to decline, reaching the lowest estimated level ever.  Projections under the MARAM management procedure predict that recovery will take place following 2007, however such projected recoveries are notoriously optimistic and routinely get postponed in subsequent assessments.  There needs to be actual realized evidence of recovery to satisfy Condition 1, not merely a projection.

One assumes that the Moody team for the current hake surveillance audit will have MARAM and MCM documents at their disposal in order to evaluate whether or not Condition 1 is being met.  

There should be full public disclosure by Moody of all relevant MCM and MARAM documents on M. paradoxus used in the audit, otherwise the public are being kept in the dark and have a right to be suspicious.

A comment on the NE Atlantic mackerel objection

From the comment section - the following anonymous comment on the NE Atlantic mackerel certification raises some interesting issues and is repeated here.


Two things strike me regarding this. 


Firstly, MSC has always said that it is not directly involved in decisions regarding who gets certified and who does not. It argues that it merely sets the standard for the assessment criteria and then it is up to an independent consulting company to determine if a fishery meets the standard. The proclamation on the MSC website regarding removal of certification by 2012 unless the whole NE Atlantic mackerel fishery meets the standard sounds like direct interference in the process to me.


Secondly, the concept that not only the enterprises seeking certification need to be abiding by the criteria, but also those outside the certification, will pose problems for other fisheries currently seeking certification, such as the offshore northern shrimp fishery of Newfoundland/Labrador. In this fishery Faroe Islands have unilaterally increased their own shrimp quota outside the overall quota set by the responsible RFMO, NAFO.

NE Atlantic mackerel – MSC policies and international governance

The NE Atlantic mackerel fishery is presenting some interesting insights into the evolving policies of the Marine Stewardship Council and its relationship with existing governance structures.

It can be argued that Marine Stewardship Council  eco-certification program only has added value in situations where national and international fisheries governance structures are not doing their job of conserving fisheries and ecosystems through sustainable management in the interests of long-term public good.

Given the poor practices of many governments in both developed and developing nations, and regional fisheries management organizations, there has been much for MSC to get their teeth into over the last 10 years.  Some of the cases they have taken on have been controversial – best known of all being the recent Ross Sea Antarctic Toothfish fishery certification.  This fishery is in international waters and is being pursued by a number of fleets from around the world.  A subset of these fleets applied for certification and achieved it despite strong objections from conservation groups (but not the responsible RFMO, CCAMLR).  Other fleets outside of the certification engaged in the same fishery have reputations as pirates and rogues responsible for serial collapses of the conspecific Patagonian Toothfish fisheries in various parts of the world.  This did not seem to matter to MSC then.

But it matters now.  MSC has announced that unilateral quotas and increases in fishing activity by Faroese and Icelandic fisheries on NE Atlantic mackerel will result in suspension of MSC-certification for those seven fisheries already certified.  Ongoing certification and any new certifications of fisheries on this stock will require establishment of a mechanism for monitoring and managing the combined catch of all the nations before the end of 2011. If not, all seven certificates will be suspended in January 2012.

The mackerel bubble was burst, not by an environmental organization but by the tweed jackets at Marine Scotland, part of the core Scottish Government set up in 2009 to manage Scotland's waters.  They recently ponied up the £5,000 required to object to the assessment by the for-profit consulting company Det Norske Veritas that the Faroese mackerel fishery smelt like roses.

So two three things of note (1) MSC threatens removal of certification unless the whole fishery including those not in the program are behaving; (2) A government challenges the outcome of the MSC process; and (3) An objection is actually sustained by the MSC appointed Independent Adjudicator.

Too bad about the Ross Sea Antarctic Toothfish though.

De-coding eco-labels, flaws and inadequacies - Food&WaterWatch

Food&WaterWatch describes a number of flaws and inadequacies with eco-certification and eco-lables in their recent publication De-coding Seafood Eco-Labels: Why we need Public standards.

Two issues that stand out are whether the public or private sector should oversee eco-certification and the certification of flawed fisheries.

Private sector eco-certification, for example the program run by the Marine Stewardship Council, limits the public right to fully determine the standards and conditions related to the labeling of their own property, the fish in the ocean.  If governments and RFMO's lived up to their responsibility to ensure only sustainable fisheries are permitted, there would be no need for expensive private sector certification schemes to second-guess the process.

Certification of flawed fisheries on condition that they undertake to improve and become sustainable in the future is very controversial.  As Food&WaterWatch point out - this deception regarding a sustainable fishery can be exploited by "free-riders" who get to ride on the reputation of the label.   Nobody should purchase a Toyota that is provisionally deemed safe provided the company figures out a way of fixing that brake problem over the next couple of years!

Seafood eco-labelling criticised

An interesting article by Clare Leschin-Hoar on the website slashfood.com on 8 December draws attention to a recent publication by Food and Water Watch on De-Coding Seafood Eco-Labels: Why We Need Public Standards.

Clare notes that among the concerns expressed by Food and Water Watch are the certification of fisheries that have only pledged improvements over ones that meet all criteria, the high costs of certification which leads to a pay-to-play environment, and the predominant use of labels as marketing tools.  Concern is also expressed about groups such as the Marine Stewardship Council setting sustainability standards rather than governments.

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?