SEAFOODNEWS.COM by John Sackton — October 8, 2014 — In a highly significant letter to the Board of the Global Seafood Sustainability Initiative, the FAO has called into question some of the draft work the GSSI has done on establishing a benchmarking process for seafood eco-labeling schemes.
Lahsen Ababouch, Director of the Fisheries and Aquaculture Policy and Economics Division, which created the series of FAO documents that represent the FAO responsible fisheries standards and their eco-labeling guidelines, said that FAO cannot support a benchmarking scheme that attempts to go beyond the FAO established sustainability standards.
In a letter sent September 19th, the FAO wrote:
“We have some concerns about additions and modification to indicators above and beyond those derived from the [FAO] Guidelines to produce the GSSI baseline. .. Unless it is backed by its Members, FAO cannot support additions or modifications above and beyond the FAO Code of Conduct for Responsible Fishing and Certification Guidelines, which are rigorous and remain the leading international instruments for promoting sustainable fisheries and aquaculture management. ”
“Another concern for the FAO is the potential for the GSSI benchmarking tool, given the proposed application rules, to block new certification schemes and developing country exporters from access to their traditional markets. We would like to encourage the GSSI Steering Board to adopt inclusive processes that do not favor large existing certification schemes and well-advanced operations…. we believe some of the processes for being benchmarked by GSSI need to be re-evaluated, .. [as they are] likely to exclude national certification schemes from GSSI benchmarking. “
This intervention from the FAO goes to the heart of a fundamental disagreement about the benchmarking process GSSI has been attempting to develop.
When it was first modeled on the Global Food Safety Initiative, the aim of the GSSI was to provide a mechanism similar to the way GFSI benchmarks minimum standards for global food safety. These standards are accepted by major buyers, so no matter what plant inspection scheme is used, whether BRC, Safe Quality Food, or any other standard, they are all considered as interchangeable for food safety requirements if they pass the GFSI benchmark. The GFSI system is pass / fail. A plant either meets global food safety standards or it doesn’t. There is no possibility for it to meet the safety standard 65% of the way.
From the very beginning of the GSSI process, the NGO’s, including WWF who supports both the MSC model and the ASC model for aquaculture, argued that a minimum standard would mean no continuous improvement, and that unless the standard had a ranking roughly analogous to the existing MSC scoring of fisheries, there would be stagnation, not improvement.
Left unsaid was that in a world with a pass-fail standard, the role of the NGO guiding major retail buyers would largely be eliminated.
The GFSI pass / fail model has a tremendous amount of continuous improvement. If you look at any the various technical sectors there is a series of improvements incorporated into the standard by consensus based on new science and better measurement practices. This has resulted in significant improvements over the years. The FAO standards also provide for consensus updates to take into account new science, developments in ecosystem management, etc. The difference between the pass/fail measuring system used by GFSI and the current GSSI draft is that for GFSI improvements are first arrived at by consensus, then incorporated into the standard, as opposed to starting with a sliding aspirational scale that emphasizes not whether a certification unit meets the standard, but where it ranks on the scale of all those schemes that meet the same standard.
As FAO points out, and as was also pointed out to GSSI in the public comments, many of the goals for having three tiers – a kind of good, better best -are in fact aspirational, go far beyond the guidelines published by the FAO, and in many cases are not even possible for a large proportion of global fisheries.
This is a recipe for blocking market access, rather than expanding it.
The requirements put forward in the draft of the GSSI would disqualify certification schemes that met the FAO guidelines for eco-labeling and responsible fishing, and would potentially exclude 60% of global fisheries from ever meeting GSSI standards.
This is a recipe for blocking market access.
For example, the FAO says that the GSSI proposed requirement that the certification scheme have documented clients for several years and auditing requirements, are likely to exclude national certification schemes from GSSI benchmarking. The use of ISEAL rather than the more widespread ISO standards would in effect prevent government bodies from developing a certification scheme that could meet the GSSI guidelines, as ISEAL’s requirements exclude government’s role as sponsor.
This is a very relevant issue, as was brought up today in the Global Aquaculture Alliance GOAL meeting being held in Vietnam. Mr. Le Van Quang, Chairman of Minh Phu which is the largest shrimp exporter in Vietnam, said that they are spending huge amounts of money on trying to comply with a plethora of buyer sustainability standards. He said this adds 5% to 10% to their total cost, and requires as much as 30% of their staff time to prepare for visits and provide documentation to meet different scheme requirements. This is because there is no standardization among the different schemes.
For example, he said that Vietnam was attempting to develop its own standard, VietGap, but this is not recognized abroad. Further, even though he is a 4 star BAP company, the highest possible rating, this is not accepted by all buyers.
For companies like Minh Phu, having a global standard that could correlate Viet GAP and BAP with FAO aquaculture sustainability guidelines, would in fact reduce costs by 10%, would improve use of staff time, and result in much more production efficiency, while making the same continuous improvements in sustainability of shrimp aquaculture.
The FAO letter suggests that the GSSI program would exclude a national scheme like VietGap not on the basis of its rigor, but on the fact it does not meet the ISEAL requirements. This is directly contradictory to the FAO program to improve the sustainability of all global aquaculture, while not creating trade barriers or artificial impediments to international trade.
The letter commends the GSSI for the work done so far, but makes it very clear that a benchmark that is tiered, as has been insisted on the the NGO’s, and which is not similar at all to the GFSI scheme, would be contrary to the spirit and purpose of the FAO guidelines for responsible fisheries and their eco-labeling guidelines, and thus could not be supported.
This story originally appeared on SeafoodNews.com, a subscription site. It has been reprinted with permission.