The Marine Stewardship Council's response to Pew's opininon piece "Seafood Stewardship in Crisis" published in the Journal Nature follows: @font-face { font-family: "Courier New"; }@font-face { font-family: "Wingdings"; }@font-face { font-family: "Calibri"; }@font-face { font-family: "Tahoma"; }p.MsoNormal, li.MsoNormal, div.MsoNormal { margin: 0in 0in 10pt; line-height: 115%; font-size: 11pt; font-family: "Times New Roman"; }p.MsoAcetate, li.MsoAcetate, div.MsoAcetate { margin: 0in 0in 0.0001pt; font-size: 8pt; font-family: Tahoma; }p.MsoListParagraph, li.MsoListParagraph, div.MsoListParagraph { margin: 0in 0in 0.0001pt 0.5in; font-size: 11pt; font-family: "Times New Roman"; }span.BalloonTextChar { font-family: Tahoma; }div.Section1 { page: Section1; }ol { margin-bottom: 0in; }ul { margin-bottom: 0in; }
Scientific consensus on the measure of sustainability
The MSC standard is a measure of the sustainability of a fishery against well-defined principles and criteria. The bar at which a fishery demonstrates it is well-managed and sustainable represents a broad scientific consensus, agreed by over 200 marine biologists, scientists, environmentalists and other stakeholders from around the world, over the course of a two-year consultation period (1997- 1999).
Every certified fishery is sustainable
Every fishery certified to the MSC standard is sustainable and well-managed and fisheries are not, as the authors assert, certified before they can demonstrate their sustainability.
The scoring of a fishery against the MSC standard has two key posts, a score of 60 and 80. In relation to stock levels (the example used by the authors of the Nature piece), the 60 score represents the precautionary limit for sustainability. A score of 60 and above indicates that the stock is not overfished and is at a sustainable level, as defined by the 2009 United Nations Food and Agriculture Organisation (UN FAO) guidelines for ecolabelling of fish and fishery products. A fishery must be able to demonstrate it is sustainable by meeting this score in order to be MSC certified.
The MSC program demands additional precaution and sets a target level for the stock which equates to a score of 80. If a fishery is scored between 60 and 80 for its stock level, the fishery must take action to increase the score to the target 80 within a set period of time. If the fishery fails to reach this target, it can lose its certification.
This higher level further reduces the risk of the stock โwhich could be being depleted because of natural fluctuations ยญโ falling below sustainable levels and allows the fishery sufficient time to respond to new data on stock levels and implement any necessary changes to ensure that the stock can move back up to the higher target level.
Stock abundance is a key indicator of the sustainability of a fishery but further rigor is built-into to the MSC standard by scoring the fishery against a total of thirty one performance indicators. If the score for any one of these indicators is less than 60 the fishery would fail.
Outcome-based system
The authors express their opinion that fisheries that use bottom trawls or utilise the catch for the production of fishmeal should not be viewed as responsible and sustainable. The MSC program does not prescribe gear types or specify the final use of the fishery products. Instead, as an outcome based programme, it requires all fisheries seeking to be certified meet the science-based principles and criteria of the MSC standard that together are a measure of the status of the stock, the level of impact on the environment, and the management system the fishery has in place. The โopenโ approach of the MSC program meets the requirement of the guidelines of the UN FAO for a global certification and ecolabel program for fish products. Consequently, the program is open to all fisheries to be assessed against the rigorous, science-based standard.
The MSC is ambitious about achieving change in management practices where it is needed and driving progress towards sustainability across all types of fisheries and it will do so, not by excluding fisheries from the program, but by encouraging them to participate.
Checks and balances ensure a credible and objective assessment
The MSC program is highly transparent and participatory, and from the outset of the assessment, stakeholders with an interest in the fishery are invited to take part in the assessment and submit information to the expert scientific team.
The MSC methodology requires certifiers to justify the conclusions reached for every score awarded to the fishery under assessment. Once the assessment team has completed its scoring of the fishery, its findings are subject to peer review by at least two independent scientists. Any comments from the peer reviewers must be fully addressed and placed on the public record.
Following the peer review, a Public Comment Draft Report is made available to all stakeholders involved in the assessment for further review and analysis. The certifier is required to address, in writing, and place on the record, any concerns and questions raised at this stage.
Only after this process has been completed does the certifier issue a final report and determination on the outcome of the assessment. At this stage, stakeholders have the opportunity to lodge an objection.
The value and purpose of the objections procedure
The ability of stakeholders to file an appeal of the certifier's conclusions is a unique and robust feature of the MSC program. The purpose of the objections procedure is to provide a structured and independent review to ensure that a certifier has followed the correct procedures; has taken into account all the relevant information; and has provided a clear rationale for each score awarded. The ruling on an objection is decided by an Independent Adjudicator, not the MSC. The objections procedure is therefore the last in a series of checks and balances which ensures the outcome of a fishery assessment is scientifically valid.
The FAO guidelines mentioned above require that objectors bear the costs of the appeal. The MSC encourages participation in the objection procedure and has recently reduced the upper limit on costs from ยฃ15,000 to ยฃ5,000 to help ensure access to the procedure by all stakeholders. In addition, objectors that lack financial resources may qualify for a total exemption from these costs. Stakeholder participation in the objections procedure has resulted in some cases in fishery scores being reduced to below 80, and as a result, management plans specifying measurable improvements incorporated into the final certification decision.
Ongoing development of methodology and governance
The MSC is continually developing its methods, both technically and in the area of governance and policy and it does this in conjunction with a wide community of stakeholders. Some recent examples include new guidance on assessing low trophic level fisheries; developing a means of assessing data-poor and small-scale fisheries to extend the program more effectively into diverse economies and regions; and changes to the fisheries certification methodology requiring certifiers to make explicit, written responses to all stakeholder comments submitted during assessments. The purpose of this ongoing work โ to which the MSC Board is committed โ is to ensure the quality and consistency of all fishery assessments.
Environmental and market impact of the MSC program
The MSC program seeks to motivate change and improvement in fishing practices through market rewards for sustainable practices. The MSC accepts the need to continue to demonstrate the effectiveness of its program to all its stakeholders: it has, for example, commissioned scientific research which will, when complete, provide the most comprehensive analysis to date of the environmental impacts of fishery certification.
The rigour, credibility and scientific consensus underpinning the MSC standard and methodology has, since 1999, encouraged significant support from fisheries, eNGOs, the supply chain, governments and others that has helped create a global market for sustainable seafood that today accounts for seven per cent of total wild-capture landings. There is a growing evidence base that certification is driving positive change in the way the worldโs oceans are fished, as well as helping more consumers make sustainable seafood choices.
Ends
Notes to the Editor
1. Regarding specific fisheries mentioned by the authors
ยท Harvest of Antarctic krill (Euphausia superba ) is very low โ less than 1 per cent of the most recent estimated biomass. The management authority for the fishery is the Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR), which was established in part to address concerns that an increase in krill catches in the Southern Ocean could have a serious effect on populations of krill. CCAMLR has adopted a very precautionary approach designed to ensure fishing activities minimize risks to the krill population. Further, for the season 2007/08, the total landings (by all boats operating in the area) were 150,000 tonnes โ just four per cent of the total allowable catch set by CCAMLR.
ยท The pollock (Theragra chalcogramma) fishery in the Bering Sea benefits from very high levels of scientific study and analysis backed up by 100 percent federal observer coverage. The science supporting the fishery is a result of local, state and federal agencies, and industry working together collaboratively. The pollock stock is well known by scientists to fluctuate, rising and falling in natural cycles i.e. not as a result of fishing activity. Annual harvest levels are set by the management agencies in accordance with these cycles. The important factor relevant to MSC certification is that the population levels are fluctuating around the target reference point (the 80 score) and therefore the fishery has been determined by the independent assessment team to be well managed and sustainable
ยท The Pacific hake (Merluccius productus) fishery was certified as sustainable and well managed following a comprehensive two-year scientific assessment of the fishery completed by an independent, third-party certifier, and a three-month review of an objection to the certifierโs finding that the fishery meets the MSC standard. The conclusion of the Independent Adjudicator was confirmation of the certifierโs original determination i.e. that the fishery meets the MSC standard on all three Principles and should be certified. Stock levels for this fishery are highly variable and large fluctuations are observed, linked to variations in the ecosystemโs capacity to support Pacific hake. Fishery harvests are reduced to precautionary levels when stock assessment models show negative trends. The 89 per cent decline figure used by the authors takes as its basis the highest ever recorded biomass of Pacific hake, 4.6m tonnes in 1984.
ยท Toothfish (Dissostichus mawsoni)is still in assessment and therefore the MSC cannot comment on its status. However, it is important to note that an โexploratory fisheryโ is not a fishery without sufficient knowledge to carry out exploitation, but rather a fishery where the management authority sets a highly precautionary catch level while investing in collecting data that is fed back into their own scientific assessment to enable further development of the fishery. The Commission for the Conservation of Antarctic Marine Living Resources (CCAMLR) is the management authority for this fishery and, as demonstrated by the case of Antarctic krill, sets very precautionary catch levels for its fisheries.
โBooming businessโ graph and definitions of fishery impact
ยท The โBooming Businessโ graph employs measures based upon a classification of fisheries which is not used in the MSC methodology. The MSC is an outcome based programme and therefore every certified fishery has met the standard, which includes specific indicators used to determine each fisheryโs impact on the environment. This is in line with the internationally agreed guidelines for ecolabelling of the UN FAO and the Code of Conduct for Responsible Fisheries.
2. The Marine Stewardship Council (MSC) is an international non-profit organisation set up to promote solutions to the problem of overfishing. The MSC runs the only certification and ecolabelling programme for wild-capture fisheries consistent with the ISEAL Code of Good Practice for Setting Social and Environmental Standards and the United Nations Food and Agricultural Organisation guidelines for fisheries certification. The FAO โGuidelines for the Eco-labelling of Fish and Fishery Products from Marine Capture Fisheriesโ require that credible fishery certification and eco-labelling schemes include:
ยท Objective, third-party fishery assessment utilising scientific evidence;
ยท Transparent processes with built-in stakeholder consultation and objection procedures;
ยท Standards based on the sustainability of target species, ecosystems and management practices.
The MSC has offices in London, Seattle, Tokyo, Sydney, The Hague, Edinburgh, Berlin, Cape Town and Paris.
In total, over 200 fisheries are engaged in the MSC programme with 94 certified and around 133 under full assessment. Another 40 to 50 fisheries are in confidential pre-assessment. Together, fisheries already certified or in full assessment record annual catches of close to seven million metric tonnes of seafood, representing over 12 per cent of global capture production for direct human consumption. The fisheries already certified catch close to four million metric tonnes of seafood annually โ over seven per cent of the total wild capture for direct human consumption. Worldwide, 6000 seafood products, which can be traced back to the certified sustainable fisheries, bear the blue MSC ecolabel.