MSC Deputy CEO Responds to Criticisms of Ross Sea Toothfish Certification
After running a blog post on the announcement of the Marine Stewardship Council's certification of Ross Sea toothfish, a variety of interesting concerns and criticisms were voiced on Santa Monica Seafood blog and others, many of which are addressed in this comprehensive letter from early January written by the Marine Stewardship Council's deputy CEO, Chris Ninnes:
The Marine Stewardship Council's (MSC) recent certification of the Ross Sea toothfish fishery has drawn some criticism from concerned stakeholders, reports www.megafishnet.com with reference to Santa Monica Seafood.
Rather than being a source of dismay, the certification of the Ross Sea toothfish is actually a great outcome, both to demonstrate the existing sustainability of the fishery and to ensure the long-term rational use of this resource. This optimistic view is the result of the continuing focus on fisheries improvement and regular evaluation that forms part of MSC certification, and because of the strict management regime implemented by CCAMLR. I believe it is through the ongoing cooperation of the fishery, MSC and CCAMLR that the Ross Sea toothfish will prosper and knowledge of the species will continue to improve into the future.
The first main concern over the Ross Sea toothfish certification is that the objections process - which forms part of the assessment methodology - is flawed, because the final decision on certification remains with the certifier and not the Independent Adjudicator (IA), and also because upheld objections do not automatically result in the failure of a fishery.
However, and as clearly set out in the objection procedure (available to all stakeholders) it is not the function of the IA to change the scores awarded nor is there any delegated authority to fail or pass a fishery. The objections process clearly requires that the final certification decision be made by the certifier "with regard to the decision of the adjudicator". It requires the certifier to examine the IA's decision and incorporate the findings into a revised Final Report.
In the Ross Sea toothfish decision, the IA upheld the objection to the scores awarded on four performance indicators (PI)1 on the grounds that the certification body did not provide sufficient evidence to justify the scores awarded. As a result, the certifier was required to re-score in accordance with the direction provided by the IA's decision. The re-scoring, carried out as per the IA's instruction, did not result in the failure of the fishery as all PI scores still remained above 60 and the averages above 80. But further performance requirements were attached to the certification decision, and the fishery will be required to undertake additional management actions to bring about further specific improvements in its operation.
Critics also claim a fishery should fail its assessment if a remand finds in favour of the objector for any PI score. This, however, is not the case, as failing the assessment is not the only possible - or necessarily correct - outcome for the fishery when an objection is upheld. Instead, a number of potential corrections to the CB's determination can arise as a result of an objection and it is not unusual for independent objection processes to be upheld in part and to proceed with certification after re-scoring takes place.
The second main concern I would like to address is that the Ross Sea toothfish fishery should not have been put up for certification in the first place, as there are gaps in what is known about the target species and it is classed as an ‘exploratory' fishery by CCAMLR.
The assumption behind the criticism is that you need near perfect information before you can start fishing without risk to the resource and this is not widely believed by most of the world's fisheries scientists. What is required is for fishing to proceed cautiously, so that the toothfish resource is not put at risk, and that scientific understanding is progressively built-up to enable management measures for the longer-term to be determined. This precautionary approach is required for any CCAMLR fisheries designated as ‘exploratory'. It is a definition that ensures that prescribed and conservative harvesting strategies are employed during the early years of the fishery.
Therefore, under CCAMLR management, harvesting of Ross Sea toothfish must proceed cautiously and precautionary management measures must take into account the incomplete state of knowledge about the stock and ecosystem. Vessels that want to participate in the fishery must abide by CCAMLR's precautionary management regime, which includes strict harvest control rules, mandatory data collection to improve understanding of the resource's biology and ecology and to support annual stock assessments and other research and mandatory observation of fishing activities and requirements to avoid incidental by-catch.
In the Ross Sea toothfish assessment, the certifier found the precautionary nature of the conservative management framework implemented by CCAMLR - recognised as a world leader in ensuring high levels of precaution are in place, and in providing incentives for further research - takes into account much of the uncertainty in knowledge, in addition to initiating research to reduce uncertainties and improve understanding. The independent adjudicator found, with the exceptions already noted above, that this assessment conforms with the MSC assessment process, and that developmental - or ‘exploratory' - fisheries with knowledge gaps can still be managed sustainably, and can become MSC certified, if they are managed with sufficient precaution.
A specific criticism raised by ASOC (FNI, December 2010) regarding the lack of information relates to the recent improved understanding of the age structure of the stock. This information has been factored into updated stock assessments and it is comforting to know that the perception of the state of the stock did not change significantly. It is still well above 70% of its unexploited stock size. This underlines why the Ross Sea toothfish fishery is sustainable and is being managed with sufficient precaution. If this were not the case then the impact of new information of this sort would have resulted in a much more significant reduction in the perception of stock status.
Consumers and retailers can be assured that the Ross Sea toothfish fishery satisfies the MSC's demanding standard of sustainability, and products from this fishery have earned the right to bear the MSC ecolabel.
As noted above the 60% minimum pass for each performance indicator that the basic biological and ecological processes of all components impacted by the fishery are not compromised now or into the future. However, the MSC program requires a higher level of performance than this minimum benchmark to meet its Standard; an aggregate score of at least 80 for each of the three Principles has to be achieved for a fishery to pass. This ensures the fishery is more resilient and better able to adapt to potential changes and risks such as fluctuations in stock levels, and so secure its long-term sustainability. It also means that the fishery, as ranked on a global scale, is performing well above accepted best practice.
The MSC sets the benchmark for science-based, sustainable fishing with strong, robust technical policy that is the backbone of the MSC environmental standard. To ensure that the MSC program continues to meet best practice, stays up to date with scientific advances and meets partners' needs, MSC policies are reviewed and developed on an ongoing basis and in consultation with stakeholders. The robustness of our program depends upon the committed contributions of interested organisations from a wide spectrum. We will continue to listen to their contributions and use them to shape improvements to how we deliver.