MSC pre-assessments and pre- pre-assessments
For the last four years we have been working with Food Certification International to obtain accreditation as a certifier of sustainable fisheries to the Marine Stewardship Council standard, undertaking both full assessments and pre-assessments.
Given our over twenty years of advisory work in:
- the development of fishing industries,
- development of markets and the seafood trade, and
- development of fisheries management systems,
we have also been well-placed to advise national administrations, local councils, seafood trade organisations and individual processing and fishing companies on how embark on the journey towards certification to the MSC or other eco-labelling standards – what might be termed pre-pre-assessments. Work has been undertaken confidentially for a range of clients, both advising them on how to proceed, but also working up research and development programmes that will progress them more quickly, and working up and quality controlling research outputs.
Drawing together our experience to date in full assessment, pre-assessment and pre-pre-assessment, the following common weaknesses have been identified in fisheries seeking to gain MSC certification. To re-cap, the MSC assessment systems comprise;s
MSC Principle 1 - Resource Sustainability
A fishery must be conducted in a manner that does not lead to over fishing or depletion of the exploited populations and for those populations that are depleted the fishery must be conducted in a manner that demonstrably leads to their recovery
MSC Principle 2 - Ecosystem Sustainability
Fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically related species) on which the fishery depends.
MSC Principle 3 - Management Systems
The fishery is subject to an effective management system that respects local, national and international laws and standards and incorporates institutional and operational frameworks that require use of the resource to be responsible and sustainable.
P1 – Principle 1 issues -
- Traditional focus on species subject to management by TAC
- Despite a fishery only capturing a very small part of the biological stock, the MSC assessment methodology requires that the health of the stock is assessed for the whole stock; where there is strong evidence that a sub-set of the overall stock is used for management purposes then the appropriateness of using such a stock unit for MSC assessment may be assessed – but this may not be suitable for the lesser geographical scale
- Much reliance is put, in a European context, on the work of ICES – and ICES is required by its members to put relatively more emphasis on assessing the stocks of species that are subject to management by Total Allowable Catch and national quota; such emphasis does not always / often cover species and stocks of particular interest to inshore fleets
- Even where ICES does report on a particular stock, it does so primarily from a scientific / biological perspective, and does not always or often provide clear advice on how the fisheries for a particular species should be managed – i.e. the provision of a complete set of reference points, a clear stock management strategy, and a set of harvest control rules to cover all / most eventualities
- Gaps where a stock is not managed by TAC, or is managed at a smaller scale
- There can be over-focus on data collection and science / biology; less focus on providing clear fishery management guidance – thus no specific stock assessment might have been undertaken, even where there is the existence of some, if not a great deal, of fishing and stock-related data
- There are many techniques for making crude but effective estimates of stock size and condition that are sufficient for fishery management purposes though they might not satisfy the accuracy expectations of the scientific establishment – the MSC standard focuses on the management of the fishery, not on the pursuit of scientific knowledge – but it does require clear evidence of stock health and condition, clear statement of how the stock is to be managed, and a clear set of harvest control rules that guide fisheries management
- Often no specific statement of a stock management strategy has been made – i.e. a statement should exist to the effect that direct and indirect mortality from fishing activity will be kept below, for example, 20 per cent of Standing Stock Biomass (SSB)
- No harvest control rules for the fishery have been put in place – instead, more typically, fishing activity is guided by economic considerations (though in the majority of cases these largely coincide with a set of rules that seek to protect the health of the stock, they tend to favour fishing over conservation, and in the extreme fishing interests outweigh stock conservation interests); harvest control rules need to be re-cast to explicitly respond to stock conservation stimuli, and to encompass a mechanistic relationship between stock condition and fishing pressure – for example, a rule such as if SSB falls below such and such a threshold, mortality due to fishing will be cut back by such and such a proportion – essentially so that the management changes are less a matter for debate, but rather a condition / response relationship
- Issues relating more particularly to inshore fisheries
- Because an inshore fishery may only harvest a very small part of a stock, often it has not been considered necessary to collect fishery and biological data that refers to the whole stock; this can mean that available data (from many such fisheries) is insufficient to allow for assessment of overall stock condition, or data is incompatible with other data-sets
- It remains the case that much data may be collected, but that it is not analysed in a form that will yield useful guidance on fishery management in the context of Principle 1 issues – stock size stock boundaries, harvest strategy and the design and monitoring of harvest control rules; sometimes it is sufficient to re-assess data in this particular context – sometimes it is necessary to add further key information to existing information to allow for such analysis
- There are situations where it is practical to treat the general extent of the localised fishery as a local approximation for a stock management unit; this is unusual, but can be applied to fisheries for more static organisms
P2 – Principle 2 issues -
- In respect of many inshore fisheries there is considerable knowledge about the extent and composition of discards, bycatch, impact on the habitat and ecosystems, and capture / impact relating to endangered, threatened and protected (ETP) species; the problem is that often this knowledge is not well documented, or data have not been formally collected or collected for a long enough period
- In the UK this is less of a problem given the extent of areas subject to marine conservation designation in the inshore area, where more focused research has been required at some time in the past
- Even so, information may not be of a quality or quantity sufficient to apply the standard MSC assessment methodology; in such cases, it may be feasible to apply an alternate risk-based assessment methodology that is under development by the MSC; this risk-based approach necessarily requires a wider margin of error to be allowed than for one which data are available – and thus is a more rather than less demanding standard; for theFCI / Nautilus has tested this assessment methodology in a pilot assessment, and its key assessors have been closely involved in the evolution of this methodology (our stock assessment specialist has worked closely with the MSC in the development of both the standard and risk-based methodologies, and our core environmental assessor is contributing to on-going work with MSC to come up with a final version of this methodology)
- In most cases it may be necessary for the collection of further information on fisheries / environmental interaction, but existing information may be sufficient to allow the scoring of a fishery in the full assessment (potentially leading to certification of the fishery), but a condition or conditions of certification may be raised that requires improvements in both the collection of data and in the operating standards applied to the particular fishery – i.e. poor scores under Principle 2 may not automatically block certification of the fishery (assuming the overall average score for P2 is 80 or above).
P3 – Principle 3 issues -
- UK inshore fisheries are subject to considerable oversight and scrutiny through the systems employed by the Sea Fisheries Committees and the MFA in relation to at-sea and in-port inspections and data provision requirements (landings returns and sales notes), though such scrutiny is generally of a different order to that applied to the rest of the fleet – i.e. different performance standards apply to vessels over 15 m in length, and over 10m in length; this does, however, mean that they are generally compliant with many Principle 3 Performance Indicators
- Where inshore fleets harvest species as target or bycatch that are subject to management by TAC, traditionally poor quota allocation to the “non-sector” and/or under 10m fleet, combined with less stringent reporting conditions, have in some fisheries meant that inshore fleets have been catching outside their quota allocations; this puts them at odds with some P3 Criteria, though this may simply prompt a score below the 80 (good practice threshold) but above 60 (minimum acceptable performance standard)
Scoring above the good practice threshold requires under some criteria that the fleet operates to established and ideally formal and documented performance standards; it is unusual that formal or documented standards exist for inshore fleets, but capture of such standards, even where it is simply stating the obvious, can greatly strengthen scoring against P3 criteria, and even criteria under P2 and P1; compliance with the Seafish Responsible Fishing Scheme goes some way to complying with this standard