Recent events in Alaska have sparked a heated debate with regard to the certification and eco-labeling of wild salmon.
The decision by the Alaskan client group (Alaska Fishery Development Foundation) to discontinue certification to the Marine Stewardship Council standard in favor of a scheme promoted by the Alaskan Seafood Marketing Institute (ASMI) has given profile to several issues with regards to seafood standards, certification and eco-labeling. Sustainable Fisheries Partnership (SFP) is a trusted advisor to many companies within the seafood sector, both at the supplier and retail level, and has been asked by several of these partners to provide guidance on this issue. We have created below a highly condensed version of our views but this vital subject deserves far greater detail and we look forward to engaging in further discussion and triggered significant discussion within the seafood industry. Alaskan Salmon and Certification – Key Points The ASMI scheme does not support a claim of ‘sustainability’ The ASMI claim of ‘sustainability’ is based solely on the Global Trust “Responsible Fisheries Management Certification” scheme. In this scheme Global Trust audits fisheries against a standard it developed, called “Conformance criteria for FAO-based Responsible Fisheries Management”. The standard is essentially an interpretation of the FAO Code of Conduct although the criteria for assessing conformity are not available publicly. The FAO Code of Conduct specifies responsible management practices, including that limits and targets should be set. But it does not precisely define these terms nor require, for instance, that wild fish stocks be above certain levels to be deemed “responsible”. The Global Trust scheme follows the FAO Code, in that it similarly focuses on assessing management practices, and also does not require that the actual current status of fish stocks or environmental impacts be above or below certain levels in determining whether a fishery should be certified. The MSC claim of sustainability is also an interpretation of the FAO Code of Conduct. However, the MSC standard is detailed in the Fishery Assessment Methodology (FAM), which describes 31 Performance Indicators (PIs) that Certification Bodies (CBs) must use when auditing a fishery. Each PI is classified according to whether they measure performance of management, information or outcomes (i.e., the amount of fish alive in the water relative to target levels). Each of these criteria includes clearly defined scoring guideposts (SGs) for a minimum pass with conditions, and an unconditional pass. Consequently, the ASMI scheme may be credible as a claim that a fishery has a management system in place (that broadly conforms with the FAO code of conduct) but it cannot support a claim of ‘sustainability’. According to Mr Peter Marshall, CEO of Global Trust Certification: “The FAO-based Certification relates to the certification for ‘Responsible Management for Sustainable Use’ of the fishery rather than targeting to make a claim of certified sustainability for the fishery. This means that the FAO assessment team does not try and make a judgment on whether the fishery is sustainable”. The ASMI scheme and MSC are not equivalent If the two certification schemes – MSC and ASMI (based on a Global Trust methodology) – are compared it is clear that MSC requires a higher level of performance from fisheries. The most obvious differences include:
- The MSC certificate details several conditions requiring the Alaska salmon fishery to raise performance while the ASMI scheme has already awarded an unconditional pass.
- The MSC scheme requires a certain level of performance against several vital “outcome” measures of sustainability such as the actual status of wild fish stocks and the environmental impact of the fishery. These are not pass/fail requirements of the ASMI scheme, which focuses on management systems.
Diversity of labels in the marketplace The seafood industry is currently wrestling with two contradictory arguments. On the one hand it is widely held that there are ‘too many’ eco-labels in the public domain which are ‘confusing the consumer’ and that this is a problem that needs to be resolved. On the other hand there are parallel (but contradictory) arguments that there are ‘too few’ wild seafood certifications, that MSC poses a threat of monopoly and that there needs to be more eco-labels placed before the public. SFP does not pretend to offer clear resolution on these points but does believe the following: That it is entirely healthy that there are a range of different certification systems available for wild caught seafood under the following circumstances:
- That certifications which offer virtually identical levels of governance and performance (ie their judgments on any given fishery would be identical) compete on the grounds of cost and efficiency AND/OR
- That certifications offer different levels of ambition (ie that some schemes offer a lower ‘pass mark’ than others) so long as the claims made for such certifications accurately represent what the schemes really measure and are both reasonable and proportionate.
It is a matter for each individual company to decide on their level of ambition with regard to sustainability and which certifications they consequently chose to support. SFP consistently recommends to partners that they aim to achieve a level of performance in source fisheries consistent with an unconditional pass with the MSC scheme (or equivalent) but this advice will not always be taken and some companies may adopt other certifications as stepping stones towards greater achievements in the future. For instance, in improving fisheries, certification by the Global Trust methodology would help verify a fishery has responsible management even though the standard is silent on stock status and environmental impacts. The implications for the seafood industry of accepting lower standards Wild fishery certifications that adopt lower levels of ambition may be attractive to industry because they will encompass a wider range of fisheries and may be cheaper (because of lower monitoring, governance and compliance costs). However, adopting lower sustainability standards for source fisheries increases the overall level of business risk, both in terms of reputation as well as the long term security of supply. This needs to be a consideration when planning a procurement and marketing strategy. In the case of Alaskan salmon there are clear concerns around the environmental impacts of hatcheries and this issue is likely to be a significant source of increasing debate in the future. The MSC scheme requires that progress be made in resolving uncertainties around hatcheries (via the currently outstanding conditions on the certificate) while the ASMI scheme is essentially ‘in denial’ and contains no requirement to address the hatchery issue. Using the ASMI scheme in its current form would therefore lay companies open to accusations of ‘green-washing’, since it would appear as if they were circumventing MSC conditions on hatcheries. What would be an appropriate claim by ASMI using the current Global Trust methodology? The least controversial claim made by ASMI with regard to their certified seafood is that it does indeed come from Alaska. This is not a trite observation – the Alaskan origin of the products is seen by retailers as the most powerful component of the marketing value bestowed by the ASMI label. In some markets Alaska has a series of ‘brand attributes’ such as purity, naturalness and health that are highly valued by the seafood sector. However, a desire to establish Alaskan origin for seafood in the minds of a consumer should not be taken as an excuse for making unsubstantiated claims regarding ecological sustainability. The claim that the ASMI label can legitimately make with regard to the conduct of the salmon fishery should be confined to ‘responsibly managed’ since this is consistent with the actual methodology of the standard (insomuch as it can be determined without full public disclosure). It would also be perfectly legitimate for retailers to ask ASMI to place the current logo on products (‘Alaska seafood’) but ask for the strapline (‘Wild, natural & sustainable’) to be removed. Why should industry waste it’s time ‘platinum coating a gold-plated fishery’? Whatever the level of controversy currently surrounding Alaskan salmon, it is clear that compared to most fisheries in the world it is well managed. Consequently, it may well be that observers of the industry are puzzled by the exertions made to improve a fishery that is already good (“to platinum coat a gold-plated fishery”) when there are so many other fisheries in the world that merit more attention. SFP offers the following thoughts: SFP has been active in promoting the Fishery Improvement Project model and has emphasized focusing improvement efforts in the worst fisheries, where improvements will generate the greatest environmental and economic benefits. However, this is a controversial strategy with some NGO stakeholders who seek improvement in ALL fisheries, where improvement is clearly identifiable – such as the conditions currently outstanding on some of the Alaskan salmon fisheries. For the purposes of reducing reputational risk we recommend that the seafood industry place the bulk of their efforts in improving relatively poor fisheries BUT also devote some resources to further improving fisheries that are already good. Given the size and iconic status of the Alaskan salmon fishery, and the sensitivity of the hatchery issue, there is clearly merit in meeting the outstanding MSC conditions. What does SFP think about the MSC? The MSC is a good, global “average” standard to measure the relative sustainability of a fishery at a given time. Its innovative use of conditions means it can apply to a relatively wide range of fisheries and create agreements on fishery improvements, thus creating change in the water toward better practice. It is the “goldilocks” standard – it is not so low that it attracts excessive levels of criticism, nor so high that it excludes too many fisheries. Although there are critics within industry who claim that the standard is too high it is the SFP view that the MSC standard is at the lowest level feasible while still adhering to good science. However, SFP support for the MSC is conditional on the organization maintaining its middle ground position between NGO and industry demands and the maintenance of a transparent, multi-stakeholder consultative process to develop the standard in the future. SFP would support another standard that promoted equivalent criteria and adopted a similarly rigorous approach to governance and standards development. SFP encourages its partners to support the MSC and to engage constructively with certified fisheries to ensure that conditions are met according to the appropriate timetable. However, this does not mean that SFP considers other certifications to be unacceptable so long as they are used in an appropriate manner consistent with their methodologies and ambition. What is SFP currently advising partners? SFP is advising retail partners to take the following steps with respect to Alaskan salmon: For all partners:
- Seek clarification about the precise origins of any Alaskan salmon that is sourced, and the likelihood that the fish originated from a hatchery (i.e., using estimates of the catch share from hatchery fish, based on sampling programs). The Global Trust certification report notes that over 1.4 billion juvenile fish were released from hatcheries in Alaska in 2009, and that over 90% of the pink and chum harvested in Prince William Sound and 88% of the chum in SE Alaska were hatchery produced. The outstanding MSC conditions are primarily in Prince William Sound and SE Alaska, and these regions carry the most environmental risk.
- Press for progress on the existing MSC conditions regardless of the certifications adopted. The hatchery issue needs to be progressed and there are real reputational issues in being seen to back away from this challenge. If it is not possible to obtain assurances regarding the fulfillment of conditions it will be necessary to consider sourcing from non-hatchery supported runs/species and/or supporting a call for a moratorium on any expansion of the hatchery programs until progress is made.
- Encourage the Alaskan salmon industry to stick with the MSC. Even for partners who do not have an MSC commitment and are not using the logo it still makes sense to require a credible standard for sustainability.
- If the Alaskan salmon industry refuses to continue with the MSC, then those partners seeking third party verification of sustainability without a consumer facing eco-label or claim could encourage ASMI to adopt a higher standard that requires equivalent technical performance to the MSC (although it is unlikely to reach equivalent governance standards in the time available). Such an approach could benefit Alaskan producers since many of their competitors would probably pass the current ASMI standard but fewer could achieve the higher standards that Alaska has already met.
For partners using the MSC label on pack: The MSC certified Alaskan salmon as 16 separate units, recognizing that significant differences exist in status and management of different species in different areas of Alaska. Many of these species and runs are in good shape, have few or no conditions, and would be readily recertified. However, significant concerns exist about the status of some specific stocks, and their MSC certificates came with several key conditions. While good progress was made in closing many conditions, little progress was made on some others. Good progress is necessary on all conditions to ensure the continued long-term certification of the entire fishery. Nonetheless, companies using the MSC label on pack should consider how best to support a new client group that can enter the entire fishery into MSC recertification, as AFDF had done in November 2011. If it becomes clear that some parts of the fishery will struggle to satisfy conditions and continue to meet MSC standards (for instance, Prince William Sound) then the client group should achieve certification for those parts of the fishery that can meet current conditions. Those parts still uncertified should be encouraged to participate in an industry-lead Fishery Improvement Project as part of a process to achieve MSC standards for all Alaska salmon in the long term.
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