Last week I was in Kochi (India) as FAO in cooperation with INFOFISH and the Government of India, with financial support from the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), convened a capacity-building workshop on “National and regional good practices in seafood traceability in Asia to combat IUU fishing”.
Besides presenting a research study, I was asked last year to do (more below). It was a good opportunity to catch up with friends/colleagues I have collaborated a lot over the years: Gilles Hosch, Vincent Andre and Heiner Lehr
Besides being a resource "expert" contracted by FAO to facilitate the workshop, I was asked to present a study they commissioned last year (I wrote about it here), and I have no shame to admit it was big challenge.
This was a comparative study of 10 country cases under the framework of the FAO lead programme called “Fisheries Management and Marine Conservation within a Changing Ecosystem Context.” I tackled this study with the help of other two great people; Melania Borit, Ph. Postdoctoral fellow, University of Tromsø – The Arctic University of Norway and Kim Thompson, Independent Consultant, Member of the New Zealand Seafood Standards Council
The main objectives of the study were “to review the 10 national traceability case studies, taking into account their relevance for combatting IUU fishing” and “to provide recommendations on ways to improve their traceability practices, especially to combat IUU fishing”.
Furthermore, it was requested that we the food safety component associated to traceability. Hence, and due to the limitations of the analysis, we focused only on sanitary eligibility involving the traceability system associated to the unique identification in terms of control of sanitary and operational conditions that the production chain of seafood in a country is required to comply with, and is therefore controlled and verified by a suitable Competent Authority (CA).
Based on the provided secondary sources (i.e. the 10 reports), we assessed the following aspects:
- if the state has a functional traceability system;
- if this system is suitable for fish products traceability;
- if this traceability system is designed as to optimize combatting IUU fishing, under two components:
- if the data captured by the system are relevant for identification of IUU fishing.
- if the traceability system covers all the points in the distribution chain relevant for IUU fishing.
- if this traceability system is designed as to optimize official sanitary eligibility of all the value chain from harvest onwards.
For Point 1, recommendations found in scientific literature for assessment of effective traceability systems were followed.
For Point 2, the recommendations of the ISO standard 12875:2011 Traceability of finfish products - Specification on the information to be recorded in captured finfish distribution chains were followed. As the name indicates, this one refers only to finfish, so shellfish are not included, but it is assumed that the results can be extrapolated to shellfish as well.
For Point 3, there is no standard addressing this issue yet and only one scholarly article could be found on the topic (Borit & Olsen, 2012). Thus, the argument in this article for both point’s 3.1 and 3.2. were followed by making a simplified version of the referenced decision matrix.
Based on this analysis, the authors evaluated the country reports traceability systems regarding there:
- Inclusivity - the extent to which the system is designed to provide guarantees for all legally-caught and sanitary controlled fish in the value chain of the species/fishery in question;
- Impermeability - the extent to which the system is designed to exclude illegal catches, and potential non-controlled processing practices; and
- Verifiability- the extent to which the system is audited by an independent body or person (i.e. by those other than the parties directly responsible for following the requirements).
Before the country analysis, we considered important to standardize the understanding of traceability and other concepts relevant to the present study based on the relevant bibliography known to them, as this would be the only way to evaluate all the country studies, under the same methodology.
After the analysis of the individual reports, it was found that none of the sources provided enough information to assess whether the principles of effective traceability were met by the traceability systems of the 10 respective countries.
Common issues identified throughout some of the reports were in regards the expectations of ToR’s; the relevance for combating IUU Fishing, ensuring Food Safety and Sanitary Eligibility, reducing vulnerability to threats and crisis (especially for small scale sector), and the importance of the role’s held by RFMO’s and other organizations
Considering the results of each country analysis, we discussed the need for standardization of the methodology and tools required to assess traceability systems, the need for coordination in between the different authorities, the roles of external and internal traceability, the incorporation of information management systems and the need for standardization in the domain language of traceability.
The study concludes that the systematic review of the 10 country reports shows that there is a lot of confusion and inconsistencies in the meaning, scope, legal status, implementation capacity and control of traceability systems.
We believe that FAO, as in other aspects of fisheries and seafood production, it is in a unique position to lead this efforts, by expanding on the work initiated by the “Best Practice Guidelines on Traceability” (COFI:FT, 2014)
We support the proposition that FAO should convene an expert consultation, which would benefit from the findings of this present study, and include international experts on traceability from all geographical regions, as well as representatives of the various stakeholders along the seafood supply chain, to provide not only a set of guidelines on how to implement traceability systems, but equally importantly, how to evaluate them.
The report concludes with a set of overarching recommendations to FAO, and to the group of countries whose reports were evaluated.
The conclusion of the study are:
- Most of the countries analysed have not legislated and standardised traceability as a requirement.
- There seems to be little interaction in between the Seafood Safety CA and the Fisheries CA in terms of its assessment.
- There is no standardized to evaluate traceability systems in the practices along the production chain and legislation.
- It seems that efforts towards the implementation of traceability systems in the analysed countries and across countries have not been supported in an interdisciplinary and standardised way.
- Traceability Systems per se are difficult to achieve with little money, little human resources and lack of political will.
The recommendations to the countries can be summarised as:
- Define within legislation and institutionalize traceability as integral part of their fisheries regulatory framework from a catch legality and sanitary controls perspective, including standardized best practices, definitions and internationally recognized standards.
- Re-evaluate the meaning, scope, legal status, implementation capacity and control of their respective traceability systems, focusing on maximizing their Inclusivity, Impermeability and Verifiability.
- Include cross-countries traceability linkages along the strengthening of their national systems.
- Harmonize the actions and policies of the different official bodies (i.e. Health, Customs, Fisheries, etc.) having responsibilities regarding seafood traceability systems.
- Liaise with Regional Organizations (ROs), International Organizations (IOs) and Bilateral Organizations (BOs) to provide institutional strengthening and capacity building in fisheries and traceability related issues under a FAO harmonised action umbrella.
- Draw on the existent academic body of knowledge when improving existent traceability systems
The recommendations to FAO are:
- Further support the work initiated by the “Draft Best Practice Guidelines on Traceability” as requested by the 13th of the Sub-Committee on Fish Trade (COFI:FT)
- Convene an expert consultation to provide not only a set of guidelines on how to implement traceability systems, but equally importantly, how to evaluate them
- Produce a set of guidelines and analytical tools (i.e. matrixes and parameters) to identify exactly what kind of data should authors of traceability evaluation reports look for in the practices along the production chain and legislation
- Provide and /or facilitate capacity building and institutional strengthening opportunities for those responsible for developing, integrating, implementing and/or evaluating traceability systems
- Provide and /or facilitate capacity building and institutional strengthening in terms of the legislative ability to prosecute when based on evidence originating from analysing data recorded by traceability systems.
- Support country and regional organizations efforts aimed to better data collection and analysis by government agencies along the domestic production chain as to strengthen the overall efficiency of their traceability systems.
I have a huge respect to those that make the study and analysis of traceability their area of expertise... after leading this study I'm happy to just stay on "knowledgeable user" rank :-)