I have tackled the FAD issues before, yet las week, in a very compelling study published recently by the top journal Marine Policy, G.Moreno, M. Herrera and J.Morón of OPAGAC* asks ‘FAD or not to FAD: A Challenge to the MSC and its conformity assessment bodies on the use of units of assessment and units of certification for industrial purse seine fisheries’.
The association considers that an industrial tuna purse seine fleet should only be certified as a whole, for its total operations, and not on “artificially construed components of the fishery”, referring to the mixed free-school and FAD fisheries in the WCPO.
Currently, all industrial purse seiners depend on drifting fish aggregating devices (dFADs) for a significant part of their catches, including companies certified by the MSC.
Fish caught in association to dFADs are, however, deemed to not meet the MSC standard and have not been certified.
OPAGAC argues that the certification of FAD-free fish is misleading as the largest proportion of the catch of any vessel comes from fishing operations that are associated to dFADs. Furthermore, the division between dFAD-associated and free school fish is not scientifically robust and can be misconstrued to get certification where it is not warranted.
The main criterion used to separate the two types of school, namely the distance to a floating object, has not been applied consistently by MSC’s Conformity Assessment Bodies, and there are serious doubts that even if it were applied consistently the level of certainty to differentiate FAD-free from FAD-associated schools could not stand up to scientific scrutiny.
The paper also raises questions about the use of species composition, another criterion used to separate the two types of schools, to validate catches. The uncertainty that is inherently present in the current classification raises serious questions about the rigour surrounding MSC-certified FAD-free catches.
“By certifying part of the catch, MSC encourages the misuse of dFADs and does not help to address the issues surrounding their use”,“If MSC wants to improve sustainability of tuna purse seining, all school detections systems (dFADs, anchored FADs, free schools, natural logs and other types of associations) should be included on the certification, Dr Morón concludes.
In response, the MSC issued a statement saying:
The MSC seeks to incentivise the use of responsible fishing techniques – by allowing the separation of tuna caught using drifting FADs, anchored FADs and free school fishing methods, we aim to incentivise a preference towards more sustainable techniques through market preference to MSC certified catch.
In the case of tuna fisheries where only part of the catch is seeking MSC certification, the relevant fisheries and processors must be certified to the MSC Chain of Custody (CoC) Standard requiring that they keep MSC certified catch separate and clearly labelled from non-certified catch.
We are very aware of the risks associated with one vessel catching both certified and non-certified catch and are working with certifiers to ensure that the MSC CoC requirements are effective and adhered to.
- MSC certified tuna must be kept separate from non-certified catch. This may involve storing and holding it in different containers, or separating it in the hold using nets.
- The weight of certified catch is recorded along the supply chain to ensure that no substitution takes place.
- MSC certified tuna fisheries may require on board observers to verify that only tuna caught using certified fishing methods can be sold as MSC certified. Observer coverage is often submitted as evidence that adequate systems are in place to assure compliance with our standard, and in some cases observers may be required by Regional Fisheries Management Organisations.
As an example, the MSC certified PNA tuna fishery has developed a sophisticated traceability system to ensure effective segregation and identification of their certified tuna catch from non-certified. It starts at sea with specially-trained observers who confirm that an individual purse seine set captured only free school tuna, and that no aggregating elements (FADs, logs, vessels or whale sharks) contaminated the set.
Free-school catches are then stored in sealed wells, and traceability is required in all stages of the transfer from catch, through transhipment to carrier vessels to landing at tuna canning factories.
Shipments are checked on landing to ensure that segregation and traceability has been maintained, and cross checks are made using data collected at the point of capture by observers and catch composition data sampled on landing. Only shipments that meet PNA’s rigorous testing and checking procedures are confirmed as coming from free school catches and can pass into the supply chain as MSC certified.
No doubt this is a valid and interesting discussion.
Beyond any ulterior motives (there is always that possibility), there is a point (at least for me) in challenging the sustainability brand of a fishery, based on the fact that the same fleet/vessel has a “sustainable” and a “non-sustainable” (or at least not sustainable enough to certify as "sustainable") way to catch the same stock..
If using no FAD, (or one particular type of FAD) makes it “sustainable” and using dFAD makes it "non-sustainable"… So should a vessel using a “non sustainable” practice be certified only for it “sustainable” one while ignoring the other? Isn't that cherry picking?
Should Tuna fisheries be only be certified if they can prove that they have not fished with FADs? Or should be fishing with FADs banned for that matter, if it obviously leads to a lesser degree of sustainability?
Really interesting set of questions, beyond the fact that the MSC certification can prove traceability and chain of custody for each well in a seiner, assuring that only the FAD-free fish get their certification.
I would also ask deeper in terms of the role of “flag state performance” for some of the assessments where vessels from Flags with poor records of compliance are involved. Even if the rules are quite clear and consistent by the regulators, and the specific vessels involved in the fishery are “clean”… but this issue may need a post on itself in the near future.
* OPAGAC is an Spanish association of purse seine fishing companies operating in the three main oceans (Indian, Atlantic and Pacific)