"One size does not fit all" - Frank Zappa on MSC P3 for Tuna? / by Francisco Blaha

I have been quite open about my issues with the ecolabelling in the past, as well to the fact that I respect in principle the work that MSC does, I went trough their standards many years ago prior the 1st certification of the Hoki Fishery in NZ. The 3 principles structure is solid, mainly because it tackles a fishery in its entirety (I have absolutely no time for any of the other approaches)

do we get a price plus just for being legal?

do we get a price plus just for being legal?

I still uncomfortable with them for reasons I described before here.

Recently I had the opportunity to go over all tuna MSC certified fisheries in the Pacific with a focus on Principle 3 “Effective management” and in particular the last two performance indicators and scoring issues,  “Compliance and enforcement” and “Monitoring and management performance evaluation”.

And honestly, except the Trimarine Solomon Islands one (5 purseiners and 2 pole&liner vessels fishing in national waters only), I don't get how they were able to score a “pass” on some of these issues.

I have no major issues (nor the knowledge) to question much on Principles 1 (Sustainable fish stocks), and 2 (Minimising environmental impacts). Most of the performance indicators and scoring issues are about work done by SPC for the WCPFC. While dependent on the quality of the data provided the methodologies behind are relatively independent of the different flag states involved in the fishery, since the key decisions do take place at WCPFC.

However, there are voices that question that the fishery "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, as I reported before here.

Back to the part I understand best, some key compliance performance indicators of principle 3, rely totally on the flag state performance and individual vessels compliance history, yet it is the client that has to provide this information. Which in some cases it would be better to hide yet in others he may not have access.

MSC expects that “Where possible the certifiers will seek independent and credible information, and would typically meet with the relevant compliance and enforcement agencies” but then, what they expect the poor performing flag state authorities to say? Other than: "we are great".

In most of the certifications, the unit of assessment – UoA (the set of vessels involved), are flagged to various flag states including DWFN (mostly associated with traders networks). Many of these DWFN have a poor record of performance. Yet in none of those certifications, they seem to be an independent verification of compliance or time spent reviewing records in the fisheries agencies in those lesser performing flag states.

Furthermore, why would the fisheries authorities of these poor performing countries allow a private consultant to dig into their MCS and enforcement data (assuming they have it available).

As an example, one of the scoring issues is “Systematic non-compliance”. I have some level of access to regional compliance databases and vessels compliance indexes, so I searched the names of some of the vessels I know are part of certified fisheries. The results were shocking in some cases. Of course, I cannot divulge this information without breaking my confidentiality agreement, even if I think that all compliance data should public.

In general, the compliance history of these vessels tends to reflect the attitude of conformity of the skippers and owners, particularly when it comes to systematic compliance issues in assessment scores. Furthermore, it shows what is the real compliance capacity of the flag states.

I struggle to understand how come Principle 3 can be evaluated without that info being available for each flag state under the UoA. On the other side, can we expect the client to have access to this data if they are not the Flag State Authority or the vessels owner? Or assuming he is keen to pass that information to his detriment?.

Perhaps is simply the case that the MSC Principle 3 was not designed for multi-state fisheries like tuna, but more for fisheries where flag / coastal / port / processing state are combined (and there are many of those)

Personally, and based on my observations from the fishing ports, I feel that the “motivation” of the vessels involved is more to “whitewash” their names and score a bit more of money that for sustainability issues.

In fact, the certified vessels are doing nothing more of what they should be doing: following the rules. Perhaps if they were to catch less of what they are allocated or giving up vessel days, then I see a sustainability drive, otherwise we are rewarding legality like if it was something special.

Furthermore, from my usual job checking training boarding officer on purseiners, I have noticed free-schools sets in the evenings or prior sunrise. From my experience, the only way to do a free school set at night is with a perfect full moon and even so is very weird.

I suspect that “free schooling” (new verb!) of FAD-associated school is going on (while the observer sleeps?). The support vessels will temporally remove or push away a FAD and then the Purse Seiner drift towards that location at very low engine revs while keeping a sonar eye on the biomass, then the school will naturally move and associate with the Vessel. Once at a safe distance, voila, you have a ‘free school.”

The other issue that bugs me is something I explained before, is what as a friend defined as MSC stands for “Mushy Skipjack in a Can” due to the soft texture of the fish. And this is something I heard now from various processors (in fact I will be codirecting a thesis on this).

Looks like with the influx of "FAD-free" fish, the canneries are encountering a much higher percentage of fish with really “soft texture,” hence the levels of rejections and downgrading has increased.

This “soft texture” may have something to do with a higher level of enzymatic reactions, and the higher body temperature of fish caught while actively feeding in a school during the day, as opposed to fish caught while lazily circling a FAD in the very early mornings.

In any case, this is a truly wicked twist in this saga, since if the level of rejections has increased which means that more fish is sent to the fishmeal factory. As the canners work against volume orders that they need to cover, more fish needs to be caught as to fulfil the contract, so the whole situation it is going against what any sustainability measure should aim for: catching less fish.

Finally, I’m not comfortable with the use of fisheries observer to “guarantee” the “catches and chain of custody” something that is only required in the Tuna Fisheries.

In the Pacific, observers have a lot on their hands already, scientific data, compliance and MarPol, in an already complex set up. So having them involved in a private commercial enterprise does not seems ethical nor fair. While observers are getting a payment plus for the MSC work, these may offer chances were a conflict of interest may arise. Furthermore, the observer is supposed to stay on board for landing or transhipment of MSC catch, which is quite a lot to ask for an observer when he gets to port.

Today for 3rd time in this year, while training officers on vessels clearance to assess the legality of catches and monitoring transhipment volumes, on vessels that had MSC catch. I've seen that no observer was controlling the mixing of certified and non-certified fish

I want to make clear that I’m not trying to fire cheap shots to MSC, I believe that it does work for some fisheries (even I don't share why we need ecolabels), but perhaps wasn't designed for the complexities of multi-states fisheries like tuna. And this should not surprise anyone after all Frank Zappa said it many years ago: "One size does not fit all.”