Can Fish Eco-Labeling be Trusted? An MSC Label Can!! Right?

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I love sashimi. I do! The fresher the fish (and the drier the sake) the better. But for me, on the occasions that I do eat tuna sashimi I want to know that the tuna is from a sustainable source. I want to feel at ease with my purchase. I want to enjoy my maguro guilt free. And I have to say for the most part I am confident that when I eat a product that is certified sustainable by a recognised eco-label (like MSC), it is exactly what it says it is.

In my mind the MSC standard is robust, difficult to meet and its very existence is having a beneficial effect on both fish stocks and the environmental effects of fishing those stocks.

It should be this easy shouldn’t it?

The Scientist

I was reading an article in the Scientist which just made me fume. The article (for last year); Can Fish Eco-Labeling be Trusted, made the ‘we’ve heard it so often’ claim that these “programs that provide sustainable certification for fisheries may be too generous with their accreditation.”

One could respond glibly:

Some might! Some of the smaller certification companies, who in an effort to gain market penetration, might let there standards slip here and there… But the main ones including MSC and to a lesser extent FOS (Friends of the Sea)… They’re certainly not generous with their ‘accreditation’.

Unfortunately others do not see it this way…

This article in the Scientist canvasses an analysis (Evaluation and legal assessment of certified food) by fisheries Biologists Rainer Froese and Alexander Proelß, published in Marine Policy that essentially a criticises the two major fisheries certification programs:

  • The Marine Stewardship Council (MSC) and the 
  • Friend of the Sea (FOS), for certifying stocks of fish that may not be sustainable.

The two fisheries biologist authors “assessed” 71 MSC-certified stocks 76 FOS-certified stocks of mackerel, swordfish, tuna, and other species to ascertain whether these products that are certified sustainable actually came from sustainable stocks. Surprise! Surprise! Both  authors arrived at the eventual conclusion that 31% of the MSC stocks and 19% of FOS stocks were “not worthy of the label“. 

What utter drivvle!

In a statement to Nature magazine, Froese provided an indication of the their intent (ooops) I mean scientific rigour:

We’re putting [the certification programs] under a lot of pressure and we hope that will work. I want to improve them, not to kill them.”

The same story in Nature quoted Canadian marine biologist Jennifer Jacquet who inadverently and unintentionally in my opinion provided a hint as to the length detractors of the certification schemes will go to attempt to undermine the public perception of what constitutes “certified sustainable”.

[The analysis by Froese and Proelß] represents not only growing concern among scientists about the effectiveness of seafood eco-labeling in general and the MSC label specifically, but an increasing willingness for scientists to take on rigorous research in response to that skepticism—research that the MSC should probably be doing itself […] The results were pretty depressing, even for someone who was already dubious of the MSC.

MSC Banner

My concerns with the robusticity of the Froese and Proelß Fishstock sustainability assessments

I have a number of concerns with respect to Froese and Proelß’s 148 sustainability assessments. I am not convinced about the rigour used, nor do I have any confidence in the interpretations and definitions used.

  • Data: Time and time again I have seen fisheries biologists, manipulate data to arrive at conclusions that suit their positions (objectively done of course).  For example an estimate for stock abundance might be taken from a series of data runs. All of the runs that show anomolies (usually ones that show higher abundance indices in relation to other runs) are excluded or marginalised. What is left (the more conservative sets of data – an estimate as well) is then tabled. This estimate replete with confidence levels, and often as is the case under the guise of the ‘precautionary principle’, (don’t get me started about scientists applying this principle to their work – when I am of the mind that robust science should be the basis by which  the precautionary principle is subsequently applied) the lower bound is provided with more weight. The result… Quelle Surpise! A fishery with an abundance index that appears to be overfished or very close to it.
  • Definitions: Scientists are often apt to move the definitional or interpretational goal posts to better align with commercial opportunities (Oh yes… Science is a business too) or results. One example of this can be seen in the definition of a ‘seamount’. In recent years a number of marine ecologists have introduced (and almost succeeded) through international publication an extended definition of a Seamount [which is a geologic entity which from its base has an elevation of over 1,000m] to include all underwater hills over 100m [unbelievable]. Such a definition is great for marine ecologists who due to the meaning of what constitutes a seamount, suddenly have a few million more alleged ‘enclaves of endemism’ to research. But the rub here is what such a definitional change would mean to Governments, who would find themselves subject to the same rules for a mud hill that is little more than 100m in elevation as they are for large undersea mountains. Craziness!. Consequently I have no confidence in Froese and Proelss’s application of ‘overfished’, nor do I have any confidence in what they therefore define as ‘sustainable’.
  • Context: Scientists rarely use context in their fisheries science conclusions. This is why scientists don’t manage fisheries, and why managers do. Context means everything. For example, one study might conclude that a estimate of the abundance of the fish stock is now only X% of the historic unfished biomass, and is just as likely to be at or below the limit where the fishery provides a maximum sustainable yield. Therefore it is overfished. However in actual fact there are three different kinds of overfishing and each has a very different outlook, and requires a completely different management approach.

There are three main types of overfishing:

  • Ecosystem overfishing -This is the overfishing that everybody has in there mind when they read that a stock is over fished. And this is only one type of overfishing – and arguably it is the least common form of over fishing. Ecosystem overfishing occurs when the balance of the ecosystem is altered by overfishing, and where it is alleged that the ecosystems ability to produce those fish is impeded as a result of fishing. Furthermore declines in the abundance of the target species (often large predatory species), result in trophic cascades of  small foraging type species (that may or may not be commercially viable).
  • Growth overfishing – This kind of overfishing occurs when fish are harvested at an average size that is smaller than the size that would produce the maximum yield per recruit. This makes the total yield less than it would be if the fish were allowed to grow to an appropriate size. It can be countered by reducing fishing mortality to lower levels to allow the average size of harvestable fish to grow to a size that will allow maximum yield per fish.
  • Recruitment overfishing – This kind of overfishing is common, and it comes about because fishstock sizes naturally fluctuate. Recruitment overfishing is manageable with the imposition of catch limits such was the case with New Zealand hoki in 2007). Recruitment overfishing occurs when the mature adult (spawning) population declines due to a lack of new fish entering (recruiting into) the fishery. Consequently, the a lack of new fish (mature adults) affects the reproductive capacity of the stock to replenish itself. Increasing the spawning stock biomass to a target level is the approach taken by managers to restore a recruitment overfished population to sustainable levels. This is what happened in the case of New Zealand hoki., where understanding the context of the overfishing problem, resulted in the complete rebuild of the ‘overfished stock’ to a management range that was significantly above the MSY within 4 years.

You know what?… I think I am going to do a blog post on the New Zealand hoki story as I see it (Management actions, Media punctuations, eNGO iterations, MSC objections and all). Please watch this space.

Attacks on the efficacy of ‘certified sustainable’ labelling and responses to those attacks by FOS and MSC

This is not the first time someone has raised concerns about the legitimacy of the sustainable labels on seafood. Undermining the efficacy of the ability of a certification scheme to denote a fishery as sustainable has now become a sustained campaign with some big name suppoters like Daniel Pauly.

MSC is coping a lot. As would be expected since they are the tall poppy. The market leader. Almost daily somewhere in the media, some eNGO or conservation scientist/advocate is arguing the that industry is buying ‘sustainble’ certificates, or that determinations are wrong (and that that particular eNGO or Scientist happens to have information that demonstrates that the fishery is in dire straits). Unfortunately this anti-sustainable rhetoric is a common aspect of the international fisheries market; but fortunately customers are tuned to it.

FOS responded to the Froese and Proelß article by saying that the discrepancy was mostly due to the fact that their organization relied on 5-year old data, rather than the newer analyses Froese’s group had done.

MSC, on the other hand disputed the investigators’ methodology completely. David Agnew  (Standards Director at MSC, and previous Fisheries Director at the marine and fisheries consultancy MRAG Ltd ) along with others including Amanda SternPirlot and Keith Sainsbury published a response in Marine Policy (March 2013. 38, pg. 551-553) Rebuttal to Froese and Proelss “Evaluation and legal assessment of certified seafood”. The paper asserts that:

Their [Froese and Proelß’s] results are derived using a definition of ‘overfished’ that is not consistent with internationally accepted definitions and interpretations. In addition, the authors used unrealistic estimates of biomass that produce Maximum Sustainable Yields (BMSY) obtained through methods that are inconsistent with the approach used by the management agencies and scientific advisory bodies responsible for the stocks in question.

Furthermore the article noted that it “seeks to correct” a number of “serious flaws in their analysis, data and resulting conclusions.” Agnew et al. instil confidence in the objectivity and robusticity of the MSC process:

Using data for 45 stocks exploited by MSC certified fisheries (>60% of total fisheries in the programme and >80% of total certified catch), internationally accepted methods for determining MSY reference points, and internationally accepted definitions of the terms ‘overfished’ and ‘overfishing’, no stocks exploited by MSC certified fisheries can be defined as overfished (below their limit reference points).

Current (i.e., most recent year with available information) biomass (B) and exploitation rate (u, similar to fishing mortality F) for individual stocks targeted by MSC-certified fisheries (n=45). Data are scaled relative to BMSY and uMSY (the biomass and exploitation rates that produce maximum sustainable yield). Vertical and horizontal solid lines represent reference points common to all fisheries (B/BMSY=1 and u/uMSY=1). Empty circles indicate stocks being targeted by fisheries which have had their MSC-certificate suspended. Biomass for all stocks lower than BMSY is still higher than determined limit reference points (Blim, the limit reference point below which recruitment is impaired, and not shown on graph, varies between fisheries as a fraction of BMSY; the proxy 0.5 BMSY is often used as a default value in the absence of empirical estimation of Blim).

Current (i.e., most recent year with available information) biomass (B) and exploitation rate (u, similar to fishing mortality F) for individual stocks targeted by MSC-certified fisheries (n=45). Data are scaled relative to BMSY and uMSY (the biomass and exploitation rates that produce maximum sustainable yield). Vertical and horizontal solid lines represent reference points common to all fisheries (B/BMSY=1 and u/uMSY=1). Empty circles indicate stocks being targeted by fisheries which have had their MSC-certificate suspended. Biomass for all stocks lower than BMSY is still higher than determined limit reference points (Blim, the limit reference point below which recruitment is impaired, and not shown on graph, varies between fisheries as a fraction of BMSY; the proxy 0.5 BMSY is often used as a default value in the absence of empirical estimation of Blim).

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