SeaChoice responds to MSC’s response to “What’s Behind the Label”

September 15, 2017

SeaChoice’s What’s Behind the Label Report” offers an overview of the Canadian Marine Stewardship (MSC) certification landscape and acknowledges the overall program contribution of the MSC to important sustainability progress in Canada. However, our findings raise key concerns, which are not ‘misleading’ as MSC’s response to our report suggests, but rather are specific to the conditions, progress, and auditing related to MSC’s Principle 2: Environmental and Ecosystem Impacts – a critical component of the Standard. SeaChoice is very careful to specify in the report that our focal analysis was on the 73 conditions of certification given under Principle 2 and we present it as such. Our finding shows that to date 15 per cent of Principle 2 conditions resulted in tangible changes to fishing practices on the water.

MSC’s rebuttal does not address this finding. Additionally, their response omits deliberate language we included in our press release which specifies our focus on impacts captured under Principle 2 “critical fishing impacts, such as harm to ocean habitats and threatened species. Only 15 per cent of certification requirements to improve such collateral impacts have led to tangible change in fishing practices.” Instead MSC notes a percentage from their files that includes Principle 1, 2, and 3 conditions and seems to also include information from the pre-certification assessment process, which is not publicly available and hence not included in our analysis. Each condition analysed under Principle 2, details of our methodology, and how we categorized actions that led to changes to fishing practices are available in our technical report. We appreciated MSC’s review of our report when it was in draft as well as their broad assessment as to their program impacts. In our September 11th letter to MSC we note why our concerns that stem from our Principle 2 focused analysis stand.

Our findings also showed 8 out of the 10 re-certified fisheries in Canada continue to carry conditions, which result in these fisheries receiving 7-9 years cumulatively over their first and second certifications to meet the 80 score of MSC’s ‘global best practice. MSC’s response indicates a small percentage of conditions are in question. While some flexibility is understood for ‘exceptional circumstances’, our analysis shows the actual number is beyond that specific MSC rule that allows extensions and also includes what are called ‘related’ conditions and auditor justified ‘new’ conditions with slight wording changes. While the fisheries may have closed the majority of their other conditions, the remaining conditions result in 80% of re-certifications having extension or long timelines. It is worth noting that 60% of the re-certification conditions in question are Principle 2 conditions.

SeaChoice is aware that all of these cases are allowed under the MSC guidance rules for certification and that our concerns may be considered subjective. The issue may lie beyond the scope of this particular report – not with the application of the MSC Standard, but with the requirements of the Standard itself and whether the MSC is asking for enough from our Canadian fisheries.

Why is MSC Principle 2 important to SeaChoice?

The MSC Principle 2 definition: “fishing operations should allow for the maintenance of the structure, productivity, function and diversity of the ecosystem (including habitat and associated dependent and ecologically-related species) on which the fishery depends.”

SeaChoice has a strong focus on reducing ‘incidental’ impacts of fishing – these are the impacts scored by MSC under their Principle 2 requirements – such as catch and mortality of bycatch, particularly for species considered threatened or endangered in Canada; lack of management and monitoring of non-target species; bottom habitat destruction; and trophic level ecosystem impacts.

While, most fisheries that enter into certification in Canada are adhering to the basic best practices for target stock management and there is little IUU fishing for the certification to catch, many ‘Principle 2’ impacts remain unaddressed by Canadian policy and fisheries management. The Canadian government itself has noted this is lagging in their own audit and this has been upheld by independent academic review. In the Canadian context, many of our MSC certified fisheries continue to be those with the greatest relative ecosystem impact (e.g. highest bycatch rates in Canada, highest bottom disturbance).

Since many Canadian fisheries continue to raise these significant concerns, despite carrying the MSC certification, it is important to understand if MSC Principle 2 certification conditions can leverage change fishing practices in a tangible way even post-certification. This is especially relevant in Canada now that most fisheries already hold MSC certification and are past the ‘pre-assessment’ phase changes.

We are aware that not all conditions of certification are designed to change fishing practice in a tangible way and note clearly in our report that Principle 2 conditions are sometimes given on a precautionary basis due to high risk or impact and that some are in fact in place to obtain more information.

However, given the work still needed on incidental impacts of fishing in Canada, our finding that only 15% of Principle 2 conditions led fishing practice change as well as our findings on flexibility of timelines for condition completion we must consider if the level required by the MSC standard is sufficient. This is also important for stakeholders weighing the costs and benefits of the time it take for full engagement in the MSC assessment and audit processes.

If, as stated by MSC, fisheries make the most changes while aiming for certification, we raise the concern that incidents of extensions and roll over of conditions, while all justified under the Guidance, may indicate that MSC is missing a crucial time to ensure changes actually happen – before these fisheries are certified. This is especially true, again, for Principle 2 issues that are harder to shift. Our concern about possible pre-mature certification stands.

SeaChoice have been stakeholders in 74% of MSC assessments and our member organizations have extensive histories of engagement at the management advisory committees for the same fisheries and other policy fora. Our interest is to understand the role eco-certifications play in system, especially as landscape shifts over time.

As noted in the MSC response to our report, “The role of stakeholders in the MSC program is key to ensuring the program operates efficiently and can achieve the stated goals.” We urge MSC to take to seriously the frustrations and concerns expressed not only by SeaChoice, but other stakeholders in Canada as well as around the world, in regards to the application of and bar set by the MSC Standard. If we are collectively to move the paradigm of fisheries management towards the internationally recommended systems of ecosystem based management, it is imperative that this is also incentivized by eco-certifications.

Further information:

What’s behind the label? (page on SeaChoice website, with links to download summary and technical reports)

SeaChoice cover letter to MSC

MSC response to “What’s behind the label”