Eyes on the MSC Review – Big Blue Future or Big Blue Failure?

The Marine Stewardship Council (MSC) is reviewing its seafood certification standard and Make Stewardship Count is watching both the process and results closely. Is the process open, inclusive and clear to everyone? Will the Fisheries Standard Review (FSR) make the critical changes needed to ensure all certified fisheries are applying global best practices?

Transparency of Engagement and Decision Making
Request for Transparency
Critical changes needed to improve the MSC Standard
Critical Changes

Transparency of Engagement and Decision Making

2020-08-25T14:13:00+00:00July 23rd, 2020|

Transparency of Stakeholder Engagement & Decision Making in the Marine Stewardship Council

It’s crucial that MSC adopts best practices for transparent consultation during this review. Stakeholders must understand who is invited to engage and why, how best to engage, how input is used, and how and why decisions are made at each step of the way. We are rating MSC against our best practice recommendations that draw from the leading literature on consultation as well as our members’ many years of experience engaging with the MSC programme.

This rating covers the 2019 research phase of the FSR, leading up to the Board’s public announcement of the Review in February 2020. This period included some information gathering workshops and meetings with stakeholders

Meets Expectations Improving Below Expectations NOTE: Click on each “finger icon” for more information.
  • Outline each process as early as possible with clear timelines and show how related processes are linked
    • A basic, high level timeline was released, but with little detail or clarity on how individual elements are related or feed into decision making.
    • The timeline has changed before and since the announcement of Terms of Reference, with the release of new Standard and adoption date now pushed back, adding to the lack of clarity.
  • Demonstrate a strategy of stakeholder selection
    • Little public rationale for who was selected to participate in 2019 information gathering workshops.
  • Give stakeholders multiple entry points for engagement
    • Stakeholder numbers were limited and workshops were only face-to-face in London requiring travel, despite requests for virtual meetings, unclear other input options open to clients, stakeholders
  • Allow all stakeholders to assist with designing the process
    • Stakeholders were initially asked to rank preferred topics for information gathering workshops, but few were then run.
    • Limited involvement of stakeholders in selection of questions or proposals for the workshop agendas.
    • Requests to broaden discussion topics were disregarded e.g. bycatch reduction in the ETP species workshop.
  • Be clear about the goals of the process from the start
    • Lack of clarity on how broad the FSR would be, which topics could be revised, and why particular topics were chosen for specialist information gathering workshops for the research phase.
    • Original plans for more information gathering workshops changed.
    • Some confusion between the goals of FSR and Fisheries Certification Process Review due to overlapping topics, such as shark finning.
  • Demonstrate the current stage of the process of consultation, and the decision that led to it
    • Early in the research phase there was no clarity on when workshops would happen, what they would cover, and why.
    • Clarity improved for workshop attendees once they had been identified – better information on what input was used to inform workshop development and goals.
  • Allow full access to all the information provided during the process
    • Reports and inputs were available to participants of workshops only.
    • Consultation documents, research and workshop reports are not all publicly available.
  • Allow stakeholders to share information and address gaps by being open about who will be, or was, involved in the process
    • Participant lists were only available to those in the workshops, and in the final report.
    • Some workshop reports to date are shared only months later with participants, thereby not allowing meaningful follow up.
  • Share the decision-making framework and rationale for each step of the process:
    • Who is involved in decision-making, at which level, and who leads the process?
    • What criteria are used to make decisions and how are they ranked?
    • What decision rules are used to finalize the decision?

    • Decision-making process was opaque and seemed to change frequently, particularly in the first half of 2019 when workshop plans were being made.
    • No criteria has been released to indicate which topics have moved forward, which will be revised.
  • Regularly review the stakeholder engagement process
    • No publicly available review of the previous review processes and improvements, or of the research phase of the current FSR.

Critical changes needed to improve the MSC Standard

2020-08-26T16:29:17+00:00July 23rd, 2020|

Critical requirements necessary to improve marine stewardship council principle 2

The MSC Standard should reflect global best practices in fisheries management and drive positive change on the water. We are watching to see how the current Fisheries Standard Review (FSR) addresses the critical flaws the Make Stewardship Count coalition of experts has identified in the current standard. To reduce the ecological impacts of certified fisheries, the revised Standard must:

This rating covers the 2019 phase of the FSR, leading up to the Board’s public announcement of the official topics included in the Review in March 2020. We will update ratings as proposed changes to the Standard are released throughout the Review process.

Meets Expectations Improving Below Expectations NOTE: Click on each “finger icon” for more information.
  • Cumulative impact assessment required for all species caught by ALL fisheries (MSC and non MSC) in the same area
    • Not included in the FSR Terms of reference.
    • Potential for this to be addressed under Review topic: Ensuring the ecosystem performance indicators are clear and consistently applied.
  • Application of precautionary principle and best science is used to 1) designate a species as ‘ETP’ and 2) assess fishery impacts on those species
    • Discussions so far suggest that only the IUCN red list will be used for designation thereby ignoring international multilateral environmental agreements (MEAs).
  • ETP species should be inclusive of, but not limited to, all IUCN Red List ‘threatened’ categories
    • Lack of clarity as to how assessment of impacts on ETP species will be addressed.
  • Prerequisite for certification: bycatch must not exceed a risk based maximum percentage of catch
    • Not included in the FSR Terms of Reference.
  • Progressive reduction of bycatch during certification
    • Conditions that define risk based annual bycatch reduction rates
    • Verification of achieved bycatch reduction during surveillance audits

    • Not included in the FSR Terms of Reference.
    • Potential for this to be addressed under Review topic: Clarifying best practice for reducing impacts on ETP species.
  • Prerequisite for certification: no fishing methods that include the intentional encirclement of marine mammals or ETP species
    • Not included in the FSR Terms of Reference
    • Potential for this to be addressed under Review topic: Clarifying best practice for reducing impacts on ETP species.
  • Prerequisite for certification: All fisheries interacting with sharks (elasmobranchs) must have a ‘fins naturally attached’ (FNA) policy implemented and enforced
    • Finning is part of the FSR but based on discussions during the 2019 FCP revision, MSC appears not to consider FNA as global best practice that should be implemented at entry level.
  • All fishing practices used by the fishery must be assessed during certification
    • Upon recertification all remaining fishing techniques have improved to the Standard

    • The revised FCP (2019) ensured that certified fisheries will no longer be able to target a stock using both certified and non-certified fishing practices with the same gear (known as compartmentalisation).
  • All ‘main’ species of the catch must meet the same criteria as target species (P1) even if discarded
    • Harvest control rules for Principle 1 are under review during the FSR, but it is not clear whether this will be extended to other main species.
  • Overfishing (F>Fmsy) is prohibited for all ‘main’ species of the catch
    • Not included in the FSR Terms of Reference for target or other main species.
  • Prerequisite to Certification: No bottom fisheries in known or likely VME areas
    • May be addressed under Review topic: Ensure habitat PIs are clear and consistently applied.
  • Benthic impacts must be reversible in less than 10 years
    • Prerequisite to certification: 50% of benthic habitat type in a region closed to all fishing

    • Review topic on habitat performance indicators continues to use the definition for ‘irreversible damage’ as ‘recover in 20 years or more.’
    • Review topic on habitat performance indicators does not indicate protection or closure thresholds are being considered.
  • Prerequisite for certification: risk based qualitative and quantitative data requirements exist for bycatch reporting
    • Consistent data requirement for comparable fisheries

    • Adequacy of data (quality and quantity) for scoring announced as part of FSR.
  • Upon request stakeholders must have access to all data used for scoring of fishery by CABs (including, inter alia, AIS, VMS, EM, observer raw data)
    • Not part of the FSR Terms of Reference but possibly to be covered under data adequacy.
  • Peer review should be included in any annual audit where conditions are closed
    • Possibility for stakeholder objection to surveillance audit outcomes

    • Conditions were addressed in the 2019 FCP (Fisheries Certification Process) Review.
    • Peer review is now required, but stakeholder objection is still not possible.
  • No recertification prior to verified fulfilment of all conditions
    • Condition extension was tightened in the 2019 FCP review, however extension of conditions is still allowed in some circumstances.

Make Stewardship Count, other stakeholders, and researchers continue to raise concerns about CAB impartiality and MSC accountability as the Standard holder. Neither of the following topics has been taken up in the Fisheries Standard Review and MSC has ignored these concerns.

  • Ensure impartiality of the assessment, certification and audit processes, CABs must be independently assigned
    • Not addressed during FCP or announced for FSR.
  • MSC must be proactive and intervene in case of urgent and obvious problems
    • No evidence of improvement apparent so far.