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:
January 2022
This rating covers the 2021 public consultation phase on the FSR, which included invite-only workshops and several rounds of public surveys on individual review topics including; Identifying further solutions to ensure MSC certified fisheries are not involved in shark finning, Supporting the prevention of gear loss and ghost fishing, Clarifying best practice for reducing impacts on endangered, threatened and protected species, Reviewing Principle 1 with a focus on harvest strategies, Timelines for transitioning to a new Standard, Ensuring effective fisheries management systems are in place, Fisheries Certification Process Review.
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
- Proposed changes to ETP cumulative impacts scoring still does not include consideration of the impact of non-MSC fisheries on the species of concern.
- ETP scoring proposed changes mean combined effects of MSC fisheries would always be assessed, which is an improvement on status quo, however, problematically this would only be done at ‘best practice’ or above (80 or 100) and not at the certification entry level of 60.
- Application of precautionary principle and best science is used to 1) designate a species as ‘ETP’ and 2) assess fishery impacts on those species
- How species are designated ETP in the Standard is a focus topic.
- The proposal in June 2021 does not adequately address the impact of fisheries on ETP species and designation remains confusing and dependent on national legislation which varies.
- Proposed changes create a more comprehensive framework for how a species can be designated ETP for MSC scoring, however, species could still be excluded from the ETP designation if there is a national level recovery management plan. The currently proposed criteria to assess the quality of such plans is still vague and open to interpretation, similar to the current Standard.
- ETP species should be inclusive of, but not limited to, all IUCN Red List ‘threatened’ categories
- The proposal provided in June 2021, with an accompanying online survey, immediately classifies out of scope species (amphibians, reptiles, birds and mammals) as ETP. However, for in-scope species, including sharks and rays, there were options that would not include all threatened IUCN Red List threatened categories.
- The best option proposed still excludes the IUCN category of ‘Vulnerable’.
- Prerequisite for certification: bycatch must not exceed a risk based maximum percentage of catch
- Not included in the FSR terms of reference or in related workshops and consultations
- Progressive reduction of bycatch during certification
• Conditions that define risk based annual bycatch reduction rates
• Verification of achieved bycatch reduction during surveillance audits- Risk-based assessment options were included in the proposal, however, the details of how this approach would be applied remain unclear and it is not clear if this will make it into the draft standard.
- Progressive reduction of bycatch has not been mentioned in any part of the process thus far. The ambiguous term ‘minimize impact’ continues to be proposed for ETP bycatch.
- Prerequisite for certification: no fishing methods that include the intentional encirclement of marine mammals or ETP species
- This continues to be a concern which the MSC is not addressing.
- Prerequisite for certification: All fisheries interacting with sharks (elasmobranchs) must have a ‘fins naturally attached’ (FNA) policy implemented and enforced
- The proposed change is presented as addressing the stated goal to ‘improve confidence and transparency that shark finning is not occurring in MSC fisheries’ and ‘ensure requirements deliver confidence in a zero-tolerance approach.’ However, it ultimately retains the status quo by allowing fisheries that target sharks to seek exemptions from a simple, clear Fins Naturally Attached rule. MSC continues down this path, despite a clear outcome from the public consultation that this proposal is not best practice, will not resolve finning, and is not accepted by the majority of stakeholders.
- 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 Fisheries Certification Process (FCP) in 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).
- In hindsight, we recognise that this category should have received a green listing in our last round of scorecards, as it has met one of our critical requirements. However, given there are still critical improvements needed to the Fisheries Standard, ending compartmentalization has yet to result in significant differences on the water for certified fisheries.
- All ‘main’ species of the catch must meet the same criteria as target species (P1) even if discarded
- Not included in the FSR Terms of Reference for target or other main species.
- Harvest control rules for Principle 1 are under review during the FSR, a proposal was provided in 2021 with a consultation survey.
- The proposal did not bring forward changes here and only mentioned a ‘phased condition pathway’ to meet conditions to adopt harvest strategies and HCRs.
- 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.
- Harvest control rules for Principle 1 are under review during the FSR, but the consultation document did not mention this point.
- Prerequisite to Certification: No bottom fisheries in known or likely VME areas
- Was not addressed in this phase of the FSR and consultations
- 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- Proposals and consultations in 2021 did not address these issues – the current definition for ‘irreversible damage’ as ‘recover in 20 years or more’ remains and protection or closure thresholds are not being considered.
- Prerequisite for certification: risk based qualitative and quantitative data requirements exist for bycatch reporting
• Consistent data requirement for comparable fisheries- Quality, type, and verification of data has been a focal topic in the Review with workshops and consultations
- Risk based assessment options were proposed in the spring 2021 consultations during invitation-only workshops. However, the summary report provided no clarity on how this risk assessment will be done, and it is unclear if MSC will pursue such additions to the standard.
- The as yet undefined outcomes of this Review topic are linked in consultation documents to a number of other Review topics. Without clear proposals on this key topic tabled yet, it is difficult to fully assess the potential changes in the other areas under Review.
- 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)
- No further discussion on this topic since the Phase 1 workshops in 2020 and it may be part of the data adequacy topic, but it remains unclear if this will be addressed in the draft standard.
- 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 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.
