One of the recommendations provided to the US Presidential Task Force on IUU fishing by the WWF conveyed "Expert Panel on Legal and Traceable Wild Fish Products" (I blogged about it here) included the adoption of my "Landing Authorization Code" concept, which is quite flattering.
The concept originates from work I have done for the DevFISH II programme (a EU funded initiative embedded in the Pacific Islands Fisheries Forum Agency - FFA). And it is based in the simple fact that “Fish does not become IUU during processing, but is either caught or landed illegally”.
The concepts “mixes” two basic elements; the requirements (in one way or another) of Port State Measures Agreement (PSMA) and a Key Data Element needed to follow a landing through the value chain.
Under PSMA, vessels have to seek advance approval to enter a port, sufficient to allow adequate time for the port state to examine the information provided. Hence the information required needs to be provided and assessed to facilitate a decision as to whether or not to deny or grant entry. If an “authorization” is given, either the master or the vessel’s representative can present the authorization to the authorities when the vessel arrives in port.
This “authorization” will need to be “coded” (on some form or another) as to be recorded in one way or another as to be able to review and accounted and potentially crosschecked if it is deemed necessary. So why not simply use this Landing Authorization Code (LAC) as the tool for the initial Key Data Element required for any Catch Documentation Scheme or traceability analysis along the value chain from landing to consumer (or wherever it is needed or most cost effective).
Furthermore, most fishing vessels operators (company own or independent) do maintain a trip or voyage coding systems in order to monitor logistics, fuel consumption, crewing rosters, general costs and more importantly “final payments”(which are in the form of a % of the catch volumes, species composition and values) are to the traced back to that landing, minus the fix costs.
Therefore the concept already exists in the sector, so this “LAC” becomes a better and standardised use of an existing tool. The "Process" associated to the use design and use of the LAC is as follow:
Arrival notification
The “authorization” to land is assessed by the fisheries authorities in the port in a compliance response to a series of requirements that are decided by the authorities of the Port State in relationship to its own legislation and requirements or those of an RFMO, international agreements, etc. The scope of the requirements can be arranged in accordance to a pre determined risk index based on the characteristics of the vessels requiring port access.
As an example: domestic flagged vessels fishing in the Port State EEZ with local VMS and observers may be at the lowest risk tier (i.e green). Foreign vessels with local licenses, foreign charter vessels, domestic vessels fishing in other EZZ or the High Seas, Fish Carriers, vessels with patchy observer coverage, indirect VMS access, etc. are in middle risk tier (yellow). Finally, foreign flagged vessels with no direct VMS access by the coastal or port state, or no observer coverage or vessels identified as a Vessels of Interest (VoI) by any country or RFMO are singled as high risk vessels (red).
As noted, the risk profile of the vessel defines the required time for arrival notification (12, 24, 48 hrs), plus the amount and depth of the information to be provided by the vessel intending to land. In considering the assessment an LAC can be provided and the vessel is allowed to dock with intention to unload. In instances where it is not provided the vessel may be allowed to dock for humanitarian or force majeure reasons but not to land.
The structure and nature of the “LAC” is up to the Port State or RFMO to decide, but it is important that it is inclusive in the information it holds, and in principle is to be an integral part of relational database such as a Fisheries Information Management System (FIMS).
The LAC “design” should include for elements such as: country identification, trip and port traceability, fishing effort measurements, observer reporting, etc. and it should have inter-operability with the vessels operators trip/voyaging coding systems, and if needed with the maritime authorities.
Interestingly, this inter-operability of the vessels operators and authorities LAC can be beneficial to crews and captains in case of payment disputes or safety at sea issues arising from the maritime authorities.
Inspections
The risk profile and compliance level during the previous step defines the need for inspection of the landing and the expected % of yearly inspections decided by the port state, i.e. 25% of landings for green tier vessels, 50% for yellow and 100% for red.
The decision of whether an inspection should take place needs to be based on the risk profile of the vessel (if red) and the % of inspections that have already taken place (yellow, green) or issues arising from the documentation presented.
If an inspection is performed, then the LAC is recorded in the inspection forms in order to provide for future verification if required and for compliance performance monitoring. Ideally the Inspection forms are digitalized on a tablet type device and the data enters the FIM is real time under the specific LAC of that operation.
If the results of the inspection shows inconsistencies or non compliances (and based on the extent of these) the landing may be authorized under bond or denied. Then the LAC associated to that landing is “flagged” into the FIMS in order to interrupt any further movements or transactions associated to that landing until the issues are resolved.
Unloading
If it is decided that an inspection is necessary then the results, if compliant, will provide the permission to unload (or transship). This landing could be conditional, as explained before (under bond). If an inspection does not take place the LAC then becomes the “de facto” authorization for unloading.
In the case of transshipments, the LAC is attached to the catch estimates (from logsheets) or real (if hanging scales are used) and reflect the captains/mates receipt or any the document the volumes being transshipped. The LAC will then accompany the transshipping documentation (printed) and if the receiving country has an MoU with the port state or is part of the same RFMO, then they can potentially log-in on to a common FIMS to cross check the legality and estimated volumes of the landing and to add their own information. If landing or transshipments are partial (and this practice should be discouraged by principle) then the LAC would need to be “partitioned” into lots associated to the original LAC with this retained as the main reference and the lots can be incorporated into FIMS. Any volumes not landed should be considered as a “lot” in the same manner as the landed ones.
Transport
If transport is required for the landing to coolstores or processing facilities then the documentation to be carried will reference the LAC in relation to the real (if fish is weighed prior) or estimated landing taken out of the documentation provided for the vessels arrival, or e-logsheets.
Reception or weight in
At the coosltore or processing facility reception or anywhere where the official sorting and weight in of the fish is done the LAC “marks” the volumes in the FIMS and into the receiving operator’s inventory system.
If the whole fish is loaded into containers for direct export then the weight in is to be recorded under the LAC on the FIMS and the volumes containerized discounted of the total volumes recorded that that landing. That exported lot would still be associated to the LAC as in the case of partial landings or transshipments.
The private operators receiving the fish could either load all the data on a FIMS portal or maintain their own inventory and traceability systems that could either be “absorbed” by FIMS or audited by fisheries authorities. In any case final volumes by species would be incorporated into FIMS for the LAC.
Companies normally use lot systems based on the species, size and vessel of origin. All these parameters can be linked to the LAC under FIMS or their own inventory and traceability management system.
Processing establishments and cool stores
Most responsible MCS systems include Mass Balance evaluation (fish landed = fish in storage + fish processed or sold) on the establishments, by the fisheries authorities.
These evaluations starts with the LAC of all fish received for a period of time and what is presently in the inventory. The officers for example may chose a minimum of 5 different pallets/boxes/bins to do a full traceability exercise and check that each of those pallets/boxes/bins (raw material as well as processed fish) are registered on company documentation and that can be traced to the LAC.
Volumes withdraw from storage for processing are “discounted” from the original landed volumes in relation to the LAC, hence each withdrawal would leave a smaller volume left from the original until the landing is exhausted. Obviously same principle applies to whole fish withdrawals. Processed product volumes will be inventoried under the same LAC taking in to consideration the processing ratios (conversion factors) associated to that type of products.
Final product Sales and Exports - Catch Certificates
Prior to the product leaving the premises Catch Certificates (domestic or market specific) are prepared based on all the operations relating to the original LAC (or LACs in the case of mixed products).
The referencing and traceability to the specific LAC plus the fish volumes accountancy through the value chain becomes the basis and condition “sine qua non” for a catch certificate, either paper or electronic.
the LAC in action
The whole system is based on my view of what is practical from "reality" perspective and the technology tools we have available today. Many countries have already FIMS, or these can be easily adapted from banking software, as the principles are similar (Landing are deposits, and processing/sales are withdrawals).
I have no idea if the concept would be adopted in some way or another by countries or international organisations, but i'm quietly proud of it :-)