NPOA-IUU and their roles

I have been dealing with National Plans of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (NPOA-IUU) for a while now… 

let me see that plan

I started in 2003 and 2004 when I participated while I was still working with industry in the consultations for New Zealand’s NPOA-IUU, one of the first ones prepared worldwide. During 2009/10, when serving as a Fishery Officer at FAO in Rome, among other tasks, he was involved in the evaluation of the operational impacts of the deposited IUU-NPOAs. During 2012-14 as part of his work for FFA’s Devfish II, I got involved in the development of various NPOA-IUU in the region as I worked across all aspects of fisheries MCS and regulatory compliance delivery, strengthening the operational aspects in EU yellow-carded countries, including capacity building in intelligence analysis, and the development of SOPs to assist with boardings, inspections and investigations. 

And even after all this, I still wonder what their real role in the operational side is… 

Let go through their “reason of being”… 

National Plans of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing (NPOA-IUU) are developed following the International Plan of Action to prevent, deter and eliminate IUU fishing (IPOA-IUU) adopted in 2001 by the Committee on Fisheries of the Food and Agriculture Organisation of the United Nations (FAO). 

The IPOA-IUU is a voluntary instrument and is one of four IPOAs (Seabirds, Sharks, Fishing Capacity and IUU) that fit within the framework of the FAO Code of Conduct for Responsible Fisheries, also adopted by COFI in 1995, and it describes the broadly accepted principles and measures to prevent and counter IUU fishing at the level of states, regional economic integration organisations and regional fisheries management organisations (RFMOs).

In light of the already existing measures to combat IUU fishing (i.e. policy, laws, institutional setup, working processes and law enforcement framework), and on the basis of principles and measures articulated in the IPOA-IUU, the objective of all NPOA-IUU is to formulate pertinent and achievable, additional measures, necessary to close gaps in the existing framework addressing IUU fishing, and to reduce in a planned and concerted manner the incidence of marine IUU fishing in a county to a minimum.

Which is all good… yet in all these years I’ve seen them gathering dust and not really being used by the frontline people… so they always fill to me as one of those things that you need to have because is expected that if you have one you a mature fishing nation… but the reality is that most of the ones I’ve seen are way too “wordy” and overcommit.

My experience is that no one really reads a report that is more than 30 pages or has the capacity to implement more than 15 recommendations in the short term.

And from my industry days, I’m very aware that: “there is only one thing worst than not having a piece of paper and is having one that you don't comply with”… so if you go overboard because is what is expected to be done… you are putting yourself to fail

NPOA-IUU have a long history in the Pacific, yet their presence has not always been noticeable. In 2005 the late Colin Brown (a good man gone to early) authored the FAO document “Model plan for a Pacific Island country - National Plan of Action to Prevent, Deter and Eliminate Illegal, Unreported and Unregulated Fishing”. 

This “Model Plan” for the elaboration of an NPOA-IUU was designed to assist Pacific Island States to give effect to the IPOA-IUU. The model incorporated the essential aspects and features of the IPOA-IUU, demonstrating how an NPOA-IUU might be drafted.

In seeking to address IUU fishing the model provides an introduction (with an important focus on the fisheries situation in the model country) followed by measures that might be adopted under the headings of all State responsibilities at the time (Flag, Coastal and State) as well as internationally agreed market-related measures, research, regional fisheries management organizations and the special requirements of developing countries. Many FFA members date their NPOA-IUU back to that document.

Then in between 2012 to 2014 and as a consequence of the EU Yellow Cards, FFA’s DevFISH II programme supported the update and redevelopment of many of these early NPOA-IUU, as to be able to facilitate FFA members to respond when questioned by the EU. 

Yet, while the earlier versions lacked depth in coverage of key MCS issues and capacities we have today, the newer versions are voluminous (i.e. 60 pages 38 action points for example), user-unfriendly and very complex, which turned off the target user groups from using it regularly. As a consequence, the documents stayed unused by officers in the compliance section, whom in principle should be using it as a working reference document.

These problems were exemplified in the words of a good friend and fisheries officer, saying that their NPOA-IUU seems to have been designed “more to be read by other countries, than to be used by us”.  

So as part of my work with MIMRA in RMI, I have re-structured their “old” NPOA-IUU, as to produce a more user-friendly document adapted to the needs and capacities of the operational users while incorporating the most updated information on the prevalence and extent of IUU in the region and our high level of collaboration with FFA, plus our cooperation with SPC, PNA, WCPFC market states and industry organisations.

So our new one has 30 pages and 15 action points while maintaining full compliance with the internationally accepted minimal components and format of FAO’s IPOA-IUU.

I personally live up to maxim that “the perfect should not get on the way of the good” and is better to start with 15 that you know you can achieve and not 38 that you can’t… once we get this 15 done, let’s bring the next 15. 

That more modest approach helped us with PSM… so let me tell you in a couple of years how with did with this one!!!

Another Vanuatu flagged longliner on a US Customs detention order for forced labor

Not long ago a I wrote about the US Custom and Border Protection Agency (CBP) withhold release order against tuna and tuna products from the Tunago No. 61 based on information obtained by CBP indicating tuna is harvested with the use of forced labour, including physical violence, debt bondage, withholding of wages, and abusive living and working conditions.

From the 18 august a 2nd Vanuatu flagged vessel, the “Da Wang” has now also been added… so far Vanuatu is the only flag state that is in that list. 

Thankfully none of the vessels is in the FFA list of good standing, yet they still in the WCPFO registry

While the vessels are Taiwan owned and operated, the factual reality is that what happens on those vessels competes to the flag state authority… the capacities of Vanuatu or their development status, are no excuse when it comes to flag state responsibility.

As I was told in the navy and the fishing boats many times… if you cannot live up to a responsibility don’t take it...

Vanuatu had already one of the 1st EU yellow cards, which was based substantially on the failures as a flag state (see the decision- last country).

One thing to keep clear is that Vanuatu is not a small player in fishing… it runs an open registry (with over an estimated -no one really knows exactly- of 100 vessels among fishing vessels and carriers). Furthermore, they are a contracting Member of IATTC, WCPFC, IOTC, ICCAT and cooperating non-Contracting Party to CCAMLR… hence their fleets is all over the world. Yet the last commercial landing in Port Vila was in 2014 and maybe a couple of pretending ones since then… but the vessels don come there… many of them use Suva as their port.

I helped with the removal of the Yellow card… yet I’m not sure how come they got away, to be honest… I remember they had a very smooth ambassador to the EU that obviously was doing a good job there… they got lots of money to develop their competent authority to gain EU market access… yet they never did much with that. They got to host an EU workshop on the impact t of ecolabels… even if they don't qualify to access to the EU. they signed PSMA, but haven done anything about it… and “hosted” a workshop wjhere nobody came after the 2nd day… and the list goes on

In any case, the EU was supposed to go back to visit them, on the back of the reissue of the yellow card they reissued to Panama… a country that shares many flag state (i)responsibilities issues with them.

While this issue relates to crew… something I feel very strongly about and I’m working on… I find it sadly ironic because Vanuatu very stringent on immigration when you arrive by plane and come to work for a couple of weeks at the request of their own goiverment and they charge over 300USD for a visa and ask you for a lot of papers…. Somehow you can go and work on a Vanuatu flag fishing boat without any paperwork or being accounted (or unaccounted) for…

As a member of FFA, they should be incorporating labour issues as part of their licensing procedures as explained here

In any case… they are also a key player in the of the biggest fisheries headaches we have in the region… transhipments at sea.

While the WCPF Convention expressly prohibits transhipment at sea (on the high seas and in a WCPFC Member’s territorial sea and exclusive economic zone) by purse seine. For longliners and other vessels, however, the WCPF Convention only requires CCMs to “encourage their vessels, to the extent practicable, to conduct transhipment in port”. Furthermore, through a binding conservation and management measure (CMM 2009-06 the WCPFC prohibits longliners and other vessels from transhipping on the high seas except where CCM has determined that “it is impracticable for certain vessels . . . to operate without being able to tranship on the high seas.” 

CMM 2009–06 requires WCPFC Members to make vessel-specific determinations as to impracticability and submit a plan detailing the steps being taken to encourage transhipment in port.  And that is not happening…. In fact, over the last two years, just 3 CCMs—China, Chinese Taipei, and Vanuatu—accounted for 84% and 89% of those transhipments in 2015 and 2016, respectively and we are talking over 100 transhipments a year… I wrote about all this before. 

Anyway if we get hold on the transhipments situation, many collateral benefits associated with port transhipment come into game:

• Under and Misreporting: FFA’s IUU quantification report identified “Unreported” as the main IUU issue in the region, having transhipment in port, under similar conditions of that PPS and with the use of scales will be a massive step towards compliance 

• Observer Coverage: having LL coming to port is key to increase the agreed percentages of Observer Coverage

• Electronic Monitoring: the main limitation for the HS vessels are maintenance of the equipment and the delivery of the footage ((hard drive based) to the national observer. Using carriers provides big delays and compromises the CoC for the hardware

• Labour issues: these could be dealt in much more depth trough having the vessels coming to port

• Safety: transhipment at the port are fasted and safer than at seas as a port are more protected to whether and swell

• MARPOL: longliners coming top port can easily comply with their MARPOL obligations

So yeah… this is bad news for all of us in the region… and I wish there was something that could be done with Vanuatu ton rail them into better flag state performance and changing their stand on High seas transhipment…

The future of food from the sea

There is an ambitious title for a paper!

One that will require quite a lot of credible authors to pull it off unscathed, particularly when is in the Nature journal. yet when you read many well-known names in the impressive list of 22 authors spanning the globe, you know that is the kind of effort needed to live up to the challenge of the title. Particularly when the results challenge the narrative that is all doom and as we still get bombarded with, they will not be fish in 2048!

the present of food of the sea

I’m way to low in the trophic and brain capacity scale as to have a valid opinion on the accuracy of the conclusions, but I liked what I read and how they angled the premises of the paper.

I just quote parts of it, yet my usual recommendation is to read the original.

The abstract sets the paper in motion:

Abstract

Global food demand is rising, and serious questions remain about whether supply can increase sustainably1. Land-based expansion is possible but may exacerbate climate change and biodiversity loss, and compromise the delivery of other ecosystem services. As food from the sea represents only 17% of the current production of edible meat, we ask how much food we can expect the ocean to sustainably produce by 2050. Here we examine the main food-producing sectors in the ocean—wild fisheries, finfish mariculture and bivalve mariculture—to estimate ‘sustainable supply curves’ that account for ecological, economic, regulatory and technological constraints. We overlay these supply curves with demand scenarios to estimate future seafood production. We find that under our estimated demand shifts and supply scenarios (which account for policy reform and technology improvements), edible food from the sea could increase by 21–44 million tonnes by 2050, a 36–74% increase compared to current yields. This represents 12–25% of the estimated increase in all meat needed to feed 9.8 billion people by 2050. Increases in all three sectors are likely but are most pronounced for mariculture. Whether these production potentials are realized sustainably will depend on factors such as policy reforms, technological innovation and the extent of future shifts in demand.

The main part describes well the challenges and the approach 

Main

Human population growth, rising incomes and preference shifts will considerably increase global demand for nutritious food in the coming decades. Malnutrition and hunger still plague many countries and projections of population and income by 2050 suggest a future need for more than 500 megatonnes (Mt) of meat per year for human consumption. Scaling up the production of land-derived food crops is challenging, because of declining yield rates and competition for scarce land and water resources. Land-derived seafood (freshwater aquaculture and inland capture fisheries; we use seafood to denote any aquatic food resource, and food from the sea for marine resources specifically) has an important role in food security and global supply, but its expansion is also constrained. Similar to other land-based production, the expansion of land-based aquaculture has resulted in substantial environmental externalities that affect water, soil, biodiversity and climate, and which compromise the ability of the environment to produce food.

Despite the importance of terrestrial aquaculture in seafood production (Supplementary Fig. 3), many countries—notably China, the largest inland-aquaculture producer—have restricted the use of land and public waters for this purpose, which constrains expansion Although inland capture fisheries are important for food security, their contribution to total global seafood production is limited (Supplementary Table 1) and expansion is hampered by ecosystem constraints. Thus, to meet future needs (and recognizing that land-based sources of fish and other foods are also part of the solution), we ask whether the sustainable production of food from the sea has an important role in future supply.

Food from the sea is produced from wild fisheries and species farmed in the ocean (mariculture), and currently accounts for 17% of the global production of edible meat (Supplementary Information section 1.1, Supplementary Tables 1–3). In addition to protein, food from the sea contains bioavailable micronutrients and essential fatty acids that are not easily found in land-based foods, and is thus uniquely poised to contribute to global food and nutrition security.

Widely publicized reports about climate change, overfishing, pollution and unsustainable mariculture give the impression that sustainably increasing the supply of food from the sea is impossible. On the other hand, unsustainable practices, regulatory barriers, perverse incentives and other constraints may be limiting seafood production, and shifts in policies and practices could support both food provisioning and conservation goals.

In this study, we investigate the potential of expanding the economically and environmentally sustainable production of food from the sea for meeting global food demand in 2050. We do so by estimating the extent to which food from the sea could plausibly increase under a range of scenarios, including demand scenarios under which land-based fish act as market substitutes.

The future contribution of food from the sea to global food supply will depend on a range of ecological, economic, policy and technological factors. Estimates based solely on ecological capacity are useful, but do not capture the responses of producers to incentives and do not account for changes in demand, input costs or technology.

To account for these realities, we construct global supply curves of food from the sea that explicitly account for economic feasibility and feed constraints. We first derive the conceptual pathways through which food could be increased in wild fisheries and in mariculture sectors. We then empirically derive the magnitudes of these pathways to estimate the sustainable supply of food from each seafood sector at any given price21. Finally, we match these supply curves with future demand scenarios to estimate the likely future production of sustainable seafood at the global level.

I particularly like the four pathways they see as to sustainably increase food from the sea: 

1. improving the management of wild fisheries;

2. implementing policy reforms of mariculture;

3. advancing feed technologies for fed mariculture; and

4. shifting demand, which affects the quantity supplied from all three production sectors.

The analysis from these bases is quite deep and interesting, I recommend you follow it, otherwise here are the conclusions 

Conclusions

Global food demand is rising, and expanding land-based production is fraught with environmental and health concerns. Because seafood is nutritionally diverse and avoids or lessens many of the environmental burdens of terrestrial food production, it is uniquely positioned to contribute to both food provision and future global food and nutrition security. Our estimated sustainable supply curves of food from the sea suggest substantial possibilities for future expansion in both wild fisheries and mariculture.

The potential for increased global production from wild fisheries hinges on maintaining fish populations near their most-productive levels. For underutilized stocks, this will require expanding existing markets. For overfished stocks, this will require adopting or improving management practices that prevent overfishing and allow depleted stocks to rebuild.

Effective management practices commonly involve setting and enforcing science-based limits on catch or fishing effort, but appropriate interventions will depend on the biological, socioeconomic, cultural and governance contexts of individual fisheries.

Effective management will be further challenged by climate change, species composition changes in marine ecosystems and illegal fishing. Directing resources away from subsidies that enhance fishing capacity towards building institutional and technical capacity for fisheries research, management and enforcement will help to meet these challenges.

Increased mariculture production will require management practices and policies that allow for environmentally sustainable expansion, while balancing the associated trade-offs to the greatest extent possible; this principle underpins the entire analysis. We find that substantial expansion is realistic, given the costs of production and the likely future increase in demand.

We have identified a variety of ways that sustainable supply curves can shift outward. These shifts interact with future demand to determine the plausible future equilibrium quantity of food produced from the sea. We find that although supply could increase to more than six times the current level (primarily via expanded mariculture), the demand shift required to engage this level of supply is unlikely. Under more realistic demand scenarios and appropriate reforms of the supply, we find that food from the sea could increase in all three sectors (wild fisheries, finfish mariculture and bivalve mariculture) to a total of 80–103 Mt of food in 2050 versus 59 Mt at present (in live-weight equivalents, 159–227 Mt compared to 102 Mt at present).

When combined with projected inland production, this represents an 18–44% per decade increase in live-weight production, which is somewhat higher than the 14% increase that the Organisation for Economic Co-operation and Development (OECD) and the FAO project for total fish production during the next decade.

Under some scenarios, future production could represent a disproportionate fraction of the estimated total increase in global food production that will be required to feed 9.8 billion people by 2050. Substantial growth in mariculture will rely partly on public perceptions. Although there is some evidence of a negative public perception of aquaculture, it is highly variable by region and by context, and certifications and the provision of other information can help to alleviate concerns and expand demand.

These global projections will not have uniform implications around the world. For example, improved policies that shift the supply curve outward will decrease prices, but income-induced demand shifts will increase prices. Both effects increase production but have vastly different consequences for low-income consumers.

Bivalves may contribute substantially to food security by providing relatively low-cost and thus accessible food, because they have a high production potential at low costs compared to finfish production (Fig. 3). If all seafood is perfectly substitutable, bivalves could contribute 43% and 34% of future aquatic food under future and extreme demand scenarios, respectively (Supplementary Fig. 3)—which suggests potential large increases in production, provided demand is high enough.

Trade also has an important role in distributing seafood from high-production to low-production regions, and in overcoming regional mismatches in price. The rate of international trade of seafood products has increased over past decades, and 27% of seafood products were traded in 2016, although major economic disruptions—such as the COVID-19 pandemic—can jointly reduce both supply and demand of traded seafood. On the other hand, trade may become increasingly relied upon as climate change alters regional productivity.

Substantially expanding the production of food from the sea will bring co-benefits and trade-offs, and will require national and interregional governance, as well as local capacity to ensure equity and sustainability.

The improved management of wild fisheries can not only increase fish biomass, but also brings the co-benefit of improved livelihoods of fishers. However, there will be some short-term costs as overfished stocks rebuild to levels that support greater food provision.

As mariculture expands, interactions with wild fisheries and other ecosystem services (via spatial overlaps, pollution and so on) must be constantly addressed. Ambitious technical innovation (that is, the substitution of marine ingredients with terrestrial-sourced proteins) can help to decouple fed mariculture from wild fisheries, but will probably refocus some pressure on terrestrial ecosystems.

Climate change will further challenge food security. Estimates suggest that active adaptation to climate-induced changes will be crucial in both wild fisheries and mariculture. Climate-adaptive management of wild fisheries and decisions regarding mariculture production (for example, the type of feed used, species produced and farm sitting) could improve food provision from the sea under conditions of climate change.

We have shown that the sea can be a much larger contributor to sustainable food production than is currently the case, and that this comes about by implementing a range of plausible and actionable mechanisms.

• The price mechanism—when it motivates improved fishery management and the sustainable expansion of mariculture into new areas—arises from change in demand, and acts on its own without any explicit intervention.

• The feed technology mechanism is driven by incentives to innovate, and thus acquire intellectual property rights to new technologies. When intellectual property is not ensured, or to achieve other social goals, there may be a role for public subsidies or other investments in these technologies.

• The policy mechanism pervades all three production sectors, and could make—or break—the ability of food from the sea to sustainably, equitably and efficiently expand in the future.

Responding to: Why I don't I don't subscribe to paid content

I get a lot of questions via mail and social media, that in most cases I’m always happy to respond. One that I get from people working in paywalled media (who wants to use my content of photos) is why I’m against subscriptions to paid content… my standard response is below:

Always looking for fish or information :-)

I totally understand you run a business and your livelihood depends on this... but you see, 30 years ago I was working on fishing boat earning 300USD a month. I manage to gain qualifications and progress in life thanks to studying and to many people that I knew but even more people I didn't, that provided me information, books (that's you FAO!), and training materials for free.

I started my blog as a sideline in my website (the blog option was part of the minimal package) so I started writing it for free and i always love making pictures of what is ee on board (and also said many times: no thanks to offers of paid sponsorship), mostly as a way to partly pay back all that free info and advice I was given... 

I work at the present with many fishers and fisheries officers in the pacific that earn less per month than the value of most paywalled fisheries news sites...

So I adhere to the principle that fisheries information should be free, otherwise the gap in between those that can access and those that by no fault of their own cannot pay for it will keep growing... and with that, we will see sustainability fall even further, since only the rich can afford to be informed and care, while the less fortunate, keep having their choices and options further and further eroded.

I'm totally aware that it is a total ideological stand, as the gap is too wide already for a one-man band like myself to make a difference, yet I’m a man of principles... so I don't subscribe to paid content.

Said so, I really appreciate your interest in my personal rumblings in the blog, and as long as I'm acknowledged as the source of pictures and contents I'm honoured for you to be using them... just let me know when you do as a matter of courtesy, that is all.

Yours in legal and safe fishing,
--
Francisco Blaha

While we worry about IUU, the real big issue keep coming in.

Is hard to read some papers some days… while I’m trying to wrap my head around the GDST standards, GS!, and the lot... I decided to read this paper “Climate change, tropical fisheries and prospects for sustainable development” (written by quite a few well-known names), to see if it aligns with other papers I read and blogged about.

is not them the real problem… is us

And when you read: the combined catch of both tuna species is projected to decrease by ~10–40% by 2050 in the exclusive economic zones of Federated States of Micronesia, Marshall Islands, Nauru, Palau, Papua New Guinea, Solomon Islands, Tokelau and Tuvalu… is hard to swallow... I work with friends in all those countries

That is enough to disbalance the weekend, and made me question my self on what I’m doing?

Is already hard to deal with the IUU issues that are my work, yet they are quite minimal in terms of political clout in comparison… so the reversion of the drivers of climate change ain’t going to change anytime soon.

The demise of commercial tuna fisheries in the WCPO is not on the greedy and terrible fisherman as the usual narrative goes on or the lack of effort of the Pacific Island countries. Is on the worldwide medium and above social class almost insatiable hunger for more energy, cars, goods etc… while the cost of their greed is paid by those that don’t have those goods and facilities. 

So yeah… have a read on the paper and let’s look deep into ourselves… because this one is on us.

I just quote there the box for the pacific…

Across the 22 Pacific Island countries and territories (PICTs), models predict an eastern redistribution in the biomass of skipjack and yellowfin tuna — the two main exported fish species — by 2050). Under Representative Concentration Pathway (RCP) 8.5, for example, the combined catch of both tuna species is projected to decrease by ~10–40% by 2050 in the exclusive economic zones of Federated States of Micronesia, Marshall Islands, Nauru, Palau, Papua New Guinea, Solomon Islands, Tokelau and Tuvalu However, given the eastern redistribution, tuna catch is anticipated to increase in the exclusive economic zones of Kiribati and Cook Islands by 15–20% 

As several PICTs are tuna-dependent economies, the impact of climate change on tuna fisheries increases the vulnerability of these small island developing states. For instance, shifts in tuna distribution, and resulting increases in catches from international waters, are expected to cause proportional changes in government revenue received by small island developing states from fishing licence fees. These changes need to be considered by the Western and Central Pacific Fisheries Commission when governing the sustainable use of the region’s tuna resources, developing harvest strategies and allocating fishing rights to minimize the implications of tuna redistribution for island economies.

The projected 20–50% decrease in productivity of coral reef fish in the Pacific Islands region by 2050 under RCP8.5 is expected to influence the contributions of small-scale fisheries to food security in most PICTs However, rapid population growth in several PICTs is expected to have a greater influence than declining reef fish production on future availability of fish per capita. The rich tuna resources of the Pacific Islands region can be used to fill the widening gap between the total amount of fish that can be harvested sustainably from coral reefs and other coastal habitats, and that required for good nutrition.

CTEs and KDEs in seafood value chains

I been writing and talking about CTEs and KDEs for while now. These concepts are not “new” they go back to a 2009 publication “Product tracing in food systems”, but I got working with them in 2015 thanks to Tejas Bhatt (we worked on this report - EPLAT). Then, I used them in two FAO publications, the Traceability for Compliance we co authored with Gilles Hosch, and the one I recently co-authored with Kenneth Katafono on Blockchain.

the very basic idea we developed on the EPLAT in 2015.

 The definitions are:

1.  CTEs – “points within a business and along the value chain where product is moved between premises or is transformed, or is determined to be a point where data capture is necessary to maintain traceability”; and 

2. KDEs – “the data elements required to successfully trace a product and/or its ingredients through all relevant CTEs”.

As any form of standardised validation and verification structure for data that is to be part of a traceability framework along the value chain needs to be based on regulatory oversight by the authorities in the different types of States, as the concept of “official guarantees” still holds strong in trade and social governance as does that of market access under the Agreement on the Application of Sanitary and Phytosanitary Measures (SPS Agreement) and the Agreement on Technical Barriers to Trade (TBT Agreement) of the World Trade Organization (WTO) as well a key element around Catch Documentation schemes aimed to combat IUU fishing.

This highlights the importance of identifying CTEs in the value chain – from the point of capture to the final point of importation – where information is to be collected and of proposing measures to address weaknesses, inefficiencies and gaps.

In order to assist with stablishing those CTEs and KDEs, I been contracted now to write a further book for FAO based on identifying Critical Tracking Events (CTEs) and authoritative sources of Key Data Elements (KDEs) as well as supporting verification mechanisms in seafood value chains (both wild capture and aquaculture).

I been quite serious about the issue of diversity and gender balance in our sector, so I try to play a helpful role on those aspects. Furthermore, the usual audience of FAO books is in the global south, so I try to make sure that I have that perspective included. I’m also the first one to recognise all of my limitations, and an inside knowledge of aquaculture is one of them, hence I suggested FAO to work with other authors and suggested my college Yahira Piedrahita from Ecuador who has extensive experience in Latina America and India and I’m also very happy to work again with Vincent Andre who has lots of experience from living and working in Thailand and Indonesia.

Furthemore, I’m not only incredible thankfull to FAO for helping me as a fisheman that had a breack thanks to one of their trainings in 1987all the way to be wirting books for them, but also for being the living example of the need of diversity.

Anyway, this study will seek to provide technical advice to FAO member states in the development, enforcement and effective verification of traceability in seafood value chains (both wild capture and aquaculture origins) as well as evaluating the efficacy of their systems and identifying gaps for those with existing traceability systems.

The idea is to address these objectives through the set- up of a list of minimum requirements for seafood traceability with clearly defined: Critical Tracking Events (CTEs) along the seafood value chain, authoritative sources of Key Data Elements (KDEs) and supporting verification mechanisms. 

Yet is our hope that by identifying and documenting CTEs and KDEs and associated verifications the work will be supporting and easing FAO's Members States transition to either low-tech or high-tech digitally-supported traceability systems. 

This study will assist the operators and authorities to identify the data that needs to be traced and define the parameters of traceability. This information should be tracked, accurate and easily verifiable. This study will also assist the operators and authorities to achieve the «verifiability » of their traceability systems and traceback procedures. It is anticipated that the final report will serve as basis for future expert consultations to deliberate and adaptation

This is a big job since we have quite a wide hierarchy of information to go over, staring with multilateral sources, then regional and then private and NGOs… and even so, I’m totally aware that there would be sources but most importantly elements of reality that will scape… since no model will ever duplicate the complexities of reality… so wish us luck and strength!

MARPOL controls - another victim of COVID 19?

I have written a bit with the general impact of COVID 19 on tuna fishing and compliance, as well as the what I think would a totally non controllable FAD closure. Yet it also occurs to me that the whole MARPOL will be unmanaged… 

Normally I keep my posts around fishing and labour, but as a keen ocean user (long distance ocean swimmer, paddler, spear fisherman, sailor) the issues of plastics and MARPOL in general interest (and affects) me.

I wrote in the past on this issue and I’ve seen the disdain some vessels already have to MARPOL issues even with the observer on board… so imagine now.

The issue of plastic in longliners in particular is a massive one, and nobody is doing much about it… particularly with those operating on the high seas… (yeap the same where we have the highest incidences of unreported fishing, the worst cases of labour abuses, and surely MARPOL issues), while I’m one against generalisations I’m sure that all high seas longline vessels dump the plastic waste from bait boxes in the ocean every day.

Yes, I know, in principle under the WCPFC Commission Management Measure (CMM) 17/04 on Marine Pollution as of January 1, 2019, all fishing vessels operating in the WCPFC Convention Area are specifically prohibited from dumping any plastics into the ocean. Clause 2 of the CMM specifically states: CMMs shall prohibit their fishing vessels operating in the WCPFC Convention area from discharging any plastic (including plastic packaging, items containing plastic and polystyrene) but not including fishing gear.  

As far as has been ascertained, outside of Australia and New Zealand, only Fiji has licensing provisions which require the retention of plastic waste on board locally based and licensed vessels for disposal on shore, so for the rest is dumping as usual.

 Let’s do some numbers to illustrate the magnitude of the issue… 

A typical tuna longline vessel will set around 3000 hooks per set.  The hooks are baited via 10 kilogram boxes which contain 100 – 120 pieces of bait. The boxes are waxed cardboard and each has a plastic liner to contain the bait and two plastic straps to seal the box. Therefore, with each set using around 30 boxes of bait for each set of 3000 hooks there are 90 pieces of plastic generated, to make numbers easier lets assume only 1000 longliners setting every day (in reality there are more than that), that represents conservatively 90,000 pieces of plastic per day or 630,000 pieces of plastic per week and 2,520,000 per month, as well as 30+ pieces of waxed cardboard overboard for each vessel each day!!!

and i’m not even talking about old lines, broken buoys, and just plastic shit…

The standard argument is that there is just no means for high seas vessels to dispose of plastic bait box waste other than into the ocean. But we all know that in reality, if there is a will… there is way.

In the case of domestic based vessels, waste can either be disposed of on return from sea or prior to departure. Consider then scenario where bait boxes and emptied into bins (such as are standard storage containers on most vessels), then these bins can be stored with 3 boxes of bait per bin and stowed in the freezer to be used as required.

There would also seem to be potential for this to apply to carrier vessels loading bait for delivery to longline vessels, but this could involve the large plastic bins commonly utilised for fish holding on vessels and in ports

Another option is for the suppliers of bait boxes could be encouraged to use waxed paper box liners and bind boxes with twine or tape which can be more easily stowed on board with the bait boxes and liners being burnt.

The reality is that the current measures lacks provisions for enforcement and current practices for plastic disposal at sea cannot be allowed to continue and new mitigation strategies are urgently required for widespread adoption.

But again, Flag State responsibility is totally lacking as usual… and is up to coastal and port state to take actions… via Electronic Monitoring (EM), and another reason to clamp at sea transhipments!

Unilateral Trade Measures, defining IUU Fishing and the “Concerns” with China

I’ve on the quiet end of blogging for the last few weeks, as I’m going through some emotional struggle and work reshuffling. But then a paper come out that wakes me, so I take a break and quote some of the pearls I read.

looking beyond the horizon on trade restrictive measures

The paper is “Unilateral Trade Measures and the Importance of Defining IUU Fishing: Lessons from the 2019 USA “Concerns” with China as a Fishing Flag State”. I have corresponded with the author Arron N. Honniball in the past and is obvious that we align in views yet he works at a level that I just look from below.

The topic is one of much interest to me and I wrote a lot about it: TREMs (Trade Restrictive Measures) associated with IUU fishing… a tool that both the EU and the US apply but in very different ways.

paper does not has alink yet, but from all accounts Arron is good man, and I’m sure he would be happy to share the paper if you ask nicelly. I just quote the intro and bits I loved from the conclusion. But please read it all.

Introduction

On September 19, 2019, the USA’s National Oceanic and Atmospheric Administration (NOAA) publicly released its 2019 biennial report to Congress, Improving International Fisheries Management, identifying Ecuador, Mexico and the Republic of Korea as states whose vessels are reportedly engaged in illegal, unreported or unregulated (IUU) fishing activities under Section 609(a) of the High Seas Driftnet Fishing Moratorium Protection Act. 

The biennial identification of foreign states is the first step in the USA’s unilateral  three- step identification and certification procedure which analyzes the enforcement of international fisheries law by foreign states. The USA will take measures against any state receiving a negative certification, including the closure of U.S. ports and U.S. markets to that state’s fishing vessels, catch and fishery products.  Additional economic sanctions may also be imposed. The USA is not unique in imposing such trade measures. The EU, as well as numerous Regional Fisheries Management Organizations (RFMOs), also identify non- cooperating or non-compliant states that may be subject to comparable trade measures.

Nonetheless, unilateral measures in pursuit of a global common interest, i.e., “ending” IUU fishing, may raise questions of legitimacy, sufficiency or coherence if domestic laws and policies substantially differ from their purported international law and policy basis. Systemic differences may first and foremost arise from different definitions of IUU fishing. Unlike the EU’s practice, which largely follows the inter-national law “definition” of IUU fishing in the International Plan of Action to Prevent, Deter, and Eliminate Illegal, Unreported and Unregulated Fishing (IPOA-IUU), the USA has prescribed a definition of IUU fishing that is fundamentally different in scope. To highlight this difference and its legislative impact, this article first intro-duces the USA’s identification and certification procedure (Part II). More specifically, this article addresses the consequences and acceptability of the U.S. definition of IUU fishing as not including vessels engaged in illegal fishing in the waters under the jurisdiction of a foreign state.

A novel section in the OMNV Report to Congress entitled “Concerns with China’s Fishing Practices” is then both demonstrative of such a legislative gap and the currently hobbled U.S. response (Part III). When the USA implements the identification and certification procedure, the U.S. definition of IUU fishing precludes consideration of alleged widespread illegal fishing by Chinese- flagged vessels in the exclusive economic zones (EEZs) of foreign states. States have a certain degree of flexibility in defining IUU fishing. However, this practice demonstrates that the current definition results in an identification and certification procedure that is inconsistent with U.S interests and is insufficient to address the USA’s global policy objectives and responsibilities. The lessons learned should promote U.S. legislative reform and equally assist other market states in designing unilateral measures that properly address a global common interest.

The OMNV Report to Congress also raises concerns with IUU fishing by stateless vessels with the “characteristics” of Chinese flagged vessels (Part IV). The identification and certification procedure seeks to address poor governance by foreign states. Given the lack of an attributable flag state for vessels without nationality, state- to-state trade measures targeting flag states should exclude IUU fishing by vessels with-out nationality. Any possible trade measures against a flag state on the basis of the “characteristics” of stateless vessels is inappropriate.

This article concludes with the way forward for the USA and other states adopting unilateral trade measures to combat IUU fishing (Part V). Wider lessons on ensuring transparent and unbiased implementation of market state measures are also raised.

Finally, this article focuses on China because it is the subject of the new “concerns” section of the OMNV Report to Congress. An independent IUU Fishing Index also ranked China as the worst performing flag state in 2019 (excluding landlocked states).1 But, it is not the objective of this paper to address the factual basis of NOAA’s concerns, nor the Chinese response. The arguments below concern the appropriate substantive design of trade measures. These design arguments do not affect the market states’ procedural discretion in implementation, nor suggest China must be identified.

Parts of the conclusions (some jewels there)

Designing state- to-state trade measures to exclude flag states facilitating illegal fishing in foreign EEZs was seen as unnecessary and inconsistent with international and national interests. From the international perspective, it excludes the most well defined and universally accepted form of IUU fishing, which is also subject to multilaterally agreed flag state obligations. If unilateral trade measures are building on the primary responsibility of flag states, they should first and foremost apply here. (love this one!)

Moving forward, the USA should amend the identification and certification procedure to include flag states responsible for illegal fishing in foreign EEZs. This will remove an unnecessary and discriminatory distinction in the design of U.S. trade measures combating IUU fishing. If necessary, the USA may then still exercise its discretion in implementation to focus identifications on fishing activities that directly infringe upon U.S. fisheries interests. Any question of identifying flag states for IUU fishing by stateless vessels with “characteristics” of that flag state should be dropped. If the USA wishes to make progress here, it will need to follow the EU’s example and design trade measures that address coastal states, port states, market states and states of nationality that are facilitating IUU fishing.

For the EU moving forward, the non- cooperating states procedure follows the IPOA- IUU definition of IUU fishing. The critiques of bias or discrimination in EU trade measures therefore result not from design, but implementation.127 This is in part due to the initial audits and informal dialogues remaining confidential. Commentators and states only have access to the EU’s reasoning in the more limited cases of a foreign state being issued a pre- identification notification (“yellow card”). Perhaps the EU has or is engaging China in confidential dialogue. The lack of transparency on which states are subject to continuing informal dialogues or have implemented reforms necessary to avoid a yellow card therefore increases the perceived discrimination. It would be in the interest of the EU and its partners to follow the transparency evident in the Reports to Congress. Similar to NOAA’s “concerns,” the EU could list its ongoing informal dialogues and omit any substantive details that could jeopardize the process. Informal dialogues that conclude in a yellow card being unnecessary could then be reported in detail similar to NOAA’s reporting on states considered but not identified. These minor reforms would greatly improve procedural transparency and shed further light on how states interpret their obligations to combat IUU fishing in international law.

Finally, whether trade measures are substantively and procedurally fit for purpose and whether they should then be implemented against a foreign state are separate questions. The difficult and potentially controversial task of identifying states - including if this should include China-is left to NOAA

FAD Closure and FAD Free in the Time of COVID 19*

As an ex fisherman, I’m always ready to remind the people that seem to think that we are all dodgy criminals and even assassins, that as in any group of people in front of a set of rules your will have really hardcore dodgy, moderately or occasionally dodgy and totally straight and honest fishers.

so much investment in echo-sounder FADs and not using it while not one is looking… really?

Real dodgy and totally honest generally make up a small portion of a given population. The real assholes do undertake IUU activities no matter what, while the honest will not engage in IUU fishing under any condition. Hence any compliance-related scheme will have limited effectiveness in the dodgy group, but an affirmative impact in the honest ones.

But then, the moderately or occasionally dodgy (the biggest group), on the other hand, will only bypass regulations if the potential economic gain is high enough to cover the potential penalty they may face given the size of the penalty when caught, but more importantly, the probability of being caught. 

Why am I saying this? Because today 1 July FAD closure at the WCPFC starts. I have written a lot on FADs and the fact that during FAD closure, the presence of observers is the key dissuasive stop for many people to take shortcuts… but without observers, the temptations are almost ridiculously high.

In my opinion, the tuna fishery survives because FADs…I’m no economist but I hang out in wharves and boats a lot! During FAD fishing a trip up to full boats would be around two weeks on a variable average (I’ve seen 7 days to 18-20) now during FAD closure we talking 20 to 40 days… with MASSIVE differences in fuel consumption (even if fuel is cheap now) and sometimes you see boast outside for 40 days and come 50% full. 

And is not like they pick up all the eFADS during the closure,  they still there operating and the vessels, vessels owners and traders still get the info, and with no one on board to give an independent oversight, the temptation is too big for the moderately dodgy and even for the hardcore honest. What is the point of maintaining a stand if you losing money?… but with those disincentives… being honest means also being stupid!

Under normal circumstances, FAD fishing during FAD closure does happen, even if observers act as a deterrence. The most common cause of observer denouncing they have been offered money is around FAD closures... And is important to note that observers which are also human, range like anyone else on theirs morals and approach to corruption, so is not hard to infer that if some denounce corruption attempts, some will take it and keep quiet. In any case, all that is out of the window at the moment, since there are no observers on board.

In Majuro during FAD closure, and as part of our Ports State Measures - Arriving Vessels Intelligence analysis (AVIR) we use manoeuvring analysis (speed pre-fishing set, time of the day, course changes, track shape and prior activity) and if we have doubts, when the vessel is in port and based on the loading log that most of the engineer keeps, we instruct the monitor to check the presence of species that aggregate and cannot be found in a free school set. e.i. the aptly named Triggerfish. 

Others like Yellowtail, Wahoo, etc can be normally separated on deck, but the triggerfish is too small and gets frozen with the rest, so if we see it during the loading of the nets in the holds or on deck... alarms bell ring... Of course, we don't have monitors during transhipment either at the moment!

 A couple of months ago pre-visioning this mess, we discussed with my RMI friends that a very good intelligence tool, that could help us lot (in RMI, but also in the rest of the members) would be an analysis on data available for the last 5 years (as an arbitrary number) during FAD closure of some parameters that can help boarding officers/MCS guys to see if the data provided prior arrival of the vessel for that period falls inside the normal distribution.

The initial parameters would be:

• sets per day,

• days at sea in between unloadings,

• speed prior to the set (you normally chasing the school fast as it moves) 

• distance travelled at night (during FAD closure you drift at night -with some exemptions- yet on FAD fishing you go to the next) 

• sets before dawn, sets after sunset - (FAD free set only happen during the day, because you have to see the fish - the full moon can help.... but is very unusual)

• and some more I keep quiet (so I can still have a job!)

To get these data, it would have required us to dive deep into SPC’s TUFMAN 2 database, that maintains vessel but also observer data. Yet nor we or SPC had the time and people available to help in compiling, analysing and presented the data in a risk evaluation friendly format… which was a pity and a lost opportunity.

Furthermore, very few vessels are coming to Majuro since it has some the most strict vessels arrival conditions in the region.

Most of the vessels are transhipping now in ports where very little PSM best practices are followed, no one does manoeuvring analysis or even intelligence analysis… and there are no observers.

With the present COVID reality…. I sadly believe that the 3 months WCPFC FAD closure would be a total failure this year. 

I’m not a friend of the Ecolabels at the best of times, but the fact that they maintain a certification that is FAD free dependent, during these times is beyond disappointing and for me just adds to the long list of grievances I have against them.

And this is not just now… since there are no observers and monitors… the whole certification is just based on self-reporting. In Majuro, we have not monitored a single transhipment or offloading since March, yet they still are getting emails of vessels transhipping/unloading MSC fish in the lagoon. 

Begs the question who is verifying these transhipments as a third party, or even when the vessel is making free school sets at sea for that matter. Seems that the “integrity” of some of the MSC unit of certification was the “official” monitor’s verification of the chain of custody, but now, who knows whats going on. 

So yea… not cool… and not much we can do to from the regulatory perspective… 

 *Love in the Time of Cholera is a 1985 novel by Colombian author Gabriel García Márquez that earn him a Nobel price.

so much investment in echo-sounder FADs (around 3000USD each) and not using it while not one is looking… really?

Fishing for Success - Lessons in Pacific Regionalism

If you have any interest in tuna in the pacific and don't know about PNA (the Parties to the Nauru Agreement) then you don't have an interest in Tuna. Yet I agree is not an easy organization to understand and it hard to see how it fits in the already complex matrix of institutions (FFA, SPC, WCPFC) that support and regulate tuna fisheries in the WCPO.

my first full page boook cover

I personally admire the leadership they brought in terms of maximising the rent of the resource use to the 8+1 member countries and supported many times their Vessels Day Scheme (VDS) as a management tool in the case where ports were not yet in the position to be “licensed fish receivers” to count and allocate catches with precision to quota owners.

For the record, I do not agree to the full flagged support of the MSC certification, but this is based on the issue I have with the ecolabels in general (based on the fact that they are hypocrisy at best and neo-colonialism at worst) but not with PNA or any of its members.

At its core, PNA emerged from a shared vision for self-determination through an unwavering commitment by ‘the right set’ of people at the helm of the fisheries organization at the time who had a clear understanding of the regional environment and its culture to ensure that this collective fishing initiative not only took hold but thrived. Furthermore, the organization had great leader Dr Transform Aqorau and a group of very envisioning assessors like Les Clark.  

The success of the PNA is a stellar example of the unswerving commitment by resource owners to take control of their fishery rights on their own terms and conditions. Since its establishment, the agreement has grown from strength to strength — a testament to the political strength and ownership behind this industry shown by the eight PNA states. The fact that they have transformed the value of economic returns from the tuna fishery from US$60 million in 2010 to around US$500 million in 2019 is no mean feat, especially when it relates to small island developing states. 

I have known Transform for many years now, and we share a love of books and self-empowerment based on the fact perhaps that we grow up in rural setting in developing areas even if in two very different countries. I’m a bit a rara avis in the consulting world in the pacific.  I wasn't born in a former colonial power (i.e. English, Australian, American, or NZ), nor a native English speaker, nor a full-blooded European, and I went from commercial fishing to development, from a fishing boat to a university… not the other way around. While this may have baffled many people at Transform’s level, he always was very kind and respectful to me… I remember asking him about accommodation in Majuro for a mission and he said come and stay at my I’m not going to be there, so I spend 2 weeks at his house working and going over his very impressive bookshelf (in my culture if someone trust with his home is a huge honour, one not to be taken lightly). Furthermore, I was also his guest at ancestral land in Rakutu, Solomon’s western province, near Noro (my favourite fisheries port in the world, and what fishing should look like in the pacific), where we shared stories of our native cultures, common visions, cava and tea in the outdoor kitchen no too different to the one in the place I grow up.

So last year when Transform asked me if I could contribute some photographs for the book he was writing on his 1st hand account of the development of PNA under his leadership I was totally honoured, and even more when I see my pictures in the cover and back cover as well as all through the text, plus his very kinds words in the acknowledgements. 

So yeah! If you want to understand PNA boat from the inside… this is the book and is written by the captain itself!

COVID as a boost to Transhipment over Landing and Containerisation?

There is something I love about English and is that it can be quite literal sometimes… Transhipment (in between ships), landing (lands), containerisation (you put it in a container)… no one should get confused about the meaning of those!

port transhipment is here to stay for while i reckon.

With the carrier fleet ageing and getting smaller many people were predicting the slow demise of in-port transhipment, and the rise of landing and wharf side sorting and containerization. The number of containers with tuna arriving in Bangkok has increased a lot over the last years, as from the processor side is great for production planning as they know they have 20—25 tons of one species and one size there… so is easier than having to sort at factory arrival. The cynic in me also says that since the introduction of PSM in Thailand, is much harder to bring in fish of dubious origin by carriers, as they fall under their PSMA responsibility… while if the fish was containerised abroad, then it corresponds to the responsibilities of the country where the landing happened.

Yet the COVID situation has pushed back the “traditional port transhipment” as a safe bet and maybe extends the life of carriers for a while incentivising the constructions of some new ones. If we didn’t have them, they wouldn't be any canned tuna in the market by now. And if there something that conservative industries (like fishing) have learned, is not to have all your eggs in one basket, and without no vessels landing in most pacific island ports, very little containerisation is taking place.

Around 520 carriers are in service worldwide, most of them built between 1988 and 1994, with very few new conventional reefers built since 2000. Of the vessels built between 1980 and 1990, close to half have been scrapped. The average age of scrapped vessels in recent years has been between 30 to 45 years old... so many vessels are getting to the end of the working life. 

In the  WCPFC Record of Fishing Vessels, there are around 420 ‘fish carrier’ vessels authorised. Panama has the largest fleet 123 vessels, then the Philippines with 111, Japan with 85, Korea with 31, Liberia with 21, Taiwan with 16, China with 12, then other smaller States (including Vanuatu and Kiribati) have around 20 registered vessels between them…. so is not a small fleet. Of the 232 carriers on the register above >1,000 GT in March 2019, an estimated 140 are active in transhipping fish from the WCPO. Of these, over half were flagged to Panama. Of the remaining fleets, Korea had the next highest number of active vessels with 27 (owned by only 7 companies), followed by the Philippines (14 vessels) and China (9 vessels).

With few processing facilities handling purse seine fish in the region, transhipping is the most common way to getting the fish from the grounds to the processing centres in Asia (Thailand, Vietnam, Philippines) and Ecuador.  The big 3 trading companies (FCF, Trimarine and Itochu) charter carriers and place them in the in a few ports (Majuro, Pohnpei, Rabaul, Funafuti, Honiara, Kiritimati and Tarawa) depending on shifting fishing grounds and licensing conditions. Some companies (mostly from Taiwan and Korea), operate their own carriers in conjunction with their vessels. How they choose where to tranship is described here

Landing, sorting and containerisation is enticing for processors and provides some benefits for the ports where it happens (like Majuro, Kosrae (FSM), Apia (Samoa) and Noro (Solomons), as it provides employment opportunities, furthermore it facilitates monitoring by the port state authorities in terms of legality (not unload unless proven legal as we do in Majuro) but then also volumes and species… since containers have a maximum loading capacity (20-25 tons, depending on freight company) and fish classified before loading. 

Yet on the other side, from the EU market access, only fish landed in the Solomons (at the moment) can maintain eligibility for the EU market even if processed in an EU authorised country from the sanitary perspective… RMI, FSM and Samoa are not authorised from the EU perspective… so if fish touched the wharf, it loses eligibility… this a bit ridiculous tho… but so its… so a Taiwanese PS can tranship in Majuro’s lagoon to a Panamanian carrier, and that fish is ok the be processed in Bangkok for the EU market. Yet if it touched the conveyor of a loader in Majuro’s wharf, even if for the 5’ before is in a refrigerated container, it cannot be processed and go to the EU…

So in RMI, for example, we are setting up a food safety body (the CA-Competent Authority) that needs to be equivalent to an EU member country (ie systems equivalent to those of Luxembourg), even if we never are going to process anything there that will do directly to the EU (too far and too expensive) for the few minutes that fish is going to be in the wharf… quite bizarre… but that is bureaucracy for you!.

Even if containerization can be done very fast 1 hr per contains and with two star loaders you could be in doing 400 tons a day, and employing locals.

The next thing that this also requires a good port with sufficient electricity to maintain the containers refrigerated and a good container vessels port, depth, facilities and schedule… other than Noro, is quite hard to find that combination in the Pacific at the moment. 

And while not all governments where transhipment takes place takes place seems to be in the position to cover these additional responsibilities and costs., sometimes being conservative pays… Under the present COVID 19 scenario… even if they had those rather expensive items and infrastructure, they could not be using it at the moment…

Putting all these issues together, transhipment seems to have getting a secure investment boost for a while longer… as I’m sure this is not the last pandemic we will face.

Further Explanation on the EU Market access side!

I had few people asking me to know more about the EU status from the sanitary perspective of the transhipment country vs the landing country, so here is and addendum

Under transhipment (in between two vessels) as long as the vessels are from EU authorised countries and are listed as approved by the flag states (https://webgate.ec.europa.eu/sanco/traces/output/non_eu_listsPerActivity_en.htm#) it does not matter where it happens and there is no requirement for the port state to be and authorised country (i.e. Majuro/RMI). From the EU IUU Catch Certificate side, the port state has to sign Section 7

Now if that fish is landed and put into containers (this is not transhipment!) then the country HAS to be authorised. so if the fish was landed and containerised in Kosrae (FSM), Majuro (RMI) of Samoa, it becomes not elegible for the EU market. So the processing establishment in any EU authorised cou ntry (like Thailand, Vietnam, etc) has to separate this non EU elegible fish from the EU elegible one (see page 31 of the publication below for details). The EU IUU Catch Certificate is totally blind to the port of unloading (incredible but true!), so there is no involvement of the port state in the case of landings that then will be processed somewhere else… the flag state has to (somehow) validate the legality of the catch without involvement or counter validation of the port was landed (and the coastal state/s where it was fished), then a copy of that Catch cert will go to the processing state and processing statements will be produced there for the volumes processed.

For how the EU sanitary and IUU systems works (or shopuld work) you can always refere to this boocledt I wrote in 2016. EU Market Access a Fishery and Aquaculture Products.

The manner with which the rules are ‘fitted’ to the system”

Working in fisheries development infrastructure and compliance, any paper that starts with ”Understanding why institutions fail is a major concern for natural resource governance. In systems where resources are managed locally, failure is often attributed to the rules poorly fitting the social-ecological system. But what might also bring failure is the manner with which the rules are ‘fitted’ to the system”

Local fisherman in Kiritimati

Is written by 3 authors of which I know one (Andrew M. Song). As a bit of an challenging (I say that as a good thing) paper, as it based in traditional markets in Greenland and uses Cybernetics (the science of control and feedback)  … it argues that the conceptual development of institutional failure could be made more tenable with cybernetics. In this case, the study and process tracing of a ‘market’ institution (an open-air fish market in Greenland), and they show how recently implemented European food safety regulations have generated unintended negative consequences, limiting Inuit access to marine foodstuffs, altering the social characteristics of food exchange, and giving rise to underground markets for marine foods.

What resonate to me is what I’ve seen so many times… well intended “western development programmes/experts” come with contemporary solutions to almost inexistent local problems… then the solutions don’t work… the investment stays idle… then of course the faults is of the beneficiaries and rarely donors assume the responsibility.

The last paragraph is spot on. 

Together, our study augments a key message posited in studies of institutional failure in environmental governance That is, that top-down, panacea thinking is not just inadequate; it can also be dangerous to the public. Institutional arrangements — including regulatory controls – that apply in European settings will not necessarily produce similar outcomes in Greenland. Ultimately, the success of these rules, we argue, hinges upon the will and capacity of communities to accept changes in the trade and market systems for marine foods, and importantly, the capacity of government to observe and evaluate how they govern natural resources. Given that open-air fish and meat markets have been a site of food governance in Greenland for over 60 years, the institutional failures set forth in this case underscore that legitimacy is key for social-ecological fit. Cybernetics shows us how legitimacy stands as a crucial measure of a community’s willingness to comply with the rules that govern them..

 The paper is here… always read the original

China’s Distant Water Fishing Fleet

I have written in the past about the role of China in world fisheries, as it is a topic I’m keen to know more since its impact is literally the biggest in the world… and it looks like is bigger than we thought. This recent report by ODI has been doing the rounds in the fishing circles of social media. I don’t know much about the authors (Miren Gutiérrez, Alfonso Daniels, Guy Jobbins, Guillermo Gutiérrez Almazor and César Montenegro) and their affiliations or the think thank publishing it, but from what I read and the references cited it looks solid and well backgrounded.

Having tried to extract information from Chinese authorities (and not getting anywhere) during an MSC pre-assessment that I later distance my self from, I was keen to see how they went on the methodology. And they have a whole annexe on it!

Basically, to identify Chinese DWF vessels, they looked at records of vessels: registered with specific Chinese public agencies responsible for regulating DWF; registered with foreign governments; or inspected outside Chinese waters. Cleverly they also looked at vessels’ unique Maritime Mobile Service Identity (MMSI) transponders being detected as active outside Chinese waters on a sample of dates during 2018.

Yet reality with China is that you never know, base data is always sketchy.

I also like that they were clear on the four key questions they wanted answers:

1. How big is the Chinese DWF fleet?

2. Where and how is it operating?

3. Where are these vessels registered, and who is operating them?

4. What are the implications of the DWF fleet’s activities for sustainable development?

The results are pretty staggering… this number says it all: 16,966 vessels, China’s DWF fleet is 5–8 times larger than previous estimates. That is really significant… almost unbelievable. Surely there are people out there that is going to review those numbers.

Anyway, I add some of the key findings but, as always, read the original.

—-

China’s DWF fleet is the largest in the world, but little information is available about its actual size and the scale of its operations. It is also unclear whether the Government of China has a comprehensive overview of China’s DWF fleet; vessel ownership is highly fragmented among many small companies and the fleet includes vessels registered in other jurisdictions. 

Key findings

• China’s DWF fleet is 5–8 times larger than previous estimates. We identified a total of 16,966 Chinese DWF vessels. These include 12,490 vessels observed outside internationally recognised Chinese waters between 2017 and 2018. 

• Trawlers are the most common DWF vessel, and most vessels are in the Northwest Pacific. We identified 1,821 individual Chinese DWF vessels as trawlers. This is more than double the largest previous estimate of the number of trawlers in China’s DWF fleet. An analysis of 5,241 fishing manoeuvres for 1,878 vessels during 2017 and 2018 found that the most frequent area of operations was the Northwest Pacific. However, the most intense operations were squid fisheries in the Southeast Pacific and Southwest Atlantic."

• Almost 1,000 Chinese DWF vessels are registered in other countries. We identified 927 vessels with Chinese owners, operators or other Chinese interests registered in other countries. 518 of these are flagged to African nations, where enforcement measures are generally limited, and where fishing rights are often restricted to domestically registered vessels. Just 148 vessels were registered in nations commonly regarded as flags of convenience. This reflects the limited incentives for adopting flags of convenience given the relatively lax regulation and enforcement of Chinese authorities.

• The ownership and operational control of"China’s DWF fleet is both complex and opaque. Analysis of a subsample of 6,122 vessels found that just eight companies owned or operated more than 50 vessels. The majority of vessels are owned by small- or medium-sized enterprises (SMEs). Many of these may be subsidiaries of larger corporations for tax or regulatory purposes. Labyrinthine company structures and a lack of transparency are likely to hamper monitoring and enforcement efforts, and efforts to ensure those ultimately responsible for malpractice are held accountable."

• At least 183 vessels in China’s DWF fleet are suspected of involvement in IUU fishing.  Just 10 companies own almost half of these vessels, and several are parastatal companies. This implies that Chinese authorities have the opportunity to target their enforcement efforts efficiently and lead by example when it comes to enforcing and prosecuting IUU activities.

Recommendations

The Government of China can take steps to demonstrate global leadership on the governance of DWF, sustainability of global fisheries and combatting IUU. Steps might include: 

• improving the registration and transparency of DWF vessels, as well as owning and operating companies;

• adopting higher standards such as ratification of the Port State Measures Agreement (PSMA), as a flag state;

• stricter regulation and enforcement of DWF operations; and

• strengthening bilateral cooperation with states where Chinese DWF vessels fish.

Our findings also highlight the need for more effective regional and global action. International bodies and agencies can:

• upgrade capacity for monitoring, information sharing and enforcement;

• take proactive measures to disrupt IUU stocks from entering international supply chains; and

• support governance capacity in coastal developing states.

More work is needed to explore the ecological, social and economic impacts of China’s DWF fleet in developing countries, and to investigate the behaviour of transnational companies engaged in DWF, particularly those registered in flag-of-convenience states and tax havens.

Webinars, working groups and outrigger canoes

My last Thursday and Friday were quite busy, imn fact I been really bussy for the last 5 weeks actually! And this has has been a very pleasant surprise. To be honest, when this all COVID debacle started I was a bit worried how would I maintain my income, yet many opportunities arise, and goodwill was shown again to me by many people and organizations, to whom I’m truly thankful

my last slide in my webinar.

For a while now the good people of SeafoodSource was keen to have me doing one of their webinars on the fishery here in the western central pacific. I responded that my views are normally from the sea level… views from the wharf. That for the higer picture they should go to the really important people. Yet they like that angle and so “View from the wharf” was born.

But I was hesitant… I wanted to make sure, that I don't play the role as the foreigner (semi-white man) that talks about the pacific, on behalf the "locals", as having it seen back where I was born (by colleagues on my dad, unfortunately), I always been pissed off by that attitude! Even if invited by my colleagues during meetings, I try to stand behind them and support if necessary… but never talking on their behalf.  

So it was a delicate situation for me personally… So I consulted with 3 different Pacific colleagues I uphold with maximum respect because of their mana… to see if was ok before saying yes.

 Thankfully all of them were fully encouraging, which gave good reassurances… particularly when one them told me: “I never seen you talking for me… if anything you talk with me”… at the time something must have fallen on my eyes because they got quite teary… 

Anyway, it went really well…  even if it started at 6 am for me! over 500 people subscribed… and many made many questions that I, unfortunately, could not answer because of time… so if you are reading this and I did not answer… I’m sorry and please email it to me. 

The presentation recording and slides can be access from the following links
Handout Link: https://divcomplatform.s3.amazonaws.com/www.seafoodsource.com/images/d76dda9ad9573ace0a75675801451a32.pdf
Recording Link: https://divcom-events.webex.com/divcom-events/lsr.php?RCID=5800325bba835e1a486411f982b6aba4

Then from the presentation straight to the online FFA MCS working group, that is one of the many meetings we do in the region that moved online. Here is wehre the planning, discussion frameworks, new issues are discussed amnong the MCS practicioners and then send to the bosses. so is always draining

Then on Friday, I went to check on the other project I’m working on the Marshall Islands and it has nothing to do with fisheries! 

Here is the story… around 18 months ago, while waiting to debrief the NZ Ambassador to the Marshall Islands (that is based in Honolulu) on my work… I found a leaflet in regards the “North Pacific Development Fund – NPDF” that NZ MFAT has, and is primarily aimed at supporting small-scale development projects or activities of non-government organisations and community groups engaged in development activities on a non-profit basis. 

Now… Majuro lagoon is majestic on whatever definition you want to use… I and as waterman that does ocean swimming, surfing, spearfishing, outrigger and stand paddling, traditional sailing and whatever other floating distraction you put in front of me I’m a bit dismayed on how little water activities we have in Majuro… Every day when I cycle back from work to the house of the family I’m staying wit, I said to my self: man if there was an outrigger canoe club here…. it would be perfect after work thing to do.

So my only two neurons connected for once, and I thought about starting an outrigger and ocean sports paddling club aimed at promoting healthy lifestyles, youth activities and safety at sea. So, talked to my local and some NZ friends based in RMI and everyone was in, so we formed the “Majuro Ocean Sports Club”, then made a proposal and applied for the fund… and we got it!  

In the best pacific way, it took time, but the funds allowed us to buy four new 6 man canoes (waka ama as we say in NZ), 2 new single ones and one 2nd hand 3 man racing one. So on Friday I dashed up to Moana Nui were they were made (north of NZ - Tutukaka coast) to see them finished them prior delivery to the freight forwarders, to then be containerised and make their way to Majuro

Needless to say…. I’m VERY happy! I paddle a lot here in NZ and paddling is one of those sports that you do alone but in community, you don't have to pass a ball or anything like that… Is open to all ages and genders, is outside in the ocean, it fosters bonds in between people and you can be a social paddler or the most hardcore competitor and still come back to the beach with a smile and enjoy the company of like-minded people.

I guess it ties up with what I was saying before when talking about the webinar… I don't go to visit Majuro, I live there for 1/3 of the year, I have friends I work with, I go surfing with, and now we will paddle as well. I don't do stuff for people… I do stuff with people. 

And honestly I can’t wait to be out there! And another aspect to thank NZ Ministry of Foreign Affairs and Trade… not only they keep me busy with my work as Offshore Fisheries Advisor, but now also given me as part of the community the option of a healthy lifestyle and a further connection to the ocean! 

The Price of Fish - An award winning feature of the NZ Geographic Magazine

To say I find most media coverage on fisheries issues totally appalling would be an understatement*, doom sells… but does not help. So when I see (what in my opinion is) a good article on fisheries issues, I think it should be celebrated and promoted.

Frame of a picture in the article by Richard Robinson

This article The Price of Fish in the NZ Geographic Magazine by Kate G Evans with pictures by Richard Robinson won the Environmental/Sustainability award at the 2020 NZ Media Awards, it shows that hard truths can (and must) be presented yet in a constructive and not demeaning way.

Problems get fixed with toolboxes and patience, not hammers and fingerpointing, as my friend Andy Mckay said: “There are plenty of problems to fix without making it harder for everyone at the same time”

Enjoy the Price of Fish in this link (and subscribe to an excellent magazine if you like)

*and when it comes to articles on the deaths of observers and the immediate assumption that it had to be murder because it was on fishing boat, and ALL fisherman are assassins, add gut wrenching to appalling.

Defining the stock structures of key commercial tunas in the Pacific Ocean: Current knowledge and main uncertainties

I was an aspiring fisheries scientist back in the last century in Argentina, but the affair didn't lasted, you had to be very ingrained in the institution as to get a full-time job, and thanks to the union for at-sea workers, I was making the same money as sampling technician… so my work focused on sampling and data acquisition for my stock assessments colleges.

So I’m aware of the amazing amount of work they do, at the time we were just starting to work on modelling based on Virtual population analysis (VPA) as a cohort modelling technique.  I soon established that I did not had the right “connections” to get into the fisheries institution and if I had to spend the rest of my time at sea, sampling for others, I rather go back fishing in warmer seas even if I loved the job and the little I helped in modelling.

Then, while I was fishing in the Pacific (92 to 95) the level and sophistication of modelling and the mathematical understanding required, took off exponentially… by the time I came to NZ it was a different world, and I knew I’ll never catch up… so I moved on. I’m not complaining at all, but I wonder sometimes how would have that B side sounded if I had followed that path.

In any case, the whole point of the story is that I have massive respect for the people that do this line of work, and I’m very lucky to know some of the best in the region… so when a paper on the topic for WCPO tuna come up… I stretch my brain and make the best effort to dive into them. 

Fig. 1. Distribution and magnitude of total catches for skipjack, yellowfin, bigeye and albacore tunas in the Pacific Ocean between 2009–2018 by 5° square and fishing gear: purse-seine (blue), longline (green), pole-and-line (yellow) and others (pink).

In this particular (and massive) paper “Defining the stock structures of key commercial tunas in the Pacific Ocean: Current knowledge and main uncertainties” quite a few people from SPC I know and respect are among the authors and is crucial reading if you are a tuna head and what to know “where we are at” on the main 4 tuna species we catch.

I quote here the abstract and the conclusion. But as always: read the original (the discussion is excellent!)

Abstract
Tunas are the focus of significant fisheries in the Pacific Ocean, where landings of four species – skipjack tuna (Katsuwonus pelamis), yellowfin tuna (Thunnus albacares), bigeye tuna (Thunnus obesus) and albacore tuna (Thunnus alalunga) – constitute approximately 70 % of the global tuna catch. Stock assessments for skipjack, yellowfin and bigeye tunas in the Pacific Ocean currently assume eastern and western stocks. For albacore tuna, separate North Pacific Ocean and South Pacific Ocean stocks are currently assumed. In each case, these geographic definitions reflect the historical development of fisheries management across the Pacific rather than biological considerations.

There is widespread agreement that uncertainties surrounding the stock structures of these four tuna species could have important impacts on the population dynamics models used to assess their status and inform management options. Knowledge of stock structure is also essential for improved modelling of the effects of climate change on tuna distribution and abundance and associated implications for fisheries.

This paper reviews current knowledge and understanding of the stock structures of skipjack, yellowfin, bigeye and South Pacific albacore tunas in the Pacific Ocean, by exploring available literature relating to their biology, movement and spatial dynamics. As a guide for future research in this area, we identify the main uncertainties in defining the stock structure of these four tunas in the Pacific, including i) spawning dynamics; ii) the degree of spawning area fidelity and localised residency; iii) the provenance of individuals in, and proportional contributions of self-replenishing populations to, fishery catches within the Pacific Ocean; iv) linkages with adjacent ‘stocks’; v) the effects of climate change on stock structure and proportional contributions of self-replenishing populations to fisheries; and vi) the implications of improved knowledge of tuna stock structure for stock assessment and climate change model assumptions and fisheries management. We also briefly propose some approaches that future studies could use to address these uncertainties. 

Conclusions
Although current assessments of skipjack, yellowfin, bigeye and South Pacific albacore tunas within each of the WPCFC and IATTC Convention Areas typically assume that each species forms a single stock, several lines of evidence reviewed here identify the potential occurrence of multiple stocks of each species within the Pacific Ocean basin at varying spatial scales. To better define the stock structures of Pacific tunas, and the underlying mechanisms by which spatial structuring occurs, additional research is required into uncertainty needs to be reduced in understanding of spawning dynamics (including any potential fidelity to particular spawning areas), origins and mixing of post-juvenile assemblages, and the proportional contributions of spawning units to mixed fisheries assemblages.

More powerful and cost effective genetic and genomic tools, in particular NGS approaches and modern molecular markers such as SNPs, combined with complementary approaches based on otolith chemistry and parasites and well-designed electronic tagging experiments, provide a promising way forward for testing specific hypotheses regarding uncertainties around the presence of self-replenishing populations and their contributions to harvested assemblages. It is recommended that management strategy simulations and climate modelling, based on various hypothetical scenarios of stock structure, be thoroughly evaluated for each species to determine how an improved understanding of stock structure would influence the management of tuna stocks and implementation of adaptations to reduce the impacts of climate-driven redistribution of tuna species on island economies.

Awesome job guys, thank you!

Fishing Tuna (in the WCPO) in the time of COVID 19

I had to remember the book “Love in the Time of Cholera” by Gabriel Garcia Marquez, while I tried to find a title to this blog entry!

I was asked quite a few times for my opinion on the topic… yet the 1st thing that question yourself when asked about the impacts of COVID 19 in the Tuna fisheries is where to start? We have not had anything at this level ever before.

My friend and colleague “Slota” in Rabaul, working under the “new normal”

So I go back to my default setting, the one I understand the world from… and I see the tuna fisheries world not too different from the way I see fishing boats. Yet, fishing operations are very choreographed, there are many specific manoeuvring routines around each fishing day that need to be strictly followed for things to work, everyone has a job to do in sequential order and has to be done right, while being aware of the weather, swell, gear design, manoeuvring mistakes, etc Most of the times, things work alright, but sometimes they don’t and need to be fixed. 

Since in this case, COVID19 came quite fast, there were no manoeuvring routines prpeared and a lot had to be improvised, and surely while many things will come ok, but is undoubtful that some will not

In a boat, we have the bridge operations, deck operations, engine and refrigeration operations. Each of them is, to a certain extent a different “world”. Still, they act in synchronicity with each other. In the Tuna fishery, I see (and operate) in 4 different “worlds”: the office/policy, the boats, the wharf and the factories/markets. (There is also the political/diplomatic one too, but that one is way above my head, so I don't touch it). So, ill discuss the impact by parts

Offices:

The office/policy worlds are made of an annually well lined up series of meetings on various topics around the regional organisations (FFA, SPC, PNA, WCPFC and others). It’s in these meetings were policies get formulated, advice is provided and discussed, scenarios evaluated and so on. All this take place along culturally established sit-downs, negotiating agreements, face to face discussions, trust-based consensus building and so on, and being the Pacific, all is well framed by sharing food, drinks and stories. 

With COVID, that well-oiled routine built up for many years has disappeared. The travel ban took all that away and now it’s all based on virtual meetings, and the simple fact is that we all needed to learn a new “way to do things” without much preparation and very variable quality of internet, which make some of these meetings very frustrating. 

I’m sure that while some advances will be made, the region will struggle to agree on some negotiations on contentious matters. And the reality is that we don’t know when this will change. Many countries have closed their borders, and the regional travel hubs we need to go to meetings (like Nadi, Auckland, Brisbane and Honolulu) are far from being accessible.

Fishing Vessels

Longliners

The freezer longliners can also be sub-divided between those that have ultra-low temperature freezing (ULT) capability at -60°C and those that have -35 to -40°C freezing capacity, with the former commanding a price premium and then fresh small-scale longliners, all of them supply mostly the Japan sashimi market.

All what is sent fresh via airfreight went downhill fast, as it uses in most cases excess capacity on commercial flights. So unless you have charter flights picking up your fish or designated cargo planes, or you have airlines that do cargo and not only as passengers, that segment of the industry is the hardest hit. While this segment is small in volumes, is significant in value, and unfortunately is one of the few that have pacific island domestic investments.

Since 80% of the sashimi market in Japan is frozen tuna, the rest of the operators are pointing their efforts on the frozen markets as carriers and containers will keep operating. Yet -60°C and -35 to -40°C Ultra-low temperature containers are expensive and require excellent logistics to be mobilised, and that capacity is not in all ports.

The bulk of frozen catch (70-80%) imported in Japan is sold outside the auction system to trading companies and processors. China and South Korea have considerable sashimi-grade processing capability, with much of their frozen processed product also exported to Japan.

Furthermore, Japan was storing a lot of frozen tuna for the Olympics that were to start un July. With the delay of a year, surely prices will go down as expected demand is not there and importers need to do their numbers on how much will it cost to keep the fish frozen for another year. I cannot see the sector recovering soon.

Purse Seiners

One assumes that being all frozen fish, there is little impact on fisheries operations, vessels come to port only to unload and tranship, and there are many measures to limit human interaction. Most of the resupply of food and fuel to Purse seiners is done from carriers and bunkers with little human interaction. Stopping fishing wasn’t an option since as we will discuss further below, demand has soared 

But then there is also a more complex issue, purse Seiners require 100% observer coverage and is not happening. Ideally one could have asked the vessels to not change crew on two weeks before coming to port and only take observers from the four main ports in the regions that are all COVID19 free (RMI, FSM, Kiribati and Tuvalu) and come back to the same port. Those countries have closed their borders, and no flights are serving the, one could have recirculated the observers from those ports only, but that option was not pursued.

This has various impacts. The 1st is that there are around 600 active observers in the region that are now out of work and income, this also extends to the transhipment monitors that are generally on-board during transhipment, and this is a harsh reality for observers in many countries in the region as it is their main source of income.

The 2nd one is that the lack of monitoring by observers will impact not only the issue of compliance (as electronic monitoring - cameras- have not been rolled out through the fleet , even if all PS have these days their own CCTV system) but also the already low data flow of biological sampling done on board that need to be used for fisheries science purposes.

Which bring us to the 3rd issue that is the verifiability of some of the MSC certification in the pacific that based on FAD free sets and compartmentalisation (i.e. separation in the storage of FAD associated and non-FAD associated fish) caught on board was done by observers. It seems that some MSC units of certification will continue based on the Chain of Custody requirements that come along with the fishery certification, but with no (or very limited) external oversight by observers or monitors during transhipment, this, of course, is not ideal as all information would be taken on face value only

Of course, this also is going to intersect with compliance issues from July onwards when FAD closure starts for three months, and while is possible via VMS manoeuvring analysis and catch composition to assess if a set was FAD associated or not, the dissuasive effect of having an observer cannot be replicated.

A further interesting further plot here is present availability of very cheap fuel at the moment. Usually, FAD free fishing implies a much biggest fuel bill, as you have to find and chase fish, instead of just go straight to the next FAD sonar buoy, that is already telling you exactly how much fish is underneath. Hence, in principle this should facilitate FAD free fish and more risk-taking by vessels in finding schools, yet without observers, it will be much harder to monitors and verify.

Michael ain’t going to a hospital… even if he is a frontline worker

In the region’s ports the situation is not easier either. The distribution of transhipments in the region moved from the traditional model of convenience and services to one where ports have undergone different degrees shutdown or temporary measures in the last two months or so. Each port has their own ways to deal with vessels, which impacts port operations. Those involved in the logistics of landing and transhipments need to follow the port situation on a day to day basis waiting for news that a particular carrier may enter a specific port and try to continue transhipment as normal. Hence the whole process is quite inefficient, and inefficiencies mean cost and money in tuna, the industry would have welcomed a more standardised approach among the main transhipment countries as they are all PNA/FFA members/

From the fisheries and boarding officers side, the whole process of incoming clearance for vessels has gotten substantially more complex in particularly for those countries like RMI who are applying Post State Measures best practices, in particular pre-arrival intelligence analysis… for example, if a PS vessel wants to come in, they have to track its fishing routes back to January 1. If it bunkered or came alongside any vessel during the current trip then they have to track the routes of those vessels back to Jan 1 as well. If compliances issues are found, the whole dynamic of inspection onboard has changed, as boarding officers will need to get the bridge or engine room to collect evidence, under really logistically complex situations, as all human contact is avoided who you are going to interrogate for evidence. 

This situation is better exemplified by the words of one of my colleagues: 

“The biggest worry is that there are no fisheries officers physically present in the entire fisheries operation anymore. A vessel can literally catch 1,000 silky sharks, not report them, tranship them to a carrier and it will all go unseen, very very easily (just an example but I do not at all believe this is going on). As a boarding officer as well, it feels really weird not showing a presence by going on these vessels and just checking them. Yet they are fishing in our waters and transhipping in our lagoon. I understand the situation and the importance of the economic benefit to our country by allowing the operation to continue as best as we can, but as a boarding officer, it's like an itch on your back you can't reach.”

Factories / Market

People panicked to buy shelf-stable food, and tuna is a tested and trusted choice, I heard that tuna cans and pouches shelf in the developed world were emptied fast, this, of course, means that brands put more orders and that rises demand.

Now the fragile point in the value chain for me is processing as tuna is really labour intensive; you need lots of people to process tuna, that is the reason why the canning countries are mostly countries with cheap labour – Thailand, Ecuador, Vietnam, etc. Even in the most developed countries that have the most automatized production lines (i.e. Italy, Spain, France) you still need quite a few well-trained people to run those fancy machines and retorts.

Processing is then pushed for products, yet on the other side factories are really wet environment, and while as much as personnel hygiene has improved in the last decades, I see two problems arising that will impact production: 

• the requirements of “personal distancing” in-between people in the workplace 1 or 2 meters in between people? Processing lines are normally elbow to elbow… so if you have fewer people that means less production.

• people working in processing will get sick, and put in quarantine or self-isolation, and by tracing the people that work with them, so absenteeism will be increased… and if you have less people that means less production. 

As the tuna value chain is not really tuned, you’ll have more fish caught and waiting to be processed that the quantities been able to be processed, so coolstores will be full. As consequence carriers can’t unload and liberate space, PS will be full and waiting at transhipment ports (like last year in May when we had 38 PS in Majuro) therefore prices will go down and fishers will get paid less

For factories in the pacific region, the situation is a bit different as other than PNG there has not been COVID cases, yet they have increased distancing and in and out controls which in turn does affect production.

For example Kiribati, KFL operates at around 5o% in the month of April and only frozen and expected to further reduce its operation if the lockdown continues. PNG is back to about 80% capacity (industry), Solomon has scaled down on the workers and continue to process and export to EU, but low supply has affected them. In Fiji, Yellowfin longliner based companies are barely operating, while frozen albacore loining (Viti Foods and Pafco) are experiencing increased demand on their products and have been operating on 6 days per week....

The challenge is lack of raw materials is varied for different segments of the industry, biut the big question is will we get back (and when) to “normalcy”?

A further area of complications is documentation, as many markets require originals in paper of Bill of Lading, Health and Catch certificates, business documents etc. as there are no income and outgoing flights, courier companies are not operating and those documents cannot leave, yet on the market side, import clearing officers (that already have problems knowing where some pacific countries are), seem to not believe that some pacific island countries are literally close to all flights.

Finally… as they say: from crisis opportunities arise and we have learned that: 

• while sometimes frustrating, technology has enabled us to have meetings and discussions globally without the need for more carbon footprinting - a lesson learned on what is "essential" travel 

• Improved Communication is needed, the fishing business revolves around the RFMO and regional organizations framework, in times of crisis it shows the inefficiencies which may be improved between all members. (e.g. establishing practical requirements on observer coverage, port entries and transhipments) 

• Improved medical support/infrastructure for the island nations. Key to the port restrictions was that PICs simply did not have the resources or even available medical facilities to deal with a single case of transmission, therefore, forcing the country to take drastic measures against vessels entering their port, while at the same time these vessels are the basis of their national income.

In conclusion, we are not discussing what is impacted or not, we are discussing the differential extent of the impact in the different areas. Furthermore, people are trying to assess (with very limited tools) the impacts around the areas we can’t really see yet. 

If it helps as anecdotal evidence, I have never in my life finished so many meetings (albeit being all online) with the words: “well… let’s see what happen”… and that can’t be good in the long term.

Blockchain application in seafood value chains - A FAO study

Back to the first boat I worked to today, I’ve been an incredibly fortunate man, in my very limited set of “rules” about life, the 2 things I despise the most are ingratitude and pretentiousness. So I could not start this blog about my latest publication without being thankful to FAO.

The new “net” in fishing

All the way back to the FAO training, I attended in Mar del Plata Fishing School aged 19, to all the books the sent me over the years, to taking me on board as Fishery Officer in Rome (to replace one of my trainers!), to later on supporting my views and ideas during the CDS expert consultation, offering me the change to co-author a book on Traceability and Compliance with my friend Gilles Hosch, to inviting my work on the development of the crucial (yet controversial) guidelines on social responsibility and to now on co-authoring this study on Blockchain application in seafood value chains.

I learned from them that there is substantial strength that comes from diversity and that offering people an opportunity has literally no price. That is the reason I’ve foster co-authoring, Gilles invited me because we come from different backgrounds but he trusted my vies and experience, when it was my turn with social responsibility I asked someone very different background to me for help; Katrina Nakamura’s angles and knowledge open crucial avenues of work I would not have recognised and even less developed by myself.  

So when approached to investigate the applicability of Blockchain to seafood value chains, my first reaction was to bring a totally different perspective to my one, and I was very lucky to know and have the trust of Kenneth Katafono, who has been working blockchain and IT for a while besides understanding fisheries from his work at FFA. Furthermore, being a pacific islander his views on the real potential and limitations of high tech, in remote and generally low-tech environments is crucial.

And while I came across many people don’t consider a big deal writing a work where your name and the FAO logo are on the same page. I say fair enough… yet most of those were people from developed countries and all of them urbanites. I grew up seen the FAO logo in trucks, books and initiatives that dealt with something those people are very lucky never had to deal with: hunger and underdevelopment. For people like me and Ken growing up in remote places and small villages, with subsistence agriculture and fisheries as nearby realities, and being the lucky ones to go to school and then study… Having our names next to the FAO logo is (and it will always be) a big deal!

Anyway… back to the publication (download it from here) the abstract pretty much says what we did: 

"This publication establishes supply chain traceability as the substrate over which digital solutions need to operate. It provides a comprehensive introduction to blockchain, and covers smart contracts, explores how they relate to blockchain with an example of their use in seafood value chains, and then examines major development and operational considerations for blockchain applications. The publication also analyses the seafood supply chain with considerations on flag, coastal, port, processing and market States. It identifies general control elements (critical tracking events and corresponding key data elements) that form the basis for traceability monitoring and acquisition and summarizes suitability for blockchain. It also investigates considerations for legality, transparency, species fraud and food safety.

The strategic fit of blockchain technology in seafood value chains is further investigated, with review and analysis of seven initiatives/projects. The publication then provides a key analysis as to whether blockchain for seafood traceability is the right tool and a comprehensive investigation of operational of blockchain. The publication concludes by providing a set of potential trade and public policy implications and recommendations" 

Our recommendations are:

From this study, it transpires that all current initiatives are private-industry-based and only cover part of the value chain for specific operators in the market, but none encompasses a whole fishery for a specific type of State, and nor are they compulsory as a form of generalized official market access, hence requiring integration across different authorities in different jurisdictions. Therefore, the potential of blockchain for official-guarantee-type, market-access systems such CDS and/or health certifications has yet to be tested.

While the technology has well-established examples of successful implementation and is constantly evolving, implementation is secondary to having an integral and well-developed traceability along the value chain. Hence, prior to deciding which technology is to be used, it is critical to define what data are to be acquired and to determine the sources and jurisdictions involved at each type of State in function of the extent of the traceability system to be built.

 For these to happen, all types of State (flag, coastal, port, processing and end-market) have essential roles in the implementation of traceability mechanisms that can be supported by blockchain, but as yet are operating under other technologies. Some responsibilities and duties are directly related to the implementation of rigorous traceability mechanisms, whereas others are only loosely related – but together they provide the conditions in which traceability functions can be enforced.

In fact, blockchain-based traceability may work best in fisheries that voluntarily intend to demonstrate their compliance to laws, management rules, and consumer demands, or in ones that are looking for a self-controlling mechanism to foster trust among competitors.

 Because fishers may want to organize themselves to reduce conflicts and improve trade opportunities, such systems may even evolve in areas where governmental fisheries is currently weakly developed or totally absent. 

The recommendation of this study for governments and international organizations in regard to the development, use and promotion of blockchain technology is to follow strict due diligence at legal, commercial and operational level prior to commitment.

Critical forethought needs to be given to the following (not exhaustive) list of critical considerations: Traceability along value chain to be covered:

• Exhaustive understanding of all possible – as distinct from desirable – supply-chain events and scenarios under consideration so that traceability can be sustained.

• Clear definition of the “critical tracking events” (CTEs) and “key data elements” (KDEs) – to be covered.

• For regulatory purposes, the segments of the analysis need to consider the administrative, logistic and legal aspects associated with the types of “States” (flag, coastal, port, processing and end-market) that have custody of fishery products as they move through national and international supply chains from harvesting, trans-shipment, landing and processing, to the consumer end-market.

• Clear understanding of the current operational and logistic limitations of the current traceability system in existence (in any).

Use of blockchain technology:

• Use a well-designed decision tree, or other decision models, to determine whether it is the right tool to use.

• If blockchain is chosen as the appropriate tool, then attention still needs to be given to:

  • operational considerations,

  • security considerations,

  • electronic data interchange,

  • regulatory uncertainty,

  • increased responsibility of the user,

  • technical infrastructure,

  • costs: design, development, maintenance, operation, integration with existing ERP, and hardware (including data capture, tagging and printing devices).

All this being taken into consideration, blockchain, with its inherent characteristics of immutability, security, and decentralization together with its smart-contract feature, has the potential to improve efficiencies and accountability in seafood value chains. Permissioned consortium blockchains, in particular, have the greatest potential in the current state of the technology to be scaled to address seafood traceability without the concerns of high energy use and slow transaction times that public permissionless blockchains have.

This study has not found limitations on the blockchain technology that cannot be overcome under the right scenario. However, whether there exists the collective will to adopt and expand an integral, value- chain-encompassing traceability system is a different matter.

The authors of the present study agree with this conclusion: “Blockchain, data mining, and AI will not stop IUU fishing, will not prevent overfishing and discarding. But they may help to make global streams of fish and seafood products with the associated flow of money becoming more visible and transparent” (Probst, 2019).

Finally, the authors of this study view as unfair the current media discourse that seems to pin the solution to multifaceted seafood value chain problems (from IUU fishing, seafood safety and species fraud to labour issues) on one data architecture tool – blockchain. This risks hyperinflating expectations on what this technology can offer, with potential operators then walking away because it does not deliver on the hype built around it.

Fraud in Ecolabels - by Miodrag Mitic

My general disbelieve around private certifications including ecolabels is not new, written a lot about it. So this week I started to think a lot on how come certification seems to be continued in the Pacific tuna fleet albeit they are operating without any observer coverage? FAD use vs free-school and compartmentalisation is already flaunted in many cases... so how would they be guaranteed now?

what you mean CoC?

My understanding is that in the case of MSC it is entirely subject to the Chain of Custody certificate that comes along with the fishery certificate requirement. Yet without external verification, the potential for fraud is there and really tempting.

And by chance, I came across the following one-pagers by my colleague Miodrag Mitic, whom I have known for a while describing why Chain of Custody certification alone can no longer support eco-label claims. The articles are a summary of lectures given to various organisations by him. He has lots of experience on the topic, in fact, he was MSC’s Supply Chain Standards Program advisor for a while. He was very kind in allowing me to transcribe his first 4 articles and I believe there are more to come on his LinkedIn page, make sure you follow them, the man knows his stuff!

I enjoy reading this work as it hits the issue of long term mass balance right in the head, with a key area that we work a lot on our CDS work with my friend Gilles Hosch. But also on the blunt conflict of interest, that implies being paid by the people you certify… I’ll have much less of a problem if they were paid by consumer organizations, as apparently the consumer seems the moral backbone of private certification work (not true in my opnion)

Fraud in Ecolabels

Selling non-certified products as certified is fraud regardless if done in error or for economic gain. The purpose of Chain of Custody (CoC) certification is to assure consumers and corporate customers that products sold as certified in fact originate from one or more certified sources. Eco-labels use CoC certification to assert that certified products are not substituted or diluted with non-certified products. However, most CoC standards simply verify that a company has a working traceability system. Eco-labels altogether make few attempts to detect fraud, which is used as the main justification for imposing the cost of CoC certification on supply chain participants. 

The inconvenient truth is that companies that perform certification fraud are almost always holders of valid CoC certificates. The possession of a CoC certificate is a precondition for being recognised as a supplier of certified products in the first place. At the many production, trading and processing points in the supply chain, the most frequent rationale for fraud is to opportunistically prevent revenue loss by fulfilling a customer order for certified products with non-certified ones. This may at first occasionally happen when a business is temporarily short on certified products. Undetected and unopposed, it has the potential become a standard business practice. 

The fraud process that begins sporadically as an opportunistic act at a farm or fishery, builds upon itself as some of the subsequent supply chain actors also find themselves short on certified products and further dilute customer orders with non-certified products. As the occurrence of fraud gradually spreads, and increasingly larger quantities of non-certified products are supplied as certified, what was thought to be a sporadic and opportunistic act of fraud of relatively small significance can result in a disastrous snowball effect. It is a vicious circle, amplified over time as more and more managers learn they can get away with fraud without any consequences. 

When there is a tangible price difference between certified and non-certified products, the incentive for fraud is no longer just to avert revenue loss, but to also make an extra profit derived from the price difference. Certified products are diluted with non-certified ones and sometimes substituted altogether. At this point I usually receive a first question from the audience: what is the prevalence of certification fraud? A comparison between the supply capacity of certified primary producers upstream and the quantity of products sold as certified downstream in the supply chain, minus conversion losses, yields an estimated quantity of products that are fraudulently sold as certified. 

Nothing prevents eco-labels to estimate the prevalence of certification fraud in their supply chains. On the other hand, should they choose to disclose the estimated quantity of labelled products fraudulently sold as certified, they would also have to declare the control measures put in place to adequately prevent fraud, and appropriate management control procedures to ensure their effectiveness. Many are in competition with other eco-labels and do not wish to "antagonise" consumers and corporate customers with bad news. A sensible first step is to introduce control measures to detect fraud and evaluate their effectiveness prior to making further improvements. 

Chain of Custody and Traceability 

Certification fraud has become a common occurrence in many agriculture and food supply chains. Chain of Custody (CoC) certification was initially introduced by eco-labels to assert that certified products are not substituted or diluted with non-certified ones. The inconvenient truth is that companies involved in certification fraud nearly always hold valid CoC certificates. This is a paradox given that eco-label integrity was the stated reason for imposing the cost of CoC certification on supply chain participants. The time has come for CoC standards to focus on detecting certification fraud rather than verify the functioning of traceability systems and sloppy mass balance calculations. 

Traceability and CoC are often wrongly considered as identical. These are two distinct systems used for different purposes. A product can be perfectly traceable and yet fail the crucial CoC requirement for segregation between certified and non-certified products. While traceability concerns multiple product content and/or production process attributes, CoC is exclusively concerned with the certified origin attribute and segregation from non-certified products. Traceability is used to mitigate the negative consequences of safety or quality failures by means of targeted product recalls, while CoC is used to mitigate the risk of certification fraud. 

Records created in traceability systems are important because they are used in CoC audits to identify suppliers and quantities of inputs received, composition of production batches/lots, and customers and quantities of outputs shipped. While a functioning traceability system is a pre-condition for CoC certification, it does not prevent a company to fraudulently sell non-certified products as certified. A work order that stipulates the use of certified inputs can be ignored. Warehouse records can be manipulated to dissimulate the disparity between certified and non-certified inputs. However, commercial and financial records are more consequential and risky to falsify. 

CoC audits should spend much time on mass balance calculations to detect fraud. Performed as input-output reconciliations, they are currently carried out on a single production batch/lot or short time-period because of time constraints imposed by audit duration. To become an effective fraud detection tool, the calculation should cover the entire fiscal year and include certified and relevant non-certified inputs and outputs. The emphasis must be on establishing the quantities of product input and output flows via financial records and comparing them with storage, transformation and shipment records minus conversion losses. Eventual discrepancies will have to be explained. 

Unjustified inconsistencies between financial, commercial, logistics and production records should result in penalties and loss of certification. If centred on a meaningful input-output reconciliation, CoC audits would change their focus from inspecting traceability management systems and procedures to fraud detection via mass balance calculations. Given that traceability is verified in food safety certification schemes already, verifying it all over again in CoC audits is a duplication. Traceability systems should have to be verified in CoC audits only when a company cannot produce a valid certificate from a recognized food safety scheme or in a separate traceability audit altogether. 

 Trustworthiness of Eco-label Claims 

The only assurance that current CoC audits can realistically provide is that on the day of the auditor's visit the company had a traceability management system and segregation procedures in place, and that the auditor could trace-back one certified product to its immediate suppliers. Traceability is not verified back to the certified primary producers upstream, just one-step-up in the company's supply chain. Because of time constraints a quick input-output reconciliation is conducted for a single production batch/lot or short time-period, and is usually only based on storage and transformation records rather than a full set that also includes commercial, financial and shipping records. 

Unannounced audits are not worthy of their name because they are always announced several days in advance to ensure access and presence of relevant staff. Companies can thus arrange to have what is required to demonstrate compliance with CoC requirements on that day of the audit and do as they please thereafter. They are allowed to shop around for less rigorous certifiers. Considering that the main audit cost element is the auditor, the certifiers who charge the least usually employ the most junior auditors. Moreover, the certifier is never truly independent from the company it audits because the two have a commercial relationship identical to a supplier and customer. 

This situation could dramatically change if companies seeking certification would pay the audit fee directly to the eco-label, which would contract and supervise the certifiers. The company seeking certification would no longer decide who performs the audit and there would not be any economic relationship between the certifier and company it audits. Additionally, traceability systems could be audited separately as a pre-requisite for CoC audits. These could then concentrate on performing a mass balance calculation covering an entire fiscal year that includes both certified and relevant non-certified inputs and outputs. This could eradicate nearly all fraud from eco-label supply chains. 

Successful eco-labels generate millions in logo licensing fees, push their own advertising narratives onto consumers, and are well integrated with marketing strategies of the brands they serve. The key barrier to change is that eco-labels are not financially impacted by certification fraud as long as consumers continue to unknowingly buy non-compliant products. Whilst aware of supply chain certification fraud, eco-labels do not publicly quantify nor address the subject in fear of antagonizing consumers and jeopardising logo licensing revenue. In such a reality, a more tactful and gradual approach is required to initiate the reform of CoC certification. 

While self-serving interests stifle most attempts to quantify and address the scale of certification fraud, a possible way forward is to improve the quality of CoC certification in incremental steps. The bare minimum is to introduce unique identification of certified companies, certificates, certifiers, auditors and audit reports to lay the foundations for future monitoring and analysis. Authentication of certificates, identification and labelling of shipments, logistic and trade units, and mandatory requirement to match quantities of certified products received with quantities stated in delivery documents and purchase orders can improve the credibility of current input-output reconciliations. 

Certification fraud is a well known risk to eco-labels.

They encounter it on a regular basis in what many believe are isolated events of small consequence. Most decision makers come to this conclusion without studying the effectiveness of CoC audits or conducting a formal risk assessment. Experts know that if the supply capacity of certified primary producers upstream is considerably less than the quantity of products sold as certified downstream then the eco-label has a real problem. When left unattended the scale of the problem can reach enormous proportions over time. It is an unrewarding subject for staff to address because it runs against eco-label's marketing narratives. 

Experts are also aware not only that certification fraud is a complex problem to solve, but also that it is likely to be exposed to the public eventually. While the precise nature and timing of such an event is not predictable with high probability, the severity of the consequences are. When the scandal erupts the brands that display the eco-label on products will most likely turn against their suppliers and blame them. Because the suppliers are required to have valid CoC certificates in order to supply the brands, they will involve the certifiers who will defend the certificates they issued. The spat may quickly spin to CoC certification, expose its deficiencies and point the finger towards the eco-label. 

In such a scenario due diligence is the eco-label's best defence. To be successful it has to demonstrate that risks were identified, assessed and systems put in place to prevent certification fraud. But are they really? Eco-labels are hesitant to address fraud in fear of undermining their marketing narratives and antagonizing the brands they serve. The good news is that it is absolutely possible to discreetly assess the risks and improve the effectiveness of CoC certification in incremental steps by adding an integrity assurance component to it. The first obvious step is to identify the supply chain risks, and then develop and implement appropriate mitigation measures. 

The known CoC risks are: a) erroneous or deliberate substitution and dilution of certified with non-certified products, b) auditor competence, c) auditor integrity, and d) counterfeit certificates. Given that companies that perform certification fraud are nearly always holders of valid CoC certificates, it is necessary to analyse the audit reports issued over the past few years to determine the baseline from which to draw the levels of risk and required monitoring for each certificate holder. The level of risk is determined by spotting a pattern of signs that point to the probability of erroneous or deliberate substitution and dilution of certified with non-certified products and substandard audits. 

The indications that can land a company on the high-risk list usually entail a history of sanctions, complaints, investigations, repetitive non-conformances, high staff turnover and/or change of certifiers. The volume of certified products they buy and sell, as well as auditor, customer and supplier profiles also play a role. Risk mitigation measures for high-risk companies include research (know your customer), visits to obtain firsthand information (human intelligence), company news monitoring, observation of audits, and when appropriate re-audits by the integrity assurance team. 

What happened with FAO’s draft guidelines on Social Responsibility in Fish Value Chains?

I have been asked a few times lately what happened with my work developing FAO’s draft guidelines on Social Responsibility in Fish Value Chains that were discussed at the FAO’s Committee of Fisheries – Subcommittee of Trade meeting in November last year in Vigo.

Sorry we still fail you!

I think is good for me to remind that I was contracted to develop draft guidelines for consideration, and I requested my friend and colleague Katrina Nakamura to be my co-developer on this, as some of the most novel ideas I hear on that topic come from her.

I wasn't in Vigo at the time because I was working Majuro and wrote this. But FAO just published the report on the meeting and their words on the topic are pasted below.

As I got to know a bit of what happened on the inside via some delegates and friends in Vigo I will comment further down on my frustrations on what happened. I just will mark in italics the areas I fill I should comment from the content point of view and some on my fears on what’s is going to happen with this fundamental topic. 

From my perspective are 3 components to this work: content, process and politics… I just will discuss content and a bit of the politics, the process is FAO’s own and while I have heard comments on the capacity by countries to influence the process as to get to the guidelines, all that is way above my understanding so I leave for others to analyse. I’m totally partial to FAO, they changed my life for better more than once.

The section in the report says: 

69. The Sub-Committee noted the work presented by the Secretariat in document COFI:FT/XVII/2019/13 and acknowledged the efforts of FAO for the broad and inclusive consultation process leading to its development. 

70. The Sub-Committee recognized the importance of social responsibility in the fisheries and aquaculture sectors, and noted that it is a wide-ranging topic. The Sub-Committee highlighted that this area of work is not within the core activities of FAO and requires close collaboration with other relevant specialised agencies, including ILO, IMO and OECD to be consistent with relevant existing conventions.

71. The Sub-Committee reiterated that any work in this area should be fisheries sector specific and technical. The Sub-Committee also called on FAO to ensure the language used reflects the voluntary nature of any guidance.

The Sub-Committee also stressed that results of this work should be non- binding, inclusive, practical and provide tangible guidance to assist fisheries sector actors in applying and implementing existing relevant instruments and guidelines, where appropriate, in support of social responsibility, and include a focus on trafficking in persons and forced labour practices on fishing vessels. The Sub-Committee reiterated that all stakeholders should continue to be engaged in the work of FAO. 

72. In order to address these concerns, the Sub-Committee recommended the Secretariat develop a scoping paper to further contextualise the fisheries sector specific issues and to identify the potential role of FAO, in consultation with Members. The Sub-Committee requested the scoping paper provide a clear outline of the major challenges and identify the key stakeholders, including their roles, core competencies and mandates, and references to relevant existing international instruments and tools, as well as identification of other ongoing work and processes. The Sub-Committee requested the paper be provided to the next session of the Sub-Committee for guidance. 

so here are my views

“this area of work is not within the core activities of FAO”

I heard that so many times “is not fisheries issue”… while I recognise that from the legal side there is an argument there… it is a fisheries issue! Every time there is news about the labour and human rights abuses on vessels… people don’t go: Ohh look how bad the labour authorities of the flag state are affecting the good name of the labour standards! They go look another are of shit performance by the fishing sector! So it occurs on fishing vessels and affects the public perception of fisheries, and in today’s world, public perception is very important are that is unwise to further ignore. So yes… I believe is part of FAO’s Fisheries mandate to assist the sector on navigating this complex area, without creating new requirements, but just researching and presenting the existing ones under the UN, ILO, IMO and OECD in way that easier to follow (which is exactly what we did).

 “that any work in this area should be fisheries sector specific and technical”

We divided the guidelines in a core (common factor) requirements and then specific appendixes: Small-scale fishing, Industrial fishing, Aquaculture production, Processing, Distribution, Retailing… now how further specific can you get!!! 

“called on FAO to ensure the language used reflects the voluntary nature of any guidance”

I quote here: Section 2: Nature and Scope. 2.1.This Guidance is voluntary in nature. 

It was the 1st thing we said!!!! How else can we say it? Could you please, if you don't mind, and have the time, as I know you are busy, and you have to play golf with your friends… but… you know… just if have the time.. the exercise your responsibility under all these international agreements to promote human and labour rights, including decent work? Sure, I wait after you fishing your beer.  And yeap… we hear already that you “stressed that results of this work should be non- binding” 

The draft said in black and white that the guidance was a resource for voluntary use assisting this purpose.  FAO is not a labour enforcement agency, but it can assist member countries to agree on targets and mechanisms.  Here it was simply putting forward what is in the internationally negotiated and agreed instruments

“clear outline of the major challenges and identify the key stakeholders, including their roles, core competencies and mandates, and references to relevant existing international instruments and tools”

Which is exactly what we did!!! The guidance compiled the requirements already in force. FAO did not need to define anything.  The anti-slavery / forced labour requirements, for example, are defined in conventions which are universally in force, whereas workplace minimums are defined domestically but linking to the Declaration of Fundamental Principles and Rights at Work.  The guidance draft clarified these things and the different things that fish companies and governments are required to do, based on what already is legally in force. 

But obviously some there don't want to see it….

Yet the excuse was the language… as NFI (US industry body) boss  J. Connelly told SeafoodSource. "We were a bit surprised that the language had turned from voluntary to a lot of, in shorthand, ‘must, shall, will be obligated to, required’ ,". "It just concerns governments enough that they talked at moving it forward in its current form ... They expected it to be voluntary guidelines to these countries."

However, as I explained the draft guidance explicitly states in the first sentence of the section describing the nature and scope of the work, “This Guidance is voluntary in nature.” Later, it says, “Nothing in this Guidance prejudices the rights, jurisdiction, and duties of States under international law.”

So in reality, things are stalled… till next year

350 USD a month, 3 year contract

For me, the only reality is that guys like Salim in this article I recently wrote earn 350US a month on 3 years not going home contract while working in a US-flagged Purse Seiner in the WCPFO, yet if he was from a developing country he would earning 4-5 times that and it would be illegal not to repatriate him for holidays. (I was earning that for the same job over 20 years ago!)

Yet, these guys never make it to the meetings where their life is discussed… as Nasim Taleb said: “Those who talk should do and only those who do should talk.”

My fear is that all this will then fall into the hand of private certifications… which I would not have a problem if they were paid by consumer organizations. But as in the case of ecolabels are paid by producers, which are being the clients of the certification companies, are firstly in a conflict of interest, but what is worst, allow for the continuation of the problem since the flag states do not take on the responsibilities they should… at the end of a day, fishing boat is an extension of the territory of the state they are flagged, and therefore everyone on board should be under the labour regime and unions that applies to that country, which have to be equivalent to those we enumerate in the FAO guide.

Furthermore, and while at least is great that there is an interest in making sure that a deckhand rights around earning 350USD a month are protected, the systems do nothing to a situation one could argue strongly that it fits under the definition of exploitation of labour.

And if they don't… then they have to comply with coastal state conditions as we did with FFA MTCs, or being made public the consumer know who not to buy from.

Honestly if not to hard to find the standards already agreed and make them comply, there is plenty of information around that…

All this saga reminds me of something that and old colleague told me in one of the first trips fishing aged 18… “at the end of day fishing is a bit like a chicken pen… the chicken at the top shits on the one below… and below fishers is only water”

Finally, for me personally it is important that we don’t pity Salim and many other thousands like him in many jobs in the world. Pity the circumstances they live in, and shame the operators that exploit those circumstances.

People like Salim are some of the most resilient, positive, nicest, innovative and determined people I have ever met and worked with. Without these qualities, they wouldn’t be alive