hypocrisy, cherry-picking information, and singling out a particular form of food production by Francisco Blaha

As I have said many times before, any form of food production has an environmental impact, full stop. 

The only way to not have an impact is for all of humanity to die at once, everything else implies some form of compromise. This applies not only to all forms of food production but also to urban development and so on. 

My mate Jan before boarding for a sampling trip in a NZ coastal trawler

My mate Jan before boarding for a sampling trip in a NZ coastal trawler

Personally I’m very interested in minimising my carbon footprint, so I cycle as much as can, I don't use any form of engine when I go spearfishing, I produce food in my garden, and so on.

But then my bicycle is made of mined metals, many parts come for oil derivatives, as it is the fiberglass of my canoe, my speargun, my wetsuit, and so on. The paddles and the boom of my canoe are partly made from wood that was cut from living trees, where my house stands there was native forest less than 500 years ago… and I’m not even bringing in the flying I have done for my work on controlling fisheries. We all have impact… how much we do is a matter of personal choice and public policy.

Fisheries do have environmental impacts no doubt… yet when I read or hear this usual argument against trawling for example: 

“Imagine if the native forests were bulldozed in at least part of them, and in all wetlands, dunes and alpine areas… the public reaction would be swift and visceral”.

And I look outside my window… and that is what I see!! Houses and farmland! If you fly from over NZ other than National parks and areas that are useless for agriculture… that is what we have done!. We almost eliminated all native forests to plant and grow introduced plants and animals and made cities.  And where is the swift and visceral and public reaction? 

My colleague and friend Andy McKay among other many talents is an oracle of information, and many times I found each other confronted by the same rhetoric. He recently posted some data in regards to the impacts of the issues discussed above… 

In comparison, trawling (that no doubt impacts benthos, yet in different ways, under different types of bottoms and gear configurations and depths) is really limited using the usual parameters of comparison. Andy did some figures from publicly released data from Fisheries NZ for 2019 via a OIA

I’m all for minimising our environmental footprint, but not from a point of hypocrisy, cherry-picking information, and singling out a particular form of food production because is the one you understand the least and/or dislike the most.

Yes fishing does impact nature, yet even in the arguable most fished area of the country, the Hauraki gulf (by commercials and recreationals), at the doorstep of the of NZ biggest and richest city, at a beach that is accessible by public transport less than 30 km from downtown (and 200m down the road from my home). I see at least 10 to 20 times a year dolphins frolicking, kahawai boilups, all sorts of birds diving for baitfish, stingrays cruising the sands while I swim above… In the meantime, I challenge anyone to find tuataras, kiwis, or any NZ native species in the same numbers at any farm in the country… let alone one at 30 km from downtown Auckland.

We all have to do better, and fisheries have a lot to do! But if you take the bias out, some fisheries are doing comparatively better than many other food systems that do not get the level of criticism (and hate) that fisheries get.

If you buy a ecolabeled fish, is it guaranteed not IUU? Yeahh.... Nah mate by Francisco Blaha

My views on Ecolabels are quite open and I’ve written in extent about it… many issues… yet the main one is that they push the myth that a fishery is sustainable because it has certification when in reality is the opposite… it is sustainable because the action of concerned governments and RFMOs and therefore it can get an ecolabel (as long as they industry pay, of course

he is the one that defines legality of catch….he does not work for a ecolabel, nor he gets any benefits from it

he is the one that defines legality of catch….he does not work for a ecolabel, nor he gets any benefits from it

Let me use 2 examples of fisheries I know well

 Hoki in NZ. Was one of the first certified fisheries in the world, is the most analysed fishery in NZ, it has almost yearly stock assessments, etc… is not sustainable because of the ecolabel… The idea that a certified product may get a price premium is not a golden rule; furthermore, the logic of that assumption is flawed. In New Zealand, we have argued that the industry should not even expect a price premium for certification noting that: “No plausible case can be made for a premium for ‘sustainable seafood’. If anything, a well-managed fishery should also be a cheaper fishery to harvest as the fish should be more abundant and easier to catch!”

The other example is Tuna in the pacific… For example, I work a lot in the transshipment hub of Majuro, and I have been many times in situations where I see very similar purse seiners transhipping to the same carrier - both fishing vessels catch the same tuna species, using the same methods, under the same management system, from stocks evaluated by the same institutions, with the same regional controls over the activities, we apply the same port State Measures regime to both…  yet fish from vessel ‘A’ that does not pay for the ecolabel process, therefore as the narrative goes, is not sustainable? While fish from vessel ‘B’ that pays, is?

I wanted to understand well the system, so I went through the process to become an evaluator against the MSC standard and I did a pre-assessment for principle 3 (the regulatory principle)… I work on a pre-assessment of a huge tuna operator and walked away as it was fleet with various flags, I insisted that the assessments were to be based on individual flag state performance… yet even so there were vessels with the worst compliance index possible in the unit of certification (which I knew from my work with regional organizations)… but I could not use it because it wasn't offered to me by the client and I had no contact with the flag state… so I did not play that game.

Even if the origin of ecolabels is based on the assumption that fisheries administrators in particular those from developing countries) are not doing a good enough job… during my work with many fisheries administrations in the Pacific I have spent 2-3 days responding to the questions of the consultants that have come to ‘assess’ the fishery for certification… so in effect, they come for data to the people and institutions that the ‘consumer’ does not trust! That irony for me is mind-blowing. If you really want to help, why not just support the official institutions in the countries whose job and whole existence is to manage fisheries in a sustainable way?.

I have lived with the hypocrisy of that narrative for a while… but a paper that I just read takes it much further by suggesting that the certification has a role in ELIMINATING IUU fishing… and I don't buy that

I don’t get pay to criticise papers so I not gonna spend to much time on it (unless someone here wants to pay me for a detailed analysis)

Firstly I start with the fact that 8 of the 11 authors work for the ecolabel they are promoting and one of the reviewers was the boss of that ecolabel, they do declare that conflict of interest, which is great… but what does this mean on the value of unbiased information? Personally, I think the views presented by the authors of that work could be perhaps more a promotional article for the ecolabel, then a science paper.

Now I want to be very clear here… I not questioning the capacity and professionalism of any of the authors and reviewers, they are all way more qualified than me by far… I’m just a self employed dyslexic ex fisherman with a couple of degrees from unknown universities that works in the MCS realm, I’m writing this as the total nobody I am and my opinions are personal, they don't represent at all the ones of any my contractors.

You can go over the paper if you like, from the operational point of view there are three components to the IUU concept. They are not mutually exclusive, but also can occur independently. A simplified “definition” of each of the concepts follows.

Illegal fishing is conducted by vessels that fail to comply with the licensing conditions put upon their operations, types of gears, access restrictions and so on, by their own legislation, the legislation of the coastal states whose waters they fish in, and/or are parties to a regional fisheries management organisation (RFMO) but operate in violation of its rules, or operate in a country’s waters without permission.”

Unreported fishing is catch that is either not reported or is misreported to relevant national authorities or the RFMO. (As reporting accurately is a licensing condition, to a certain extent unreported fishing is also illegal fishing.)

Unregulated fishing is conducted in areas or for fish stocks where there are no applicable conservation or management measures and where such fishing activities are conducted in a manner inconsistent with state responsibilities for the conservation of living marine resources under international law. (Conservation and management measures are rules set by an RFMO that govern fishing in its jurisdiction.) This term also covers vessels without nationality or flying the flag of states that are not parties of relevant fisheries organisations, and which therefore consider themselves not bound by their rules.

 So, the first two are related to each other, and unregulated fishing is much rarer these days. There are only a few areas of the world that are not under the management of an RFMO, one of them being the South Atlantic off the coast of Argentina beyond the country’s exclusive economic zone.

So if the fishery is unregulated or performed by vessels without nationality, then chances are that the P1 and P2 would of the MSC would not have data to start… furthermore the operators in those fisheries would not even thinking to pay for a certification… so to suggest that the ecolabel has a role there is rather flimsy.

In terms of Illegal and unreported, the key issue here is that they happen during the fishing event, they happen at sea every time the vessel operates… how does a certification that is reviewed every 3 years or more can check every fishing event. Let me use the Pacific tuna case, where different state actors are involved. Some responses rely on the national legal frameworks, which may need improvement, while others rely on regional organisations such as FFA, and international frameworks, as is the case of RFMOs.

For us in the WCPO, we have robust systems based on the unique coastal-state cooperation (via the Forum Fisheries Agency and the Pacific Community) that marks our region. We use common tools, like the shared registers; the vessel monitoring system; shared surveillance operations with the support of the USA, France, Australia, and New Zealand defense assets; and so on.

These tools have been in use in our region for a couple of decades now. Therefore, we have achieved a solid level of control over the common understanding of what illegal fishing is, and, as said, unregulated fishing has not been a problem in the region for many years.

The FFA 2016 IUU fishing quantification study (currently being updated by way of IUU mitigation progress report) showed that the key area of problems for us is unreported fishing. This can happen in different individual or combined ways, including non-reporting, misreporting (saying you caught A, when in reality you caught B) and under-reporting (declaring you got 50 when in reality you caught 70).

So, this is the area we are focusing on in the WCPO, through a series of initiatives and innovations such as strengthening our port state measures, monitoring transhipments with remotely read electronic hook scales, catch documentation schemes, and electronic reporting and monitoring, just to name a few. All of this is under the jurisdiction of the national agencies (those that by principle consumers don’t trust) 

In the region, the legality of the catches is verified by the PSM systems prior authorising unloading (we check identity, licensing and maneuvering) and is the same for vessels that pay for the certification or don’t. No one from the ecolabels has any role in this… if the officers fail the fish goes straight to the consumer

As per unreported… we have monitors that crosscheck the volumes with scales against the logsheets and then as part of the catch certification process… and again is the same for vessels that pay for the certification or don’t. No one from the ecolabels has any role in this… if the officers fail the fish goes straight to the consumer

The one I give them is that they have a “chain of custody” (CoC) which could stop the laundering of fish (mixing reported fish with unreported fish) in the factories. CoC is required to maintain certification in regard to the integrity of the product bearing the logo of the ecolabel, particularly in the case of purse-seine caught tuna certification, as vessels fish in the same trip both certifiable products (FAD-free) and noncertifiable products (FAD-associated).

The issue here is that the CoC only applies to products in the wells that have fish caught without FADs in vessels that are part of the unit of certification (i.e. have paid for the certification). Is not designed to assure “non IUU fish” but to make sure the fish does not mix with fish from FAD wells or the fish from other vessels fishing the same stocks, with the same fishing gear, during the same seasons are not clients of the ecolabel. 

 Anyway… my main point is that the fight against IUU happens at sea and in port, normally by people who do not get ANY benefit from ecolabeled fish…

Let me use a parable to explain: in most countries of the world, to drive a car, you need to go through the process of getting a driver’s license run by an official institution in that country. Once you have that license, you can legally get on the road and drive a car.  How good that system depends on a varied number of reasons such as human resources, cultural values, the rule of law, transparency, etc. Obviously, there would be countries that are better than others at this. So let’s say that a country has a bad rate of accidents by licensed drivers, in comparison with other countries. So what you do? 

For me, the most logical, democratic and cost-effective solution is to set up a programme to strengthen the institution that is legally authorised to do that job in the country, standardise the licensing systems, exams and controls under auditable standards and reward conformance in some way.

What I would not do is to create a private parallel system on top of the already existing national system. Hence I, as a driver need to get through the hurdles of the official systems, and then contract a foreign private assessor and go over a whole set of new exams and tests (at my cost) to prove to people in rich countries that I know how to drive in a way they consider ‘safe’. And that is what in my opinion private certifications do: they create a parallel system instead of supporting the organisations that are supposed to do the job.

In my opinion, one of the biggest hurdles that we face in legality and sustainability is that while we want it, we allow the underfunding of official institutions and pay fisheries officers and fishers salaries that are way below mediocrity, but we expect excellence from all of them. They are the ones that have a role in IUU fishing.

FAO tell us that over 70% of the seafood consumed in developed countries comes from developing countries. Partly this is because the fisheries in developed countries have either collapsed or can’t keep up with local demand. Yet all of the ecolabels, private certifications, retailers, and most of the consumers that allegedly require them are based in developed countries. This has led me to say that I see the whole private certification scene as hypocrisy in the best-case scenario, or neo-colonialism in the worst-case scenario.

Fijian flagged vessel on a US custom detention order for forced labour, by Francisco Blaha

3DOE_HANGTON 112_03_Feb_2018.jpg

I wrote in the past about Vanuatuan flagged vessels on a US custom detention order for forced labour, this time is Fijian flagged one.

This is quite unfortunate (particularly taking into consideration the COVID crisis there), and a reminder of how much work is ahead of us to make good of the great step that was the inclusion of decent labor conditions under the FFA’s Harmonised Terms and Conditions of Licensing (HMTCs)

The use of trade-restrictive measures (TREMs), as “trade sanctions“ enacted by a market-state have aimed to the IUU side of fisheries, either by closing the market to a country (as in the case of the EU with the red cards) or to an individual vessel on IUU blacklist, the USA is increasingly using them for labour issues.

While these “name and shame” trade measures do hurt, as they bring shame to a country and are normally based on a few bad operators, at the expense of the excellent ones (like Solender and Sequest whom I worked with and are already hurting from the COVID crisis) and have a very progressive and efficient fisheries administration whom I’m proud of having worked with for many years.

Yet the truth is that they are Fiji flagged, so hopefully, this type of announcement can catalyze much-needed strengthening.

While the vessel at the center of this announcement is Chinese-owned and operated, the factual reality is that what happens on those vessels competes to the flag state authority… the present capacities of Fiji or their development status, can’t be an excuse when it comes to flag state responsibility.

There are reports that the company who at this point are denying the allegations and want to respond to US BPC… yet the bad publicity via the news this is bringing even if the company is “innocent” is quite bad.

Effective August 4, 2021, U.S. Customs and Border Protection personnel at all U.S. ports of entry will detain tuna and other seafood harvested by the Hangton No 112, a Fijian flagged and owned longliner operated by a Chinese national. The order came after the agency determined there was credible evidence that the vessel’s crew was operating under forced labor conditions

While the vessels of this company are China-owned and operated, the factual reality is that what happens on those vessels competes to the flag state authority… the capacities of Fiji 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!

Unfortunately, vessels still are in the FFA list of good standing, even if their listing by the US put serious doubts on the adherence of these vessels to the HMTCs, this event so new, I guess that listing is to be changed at the request of the flag state.

CBP issued a Withhold Release Order against the longliner fishing vessel based on information that reasonably indicates the use of forced labor in the vessel’s fishing operations. CBP identified at least three of the International Labour Organization’s 11 indicators of forced labor during its investigation: withholding of wages, debt bondage, and retention of identity documents.

“Foreign fishing vessels like the Hangton No. 112 continue to lure vulnerable migrant workers into forced labor situations so that they can sell seafood below market value, which threatens the livelihoods of American fishermen,” said CBP Acting Commissioner Troy Miller. “CBP will continue to stand up against these vessels’ abusive labor practices by preventing the introduction of their unethically-harvested seafood into the U.S. market.”

The International Labour Organization estimates that 25 million workers suffer under conditions of forced labor worldwide. The distant water fishing industry is at high risk of forced labor as foreign companies often coerce vulnerable migrant workers to perform hazardous labor for little or no pay aboard fishing vessels that may spend months at sea without making port calls.

19 U.S.C. 1307 prohibits the importation of merchandise produced, wholly or in part, by convict labor, forced labor, and/or indentured labor, including forced or indentured child labor. CBP detains shipments of goods suspected of being imported in violation of this statute. Importers of detained shipments have the opportunity to export their shipments or demonstrate that the merchandise was not produced with forced labor.

CBP has issued Withhold Release Orders on other fishing vessels, including the Lien Yi Hsing No. 12, the Da Wang, and the Yu Long No. 2. In May 2021, CBP issued a Withhold Release Order on seafood caught by a fishing fleet owned by the Dalian Ocean Fishing Co. Ltd. All Withhold Release Orders are publicly available and listed by the country on CBP.gov.

Pathways to sustaining tuna-dependent Pacific Island economies during climate change by Francisco Blaha

Once in a while, a fundamental paper get published… and you know that is fundamental not just because of what they say but who is saying it.

This paper “Pathways to sustaining tuna-dependent Pacific Island economies during climate change” has in its authorship pretty much everyone I worked with and respect in the region (i.e. Johann D. Bell, Timothy Adams, Sangaalofa Clark, John Hampton, Quentin, Steven R. Hare, Simon Nicol, Yoshitaka Ota, Graham Pilling, Chis Reid, Neville Smith and Peter Williams

Redistribution of biomass and purse-seine catch from the combined EEZs of the tuna-dependent Pacific SIDS

Redistribution of biomass and purse-seine catch from the combined EEZs of the tuna-dependent Pacific SIDS

I have written in the past about the impacts of climate change on tuna fisheries, yet this paper is putting it in very unequivocal ways… and like anything else with climate change… is not good.

I quote here the abstract, part of text and discussion… but read the original.

Climate-driven redistribution of tuna threatens to disrupt the economies of Pacific Small Island Developing States (SIDS) and sustainable management of the world’s largest tuna fishery. Here we show that by 2050, under a high greenhouse gas emissions scenario (RCP 8.5), the total biomass of three tuna species in the waters of ten Pacific SIDS could decline by an average of 13% (range = −5% to −20%) due to a greater proportion of fish occurring in the high seas. The potential implications for Pacific Island economies in 2050 include an average decline in purse-seine catch of 20% (range = −10% to −30%), an average annual loss in regional tuna-fishing access fees of US$90 million (range = −US$40 million to –US$140 million) and reductions in government revenue of up to 13% (range = −8% to −17%) for individual Pacific SIDS. Redistribution of tuna under a lower-emissions scenario (RCP 4.5) is projected to reduce the purse-seine catch from the waters of Pacific SIDS by an average of only 3% (range = −12% to +9%), indicating that even greater reductions in greenhouse gas emissions, in line with the Paris Agreement, would provide a pathway to sustainability for tuna-dependent Pacific Island economies. An additional pathway involves Pacific SIDS negotiating within the regional fisheries management organization to maintain the present-day benefits they receive from tuna, regardless of the effects of climate change on the distribution of the fish.

The projected climate-driven redistribution of tuna biomass and purse-seine catches also has potential implications for sustainable management of the world’s largest tuna fishery. In a scenario where a lower proportion of tuna resources is under the jurisdiction of the PNA VDS, the sustainability of tuna catches could be at greater risk because the monitoring, control and surveillance required to combat illegal, unreported and unregulated fishing, and impose penalties for non-compliance, are more difficult in high-seas areas. This is because responsibility for compliance with fishing regulations on the high seas rests with the states that ‘flag’ fishing vessels (often resulting in self-regulation), whereas compliance within EEZs is under the purview of coastal states. With continued GHG emissions, the onus will be on WCPFC to implement tighter controls on fishing for tropical tuna species by all vessels operating in high-seas areas of the WCPO.

Discussion

This analysis demonstrates that sustainable development of tuna-dependent economies in the Pacific Island region is likely to be at substantial risk from continued high GHG emissions. Although considerable uncertainty remains, our modelling provides sufficient information to indicate that it is not a question of ‘if ’ tuna biomass will shift from the combined EEZs of the ten Pacific SIDS but ‘when, how quickly and to what extent’. It is important that this risk be recognized by the United Nations Framework Convention on Climate Change and included in the rationale for limiting global warming in line with the Paris Agreement.

The process to identify a mechanism to eliminate or substantially reduce this risk for tuna-dependent Pacific SIDS, based on the principles of cooperation and long-term sustainability through the WCPF Convention, should also begin immediately. Ultimately, the necessary international negotiations will be facilitated by reducing uncertainty in the timing and extent of tuna redistribution and the associated impacts on catch, access fees and government revenue.

Reducing the remaining uncertainty in redistribution of tuna biomass will depend on improving tuna modelling to increase the spatial resolution (for example, up to 0.5°), incorporating ocean forcings for all emissions scenarios considered.

Model Intercomparison Project Phase 6 (CMIP6), integrating additional and enhanced biogeochemical models into the simulation ensemble for the impacts of ocean warming and acidification on the food webs that support tuna, and assessing the effects of the Interdecadal Pacific Oscillation on the onset of accelerated ocean warming. Preliminary genetic research, showing that some tropical tuna species are composed of multiple, self-replenishing populations (‘stocks’)41–44, indicates that efforts to reduce uncertainty in redistribution of tuna biomass will also be strengthened by identifying the stock structure of each species. This would enable the response of each stock to climate change to be modelled separately and then aggregated to produce a more accurate understanding of tuna redistribution from EEZs to high-seas areas.

Using Lessons Learned to Strengthen Implementation of the UN FAO PSMA by Francisco Blaha

I get often asked what is the main problem faced by fisheries… like of it was only one simple thing you can point out! I’ve written in extent about some of them: subsidies, climate change, geopolitics, poor flag state performance, CDS, labour issues, pathetic budgets for fisheries administrations, and so on… but the one that worries increasingly is that as a sector we fail to engage with new people and more importantly diversity among the people working in fisheries science, policy and MCS .

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I think I have been one of the youngest consultants in fisheries in the region for over 20 years now … and that reflects very badly on us as a sector… if you were to try to design the stereotype of a fisherman, you wouldn't fall far from a big bearded man with sun and salt dry skin that is weary of paper pushers. So you’ll come not far from me… yet if my gender, age, and background represent the only good way to do things, then how come we are facing the problems we have? How hypocritical would it be of me to not try to bring in, listen to new voices, new perspectives, new ways to do things. 

So as much as I can I take on supporting students working on fisheries issues (and I do this on a pro bono basis) this year I’m involved with 3 different masters and PhD students.

One that was just published, and I got quite involved as she was working on PSM in two countries I work with RMI for the last 3 years and Thailand (via FAO and Ocean Mind) is Chloé Gouache’s one.

Her thesis “Proposed Guidelines on Pre-Arrival Risk Assessments of Foreign Vessels: Using Lessons Learned to Strengthen Implementation of the UN FAO Agreement on Port State Measures” was also supported by the following colleagues and friends: Mark Young (whom I worked with at FFA, PEW and now IMCSn), Dawn Borg-Costanzi (whom I worked with at FAO and now PEW), Natalie Tellwright (whom I work with at Ocean Mind) and Sara McDonald (whom I worked with at Monterrey Aquarium)

PSMA is not prescriptive about the ways a risk assessment on arriving vessels should take place or how to effectively perform this risk analysis. The objective of her work was to attempt to fill this information gap and compile lessons learned from countries that have implemented a port inspection regime of which risk assessment is an integral part: Thailand and The Republic of the Marshall Islands. These lessons helped generate proposed guidelines for the implementation of the pre-arrival risk assessment of foreign vessels in the context of the PSMA. The goal for these guidelines is that they will help those countries that have become Party to the Agreement or are looking into ratifying the Agreement in the future and be used as a resource by port authorities.

It would be a substantial piece of work for MCS practitioners, let alone for someone coming from the outside… but maybe that fresh view from the outside coupled to listening and respecting those on the inside is why she nails it!

Chloé, I do hope you stay working in fisheries… we need more people like you!

I recommend you read it if you are interested in PSM implementation, in the meantime, I quote below her work closing remarks:

I- Importance of Regional Context

The regional context is key for the implementation of good Port State Measures. The Marshall Islands’ membership in the FFA, which made fighting IUU fishing a priority, allows the country to benefit from resources it uses every day to perform risk analysis on foreign vessels. But for the tools created and shared by the FFA to its members, implementing PSMs would be even more challenging the country’s port authorities.

In addition, experience from Thailand and the Marshall Islands shows the importance of having a consistent process including for the request of port entry. Both countries agree that a measure of success is how better prepared vessel agents are when asking port entry over time. A consistent process changes expectations and results in efficiency over time. This links back to the need for consistency in the implementation of Port State Measures among states and the requirement of documentation to prove legality before port entry. Further, in a regional context, the issue of a potential transfer effect from implementing more stringent measures than neighboring countries is reduced. With a consistent regional framework and implementation of PSM, it would be more challenging if not impossible for vessels to land their catch in another port to escape controls.

Regional frameworks and RFMOs in particular, also play a key role in cooperation. Those that maintain registries and tracking of vessels fishing in their region accessible to their members and non-member cooperating countries facilitate the risk analysis of port States on these vessels. It seems that for some RFMOs, states are keener to report and update the available tools than they do for the FAO tools.

In addition, RFMOs and other regional groups such as the FFA forbid certain behavior.

Among these measures, they both prohibit transshipment at sea, which allows for more oversight and control. Transshipments must occur in port, which contributed to the heavy vessel traffic the Marshall Islands receive. Indeed, tuna purse seiners use Majuro for unloading and transshipping tuna catches because the RFMOs in the Western Pacific and Indian Ocean prohibit at-sea transshipping.  At-sea transshipment is a particular risk because of the lack of oversight on fishing vessels that are not returning to port. Mandating that transshipments should occur in port, allows for implementation of risk assessment process such as those described in this report, as well as inspections of these fishing vessels, and control over the transshipment operations. By prohibiting certain risky behavior in their region and promoting robust MCS measures, RFMOs lower the risk of IUU fishing behavior.

II- Decision to Deny Port Entry

The PSMA empowers the port State to deny entry to vessels for which the risk of it having engaged in IUU fishing is too high, but if the port State has the capabilities and resources, the best scenario would be to permit entry into Port and conduct a full investigation, and, if warranted, impose sanctions. This would contribute to solving the problem rather than denying entry which would push the problem to another port State, which might not have the capacity to perform a full risk analysis or take appropriate enforcement action.

In the Marshall Islands for example, port authorities are empowered to grant port entry and eventually delay port use pending the clearance of all risks. As an example, in 2020, the Marshall Islands charged a Korean fishing vessel for fishing in its waters without a valid license.

For this to be possible, there is a need for national legislation that forms the basis to prosecute such behavior when the illegal activity occurred in waters beyond national jurisdiction. The Lacey Act in the United States for example creates a basis for prosecution of international trafficking of wildlife. This includes, among other behavior, illegally taken commercial fish. The Lacey Act requires accurate labeling of all wildlife shipments entering the country and criminalizes most types of trafficking of wildlife, including fish that have been “taken, possessed, transported, or sold in violation” national or foreign law. Violators under the Lacey Act can face a range of penalty including civil fines, forfeiture of wildlife and equipment, and criminal penalties, including fines and incarceration.

But these decisions also have a cost, the cost of unloading the catch, and keeping it in bonds to conserve it pending investigation, or the cost of the investigation itself and the possible court proceedings. In practice, some decisions are based on economics and capacity. In Thailand, investigations can be so costly that even if the recommendation would be to allow vessels to enter port to investigate, the costs are potentially so high that the decision can be made to refuse port entry rather than using government funds.

It seems that there is a lack of incentive to take enforcement action. When a vessel presents a high risk of having engaged in IUU fishing activities, there is no incentive for a port State to spend resources and funds on a thorough investigation, conserve the catch in the meantime and prosecute that vessel. Therefore, the solution to deny port entry might be the one that makes the most sense financially. This must be taken into consideration in the cost of becoming party to the PSMA. There are financial consequences for a country to implement more stringent controls. An option could be granting port entry and imposing higher fines that would cover the cost of the investigation, thereby incentivizing port States to take enforcement actions.

Complying with new laws and regulations can increase production costs for port States. As a result, international suppliers must also agree to eventually increase their price. There is increased demand from seafood companies across the globe for expanding seafood traceability, including through the ratification and implementation of the PSMA, which should put further pressure on governments to become Parties to the Agreement.  This, however, also includes supporting the change and potential associated costs.

Another issue of denying port entry is the potential transfer effect of vessels going to a port that enforces fewer controls, which allows catch from IUU fishing into the market. However, increased concern from seafood buyers and seafood industry for port state controls would offset the interest to go somewhere else.

 III- Container Vessels

The Port State Measures Agreement includes an exception in its scope for container vessels. As such, the Agreement does not apply to:

“container vessels that are not carrying fish or, if carrying fish, only fish that have been previously landed, provided that there are no clear grounds for suspecting that such vessels have engaged in fishing related activities in support of IUU fishing.”

Likewise, the IOTC PSM Resolution’s scope of application is to all vessels not entitled to fly the port State’s flag that request entry to their designated ports, with the exception of:

“Container vessels that are not carrying fish or only fish that has been previously landed”.

Therefore, containers vessels are currently out of the scope of the PSMA, as long as fish they transport have been previously landed. Movements of containers have increased over time because of many factors including aging carrier fleets, or improved efficiency. As a result, containers are increasingly used to move fisheries products to market.136 This exception in the Agreement has created a potential loophole and provides for opportunities for IUU fish to land and make its way to market through container vessels, thereby circumventing some reporting obligations.

The lack of definition of the concept of “landing” in the PSMA, also leaves room for interpretation and inconsistencies between port States. A 2016 FAO document for the Implementation of Port State Measures provided a proposed definition of landing as “to begin to offload fish or to offload fish from any vessel in port or at a dock, berth, beach seawall or ramp, but does not include transshipment”.

Under this definition, some catch in container vessels might not have been properly landed and should be covered by inspection.

Often times, catch would be directly unloaded on the container vessel and no documentation would prove that it was properly landed. In addition, container vessels do not use fishing ports but cargo ports that do not enforce Port State Measures because of that loophole. Such use of containers can therefore circumvent PSMs when there is an assumption that the fish has been landed before.

A 2020 UN FAO study on transshipment also highlighted a practice called “transshipment in transit” where fish is directly transferred to containers without any monitoring or control, blurring the line between landing and transshipment and “in fact not defining it as either the one or the other”. During these operations, port authorities have no insight on whether the catch has been previously landed and no effective Port State Measures can be applied.

In addition, new issues are emerging with the use of containers. Some carrier vessels are now carrying containers themselves to reduce the landing costs. The fish is stored directly in containers on the carrier before being transported to port and transferred to a large container vessel. These are charging lower transport rates. The UN FAO transshipment study highlighted in 2020 that unless clear port procedures are developed, there is a risk that carrier vessels will “switch to operating as merchant vessels that transfer containers to another merchant vessel in a free zone, instead of as vessels engages in “fishing related activities” for the purpose of the PSMA”.

This is also an important aspect of defining international transshipment guidelines and will have to be considered in the near future in implementing the PSMA. It seems that offloading fish to containers should be considered as landing or transshipment and be within the scope of the PSMA.

 Mapping interests in the tuna fisheries of the western and Central Pacific ocean by Francisco Blaha

One thing I really like about fisheries is that it attracts a diversity of people, many against it of course, some (like me) that work on it, either as regulators, industry, service and tech providers, capacity and institutional support providers… and then the academics 

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And here you also have two main groups: have the scientists that work providing services (stock, climate modeling, primary productivity, bio-economists, social scientist, etc) normally as part of different types of institutions … so to an extent, we are all stakeholders. But then you have the academics that work for universities and study aspects of fisheries.

These guys are an interesting lot… because they have (to an extent) or should have a higher and perhaps more detached and neutral opportunity to “see” things those of us more inserted may not see. In another life, I would like to be a more traditional academic and be paid to study things like many of these guys do…

Said so there is a full range in this group too… from total idiots that obviously have no clue of what they are talking about and don't understand how fishing works, or fully biased and bring a position with them, and then those few that do really engage study, collaborate and contribute with unique knowledge that explains things and/or add vison to the general understanding. 

I really like when I read one of these papers… and here is one: Mapping interests in the tuna fisheries of the western and Central Pacific ocean. By Kamal Azmi and Quentin Hanich, from the Australian National Centre for Ocean Resources and Security, University of Wollongong, Australia

I’m not surprise is a good paper because I know and collaborated in the past with both authors and have lots of respect for their work, and from what I have seen, they are genuinely nice people, and that really counts in my book. Furthermore, I kind of envy them for their jobs… to be paid to think and anise stuff, drawn conclusions and so on… I guess I do the same at a lower level with my work… but we all know the grass is always greener in the field next door!

In any case, great insight if you are tuna in the WCPFC nerd… which let’s agree may not be a huge group… but chances are that if reading this blog… you definitively are one! So the different interest-driven dynamics of the players in the WCPO fishery is something you’ll be keen to further undersytand!

As usual, read the original (great graphs), in the meantime, I just quote the abstract, a bit of the discussion, and the conclusions!

Abstract
Fisheries for highly migratory fish stocks are complex, featuring multiple species targeted by different gear types across several national jurisdictions and high seas areas. They require effective cooperation to manage sustainably, typically through a regional fisheries management organisation (RFMO). However, diverse interests in different species and gear types among participating states and fishing entities, many of which are developing, mean that cooperation can be difficult to achieve, with severe consequences for fish stocks, the economies of states with an interest in those stocks, and the livelihoods of communities that depend on them.

The Western and Central Pacific Fisheries Commission (WCPFC) manages some of the world’s largest tuna fisheries and exemplifies these challenges. We argue that a prerequisite for effective cooperation is an understanding of the interests of each participant in each species and gear type to ensure that conservation and management measures take into account the differential impacts on each one, including whether measures place a disproportionate burden on developing states. This paper uses catch value data for four key tuna species of the WCPFC convention area to illustrate the diversity of interests of participants in these fisheries, with a view to enhancing delegations’ understanding of those interests and to inform more effective cooperation.

Discussion (last part)
There are many conclusions that can be drawn from the foregoing analysis. We identify three examples of concern in the WCPFC in which new measures will have differential impacts on various interests. First, the determination of whether a disproportionate burden is likely to be placed on developing CCMs by a new measure needs to take account of any new measure’s impact on each species and gear type. For example, tropical SIDS′ strong interests in purse seine fisheries are likely to be affected by measures to restrict purse seine fishing in order to protect bigeye stocks. This has been a longstanding point of tension in the WCPFC. Second, compared to the tropical purse seine fishery, power in the tropical longline fishery is tilted more toward large, well-resourced distant water fleets, which tend to operate more commonly on the high seas.

High seas limits must recognise the particular circumstances of SIDS that rely on catches of the same stocks within their waters. This also requires giving practical meaning to the compatibility requirements of UNFSA and the WCPFC’s founding Convention. Third, the ongoing delays in restricting longline catches of albacore in order to improve the profitability of the southern longline fishery, are likely to favour distant water fishing states with substantial resources compared to SIDS. But in the absence of restrictions for the high seas, SIDS struggle to agree on restrictions for their EEZs.

 Conclusion 
In 2017, the WCPFC achieved a breakthrough when the Commission agreed that it would begin a process to establish hard limits for the high seas purse seine fisheries, and a framework to allocate these limits (WCPFC, 2018, paragraph 29), thereby implicitly recognising the sovereign rights of coastal States over fisheries within their EEZs and their own domestic limits for purse seine. The Commission would also establish hard limits and allocation frameworks for bigeye catches by longline vessels, but apply these across high seas and EEZs (WCPFC, 2018, paragraph 39). This process began in 2018, but has now been stalled by the COVID- 19 outbreak as travel bans impact on decision making. In the meantime, the WCPFC tropical tuna CMM, which was to expire in February 2021, has been extended for a further year through the adoption of CMM 2020- 01.

This paper has sought to identify the key interests among flag states and coastal states, both developed and developing, in the key species and gear types that are subject to the CMMs of the WCPFC. It did so by building on similar previous analyses of the same fisheries with more recent data and further refining the analytical framework. Steps taken in recent years to strengthen measures to conserve and manage these species have been positive but incremental.

The entrenchment of coalitions within the WCPFC, such as the FFA and the PNA, have demonstrated that gains can be made by groups of like-minded participants. The incorporation of some of their positions in key WCPFC measures – most notably various iterations of the tropical tuna measure (WCPFC, 2018) – has demonstrated that such coalitions can stimulate cooperation among a broader, more diverse group of interested participants. This case study offers both a rich line of inquiry for the study of approaches such as cooperative games (Munro, 2008) and an opportunity for RFMO negotiators to progress the sustainable management of the stocks under their stewardship. As for the WCPFC, once negotiations resume, it will be critical that the WCPFC understands and considers the interests identified in this paper.

A clear understanding of the interests of each CCM in each species and each gear type, and whether as a flag State or a coastal State, will help to ensure that new CMMs take into account the differential impacts on each participant, including whether they will place a disproportionate burden on developing States. In doing so, RFMOs will be more likely to achieve an outcome, and that outcome is more likely to be an enduring and effective one that is also more likely to move toward SDG14.

Flag state interests in distant water fishing: catch value, all gear types, all species 2016–2018. This chart plots each WCPFC flag state against two dimensions – _the vertical axis indicates the state’s GDP per capita as a measure of the level of d…

Flag state interests in distant water fishing: catch value, all gear types, all species 2016–2018. This chart plots each WCPFC flag state against two dimensions – _the vertical axis indicates the state’s GDP per capita as a measure of the level of development, while the horizontal axis indicates the proportion of the value of catches by the state’s national fleets that is caught beyond the waters of the flag state. The latter is inferred from FFA value of catch data for each national fleet less the value of catches by vessels flying the flag of the coastal state in which the fish are caught. A third dimension – _the value of the total catch by each national fleet in both national waters and beyond national waters – _is illustrated by the size of the bubble for each coastal state. Datapoints represented red bubbles are FFA members, and blue bubbles represent non-FFA members.

 

Online week: Global Fisheries Enforcement Workshop and Social Responsibility in fisheries webinar by Francisco Blaha

in this new world, we swapped o week meetings for a couple of days of online catch-ups, yet I’m sure there is a very similar amount of work by the organizers behind it!

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I have been very lucky to be invited to speaker/panelist at the last 2 iMCSn Global Fisheries Enforcement Workshops (Auckland 2016 and Bangkok 2018) , so I jumpd at the opportunity to participate in the online version of this year’s one, crafted by my brother Mark Young that deserves all kudos possibles for organizing a very successful event on an online platform.

I was part of a panel on “The Emerging Complexities of Containers Related to Transshipment’, where I articulated my take pm this topic along the lines of what I wrote here (the slides of the short presentation are below). I really enjoyed it as I was discussing the issue with some very amazing panelists Tony Long, Duncan Copeland, Peter Flewwelling and Kristin von Kistowski

Needless to say, I still have to pinch myself sometimes when I'm in those situations to see if they are real! A mongrel like me to be among MCS royalty! and I got quite a lot of good feedback… my favorite: Great presentation Francisco... practical, easy to follow, and laced with an uncommon dose of common sense!

Then the next day I also talked about the crane scales (and the selection process), we are using in Majuro now

then the next day I swap interests and was part of a panel for the webinar “Building Resilient Supply Chains: The Case for Comprehensive Social Responsibility Programs” I wrote about here. The video, if anyone is interested, is here

I’m incredibly humbled and thankful to the organisers for their invitation and trust... I don't have an organization behind me, not a line to follow or a product to sell… I'm invited just by being me, and that is a total privilege that I don’t take lightly

My presentation is below


Free Webinar: The Case for Comprehensive Social Responsibility by Francisco Blaha

The good people of RISE/FishWise (whom I have been working with for a few years) now and Seafoodsource.com are putting a free webinar “Building Resilient Supply Chains: The Case for Comprehensive Social Responsibility Programs” on July 15.

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I’ll be sitting as part of a panel with Marina Colby - Senior International Relations Officer (US Department of Labor | Bureau of International Labor Affairs) and Tom Pickerell - Executive Director (Global Tuna Alliance)

The pitch of the webinar is below, but basically is for you to learn about RISE and see if it can help you!

Register and see you then!

Demand for responsibly sourced products and momentum for mandatory human rights due diligence is increasing. Many companies recognize their responsibility to proactively identify and remediate labor and human rights abuses, but strategies that focus on risk mitigation and social compliance fall short of international norms and standards. Instead, to accelerate progress toward the ILO Decent Work Agenda, UN Guiding Principles on Business and Human Rights, and UN Sustainable Development Goals and to make impactful investments to protect human and labor rights within their supply chains, companies must take a comprehensive approach to social responsibility. Supporting decent work and other worker protections are also essential to maintain public trust and build supply chain resilience.  

Today, seafood businesses need a one-stop-shop to learn about human rights risks, find streamlined and useful guidance tailored to their operations, and identify organizations that can support their improvement efforts.

That is why FishWise created RISE - the Roadmap for Improving Seafood Ethics. RISE is a free, online resource that provides comprehensive guidance for seafood companies, from producers and processors to retailers and brands, and organizes resources from across the sustainable seafood sector, into an 8-step roadmap that is aligned with UN Guiding Principles and other international norms.

In this webinar, you’ll learn how RISE can help companies to:

  • develop a comprehensive and proactive social responsibility program,

  • take action on responsible recruitment, worker engagement, and decent work at sea,

  • and get connected to the tools, resources, and organizations that can help them take action today.

RISE advocates a paradigm shift. Moving from avoiding corporate risk to building value for workers, communities, and companies to create supply chain resiliency and sustainability.

Free Workshop on the Implementation of Port State Measures by APEC by Francisco Blaha

I have done work for APEC in the past… they are a very unique organisation in the membership and scope, i like the fact that their Ocean Fisheries Working Group (OFWG) has beee alwasy quite active and keeping up with what is happening.

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It is NZ turn to host the meeting this year… but COVID got on the way, so NZ is hosting it on line… which as most things in life has advantages and disadvantages…. to be on the positive side the advantage is that it can now be open to everyone… member or not, as there is no cap on attendance.

The workshop will feature a wide range of speakers (including me) covering a range of topics associated with Illegal, Unreported, and Unregulated (IUU) fishing, with a specific focus on port state measures as a tool to combat IUU.

This workshop aims to build capacity to implement port state measures through sharing experiences and how challenges associated with their implementation can be overcome. This is a significant event, as it is the first step in the APEC Roadmap to Combating IUU Fishing.

Below is the workshop agenda for your reference.

The work will be held across two days (21 and 22 July) from 14:00-17:30 NZT! Even if you can only join for a small portion of the workshop, you are most welcome!

To register for this workshop, please: 

1) complete this online form; and then 

2) compete the attached ‘Consent Form for NMP’ spreadsheet and send it to caleb.blackbeard@mpi.gov.nz [please note that there are two tabs/sheets in the spreadsheet, both need to be completed]

Please complete both of these steps before COB Tuesday 13 July and I “see” you there

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AIS-based profiling of fishing vessels falls short as a “proof of concept” for identifying forced labor at sea by Francisco Blaha

Back in December I was quite critical of a paper that correlated IAS, vessels characteristics and labour abuses. Of course, my criticism was based on my understanding and experience and the fact that did din not seem to have ground-truthed their assumptions and indicators with fisherman, as they could have immediately picked up the issues I picked up.… but then I’m just an ex fisherman and a couple of masters, while the authors are all PhDs and academics… so my criticism was just on this blog.

Not bad for vessels with a big engine

Not bad for vessels with a big engine

Now interestingly a letter to the authors was sent by some heavyweights scientists and published over a month ago. The authors say is way more elegant English (and without needing too many details) things around the line of what I wrote, further adding that it fails a “proof of concept”

Not that it really matters at the end, but it made me feel well. Maybe one day I’ll give PhD a go.

In the meantime, I paste the letter below, original here.

McDonald et al. argue that labor conditions in fisheries can be discerned from the movement and characteristics of fishing vessels. We recognize the authors’ effort, yet have strong reservations regarding their 1) limited dataset, 2) assumptions, and 3) model validation. Forced labor is a serious human rights violation, and any scientific claims potentially informing policy must be considered with particular care to best promote efforts toward ending human terror and supporting survivors. We, therefore, urge that the authors consider how their efforts may misinform policy.

The authors create profiles from vessels reported to have committed labor abuses, search for similar profiles in a database of 16,000 vessels with available positioning (automatic identification system [AIS]) and associated data, and conclude that up to 4,200 vessels in “global” fishing fleets are “high risk” for labor abuse. First, of 193 labor abuse vessels identified by McDonald et al., only 58 used AIS and just 21 yield AIS profiles suitable for their analysis, implying that nearly 90% of their known cases are undetectable by AIS-based profiling as proposed.

Second, the 27 features used in their profiles are not causally linked to labor conditions onboard. The four features identified as most predictive of labor abuse “risk” (engine power, maximum distance from port, yearly voyages, average daily fishing hours), describe large distant-water vessels and are therefore likely correlated. Third, there is no testing of vessels with similar profiles that have not engaged in labor abuse. Existing evaluation methods for positive-undefined learning systems require some positive/negative-class knowledge of unlabeled cases in the training or test datasets, and their performance given unbalanced data (with many more “undefined” than “positive” cases) is questionable (24). The authors fail to accomplish the former and display problems of the latter. The use of the 21 positive cases to both train and validate the model violates the golden rule of machine learning in that the test data cannot influence the training phase. Additionally, risk as presented is not likelihood or probability of labor abuse and statistical findings are not ground-truthed; thus, the data offer no evidence that forced labor is more prevalent in vessels identified as high risk.

Given the suggestion that their model provides “new opportunities for unique market, enforcement, and policy interventions,” we believe the authors must address the potential ethical implications of their approach. Statistical profiling risks being reductive, especially given limited understanding of the modeled system, and there are real concerns over its use leading to unfair decisions or discriminatory practices (57). McDonald et al. emphasize that model limitations may underestimate high-risk cases; given their limited sample and lack of model validation on data not used for training, even this statement remains speculative. We appreciate that their model is exploratory, but it remains largely untested and these crucial limitations should have been at the fore of the analysis. In conclusion, McDonald et al. falls short as a “proof of concept,” and therefore, the capacity of remote sensing as a tool for detecting fishing vessels engaged in labor abuses remains unsubstantiated.

And to be correct, I also acknowledge the response to the above letter by the authors of the original here. Yet for me personally their answer does not really address the obvious problems with the paper

Do FADs Contravene International Marine Pollution Law? by Francisco Blaha

A couple of days ago I blogged about the complexities of estimating how many FADs are added every year to the WCPO fishery, and more generally ho FAD fishing changed the fishery from the days I was fishing.

If I was to go back I would have to learn how to find fish again… literally. I don’t think Purse Seine tuna fishery would be economically viable at the present catch rates without FADs… you just have to see the catch rates during the next 3 months (FAD closure on the WCPFC area) to see that most of the fleet would be losing money at the present tuna prices.

I’m actually made for you to find me.

I’m actually made for you to find me.

In any case, there is an aspect of FADs that can’t be argued, they contribute to Marine Pollution (MARPOL), and this a paper Just a Harmless Fishing Fad—or Does the Use of FADs Contravene International Marine Pollution Law? analysis that fact from a legal perspective., which is always interesting.

I have no sufficient knowledge on the topic to make a value judgement on the paper, yet the fact that the author, Dr Robin Churchil, is an Emeritus Professor of International Law, University of Dundee, should be a guarantee, as Plastic from FV is a topic I worked working recently, I make an effort of learning by reading.

I quote the conclusions below, but as always I recommend you read the original from the link above.

Conclusions

A large number of FADs are lost or abandoned every year, with many eventually washing up on beaches as litter, stranding in sensitive marine habitats, such as coral reefs and seagrass beds, or sinking and causing damage to seabed habitats. That raises the question of whether international marine pollution law, in particular the international dumping regime (the London Convention, London Protocol, and UNCLOS) and MARPOL, could be used to regulate and mitigate such loss and abandonment. As far as the international dumping regime is concerned, the abandonment (but not the loss) of a FAD probably constitutes “dumping.”

From that it follows that where the London Convention is the applicable law, the state of loading or the flag state, as the case may be, must prohibit the abandonment of FADs made of persistent plastics or other persistent synthetic materials and issue permits for all FADs made of other materials that a fishing vessel intends to abandon. Where the London Protocol is the applicable law, the state of loading or flag state must prohibit the abandonment of FADs made of materials other than “organic material of natural origin,” and must issue permits for the deliberate abandonment of FADs that are made of such materials.

Under UNCLOS, where a fishing vessel intends to abandon a FAD in the territorial sea, EEZ, or continental shelf of a state other than the state of loading or the flag state, it must obtain the express prior approval of that state. There is a due diligence obligation on the state of loading and the flag state to enforce the prohibitions and permit systems of the London Convention and Protocol. Where those states fail to do so, they may be made subject to the dispute settlement processes of the London Protocol and UNCLOS, and to the noncompliance procedure of the London Protocol.

In the case of MARPOL, the nonaccidental loss of a FAD constitutes a breach of Annex V. That is also the case with the abandonment of a FAD, should the conclusion that abandonment falls within the scope of the international dumping regime not be correct. Flag states are under a due diligence obligation to enforce Annex V. Action against states that fail to do so may be taken under the dispute settlement procedures of MARPOL or UNCLOS. Alternatively, such failure could be drawn to the attention of the IMO when the flag state concerned was next due for audit under the IMO’s mandatory audit scheme.

Over the past few years, tropical tuna RFMOs have adopted a number of measures designed to alleviate some of the environmental problems caused by lost or abandoned FADs. All four RFMOs prohibit the use of entangling material suspended beneath FADs in order to prevent sharks, turtles, and other non-target species from becoming entrapped, and “encourage,” but do not (yet) require, FADs to be constructed of biodegradable materials apart from the satellite buoy.

The ICCAT and WCPFC encourage the recovery of lost and abandoned FADs.80 Both RFMOs also prohibit the use of FADs in certain areas at certain times of the year81; it is not clear whether that leads to a reduction in the use (and therefore the loss and abandonment) of FADs or simply leads to greater concentrations when their use is permitted. It remains to be seen how well the mandatory measures will be observed, and whether the hortatory measures eventually become mandatory.

In the meantime, there is a real need for the international dumping regime and MARPOL to be properly implemented and effectively enforced so that the significant pollution caused by lost and abandoned FADs may be reduced and eventually eliminated.

Quantifying FADs use by the world's largest tuna fishery by Francisco Blaha

As most of you know the issue of dFADs (I call them eFADs, because of their e-capabilities) is of real interest to me, they touch pretty much every aspect of fisheries I’m interested in. Harvest technology, policy, management, bycatch, MCS, science, operations, subsidies and so on. No doubt (and by far) there the biggest impacting development in Purse seine fisheries in the last decade.

just a small sample

just a small sample

They are controversial and polarising, while some focus on their elimination (which is something I personally doubt would be possible), I like to know as much as I can about it… and with that understanding try to manage their negative impacts (plenty written about them) and see if they are positives from them… 

What do I mean with positives? Back in the last century when working in fisheries research and stock assessment (differentiation of reproductive stocks in hake was my thing) we started harnessing the power of biomass determinations by using sonars… monstrous things at the time… that required regular calibration… the number of times that we had with a colleague to walk the vessel sides on fair weather holding marked lines with a copper ball at the mid-distance to find the transducer and calibrate that thing at different depths was pathetic… anyway… it was a game-changer.

Today we have at any time 20 to 40000 of these mini sonars deployed every year in the WCPO… if there was a way to harness all that data we could (to a certain extent only) almost have a version of real-time biomass assessment which could hugely beneficial for stock assessments and therefore management and policy. 

I know… perhaps unsurmountable issues around the property of data (its all own by the buoy owner) and well as the capacity to harness and make productive use of that data… 

But then… as I said in a recent interview… “If I wasn’t obstinately optimistic… I don’t think I’ll be alive today. I cling to any positive news I can, and see if the model that got us to that positive news can be adapted somewhere elsewhere we have a problem"

(Don't worry I’m tacking eFAD as MARPOL in the next blog)

Anyway…. 20 to 40000 deployments a year is a huge range (and add to the ones there are already!) but how we know that number?

Here is where my really clever colleagues from SPC come in… as part of their work as science providers for stock assessment, the “effort creep” associated with eFADs is a key part. 

Their latest efforts have been published in this very interesting and innovative paper, where they explain how they estimated the use of dFADs in the WCPO through a novel combination of four fisheries datasets over the 2011–2019 period: at-sea observers’ data, vessel logbook reports, Vessel Monitoring System (VMS) data, and trajectories from the satellite buoys on dFADs. 

I can only imagine the hurdles and complications around using these data, which are often privacy and commercially sensitive and confidential, but kudos to them as they are seen as secure partners by all players in the fishery.

The key finding is that between 20,000 and 40,000 dFADs are deployed per year. This corresponds to every purse seine vessel monitoring on average between 45 and 75 dFADs each day. A striking result was also the relatively stable trend in terms of dFAD deployment detected over the last decade, which is different from the increasing trends seen in other oceans that rely more heavily on dFADs.

I recommend you read the original I just going to quote the Recommendations for improved dFAD monitoring they propose, which are key to my interest. 

While current levels of dFAD use remain challenging to determine with high certainty worldwide, the long-term management of dFADs could benefit from a better understanding of the optimum number of dFADs to maximize profitability while limiting impacts on tuna stocks and ecosystems. Results from this study could provide baseline data to monitor dFAD use and impact in the WCPO, with application of these methods in other oceans. 

However, to improve the ability to estimate potential dFAD levels (e.g. deployments, dFAD density, active buoys), the collection of additional information is suggested. For example, to better understand the total number of dFADs in the water and the number of dFADs used per vessel, the provision of: (i) the number of new dFADs deployed per year per vessel or fleet; (ii) the average daily or total number of active dFADs per vessel per month; and iii) the number of deactivated dFADs per month, would enhance these efforts. Some of these data are already being collected by some Regional Fisheries Management Organisations (Báez et al., 2020). This could also be achieved through complete submission of dFAD trajectories, which in turn will be a key addition to scientific studies on dFAD density (Restrepo and Justel-Rubio, 2018); impacts on catch rates, and tuna behaviour (Scutt Phillips et al., 2019b). 

The PNA FAD tracking database, through the compilation of local dFAD density will allow for such additional studies on the impacts of dFADs on tuna ecology to be performed. New FAD logsheets have been launched in 2020 in the WCPO by the PNA and will require captains to fill in any dFAD related information, including the unique buoy identification number, which will improve some of the issues with the data currently collected. In addition, given the connectivity between the WCPO and the EPO and the general westward trend in currents, collaboration between scientists working in both these Pacific regions should be encouraged. Additional data sources could also be considered (e.g. dFAD marking with fishery-independent autonomous satellite devices; data collection of dFADs reaching coastal areas).

This could help to better assess other environmental impacts, such as dFAD loss, marine pollution, and beaching, or to follow individual dFADs instead of the satellite buoy attached to it which may be swapped several times. Overall, the compilation of these data would allow better scientific analyses and advice on the optimum management strategies for sustainable use of dFADs by the purse seine fleets in the WCPO and other ocean basins.

The other one, the one called Francisco, is the one things happen to by Francisco Blaha

I was looking for something today and came across an old short story/rose by one of my favourite writers ever Jorge Luis Borges. it’s a great little piece called “Borges y yo”, that always resonated with me and as time passes by and I get older and more defined by my work, my age, my COVID constrained present in front of a screen instead of being out there, the echo is even bigger. So I decided to adapt to English his words and apply them to my path in this life… knowing very well I don’t even get to the level of his feet.

Gracias Maestro Borges, y por favor no se ofenda por mi pobre uso de sus palabras (thanks master and please don’t get offended by my poor use of your words)

—-

The other one, the one called Francisco, is the one things happen to. 

I close my eyes and I stop, perhaps mechanically now, to remember a sunset at sea, tiredness in my body after a day on the deck, the happiness to know we heading back to port to unload…

I know of Francisco from the emails and see his name on a list of speakers for a seminar or in a report about some obscure aspects of fisheries. 

I like sextants, maps, the names of the pacific islands, the taste of coffee and the feel of warm seawater in my skin; he shares these preferences, but in a vain way that turns them into the attributes of a consultant. 

It would be an exaggeration to say that ours is a hostile relationship; I live, let myself go on living so that Francisco may contrive his work and this work justifies me. 

It is no effort for me to confess that he has done some good work in fisheries, but that work cannot save me, perhaps because what is good in fisheries belongs to no one, but rather to the ocean and to the tradition or fishers. 

Besides, I am destined to perish, definitively, and only some instant of myself can survive in him. Little by little, I am giving over everything to him, though I am quite aware of his perverse custom of falsifying and magnifying things. 

Years ago I tried to free myself from him and went from the catching of fish to writing and working on the controls in fisheries and capturing with my camera images that most never see because they happen at sea. 

But those jobs and images belong to Francisco now and I shall have to imagine other things. 

Thus my life is like a wave destined to reach the coast and hopefully be surfed, yet so I lose everything and everything belongs to oblivion, or to him. 

I do not know which of us has written this page. 

Social Responsibility Tools for fisheries by NGOs by Francisco Blaha

I just finished being part of an early zoom meeting organised by the good people of the Conservation Alliance Global Hub they are a great bunch of colleagues I respect and admire.

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Today’s zoom call was as around presenting the tools available around the pressing issue of social responsibility and we had beautifully crafted presentations by the IPNLF, Conservation International, RISE, FishChoice, and Montery Bay Aquarium Seafood Watch. All presentations very insightful and professional and I’m very lucky to know personally some of the presenters

it was interesting to see that most of the presentations put a lot of focus on being based on basic regulatory frameworks around labour and human rights for each of the initiatives and then sending importers (and industry) to cross-check compliance or offering services around that necessary due diligence.

As I work mostly supporting governments institutions in charge of upholding regulatory frameworks (mostly in fisheries but I’m moving from a professional and personal interest -I was a fisherman- into the social domain)… yet the problems that the tools these NGOs have developed to address labour and social issues, start with the shortcomings from the government institutions in charge of labour and human rights for fishers.

But none of those tools and seems to cater to help or intervene at the government level and I worry we are creating parallel systems that replace those core responsibilities from state institutions.

And not for a moment I’m saying that government institutions would be better than any private initiative, yet in the end upholding regulatory frameworks is their mandate (and reason of existence) and while we like it or not, chances are that government institutions would be (in some way or another) there in 30 years… while industry and NGOs initiatives may not.

I posted a question: Is anyone of your initiatives supporting government institutions in countries with known fisher labour issues? unfortunately, they could not answer it… but is a genuine worry I have.

The other issue that was interesting for me was that almost all of the initiatives were USA based, which seems ironic since the USA delegation at FAO COFI Trade meeting was the most vocal against the proposed voluntary FAO Guidelines on Social Responsibility in Fisheries and Aquaculture Value Chains

About the future and food (in 2009) by Francisco Blaha

This blog had an embryonic predecessor in 2002 that didn’t last too long, and it was a bot more personal, it was called “Life in Development”, why I’m mentioning this? My friend Andy McKay, linked me with an article of the Guardian where Dr Sylvai Earle says:

“It’s not food security, if’s food choice. Who in the world really needs to eat tuna?” she asked.

“It’s not food security, if’s food choice. Who in the world really needs to eat tuna?” she asked.

“It’s not food security if’s food choice. Who in the world really needs to eat tuna?” she asked. “This is a luxury choice, new for most people on the planet since towards the end of the 20th century when marketing created this appetite for tuna that didn’t exist early in the 20th century. People got along perfectly well and ate well without eating tuna.”

Maybe she needs to come to the pacific… where it is food security and it is the main income earner for many of our countries… so much so that we have world tuna day. Also to imply that can tuna is a luxury seems odd

In any case… it took me back to 2009 and one of my first blogs on that early attempt to put my thoughts in place about fish as food… unfortunately not much has changed other than we became more polarised, way deeper into climate impacts and way more righteous about what people think is right (and their right)

Here is a part of what I wrote then, when I was a senior officer at the UN FAO:

A bit more than a year at the UN, has given me a good inside view of this massive organization and exposed me to the "really big picture". I guess the main impact of this job on my life is to really see things from a “truly” global perspective... I have to deal with technical issues at community, regional and at a maximum country level... but here the job is the world...

And while I can remember there always been “apocalyptic” type challenges that never totally eventuate (a tribute to our environment resilience?), I see through my work here some real challenges...

Without trying to provide a complete account of them, some of the most key challenges in the discussion table are:

The key (for me) is that the world population is projected to grow from 6.5 billion in 2005 to nearly 9.2 billion by 2050... to feed a population of more than 9 billion free from hunger, global food production must nearly double by 2050... today’s figure of people living below 2 USD/day is 58% of the world population...

The entire population growth will take place in developing countries and it will occur wholly in urban areas, which will swell by 3.2 billion people as rural populations contract. That means that a shrinking rural workforce will have to be much more productive and deliver more output from fewer resources.

Higher productivity requires more investment in agriculture, more machinery, more implements, tractors, water pumps, combine harvesters, etc., as well as more skilled and better-trained farmers and better functioning supply chains.

This means that fewer farmers will have to feed a more populous world with fewer resources and minimal access to credit under the present crisis.

One way would be for world agriculture to expand its land basis and use some of the nearly 4.2 billion hectares potentially available for rain-fed crop production (only 1.5 billion ha are currently in use). But that would not be possible without further environmental damage and increased greenhouse gas emission.

Another avenue would be to tap into yet-unused yield-enhancing resources, which could double productivity for many crops in many countries. However, such potential can only be realized if farmers have improved access to inputs, apply better fertilizers in more abundance, make use of better seeds, improve their farming and management skills and expand land under irrigation. These as well are measures that have serious socio-economical and environmental consequences.

In addition to rising resource scarcity, global agriculture will have to cope with the burden of climate change.

The IPCC has documented the likely impact of climate change on agriculture in great detail. If temperatures rise by more than 2C, global food production potential is expected to contract severely and yields of major crops may fall globally. The declines will be particularly pronounced in lower-latitude regions. In Africa, Asia and Latin America, for instance, yields could decline by 20-40%.

In addition, severe weather occurrences such as droughts and floods are likely to intensify and cause greater crop and livestock losses.

Rapidly rising energy prices have created an added challenge for global food supplies. Rising fossil energy prices mean that agriculture will become increasingly important as a supplier to the energy market.

Important here is to understand that the potential demand from the energy market is so large that it has the potential to change the world’s traditional agricultural market systems completely.

However, for me in the short term, even more, critical is likely to be the impact of the financial crisis on the availability of credit, which is widely recognized as one of the major constraints to agriculture development in the developing countries, the rationing of which is likely to be more serious than any interest rate effects.

The combination of falling agricultural prices and reduced access to credit may have a knock off impact on agricultural production, with very serious implications for global food security.

For instance, a cutback in grain plantings against the background of continuing low grain stocks, which have not been rebuilt since the high food price episode, would increase the risk of global food crisis if harvests turn out to be poor, especially if countries cannot access credit for food imports.

As a father, and perhaps just as basically a human... the future kind of scares me... these are not “predictions” of scare far fetched “greenes”... these are people I respect (albeit at different levels).

I guess this basically means that “we all” have a lot of issues to be dealt with ahead of us... but my usual optimism is quite dented... (all the hard data, figures and expansion on these issues can be found
here

So yeah… 12 years later… the same problems still stand… not much has happened with the rest of the food productions system, the economic-financial crisis, merged with the COVID one…. the investment needed has not eventuated… and fisheries are relatively stable…. yet they are always evil

An assessment of plastic waste generation from FV in the WCP, and potential measures to improve onboard management by Francisco Blaha

Back in March, I wrote about a study we were working on with my friends Robert Lee (a former longline skipper, fleet manager and FAO officer) and Alice Leney ( a waste management specialist - garbologist, besides a being mechanical and solar power maverick)... Even if it did not include fishing gear, the job was to: 1) identify, then assess volumes produced board and then potentially dumped, and then 2) come up with practical and policy-based alternatives that are aligned to the regional framework (a WCPFC CMM) and the international one (MARPOL convention) while thinking laterally around how to do under limited enforcement opportunities… and I recognised then that was a much bigger job we all anticipated.

Plastic Salt Bags in the wet deck of a purse seiner

Plastic Salt Bags in the wet deck of a purse seiner

We finished it, and was presented at the latest FFA big meeting, and approved… Is a big and unusual document to the ones I normally do… My 1st skipper told me decades ago: either you learning, or you are making money if you do both: Bingo! if you ain’t doing any… move on.

With this job, I did Bingo!

FFA did a press release about here. if you want to download the full 86 page report download it from here

The SPC Fisheries Bulletin (a fantastic publication) published today has an article based on the executive summary of the study and is a good entry to it, so I quote it below, the very nicely laid out pdf from SPC is here

Otherwise, feel free to take your time and read below

This article is based on the executive summary of a report[2] commissioned by the Pacific Islands Forum Fisheries Agency (FFA) to gain an understanding of the situation regarding plastic waste that is dumped into the western and central Pacific Ocean from fishing vessels. Given the current situation with the COVID-19 pandemic, this desktop study reviewed the existing literature on the subject to gain insight about waste management practices on board fishing vessels. Fishing boat officers and/or company personnel were surveyed when possible, and the extensive experience of the authors in the fields of fishing vessels and waste management were also relied on to make an overall assessment of the current situation regarding waste disposal on vessels in the Pacific. 

The ultimate aim of the study was to provide possible strategies and actions that could be taken at both the national and regional level to eliminate all plastic waste disposal at sea. The authors have endeavoured to address this central point through a thorough and careful analysis of the information available. It is essential to bear in mind from the outset, the reason why an attempt was being made to determine the amount of waste that is dumped in the ocean: to prevent it.

Estimates of waste generation by fishing vessels

Estimates of waste generation by fishing vessels is only ever amenable to broad estimates, as the amount changes every day and there are many variables, including vessel size, crew numbers, type of fishing, length of voyage, vessel condition and operating standards on board.

Similarly, given that waste management practises onboard vessels vary widely, it is not realistic to make any meaningful estimate of the amount of waste being dumped unless an extensive, real-time study of several vessels duration is conducted. To make a broad sweeping claim regarding the amount of waste dumped from all fishing vessels might discourage those operators who are doing their best to deal with waste problems onboard, while making those – if any – who dump everything over the side, actually look better.

Faced with this conundrum, and mindful of the ultimate purpose of this study, the authors have taken the approach of trying to estimate the amount of waste that certain vessels might generate. 

The full report differentiates between: 1) operational and maintenance waste that is related to crew and vessel size and condition, and days at sea; and 2) fishing operations waste that is directly related to the type of fishing and total fishing effort. Using existing literature, observer reports and the authors’ varied experience, some broad estimates have been made that might allow a determination of a vessel’s expected waste generation. These estimates are of a conservative nature and are applicable to a broad range of vessels.

The study did not look at the issue of lost and discarded fishing gear, as this was not part of the terms of reference. The issue could, however, be addressed through recommendations and standards that are already in place, such as of the International Convention for the Prevention of Pollution from Ships (MARPOL)[3] and the International Maritime Organization (IMO).[4] The strategies and actions proposed below take account lost or discarded fishing gear and allow for the integration of measures to combat this problem into the proposals, through the marking of fishing gear. 

Our estimate of waste generated by the different tuna fishing fleets in the western and central Pacific Ocean (WCPO) is as follows.

Longline vessels. For the 1700 active vessels in the WCPO:

·       Plastic lines on bait bags: 402–935 tonnes; median: ~ 670 tonnes per annum.

  • Cardboard: 2958–6879 tonnes; median: ~ 4920 tonnes per annum.

  • Using 60% as a proxy based on observer reports: between 241 and 560 tonnes of plastic waste from bait alone is being dumped at sea every year, while the figure for cardboard is between 334 and 776 tonnes.

Purse-seine vessels. For the 253 vessels in the FFA register:

•       Salt bags for brine making: 210 tonnes, equivalent to 2,800,000 individual bags.

•       Using a 37% proxy: 77.7 tonnes of woven plastic salt bags (equivalent to 1,036,000 individual bags) are dumped into the ocean every year.

Operational and maintenance waste: 

•       Longline vessels: 1000 tonnes produced, 600 tonnes dumped into the ocean every year. 

•       Purse-seine vessels: 220 tonnes produced, 80 tonnes dumped into the ocean every year.

Existing international frameworks and guidelines

Having determined some idea of the type and scale of the problem regarding the waste generated on fishing vessels, the study then looked at the practicalities of dealing with those quantities and types of waste. The current institutional frameworks that exist – under MARPOL, the Western and Central Pacific Fisheries Commission (WCPFC) conservation and management measure (CMM) 2017-04,[5] and IMO agreements – are looked at in detail to determine if a good framework and clear guidance already exists. It is clear that all of the institutional frameworks, guidance documents, standards and agreements that might be needed by ship operators to address the issue of onboard waste management are, in fact, already in place.

Waste reception capacity at Pacific ports

The study examined the potential to off-load waste at several Pacific Island ports. The picture is grim: of the five fishing ports in the region that were looked at, only one – Suva in Fiji – has access to a landfill facility that is in any way compliant with any desirable standards. The other four nations – the Federated States of Micronesia, Kiribati, Marshall Islands and Solomon Islands – struggle with their own local waste management to varying degrees, and their landfill facilities are mostly already overwhelmed. Adding foreign commercial waste to existing domestic waste is not a viable solution, where that is avoidable. While some fishing vessels do operate out of Pacific Island ports as a home base (e.g. one company in the Marshall Islands and another in Noro, Solomon Islands) and have to dump their waste in local dumpsites, the majority of fishing vessels are actually foreign-based, and materials that are now waste were once provisioned onto those vessels either at overseas ports or from carrier vessels. 

The waste “management” centre in majuro

The waste “management” centre in majuro

Waste disposal for the distant-water fishing nations vessels

Taking a conventional solid waste management approach of investigating “reverse logistics pathways”, and following the internationally accepted principle that the country to which a fishing vessel belongs is also responsible for the waste that vessel produces (in this case, the flag state or de facto home port). The carrier fleet provides an excellent opportunity to improve waste management at sea. Carrier vessels are typically larger than fishing boats, and have adequate deck space for taking waste back to an appropriate port to be dumped. Because the actual waste takes up less space than the products that originally generated that waste, there is clearly an opportunity to involve the carrier fleet in a formal waste management function. 

 It is fully accepted that the carrier fleet fills its holds with fish that take up some of the space of supplies that were carried out. But while longline vessels consume vast numbers of boxes of bait, and purse-seine vessels take on many tonnes of 50-kg sacks of salt, there is space on decks and in dry holds to store carefully managed waste that can be taken back to shore. Carriers have the potential to have small compactor baling machines onboard that can compress waste, increase the density, and thus reduce the stowed volume of waste. And some vessels have IMO-compliant incinerators that are much safer for both ship and crew than rusty oil drums with holes that are common on the decks of many fishing vessels. Oil drum incinerators are undesirable from a ship safety point of view and are a known health hazard to crew as they generate carcinogenic smoke in significant quantities. 

In short, if the waste produced by fishing boats is to be professionally addressed, then it must become part of the everyday operation of running a tight ship, and waste needs to be managed and stowed for off-loading at the appropriate place and time. Good ship operators are already doing this, and all the guidance that is needed to help other operators improve their onboard waste management exists in great detail under the MARPOL and IMO frameworks. The logistical problems are quite easily solved, and there is no shortage of guidance on how to address them; the major challenge at present is the indifferent attitudes toward proper waste management.

On this note, the full report provides some simple and practical advice on onboard waste management that is derived from the direct experience of the authors in this field, one of which spent several years at sea during which one of his tasks was to manage the waste onboard, ensuring that nothing went over the side except food waste.

Economic incentives for improved waste management

Having determined that, for the carrier-supplied fleet at least, there is a clear alternative to dumping waste in the ports of Small Island Developing States (SIDS), and that commercial and financial considerations are a significant driver in how waste is managed onboard. The report takes a brief look at the economic incentives that currently exist and may drive how waste is managed on fishing vessels. It can be clearly seen that the economic incentives are entirely aligned to encourage poor waste management and ocean dumping. This is an important insight, and one recognised by the IMO, and several MARPOL documents call for the creation of incentives to improve waste management. The report quotes a ground-breaking recent economic analysis[6] from the British government to support the conclusions reached here. Improved waste management will incur additional costs, but this is simply part of the cost of running a responsible business and cannot be used as a justification to pollute the natural environments of small Pacific Island nations. Currently, the “avoided cost” (i.e. financial benefit) of poor waste management is, de facto, a subsidy from island nations to those businesses that evade their responsibilities under MARPOL. In fact, a “secondary market” in waste may appear whereby carriers charge fishing vessels to take their waste away, thus allowing those vessels to fulfil their waste bond requirements.

Strategy to eliminate the dumping of waste at sea

With all of the above now providing some clarity to the waste management situation onboard fishing vessels, we reach the heart of the matter: How might any dumping of waste from fishing boats cease? From the above, strategic points can be developed and enumerated, and resulting actions that can be taken to implement these strategic points can become clear.

The resulting strategic points are as follows:

1.     Either waste is dumped into the sea, or it is returned to port at some point, and in some form. MARPOL does not allow the dumping of any solid wastes considered in this study to be dumped into the ocean, including incinerator ashes, thus:

 All vessels should return with some quantity of waste to off-loaded at port.

2.     If something is to be managed, then it will need to be measured. Therefore, the questions are: How much? and How do we measure it? There are two separate waste streams to consider: fishing operations waste, and operational and maintenance waste. The first is related to fishing effort while the second is related to crew and vessel size, and the number of days at sea, thus: 

A measure of expected waste generation by vessel is required.

3.     The overall framework of institutional and technical standards and guidelines already exists with MARPOL and IMO. The overall aim must be to ensure that those vessels that do not currently have good waste management practices, must change their current practices, thus:

Under the FFA Harmonised Minimum Terms and Conditions, all licensed fishing vessels must comply with MARPOL, whether the flag state is a Party or not.

4.     There is actually an economic incentive to operate a vessel with poor waste management; an economic incentive must be created to improve waste management, thus: 

An economic incentive to follow MARPOL requirements must be created.

5.     Measures must be simple to implement where possible for both FFA and fishing companies. Onerous and complex reporting systems that require significant additional effort and cost to report, monitor and enforce are unlikely to be adopted, thus:

Simple metrics must be used, and effort must focus on a small number of key ports and/or locations.

6.     The issue of onboard waste management is fundamentally a logistical challenge; all of the materials that become waste were put on the ship either in port or during a carrier transshipment, thus:

Existing reversed logistical pathways must be used. 

7.     Pacific Island ports already have a domestic waste crisis and are, in very large part, unsuitable places to take foreign waste generated by overseas business operations. Therefore, aside from local-based fishing vessels, vessel waste needs to be returned to originating home ports, thus:  

Wastes from vessels of distant-water fishing nations should not be off-loaded at Pacific Island ports. 

8.     Larger vessels are much better placed to have better waste management systems because they have more space, can operate small compactors to increase waste density, can operate safe and compliant incinerators, and can handle and stow larger waste containers, thus:

Carrier vessels must accept waste from fishing vessels. 

9.     There must be a long-term element to the strategic actions that is aimed at changing, over time, the culture onboard those fishing vessels that do not currently have good waste management systems in place, thus: 

Easy waste management measures should be imposed at the start, and the bar should be raised over time.

10.  Ship owners and operators who can show that they have MARPOL-compliant systems already in place, and already take waste management seriously, must be recognised. Those who do not must be held accountable, thus:

Good businesses should be rewarded, and poor operators should be targeted.

These strategic points rest on two fundamental pillars: 1) simple ways to measure and monitor onboard waste to know that change is occurring; and 2) the development of incentives to reward those already doing the right thing, encourage change in those who need to, and sanction those who resist.  

Proposed actions to take

From this strategic analysis, and a close look at the realities of dealing with waste onboard ships, the report recommends a divergence from the MARPOL method of measuring waste by volume in cubic metres, to that of weight in kilograms. The reasons for this are elaborated on in the report, and the key considerations are provided by strategic points 5 and 9. Measurement must be as simple as possible and consistent with reasonable estimates because reasonable estimates are the bedrock of waste measurement. This approach meets the requirements of the first pillar on which the strategy rests.

For the second pillar, the heart of the proposed actions is the FFA Harmonised Minimum Terms and Conditions that require demonstrated effort to comply with WCPFC CMM 2017-04 as well as MARPOL requirements. Alongside this, using the widely used waste management principal of extended producer responsibility, a “waste bond” is proposed, whereby a vessel must show that a reasonable quantity of waste is disposed of onshore in an acceptable manner to avoid sanction. 

This waste bond would be held in escrow in some conventional form[7] to ensure that good operator are not penalised, but poor ones are. Greater detail of this proposal is provided in the report, but in essence, the following “action points” are proposed.

A.    Provide, as part of licensing (under the Harmonised Minimum Terms and Conditions), vessels with a simple electronic template for a Garbage Record logsheet 

Some work will need to be conducted to develop a suitable electronic Garbage Record logsheet template, that will minimise the quantity of information required to be recorded so that it is as simple as possible to fill out and check. This would be similar to vessels that presently do electronic reporting. For example, the garbage categories used in MARPOL can be simplified significantly for the purposes of this action: there is no need to identify so many categories. 

Weight in kilograms should be entered into the Garbage Record logsheet, which could consist of a simple MSExcel spreadsheet. The logsheet should be uploaded regularly to a shared database managed by either the Secretariat of the Pacific Regional Environment Programme (SPREP), the Pacfic Community or FFA. Each ship would have a specific identity, just like with electronic catch and effort logsheets. Each uploaded logsheet, with new information added, would replace the previous one, allowing to gather an annual total for each fishing vessel. This is consistent with strategic points 1, 2 and 5 described earlier.

B.    Set up a database for Garbage Record books/logsheets.

An electronic repository for the standardised Garbage Record Books is needed on the servers of SPREP, SPC or FFA, or “in the cloud”, on which vessels can upload their data. This is an electronic reporting task and complements action point A.

C.    Require all FFA-licensed vessels to provide a garbage management plan.

This plan should be as simple as possible and consistent with representing the realities of waste storage on the vessel in question. A concise template plan should be drafted to assist standardisation and encourage simplicity, and to avoid recording any unnecessary information. Carrier vessels should be expected to include provisions in their plans to take waste from fishing vessels during transshipments. Carriers will be expected to show compaction capacity and/or large waste holding capacity.

Standardising plans will help ensure that only the important information is in the plan (e.g. how waste is contained and stowed, any compaction measures, scrap metal separation, description of any incinerator used). There is no needto describe recycling capacity, waste type and separation. A template should be drafted and field tested on a small number of suitable candidate companies and vessels that are prepared to assist in this endeavour, so as to develop the simplest plan but one that fits the purpose. This is consistent with strategic points 3, 5, 6 and 8.

D.    Develop a formula for calculating expected waste generation per vessel.

The goal here is to identify a small number of vessels that have good waste management systems, learn what works best, and use that information to develop a simple formula based on vessel size, number of crew members, days at sea, fishing type and fishing effort. This current report can provide some guidance to for how to go about this, but because it is a desk-top study, it is not ideal. The use of existing observers to collect data for such a study is ideal, and training could be easily provided to them for this purpose.

This action can be combined with action point C so that the same field testing of a management plan can be used to collect data. The study period need not be too long, the intention is to determine a number for a reasonable quantity of expected waste generation, and feed into the development of onboard systems. Good measurements will provide good data to help vessel owners determine waste stowage requirements for an expected voyage length.

Vessel owners could be encouraged to participate in such a study by being given a waiver from having to post an initial waste bond, if that approach was subsequently taken. This is consistent with strategic points 2, 9 and 10.

E.    Require all onboard incinerators to meet IMO standards.

Any waste incineration that takes place onboard should be done so in a proper incinerator that is made for the purpose, and not in a non-compliant device that is a potential health and safety hazard. Incinerators that are IMO-compliant are larger, more complex and expensive. It is expected that these will mainly be used on carrier vessels. This will concentrate monitoring effort on a smaller number of vessels, especially as incinerated waste is harder to measure. 

This action requires that vessels submit pictures and specifications of their installed incinerator, at the same time as – and as part of – their waste management plan. Non-compliant incinerators could cause rejection of the plan. A date should be set as to when a vessel must comply. MARPOL standards for incinerators are extant;[8] this action requires no additional effort to develop standards. This action is consistent with strategic points 3, 4, 8 and 10.

F.     Develop a waste bond system that is payable at the time of licensing.

The action points above will feed into the development of a waste bond. With a reasonable estimate of the amount of waste expected to be generated, consistent with ship operations and size, the amount of waste bond that should be posted can be determined. Many factors that must be considered when setting the bond amount, including practical, economic and political factors. The waste bond would be held in escrow, possibly using a conventional commercial mechanism, and rolled over annually for each license period, or as required. Those vessels that consistently fail to manage their waste may lose their bond. 

Action points A to E could be conducted over the course of a year, so that by the end of the first year the formula for expected waste will have been developed, and templates for Garbage Record books and management plans have been field tested. The study of a select small number of vessels that currently have good waste management systems can be conducted using a cohort of waste-trained observers. At the start of a new licensing period, vessels will be required to post a waste bond that will be fully refundable when, at the end of the period, the expected amount of waste has been off-loaded. Vessels that are being re-licensed can roll-over their waste bonds. Non-compliant vessels will lose their bond and be required to pay another. Fishing vessels that pass their waste on to a carrier vessel can be deemed to have effectively fulfilled their responsibility, thus transfering that liability to the carrier vessel. Carriers will also be required to have waste bonds as part of their licensing conditions, and will acquit those responsibilities at the point of off-loading waste to a port, and recorded in their Garbage Record book. 

The amount of a waste bond to be paid could be set at the end of each permit period, using a sliding scale that rewards good operators, and puts pressure on the worse ones by increasing the level of their bond.

Vessels that can demonstrate full compliance with MARPOL and produce records and plans to support that compliance, including pictures of the current waste management situation on the vessel, may not be required, at the discretion of FFA, to post a waste bond. This rewards businesses that are already making the required effort to manage their waste responsibly. This is consistent with strategic points 4 and 10.

G.    Communicate the new waste regime to FFA stakeholders.

If the above action points are adopted and implemented, then the rationale for following them needs to be communicated to key stakeholders during the development stage. This could be refined and spelled out in at least two briefing papers: one that is more detailed along the lines of an executive summary that might go to key stakeholders, and one that is a factsheet that can be more widely circulated to those who are less interested in the details but need to know about the coming changes to licensing conditions.

Subsidiary actions

Strengthening enforcement and reporting of WCPFC CMM 2017-04

The MARPOL requirements described above must be viewed in the light of WCPFC CMM 2017-04, which expressly addresses waste from fishing vessels. The section of this report that discusses this alignment clearly demonstrates that these proposals to drive as much waste as possible back along the logistical pathway provided by the carrier fleet is the cheapest option for both SIDS and distant-water fishing nations and Flag State operators. 

CMM 2017-04 explicitly recognises that WCPFC members, cooperating non-members and participating territories (collectively referred to as CCMs) should follow MARPOL; it also explicitly recognises that SIDS are challenged through an inability to provide adequate facilities for receiving and managing waste from ships in their ports; and explicitly states that[9]

CCMs shall cooperate, consistent with national laws and regulations, directly or through the Commission, and in accordance with their capabilities, to actively support SIDS and territories through the provision of adequate port facilities for receiving and appropriately disposing of waste from fishing vessels. [emphasis added.]

It is incontestable that it will be far cheaper for both SIDS and Flag States to drive waste back through the logistical chain to ports that do have adequate facilities to accept commercial wastes from fishing vessels. The cost of building landfills and other waste management facilities in SIDS is not only immense but a long-term programme of improvement completely unsuited to the vagaries of short-term commercial considerations. 

Through the waste bond system proposed, which would of course also apply to carrier vessels and any other FFA-licensed vessels, the carrier fleet can actively participate in ensuring that waste only goes to ports that have adequate facilities. As carriers take on the waste from fishing vessels – even from vessels belonging to a different Flag State to the carrier – a secondary market will spring up whereby carriers are paid by the fishing vessels to take their waste away – just as vessels would normally pay to have their waste disposed of in port.[10]

The Garbage Record book/logsheet will record transshipment to a carrier as a transfer of ownership just as it does with fish, and so fulfil fishing vessels’ obligations to dispose of their waste correctly under the conditions of the waste bond. The cost will be up to the market and will also be influenced by the amount at which the waste bond is set: if set too low, the market will not function. Carriers will then in turn pay to dispose of the waste at a port with adequate facilities. This proposal is using market mechanisms to enact point 8 of the CMM, and at a far lower cost than that of financing waste management facilities and landfill construction in SIDS. 

Similarly, the action points recommended in this report will help address CMM points 9[11] and 10[12]: the loss and recovery of fishing gear. The proposed Garbage Record book/logsheet to be developed could easily incorporate a lost fishing gear component; if fishing gear were both marked (as required by the Harmonised Minimum Terms and Conditions) and logged as lost, then this study proposes using a waste bond as an incentive to those vessels that recover lost fishing gear, in line with strategic points 9 and 10 above.

Inclusion of CMM 2017-04 and MARPOL issues as part of electronic monitoring objectives

Electronic monitoring is set to be deployed in the region and already plays a role in pollution monitoring, despite the political, logistical and operational problems discussed. Therefore, the potential of incorporating issues related to waste offloading to the present scope of electronic monitoring is consistent to both areas of compliance. 

Off-loading fish to a carrier vessel or at a home port should be accompanied by off-loading of waste, and thus could be easily verified through video footage. Video observers should not be expected to look through large quantities of footage for incidents of waste being dumped overboard during normal ship operations. This is consistent with strategic points 5 and 6.

Strengthening existing requirements of marking fishing gear and using biodegradable fish aggregating devices 

The IMO Action Plan[13] suggests that fishing gear should be marked with the deploying vessel’s identifiers, and this should also apply to FADs. If this measure was enacted, it would be possible to reward those who collected discarded fishing gear by using the waste bond money of those who lost the gear. 

There is a large area of potential study and policy development to consider when working out a sliding scale to sanction those who lose large amounts of fishing gear at sea. For example, the loss of a FAD that was built with only biodegradable materials, designed to break down over time in the ocean, and not entrap bycatch of any sort might not incur penalties; the loss of a FAD made of plastic components, on the other hand, would. A waste bond could provide the source of funds. Such work would need to be conducted after the effort to develop an initial waste bond level. 

Conclusion 

If the above proposals were to be accepted and acted upon, there are many details to be worked out; but the proposals developed here are offered as a workable way forward to address what has been, until now, somewhat of an intractable problem. These proposals show a clear way forward using the principles of waste management and economic incentives that have been tried and tested, and proven to be successful, albeit in quite different fields. They could, however, well work in this one too.


[2] Leney A., Blaha F. and Lee R. 2021. An assessment of fishing vessel plastic waste generation in the WCPO region – And potential measures to improve waste management in the fleet. Honiara, Solomon Islands: Pacific Islands Forum Fisheries Agency.

[3] https://www.imo.org/en/About/Conventions/Pages/International-Convention-for-the-Prevention-of-Pollution-from-Ships-(MARPOL).aspx

[4] https://www.imo.org/en

[5] https://www.wcpfc.int/doc/cmm-2017-04/conservation-and-management-measure-marine-pollution

[6] The Economics of Biodiversity: The Dasgupta Review February 2021: https://www.gov.uk/government/publications/final-report-the-economics-of-biodiversity-the-dasgupta-review

[7] There are a range of potential financial mechanism by which businesses operate escrow arrangements, for example “trust accounts” and “bank guarantees” to name but two. 

[8] Resolution Mepc.244(66) 2014 Standard Specification for Shipboard Incinerators

[9]WCPFC CMM 2017-04 Adoption Point 8

[10] If a fishing vessel is not already paying to have its waste disposed of in port, then it is clear why the WCPFC states in CMM 2017-04 Preamble: “convinced that certain activities associated with fishing may affect the Western and Central Pacific marine environment … and impacts on marine ecosystems”.

[11] CMM 2017-04 Adoption Point 9: CCMs are encouraged to develop communication frameworks to enable the recording and sharing of information on fishing gear loss in order to reduce loss and facilitate recovery of fishing gear.

[12] Ibid, Point 10: “CCMs are further encouraged to develop frameworks or systems to assist fishing vessels to report the loss of gear to their Flag State, relevant coastal States, and the Commission.”

[13] Resolution Mepc.310(73) Action Plan to Address Marine Plastic Litter from Ships

A look on the mental health of fisherman by Francisco Blaha

I have been always quite open that I got into fisheries for two main reasons: 1) I always loved the thrilling and open nature of the ocean (particularly after my time in the navy as a cadet), but equally important 2) because I really didn't fit anywhere else…

Let it be your reality for 3 years no going home.

Let it be your reality for 3 years no going home.

My dyslexia was shown as a sign of being dumb, add to that I’m (and was even more at the time) what we will call today neurodiverse, and definitively had PTSD (still today). At almost 2 mts tall (6’6) and a competitive rower and Rescue swimmer, I was quite imposing, and no one really knew how to deal with me (nor I knew how to deal with them nor my self

When I started the main qualifications you needed to go fishing is a hard stomach and to don't give a shit about much really… so was kinda natural fitting. It was rough, but the entry requirement was really low, you made relatively good money and had a strong fisherman union.

Yet you realize very soon that is not a job for “normal” people. If you don't really know if you coming back every time you get out fishing, everyday life looks rather different. Life at sea sorts out people quite fast, either you deal with it, or you don't and you never come back, and that is ok, we respect that.

Also the basis of your relationship with fellow humans changes… when you share living quarters that are barely liveable with people you never meet before, yet you hear ALL their body’s noises less than a meter from you… one develop an open mind and thick skin. I soon realize, I didn’t have to like the bloke next to me… nor he had to like me… but we need to trust each other because our life depends on each other. I fished with awesome people and some real shitheads, whose views about aspects of life I despised… but they were “solid” fisherman and I’ll have them as crew anytime.

In any case, fishing was (and still is) the option for people on the margin of “normal” society, for the “unadapted” (what a concept!), to have a chance to make relatively good money (at least in comparison with the other options available) if one had the guts to deal with it.

That was then… today’s picture is different, while still has some of those guys, but now includes the poorer (and sometimes options-less) citizens of complex countries in SE Asia (Philippines, Indonesia, Vietnam, Myanmar, etc). I fished with many of them and their angle was different, their options are so much more limited than for westerners (or part Europeans like me) so they get into fishing because is one of the few things they can do and not because they are not really good for anything else (as in my case).

Needless to say, fishing with them was one of the best and more eye-opening experiences I had onboard fishing boats, amazing, resourceful, resilient and truly gentle people coming with a worldview most westerners will never grasp.

Some of the most positive and resourceful people you’ll ever meet

Some of the most positive and resourceful people you’ll ever meet

For many of these reasons, I was interested in the title of this paper “Mental health in the commercial fishing industry: Modern uncertainties and traditional risks” and had a read.

On the bridge of the Ocean Breeze south of Tazzie

On the bridge of the Ocean Breeze south of Tazzie

I liked it, even if I immediately understood that it was a very geographically and socially limited view of fishers… I only fished with a mixed NZ / Australian crew out of Hobart for Hoki in a factory vessel (the Ocean Dawn) in 1997… and it was up with the most comfortable and safe fishing trips I ever had.

So I think these results are equally comparable to those we find in NZ where I worked more extensively in smaller vessels… yet in any case, they were a far cry from some of the shit boats I been working in Argentina and the Pacific.

I did especially like the fact that it separated the ‘stressors” into two “usual” categories: ‘traditional risks’ and ‘modern uncertainties’ and adds a new one “future concerns

The ‘traditional risks’ of fishing include the physically dangerous nature of the job, the variable weather, long and unsocial hours of work, being self-employed, managing crew dynamics, responding to fluctuating market conditions, and variable catches. While it is impossible to eliminate these risks, fishers do have some day-to-day control over traditional risks through their skills, knowledge, and experience. It is argued that fishers have traditionally faced these stressors with virtuosity, through some combination of a heightened tolerance for risk, a capacity to navigate and mitigate such risks through either learned or inherent characteristics and abilities, and through a willing trade-off between the perceived risks and rewards of the lifestyle … basically is ‘what we signed up for’.

In contrast, ‘modern uncertainties’ is where I see (somehow ironically) the privilege of being a fisherman in rich countries… because we are talking about increasing regulatory surveillance, oversight and compliance requirements, a reduction, removal, or restructuring of access rights (including intergenerational access), negative representation in the media and conflict with other stakeholders (e.g. anglers, energy developments, other commercial fishers). Modern uncertainties tend to emanate from policy decisions that have arisen in recent decades as the regulatory environment has tightened in response to actual and perceived environmental decline. While regulatory agencies purportedly make policy decisions about fisheries access and practices in a manner consistent with scientific evidence, the powerful role of public opinion, political negotiation, and including a sense of public disregard or even demonization, which potentially undermines political support for commercial fisheries, are types of modern uncertainties that have added to the stressors already posed by traditional risks.

This is not to say at all… that these modern ones are not important… I never felt so much like shit when my young daughter was almost apologetic in saying to a friend that I was a fisherman but a nice one… as if I was a criminal or something… still stings my soul.

For the foreign fisherman (normally these from poorer countries) the ‘modern uncertainties’ are a luxury most of them cannot afford… their reality is an amplification of the the “traditional” ones… no money, not being home, in most cases no legal status or protections on board. Needless to say, the “future concerns” are even less than an option, since when you barely have a present… the future is an extravagance. 

Multiculturality in  a tuna seiner

Multiculturality in a tuna seiner

Anyways, an interesting paper I just will highlight some elements from the introduction and the conclusion, but as always: read the original!

 Introduction

Commercial fishing poses a range of physical and mental challenges. Levels of physical injury and fatality exceed those of most other peacetime occupations, and labouring in dangerous or demanding environments can put pressure on the mental health of workers. However, research also suggests that overcoming physical challenges and managing calculated risks can contribute to fisher job satisfaction. Many remain in the job long after it would be economically rational to leave because of an emotional attachment to the occupation and lifestyle. Understanding poor mental health that occurs within the fishing industry requires careful atonement to the culturally specific negotiation of risk and harm.

For over twenty years, researchers have suggested that the state of mental health among commercial fishers is cause for concern. In 1998, was reported that 35% of 567 Gulf of Maine shrimp captains interviewed had a diagnosable mental health disorder, roughly double that of the general American male population. Since this alarming discovery, there has been little attention paid to understanding the state of mental health among commercial fishers. While qualitative social science has explored the nature of the problem and considered underlying drivers, few have quantitatively measured the state of fishers’ mental health until very recently.

What drives poor mental health in any individual is complex and multifaceted, and incorporates environmental, biological, cultural and circumstantial factors. Some research links the physically risky nature of working at sea and the accompanying isolation with poor mental health (ITF Seafarers’ Trust, 2017); however, these assumptions remain largely untested. Seafarers also report that long periods of time spent in nature, or among a small group of like-minded colleagues, are an appealing, emotionally uplifting aspect of the occupation.

Conclusion

This study provides robust quantitative evidence supporting the call for greater attention to fishers’ mental health. There has already been significant work done by researchers and practitioners to identify ways to improve mental health in cohorts with which fishers overlap (e.g. ‘men’, ‘primary producers’), and opportunities exist for tailored remedial measures to be modelled on proven techniques. The novelty of this study is that it delineates stressors in a way that allows a clearer understanding of the threats that are specific to fishers— and therefore possible avenues for even more bespoke solutions— to improve mental health in the fishing industry.

This study differentiates between the categories of stressor that are expected to affect the mental well- being of fishers, namely ‘modern uncertainties’, which are largely beyond fishers’ individual control, and ‘traditional risks’, where some individual mitigation actions are possible, and adds the category of ‘future concerns’. The finding that modern uncertainties had a significantly greater im-pact on skippers than crew supports the idea that these stressors are likely to be more detrimental to their mental health than those traditional risks they ‘signed up for’. In contrast, the younger crew cohort was more likely than skippers to experience future concerns about climate change and changing skill requirements.

These findings provide strong evidence that changes to factors associated with modern uncertainty stressors - government management techniques, media representation, political support - could significantly improve mental health and well-being in the commercial fishing sector. Possible avenues of change may be streamlined administrative requirements, more explicit support from political representatives, and positive media representation.

STATEMENT BY THE MARSHALL ISLANDS TO THE FAO PSMA MOP3 by Francisco Blaha

All this week from 8 to 12 pm I’m attending the Third Meeting of the Parties of the 2009 FAO Agreement on Port State Measures (PSMA) #PSMAMOP3 being hold virtually. I’m supporting my friend and colleague Sam on some technical issues, yet I’m totally proud of his statement, presented below.

STATEMENT BY SAMUEL K. LANWI, JR.
DEPUTY PERMANENT REPRESENTATIVE
PERMANENT MISSION OF THE REPUBLIC OF THE MARSHALL ISLANDS TO THE UN OFFICE & OTHER INTERNATIONAL ORGANIZATIONS IN GENEVA

 Third Meeting of the Parties to the 2009 FAO Agreement on Port State Measures

31 May 2021 

Agenda Item 3: Status of the PSMA 

Thank you Chair,

Having the second busiest port in the world in terms of frequency of port calls by foreign fishing vessels, with over 450 tuna transhipments carried out each year prior to the pandemic, the Republic of the Marshall Islands considers efficient fit-for-purpose Port State Measures as fundamental to our obligations as a responsible Coastal State, Port State, and Flag State. 

We continue to support the 2009 FAO Agreement on Port State Measure and have been building our national capacity to ensure that our operational capabilities are aligned with the PSMA to which we are planning to become a party over the next 12 months as we continue to strengthen our reporting capacity. 

Having said that, we look forward to learning more about the capabilities of the PSMA Global Information Exchange System (GIES) and its practical applications across the board. 

Chair, 

In our view, high seas transhipments and Port State Measures are intrinsically linked, so we welcome the ratification of the PSMA by members that have fishing fleets operating in the Western and Central Pacific Ocean and further encourage them to uphold their commitments, under Article 20, Paragraph 3 of the PSMA which states: “Each Party shall encourage vessels entitled to fly its flag to land, tranship, package and process fish, and use other port services, in ports of States that are acting in accordance with, or in a manner consistent with this Agreement.” 

For our part, even though we are not yet a Party to the PSMA at this stage, we have been actively working to build and further strengthen our operational and reporting capacity in a consistent manner in line with the PSMA which has given us the advantage of learning by doing and observing lessons learnt thus far by PSMA Parties. 

The Republic of the Marshall Islands look forward to actively participating in the FAO's planned expert consultation and voluntary guidelines on transhipments over the next 2 years, as we consider standardization of terminology and practices as key to our collective PSMA responsibilities. 

I thank you Chair.  

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Seafood and health: What you need to know? by Francisco Blaha

Recently I commented that what I miss from my fishing days, was that a the of my working day, I could look down to the fish hold and see food for thousands… now I just click “save” on my computer, and put it to sleep.

This made me realize, again and again, something that is so easy to forget and seems to be mostly missed in the discourse around fisheries that is overwhelmingly focused on the resource, sustainability side with an overreliance to see people in fishing as greedy environmental (and otherwise) criminals or just pure victims.

P&LSolomons 5.jpg

We don’t fish to pile it somewhere… we fish because people that do not catch fish do like eating fish… and is really good food!

These aspects of fish as good food seem to be particularly blurred in developed nations (that are the buyers of over 80% of the fish produced by developing nations)

Back when fishing, it was an epiphany for me to realise that once the fish is on deck, isn’t just fish anymore… is food, and as such a whole different regulatory, scientific and operational world opens… and one that wasn’t worked out much on fishing vessels since the people in that world tends to be food scientists, veterinarians, microbiologists and so on… not really fisheries people… even if all starts in a fishing boat.

So during my early years as a consultant, as an immigrant, I had to find a work niche that wasn’t taken by many established consultants… and absolutely no one that knew fishing from the inside was working on the “fish as food” area… particularly when it became a market access issue via food safety, country competent authorities and the lot… so besides getting good work I also did my 2nd MSc.

Anyway… my 1st love was always fishing, so once established… I moved away because also during those years I trained and worked a lot of good people that stayed into that area, and are doing a great job.

S when this little paper came to my attention today in a miserable Wellington sunday while i’m at the airport, is juts to good to not write something about it and promote it.

The main author Catherine (Chengchu) Liu, Ph.D. starts from the challenging presmise that "not eating enough seafood" is the leading seafood problem in the USA (And also asume that it would extend to most developed countries) In order to address this issue, she recently wrote a chapter entitled "Seafood and Health: What You Need to Know" for a book "Advances in Food & Nutrition Research". It was just published online by Elsevier. The publisher provides 50 days' free access to this chapter.

Anyone can access it by clicking on the link below before June 25, 2021. https://authors.elsevier.com/a/1d0vi3jGE%7Eq8yo

I personally think that those of us working in the fishing side should actually quote parts of papers like this more often… as it is a fundamental reason of why we fish and we need to get it right.

I just quote the abstract and conclusions, but have a go to the whole paper, even if it is “USA centric”

Abstract

Seafood, including fish and shellfish, provides an ideal package of nutrients and is an important part of a healthy diet. Strong evidence has shown that eating fish and otherseafoods improve brain, eye, and heart health. The new 2020–2025 Dietary Guidelines for Americans (DGA) recommend that Americans of all ages should eat more seafood—at least twice a week—particularly pregnant women and young children. However, less than one in five Americans heed that advice. About one-third of Americans eat seafood once a week, while nearly half eat fish only occasionally or not at all. This calls for a drastic shift in the American diet to vary protein sources and include more seafood products in order to receive the most health benefits. This chapter covers (1) seafood nutrition and health benefits, (2) seafood’s protective effects against mercury toxicity, (3) selenium health benefit values (HBVs), and (4) challenges and opportunities for seafood production, demand and sustainability. This chapter aims to convey recent advances in science-based information to increase public awareness of seafood safety, nutrition and health benefits of seafood as part of a healthy diet, and to advocate healthy eating with smart food choices by promoting two servings of seafood per week. This will support the healthy eating patterns and promotes a minimum two to three servings of seafood recommended by the current DGA.

Conclusions

The benefits of seafood consumption are observed in improved neurological health and development, as well as in the protection of cardiovascular and ocular health. Increased seafood intakes are associated with reduced cancer incidence and diminished development of neurodegenerative diseases.

While public awareness has previously focused on Hg exposures, advances in understanding emphasize the need for ensuring adequate intakes of seafoods. (My blog posts on Mercury in tuna, are some of the most visited… with over 25000 visits over the years)

Although fish and shellfish may contain microbial or chemical contaminants, evolving scientific understanding has revealed that far greater health risks accompany the nutritional deficits that arise from the inadequate seafood intakes of U.S. consumers. The adverse effects of seafood deficient diet include diminished child neurodevelopment, increased risk of cardiovascular, ocular, cancers, and neurodegenerative diseases and disorders.

Previous public health campaigns were successful in urging caution but now that the assumed risks have been found to be largely absent while substantial beneficial effects accompany ocean fish consumption, outreach efforts are required to overcome the mistaken ideas developed from decades of largely inaccurate public assumptions.

Comprehensive communication Public health policy makers and regulatory agencies need to become aware of the environmental significance of multiple concomitant exposures to metallic and organic soft electrophiles and the importance of Selenium rich seafoods in providing far-ranging benefits. There is an urgent need to improve seafood consumption during pregnancy and childhood to ensure future generations receive health benefits and enjoy longer, healthier lives.