Spiny Dogfish and the MSC – An Interview with Ian Scott

A big developing story in the world of spiny dogfish and fisheries management has been the petition to have the Atlantic spiny dogfish fishery MSC-certified for sustainability.  I’ve been following this story as information becomes available.  Adding some drama to the mix are accusations that the Marine Stewardship Council’s certification process may be influenced more by bureaucracy than science, which is troublesome to hear when a long-lived, slow-growing species is the focus of the fishery.  However, it’s one thing to report on what others are saying, and another to try and find out for yourself, so I made use of the contact information provided by the MSC’s website.

One thing I’m happy to report is that the MSC does make an effort to be reasonably transparent in how they go about certifying a fishery.  Ian Scott, the contact person for Moody Marine, Ltd., who are performing the sustainability assessment for the dogfish fishery, was kind enough to respond to some questions I had regarding how these assessments are conducted and what being certified as a sustainable fishery may mean for spiny dogfish and other sharks.

My questions are in bold, his answers are in italics.

How many sustainability assessments have been performed by Moody Marine, Ltd. for the Marine Stewardship Council?  Which fisheries were they?

MSC certifications are completed by independent third party auditors known as certifying bodies (CB). CB themselves have to be accredited as having the capacity to undertake the work and meet the various conditions.  In addition the work of the CBs is audited by an independent auditing company contracted by MSC. From the MSC web site , I note that there are 9 accredited CBs and 3 in process (http://www.msc.org/get-certified/find-a-certifier/fisheries-assessments).  Off hand, I do not know how many of the 101 certified fisheries and the 131 fisheries undergoing assessment in the MSC programme were completed by Moody, but on the basis of my understanding I would hazard that Moody has completed the most of any CB. A complete list of the certified fisheries can be seen at http://www.msc.org/track-a-fishery/certified and those in process at  http://www.msc.org/track-a-fishery/in-assessment. Details show the CB responsible for each certification.

What criteria usually need to be fulfilled in order for a fishery to be certified as sustainable, and what would you be looking for specifically in the spiny dogfish fishery?

The three principles against which the fisheries are assessed are: (P1) the impact of a fishery on the target species; (P2) the impact of the fishery on other elements of the ecosystem; and (P3) the management system established to ensure the sustainability under the other two principles. We are not looking at anything in particular in the dogfish fishery; we will audit the fishery against the MSC principles and criteria. Each principle comprises a number of performance indicators (PIs). These PIs are scored out of 100 on the basis of how the UoC (see below) meets the standard. If the average score for each principle is 80 or above, a fishery is certified. If a principle  fails to achieve an average score of 80 a fishery fails. If individual PIs fail to achieve a score of 80 – but score 60 or above – then if each principle scores 80 or above a fishery is certified but with conditions on that certification. Clients respond to conditions by defining an action plan that describes how the PI in question will achieve a score of 80 or above within a defined time period (no longer than 5 years). It is for the CB to accept this action plan and audit progress towards its achievement each year. As far as I am aware, to date no fishery has been certified without conditions.

What methods will be used to carry out this assessment?

For each assessment the usual approach is for a nominated three man assessment team to complete the audit – one expert for each principle, one of which has experience in audits and is nominated the lead. The MSC process requires that the audit process be transparent and incorporate to the extent possible the views of stakeholders. The first step is for  a new assessment to be announced , along with the proposed team and the approach (the fisheries assessment methodology or the risk based framework developed to deal with fisheries where data is deficient and not enough to complete the traditional approach). Stakeholders have the opportunity to comment on each of these announcements. After a pre-defined period, the site visit is announced. CBs will have identified stakeholders and will contact them directly, but each announcement is posted on the MSC web site. On the site visit the team meets (i) those stakeholders who have requested a meeting to present their views on the possibility of certification (either for or against) and (ii) knowledgeable persons who can present the evidence needed in order to audit the fisheries and put this in context. Stakeholders may also make written presentations if they so wish.  After the site visit the auditors go away and write their report and review all the evidence as collected on the site visit or identified on the internet. Once the draft is complete the team meets to score the fishery. The scoring is included in the first draft of the report that is sent to the client for comment. The auditors review client comments and amend the draft as considered appropriate. Note however that the auditors are independent; they are not obliged to accept the clients comments. Indeed at this stage it is possible for the client to disagree with the findings of the auditors and withdraw from the process. I have not heard of this happening. Subsequent drafts of the report are reviewed by peer reviewers (version 2) and stakeholders (version 3). The auditors are obliged to consider each comment and detail their response and the report is edited as considered appropriate. The auditors send their recommendation on certification to the Governing body of Moody which makes a determination. This determination is posted on the MSC web site to give the opportunity for interested stakeholders to object. If there is an objection there is a well defined MSC process to handle this including the contracting of an independent adjudicator. Assuming the process is successful a  fishery is certified for 5 years but in that period it is audited each year to ensure that the situation has not changed. Certification takes the fish to the first point of sale; subsequent steps in the distribution chain (where ownership changes of the product is transformed)  are subject to chain of custody audits in order to reduce the risk of certified fish being mixed with non-certified product.
To your knowledge, have any fisheries been rejected by the MSC for sustainability certification?  If so, on what grounds?

As far as I know two fisheries have failed an assessment but there may be more. The most recent was in St Helena. See http://www.msc.org/track-a-fishery/in-assessment/south-atlantic/St.-Helena-pole-line-and-rod-line-yellowfin-bigeye-albacore-and-skipjack-tuna. It should be noted that it is usual for a client to have a pre assessment of a candidate fishery to identify the potential issues in any certification process and indicate whether it may be possible for a fishery to be certified. I have carried out a large number of pre assessments, and my recommendation for at least one-third of them was to not proceed to a main assessment. The details of pre assessments are confidential to the client. The certification process is expensive in term of both $ and time and represents a big commitment from clients.
If the spiny dogfish fishery is certified as sustainable, could this potentially create an opportunity for other shark and ray fisheries to become eligible for sustainability certification?

Not necessarily, each fishery would have to be audited against MSC principles and criteria.

Certification is of a unit of certification i.e. species, gear, sea area and management authority. For US spiny dogfish there are 24 UoC. For British Columbia spiny dog fish there are 2 UoC.

Thanks to Ian for taking the time to respond to my questions.  For further information, check out the MSC’s Track A Fishery page for US Atlantic spiny dogfish, and of course keep checking back here too.

Full disclosure – the author is listed as a stakeholder for the Atlantic spiny dogfish sustainability assessment.

This entry was posted in fisheries management, MSC, spiny dogfish. Bookmark the permalink.

6 Responses to Spiny Dogfish and the MSC – An Interview with Ian Scott

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  3. Fishyfellow says:

    Interesting interview. It is worth noting that Moody has opted for a Risk-based Assessment (RBA) approach, rather than a full blown assessment using the default MSC assessment tree. RBA is a qualitative approach developed by MSC for data-poor cases, particularly in developing nations. What excuse does Canada have for not having adequate data to determine the sustainability of this stock? The last stock assessment in the public domain was carried out by DFO in 1987. A new assessment carried out by DFO in March 2010 has yet to be made public, although one must assume that Mood had a sneak peak, because in October they announced they were switching from the default assessment tree to RBA. Remember, this stock is public property. The public have the right to know what data are available, that the status of the stock has been adequately assessed and any fishery allowed will be sustainably managed from the get-go, not some time down the road when it eventually meets some conditions. Data-poor stocks should not be considered sustainably managed – we need to see data to prove this is so. Read more on this here:
    http://fishyfellow.blogspot.com/2010/11/bc-spiny-dogfish-sustainable-fishery-or.html

    • Chuck says:

      Interesting stuff. I had a post on the BC fishery earlier (http://yalikedags.southernfriedscience.com/?p=278) and thought it was kind of odd that that fishery was considered “data poor.” As far as I’ve been able to find the Atlantic assessment appears to be using the normal approach, but it’s still early on that one.
      As an interesting aside, recent findings suggest that North Pacific spinies are genetically distinct from the populations in the rest of the world, potentially to the point of being a different species. What kind of effects do you think that might have on their management in BC?

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  5. Ian says:

    In response to “fishy fellow” and the comments on the revised approach to the assessment of the BC spiny dogfish fishery, please note the announcement posted on the MSC web site. It is not that as auditors we did not like the PSAR report, rather in the light of the report’s conclusions we felt it appropraite to use the RBF (which can be categorised as being more precautionary that the FAM).

    It is not for me to comment on the distribution of the PSAR report and I do not have an opinion.

    The MSC approach embraces stakeholder participation and I would welcome comments on the potential for certification of the US spiny dogfish fishery, whether these be in favour or against. Please recall that we look for evidence informed opinion related to the three MSC principles, with references as appropriate.

    If anyone would like to attend the stakeholder work shops being held to discuss the BC fishery (stock status) (Nanaimo – 7 Dec morning; Vancouver 7 Dec afternoon) then please let me know.

    Thank you

    [email protected]
    ============================================
    http://www.msc.org/track-a-fishery/in-assessment/pacific/british-columbia-spiny-dogfish/assessment-downloads

    Following the site visit and review of the completed PSAR report “Canadian Science Advisory Secretariat Science Advisory Report 2010/057: Assessment of Spiny Dogfish (Squalus Acanthias) in British Columbia in 2010” the auditors consider it appropriate to use the risk based framework for P 1.1.1 for both units of certification. The PSAR report concluded that; for one unit of certification (the Outside Migratory stock) “there was no consensus reached on a scientifically valid approach on which to base yield recommendations”; and for the second unit of certification (the inside stock – Strait of Georgia (Area 4B)) “in the absence of accepted model derived yield recommendations, qualified harvest recommendations are provided for the inside stock, based on average catch history, trends in survey results and expert opinion”. We welcome any comments on the use of the RBF for PI 1.1.1; these should be sent to Moody Marine using the contact details shown below. Comments should be made as specific as possible concerning the suitability or not of the RBF for use in assessing this performance indicator. As the RBF will be used a further site visit will be required to conduct a stakeholder workshop. This stakeholder workshop will seek to engage stakeholders with a good knowledge of the fishery to allow an in-depth risk based assessment of the status of the stock using PSA and SICA. Further information will be provided to stakeholders once the timing of the visit has been fixed; a specific email will be sent at least two weeks prior to the workshop to provide detail on the approach and the expected output.

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