SEAFOODNEWS.COM By John Sackton and Peggy Parker — November 13, 2014 — Seafood buyers and suppliers are coming together over something called GSSI – and if it is successful, sustainability will become a norm in the seafood industry; not an arena for brand competition.
Such an outcome would go a long way towards normalizing long term sustainability for wild caught fisheries, and establish that sustainability, like food safety and sanitation, is a given for seafood buyers, not something to be negotiated separately for each purchase.
GSSI stands for Global Seafood Sustainability Initiative. It is modeled on a successful global retail program called GFSI – the Global Food Safety Initiative.
The initial draft of the GSSI standards, released for public comments in June, attracted a lot of industry and FAO comments regarding whether the draft was sufficiently focused on the core mission of providing a benchmark for sustainability certification that would reduce market confusion. In particular, the FAO and may industry commenters focused on the fact that GSSI was considering a multi-tiered system based on rankings, rather than a simple pass / fail system to certify meeting FAO standards on sustainability. They argued this approach undermined the basic reason a global initiative was undertaken.
The GSSI Steering Board will meet on December 10-11, 2014 in Amsterdam to address these and other concerns identified through the public comment process.
To understand the issues, it is helpful to compare the GSSI to the Global Food Safety Initiative, on which it is based. (We apologize for all the acronyms. GFSI is Food Safetey. GSSI is fish.)
GFSI explains itself: “During the 90s, there were a series of high-profile international food safety crises including BSE, dioxin and listeria. Within the food industry there was a growing audit fatigue as retailers and brand manufacturers audited factories against their countless in-house standards, each developed in isolation and with no consideration of convergence. The results showed no consistency. Consumer and food industry confidence was low.
The CEOs of the world’s food retailers agreed to take collaborative action. In May 2000, the Global Food Safety Initiative, a non-profit foundation, was founded.
GFSI specifies requirements for food safety management schemes to meet its standards, as specified in their guidance document. Schemes that meet the standard are all equally compliant. GFSI also brings together global food safety experts to expand and update standards as needed. Finally, GFSI stimulates multi-stakeholder projects for collaboration on common issues, such as building out food safety capacity.
GFSI has been very effective in reducing audit costs and simplifying and standardizing food safety certification requirements.
GFSI is also very clear about what they do not do. They specifically do not
– Make policy for retailers, manufacturers or food safety scheme owners
– Undertake any accreditation or certification activities
– Own any food safety schemes or standards
– Undertake training
– Have any involvement outside the scope of food safety, such as animal welfare, the environment or ethical sourcing
For seafood, a number of major retailers, manufacturers and foodservice companies, including Delhaize, Kroger, Loblaw, Metro AG, Marks & Spencer, Sainsbury’s, Royal Ahold, WM Morrisons, and foodservice companies including Darden, Sodexo, and producers and manufacturers like American Seafoods, Bumblebee, Espersen, Gorton’s, High Liner Foods, Iglo, Lyons Seafood, Marine Harvest, Pacific Seafood, Slade-Gortons and Trident among others have come together for a similar purpose.
The companies have formed a strategic alliance to “bring clarity and transparency to the issue of the sustainability of seafood worldwide. ”
The benefits will be to first, reduce the duplication and redundancy and cost of seafood sustainability certifications, and second to reduce consumer confusion about seafood sustainability brought about by the number of competing standards all claiming to represent a certification for sustainable seafood.
The GSSI standard will measure conformity with seafood sustainability indicators based on the FAO Guidelines for ecolabeling fish and fish products from wild capture marine, inland and aquaculture production.
Although no NGO’s are funding partners of the GSSI initiative, the New England Aquarium, and WWF and the Von Thunen Institute are affiliated partners.
However, the NGO representatives have been very active in working groups developing criteria for the benchmark.
For example, in the three working groups on Process, Wild Fisheries, and Aquaculture, NGO representatives made up about 40% of the membership in each group.
Right away a major problem emerged. The initial idea of GSSI was to provide a pass-fail standard, so that each sustainable certification scheme that met the FAO criteria was identified, and was to be considered equally effective as the other schemes. This is what was behind the goal of simplification.
But that approach undermined the NGO business model, and was fiercely opposed. Instead, the NGOs demanded a ranking, where each sustainability scheme would be ranked or scored based on not just whether they met the FAO criteria, but on how much they exceeded it, on how much they incorporated other goals beyond the FAO consensus, and on how they conformed to a particular concept of governance that would disqualify most national schemes or government certifications.
Why the ranking demand? Because the NGO community is now the beneficiary of approximately $500 million annually spent by donors and foundations to support marine sustainability. There is fierce competition for this money among NGOs, and they must differentiate themselves from each other to secure the most funding.
At the same time, there is intense competition among the NGOs to sign up industry partners, in particular retailers, whom they promise brand protection in exchange for a paid partnership.
WWF for example is paid hundreds of thousands to potentially millions of dollars by retail and foodservice partners to provide advice and guidance on sustainability. If a global standard emerged, the monetary value of the WWF partnership would diminish substantially.
So the NGO solution was to incorporate their desire for ranking within the draft GFSI guidelines, or threaten to not cooperate.
The initial draft of the GSSI benchmarking tool included a number of tiers or ranking measures that would preserve the NGO business model.
That met with fierce resistance from many industry commenters, and from the FAO, which saw the complexity of ecolabeling schemes as a direct threat to seafood trade from less developed countries.
Less than a month after the new tiered version of GSSI was released, FAO sent a strongly worded letter to the GSSI Board.
“We have some concerns about additions and modification to indicators above and beyond those derived from the [FAO] Guidelines to produce the GSSI baseline, ” wrote Lahsen Ababouch, Director of the Fisheries an Aquaculture Policy and Economics Division, which created the series of FAO documents that represent the FAO responsible fisheries standards and their eco-labeling guidelines.
The “additions” would be Tiers 2 and 3, which go beyond FAO’s international standards and enter the world of “aspirational” goals. Those goals are fine for and if they are relevant to a specific fishery, market, or customer base, but they are impossible to apply as an international standard.
“Another concern… is the potential for the GSSI benchmarking tool, given the proposed application rules, to block new certification schemes and developing country exporters from access to their traditional markets. ”
The letter encouraged the GSSI Steering Board to be “inclusive” by not exclusively favoring only “large existing certification schemes and well-advanced operations. ”
For example, some countries, such as Thailand, are committed to establishing a national certification scheme that would measure Thai fisheries and aquaculture against FAO guidelines. Under the original GSSI initiative, it would be a welcome development if the Thai national scheme was assessed and found to meet the FAO standards. In that case, fisheries and aquaculture certified as compliant by Thailand would be recognized in the international market as meeting the Global Sustainability Standard.
Subsequently if buyers wanted to use other criteria, such as labor law enforcement, by catch reduction, or traceability of fishmeal, they would be free to do so, just not have these more unique and buyer specific requirements enshrined in an international standard.
The current draft of the GSSI standard would preclude a national standard in Thailand for example, from every being certified as meeting FAO sustianable seafood and aquaculture guidelines.
At the heart of the FAO’s concern is the fact that certification schemes for sustainable fisheries have so far focused on developed nations that are large seafood producers, and virtually ignored established fisheries from developing nations.
If the GSSI were to adopt a tiered approach to sustainability, rather than a simple “pass/fail”, developing nations with established and sustainable fisheries would likely be shut out of the market. This goes against the FAO mission of expanding markets and increasing food security around the world.
“FAO member States from regions outside those that are engaged by GSSI will be critical of these new higher ‘standards’, of their interpretation as ‘benchmarks’ and ultimately, of the ‘codification’ of non-binding aspirational guidelines that were not intended to be used as standards, ” wrote George Clement, CEO of Deepwater Group, representing New Zealand’s fishing industry.
Two examples he gives of aspirational guidelines that were never intended to be standards would be bycatch and data collection/management. The FAO addresses these important issues head-on and in detail, but stops short of imposing international measurable standards.
The many FAO documents on precautionary approaches, reference points for fisheries management, and technical issues intentionally describe these approaches as guidelines, not standards. There are too many variables for FAO to issue a document providing a “single prescription of optimal management in the case of a given fishery” as they state in the introductory note to the FAO Fisheries Management Guidelines.
Clement describes the potential of “some markets accepting only Tier 3 standards for certification schemes” thus creating “difficulties for future FAO engagement with GSSI, along with engagement by many fisheries management agencies and certified fisheries. ”
Ultimately, Clements says the three-tiered path may be self-sabotaging.
“It is highly likely that the implementation of three-tiered ‘benchmarking’ system for seafood standards and certification schemes could result in more of the very confusion the GSSI scheme was initially proposed to overcome, with seafood suppliers and customers having no clear and certain understanding of the comparability between fisheries/aquaculture certification schemes in the market, ” he wrote.
These comments were echoed by the comments of the Association of Sustianable Fisheries, a group that represents many of the major fisheries currently certified by the Marine Stewardship Council, and which advocates within the MSC process for the needs of these fisheries.
Writing for the Association, Christina Burrage, chair, "Unfortunately we find that the current GSSI requirements for fishery certification standards no longer looks like a benchmarking tool that provides this common ground, but has grown into something which resembles a full-blown certification standard in itself, i.e. something which essentially attempts to measure the performance of the fisheries, rather than the certification scheme. This seems to have happened through the inclusion of requirements that go far beyond FAO guidelines and current global best practice and science."
"We recognise [these requirements] as aspirations of environmental NGOs. Many of these aspirations were also tabled in the just finished review of the MSC standard, but not carried into the standard because they were considered impractical at the current level of scientific understanding by the experts on the MSCs Technical Advisory Board."
At a recent meeting in New Orleans, Grimur Valdimarsson, who was involved with the initial GFSI effort, said the key to their success was their agreement to only base the standard on the internationally accepted Codex Alimentarius, and reject all efforts to add addiitonal range and scope to the project. He stressed the importance of building the certification tool against those sustainability principles that have broad and widespread acceptance, as indicated by their incorporation in FAO documents representing negotiated language of 191 countries.
At the December meeting of the steering board, it is expected the Board will address the significant number of comments opposed to the initial draft's three tiered system and hopefully a simpler, more robust draft tool will emerge that is more closely aligned with the GFSI.
This story originally appeared on Seafood.com, a subscription site. It is reprinted with permission.