Dear Dr Kiene and members of the Board
(Cc Rupert Howes)
On The Hook call for an independent review of the Marine Stewardship Council
Thank you for your letter of July 12th, in response to On The Hook’s relaunch and call for a full independent review of the Marine Stewardship Council’s (MSC) Standard, governance and operations.
While we appreciate that MSC is a global standard setter endeavouring to balance the needs of wide-ranging stakeholders and fisheries, unfortunately your letter did not alleviate our concerns that MSC must reform to retain credibility. We therefore write once again to call on MSC to undertake a full, external, and independent root-and-branch review covering not just its Standard but also its governance, operations, business model and application of that Standard.
In its 25 years of existence, the MSC program has grown and developed substantially, and the ecological emergency which it seeks to address has become ever more urgent. It is therefore not unreasonable that stakeholders are calling on MSC to take this opportunity to understand, via an external and independent review process, whether it is still delivering effectively on its stated aims and whether its operations are keeping pace with the scale of the crisis in our ocean.
We write therefore to inform you that if MSC does not itself initiate an independent review process covering its Standard, governance, and operations then we, the On The Hook campaign, intend to do so ourselves.
We unfortunately do not share the view stated in your letter that “existing governance systems provide sufficient rigour and oversight”. The ISEAL and GSSI guidance referenced is simply a benchmarking tool rather than an indication of the level to which a ‘gold standard’ ecolabel should aspire. Furthermore, while the board of trustees, TAB and STAC are valuable resources, these bodies are selected and have their scope determined by MSC and place limited information in the public domain. They provide a crucial input to MSC but not one which replaces the need for external involvement.
There are substantial underlying weaknesses in the MSC process, which will not be effectively resolved through the Fisheries Standard Review for reasons including that:
• The FSR is an internal MSC-driven exercise, meaning it is inevitably shaped by MSC interests and priorities.
• Stakeholders do not shape the agenda of the FSR but merely feed in through limited consultation windows on pre-determined topics and proposals.
• Processes of decision-making are unclear, as is whether stakeholder input has direct bearing on subsequent policy outcomes, as evidenced by recent stakeholder rejection of MSC’s eventual shark finning proposal.
• The FSR is focused solely on the Standard and does not address broader questions of MSC’s management and governance, charitable objectives, scope and intent, the underlying philosophy in terms of how sustainability is defined, or the application of the MSC Standard by CABs and whether MSC has sufficient oversight of this process.
• It is a slow process which, coupled with long implementation periods, means MSC inevitably falls further behind the curve of rapidly evolving science and best practice.
• It is heavily framed around what is feasible for fisheries to adopt rather than what is desirable in order to improve fishery operations and ocean health.
• Participation is inaccessible, requiring familiarity with a range of jargon and documents and with certain workshops being invite-only or requiring a level of expertise. While clearly technical scientific input is valuable, it is certainly not the only valuable form of knowledge, and aspects such as the broader intent and level of ambition should be shaped in consultation with a wider stakeholder audience.
Quite simply, if the current review process was adequate then we would not be seeing the current rate of certification of unsustainable practices and fisheries happening, which is eroding sector and public confidence. It is for this reason that we have repeatedly proposed a full independent, external review which should:
• Consider holistically not just the MSC Standard but also the application of that Standard, MSC’s mission and philosophy, and its management, governance and operations.
• Focus on what MSC could and should be, in order to drive improvements on the water, rather than what is feasible for certified fisheries to implement.
• Be accessible to all forms of knowledge and all stakeholders.
• As a voluntary and additional exercise, move faster than the Fisheries Standard Review process.
Our proposal is that this review:
• Begin with an entirely open call for (publishable) evidence from all stakeholders on whether MSC is effectively delivering on its stated objectives and, if not, what needs to change.
• Convene a panel of external experts from key stakeholder groups (e.g. science, conservation, retail, industry, human rights) to systematically investigate the topics raised by stakeholders through a series of publicly available evidence sessions with expert witnesses who have relevant experience and constructive suggestions.
• Result in the publication of a report summarising written and oral evidence and publicly making recommendations to MSC, which MSC would be accountable for implementing.
We are proposing that this be a sharp, timebound exercise looking at the bigger picture of how MSC can effectively deliver on its objectives, rather than a further detailed analysis of the Standard. As this exercise is not focused solely on the Standard, but rather on the entirety of MSC’s operations, we do not agree that this risks duplicating the Standard Review but would suggest rather that it is a necessary complementary process which should feed into and strengthen the ongoing Fisheries Standard Review.
We have always been clear that the independent review should ideally be instigated by MSC, in order that it is given the access it needs and that it can most directly drive change. However, the need for this exercise is becoming increasingly urgent as the number of unsustainable certified fisheries grows, as does the number of unsustainable fisheries entering the MSC program, and the current FSR process will not resolve this. Therefore, we wish to inform you
that if MSC does not accept the need to initiate such a process then we will be seeking to open this long-overdue conversation ourselves by opening a public review of the MSC and inviting all stakeholders to participate.
As this letter relates to serious and long-term concerns regarding the functioning and credibility of MSC, we believe that this warrants a board-level response and look forward to hearing from you.
Yours sincerely,
Blue Marine Foundation
Blue Seas Protection
Environmental Justice Foundation
Fair-fish International
Island Conservation Society
Shark Guardian
SharkProject International
World Wise Foods
Prof. Jennifer Jacquet
