The Role of Certification in Rewarding Sustainable Fishing

Written Statement of the Gulf Seafood Institute Before the Senate Subcommittee on Oceans, Atmosphere, Fisheries and Coast Guard “The Role of Certification in Rewarding Sustainable Fishing”

September 24, 2013

The Gulf Seafood Institute is pleased to present the following written testimony on third-party sustainability certification of U.S. seafood and its impact on the seafood community, consumers and the marketplace. As a voice for the Gulf seafood communities in Texas, Louisiana, Mississippi, Alabama and Florida, the GSI maintains that the federal government, primarily the U.S. Department of Commerce and the National Oceanic and Atmospheric Administration (NOAA) under the Magnuson Stevens Fishery Conservation and Management Act, must have the loudest voice and the final say when determining the sustainability of our fisheries and when communicating that message with consumers.

The mission of the Gulf Seafood Institute (GSI) is to protect the Gulf’s unique culture and environment while elevating the Gulf seafood brand with consumers, customers and policy leaders through advocacy, education and science. The GSI’s board of directors represents every Gulf state as well as every aspect of the industry – both commercial and recreational – and is positioned to be a leading voice on key issues including sustainability, seafood safety, disaster mitigation and recovery, and data collection. Additionally, GSI will seek to bolster fisheries science and research that will help preserve the Gulf seafood resource and contribute to the longevity of the industry overall. The GSI came together in July 2013 and is currently taking the steps necessary to organize under the laws of the state of Louisiana and will then seek approval of the IRS for determination of approved 501(c)(6) status.

When it comes to ensuring the sustainability of our nation’s fisheries, GSI maintains that the process outlined under the Magnuson Stevens Fishery Conservation and Management Act (MSA) is working. The Department of Commerce, the National Marine Fisheries Service (NMFS) and the eight Regional Fishery Management Councils work together to monitor, manage and enforce a program that has led the United States to its position as a global leader in responsibly managed fisheries and sustainable seafood. Guided by 10 National Standards of sustainability, these agencies monitor, manage and legally enforce all marine fisheries in the United States under the most restrictive regulations in the world. As a result, U.S. fish populations are rebuilding and overall fish abundance is improving. Since 2000, thirty-two fish stocks in the U.S. have been rebuilt meaning that routine stock assessments conducted by fishery scientists indicate that the abundance of the stock is above the maximum sustainable yield.

While protecting our fisheries and ocean ecosystems is imperative in its own right, getting U.S. seafood on the plates of consumers is equally important for both public health and for the economy of the U.S. seafood community. In order to be comfortable choosing seafood when making mealtime decisions, consumers must be confident in the sustainability of our fisheries. Along these lines, NOAA has implemented the FishWatch program as a primary tool to educate the public about seafood sustainability. FishWatch was designed to provide easy-to-understand, science-based facts to help consumers make smart, sustainable seafood choices. According to NOAA, FishWatch does not discriminate against one fishery or advocate for another, nor is it an ecolabel or certification. Rather, FishWatch helps consumers understand the science, laws and management processes working to protect our seafood supply.

Despite NOAA’s efforts to get out the message on sustainability, perhaps not enough is being done as evidenced by an abundance of third-party seafood certification programs competing for the public’s trust and attention. Market demands for more traceability have led to the emergence of several Gulf-based programs including Gulf Seafood Trace as well as state-sponsored programs in Alabama, Mississippi and Louisiana. These programs are supported by many in the commercial seafood community and are seen as a positive compliment to federal data on sustainability by telling consumers a bigger story about where their seafood comes from. However, other programs that pit certain species against one another based on various and sometimes arbitrary criteria go beyond simple traceability and might lead to confusion rather than clarity in the marketplace.

For example, the Marine Stewardship Council (MSC) and the Monterey Bay Aquarium have aggressive sustainability certification programs that are increasingly being relied upon by consumers, retailers and restaurants, oftentimes more than the U.S. government’s own FishWatch program. The MSC, a London-based 501(c)(3) charity which sets standards for sustainability and seafood traceability, has partnered with the world’s leading retailers to help promote certain seafood products that meet their criteria. The Monterey Bay Aquarium’s Seafood Watch program makes recommendations regarding which seafood items are “Best Choices,” “Good Alternatives,” and which ones you should “Avoid.” Monterey Bay Aquarium’s process for ranking seafood is not transparent (unlike NOAA’s process which encourages public participation at every level) which leads to concern from some in the seafood community.

Given the abundance of seafood labeling programs, oftentimes the American public remains confused as to which products meet basic sustainability criteria as defined by the federal government and assured by the MSA process. Compounding this confusion is the fact that third-party recommendations often run counter to recommendations provided by FishWatch. For example, one prominent environmental organization lists most canned tuna as something to “Avoid” while FishWatch provides consumers much more detailed information on these species, leading with the fact that if seafood is harvested in the United States, it is inherently sustainable as a result of the rigorous U.S. management process that ensures fisheries are continuously monitored and improved. When one private third-party needlessly tells consumers to “avoid” canned tuna, one of the least-expensive, readily available sources of healthy seafood for families on a tight budget, they make it very difficult for Americans to meet their recommended three seafood meals per week per USDA’s dietary guidelines.

NOAA has a responsibility to alleviate confusion and encourage Americans to make more trips to the seafood counter by launching a stronger communication and outreach program on seafood sustainability. Consumers are actively seeking input on sustainability and they want this information to come from the U.S. government, not from privately funded third parties. In a survey of nearly 2,000 consumers conducted in 2011 by the Gulf Seafood Marketing Coalition, respondents stated they were most comfortable with seafood data provided by the federal government, over and above data from private industry and environmental organizations. With the USDA pushing their updated seafood consumption guidelines and clarifying guidance for pregnant women, now is an ideal time for the Administration to marry the concepts of healthy and sustainable seafood in their messaging materials.

No one understands the importance of robust communications better than the Gulf seafood community. In the wake of the Deepwater Horizon incident which gushed 200 million gallons of oil into the Gulf of Mexico, overcoming public perception that our fisheries were somehow “tainted” became the biggest challenge to the fishing community’s economic recovery. Despite the fact that thousands of water samples taken by FDA, state health agencies and NOAA tested as completely safe, consumers avoided Gulf seafood on a massive scale for months. Following multi-million dollar marketing campaigns undertaken by the Louisiana Seafood Promotion and Marketing Board, the Gulf Seafood Marketing Coalition and others, consumers are finally returning to Gulf seafood three years after the oil spill. In addition, several letters went out from numerous U.S. Senators to federal agencies calling for support in actively promoting the safety of Gulf seafood and asking for strong refutation of unscientific claims stating otherwise. While the issue of sustainability is separate and apart from seafood safety, there is clearly a need for strong communications from NOAA and its partners on both sides of the seafood coin.

In closing, the GSI is pleased to note that the General Service Administration (GSA) recently rescinded their guidance that the National Park Service look to independent third-parties for seafood certifications. However, the fact that the misguided policy was issued in the first place is cause for alarm. Further compounding this concern is that NOAA was never even consulted prior to GSA issuing this guidance. Clearly, NOAA’s outreach team has their work cut out for them. If the Administration’s own personnel are not looking to NOAA for the facts on sustainability, the American public certainly can’t be expected to. One way Congress can ensure this situation doesn’t arise again would be to pass S. 1521, the Responsible Seafood Certification and Labeling Act, which prohibits federal agencies from requiring seafood to be certified as sustainable by a third-party nongovernmental organization. GSI encourages members of this Committee to work with your colleagues on the Health, Education, Labor and Pensions Committee to move S. 1521 as quickly as possible.

The GSI stands ready to assist Congress, this Committee and the Administration in any way possible to get out the positive story on Gulf seafood sustainability. We look forward to working with you on this and other important seafood issues moving forward. Thank you.

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