Stakeholder Consultation Questions Fair Trade USA Draft Capture Fisheries Standard April - May 2014 Feedback Period Fair Trade USA (FTUSA) recently published a draft standard for the Fair Trade certification of capture fisheries. We welcome any interested party to download the standards and compliance criteria (available at http://fairtradeusa.org/products-partners/seafood/standard-feedback) and provide feedback to FTUSA to fisheries@fairtradeusa.org. We recognize that reading standards can be cumbersome, so have outlined some of the key topics on which we’d like feedback using a questionnaire format. Please feel free to send written comments using this questionnaire, or contact us if you’d like to set up a phone interview to discuss specific topics. The Case for Fair Trade Fisheries Fair Trade USA believes that sustaining fish species means supporting global small-scale fishermen. As the leading third-party certifier of Fair Trade goods in North America, Fair Trade USA delivers the environmental, economic, and social benefits of certification to over 1.2 million producers throughout the world. After over two years of due diligence with a variety of stakeholders and the formation of the Fair Trade Fisheries Advisory Council, we’ve adapted our time-tested agricultural certification model to create the world’s first Fair Trade Capture Fisheries Standard. Fair Trade certification will provide a framework for fishers to organize into self-empowered associations, improve their business skills, access premium markets and steward their marine resources. In addition, fishers will receive extra financial premiums to devote to community development such as education, healthcare and infrastructure and environmental improvement projects. Our vision is that Fair Trade’s contribution to sustainable marine fisheries will: i) Improve working and living conditions in fishing communities; ii) Improve ecosystem resiliency by generating a transparent and steady incentive to activate progressive improvements in marine resource management; and iii) Harness the purchasing power of consumers in the global North to increase financial returns for improved livelihoods in the global South. Fair Trade USA is seeking to compliment the available certified fish sourcing options for retailers and consumers. Our certification will provide a recognized label with a focus on social and economic sustainability that mandates continuous environmental improvements. Introducing Fair Trade certification to tuna and other fisheries will contribute to verifying and monitoring sustainability progress at Fisheries Improvement Projects (FIPs). Based upon interest of the fishing community, it could also serve as a bridge to MSC or equivalent certifications. 1 Goals of the standard1 The Fair Trade Capture Fisheries Standard (CFS) was developed in order to provide access to the Fair Trade market for the many small-scale fishers and their communities that rely on fishing for livelihoods. Fair Trade USA aims to provide the opportunity for fishers to demonstrate the core elements of Fair Trade in their practices, while helping them to partner with a Fair Trade Certified Market Access Partner to commercialize their product. The Fair Trade Standards consist of six main criteria sections: 1) 2) 3) 4) 5) 6) Structural Requirements Empowerment Economic Development Social Responsibility Resource Management Commercial Trade Requirements Outline of the standard The scope of the standard, or unit of certification, is groups of mainly small-scale fishers, described as those fishing mainly with friends and family members and often using a share-catch system rather than working for a wage. It includes the practices of individual fishers when they are fishing for those species (stock) covered by the certificate, including the vessels and gear that they use, the fishing grounds (habitat and associated species) and legal management framework. In addition, the operations of the Market Access Partner (MAP) as they relate to the species (stock) taken by the fishers are covered by the certificate, including workers in processing facilities if the MAP is a processor and workers on boats employed by the Market Access Partner and/or the individual registered fishers. The fishers form a democratically-organized Fisher Association to represent the fishers in fisheries management and move towards a ‘co-management’ approach, which secures the long-term health of the fishery. The Fisher Association partners with a Market Access Partner (MAP), who will hold the Fair Trade certificate and be responsible for ensuring compliance of the registered fishers with the standard. The MAP could be a processing facility, an aggregator, or even an NGO – the main requirement is the MAP has a strong relationship with the fishers and can support them with training to improve working conditions and fisheries management. The fishers also form a democratically-elected Fair Trade Committee, which will receive a Fair Trade premium to be used as they choose to improve their livelihoods, their communities, and/or their fishery. If the Fisher Association is already majority-controlled by small-scale fishers, then the Fisher Association can just directly fulfill the duties of the Fair Trade Committee. Please note that unlike some other Fair Trade products there will not be a Fair Trade Minimum Price for seafood, given the range of sizes and 1 The first section of the standard includes a more comprehensive description of its goals and objectives. 2 species which will be certified. However, the Fisher Association will receive Fair Trade Financial Premiums, which is an additional payment per lb. of Fair Trade seafood sold into the market. Consultation questions We appreciate feedback on any section of the standard, but have drafted the questions below to highlight core areas which will be of interest to fishery experts new to Fair Trade as well as Fair Trade experts new to the world of sustainable fisheries. Fair Trade USA Draft Capture Fisheries Standard Feedback Form Name: Organization: Email: Expertise: Phone: Please note that unless you specify otherwise, your comments may be posted with attribution in the public summary of stakeholder feedback. Are you working on any related initiatives, or know of any that you recommend FTUSA work with? Scope and definition The standard is open to groups of mainly small-scale fishers. Does the following definition of ‘small-scale fishers’ in the glossary seem reasonable? “Fishers who go to sea in small vessels catching for commercial trade with a few crew members, who are typically their own friends or relatives. The technological sophistication of vessels, gear, and equipment that they use is equal to or below the average of fishers harvesting the same species in the region. Fishers who hand-harvest (i.e. by swimming or diving) individually and not as waged workers are also considered small-scale.” Comments: Social Responsibility Section A core tenet of FT is ensuring fair compensation. In some fishing systems, fishers are compensated by the boat captain with catch in lieu of wages. In cases where this is applicable, ED-FTP 3 requires that if “the registered fishers are paid as a share of the catch, the share system and working conditions on board are agreed to in writing among all parties involved.” We envisioned that fishers could for instance, sign a framework agreement with the Fisher Association or MAP describing different payment methods. For each trip, the fisher could then sign the trip log referring to a specific share arrangement. We understand that this is not common practice, but does it seem reasonable to ask? Comments: 3 In small-scale and artisanal fisheries, children often participate in fishing. Working on boats is hazardous, and we have tried to incorporate the relevant ILO conventions and guidance to ensure children are protected. Do you feel that the section on Protection of Children and Young Persons, shown below and in section 4.3 of the standard, is robust yet realistic for small-scale fishers? SR-PC 1 Children below the age of 15 (or below the working age defined by national law, if higher) are not employed. Children aged 15 or over (or of the working age defined by national law, if higher) may be employed for work in production facilities and light work during school holidays. The minimum age for employment on fishing vessels is 16 or as defined in law, if higher. SR-PC 2 The children of registered fishers below the age of 15 (or below the working age defined by national law, if higher) may work with their relatives provided that: The work does not jeopardize schooling and is within reasonable time limits after school or during holidays. The work does not jeopardize the child’s social, moral or physical development and does not constitute a hazard to the child’s health. The minimum age for a child helping his or her family on fishing vessels is 12. Their relatives provide supervision and guidance. SR-PC 3 Workers under the age of 18 have working conditions that are modified in consideration of their age and physiological needs. SR-PC 4 The minimum age of admission to any type of work which by its nature or the circumstances under which it is carried out is likely to jeopardize the health, safety, or morals of young people, is 18 years (or the age of legal adulthood as defined by national law, if higher). This includes night work. Comments: RESOURCE MANAGEMENT SECTION 5 In the charts below, we have summarized the minimum Resource Management (Environmental) performance requirements for Fair Trade Certification. - Year 0 Entrance Criteria to become Fair Trade Certified Fishery - Year 6 Progress Criteria - indicating the performance level the fishery will need to have achieved by the sixth year of certification. 4 RESOURCE MANAGEMENT SECTION 5 - PROFILE OF A YEAR 0 FAIR TRADE USA CAPTURE FISHERY Performance Indicator Requirements 5.1 Information to Support Resource Management (IN) The Market Access Partner (MAP) has developed communications tools concerning all annual catch that provide information on: Retained (landed) species Bycatch (discarded) species Endangered, Threatened, or Protected species Habitat Other topics necessary for common understanding among stakeholders. The MAP and Fisher Association (FA) have a document that shows the relationship between all naming conventions for all species in the catch (Retained and Bycatch species). All Endangered, Threatened, or Protected (ETP) species have been documented. A table is available classifying all of a fishery’s species into the following categories: o Major Main Retained (any one species that comprises >25% of the total landed catch, in two consecutive years of landings data). Species in this category may be eligible for certification. o Main Retained (any one species that comprises >10% of the total landed catch). Species in this category may be eligible for certification. o Minor Retained (any one species that comprises <10% of the total landed catch). Species in this category are not eligible for certification. o Main Bycatch (any one species comprising >10% of the total discarded catch). Species in this category are not eligible for certification. o Minor Bycatch (any one species comprising <10% of the total discarded catch). Species in this category are not eligible for certification. 5.2 Overfished Status (OF) All Retained species are assessed. All Bycatch species are assessed. The MAP and/or FA have determined risk of being overfished and/or stock status using an appropriate peer-reviewed and tested stock assessment method based on available data. The FTUSA Productivity and Susceptibility Analysis is considered an appropriate assessment method. Species in the following categories may not be overfished: o Major Main Retained o Main Retained If a species is at risk of being overfished, a rebuilding strategy must be in place. The MAP and/or FA have determined risk of being overfished and/or stock status using an appropriate peer-reviewed and tested stock assessment method based on available data. The FTUSA Productivity and Susceptibility Analysis is considered an appropriate assessment method. The fishery does not pose a high overfishing risk to any species that fall under the Main Bycatch category. 5.3 Biodiversity Protection (BD) Endangered, Threatened, or Protected (ETP) species do not fall under the following species categories: Major Main Retained, Main Retained, or Main Bycatch. ETP species may not be landed or discarded in quantities >10% for any one species. The impact of the fishing gear on the benthic habitat has been scored according to Monterey Bay Aquarium Seafood Watch rankings (low impact to very severe impact). Fisheries categorized with severe or very severe impacts cannot be certified. The fishing gear used does not cause severe harm to benthic habitat. 5 5.4. Fisheries Management (FM) Vessels are registered and licensed. The MAP and FA support the monitoring and reporting of illegal fishing activity. 5.5 Waste Management (WM) Hazardous waste is handled safely, according to applicable laws and regulations. Vessels used by registered fishers are legally registered and licensed. Fishermen registered in the FA do not participate in illegal fishing in any form. The processing facilities' procedures for handling hazardous waste are in line with applicable laws and regulations. RESOURCE MANAGEMENT SECTION 5 - PROFILE OF A YEAR 6 FAIR TRADE USA CAPTURE FISHERY Performance Indicator Requirements 5.1 Information to Support Resource Management (IN) The Market Access Partner (MAP) has developed communications tools concerning all annual catch that provide information on: Retained (landed) species Bycatch (discarded) species Endangered, Threatened, or Protected species Habitat Other topics necessary for common understanding among stakeholders. The registered fishers have a system in place (for example, a logbook) to collect data necessary to comply with this standard, including information on fishing trips and catch (Retained and Bycatch species). The MAP and Fisher Association (FA) have a document that shows the relationship between all naming conventions for all species in the catch (Retained and Bycatch species). All Endangered, Threatened, or Protected (ETP) species have been documented. A table is available classifying all of a fishery’s species into the following categories: o Major Main Retained (any one species that comprises >25% of the total landed catch, in two consecutive years of landings data). Species in this category may be eligible for certification. o Main Retained (any one species that comprises >10% of the total landed catch). Species in this category may be eligible for certification. o Minor Retained (any one species that comprises <10% of the total landed catch). Species in this category are not eligible for certification. o Main Bycatch (any one species comprising >10% of the total discarded catch). Species in this category are not eligible for certification. o Minor Bycatch (any one species comprising <10% of the total discarded catch). Species in this category are not eligible for certification. For Retained species, a map depicting the range of fishing vessels registered with the FA has been developed. The MAP can demonstrate that systems are in place (logbook or otherwise) to support the 'Conditions of Employment' and 'Resource Management' sections of this standard. The data collection system is inclusive, effective and accessible by the registered fishers. Vessels record fishing trip data with crew lists for each voyage. Fishing trips record data on Retained and Bycatch species. Landings data are appropriate to support the methods used to assess the health of stocks under “5.2 Overfished Status (OF)” below. Registered Fishers have implemented a system to ensure traceability back to a point of capture. 6 There are landings data which reflect the composition of Retained species. Systems are in place to control the quality of catch, landings, and fishing trip information. The MAP and FA developed and implemented a strategy plan for meeting the Resource Management section of this standard, including progress requirements over time. Performance Indicator Annual landings data per fishing trip reflects catch for Retained species from at least 50% of landings sites, and/or includes records from at least 25% of total trips for the past six months. The landings data are representative of both the fishery and the true composition of Retained species in the water. All landings are received at recognized ports. The MAP has GPS records documenting the location of all main and minor landing sites. At sites where data are collected, there is a system in place via designated data collectors and data collection systems to control data quality. Data collectors, including fishermen, are regularly trained in data collection, data safety, and data management. Written procedures are provided regarding the above topics. The Certification Strategy outlined additional information that need to be collected, actions that needed to be taken and parties responsible for each activity, and the budget required for implementing progress toward Year 6 certification. Requirements 5.2 Overfished Status (OF) Retained species are not overfished, as defined by an appropriate peer-reviewed and tested stock assessment method (see “FTUSA Data-Limited Stock Assessment Decision Tree”). If a species is at risk of being overfished, a rebuilding strategy must be in place. All information listed in 5.2 Overfished Status must be included in the Fishery Management Plan (see 5.4 Fisheries Management). The MAP and/or FA is Marine Stewardship Council (MSC) certified or has determined stock status using an appropriate stock assessment method based on available data (see “FTUSA Data-Limited Stock Assessment Decision Tree”). If a Retained species were found to be at risk of being overfished, the MAP and FA included a rebuilding strategy in the Fishery Management Plan that accounted for the fishing pressure exerted by the registered fishers. Life history information relevant to fisheries management is available for Major Main Retained and Main Retained species. All Bycatch species have been assessed (see “FTUSA Data-Limited Stock Assessment Decision Tree”). The fishery does not pose a high overfishing risk to any species that fall under the Main Bycatch category. 5.3 Biodiversity Protection (BD) Endangered, Threatened, or Protected (ETP) species do not fall under the following species categories: Major Main Retained, Main Retained, or Main Bycatch. ETP species are not be landed or discarded in quantities >10% for any one species (i.e. ETP species may not fall under the Major Main Retained, Main Retained, or Main Bycatch categories). The MAP and FA have included in the Fishery Management Plan a strategy to ensure all ETP laws are adhered to and retention and/or bycatch of ETP species is not >10% of any one species landed. A system is in place to ensure that ETP species encountered by the fishery do not have consumable value to registered fisheries, defined as not sold, eaten or traded. 7 The fishing gear used does not cause severe harm to benthic habitat. The FA has developed a plan for monitoring the local ecosystems. If the fishery scored moderate-severe for habitat impacts according to the Monterey Bay Aquarium (MBA) Seafood Watch rankings, a strategy has been developed and included in the Fishery Management Plan to reduce the habitat impact score to moderate or low within six years. The gear does not contact the bottom or the fishery gear’s impact on the substrate scores low or moderate according to the MBA Seafood Watch rankings. The FA has identified its roles and responsibilities for gathering the data and recording metrics that can be used as a warning sign of changes occurring in the ecosystem, with a goal of obtaining at least six months of data within one year. These elements may be incorporated into the Fishery Management Plan or may be a separate document, as seen fit. The FA plans to share the data collected with the responsible management agency. The plan includes steps to review the ecosystem monitoring program on a yearly basis and make necessary adjustments to improve its effectiveness or collection of the desired information. 5.4. Fisheries Management (FM) The fishery has a functional Fishery Management Plan in place that includes appropriate reference points and management actions. Performance Indicator All existing management rules are compiled into a single document. The Fishery Management Plan includes one or more controls on fishing mortality. The Fishery Management Plan also includes: (a) A means for tracking changes in stock status, (b) Details for how changes in stock status will lead to modifications in harvest practices, (c) A preagreement on how any decreases in landings associated with diminished stock abundance will be distributed amongst fishers, and (d) a Data Plan. The Fishery Management Plan has been developed during a workshop where discussion includes: (a) Incentives, (b) Behavioral solutions, (c) Innovations, (d) Examples, (e) an Action Plan, and (f) Minutes The Fishery Management Plan is implemented and updated annually. Requirements 5.4. Fisheries Management (FM) [cont…] Vessels are registered and licensed. The MAP and FA support the monitoring and reporting of illegal fishing activity. Vessels used by registered fishers are legally registered and licensed. Applicable to certain vessels, there is a document from the competent authority demonstrating a passing inspection related to living and working conditions on board vessels. Fishermen registered in the FA do not participate in illegal fishing in any form. The FA and the MAP have together created an IUU enforcement strategy to identify and report illegal, unreported, and unregulated (IUU) fishing in the area. The enforcement strategy is included in the Fishery Management Plan, and is implemented and updated annually. All catches of FA members and associated information are reported to the relevant authorities. 8 The FA is actively involved in the management of the fishery, according to a co-management agreement. There is a procedure for resolving conflicts among fisher groups, the FA, and the legally responsible agency over the management of the fishery and the use of the fish resources. There is a written co-management commitment signed by the FA, the MAP, and the agency legally responsible for the resource that includes: (a) a shared commitment to undertake resource management efforts necessary for Fair Trade certification, (b) A commitment to undertake collaborative management of the fishery, and (c) a commitment by all parties to attend at least one yearly meeting aimed at collaborative discussion of management improvements. The annual co-management meetings have identified the main risks to the fishery. An Action Plan to address the issues identified in the co-management meetings has been developed, with activities and responsible parties identified. There is a basic, written conflict resolution procedure explaining how the MAP, the FA, and the legally responsible agency intend to undertake conflict resolution. All parties have a signed commitment agreeing to work towards collaborative resolution of conflicts between management and resource users. Minutes from annual co-management meetings and progress towards solutions are documented. The FA drafts an Action Plan at each annual co-management meeting, designating responsible parties and activities to resolve priority conflicts. 5.5 Waste Management (WM) Section 5.5 is applicable only for facilities where the MAP is processing the harvest. Hazardous waste is handled safely, according to applicable laws and regulations. Where there is major risk of harm or contamination (to humans and/or the environment) from waste while processing, the MAP, and if applicable the FA, implement a Waste Management Plan to minimize or eliminate the risk. The processing facilities' procedures for handling hazardous waste are in line with applicable laws and regulations. There are designated areas for the storage and disposal of hazardous waste. If the MAP, and if applicable the FA, have identified significant risks of harm or contamination, a Waste Management Plan to minimize or eliminate the risk has been developed and implemented. If waste water from processing facilities poses a major risk, waste water from central processing facilities is handled in a manner that does not have a negative impact on water quality, the environment, and/or human health. 9 Resource Management Section 5 Based upon the information provided above, please answer the following questions. 1) Given that our intended beneficiary of this standard is small-scale and artisanal fisheries, do you think the Year 0 entry requirements are viable for them to achieve? Will it be necessary for them to have outside support to be able to meet these requirements? 2) Do you feel that we have achieved a set of entry and progress requirements which ensure the worst practices are not occurring and that small-scale and artisanal fishers are making strong progress towards building a sustainable fishery? Comments: In developing this draft standard, we tried to balance the need to ensure a healthy fishery with the data that small-scale fishers are able to gather, monitor, and assess. To that aim, we have developed tools that data-limited fisheries can use to meet the requirements of the standard including a Data-Limited Stock Assessment Decision Tree available to download here: http://fairtradeusa.org/productspartners/seafood/standard-feedback. Do you think these tools will be easy for small scale and artisanal fishers to use? Do you think they incorporate appropriate best practice and methodologies? We appreciate your detailed feedback. Comments: Other comments and suggestions If possible, please refer to the standard reference number or the compliance criteria number,e.g., EM-DM 1). Thank you for your feedback! Please return this form to fisheries@fairtradeusa.org by May 30, 2014. 10