In light of recent criticism, SeaChoice provides further information on our report , “Global Review of Aquaculture Stewardship Council’s Salmon Standard”. The report provides the rationale and options for immediate and medium-term actions the ASC can take to reform key deficiencies and maintain or enhance the scheme’s credibility and its positive environmental and social impact. Our findings raise significant concerns for which, in turn, SeaChoice offers key recommendations.
The Salmon Standard v.1.1 explicitly states, “Farms must meet 100 percent of the requirements in this document to achieve certification” 1.
In order to assess whether ASC certified farms were in fact meeting this statement, we analyzed every audit from the first in 2014 to March 2018. We were able to review farm conformance and performance as certification progressed: from a farm’s initial audit to surveillance to recertification. In doing so, we were able to identify whether auditor reporting of farm-level metrics had improved (it has, mostly2), and whether farm conformance improved over time (it varied3). We additionally reviewed whether performance on Standard key indicators has changed over time. For example, SeaChoice examined farm’s forage fish dependency ratios – comparing Salmon Standard versions 1.0 and 1.1 feed requirements. We found certified farms have improved their fishmeal dependency ratios over time and that 95% of farms can easily meet version 1.1 Standard requirements, leading us to recommend that the ASC consider further reductions to reflect current best practices4.
It is important to note that the Salmon Standard (and the other ASC standards) is supplemented with an auditor guidance document, known as the Certification Accreditation Requirements (CAR). SeaChoice’s review analyzed the CAR, as written and as operated, through the 456 audit reports. Our report found deficiencies with the CAR. For example certified farms in major non-conformance with the Standard have sold and are able to sell their product with the ASC logo5. This demonstrates the CAR’s suspension and withdrawal rules need strengthening.
In addition, the ASC deploys a number of processes which affect the way in which the Standard and/or auditing processes (i.e. the CAR) operate. These include, variances (alterations to the Standard requirements at the request of auditors) and interpretations (ASC guidance to auditors). While these processes are deemed necessities for certification scheme operations, these processes in practice amend the Standard and/or CAR as written. Some amendments were found to be undermining the organisation’s theory of change by eroding the best practices codified in the Standard.
Critically, the variance request (VR) approval process lacks stakeholder engagement, as well as independent technical and scientific advice6. As International Social and Environmental Accreditation and Labeling (ISEAL) members, ASC follows defined codes of practices. Section 6.4 of ISEAL’s Standard Setting Code states, “The standard is relevant in the local contexts where it is applied, based in part on input from local stakeholders”. To date, aside from the farm client (industry) themselves, no local stakeholders have been included in the VR process. We will continue to advocate for an inclusive and transparent VR process until such time as ASC has publicly moved toward stakeholder and technical inclusion.
SeaChoice’s review also found some variances can enable farms that would otherwise be in major non-conformance with the Standard to be certified7. ASC’s own accreditation body Accreditation Services International (ASI) warned ASC that such VRs substantially alter the intent of the Standard and are “probably putting at risk the program integrity”. They further recommended, “In case a VR changes the original intent of the Standard it is recommended that this should not be possible without public consultation and stakeholders review”.
Our report also found ASC’s interpretations to be problematic. For example, an ASC interpretation allows auditors to omit intermediary stages from compliance8. Consequently, an ASC label does not guarantee the fish was “farmed responsibly” from egg to harvest. It also means an ASC-certified salmon in Australia or Canada (where interim farms are common) is not held to the same level of scrutiny as an ASC-certified salmon farmed in Chile or Norway.
Furthermore, the ASC’s proposal for their Parasitcide Treatment Index (PTI) operational review takes an approach that is more aligned with an aquaculture improvement project (AIP) model and not that of a ‘best practices’ certification9. The ASC PTI review proposes increasing the number of allowable sea lice treatments by up to 450 % in some countries (e.g. 11 sea lice treatments for Chilean farms) on the “condition” these farms eventually meet the ‘global target’ metric (i.e. 4 sea lice treatments). Yet our report found that 96% of farms can easily meet the current PTI threshold (2-3 sea lice treatments). To clarify, the ASC PTI proposal is not linked in any way to the ASC’s recently announced Improver Programme. However, on reflection, perhaps the PTI proposal would be more ideally suited for the Improver Programme.
Eco-certifications, when done right, can help drive important sustainability gains. This is why SeaChoice advocates for consumers and retailers to use credible eco-certifications to guide their seafood purchasing decisions. In addition to being able to demonstrate improved environmental performance of eco-certified producers, credible eco-certifications’ practices must be transparent and inclusive, with procedures that are fair, and criteria that are rigorous and upheld. It is with that vision we provided ASC with recommendations that have the potential to strengthen the certification scheme in the long-term10. This in turn could help drive sustainability gains in the industry. Many of our recommendations are easily applicable to all ASC Standards as many stem from concerns systemic across the ASC scheme.
SeaChoice member groups have been active stakeholders in the ASC and Salmon Aquaculture Dialogue for more than a decade. This has included steering committee representation during the original Aquaculture Dialogues, core participation in numerous ASC advisory and working groups, and active stakeholder engagement on ASC audits and projects. We will continue to work with the ASC, through various mechanisms, to ensure the intent of the Salmon Standard is upheld.
