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The FDA's Investigation into Seafood Mislabeling

By: Alanna Gisondo

Most of us who work in the seafood sector are well aware that seafood fraud and mislabeling are two issues that have been commanding a lot of attention lately. In the past several years, we’ve seen investigative reports and academic studies address fraudulent seafood labeling in the U.S. marketplace and estimate rates at which it is occurring in retail stores and restaurants across the country.

So much attention in fact, President Obama recently issued a Presidential Memorandum that established a Presidential Task Force on Combatting Illegal, Unreported, and Unregulated Fishing and Seafood Fraud.

All this attention around seafood mislabeling begs the question, “How much of our seafood is labeled correctly?

It’s a question that the U.S. Food and Drug Administration (FDA) set out to answer when they launched an investigation into seafood mislabeling back in 2012. The two-year extensive analysis included 700 DNA samples collected from the wholesale distribution chain (prior to retailers) across 14 states, and targeted seafood that is most often suspected of being mislabeled.  And now, the results are in

The FDA found that 85% of the seafood it tested was labeled correctly. What’s more, the FDA also found that mislabeling occurred most often in snappers and groupers, two species that constitute less than 2% of total seafood sales in the U.S. This mislabeling rate is lower than other mislabeling studies, which could be attributed to the sampling location of the wholesale distribution chain before the retailer. In studies by Oceana, mislabeling percentages were 18% at retail, 38% at restaurants, and 74% at sushi venues (though sample sizes for each differed). This may indicate that mislabeling is happening more frequently after the wholesale distribution chain and warrants further study.

The FDA’s recent findings provide additional insight into a confusing and frequently debated seafood issue, and indicate that seafood mislabeling is likely the most problematic within specific species groups of seafood (e.g. the snapper & grouper complexes), which other mislabeling studies have also found. With these new statistics, seafood businesses have a better understanding of the scope of the problem, where along the supply chain mislabeling is likely to occur, and which species complexes are most susceptible to mislabeling.

While the FDA’s study is encouraging, it does not mean that seafood mislabeling is no longer a serious problem. Seafood mislabeling is often associated with food safety and public health concerns, continues to generate media coverage, and poses serious challenges for businesses in meeting sustainable seafood policies and commitments.

The good news is that there is a suite of tools that can help to identify and reduce the risk of buying and selling mislabeled seafood. Businesses can help to ensure that products aren’t mislabeled by reviewing and improving their electronic data systems, verifying product claims via paper audits (aka tracebacks), conducting DNA testing of products of high-risk products, and implementing robust traceability policies that are communicated throughout the supply chain. Looking to different commodities —such as fair trade coffee and certified natural products— is also helpful in understanding how other sectors have innovated solutions to their own labeling challenges.

You can read more about the FDA study here.

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Labor Abuse in the Seafood Industry Captures Media Attention

By: Aurora Alifano

Labor and human rights violations in the global seafood industry have been documented for years. Media coverage of trafficked workers in Thailand has traditionally focused on the sex industry, but recent reports of shocking human rights and labor violations in Thailand's shrimp industry captured public notice. For the first time, the names of major retailers in the U.S. and Europe that sell Thai shrimp produced with human trafficking and forced labor were exposed by the Guardian in June 2014.  International media outlets further broadcast the story, highlighting human rights violations in Thailand’s fisheries.

Less than a month after the investigation release, the U.S. State Department determined that that Thailand does not comply with the minimum standards for the elimination of trafficking and that human rights violations within the fishing industry remain a problem, as outlined in the 2014 Trafficking in Persons (TIP) report. Once again, Thailand made headlines when it was downgraded to Tier 3 in the 2014 TIP report, the lowest possible level.

Exposed companies addressed the media coverage by publically advertising their efforts to reduce and eliminate human trafficking and other labor violations in their supply chains. These problems were met with encouraging action by retailers.  "We are committed to working with our suppliers of Thai shrimp to require them to take corrective action to police their feedstock sources with respect to poor labor practices," read one retailer’s initial statement. "This commitment so far has involved visits by our buying staff to Thailand and discussions with the Thai government, our suppliers, and other industry participants.”

How are sustainability certifications responding?

In response, the Marine Stewardship Council (MSC), a major seafood certification body, announced a new policy against forced labor in August 2014. The Marine Stewardship Council (MSC) stated, “MSC condemns the use of forced labor. Companies successfully prosecuted for forced labor violations shall be ineligible for MSC certification.”

Aquaculture certifications are also looking to address this issue. At the 2014 Global Outlook on Aquaculture Leadership (GOAL) conference, the Global Aquaculture Alliance (GAA), International Fishmeal and Fish Oil Organisation (IFFO), Lyons Seafoods Co. and Wm Morrison Supermarkets collectively agreed to a position statement addressing the social concerns related to aqua feed production. The statement affirmed, “It is essential that robust, comprehensive and socially responsible standards are implemented within aquaculture and its supply industries and that human rights are protected”.

Through the public statement, each party committed to supporting and promoting Fishery Improvement Projects (FIPs) that incorporate social standards and other programs based on the key elements of the ILO Work in Fishing Convention (ILO 188).  

Seafish’s Responsible Fishing Scheme (RFS) recently updated fishing vessel standards with a focus on social and ethical criteria to prevent trafficked or bonded labor. It is widely accepted that fishing vessels operate at sea with limited monitoring and enforcement, and are often considered hazardous working environments. Workers can encounter a spectrum of issues ranging from extremely low wages, inadequate sanitation, lack of safety equipment, and long working hours to documented cases of forced labor, human trafficking and even murder (ILO 2013). Ongoing development of the RFS could offer a potential solution to address ethical issues on board fishing vessels.

Until international efforts can improve the monitoring and enforcement of social standards in the seafood industry, more stories linking seafood companies with products tainted by trafficking and forced labor are likely.  Seafood businesses can promote the adoption of good labor practices by using their influence to proactively engage their supply chains.

Next Steps:

When human rights and labor violations are featured in reports and globally broadcast in the media, the potential for hardened public attitudes toward seafood industry actors and impacts to seafood sales escalates. There will be continued reputational and financial risks to seafood businesses until serious progress on this topic has been made.

We suggest companies familiarize themselves with case studies to understand the scope and breadth of these problems. To take action, we suggest companies review the following guidelines, and contact FishWise (This email address is being protected from spambots. You need JavaScript enabled to view it. ) to be connected to human rights experts.

Case Studies:

1.    The Guardian Investigation
2.    EJF Video and Report- Sold to the Sea- Human Trafficking in Thailand’s Fishing Industry
3.    Slaves in New Zealand Video and Report
4.    MTV Exit

Guidelines:

1.    Walk Free Trafficking in Supply Chains Guidelines
2.    Greenpeace Report
3.    EJF Hidden Cost of Shrimp

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Lessons learned from the Global Outlook on Aquaculture Leadership (GOAL) conference

By: Kathleen Mullen-Ley

I recently had the pleasure of participating in a retail panel discussion at the Global Aquaculture Alliance’s (GAA) annual Global Outlook on Aquaculture Leadership (GOAL) conference in Ho Chi Minh City, Vietnam.

This year’s overarching theme was ‘Celebrating Leadership’ in acknowledgement of the challenges of responsible aquaculture and the need for collaboration to overcome those challenges. Being relatively new to field of responsible aquaculture, I took full advantage of the opportunity to learn from the industry experts, retailer and foodservice seafood buyers, investors, and academic researchers in attendance.

In my opinion, there are four main takeaways from the conference:

1. Early mortality syndrome (EMS) in farmed shrimp is still a major problem and seafood buyers should diversify their sources to minimize risk. 

2. Zone management of farm clusters is a potential solution to the looming dilemma of how to develop the aquaculture industry responsibly.

3. Responsible feed production will require a shift from wild fish protein to alternative protein sources.

4. There is widespread acknowledgement that human rights abuses in the aquaculture industry are real and need to be addressed but there is uncertainty around how. 

The first two takeaways are closely linked. Zone management was touted as an effective solution to fight EMS and prevent future aquaculture epidemics. Showing strong support for this view, the GAA announced the development of a fifth star in the Best Aquaculture Practices (BAP) certification scheme for zone management. GAA was vague on the details of the standard, but seemed confident that it will be able to address a wide range of aquaculture challenges including disease management and engaging small-scale farmers.   

The topic of responsible feed was the most divisive. Alternatives to wild fish protein are severely lacking. Soybeans, rendered animal products, and insects were discussed as alternatives, but none struck me as being both viable and responsible in the short term. The path forward appears to be a two-pronged approach of improving the reduction fisheries involved in fishmeal and fish oil production through improvement projects and continuing to research and develop alternatives. 

The issue of human rights was clearly the newest and the most uncomfortable for conference attendees to discuss. Everyone passionately agreed that something must be done, but what and how? Fortunately, FishWise has been tracking the issue of human rights abuses in seafood supply chains for some time now and so I was able to make a valuable contribution to this area of discussion during the retail panel. 

The retail panels were composed of representatives from the NGO community, major retailers, and seafood companies to give a breadth of views and experience. Despite having different backgrounds, the panel members were mostly in agreement on the challenges facing responsible aquaculture and the need for collaboration to overcome those challenges. On my retail panel, the most interesting part of the discussion was around how the recent revelations human rights abuses in seafood supply chains has changed how we think about sustainability. The uncomfortable truth is that we may have been calling some seafood ‘responsibly sourced’ despite being associated with egregious human rights abuses. Now that another (yes, this issue has been around for a while) clear link has been made between seafood production and social welfare, the definition of seafood sustainability can no longer be restricted to environmental standards. Figuring out how to address both environmental and social considerations in seafood production and improve traceability so sustainability claims can be verified is our revised challenge moving forward.

Should be easy, right?     

Participating in a retail panel discussion at the GOAL conference in Vietnam was a fantastic experience. The GAA is already encouraging increased attendance by NGOs and retailers at the 2015 conference in Vancouver, so if you’re interested in attending next year, you already have a seat at the table. 

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New Future of Fish Report Provides Traceability Technology Guidance for Seafood Companies

A valuable new report released by the nonprofit Future of Fish last month highlights the business case for improved seafood supply-chain traceability and describes important technology considerations and third-party options available to the seafood industry.  The report, entitled Getting There from Here: A Guide for Companies Implementing Seafood Supply-Chain Traceability Technology, was developed with input from technology vendors, NGOs, trade groups, and members of government agencies working on the issues of seafood traceability, mislabeling, and fisheries management.

This report makes three important contributions:

Firstly, it enumerates many reasons traceability technology systems can be very good investments for seafood companies – from their ability to create inventory management system and operational efficiencies, to their marketing, CSR, and brand loyalty benefits. Furthermore, the “Traceability Vendor Benefits Grid” (found in the appendix) critiques many existing traceability solutions, allowing business to assess which product might best fit their organization, existing challenges, and technologies.

Secondly, the report also includes a frank and informative discussion of the barriers faced by companies assessing technological tools to achieve interoperable whole-chain traceability. Many common concerns relating to new technology adoption (e.g. data security concerns and outdated data collection methods) and whole-chain traceability (e.g. lack of interoperability and uniform standards) are discussed alongside useful summaries of existing policy and certification standards.

Finally, the report describes key principles for the successful adoption and implementation of traceability improvements. Guidance on which traceability technology features might be considered essential versus “nice to have”, the benefits of building traceability into business plans and operational protocols, and the importance of trust building and data sharing among firms in the supply chain.

Given the growing pressure industry faces from government, consumer advocacy groups, and competitors to fight mislabeling and improve traceability, this new report is a valuable resource for seafood companies. The report also helps companies implement traceability improvements that not only reduce risk, but can enhance brand reputation and improve supply chain management.

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Restoring Wildlife May Help Stop Forced Labor and Human Trafficking

 

As some natural resources - including certain seafood species - continue to diminish, resource harvesters must work harder to get the same nutrition or economic gain from their effort. Fishers have to search father out at sea, endure harsher conditions, and fish for longer periods to attain the same returns they did a generation ago. 

Sadly, exploitative labor practices are being used to make up for the increasing costs of resource extraction, fueled by the hidden international demand for human trafficking and forced labor. For example in Thailand, Burmese, Cambodian, and Thai men are trafficked to work aboard fishing vessels. Unable to leave, they may remain at sea for several years without pay and endure depraved conditions that may include starvation, physical abuse, or murder. For more information about human rights abuses in Thai seafood supply chains, see the Guardian report Revealed: Asian slave labour producing prawns for supermarkets in the US, UK.

A recent article in Science magazine highlights a direct link between wildlife conservation and the prevention of human rights abuses. The escalation of human trafficking associated with declining fishery harvests exposes the connections between fishery decline, poverty, and human exploitation. Anti-trafficking laws and policies exist, but do not adequately address the scale of the problem or underlying issues like the rapid depletion of wildlife. Similarly, policies aimed at addressing wildlife decline must also consider the social context of wildlife use and connections between wildlife scarcity and social conflict.

The authors call for biologists to work with politicians, economists, and social scientists to find solutions. Combatting trafficking should be one part of an integrative approach that also considers the ecological, socioeconomic, and institutional contexts in which wildlife declines have cascading effects.

For information on Thai shrimp recommendations for seafood businesses, please see the FishWise briefing document

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Photo: Susan Braun