Saturday, July 6, 2013

ASC/Selva Shrimp Certification

Consumers in the global North have been calling for seafood certifications so that they might be able to make conscious decisions about the food they eat, where it comes from, how it is produced, and the impact of production on people and the environment. Although seafood at the supermarket may proudly display labels from the Monterey Bay Aquarium or the Marine Stewardship Council, certifying something, most consumers do not know what that certification really means. Worse still, that certification scheme, that label, may not reflect what consumers are after: seafood that is produced with minimal impact on the environment; that supports workers and their livelihoods; and that is safe and wholesome to eat. Mixed shrimp farming-mangrove forestry systems have been gaining the attention of seafood certification organizations and scientific research alike in recent years. This system ideally integrates shrimp farming into the landscape of coastal ecosystems in order to maintain the ecological function of mangrove forests and the surrounding areas while minimizing shrimp disease and providing shrimp farmers with a sustainable livelihood. While this system may sound viable and sustainable, there is a potential for the practice to stray far from what is preached. We at the Mangrove Action Project are particularly concerned that this production system will continue the process of degradation and deforestation of mangroves.
A recent certification scheme has come into use called Selva Shrimp®, developed by Blueyou Consulting Ltd. for the Aquaculture Stewardship Council (ASC) and awarded a “Best Choice” rating by Seafood Watch (Brisdon, 2013). Selva Shrimp® look good on paper; brochures and leaflets available from Blueyou Consulting are slick, colorful, and attractive. Aimed at businesses, this particular brand of shrimp is touted as a sustainable choice that directly connects consumers to the small-holder farmers producing these shrimp. Clients are assured that shrimp are raised without any addition of feed, fertilizer or antibiotics in a “natural” way that enhances mangrove conservation and benefits the local communities. These assurances arise from independent certification through an Internal Control System (ICS), and later subjection to independent certification by the ASC (Blueyou Consulting Ltd., 2012).
All of these assertions sound good, as if we have finally found a way to farm shrimp without causing severe environmental destruction in the clearing of mangrove forests and other coastal areas, thus allowing us to continually supply hungry nations with warm-water shrimp guilt-free. On closer inspection, however, the picture looks less rosy. Even Seafood Watch, a branch of the Monterey Bay Aquarium, which granted Selva Shrimp® a “Best Choice” rating raises many concerns about whether what the ASC says is happening is really playing out on the ground. What is astounding is that, despite many criteria of the Seafood Watch assessment being hard to measure, especially in critical areas of habitat and environmental impact, the report sweeps aside these concerns, citing a handful of scientific research articles. While we hope that the standards developed for Selva Shrimp® are indeed maintained and even enhanced, the same set of articles that Seafood Watch cites in support of this certification may also be used and interpreted in opposition to the scheme.
Although there are many areas of concern, chief among them for the Mangrove Action Project are the provisions of the scheme that relate to mangrove forests. Seafood Watch uses eight criteria for assessing certifications, and in each provide justification for the rating they hand down. Criteria 1-3 all pertain to mangrove and ecosystem health in some way, although Criteria 3 is the main focus of habitat. For Criteria 1: Data quality and availability, Selva Shrimp® earned a yellow score of 6.1, since data availability is somewhat minimal especially at the individual farm level, citing Tho, Ut, & Merckz, 2011. However, due to a few recent studies made into the Ca Mau province where Selva Shrimp® are currently available and where other organic shrimp certification operations exist such as Naturland, the production system defined by Selva Shrimp® is deemed typical of the region. Seafood Watch seems to argue that because the production practices laid out by the Selva Shrimp® standards are largely already in place even before certification, the lack of data is of less concern. There is an implied assumption of responsible practice without any direct verification beyond the bare minimum. In our opinion, this is simply not enough. Without adequate data, consumers cannot be assured that the label actually reflects their hopes and intentions when they choose to purchase Selva Shrimp® or some other certified seafood.
The Seafood Watch report also determines that this scheme is applicable to other regions outside of Ca Mau, where it was originally piloted, based on the independent verification required to earn and maintain the certification. According to Blueyou Consulting, “The Selva Shrimp® program uses specific criteria and measurable parameters as guidance for all relevant processes of aquaculture improvement... These criteria are subject to regular monitoring and independent verification by a third-party auditing body. The Selva Shrimp® criteria will be implemented through the establishment of an Internal Control System (ICS). In a later phase of the program, the small-scale farm clusters and the implemented ICS shall be subject to an independent assessment and certification against the standard of the Aquaculture Stewardship Council (ASC)”. The use of an ICS may make implementation of the criteria easier, since it is performed by individuals within farm clusters in pre-existing social networks, but this method is also subject to concern. Ha, Bush, Mol, & van Dijk, 2012, described an ICS used in Ca Mau for the Naturland certification where the collectors of shrimp, who also performed the internal audits, often mixed organic and non-organic shrimp to increase their own income. Additionally, “those directly involved in the ICS recognize they should not only rely on farmers for auditing information, but are restricted by costs” (Ha, Bush, Mol, & van Dijk, 2012). Combined with the findings from Tho, Ut, & Merckz, 2011, that “farmers do not keep records of pond inputs or other production aspects such as potential escape event” and “data collection and record keeping at the farms are minimal to non-existent” reported in the Seafood Watch assessment, the objectivity and accuracy of ICS auditing is put into question (Brisdon, 2013).
The Seafood Watch assessment highlights that a minimum of data must be collected and maintained on “mangrove coverage and harvesting records” for external oversight (Brisdon, 2013). Although data may be collected and recorded through the ICS, the third-party auditing of these records, and even the internal auditing itself, may not catch instances of non-compliance. Hatanaka, 2010a, found that farmers in Thailand under organic certification projects sometimes chose to ignore certain aspects of standards they disagreed with, but in a manner that allowed them to maintain certification; many farmers supplied inaccurate information to the ICS inspectors. Comments collected by Hatanaka, 2010b, revealed that farmers would simply lie to the inspectors, who would believe them without making an independent verification or observation themselves. When a third-party certifier comes annually to audit member farms, Hatanaka, 2010b, describes that certifiers audit a few random samples of ICS documentation as well as sample random farms, processing centers, warehouses, and question farmers. However, rather than actually auditing most of the farms directly, it is the records that are audited; any non-compliance would go unnoticed in this situation (Hatanaka, 2010b). Therefore, although the standards may be in place and a minimum of data is supplied, that data may be inaccurate and farmers may be non-compliant but still granted certification. This is of great concern for the protection of mangrove forests on these farms, which must make up a minimum area as defined by the Selva Shrimp® standards; farmers may be able to lie about the area of mangroves on their plots, allowing them to expand shrimp ponds to the detriment of the environment while still maintaining certified status.
Additionally Gebhardt, Nguyen, & Kuenzer, 2012, found that manual assessments of mangrove areas have proven highly variable and have a significant potential for inaccuracy. Different methodologies and definitions for measuring mangrove area and density make it hard to determine the actual coverage of mangrove forests without remote sensing. Under the current standards for certification, farms must maintain at least 50% mangrove cover. Farm leases are usually issued for twenty years in Vietnam; mangrove forests are allowed to be thinned at 5, 10, and 15 years, with a final harvest of all remaining mangroves at 20 years (Clough, et al., 2002). Farmers rarely own the land they farm in the Ca Mau province of Vietnam, where Selva Shrimp® are currently being certified, and unless farmers plant mangroves in the first year of their twenty-year leases they cannot benefit from the final harvest at 20 years (Clough, et al., 2002). As a result, farmers do not have an incentive to manage the mangrove forests well. Ha, Bush, Mol, & van Dijk, 2012, found that there were differences in the perception of what “constituted ‘forested’ area,” resulting in instances of non-compliance. Although calculation of mangrove area may be easier at the farm or farm cluster level, if compliance to mangrove area requirements is based largely on information provided by farmers with little or no motivation to actually conserve mangrove forests, there can be no assurance that area requirements are met without true third-party assessment. With all of these confounding factors, we are concerned with Seafood Watch giving Selva Shrimp® the benefit of the doubt. Greater transparency should be required to ensure effective enforcement of the certification standards.
For Criteria 2: Effluents, the same issues of data quality and reliability apply. The Seafood Watch assessment acknowledges this conundrum, but because the Selva Shrimp® standards prohibit “the use of synthetic fertilizers or any natural materials that do not come from the farm area itself” and several scientific studies that define common practices in Ca Mau as low-input the certification is granted a score of 10 out of 10 (Ha, Bush, Mol, & van Dijk, 2012). Again, without accurate and thorough data, there are no assurances that these practices are actually upheld. Mangroves are also vital as biofilters in mixed shrimp-mangrove systems (Bush, et al., 2010). However, if mangroves are not well managed and ecosystem services are lost, the ability of mangrove forests to actually perform this function may be limited (Cardinale, et al., 2012).
The area of greatest concern for the Mangrove Action Project is Criteria 3: Habitat. In the justification of scoring for this criteria, the Seafood Watch report describes the history of deforestation of 80% of mangroves in Vietnam. These mangroves were primarily composed of “mature Rhizophora forest,” but reforestation efforts (both natural and planned) were largely with a monoculture of Rhizophora apiculata (Brisdon, 2013). Vietnam is home to at least 35 species of true mangroves; three of those belong to the Rhizophora genus and 30 species can live in the southern coastal region where the Ca Mau province is located (Marchand, 2008). It is clear that the biodiversity potential for mangrove forests is high, yet reforestation has largely produced a monoculture forest for economic reasons alone.
In a review of twenty years of biodiversity and ecosystem function (BEF) studies as well as biodiversity and ecosystem services (BES) studies, Cardinale, et al., 2012, found a consensus in the field that there is “unequivocal evidence that biodiversity loss reduces the efficiency by which ecological communities capture biologically essential resources, produce biomass, decompose and recycle biologically essential nutrients.” The Seafood Watch assessment even highlights the important ecosystem services that mangrove forests provide, but in a monoculture those services are likely to be minimal or lost entirely. This is and was exacerbated by shrimp aquaculture, and Seafood Watch also recognizes that extensive aquaculture is largely to blame for this loss (Brisdon, 2013). Indeed, the report acknowledges “it is likely that, due to the heavily modified hydrodynamics, the ecosystem services of the farm areas have, to some extent, been lost. Therefore, for the purposes of this assessment, the heavily managed habitat is considered to have lost functionality” (Brisdon, 2013).
It is stunning that despite this loss of habitat functioning, the Seafood Watch report still allows Selva Shrimp® to carry a “Best Choice” rating. The report justifies this scoring because the Selva Shrimp® production system protects further land conversion to the intensification of shrimp aquaculture, but given the cycle of forest thinning and harvesting, it seems unlikely that even some semblance of the former health of mangrove forests could be regained. The current forestry management practice mandates an initial planting density of 20,000 ha-1, with 20-30% manual thinning at designated intervals (5, 10, and 15 years) with a final harvest at 20 years (Clough, et al., 2002). The mangrove forests begin to self-thin around 5 years, so the first thinning is appropriately timed; however, subsequent manual thinning are ill-timed as the forests begin to self-thin at 8-9 years and 18-19 years, representing loss of wood production for farmers (Clough, et al., 2002). Given the limited incentive for farmers to manage the mangroves well, any loss of potential income may exacerbate this ambivalence. The self-thinning is also evidence of a policy that clearly mismanages the forests; the initial stand densities are too high, so the forests self-thin as time goes on (Clough, et al., 2002). The harvest at 20 years also prevents the eventual establishment of a mature mangrove forest.  A cycle of twenty-year harvesting with required manual thinnings does not “protect” the forest. The land area may not be converted to intensified shrimp aquaculture, but neither is it restored to health.
Under the Selva Shrimp® standards, the mangrove:pond ratio must be greater than 50%, although many farmers have complained that this is an arbitrary number and that the mangrove area should be based on farm clusters, rather than individual farms, in order to capture the cumulative impact of organic aquaculture (Ha & Bush, 2010; Ha, Bush, Mol, & van Dijk, 2012). This conflict demonstrates the tension between the epistemology of farmers and the regulatory standards, and highlights the lack of inclusion of producers as key stakeholders in the entire system. A greater concern, however, is that a 50% ratio of mangrove forest to shrimp ponds does not reflect a healthy, functioning ecosystem. Several studies have shown that the ratio is important to the ability of mangrove stands to process nutrients, with varying results. A study by Saenger, Hegerl, & Davi, 1983, found that a minimum mangrove:pond ratio of 4:1 was necessary to establish and maintain a healthy mangrove ecosystem.  Shimoda, Fujioka, Srithong, & Aryuthaka, 2007, estimated that “between 2.1 and 5.2 units areas of mangroves is required to remove the nitrogen remaining in the aquaculture pond” and Shimoda T. , Fujioka, Srithong, & Aryuthaka, 2005,  estimated “6.2 or 8.9 ha of mangrove area was … required by 1 ha shrimp ponds to fully process the phosphorus” in mixed shrimp-mangrove systems.
Whether or not there is a settled agreement of the best ratio of mangrove to shrimp ponds to maintain the provisioning of ecosystem services such as nutrient recycling, it appears that the 50% value is an arbitrary number and not based on any scientific conclusion. The Selva Shrimp® standards do not justify the reasoning behind the required ratio. Additionally, the standards do not specify the mandatory area of the buffer zone of mangroves in the published brochure, where no human activity is allowed, nor whether the buffer zone is included in the calculation of a 50% mangrove:shrimp pond ratio. Lack of clarity and transparency on these issues can allow non-compliance for the farmers, and confusion for inspectors, auditors, and consumers alike. These glaring omissions highlight the fact that Selva Shrimp® certification does not in fact uphold the assertion that this production scheme “[enhances] the effectiveness of mangrove conservation” (Brisdon, 2013). As mangrove conservation is one of the key thrusts of the Selva Shrimp® certification system, it seems to warrant greater scrutiny than the Seafood Watch assessment undertakes. We find it unreasonable that the actual health of the mangroves is ignored in this manner. If the ASC is asserting that Selva Shrimp® is good for mangrove ecosystems and conservation, they should prescribe and uphold standards that actually protect the mangroves.
The hydrological characteristics of forests are also damaged by shrimp farming; the mixed shrimp-mangrove production system of Selva Shrimp® is no exception. Again, the Seafood Watch report acknowledges this fact, citing Clough, et al., 2002: “aquaculture development in Ca Mau Province has had a significant impact on the hydrology of mangrove areas. Many of the remaining mangroves are surrounded by levee banks, or situated in areas where tidal access is hindered. In mixed farms, where mangroves are enclosed within a levee surrounding the farm, normal tidal flooding and flushing is prevented by the more or less constant water level in the pond. Flooding and flushing of mangroves in these farms is further hindered by the usual practice of placing soil excavated during pond construction, along the edge of the adjacent mangrove areas. Reliable estimates of the frequency and duration of flooding for mangrove areas [in the areas studied] are not available. However, based on general field observations it is probable that mangrove areas within the ponds of mixed farms are rarely flooded. The situation for mangrove areas located outside the pond on farms using the separate farming system is less clear, but field observations again suggest that many areas are flooded for not more than about 2-3 days per month.” Flooding is critical to the health of mangrove forests, both in duration and frequency, as well as to the provisioning services that mangroves provide (Bosire, et al., 2008). The Selva Shrimp® certification cites that mangrove conservation is “enhanced” in part through the existence of “ponds and channels [that] are connected to the estuaries by gates that can control the in- and outflow of water during the tidal flow” (Blueyou Consulting Ltd., 2012). The findings of Clough, et al., 2002, essentially disprove this assertion, raising doubt that this production system can in any way enhance mangrove conservation. It is possible that the Clough, et al., 2002, study is dated, which Seafood Watch also addresses, but they accept the conclusions found therein. Therefore, the scientific studies that the report cites and relies on as part of the basis of the analysis of Selva Shrimp® are in disagreement with the assertions of the certification scheme itself.
The Selva Shrimp® brochure states outright that shrimp are raised naturally “by maintaining a functional ecosystem of mangrove forests and aquatic species” (Blueyou Consulting Ltd., 2012). The Seafood Watch also outright states, as mentioned above, that “the heavily managed habitat is considered to have lost functionality.” These two statements are in direct contradiction. The certification standards do not make any mention of efforts to restore ecosystem functions in these mangrove forests, such as planting multiple species of trees. This production system, while a step in the right direction, is simply not good enough. Consumers across the world use the Seafood Watch guides when purchasing seafood to make ethical, environmentally responsible and healthy decisions. We do not consider that Seafood Watch has made an accurate assessment of this certification system, and in doing so deceive the public that depends on the authority of Seafood Watch and the Monterey bay Aquarium. As such, we urge Seafood Watch to retract the “Best Choice” rating for Selva Shrimp® until on-the-ground evidence of this particular certification and production scheme can be studied and scrutinized, rather than relying on evidence based on different systems of production and certification. Seafood Watch is viewed as a paragon of information about sustainability; it should not be swayed by smart wording and benefit of the doubt. Shrimp aquaculture has serious environmental, social, and economic impacts, and all of these should and must be considered in the assessment of any kind of certification. Not only must the seafood be a good choice, but the production of that seafood must nurture the environment if it is to be truly sustainable.


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