A number of parties involved in the international seafood supply chain have recently come together around the concept of creating a "global sustainable seafood initiative", or GSSI. The stated aim is to "enhance and support an efficient, sustainable seafood supply chain, by providing transparent and objective analysis of the credibility, performance and acceptance of the different certification programs that exist within the wild capture and aquaculture sectors." The MSC has released a position statement regarding this initiative, below.

Statement

MSC welcomes the proposal to create a Global Seafood Sustainability Initiative, if we are correct in our understanding of the intent behind the initiative. With the growing number of certification programs as well as other forms of sustainability assurance programs operating in many markets around the world, there is an indisputable need for truly independent review and ranking of the services and claims being made by the various programs, as well as a mechanism to ensure quality control among the programs.

MSC would be delighted to see a credible, balanced, transparent process to evaluate, benchmark and grade the performance of the various programs providing assurances about sustainability and responsible management in world fisheries. That would be a welcome and needed evolution in the sustainable seafood movement.

We understand that the initial proponents of a GSSI are only at the scoping phase and are seeking input into its design and structure. With that understanding, we would offer the following comments:

1. Any benchmarking and evaluation system must be set up on a graduated grading basis. A graduated system will drive a race to the top rather than a race to the bottom. A simple pass/fail will be most likely to lead to a relaxation of higher performance down to the minimum bar; not recognise and reward the best performers; nor drive lower performers to improve performance against the scale.

We believe that whatever system the GSSI ultimately establishes, it must have a floor of minimum acceptable performance, and a graduated system to evaluate performance above that level.

2. The benchmarking system must look at the content of the standards that are being evaluated in addition to the process programs use to apply their standards. Good process is hollow without meaningful standards. Early GSSI documents reference compliance of seafood ecolabelling schemes only against the FAO Guidelines for Ecolabelling Fish and Fisheries Products from Marine Capture Fisheries. We believe this needs to be broadened to include other documents such as the FAO Code of Conduct for April 23, 2012 Responsible Fisheries; the FAO technical guidelines for responsible fisheries: Inland fisheries and the draft evaluation framework FAO established in 2010 to "provide a consistent approach for organisations to assess conformity with the FAO guidelines for the ecolabelling of fish and fishery products from marine capture fisheries."

3. The benchmarking system should also be built to evaluate standard-setting schemes against international, normative documents that have been built from wider experience outside fisheries, and which seek to set and maintain best practices in the arenas of social and environmental standards, such as the ISEAL Code of Good Practice for Setting Social and Environmental Standards.

4. In addition, a credible benchmarking system must go beyond the written documentation of a standard and the methodology to apply it. It must also include evaluation of the actual performance of the program against both the benchmarks and the claims, and seek to corroborate by direct evidence that the program assures and drives genuinely sustainable outcomes.

5. Finally, if and when we get to the next step of establishing the GSSI, one of the most critical decisions will be about the design of the governance structure. The governance structure will ultimately make the all of the critical decisions about the benchmarking and evaluation systems, and will approve and endorse the outcomes. Therefore, it is critical that this structure be broadly-based, balanced, with a high degree of transparency in its operations, and sufficient opportunities for review and participation by those who are not part of the governance structure.

To reiterate, we support the intent as we understand it behind this initiative and we look forward to its contributions to furthering the sustainable seafood movement by ensuring that there is rigor, quality and real outcomes behind claims and assurances provided by those of us in the certification and assurance business.