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LETTER: NGO study misrepresents ASC salmon standard

ASC argues SeaChoice completely overlooked and understated the fact that the ASC salmon standard has already progressed.

The following letter to the editor was sent to IntraFish by Aquaculture Stewardship Council (ASC) Communications Director Contessa Kellogg-Winters in response to the story 'New NGO study claims ASC label not all it cracked up to be.'

The study by SeaChoice cited in your article titled “New NGO study claims ASC label not all it cracked up to be,” published on October 18, 2018 is inaccurate and misrepresents the mechanisms underpinning the Aquaculture Stewardship Council (ASC) Salmon Standard.

Amongst both stakeholders and critics, ASC is recognised as being the most robust, transparent and stringent global aquaculture certification for responsible aquaculture. All of our standards include provisions for the protection of workers and the community, and criteria to both measure and improve farm performance. The scrutiny arising from the unrivaled level of transparency embedded in the ASC standards, and in the Salmon Standard in particular, has over the years had significant industry-wide beneficial effects including – but not limited to – making salmon farmers more accountable.

This level of disclosure, together with ASC’s dedication to a multistakeholder approach and mandate to progress standards through Operational Reviews to ensure that they continue to be informed by the latest knowledge, have been driving improvements in global salmon farming. No other global scheme requires farms to report data on several important issues including escapes, diseases, parasiticide treatments and sea lice, despite the fact that farms may then be suspended or have their certificates withdrawn.

By providing such accountability and transparency, and enabling in-depth scrutiny — SeaChoice would not be able to equally criticize other aquaculture certification schemes not only due to programmatic differences, but also on the basis of their non-publication of audit reports — the ASC provides insights than can increase the public’s confidence in the fish they eat and drive greater improvements over time.

Whilst the ASC is a multistakeholder initiative and welcomes all constructive criticism, we take exception to SeaChoice’s representation of where the ASC Program currently stands in regard to salmon certification in the recently released “Global Review of the Aquaculture Stewardship Council’s Salmon Standard." Notably, by amalgamating analysis of audit reports from 2014 — representing the period when the standard was first launched — through March 2018, SeaChoice completely overlooks and understates the fact that the ASC Salmon Standard has already progressed.

It is misleading at best to attempt to make a case on the fitness of the program irrespective of the changes that came into effect with v1.1 of the ASC Salmon Standard. The first full review of the standard was finalized in April 2017 and the revision introduced improvements which led to recognition by Monterey Bay Aquarium’s Seafood Watch. Since then, additional reviews of three other aspects of the Standard relating to smolt, parasiticide treatment index (PTI) and sea lice limits have also been initiated. These reviews are in progress and, just like all amendments to the ASC standards — have been subject to public consultations, some of which SeaChoice and some of its members have participated in.

The ASC does not require "100% compliance." Such ridgidity may not be possible for a variety of reasons and would not be compatible with the spirit of the ASC vision and mission to transform aquaculture towards environment sustainability and social responsibility.

As those familiar with certification schemes know well, a standard is not a stand-alone document. Farms must meet the certification requirements set in the ASC Certification and Accreditation Requirements (CAR) that together with the standard determine if a farm can be certified.

Introduced and operational at the same time as the Salmon Standard in 2012, the CAR allows farms to be certified provided no major non-conformities are open and minor non-conformities are closed in a defined timeline. This is not unique to ASC or ASC-certified salmon farms, but is in force and consistent for all species that ASC certifies.

SeaChoice’s strong focus on, and criticisms of, variance requests (VRs) as part of the ASC certification process, highlights the organisation’s lack of understanding of how the ASC and certification schemes actually work. Far from being "de facto amendments," VRs are an integral part of the certification process when and if solutions are needed to meet specific requirements. This is wholly consistent with Section 6.4 of ISEAL’s Standard Setting Code. Notwithstanding the need for compliance to standards’ requirements, the various ASC reviews are actually needed and desirable in order to improve the standards, based on the evolving definition(s) of “sustainability” and of the underlying science.

The very fact that the ASC Program provides a mechanism for assessing what may constitute non-compliances to standard requirements (with obligation to address and remedy to them) is being highlighted by SeaChoice as a flaw, whereby it constitutes one of the pillars of the continual improvement ethos underpinning the ASC Mission.

Participants in the original Salmon Aquaculture Dialogue – which included members of SeaChoice - and the ASC Technical Advisory Group (TAG), acknowledged when the salmon standard was being developed that the lack of data on salmon farm performance created challenges in calibrating metrics for certain aspects. Therefore, contrary to the case made in the report, the VR process is not only appropriate, but necessary.

SeaChoice’s misunderstanding as to what actually constitutes “compliance” and of how the ASC certification of a salmon farm is actually obtained resulted in SeaChoice’s alarming statement that “only about 20 percent of salmon farms actually follow the criteria as written.” This is wholly misleading. ASC firmly stands by the fact that all certified farms are duly so. However and as previously acknowledged, we recognize that no standard is infallible nor able to be applied strictly as written in every jurisdiction, due to the multiplicity and specificities of the various salmon farming environments and conditions.

ASC does not permit farms that have failed audits to use the ASC logo. The rigour of the ASC Program requires the withdrawl or suspension of farm or Chain of Custody certificates and/or the suspension of ASC logo licensing agreements in the event of a failed audit. We post these action publically on our website and all information on farm status is also similarly available.

ASC very much welcomes – and depends upon - constructive criticisms, for the design of new standards and the reviews of existing ones. As such, the SeaChoice report does make some valid observations, which we have duly noted. We also understand some of SeaChoice’s frustrations: the nature of multistakeholder processes means the while all contributions are considered, not all views will automatically be reflected in the final revision. While we make every attempt to provide stakeholders the opportunity to participate in these processes, this does not mean that all stakeholders will be satisfied with the outcome.

ASC remains engaged in an ongoing and open dialogue with multiple stakeholders, including Seachoice, based on a shared interest to bring further improvements to the aquaculture industry. Hence, we will strive to clarify the issues creating confusion, and continue improving the stringency of the ASC program, in line with our mission to transform current aquaculture practices towards environmental sustainability and social responsibility.

In the meantime, we remain confident that our continual improvement focus, the stringency of the standards and of the mechanisms in place to deliver it, ensure that the ASC Program is and remains meaningful, credible and effective.

Here are a few additional facts:

• ASC is the only standard for salmon aquaculture that has achieved benchmarks to Monterey Bay Aquarium’s Seafood Watch Program and the Global Sustainable Seafood Initiative (GSSI) —earning further distinction from the GSSI by achieving 52 "supplementary components," more than any other aquaculture certification scheme.

• ASC has several improvement initiatives in place to strengthen quality assurance (QA) work and the quality of auditor training since the formation of our Program Assurance team in 2017.

• ASC has begun using two methods to review audits reports, adding a risk-based approach to review additional filings.

• The ASC is reviewing, and where needed revising, the VR-process; something which SeaChoice had been informed of prior to the publication of its report in October 2018.

• Changes to provide increased consistency across all of its standards to the current process of raising non conformities will take place during the next ASC Certification and Accreditation Requirements (CAR) review and revision in 2019, in connection with the delivery of the first phase of ASC’s aligned standard.

A full and detailed ASC response can be found here: https://www.asc-aqua.org/news/latest-news/asc-response-to-seachoices-global-review-of-the-aquaculture-stewardship-councils-salmon-standard/.

Contessa Kellogg-Winters

Communications Director

Aquaculture Stewardship Council

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