Can MSC Prevent Fraud?

Many in the tuna industry are realizing that ensuring sustainability in the sector is something that cannot be ignored for the long term viability of their business. And what’s evident is that MSC is generally regarded as the most recognized certification to guarantee it.

But while its blue tick logo strives to give retailers and consumers assurance that a product has been sourced sustainably, there’s not much access to what happens behind the label.

As previously reported by Atuna, and to the surprise of some, while MSC labeled seafood includes the reference code for the firm licensed to use the ecolabel, and can be used by MSC to trace the origin of seafood, it’s not possible for end market buyers or consumers to do the same.

Wendy Banta, from the MSC Chain of Custody (CoC) Traceability Team, told Atuna that there are companies with certification that go beyond the standards, to offer full traceability to their consumers, but this is not a requirement of MSC as it stands. However, she indicated that MSC is working on ways to recognize these efforts in the future.

To be sold with the MSC label, seafood from certified fisheries can only be handled, processed and packaged by organizations with a valid CoC certificate. These companies are regularly audited by third parties, usually once a year, to ensure that all MSC standards are being adhered to. This is overseen by the MSC’s product integrity team.

There are currently 26 third party assessors, or Conformity Assessment Bodies (CABs) accredited to carry out MSC CoC assessments, and this approval lasts for five years. The fishery or company entering the MSC process chooses from this list, and is responsible for paying. The initial CAB is usually then used for subsequent re-assessment or audits.

However, following concerns that these pre-arranged audits by CABs are not catching all possible supply chain issues, unannounced audits have come into play; a relatively new part of the process still being trialed. Banta explains, that for now, each third party auditor is required to randomly check just one percent of its MSC clients per year; a small portion, but this may be increased or altered in the future.

Random checks are very similar to regular audits, she notes, adding that a checklist is taken on site. “The company must demonstrate that for each point it is meeting the standard.” Auditors check if the product is being segregated, identified and labeled at every production step and staff are interviewed to ensure they are aware of and are implementing MSC’s requirements.

Another activity conducted is an in-put out-put reconciliation, sometimes called a mass balance or volume check, Banta explains. “It’s a key way to make sure that volume fraud is not happening. A company can’t sell a greater volume of MSC certified tuna than what it received; it has to be equal or less.”

What the CoC auditor cannot verify however is whether the MSC catch volume from a particular vessel matches up to the total MSC certified volume received from each buyer its landings are sold to.

Banta explains that each audit can only check a single company, and can only know the volume that firm has received. Each vessel can be selling to a number of clients, however, which suggests that there is often no clear overview of the total journey of that boat’s catch.

She does stress however that while there is one team in charge of CoC traceability, there is also another that checks up on the standards of MSC certified fisheries. This means every stage of the certification and supply chain is thoroughly examined, she believes.

But there have been certain doubts over how fool-proof MSC’s supply chain checks are, especially related to tuna, and its often long, complicated journey from sea to shelf.

Just recently, Pacifical, the marketing arm of the PNA’s MSC certified free-school caught skipjack and yellowfin tuna fishery, responded to comments questioning the credibility of the accreditation. It stated that similar concerns led it to launch an independent, stringent tracking system of its own products and their supply chain, back in 2011.

Tuna can travel extensive distances of thousands of kilometers before it ends up on a plate. Its journey usually sees it jump from fishing vessel to carrier, then from carrier to cold storage, then finally to the cannery. There can even be another international trip before it lands at its end market. There are very few cases in which tuna goes straight from fishing boat to the cannery.

Concerns related to the complicated journey of tuna catch to end product have been aired by other firms in the industry, even those certified themselves. Atuna previously spoke to management from a Maldives tuna processing company, who questioned the reliability of the MSC journey of pole and line catch, and the surety behind the strict separation of certified and non-certified fish at every stage of the process.

He thinks that in some cases, MSC certified pole and line skipjack caught in the Maldives can be mixed with other non-certified catch in Thai canneries. He also believes this mixed product is then still marketed as MSC pole and line catch in the European market.

The source did add however, that without MSC certification, he would expect this sort of pole and line fraud to happen more commonly. He gave the impression that while he thought MSC wasn’t bullet-proof, supply chains with the certification were less open to fraud than those without.

MSC’s Banta stressed that any doubts within an MSC supply chain can and have been checked up on: “If we do have a specific concern about volume or suspicion surrounding a company, we can look into that.” She explained that this has been needed in the past, withholding any examples, but said that discrepancies were immediately resolved.

While she acknowledges that tracing back through a tuna supply chain is not information that MSC has readily available, she did say: “We can use auditors from the different third parties, and check all companies involved in the chain of a specific product to make an overall check.”

DNA tests are conducted as part of many audits, and MSC has released recent results, boasting nearly 100 percent accuracy. But this has not included tuna, which Banta explains is due to the highly de-natured characteristic of canned tuna, making it very difficult to detect the species. MSC is now working with researchers in Australia to develop a way to do this.

DNA testing has its limits for other species too, as despite being able to check that the label matches the product, in most cases it will fail to detect where the fish was caught, and definitely cannot reveal the gear type that caught it. That’s where Banta says that the CoC comes into play, and the traceability checks made around it.

She stresses that each link or company in the supply chain has a CoC certificate which is regularly audited, and that at every stage there is documentation to prove that the fish was bought from another MSC certified firm. “So there can be no breaks in the chain to allow product from a non-certified fishery to come in,” she assures.

But, as addressed before, seafood traceability can be complex at the best of times, and for tuna, a globally fished, globally processed, and globally marketed species, keeping track of the international flow of products from the point of sale to the source, can be much more difficult. Not only species fraud can creep in, but also the entrance of illegally fished products.

This is a subject that Gilles Hosch, an adviser to the FAO and expert on traceability and certification in the seafood industry, has touched on heavily in the past. He has explained that tuna Catch Documentation Schemes (CDS) have had a hard time reigning over IUU fishing and diminishing trade avenues of IUU tuna within the global market because of this.

Hosch has stressed that CDS’ and document flows do not manage to effectively connect with the complexities of international supply chains. In 2013, a study titled ‘Traceability, legal provenance and the EU IUU Regulation’ by Hosch and Shelly Clarke, addressed the certification scheme of EU IUU regulation. It found “critical flaws” such as “ineffective implementation, including widespread and often undetectable document fraud.”

For now, the documentation that MSC claims eradicates this, and allows it to make tuna product trace-backs, is kept for MSC and its auditors themselves, and there is no requirement to divulge this to consumers. However, Banta does acknowledge that there are fisheries and firms going above and beyond to allow consumers access to this type of traceability; “the PNA and Pacifical are a prime example.”

Using a QR or production code available on any can of Pacifical MSC certified tuna, a consumer can fully trace the product through its entire supply chain. An online video is displayed for the shopper to view, showing details such as the vessel name, captain name, species, fishing method and date and location of the catch.

The consumer will also be presented with the cannery name, location in which the tuna was processed, and the date that the can of tuna they are buying was produced.

Pacifical makes this information available with the cooperation of the PNA office, which assigns each purse seiner owner with an MSC trip number for each trip, and assigns an MSC trained observer to the vessels. The observer then, using a tablet, electronically takes note of catch, species, quantity and bycatch, which several times per day is uploaded through satellite to the PNA computer system; FIMS.

This data is then verified by PNA officials and is shared with the Pacifical tracking system. It is made available to canneries, so that they can connect their production code to the MSC trip number, enabling consumers to verify by which sustainable fishing method their canned tuna was caught, including plenty of other details.

Banta said that MSC recognizes this initiative from Pacifical as great work, and she indicated that MSC is working on ways to recognize this type of effort in the future.

Overall, MSC gives clear details on what is happening behind its eco-label, now stamped on hundreds of products across many markets, to ensure credibility and integrity. But the organization itself realizes that improvements still need to be made and is responding to them.

For now, however, while the retailers and consumers buying these products are generally assured on sustainability by the presence of this blue tick logo, they don’t have access to the important checks, findings and potential shortfalls happening behind it.