Asking for transparency from the MSC
On 25 July 2021, we sent the MSC a letter asking for further information on the consultation process for the Fisheries Standard, giving them until 9 August torespond. Our key questions were:
1. When will the comments from the stakeholders be publicly available and what format will they be in?
2. How are stakeholder comments weighted and how did MSC policy development progress from the discussions of last summer to the proposed solutions consulted on last month?
We also requested observer status (for a second time) at the next STAC and TAB meetings.
The MSC responded on 20 August. You can see their response below.
Dear Fin Free MSC Campaign
Thank you for your letter sent to Rupert Howes, Chief Executive, and Rohan Currey, Chief Science & Standards Officer, relating to the Marine Stewardship Council’s (MSC) recent Fisheries Standard Review (FSR) consultation on shark finning, and seeking to observe the forthcoming meetings of the Stakeholder Advisory Council (STAC) and Technical Advisory Board (TAB). I am responding on behalf of the three of us.
The MSC strives to prioritise stakeholder input and embraces a multi-stakeholder approach in its work. As you know, we have invested heavily in our engagement and consultation processes related to our current Fisheries Standard Review (FSR) and have ensured that stakeholder feedback is considered and incorporated across all FSR topics. Such inputs help to ensure our Fisheries Standard evolves according to advancements within global best practice of fisheries management and science. We are delighted to have had such extensive stakeholder participation in the FSR to date, with input from a diverse range of stakeholders.
In this context, therefore, MSC appreciates the interest and engagement of the Fin Free MSC campaign, with contributions made by several of your members to our various consultation exercises. We thank you for your involvement.
Turning to the detail of your letter, you raise number of questions, which I will address in turn:
Stakeholder consultation responses: the MSC has today published summary reports from our 2021 FSR public consultations. I am therefore pleased to share with you a link to our website where you will find the 2021 summary report on ‘Identifying further solutions to ensure MSC certified fisheries are not involved in shark finning’. You may recall that MSC published the same type of report after the 2020 consultation on preventing shark finning, and you can read that report on the same page on our website.
The preparation involved in making this information available externally takes quite some effort, and all the more so this time around, given the degree and range of interest we had in our most recent consultations. These summary reports contain an overview of the topics for consultation and descriptive analyses of the participating stakeholder groups. The report also includes the raw consultation feedback: publishing raw consultation feedback is considered ‘aspirational good practice’ by ISEAL. However, the report does not include policy direction.
At the end of the FSR process, we will also produce stakeholder engagement reports which will be made publicly available.
Stakeholder consultation input: we consider all stakeholder input to our consultation processes equally and objectively: it feeds into the policy development process alongside independent research, our own data analysis and impact assessments. These elements have been used in the FSR to develop policy options for each issue under review. We also carry out impact assessments on all proposed changes. This provides comparable information on the potential or expected impacts of the options considered and helps to increase transparency around decision-making.
Development of FSR policy options: following consideration by the Board in January 2022, we will share findings from the consultations and impact assessments and explain how we developed potential options for each topic. These findings will be communicated with stakeholders in early 2022. Stakeholders will also be given information on how to take part in the 60-day public review of the full draft Standard and Fisheries Certification Process (FCP), which is due to occur in early 2022.
Forthcoming STAC & TAB meetings: thank you for your request to observe the forthcoming meetings of the STAC and the TAB. As we explained in our letter last year to the Make Stewardship Count campaign, of which many of you are also members, MSC has limited space to offer for observers at STAC and TAB meetings. In considering observer attendance, therefore, we have now adopted an approach of taking careful account of the specific expertise that an observer is able to bring to these meetings, as well as the other, more effective, alternative mechanisms that enable the participation of the many interested third parties within our policy making processes. As outlined last year, this means that typically the (limited number of) observers we are able to host are invited to attend STAC and TAB meetings, rather than having sought to attend by application.
With regard to the forthcoming round of governance meetings, given the extensive engagement of stakeholders from all sectors in our FSR consultation exercises in 2020 and 2021 and the fact that the FSR is drawing towards is conclusion, we know there will be very high interest in these meetings; as a corollary, we anticipate an unprecedent number of applications for observers to attend the STAC and TAB meetings in the coming cycle.
In view of these particular circumstances, we have therefore decided that we will not be accepting observer applications from any stakeholders for these meetings – this will ensure a fair and consistent approach for all those who share in interest in the outcome of the FSR (and FCP). (ASI and representatives of CABs/assessors only may be invited to selected items for their technical expertise). I am sure you will understand that for these reasons, we will not be extending an invitation to you to observe the late-2021 STAC and TAB meetings.
Engagement with Fin Free MSC: MSC has gained valuable and important insights and perspectives over throughout the FSR process through its bilateral engagement with your members in the context of various campaigns and meetings in which they have participated, as well as well as through their active contributions to our consultation exercises. As is the case with all interested stakeholders, we look forward to our continued positive interactions with you through our established engagement processes and mechanisms. In particular, we will welcome strong stakeholder participation in our planned FSR consultation in 2022.
In closing, I would like to express my thanks for your continued interest in the MSC and its work, and your commitment to sustainability.
Dr Alene Wilton
Chief Operating Officer