ASC response to the  Review of Eco-labelling Standards in Relation to Salmon Farming in Macquarie Harbour,  a report commissioned by WWF Australia. 

The ASC welcomes the review. It presents a number of helpful recommendations that build on the existing credible ASC certification framework and recognises that the “ASC standard functioned successfully in Macquarie Harbour”.   

ASC is an independent charity operating a voluntary certification scheme – a market-based programme that recognises and rewards responsible farming practices in aquaculture. In 2018, companies certified to the ASC standard in Macquarie Harbour were lost as they could no longer comply with the standard.   

The ASC is not an industry body, nor does it receive money from farms through the certification process. The majority of our income comes from a royalty that seafood brands and retailers pay to the ASC if  the ASC logo is used on certified products.   

The ASC is an evidence-based body – we do not make general or speculative claims about the aquaculture sector: we will only use the claim “responsibly farmed” for farms that have objectively met our standards by way of an independent, on-site review of the farm against over 150 performance requirements. Macquarie Harbour farm certificates were lost as the companies were unable to take sufficient action in time to address declining water quality and meet related requirements.  

ASC operates globally and there are currently around 1,500 farm operations certified in 50 countries. Of these 557 are salmon farms, 267 are located in Norway, a further 136 in Chile and others are certified in Scotland, Ireland, Canada, Faroe Islands, Iceland, Poland and New Zealand. Currently only eight salmon farming sites are certified in Australia, all of them in Tasmania and all are operated by Tassal, who in total farm at 36 sites in Tasmania.  

Not one of the 11 salmon farming sites in Macquarie Harbour is certified to the ASC standard. However, they are still certified to other aquaculture standards that have lower environmental requirements. 

To transparently inform stakeholders about certified farm performance, the ASC makes available all assessment reports for public scrutiny. This provides accountability, informs future aquaculture research and improvements to the ASC Programme.   

The review provides useful and detailed information about the Macquarie Harbour environment; notably having poor water circulation, is subject to rapid changes in water quality and is naturally low in oxygen at deeper levels. Freshwater inflows from heavily forested catchments bring in large amounts of organic matter (leaves) which sink to the seabed and reduce oxygen levels as they rot. These conditions and the implications they bring for management of farming are therefore also unique and have not been experienced at any of the other certified salmon sites globally. 

As the review notes the success of an aquaculture project relies heavily on an appropriate location, and the consequences of site selection can greatly affect a farm’s future ability to comply with voluntary standards for responsible and sustainable aquaculture. The reviewers consider a number of suggestions as to how voluntary sustainability standards (VSS), such as ASC, could be more adaptive to ensure special conditions specific to a local environment can be taken into account and how indicators can be designed to reduce impacts that cannot be managed at the individual farm-level. 

While the reviewers do not suggest that VSS should include requirements for the zoning and site selection process, they do suggest that it might be worth exploring non-binding guidance on an effective zoning and site selection process. We agree with this suggestion. 

Other suggestions by the reviewers include considering the use of local interpretations of globally applicable standard content, which is a mechanism ASC has used and will consider further regards Macquarie Harbour. Perhaps more interesting are their suggestions as to how Environmental Impact Assessments (EIAs) can be enhanced to assess the risk of cumulative impacts beyond the footprint of a single farm.   

There are three other key recommendations made in the review worth highlighting here, which build on ASC’s existing systems and current standard review work. The first is how the existing and leading requirements for Area Based Management (ABA) can be enhanced. Our existing ABA approach focusses on biosecurity but other topics that require solutions beyond a single farm, such as carrying capacity, should also be explored.  

The second relates to how the perspectives of local stakeholders can be better incorporated into our certification processes and how expectations of process and resulting outcomes can be aligned. While this is already a unique strength of the ASC program: which requires stakeholder consultation and engagement when farm audits are announced and when the draft public report is consulted on, the further suggestions by the reviewer aligns well with these opportunities and will be taken forward. The third area considers how compliance against the regulatory environment can be further strengthened by considering the effectiveness of enforcement. 

Our work to incorporate the reviewer’s recommendations has been underway for some time and is incorporated into a broader review of our standards. The ASC is currently seeking to align all of the content from individual farm species standards into a common and consistent format. This of course recognises the need for indicators that are production-specific and species-specific when needed. But the ambition is to achieve greater coherence and efficiencies across all of this content. The lead author of the Macquarie Harbour review is working with the ASC to help incorporate the key findings into this work and they will be available for public consultation scheduled for March 2022. A few details are provided below. 

We are proposing modifications to the existing EIA requirements to incorporate both broader “risk- scoping” and “response driven” concepts. These concepts are already embedded in our recently published Feed Standard for the assessment of feed ingredient sourcing risks and has now been expanded into our EIA review. 

Within the work to align how we assess benthic impacts in the future, indicators have been developed to make sampling and limits more “risk sensitive” and requiring escalating responses as performance decreases. Further work is underway to substantiate trigger points, how these are monitored and reviewed, including when sampling should occur and where site selection should be located for reference sites. 

Our review of water-quality indicators has recognised the need to assess the suitability of current parameters, and the need for new parameters to establish core carrying capacity requirements for data collection at farm level, that will inform the later development of carrying capacity models.   

The compliance with regulation and review of regulatory performance is an area that will be reviewed and incorporated within the upcoming aligned Farm Standard. 

Much of what is contained in the review is not only already known to the ASC but is being addressed as part of its normal and ordered process of reviewing and refining its standards, including the salmon standard.   

At ASC we have long called for greater collaboration in the aquaculture sector and have tried to lead by example in this regard, involving NGOs, scientists, industry experts and the public in both the development of our standards and farm audits themselves. Macquarie Harbour can be an opportunity for all responsible stakeholders, including farms, government and NGOs, to work together to ensure the lessons learnt can be incorporated into future best practices.

Published on
Monday, 06 September 2021
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