Following the MSC certification of the Russian Sea of Okhotsk (SOO) pollock fishery in September 2013, the MSC carried out proactive monitoring to investigate the integrity of the fishery’s supply chain.
Between October 2013 and February 2014, the MSC conducted a detailed reconciliation exercise on global sales and purchasing of MSC certified and ‘under MSC assessment fish’ (UMAF) pollock. This is to ensure MSC labelled products were fully compliant with MSC Chain of Custody (CoC) requirements. This reconciliation included products from both the Russian fishery and the MSC-certified Alaskan pollock fishery.
The exercise was a precautionary monitoring measure, which was conducted due to the complex UMAF requirements relating to the Russian SOO pollock fishery.
Under MSC’s ‘UMAF’ requirements, some products harvested during a fishery assessment period may eventually be sold as ‘MSC’ once the fishery is certified, subject to specific constraints. Through the collection of data on volumes of certified products bought and sold at different points along the supply chain, the MSC can verify whether UMAF procedures were followed correctly.
Results of the Russian pollock reconciliation
MSC contacted 75 CoC certified companies from different parts of the global supply chain (US, EU, China, Russia, and Hong Kong) to request sales and purchasing volumes of MSC certified and UMAF pollock products from Alaskan and Russian SOO fisheries.
Under the MSC CoC, companies are required to respond to such a request and 70 companies did provide the full set of requested data to the MSC. In the five cases where companies did not respond, the request was followed up by the conformance assessment body (CAB), who issued a major non-conformity and eventually suspended the certificates.
The monitoring exercise allowed the MSC to cross-reference purchase and sale transactions across various links in the supply chain. This provides an additional level of assurance beyond the verification of traceability records at each step of the supply chain which is required in routine MSC CoC audits.
The reconciliation showed that the majority of fish sold as ‘UMAF’ by the members of Pollock Catchers Association (PCA), the client group for the Russian SOO pollock fishery, was handled by companies further down the supply chain as non-MSC certified product. Where ‘UMAF’ fish was sold as MSC certified pollock, following the fishery certification, full compliance with UMAF requirements was demonstrated.
Results of integrity checks on other products
The Russian SOO pollock reconciliation exercise was part of the MSC’s ongoing program to monitor the effectiveness of the CoC system. The MSC carries out additional assurance – including DNA testing, product tracebacks, and supply chain reconciliations – either in cases where specific traceability concerns have been identified, or to proactively monitor high-risk supply chains.
During 2013, the MSC performed tracebacks on MSC-labelled mackerel products following the suspension of seven MSC certified mackerel fisheries in the North East Atlantic. The process involved tracking samples of MSC-labelled products collected in different EU countries (UK, Sweden, Netherlands, and Denmark) back to the level of the fishery and found no cases of substitution or mislabelling.
Similar tracebacks were conducted following the MSC’s December 2013 DNA results. DNA testing showed that only 3 products from 320 samples tested were found to be mislabelled. As a result of the tracebacks on these three products, one company had its MSC certificate suspended for mislabelling and another agreed with their certifier to develop a corrective action plan to respond to an incident of substitution between two certified species. Areas of concern identified during the third traceback were passed on to the relevant certifier and further investigation is currently underway.