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Consolidated Comments Shrimp Aquaculture Dialogue Public Comments Recieved Dec 1, 2010 – Feb. 1, 2011 (2nd Period) Table of Contents Gert van der Bijl (Solidaridad) 3 Thomas Wilson 5 Dallas Weaver 6 Blake Lee Harwood 8 Alfredo Quarto (Mangrove Action Project) 9 Brad Price (Seajoy) 9 Tatiana (WWF MTI Soy Team) 10 Aldin Hilbrands (Royal Ahold) 10 Frédéric Millet (National Prawn Company) 11 David R.W. Griffith (C. I. Cartagenera de Acuacultura) 13 Serge Orru (WWF France) 15 Anders Hviid Jensen (Nordic Seafood A/S) 16 New England Aquarium 17 Richard Luney (Marks & Spencer Plc UK) 21 Bambang Widgdo (PT.Central Proteinaprima) 25 Marie Logan (Food & Water Watch) 26 Conscientious Objectors 27 Belize Shrimp Grower’s Association 30 Mathias Ismail (OSO Gastronomie) 31 Marc Le Groumellec (UNIMA) 32 Lena Klevenås (FoodFirst Information and Action Network Sweden) 39 Monica Erwér (The Swallows India Bangladesh desk, Sweden) 41 Joseph Suresh 42 Dr. Niti Chuchird (Kasetsart University) 42 Jake Piscano 43 Mr. Vu Vi An (Reseach Institute for Aquaculture 2) 44 Greg Small (Rubicon Resources) 45 WWF Malaysia 49 Dr. Stanley Chia 60 Mark Nijhof (Heiploeg Group of Companies) 61 Rujinop Tanjaturon (Seafresh) 65 M.N. Kutty 73 1 Grupo Granjas Marinas, Honduras 74 Stephanie Mathey (Carrefour) 80 Dirk Lamberts 82 WWF Vietnam 83 WWF US, Costco, Thai Farmers 85 Peter Vandergeest 93 Dan Fegan (Cargill) 98 WWF Germany, Switzerland, Austria, and Sweden 110 Vu Ngoc Ut (CanTho Universty) 117 Vu Ngoc Long (CBD) 117 Dr. Tuan (MARD Vietnam) 119 Timeline for Response The public comments have been separated into Principle, Criteria, and Indicators/ Standards and are now under review by the GSC. A formal response will be posted with the comments received when Version 3 of the ShAD standards is posted sometime in May. Version 3 will be used to develop the guidance and will be used for field testing the standards. The Global Steering Committee for the Shrimp Aquaculture Dialogue is appreciative of all the comments received and will consider and respond to all comments. 2 COMMENT # 1 – Gert van der Bijl Van: Gert van der Bijl Verzonden: vrijdag 28 januari 2011 14:22 Aan: '[email protected]' Onderwerp: Shrimp Aquaculture Dialogue Public Comments Due February 1, 2011 Please find below some the text parts of the draft Shrimp Aquaculture standard in box with below each box some of my comments First of all: there is a considerable number of highly relevant issues (e.g. social issues), also from the point of view of our organization, that I don’t comment on. I focus my comments on the chapters covering terrestrial feed as my perception is that in this chapter there is much room for improval. • Feed management: Wild stocks of fish can be depleted for use in formulated feeds for shrimp production Comment This is definitely true. But as in feed for aquaculture fish is increasingly being replaced, and likely to be replaced by terrestrial feed, concern about the possible negative social and environmental impact of production of crops should be added here as an important concern. 1) Some GSC members think that these standards can be audited through documentation provided by suppliers that may or may not be audited by an independent third party. Others are concerned that this will not be strong enough for a credible eco‐label given that it will rely heavily on documentation for compliance. 2) Some GSC members are suggesting to take Principle 7 out of the standards in order to not bring confusion and to creating false expectations for consumers what issues have been adequately covered. As a consequence, they suggest waiting until a specific standard is designed for shrimp feed plants, and independent ASC auditors are able to validate the practices at this level of the chain of custody before communicating on these issues towards the consumers. The GSC welcomes opinions or suggestions on how to handle this issue Comment I am afraid that taking out this Principle 7 will create more confusion among consumers and buyers and will create more false expectations. Consumers and buyers are likely simply to expect that a standard addressing sustainability of shrimp production will be integral and holistic and therefore as much as possible also cover sustainability of feed production. Not addressing this issue will be very difficult if not impossible to explain. 7.1.3 Responsible sourcing of feed ingredients the feed manufacturer must provide evidence of policies to source only feed ingredients which comply with internationally recognized moratoriums and local laws, including vegetable ingredients or products derived from vegetable ingredients. The ingredients must not come from the Amazon Biome, as geographically defined by the Brazilian Soya Moratorium. Guidance 7.1.3: The farmer or feed company must demonstrate that ingredients are not coming from the Amazon biome or other regions of globally significant biodiversity. 3 Comment I see several problems here: 1. The indicator and the text for Guidance seem to be not fully in line. In the indicator only the Amazone Biome as defined by the Brazilian Soya Moratorium has been mentioned, whereas in the guidance ‘or other regions of globally significant biodiversity’ is added. Adding other areas is important for two reasons: a. The Soya Moratorium is only working in one country (Brazil) in one area with just a very small part of the Brazilian soy production b. Deforestation is a problem in other areas in Brazil and in other countries as well. But in that case a list of areas should be added, which would further complicate issues. 2. The Soya Moratorium is an important element to assist companies in defining a responsible sourcing policy for soy, which is an important vegetable ingredient for shrimps. However, Compliance to the Soy Moratorium does not mean that the soy does not come from the Amazon Biome. The Soy Moratorium inhibits trade of soy from areas deforested after July 24th 2006 in the Amazon Biome. 3. A considerable number of companies has expressed support to the Soy Moratorium. But at batch level it is not possible to verify compliance to the Soy Moratorium, so for an individual shrimp producer it is impossible to proof compliance to this criterion. 4. It seems that sustainability issues here are reduced to just one (important,) issue. But there is a large number of other social and environmental issues that should be part of a responsible sourcing policy, including pesticide use and other elements of Good Agricultural Practices and good labour conditions to mentioned but a few. Recapping: Although supporting the Soy Moratorium can be seen as relevant and important, it will be very complicated if not impossible to link it to certified shrimp production. As far as I see the only alternative will be to demand certified feed production as soon as reasonably possible. 7.3.1 Percentage of non‐marine ingredients from sources certified by an ISEAL member’s certification scheme that addresses environmental and social sustainability 100% within 5 years of the date of ShAD standards publication for soy and 3 years for palm oil Guidance 7.3.1: Soy must originate from sources certified under an ISEAL membership scheme. It is expected that this can include the Sustainable Agriculture Network (SAN) protocol for soy and/or the Roundtable for Responsible Soy Production (RTRS) within 5 years of the publication of the ShAD standards. Palm oil must originate from sourcing certified by the standards created by the Roundtable on Sustainable Palm oil within 3 years. Other ingredients must originate from certified sources within 5 years of the standards. Comment Suggested requirement: Presence and evidence of a responsible sourcing policy for the feed manufacturer for feed ingredients which comply with recognized crop moratoriums, local laws and compliance to relevant independent, third‐party sustainability schemes for the key vegetable ingredients. For soy compliance with RTRS or any standard that is considered to be equivalent by ASC is required in those countries where RTRS soy is available. It is difficult to think of a good reason to add that this is ‘expected to be included within 5 years’. RTRS soy will be available from 2011 onwards. RSPO certified produce has been available for a number of years. Availability of segregated material still is limited. But other chains of custody could be included. Gert van der Bijl Programme Officer Sustainable Agri‐commodities Solidaridad 4 't Goylaan 15 ‐ 3525 AA Utrecht ‐ the Netherlands t. + 31 (0)30 272 0313 m. + 31 (0)6 22784846 [email protected] skype: gert.van.der.bijl COMMENT # 2 – Thomas Wilson I have some comments on the proposed standards: "Some GSC members are suggesting to take Principle 7 out of the standards in order to not bring confusion and to creating false expectations for consumers what issues have bee nadequately covered. As a consequence, they suggest waiting until a specific standard is designed for shrimp feed plants, and independent ASC auditors are able to validate the practices at this level of the chain of custody before communicating on these issues towards the consumers. " I feel that it would be better to have a specific set of standards for feed mills, and that the farmer should be required to buy feed from feed companies that have received certification regarding those standards, if that is possible. In the interest of social and economic sustainability, there should be an option for supplying shrimp even if certified feed is not available in the country where the shrimp are being produced. Requiring the farmer to import feed from elsewhere has environmental and economic costs that may out way the benefit of forcing feed compliance. "list of feed ingredients present in a proportion of>1%, including all marine, terrestrial plan t, and terrestrial animal ingredients " The shrimp feed business is highly competitive and we have to have a bit of leeway for differentiation without making all of our information available to competitors.
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