Monday,29 August,2011 08:00:45
We all rely on suppliers to be honest with us. This is an imperative with the regulatory scrutiny regarding drug residues, identity of the raw material, traceability requirements, real weights (versus artificially inflated weights due to glazing or soaking) and the nutritional information on the outside of the package. How do we know that we can trust the information? The fact that it is illegal to sell fish contaminated with certain drug residues, labeled as a species that they are not, that are weighed with inadequately calibrated scales, etc. is unfortunately little protection.
When a consumer goes to the local grocery store and the store tells him that the product that he is buying is a given fish species, that it is fresh or not, that is it sustainable, that it contains a certain amount of sodium in it, etc., they believe that the store knows that these are truths. Does the store really know? They rely on what the supplier of the product tells them. Perhaps for some (or many) that means that the supplier knows. From where I sit, this is not necessarily the case. The supplier relies on the information that the vendor supplies to him. When someone tells you something and you relay that information to someone else and that information is not true how much of the responsibility for finding out the truth rests with you? This is why the term “caveat emptor” is so important. It is Latin for “Let the buyer beware”. Although the terms original use in modern jurisprudence dealt with real estate, it is readily applicable to seafood, whether from capture fisheries or from aquaculture.
This is one reason why consumers rely on third parties to sort these things out. A great deal of energy has been devoted towards educating consumers as to the veracity of various claims that are made regarding the true nature of products that are being bought. Well then, that means that we can rely on these parties to tell us the truth and use it to guide our judgment. Well, this turns out to be less than completely true as well.
Strong biases against specific production methodologies, farming of certain species, groups armed with poor quality or even high quality science misinterpreted can lead to misstatements of risk. With certification of capture fisheries and certain aquaculture species (typically on a farm by farm basis), we are being told that this assures you of certain truths. Based on my experience, this may be true in general. However there are exceptions to this and inspectors can be manipulated or lied to in some cases (note that I am not saying that this is the norm and it is likely exceptional-but it does occur and in some cases does create a real risk).
Recently I had occasion to audit a Tilapia farm that was interested in applying to be audited by a third party NGO as a result of a client requesting it. During the course of the audit a number of practices were uncovered that needed to be modified before the farm would be a suitable candidate. When I questioned the ability to trace the fish to the point of origin there was some hesitation and obfuscation. Upon further examination it turned out that the permits for export issued by the competent authority were not sufficient to meet client demand and that the client was sourcing product from non-approved sources and covering it up by forging and faking documents. This admission put everything that they told me into the category of questionable. After all if they were willing to cover this up and do it in a manner that made it a challenge to uncover in a routine inspection, what else would they cover up? In fact the farm went on to get registered with the NGO with no changes to the inaccuracy that I noted. It is my understanding, that they are currently registered and yet they are engaged in fraud. Given other experiences with producers in this part of the world, it is a safe bet that this operation is not the only case of this occurring. So if we rely on the farmer to be honest with the processor who is honest with the buyer who is honest with the seller who is honest with the consumer…. As one can see there is plenty of opportunity for misrepresentation here. Companies that will engage in activities such as this will go to extreme lengths to hide their duplicity. Where and how does this end? What are the risks to us as consumers? How much faith should I as a consumer have in what I am being told? What do I tell my wife when she goes to buy product from a major grocery store chain in the US that came from the geographic area? I tell her not to buy any seafood product from that area. This would also be my advice to anyone asking.
Until this happened I was adamantly opposed to advisory systems that condemned an entire countries production system. Perhaps I was the naïve one in this. While I still believe that these approaches are not universally acceptable, I believe though that there is no one approach to take that will ensure that you get what you think you are getting. After all, who is watching the watcher? My advice is to take everything with a grain of salt and do not rely absolutely on what you are being told by others. If you are the buyer, check on what the issues are and build in your own mechanisms to verify. This means conducting unannounced visits. This means randomly sampling product and having it tested. This means demanding that all analytical work be done according to accepted standards. Don’t assume that because they have been given a green light by a third party that they are actually doing what they are supposed to be. In many cases it is impossible for a third party to view all of the paperwork generated in a typical plant in-between inspection intervals, at least not within the framework of a half to two day visit. A random assessment of what has transpired between inspections is taken to be indicative of what reality is. Personally I don’t think that this necessarily means that I have the true picture of what is going on. If the intent is to deceive, it will occur and some third parties may not look deep enough to see what may actually be going on. I want to make it clear that I am in no way condemning third party participation in the process. In fact it is a valuable component, if properly conducted. By this I mean that it is not a rubber stamping of the processes but an active attempt to ensure truthful and full compliance with standards.
While few would accuse me of being an optimist, I firmly believe that this will be sorted out in time. It will take a few scandals, arrests, fines, imprisonments before it happens though. In the meanwhile, keep caveat emptor in mind and be skeptical. Check things out to the greatest extent that you can and do not rely on what you are being told by others. You are as capable of determining what is real and what is not as any third party. All it takes is a little effort. It is unfortunate but failure on the part of a single company to adhere to requirements can condemn an entire nations output and in some cases it should.