Mr. President, the U.S. Department of Commerce and related agencies:
The U.S. seafood industry appreciates that you’ve turned your attention to Illegal, Unreported and Unregulated (IUU) fishing and seafood fraud. The task force you established to address this longstanding problem issued many recommendations for addressing the issue, and they have been met with widespread applause from non-governmental organizations that have an interest in making global seafood supplies as sustainable as possible. That cannot be accomplished if IUU fishing is left to continue unabated.
After a lengthy process, the National Ocean Council presented your office a series of recommendations on how to implement a “comprehensive framework of integrated programs to combat IUU fishing and seafood fraud that emphasizes areas of greatest need.” And on 15 December, National Marine Fisheries Service Deputy Assistant Administrator for Regulatory Programs Samuel Rauch issued a call for public comment on these recommendations.
Here is mine: Don’t shy away from the price tag. A true commitment to implementing all of the actions outlined in Rauch’s comprehensive notice will require more time, manpower and funds, not to mention hard deadlines with punishment for non-compliance. The cost will likely be a lot more than what the federal government is currently budgeting for fisheries and seafood trade law enforcement.
The United States, which Rauch deemed a “global leader in sustainable seafood,” must now demonstrate just that by also partnering with like-minded governments around the world and enforcing existing laws banning IUU fishing practices. Because so much of the current IUU fishing activities occur on the high seas the challenge is massive, but sufficient laws already exist. Enforce them.
Address all coastal nations around the world and urge them to adopt stricter regulations regarding the 2009 Agreement on Port State Measures to Prevent, Deter and Eliminate IUU Fishing (PSMA), such as the flags that fishing vessels fly when bringing fish to port.
Enable regional fishery management organizations (RFMOs) to enforce traceability regulations for all fishing vessels. Require that all RFMOs adhere to all measures of the 1995 United Nations Fish Stocks Agreement (UNFSA), allowing for high-seas law enforcement around the globe, not just in certain areas.
Internally, pertaining to U.S. seafood imports and economic integrity regulations, direct the U.S. Food and Drug Administration (FDA) to make food safety and labeling laws an agency priority. The FDA needs to have a greater presence at key ports of entry and aggressively inspect shipping documents and product samples. A better-equipped FDA is essential to show that the United States is serious about policing the seafood trade, as its inspectors are a key line of defense, particularly with seafood fraud.
Lastly, do not allow the passage of the U.S. Department of Agriculture Catfish Inspection Program. Rauch identified “multiple federal agencies responsible for regulating only a part of [international and domestic] trade” as one of the challenges that undermine efforts to collect, share and analyze information in combating IUU fishing and fraud. Repealing this measure, required by the Farm Bill, is a great place to start.
In the end, the success of these efforts will require sufficient funding. Please ensure that the livelihoods of law-abiding commercial fishermen and seafood traders are protected by allocating the necessary funds to not only carry out these agencies’ duties but allow their efforts to expand and set an example for other nations around the world.
Best regards,
James Wright, senior editor, SeafoodSource
Please submit any comments by 16 January 2015 via the Federal e-Rulemaking portal by visiting www.regulations.gov/#!docketDetail;D=NOAA-NMFS-2014-0090 and clicking on the “Comment Now!” icon.
