This article is based on the information given by the Fishmeal Information Network (FIN), and has been written by David Hill, an ex industrial fisherman, of 27 years experience, and it is critical of the impression given by the FIN in it´ s 2003 Sustainability Dossier. This article is written with the view of giving an opinion of the information that is in the FIN dossier.

 

                        Fish meal Information Network (FIN) www.fin.org.uk

                     A critical review of the January 2003 Sustainability Dossier

FIN claims, and rightly so, that the sustainability of fish stocks, remains a crucial issue, and also, that the fish meal industry is concerned to ensure that its raw materials continue to be managed and conserved according to sustainable principles. In regard of the White fish stock situation, especially the Cod Haddock and Whiting, it has also become a moral issue.

FIN also informs, that the sustainability dossier is updated annually.

FIN claims, in its dossier;

1. Under the heading “Fish species used to produce fish meal “,  ” fish meal is produced from small bony species of pelagic fish (living in the surface waters or middle depths of the sea) ”.

2. “Currently sustainable amounts of fish, estimated by FAO, at 25 – 30 million tons, are caught as by catch along with human grade fish.

By catch is thrown overboard (it is all protein and simply goes back into the food chain)”.

3. “ In future more accurate targeting will reduce the by catch and more what is caught will be landed for fish meal and oil production”.

 4. FIN informs, “ Seven key species are used to produce fish meal and oil in Europe. These can be divided into three groups;

a     No use for human consumption (inedible feed grade fish – sand eel, capelin, Norway pout).

b     Potential use for human consumption but mainly used for fish meal because of limited outlets for human       consumption (blue whiting, sprat).

c.     Primary use in human consumption but surplus may be used for fish meal (herring, horse mackerel).                                                                                                   

5. FIN claims, “ The information contained in their dossier supports FINs continued assurance that fish meal is produced from fish stocks (either non- food fish or trimmings from the food fish processing sector) which are properly monitored according to independent scientific advice.

In view of the claims that FIN make, the real world of industrial fishing, the fish stocks that are being used for reduction purposes, and the ICES recommendations for the same stocks, or lack of them, all of the North Sea fish stocks are heading for a disaster, of a proportion that has never been seen before, and I will give my reasons for believing that .

1.   Fin claims that fish meal is produced from small bony species of pelagic fish, living in the surface waters or middle depths of the sea, this claim must refer to the catching of very small immature fish such as the sand eel where the industrial fishermen themselves made an agreement not to catch sand eels under 9 cm. in length the one day, and annulled the agreement the next day. Although the description may be the truth in some of the South American fisheries, it could absolutely not be further from the truth when talking of the EU waters industrial fishing species.

Sand eel, and Pout, the two most important industrial species, are sea bed

(Bottom)   fish, and it is a well known fact that the sand eel buries itself in the sand, and that the pout fishery is a very muddy affair, where large amounts of chains and weight, and long wires are used to keep the trawl on the bottom.  I have a strong suspicion that the reason for not mentioning that “bottom fish” are used as raw material, is that if it is, the question of Dioxin in the end product will also have to be mentioned, and I will address that problem at the end of this article. The introduction of Herring as a reduction species happened through the back door by the enormous amounts of by catch in the sprat fishery, which for the most is also caught on the sea bed.

The large amounts of Haddock, a white fish species, that have been dominant in the recent pout landings, up to 30% of the catch, proves that the claim for raw material that FIN make, “small bony surface fish”, should be studied carefully.

Over 100 licenses were revoked in 2000 for illegal by catch landings of herring in the sprat fishery, this must be said to be an alarming number, when regard is taken to number of vessels that are catching industrial fish.

2.Fin claims, that FAO has estimated, that 25-30 million tons of fish are caught as by catch along with human grade fish, and this by catch is thrown back into the food chain.

This is very commendable, especially as facts show, that the by catch caught by the industrial fishermen, goes into the fish room and is reduced together with any industrial fish caught, FIN claims “ it is all protein and simply goes back into the food chain.

Is this why Fish meal and fish oil interests want industrial fishing called    “ feed grade fishing “ and  the species they catch, “protein fish”?

3. FIN also claims that in future more accurate targeting will reduce by catch, and more of what is caught will be landed for fish meal and oil production. In the 1950s when the industrial fish production started, the biggest problem was not catching raw material, it was finding mesh sizes small enough to hold the small fish, and this situation, and mesh size has been predominant over 50 years in the industrial fisheries. If on the other hand you look at the white fish mesh developments, they have been increased since 1985 from 85mm to 140mm.                                           Industrial fish are  still caught with a 16mm mesh and how FIN thinks that targeting will be better in the future, than it has been in the past, will be a sight worth seeing. The industrial boats have become much larger, and more powerful and effective than ever before, and the proof of that lays in the catching figures.

In 1994 there were 404 Danish vessels that caught only industrial fish species, that figure is down, in 2003, to 150. In 1994 there was landed over a million tons raw material for reduction purposes, and in 2002 the amount was the same. A reduction of   250 vessels made no difference to the amount caught. More sophisticated gear, and instruments to help the catching power, has only produced the need for industrial fishing vessels to take absolutely no consideration as to which species are in the catch, and the illegal by catch situation proves this.

How can FIN /GAFTA ever expect that the stock situation in the North Sea will continue to be what they call “ sustainable” when the TAC s and quotas “ roll over” from one year to another, mainly because there are no scientific surveys made of these stocks, and  even though the fleet is cut back, the effort is increased ?

4. FIN informs that seven key species are used to produce fish meal and oil in Europe – Sand eel, Capelin, Norway Pout, Blue whiting, Sprat, Herring and Horse Mackerel. The dossier does not mention at all, that industrial fish are feed fish for all other species in the North Sea, or that large amounts of white fish are caught in the 16-mm. Mesh trawls.

 In the 1994 study of the Danish fish meal and fish oil industry, the true story is altogether a different story. Up to 13.000 tons of white fish were being caught in the North Sea, 9.000 tons in the Skagerrak, and 800 tons in the Kattegat, and other reports set this figure much higher, which makes these catch figures, untrustworthy. 

As I have informed, the industrial catch is the same now as for 30 years ago, the assumption must be, that this “ by catch “ is continuing, and the figures are there to prove it.

5. FIN claims, that the information contained in their dossier supports their continued assurance, that the fish meal produced, is properly monitored according to independent scientific advice.

No doubt that FIN refer to ICES but just how much independent is ICES , it must be  left to the imagination. Recently, some scientists are having misgivings about the industrial removal of 1 million tons from the feed chain, whilst other scientists are advising, that the fish in the North Sea are starving, and that means only one thing in any language, the removal of a million tons of feed (industrial) fish from the North Sea, is effecting all other species, but this is not the impression given in FIN s sustainability dossier 2003.

In 1993 a report concluded,” data shows that the biomass of sprat and Norway pout removed by fish predators far exceeds that removed by the fishery, however this is not the case for sand eels where the fishery is a more serious competitor for the resource, taking over half as much  sand eel biomass as all the fish predators combined “.

To understand the full impact of this statement you need to take into account the state of the 3 fisheries in 1993. The sprat stocks had been reduced so much that the Danish industrial quota had been reduced from 60.000 tons in the late 1980 s to below 30.000 tons in 1993. The Norway pout stocks had also been considerably reduced so much by 1989 that a precautionary quota was applied. As regards the sand eel, a TAC of over 1.million tons was introduced in the North Sea in 1997, but barely the half of it has been caught every year since it came into force, and yet ICES still maintains that “ these stocks are within safe biological limits” and the stock can sustain current fishing levels. If this is true, and it is ICES that claims it to be, then the TAC should have been lower than the actual catch, which is about 500.000 tons, but it isn’t.

Why has a precautionary TAC not been enforced ? What are the  reasons for letting this TAC “ roll over” ?

Where is the “ common sense “ in these decisions ?

In South America, according to FIN itself, there seasonal bans, and MLS on all species used for meal and oil.

It should be mentioned, that the FIN sustainability dossier does not mention any MLS s for the E U sustainable fish stocks that are used for reduction to meal and oil, probably because they do not exist on any of these species, but do on all the white fish species.    

According to reports in Denmark, in 1992 there was 24.869 landings of industrial fish, and 8% were inspected. In 2002 there were 6.879 landings of the same amount of fish, and only the same percentage of inspections were carried out, 7.7%.

This is what FIN calls “ Independent  Monitoring “ .

The roll of the industrial fish species in the food chain of the North Sea has never been surveyed, and despite claims and assessments by many scientists their roll remains a mystery. Certainly many scientists have many theories as to the roll played, but an independent survey has never been carried out, only talked about. In recent years, probably to protect industrial interests, the introduction of a new fish predator that eats enormous amounts of Sand eel has entered the arena. In 1994, the mackerel ate, according to the industry itself, 5% of the sand eel stock. In 2001, according to UK scientists (fishing news 5-4-01) it ate 46% of the stock, 1994 was a good year for the Sand eel, but it has been determined that the North Sea Mackerel stock, which is severely depleted, and which is a component of the Western Mackerel, and was thought to migrate back to the Western waters in December, does in reality, after new scientific  observations, migrate to the North Sea in July and August, after the sand eel season, and migrates back again in February, long before the sand eel season ever starts, and therefore the conclusion must be, that the severely  depleted North Sea Mackerel  stock, does not eat 46% of the sand eel stock.

Last but not least, the sustainability dossier fails to mention the question of Dioxin in the raw material it uses to produce fish meal. The seven key species used in the production of both meal and oil contain Dioxin, some much more than others. A single North Sea winter  sand eel has been found to have a content of 14.000 picogram (pg) dioxin in it and a single summer sand eel 6.000 pg. Herring from the Baltic 20.000 pg, a single herring from the North Sea 6.000 pg. The fish and meal industry argues that these measures are not damaging to your health, but the new EU rules state that there must not be more than 1.25 nanogram Dioxin in a kilo fish meal, and up until now only one factory in Europe can clean 60.000 tons of its total raw material of 250.000 tons. It should be remembered that the total industrial fish catch for the North Sea is between 1.3 – 1.7 million tons, and out of this raw material, 325,000 tons of meal is derived, and 90.000 tons fish oil .

David Hill

E- mail address: 3176@ vip.cybercity.dk