Download Start letter here - Shellfish Association of Great Britain

Natural Environment White Paper Team
Area 3D
Nobel House
17 Smith Square
London
SW1P 3JR
10th August 2010
Discussion document “An invitation to shape the Nature of England”
Dear Sir/Madam
I am writing on behalf of the Shellfish Association of Great Britain (SAGB). We are the
UK industry trade association based at Fishmongers’ Hall, home of the Worshipful
Company of Fishmongers; one of the 12 great livery companies of the City of London.
Our comments follow the sequence of the discussion document.
It is stated on page 5 of the document that - "A project in the South West has found that
working with farmers to reduce pollutants from their land entering rivers should return
benefits of 65 times the investment costs for water companies, and saves individual
farmers money." We have been unable to verify this from the quoted reference.
While we understand the sources from which the data is derived, we are surprised by
the paragraph on page 6:
The quality of the water in our rivers has improved measurably since 1990,
demonstrated by the return of otters, salmon and other wildlife to many rivers for the first
time since the Industrial Revolution. Between 1990 and 2008 the percentage of rivers of
good biological quality in England rose from 55 to 72%. These improvements are
attributable to the positive impact of investments by the water industry and pollution
control measures.
The reason for our surprise is that this improvement has certainly not been seen in
shellfisheries; in fact, the reverse has been recorded.
Within the European Union, Council Directive 91/492/EEC (the Shellfish Hygiene
Directive) lays down the health conditions for the production and placing on the market
of live bivalve molluscs intended for human consumption. It stipulates that shellfish may
only be harvested from areas that have been monitored and classified according to the
amount of microbiological contamination found there. The Directive also states that
indicators of faecal bacteria1, such as E. coli, should be used. In the UK the Food
Standards Agency (FSA), as the competent authority for the UK, is responsible for this
monitoring.
Shellfish harvesting areas are classified as A, B, or C or harvesting may be prohibited in
any area considered unsuitable for these activities for health reasons. To be classified
as: A class, shellfish must have less than 230 E. coli per 100g of mollusc flesh. B class
shellfish must have less than 4,600 E. coli per 100g of mollusc flesh. C class shellfish
must have less than 46,000 E. coli per 100g of mollusc flesh. More than 46,000 E. coli
per 100g of mollusc flesh results in a prohibition.
Since 2002/03 (earliest figures available) we have seen a decrease in Class A beds to
less than 1% of all English & Welsh shellfish beds. The number of Class C beds has
risen from 41 to 51 and the number of prohibited beds from 6 to 10. Figure 1 shows the
UK shellfish bed classifications from 2002 to 2010 and figure 2 shows the same figure
with Class B beds – purely to stretch the y-axis.
Figure 1
Shellfish Bed Classifications 2002-10
350
Number of Beds
300
250
Class A
200
Class B
150
Class C
Prohibited
100
50
0
2002/03
2003/04
2004/05
2005/06
2006/07
2007/08
2008/09
2009/10
Year
1
The presence of faecal bacteria in aquatic environments may indicate that the water has been
contaminated with the faecal material of humans or other animals. Faecal bacteria can enter rivers through
direct discharge of waste from mammals and birds, from agricultural and storm runoff, and from human
sewage.
Figure 2
Shellfish Bed Classifications 2002-10
70
Number of Beds
60
50
Class A
40
Class C
30
Prohibited
20
10
0
2002/03
2003/04
2004/05
2005/06
2006/07
2007/08
2008/09
2009/10
Year
Whilst England & Wales has an unbelievably low proportion of Class A shellfish beds
many other European states support drastically higher proportions (Table 1). Maybe we
need to re-think the view that “The quality of the water in our rivers has improved
measurably since 1990…….These improvements are attributable to the positive impact
of investments by the water industry and pollution control measures”.
Table 1: European Shellfish Hygiene Classified Comparison
Member State
England & Wales
Spain
Holland
Denmark
Ireland
Class A waters
0.55%
33.6%
100%
62.6%
38%
Class B waters
81%
55.4%
37.4%
62%
Question 2 - “Have we identified the right overarching challenges for the White Paper to
consider?”
Of the three challenges, we believe that climate change is the primary issue that needs
consideration and we urge greater focus on the potential impacts on shellfish and
shellfisheries. Climate change factors can affect shellfish in many ways, for example
growth, reproduction, distribution and health and ultimately our ability to capture and
cultivate.
The headlines often focus on ocean acidification (and reductions in pH can lead to
increased physiological stress, reduced growth and survival of early life stages, reduced
ability to calcify and changes in energy budgets in crustaceans). However, consideration
is also needed for:
(1) the impacts of increased water temperature which can cause (i) changes in
phytoplankton species composition, (ii) eutrophication (algal blooms), (iii) illnesses &
pathogens (both human & stock impact), (iv) shift of species distributions, (v)
changes in pests & predators and (vi) increased mortalities;
(2) raised sea level which (i) alters optimal growing areas, (ii) may shift optimal growing
areas off the farmer’s property, (iii) may alter patterns of predation and exposure, (iv)
may require modification or replacement of shore-based facilities and (v) can alter
timing and access to shellfish grounds;
(3) altered water currents & circulation affecting (i) movement of toxic algae blooms into
coastal and inshore waters, (ii) changes in nutrient levels and distribution in coastal
estuaries, (iii) modification of larval and juvenile shellfish transport and (iv) potential
for expanded distribution of invasive species;
(4) increased freshwater run-off causing (i) reduced salinity of surface waters, with
possible mortalities during extreme events, (ii) increased stratification, especially in
circulation-limited waters, (iii) changes in phytoplankton types or distribution and (iv)
increased shellfish closures with water quality restrictions tied to rainfall events.
Rather than clamour for a cessation of emissions we believe an achievable solution
should focus on shellfish in the context of the ecosystem as a whole. We need to
prioritise the ‘healthiest’ areas and current regulations need to be ‘future proofed’ in light
of potential impacts posed by climate change. It would be worth following the lead of the
Interreg SUSFISH project (between Aberystwyth, Bangor and Swansea Universities in
Wales and Cork University in Ireland) which is looking at identification of adaptation and
mitigation measures to the impacts of climate change and the production of
corresponding guidelines for the future fisheries management in the Irish Sea.
The paragraph headed ‘Demographic changes’ seems to focus on food security, and
while we agree this is extremely important the section fails to address first, the prospect
of an increasingly unhealthy population and secondly the increased demand for waste
disposal. With regards the former, we consider shellfish cultivation to be considerable
opportunity for providing high-levels of protein at minimal environmental footprint. The
latter demands the ‘future proofing’ of all plans.
Unfortunately, previous Government strategy seems to overlook the shellfish sector: The
Cabinet Office report “Food Matters – Towards a Strategy for the 21st Century” focuses
only on wild-capture fin-fish, contains little on wild-capture shellfish and mentions
aquaculture not once. Defra’s discussion paper “Ensuring the UK’s Food Securing in a
Changing World” barely touches on seafood except for para 4.50 “The greatest threat to
the longer-term sustainability of fish stocks, remains excessive fishing……The intention
is that by 2015, all EU fisheries are managed on the basis of Maximum Sustainable
Yield i.e. they are fished at a level which balances the scale of exploitation with the need
to retain strong stocks.” Again no mention of shellfish cultivation. The EFRA Committee
report “Securing Food Supplies up to 2050: The Challenges Faced by the UK”
recommends that “the fishing industry and the Government have a duty to encourage
consumers to try sustainable, less well-known types of fish and shellfish”; again failing to
recommend increased shellfish cultivation. The Government response to this report
finally mentions aquaculture, though unfortunately focuses on fin-fish: “Defra
recognises…that current conversion rates are unfavourable for the most commonly
produced fish from aquaculture and that some environmental concerns remain.”
We urge the UK Government to commission a study evaluating the potential of greatly
enhanced sustainable shellfish aquaculture off the shores of the UK.
With regards our second point; cardiovascular disease is the leading cause of death in
the UK and accounts for nearly 200,000 deaths per year1. It is also a leading cause of
premature death accounting for over 53,000 premature deaths annually2.
A high intake of saturated fat can raise blood total and low density lipoprotein (LDL)
cholesterol levels and this in turn can lead to an increased risk of developing heart
disease3 4. Accordingly, it follows that reducing the intake of saturated fat should lower
levels of blood total and LDL cholesterol levels and that this in turn should lead to a
reduced risk of developing heart disease.
The UK public health recommendation for saturated fat is that population average
intakes should not exceed 11% of food energy2. This recommendation was reflected by
the World Health Organization in 20033. Current intakes exceed this recommendation by
20% (at 13.3% of food energy5).
It has been estimated that reducing saturated fat intakes to within recommended levels
could result in approximately 3500 UK deaths averted annually and should improve the
quality of life of many more people56.
Obesity is an important risk factor for a number of illnesses including CVD, some
cancers and type II diabetes. It has more than doubled in the last 25 years in the UK7.
In England alone, nearly a quarter of men and women and about 10% of children are
now obese, with a further 20-25% of children overweight6. In Scotland, over 25% of men
and women were classed as obese with over a third of Scottish school children outside
2
www.heartstats.org
Department of Health (1994), Nutritional Aspects of Cardiovascular Disease. Report on Health and Social
Subjects 46. London: The Stationery Office.
4 World Health Organization (2003), Diet, nutrition and the prevention of chronic disease. Report of a joint
WHO/FAO Expert Consultation. Geneva.
5 Henderson, L et al. (2003), The National Diet & Nutrition Survey: adults aged 19 to 64 years. Volume 2:
Energy, protein, carbohydrate, fat and alcohol intake. London: HMSO.
6 www.ofcom.org.uk/consult/condocs/foodads_new/ia.pdf
7 Government Office for Science (2007), Foresight: Tackling Obesities: Future Choices. Department of
Innovation Universities and Skills.
3
the healthy weight range8. In Wales, 57% of adults are overweight or obese, 21%
classified as obese, and 33% of children are overweight or obese9.
The Government’s Foresight programme suggested that without intervention
approximately 60% of Britons will be obese by 20506. Obese and overweight individuals
place a significant burden on the NHS. By 2050, the NHS cost of overweight and obesity
could rise to £6.5 billion per year, with the wider cost to society being £49.9 billion6.
It is widely recognised that a seafood-rich diet can address many of these concerns; the
American Institute of Medicine of the National Academies (in their independent study
titled “Seafood Choices: Balancing Benefits and Risks” funded by The National Oceanic
and Atmospheric Administration, with support from the Food and Drug Administration)
found that seafood is rich in nutrients, low in saturated fats, and should be incorporated
more into the American diet to reduce the risk of early death by heart disease – the
primary cause of death in this country. These findings affirm dietary guidelines
established by the U.S. Department of Agriculture. Sadly the UK Food Standards
Agency (FSA) currently advises that we should eat at least two portions of fish a week,
one of which should be oily. The joint report by the Scientific Advisory Committee on
Nutrition and Committee on Toxicity from which this advice was developed did not
consider shellfish and hence the FSA advice is limited to finfish. Despite this the FSA
website does notes: “Shellfish contain similar nutrients to white fish and similar amounts
of omega 3, though some types of shellfish contain more omega 3 than others. For
example, crab and mussels are quite good sources of omega 3, but prawns contain
hardly any…...Shellfish are good sources of selenium, zinc, iodine and copper.”
Question 3 – What are the existing policies and practices aimed at protecting England’s
natural assets (including but not limited to those set out above on our biodiversity, seas,
water bodies, air and soil) that currently work most effectively?
Policies that are developed at local levels, e.g. Sea Fisheries Committees bylaws.
a. What works less well – what could we stop doing or do differently?
The monitoring of pollution in the sea and estuaries. Development of early warning
systems is essential.
Question 4 – What mechanisms should we focus on to ensure we manage our natural
systems more effectively in future?
Use of local knowledge.
a. How should we define success?
Healthy seas with sustainable production with socio-economic sustainability
b. How can we agree on common goals and assess our progress towards them?
We need to move away from “proving no harm” and agree ‘acceptable footprints’.
Everything has an impact.
8
Bromley C, Bradshaw P, Given L (Eds) (2008), The Scottish Health Survey 2008. Welsh Health Survey
(2008). www.wales.gov.uk/docs/statistics/2009/090929hlthsurvey08en.pdf
9 Welsh Health Survey (2008). www.wales.gov.uk/docs/statistics/2009/090929hlthsurvey08en.pdf
Question 5 – How best can we reduce our footprint on the natural environment abroad,
through the goods, services and products we use?
Reduction of imports, and greater reliance on local produce and central support for
promotion of said products.
Question 6 – What best practice and innovative approaches to protecting and enhancing
our natural environment do you think should be considered as we develop the White
Paper?
The development of an approach which says "how" rather than "no".
Question 7 – How best can we harness and build on public enthusiasm for the natural
environment so people can help improve it through local action, as informed consumers
or by shaping policy?
Stop focussing on the vocal minorities and listening to those who don’t have time to or
no knowledge of how to engage with decision making.
Question 8 – What should be our vision for the role of Civil Society in managing and
enhancing the natural environment and for engaging individuals, businesses and
communities in setting the agenda for that work?
Demonstrating that the role of Government and its quangos is to listen and react rather
than to dictate and direct.
Question 9 – How best can Government incentivise innovative and effective action on
the natural environment, across England, at the local level?
Developing the response to questions 7 and 8.
Question 10 – How best could the economy reflect the true value of nature’s services in
the way business is done, to drive smarter, greener growth?
Less emphasis on cash calculations and more emphasis on actual outcomes.
Question 11 – Responsible businesses are already looking for ways to reduce their
impact on the environment. How can we encourage more action like this?
Provision of relevant information. Currently too many sources of conflicting and
contradictory information. Example in seafood is the Marine Stewardship Council
ecolabel. Many eNGOs say this is the “gold” standard” others disagree. Very difficult for
a consumer to know who to believe. Government needs to back third-party organisations
in each area and direct people to them.
Question 12 – What are the barriers to joining up and seeking multiple benefits from our
natural assets?
Frankly, organisations like Natural England or seem to be fixated on zero impact. See
MPAs in the marine environment.
Question 14 – What should be the priorities for the UK’s role in EU and international
action, to protect and enhance the natural environment at home and abroad?
We suggest you focus on getting it right in the UK first.
Question 15 – If you could choose just one priority action for the Natural Environment
White Paper to drive forward locally, nationally or internationally – what would it be?
Improving coastal water quality.
Please do not hesitate to contact me if I can provide any further information.
Yours sincerely
Dr Tom Pickerell
Director
Mob:
:
07507 339156
[email protected]