Download Do you agree with the seven priority issues for food quality in Wales?

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Cadeirydd / Chair : Geraint Hopkins
Cyfarwyddwraig / Director : Susan Evans
www.waleslink.org
The Welsh Food Debate: Quality of Food consultation response
–Wales Environment Link’s Marine Working Group
Wales Environment Link (WEL) is a network for voluntary environmental and countryside
organisations in Wales, most of whom have an all-Wales remit. WEL is officially designated the
Intermediary Body between the government and the voluntary environmental sector in Wales.
Our vision is to increase the effectiveness of the environmental sector in its ability to protect
and improve the environment through facilitating and articulating the voice of the sector. This
paper represents the collective views of the members of WEL’s Marine Working Group
(MWG), but does not necessarily reflect the policy positions of each individual member
organisation.
WEL is pleased to be given this opportunity to respond to the Welsh Assembly Government’s
consultation document on the Quality of Food Strategy: Task and Finish Group Report. Many
of WEL’s members will be responding individually to this consultation, our joint response
therefore focuses on key issues of collective concern.
Question 2: Do you agree with the seven priority issues for food quality in Wales?
Health
The consultation document notes that diet, throughout life, has an important role to play in the
prevention of risk factors such as obesity and chronic diseases such as coronary heart disease
and diabetes as well as other diseases such as cancers. There is good evidence that eating
oily fish such as mackerel, herring (which contain Omega-3) and shellfish reduces the risk of
death from heart disease and other physical and mental illnesses, however this is not
recognised in the Quality of Food Strategy. Consumers generally perceive fish as being a
healthy option and wild caught fish are also regarded as a ‘natural’ product. The draft Wales
Fisheries Strategy notes that the future growth in sales of fish and shellfish products in Wales
will be partially driven by public health issues as the potential benefits of increased seafood
consumption become clearer.
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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Safety
The consultation document notes that microbiological and chemical contaminants, and
naturally occurring allergens can all affect the safety of food and feed. Although most people
would benefit from eating more oily fish, recent studies have shown that oily fish can contain
low levels of pollutants such as dioxins and polychlorinated biphenyls (PCBs) that can
bioaccumulate over time and prove harmful to human health. For this reason, the Food
Standards Agency has recently issued new advice on eating oily fish, recommending for the
first time maximum levels at which the health benefits clearly outweigh the possible risks from
these contaminants.
There is also a safety issue around the storage and preparation of some seafood products,
particularly shellfish. Raw shellfish or shellfish that have not been cooked properly can contain
harmful viruses and bacteria. Most problems can be mitigated by ensuring that shellfish are
cooked properly. Consumers are increasingly aware that there are risks associated with the
food that they eat and need to be reassured that the shellfish they purchase has been treated
or monitored in such a way as to safeguard their health. Legislation and initiatives concerning
the labelling of farmed and fished products provide the customer with more information and
enable them to make more informed choices about their purchases.
Environment
The consultation document recognises that the food system has significant environmental
impacts. However, reference is made only to the agri- (farmed) food sector with no mention
made of the environmental problems associated with the Welsh capture fisheries and
aquaculture sectors.
Welsh seas have the potential to provide a rich source of food, provide a livelihood for
fishermen and their dependant communities and should support rich and diverse wildlife.
However, without proper management, human activities could place all of these at risk. The
draft Wales Fisheries Strategy recognises that the effective absence of any specific fishery
management plans in the past has sometimes led to ‘boom and bust’ situations, with a lack of
adequate control measures resulting in overfishing of many stocks. The lack of an holistic
sustainable management strategy for the Welsh industry has prevented stakeholders from
being able to make long-term investment and business decisions and has encouraged a free
for all approach, undermining the need for sustainability. The recently launched consultation on
the Wales Fisheries Strategy represents a positive step towards securing a more sustainable
future for the industry and the wider marine environment.
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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However, further attention needs to be given to aspects such as bycatch and the impacts of
fishing activities upon marine habitats and species. An ecosystem-based approach to fisheries
management is called for, which integrates fisheries management and marine conservation
policy and addresses the marine ecosystem as a whole rather than as separate, individual
parts. At present, most fisheries are managed on the basis of the size and distribution of
stocks of individual fish species. It has long been recognised that this approach does not
adequately take account of the interactions between fish species or take full account of
fisheries bycatch. The ecosystem approach to management enables multi-species
management. Such an approach also enables the environmental impact of fishing and
subsequent knock-on effects in the biological community to be taken into account.
Fair trade
Fishermen and those concerned about the environment share a common long-term vision of
healthy seas and abundant fish stocks. We support initiatives involving partners in the fishing
industry to find new, innovative forms of management that conserve fish stocks, do not harm
other marine species, protect the structure and function of marine ecosystems, and support
sustainable fisheries and the fishermen that depend on them.
Some buyers have shown a preference for Marine Stewardship Council (MSC) labelled
seafood and several fisheries have found new markets for their products. For retailers, the
MSC ecolabel provides an effective mechanism to meet the expectations of environmentally
aware customers, and an opportunity to demonstrate corporate responsibility.
Economic viability
The draft Wales Fisheries Strategy recognises that there is considerable scope for
improvement in the economic strength of inshore capture fisheries, primarily through initiatives
aimed at countering the highly fragmented nature of the sector and providing added value
processing infrastructure and the achievement of improved industry logistics. Currently Wales
is disadvantaged in that it does not have a recognisable internal market structure – the
absence of a Welsh auction or other markets mean that fishermen have to transport their
catches to English markets in many cases. Processing and other added value infrastructure is
also weak in Wales, further restricting the ability of fishermen to obtain the best returns for their
catches. Overcoming these impediments would seem to be a priority for the future
development of the sector.
A further consideration with respect to the economic viability of the sector is improved
marketing and promotion of Welsh seafood, which is a key component in the development of a
profitable industry. The Welsh Fisheries and Aquaculture Sector Strategic Action Plan
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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acknowledges that, at the volumes produced in Wales, there is no sub-sector in which the
Welsh product can dominate or significantly affect market price formation. In marketing the
Welsh fisheries sector, therefore, the emphasis should be upon quality rather than quantity –
not only in freshness and in taste but in overall trading practice. The ultimate goal is to achieve
quality management and certification throughout the supply chain – from harvesting through to
point of sale.
The Marine Stewardship Council’s (MSC) certification scheme is an example of such best
practice. The MSC promotes equal access to its certification programme irrespective of the
size, scale, type location or intensity of the fishery. Currently the Burry Inlet cockle fishery is
the only MSC accredited fishery in Wales, although there is significant potential for other
fisheries to undergo the assessment process. For fisheries, certification helps product
differentiation in competitive markets. Once certified, companies wishing to use the MSC
products undergo a Chain of Custody certification that guarantees traceability of MSC-labelled
seafood, ensuring that it has been separated from non-certified product at every stage of the
production from the boat to the plate. Those companies then gain the right to use the MSC
logo on their products.
Accessibility and affordability
Changing shopping patterns have seen the closure of many high street fishmongers, as
supermarkets have established in-store fresh fish counters, and presented the consumer with
an increasing range of convenience pre-packed fresh and frozen processed fish. Retailers can
play a decisive role in leading fisheries on to a sustainable path since their purchasing power
gives them a strong voice within the industry. Consumers are becoming increasingly aware of
sustainability issues in relation to fisheries and their purchasing patterns reflect their concerns
over unsustainable fishing practices and high discard rates in some fisheries. The Marine
Conservation Society Good Fish Guide and fishonline.org website have demonstrated that the
public desire to be better informed when making their choice of which fish to buy, with over
200,000 hits on fishonline a month and more than 350,000 pocket good fish guides distributed
since 2004. For instance, a survey by Marks and Spencer placed overfishing at the top of a
list of customer concerns about food and the environment, above even pesticide residues in
food. As a result, retailers are implementing sourcing policies that highlight environmental
considerations and favour seafood sources that are certified against the Marine Stewardship
Council’s environmental standard and also the Marine Conservation Society species ratings (in
particular for those stocks not yet assessed by the MSC), which are then reflected in the MCS
supermarket league table. Buyers and consumers are demanding these products and are
prepared to pay a relative premium for products supported by quality assurances and
guarantees.
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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Furthermore, instead of continuously increasing prices and offering no alternative to nonsustainable cod and haddock, diversification of effort could lead to the development of new
sustainable fisheries provided the appropriate economic and environmental safeguards are put
in place. Encouraging consumers to diversify their taste could help to produce a market for
previously unmarketable, less exploited fish. This could reduce pressure on traditionally fished
species and provide the consumer with a greater choice of product at the fish counter. This is
an area where more focused marketing effort is likely to yield improvement.
Culture
In addition to the important role that food plays in sustaining lifestyles and culture, it is
accepted that many of the traditional methods employed in marine capture fisheries around the
Welsh coast also have a strong cultural or heritage value. Some of these methods are now
unique to Wales and are an important part of our historical and cultural heritage. In addition,
the public have, for generations, exercised the right to collect certain shellfish in small
quantities, sufficient for personal consumption. In order to prevent abuse of this right, byelaws
exist which restrict the maximum amount that each person may take.
Question 3: Do you agree with the challenges and gaps identified?
The significant omission in this section is any reference to the current consultation on the
Wales Fisheries Strategy. The consultation represents the work undertaken by the Welsh
Assembly Government, its partners and fisheries stakeholders to develop a strategy on the
future of fisheries in Wales. It sets out the Assembly Government’s long term strategy for the
management and development of fisheries in Wales across all sectors of aquaculture,
commercial fisheries and recreational fisheries for the next 15-20 years and therefore has
significant implications for the development of a Quality of Food Strategy that purports to
support the fisheries sector. The vision of the Wales Fisheries Strategy is to: “Support the
development of viable and sustainable fisheries in Wales as an integral part of coherent
policies for safeguarding the environment”. A number of goals underpin this vision, all of which
are relevant to the Quality of Food Strategy:
 Healthy fish stocks – development and management of fisheries at sustainable levels as a
part of healthy and productive ecosystems.
 Positive community role – recognition of fisheries as a positive contribution to the
communities of Wales.
 Environment – Fisheries developed and managed in a sustainable way contributing
positively to environmental policies of Wales.
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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 Partnership working – To further the partnership working already established between policy
makers, stakeholders, and delivery agents for fisheries and establish this joint role as
custodians for the future.
 Economic contribution – Maximising the economic importance and contribution of fisheries
to the development of the ‘Wales’ brand on a Wales / UK / EU / International level.
Greater synergy between the Wales Fisheries Strategy and the Quality of Food Strategy would
be welcome. In particular, we would welcome details on how the following challenges and
gaps will be addressed:
 Ensure that fish and shellfish stocks and the marine environment are managed to ensure
their long-term sustainability through greater emphasis upon the conservation of ecosystems
rather than just of commercially important stocks of fish.
 How to ensure that fishing / aquaculture practices in the Welsh context are sustainable /
promotion and encouragement of sustainable practices throughout the food chain.
 Improved knowledge on the levels of fishing effort and the status of fish stocks around the
coast of Wales.
 Focusing on the enhancement of product quality through provision of increased quality
assurance / ecolabelling ( e.g. MSC accreditation) and added value services attaching to the
product.
 Exploitation of market opportunities to the best advantage of the Welsh fishery sector and
promotion of Welsh produced and / or landed fish and seafood in the marketplace.
WEL will be responding in detail to the Wales Fisheries Strategy in due course.
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
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How WEL has come to agree this response
The production of consultation responses within the WEL network is an inclusive and
comprehensive process. Whilst WEL recognises that all consultation responses must be given
equal treatment, we would ask the Committee to note WEL’s protocol for writing consultation
responses, as well as the number of organisations that have signed up to this response:
1. WEL’s Marine Working Group members were asked to contribute their experiences and
opinions in response to the questions in the consultation letter.
2. Co-ordinator used contributions to determine common positions.
3. Coordinator circulated first draft around WEL Marine Working Group members via email,
giving members the opportunity to amend the text.
4. Any point over which there was disagreement was further discussed via email.
5. A final draft was sent around inviting sign-up.
The member organisations of Wales Environment Link’s Marine Working Group are:
Marine Conservation Society
National Trust Wales
RSPB Cymru
Wildlife Trusts Wales
WWF Cymru
For further information please contact:
Michele Aitchison
Advocacy Officer for Wales Environment Link
Baltic House
Mount Stuart Square
Cardiff
CF10 5FH
Telephone: 02920 431 716
E-mail: [email protected]
Wales Environment Link unites voluntary bodies whose primary aims include the conservation, protection or quiet enjoyment of landscape, wildlife or amenity in Wales
Mae Cyswllt Amgylchedd Cymru yn uno cyrff gwirfoddol sydd â’u hamcanion pennaf yn cynnwys cadwraeth, gwarchodaeth neu fwynhad tawel o dirlun, bywyd gwyllt ac amwynder yng Nghymru
Reg. Charity No: 1022675
Rhif Elusen Gofrestredig: 1022675