• Why not take a moment to introduce yourself to our members?

naesco

Advanced Reefer
Rating - 0%
0   0   0
Mine was a suggestion. Do you have one.
It seems to me that if the annual cost of CDT is say $50,000 per year it is quite simply to calculate the number of planned random tests.
At 15.00 per test you would have over 3000 tests each year or roughly 60 a week.
There are at least 5 exporters (who are selling in US dollars) which means it would cost them each $10,000 per year. Peanuts!
 

MaryHM

Advanced Reefer
Rating - 0%
0   0   0
$10000 a year is peanuts?? I am an importer, but if I had to pay $10000 a year for testing I would go under.
 

naesco

Advanced Reefer
Rating - 0%
0   0   0
No not you or anyone stateside. You are importers and wholesalers.

I am referring to the major Phillippine exporters who are members of the Association in Manila.
 

kylen

Experienced Reefer
Rating - 0%
0   0   0
Here's another...how about a $1 surcharge per box at export level? In a previous thread the number of boxes being exported from the PI was quoted at 100,000 per year. Just a thought.
 

PeterIMA

Advanced Reefer
Rating - 0%
0   0   0
Subject: Sampling and CDT.

It is encouraging that the MAC is willing to reform its Certification program to include cyanide testing. I hope they clarify what cyanide test procedure they consider reliable soon.

It also is encouraging that the Philippine Tropical Fish
Exporters Association (PFTEA) is willing to "allow" random sampling in their facilities. The sampling previously conducted by Marine Inspection Sampling (MIS) officers working for IMA (deputized as fish wardens by BFAR) was conducted randomly. So, resuming random sampling can be done. Personally, I would prefer that the Philippines Bureau of Fisheries and Aquatic Resources (BFAR) take on this responsability. Sampling and testing must be tied to law enforcement. It is the responsability of BFAR and other law enforcement agencies to conduct sampling that will support enforcement of laws against use of cyanide by collectors and export companies (many of which support the distribution and sale of cyanide and export cyanide-caught fish).

At present BFAR has all of the CDT equipment and nominally 3 out of the original 6 CDT laboratories still exist. A fourth laboratory exists at BFAR headquarters in Quezon City (the Manila lab run by IMA near the airport closed). Some of this equipment belongs to IMA, and BFAR still has not paid IMA the money owed for the equipment and for the work performed under the last BFAR/IMA contract (about $100,000). It costs about $5000 for the CDT equipment needed for each laboratory.

While I am not sure why BFAR was not able to perform more cyanide testing, I suspect that the problem is financial. I suspect that the money from the Philippine Treasury earmarked for CDT did not make it to the Department of Agriculture over BFAR. The problem is more complex since BFAR headquarters does not control what provincial BFAR officials do. There are 3 CDT labs being run by various provincial officials of BFAR (CDT labs situated in cities of Zamboanga, Puerto Princesa, and Cebu). Only the Manila laboratory is under national BFAR control. At the time the IMA relinquished running the labs, Malcolm Sarmiento (Head of BFAR) asked the Provincial BFAR chiefs to find funding to run the labs situated in their provinces.

It should be noted that the Philippine Government has a responsability to see that CDT analyses are conducted as part of the approximately $98 million US dollar loan for the Fisheries Resources Management Program (FRMP) provided by the Asian Development Bank (ADB). Default on the testing and the ADB can revoke its loan to the Philippine Government.

One wrinkle here is that the agreement between the ADB and the Philippines Government stipulated that about 5 million $USD be dedicated for CDT equipment. The problem that IMA encountered was that there was no money in the FRMP loan earmarked for staff salaries to run the CDT laboratories. I suspect that BFAR thought they could take control of the laboratories, and get FRMP money for either CDT or other purposes. Apparently, they failed in this. So, even BFAR does not have sufficient funds to run the CDT laboratories. Now they charge exporters about 15 $USD for each test when an exporter sends fish to the Manila CDT lab for testing (previous testing done by IMA was free). At least that is my understanding of what has occurred.

While, the MAC can (and should) endorse CDT testing procedures, I don't feel they should conduct testing. Likewise (as previously stated) I don't feel that BFAR should do it. BFAR may not presently have the desire to continue to do so; now that they know there are insufficient funds.

The IMA is interested in conducting cyanide testing but also would need funding. The IMA could run a Manila laboratory for about 50,000 $USD per year. The Manila laboratory performed more tests on aquarium fish than the other labs. So, it is the most essential.

Two possibilities exist: (maybe more?)

a) Someone convinces the ADB to revise its loan to allow for use of some of the funds earmarked for CDT to be used for laboratory staff salaries. So far, even Sarmiento has failed at this. However, this would be the best solution. If the MAC and the exporters got behind this option, it may be possible to amend the FRMP agreement between ADB and the Philippines Government.

b) Someone suggested that a fee be charged for each box of marine aquarium fish exported. BFAR presently charges a fee of about about $15 to issue an export permit each time an exporter makes a shipment. I am not sure whether the fee applies to each box or multiple boxes (e.g. same fee for 20 boxes as for one box). In any event, it might be possible for BFAR to raise the export permit fee and charge $1.00 per box of fish exported. These export fees could then be used to run CDT laboratories.

BFAR shouuld only issue export permits to export companies that demonstrate that their fish are cyanide-free (from the laboratory testing). These would be fish coming from net-caught suppliers. This would put pressure on the exporters to stop buying cyanide-caught fish.

If the members of the PFTEA and other non-member companies would pay an economic incentive for net-caught fish (10% more) the number of collectors using nets would rapidly increase. My understanding is that many collectors know how to use nets, but don't do so because it is more work and there is no economic advantage (over collecting fish with cyanide). With proper economic incentives there would be more net-collectors and Collectors Associations willing to become MAC Certified. Otherwise, many net-collectors probably will not participate in the MAC Certification Program.

While I have differences with the MAC and the way it has been run, I would like to see these problems resolved and MAC Certification implemented. So far, the announcements by the MAC to date are insufficient to make me believe that the problems concerning the CDT and the net-collectors have been solved. There is an urgent need to find solutions. I hope that Mike King and John Brandt will be able to shed some light on what is happening and possibly find some solutions.

Sincerely,
Peter Rubec
 

kylen

Experienced Reefer
Rating - 0%
0   0   0
Would the $50k annual cost of operating the lab be dependant on the number of tests performed or would the tests themselves be a nominal cost? I would imagine that much of the operating cost would be physical space, staff, and supplies.

I completely agree that the CDT should be directly linked to export permits. Mary (I believe) suggested progressive penalties for every positive test. This too is a must. There has to be some teeth in the enforcement side to dissuade exporters from purchasing cyanide caught fish.

I wouldn't even blink at an additional $1 per box charge. If this would ensure that my product is net caught and tested as such, then it is a very small price to pay. Hopefully this can all proceed quickly, but more importantly effectively. Or is this just pie in the sky...I hope not.
 

PeterIMA

Advanced Reefer
Rating - 0%
0   0   0
Kylen,
Yes, the $50,000 cost of operating a CDT lab includes lab staff salaries, rent for the space, electricity, phone/fax, lab equipment, chemicals, and other expendables. It did not include the cost of sampling and the samplers' salaries. If IMA was running the lab there would not be any fees for testing.

IMA previously represented BFAR (under contract). If BFAR helped to fund the CDT (either from FRMP or from export fees) the laboratory would have a sign on the door stating BFAR laboratory. This was the case previously. Otherwise, the laboratory designation might state MAC/IMA.

If BFAR charged more for their export fees to help fund CDT laboratories exporters certainly would be justified in passing on these additional costs to importers. I agree that if the fish are MAC Certified as being "Net-Caught and Cyanide-Free" the additional cost is well worth it. Under the arrangement I suggested, there would be (for a time at least) fish from other exporters which were not MAC Certified. These exporters also would pay the export fees.

Implementation of what I have suggested would probably require BFAR passing a Fisheries Administrative Order (FAO). BFAR had planned to pass an FAO to link export permits to CDT when IMA was running the laboratories. The original idea was similar to the US three strikes legislation.

First, fish would be sampled monthly from each exporter's facility. I have suggested to the MAC that sampling be random at the Family level. Hence if there were 15 fish families present either at the export facility or at field holding sites, there would be 15 fish sampled for CDT. There might be 20 species of damselfish in a facility and only one damselfish sampled. Likewise, if there were 8 angelfish species only one angelfish would be sampled. There would need to be a method applied for randomly sampling the angelfish species (possibly with size grades also randomized).

2. The CDT testing would be for Presence/Absence of cyanide. Any fish with cyanide present (above the lower level of detection) would be scored as Cyanide Present. With the existing APHA/ASTM test for cyanide ion the daily calibration was linear on a log-normal plot from 0.03 to 10.0 mg/litre (ppm by volume). Hence, any Ion Selective Electrode (ISE) reading equal to or above 0.03 mg/L would be considered Cyanide Present. Cyanide detected below this level would be scored Below Detectable Limits (BDL) or Zero (if no cyanide was detected). BDL and Zero could be considered as Cyanide Absent. I suggested to the MAC (in an email) that the testing should meet some percentage (say 60%) of the fish with Cyanide Absent each month. The laboratory would issue a Clearance form to BFAR to allow exporters who passed the CDT (at least 60% of fish tested Cyanide Absent) to obtain Export Permits from BFAR during the following month.

3. The three strikes rule could be applied in the following manner. An exporter would be given a warning that his facility failed to Pass the 60% Cyanide Absent criterion for the previous month. After two such warnings, the third violation could lead to either BFAR revoking the company's export permit or to prosecution of the exporter for violation of the Fisheries Act against sale and distribution of fish caught by illegal means (cyanide).

4. A similar 3 strikes criterion could be applied with fish collectors and/or Collectors Associations (collection locations). This might be more fair than the present situation where potentially a collector could be tried and convicted if even one fish was found to have cyanide present. However, collectors prosecuted usually have also been found with cyanide in their possession.

5. I must also note there is an urgent need for CDT laboratories to enforce Philippine laws against collectors and exporters of live food fish (groupers) exported to Hong Kong, mainland China, and Taiwan. Similar approaches should also be applied to this trade concerning CDT and enforcement.

Sincerely,
Peter Rubec
 

Jaime Baquero

Advanced Reefer
Rating - 0%
0   0   0
Peter,

Seems that the passing of the Fisheries Administration Order by the Filipino government is vital for the CDT to have a real impact.

I do remember that we have been talking about the implementation of this FAO for almost 10 years.

What do you think need to be done to force the filipino government to implement the FAO?

I guess MAC is working on this. Without FAO things are going to be difficult.

jaime
 

PeterIMA

Advanced Reefer
Rating - 0%
0   0   0
Jaime, There are tough laws against the use of cyanide in the Philippines. However, IMA found that the court system did not fully support prosecutions. With the FAO, BFAR can pass it and enforce it. So, even without prosecutions (through the courts) it would be possible to link CDT to export permits, implement the 3 stikes rule with exporters, and if necessary to revoke exporters' licences. Exporters might not like the 3 strikes rule; but they should consider whether or not they would prefer being in prison.

It remains to be seen whether BFAR has the will to enforce laws against cyanide. It also remains to be seen what MAC intends to do with regard to cyanide testing.

For my part, I am not willing to wait too long. The MAC and BFAR need to act on these matters soon.

Peter Rubec
 

My Hairy Ass

Experienced Reefer
Rating - 0%
0   0   0
For my part, I am not willing to wait too long. The MAC and BFAR need to act on these matters soon.
And what, exactly, are YOU, Peterex-IMA going to do, if you are not willing to wait too long? Go in unilaterally and enforce the legislation yourself?! I think you are watching a little too much news and it is rubbing off on you!
 

PeterIMA

Advanced Reefer
Rating - 0%
0   0   0
Hairy Ass, Still hiding behing your tail?

The difference is I am doing something and have been since 1983. The trade has done next to nothing to deal with these problems. Rest assured something is being done. Wait and see.

Peter Rubec
 

MaryHM

Advanced Reefer
Rating - 0%
0   0   0
MHA- Stop it with the little name jabs. I'm serious. I am so sick of this from you all that I could scream. If you can't post without jabbing someone else then GO SOMEWHERE ELSE.
 
A

Anonymous

Guest
Rating - 0%
0   0   0
MaryHM":3djxmior said:
MHA- Stop it with the little name jabs. I'm serious. I am so sick of this from you all that I could scream. If you can't post without jabbing someone else then GO SOMEWHERE ELSE.

Awww...Mary, I don't post that much, but all my posts are well thought-out and are not mean-spirited toward anyone.

Please don't say 'you all' because it makes me sad...

:(

Peace,

Chip

P.S. Yes, I know you didn't mean me, but I wanted to rib you a little bit about it... :D
 

dizzy

Advanced Reefer
Rating - 0%
0   0   0
marillion":370w4y3i said:
Awww...Mary, I don't post that much, but all my posts are well thought-out and are not mean-spirited toward anyone. Chip
:D

Dude,
You made like over 800 posts in less than two years.
 
A

Anonymous

Guest
Rating - 0%
0   0   0
dizzy":3bqkzjfs said:
marillion":3bqkzjfs said:
Awww...Mary, I don't post that much, but all my posts are well thought-out and are not mean-spirited toward anyone. Chip
:D

Dude,
You made like over 800 posts in less than two years.

:lol:
 
A

Anonymous

Guest
Rating - 0%
0   0   0
vitz":3ovc0de3 said:
dizzy":3ovc0de3 said:
marillion":3ovc0de3 said:
Awww...Mary, I don't post that much, but all my posts are well thought-out and are not mean-spirited toward anyone. Chip
:D

Dude,
You made like over 800 posts in less than two years.

:lol:

Big deal, vitz thinks through all his posts. :roll:
 
A

Anonymous

Guest
Rating - 0%
0   0   0
dizzy":3j1hajoe said:
Dude,
You made like over 800 posts in less than two years.

I was referring to posts within the Industry Forum itself, and not the entire Reefs.Org site. Sorry for the confusion. :)

Peace,

Chip
 

Sponsor Reefs

We're a FREE website, and we exist because of hobbyists like YOU who help us run this community.

Click here to sponsor $10:


Top