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 labor
atories 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
