Comments about CDT and MAQTRAC.
1) The CDT test done previously by IMA for BFAR (and now by BFAR) involving ISE was (and still is) an accurate reliable test procedure. I explained to Horge that a level of 0.2 ppm was set for prosecution purposes. This was too leniant and let exporters off the hook (since most fish sampled from Manila export facilities were found to have cyanide levels below 0.2 ppm). Hopefully, BFAR will lower this cut-off level to something more realistic associated with the MAC/BFAR cyanide testing program.
2) The IMA conducted random sampling of aquarium fish and food fish from collectors and from export facilities. My understanding is that BFAR will conduct random sampling of MAC Certified export facilities. Random sampling of aquarium fish has not been done since BFAR took over running the CDT from IMA in October 2001.
3) Sampling for cyanide testing should be applied to all fish species held in MAC Certified export facilities (not just to the ones from MAC Certified Collection sites).
4) The test results should be used to prosecute exporters and/or collectors. The MAC has not clarified how the results will be utilized. If there are no prosecutions the testing has no legal authority.
5) Some bright person (idiot) in BFAR decided that the present cyanide testing should be self financing (though fees charged to exporters). Exporters presently can have their fish tested for cyanide by voluntarily submitting specimens and paying a fee. Will the MAC Certified exporters be required to pay fees for the cyanide testing done on the fish randomly sampled from their facilities?
6) Some of you believe that certain species of aquarium fish were targeted with the use of cyanide. This implies that other species were collected without cyanide. The latter statement is not true. Of over 600 species of aquarium fishes tested almost all species were found to have been exposed to cyanide at some time or another. There is a serious problem with cyanide fishing for: a) aquarium fish, b) food fish sold in local markets; and c) for live food fish for export. Cyanide testing should not just be focused on a few species of aquarium fish that some misguided persons "believe" are targeted by fishermen/collectors. There needs to be a comprehensive sampling and testing program to a) protect human health, b) protect the coral reefs, and c) protect species diversity on the reefs. The MAC/BFAR CDT program as described appears to be a band- aid to deodorize MAC Certified exporters.
7) There are many more net-collectors than those that are presently MAC certified. There are negotiations presently being conducted between Ferdinand Cruz and Lino Alvarez (the MAC Philippines Coordin
ator). Hopefully, this will lead to the MAC certifying the collection sites and collectors where Ferdinand Cruz conducted CAMP training for the MAC during 2002. To do this the MAC must endorse the underwater surveys and CAMP documents created by the collectors in the municipalities of Palauig, Busuanga, Coron, and Bagac. The underwater survey methods applied by the collectors in these areas used methods documented by Ferdinand with several other co-authors. I can attest (from reading the survey manual and reading the CAMP documents) that the underwater surveys conducted at these sites (not MAC Certified) were done in a scientifically sound manner.
8) As far as I know ReefCheck did not use the MACTRAC underwater survey methods at either Batasan Island or at Clarin (based on an email communication from Craig Shulman of ReefCheck). MACTRAC was not finalized until January of this year. They may have applied a Rapid Appraisal Method (RAP) at Batasan Island this year after the CAMP was created and after the third party certifier had visited the Island of Batasan to conduct MAC Certification last year. No matter how good MAQTRAC appears to be (my reading of the document), I see no indication that it has been adopted or endorsed by the MAC. Since, no CAMP documents and no reports concerning underwater surveys have been publicly released for either Batasan or Clarin, I can not conclude that that the underwater surveys were conducted in a scientifically sound manner or that these sites are "sustainable".
Sincerely,
Peter Rubec, Ph.D.