MAC Cyanide Detection Testing
- Thread starter JennM
- Start date
Briefly about the status of MAC CDT:
MAC, through Lino Alvarez, brought the parties (BFAR and PCSD) together to discuss the issues which resulted in BFAR committing to revisit/revise/overhaul its procedures on sampling, handling of evidence, actual testing and release of test results. BFAR also promised to adopt stricter controls to protect the integrity of the entire process.
MAC is working with BFAR on the CDT program. BFAR requested a delay of a couple of weeks but they should start June 25 or 26, 2003.
Please don't think that MAC is not serious about bringing cyanide-free Philippine fish to the world. The systematic administration of the CDT test on MAC Certified fish will bring about one more necessary weapon in the fight against destructive collecting methods.
MAC, through Lino Alvarez, brought the parties (BFAR and PCSD) together to discuss the issues which resulted in BFAR committing to revisit/revise/overhaul its procedures on sampling, handling of evidence, actual testing and release of test results. BFAR also promised to adopt stricter controls to protect the integrity of the entire process.
MAC is working with BFAR on the CDT program. BFAR requested a delay of a couple of weeks but they should start June 25 or 26, 2003.
Please don't think that MAC is not serious about bringing cyanide-free Philippine fish to the world. The systematic administration of the CDT test on MAC Certified fish will bring about one more necessary weapon in the fight against destructive collecting methods.
naesco":bss6lzgb said:
naesco- you don't really annoy me- i just wish you'ld take the time to understand the issues abit more deeply than you seem to bother to understand them :wink:
btw-mac just asked for an extension on their own publicly announced self imposed cdt deadline
what do you think about that, naesco? do you see the repeat pattern, yet?
i think any ngo that behaves so irresponsibly as to announce a self imposed deadline for anything, only to not be able to have it ready as announced, should be labelled incompetent, and have all funding immediately withdrawn, so that those who can do what they promise may be given the chance, instead
its always one bs excuse/greenwash/lie after another w/mac-and i'm sick of hearing that old broken record-holthus's, ET AL (for those who are still watching
)words aren't worth a fiat dollar any longerat least, not to me
i'll place my faith in other orgs instead-those that decide to be self funding, so if they screw up(and i hope they don't) at least it'll be with their own money, or money they actually had to earn
hmmm...
i wonder if mac would have done what they always claimed they want to do, if they weren't futzin around with other peoples money?
how's my hair?
vitz":2g28visl said:
Vitz,
You should read my message closer. It seems that it was BFAR (Bureau of Fisheries and Aquatic Resources - Philippines) that asked for the delay, not MAC. BFAR is the Philippine Government Agency that is administering the CDT.
john
w/ all due respect-that is of no importance to me
when i give a client who pays me money to do a job a time committment, i stick to it, no matter what, because the buck stops w/ he who gave his word
mac tells us something-and gives the other end the ok to change the committment deadline?
mac had better grow up, fast, methinks
if i honestly can't meet a clients deadline because of some shmo i have no control over, you know what i do?
i give the client their money back, or at least offer to, and i make sure i won't be put in a position to rely on the shmo who seems to think that the word and committment i gave to others isn't worth an extra effort on their part, to keep me happy
but then again, i've always tried to be moral, ethical and responsible when i'm handling other peoples money :idea:
just how dumb/naive/childish does mac think we all are, that they can still keep playing the 'throw out a promise to keep 'em appeased a little while longer so we can collect our fat salary's while we can' game?
i have nothing personal against you, john
but you haven't one iota of respect for me, or from me, when you wear the mac hat, and the same goes for anyone affiliated w/mac-end of story
w/ all due respect-that is of no importance to me
when i give a client who pays me money to do a job a time committment, i stick to it, no matter what, because the buck stops w/ he who gave his word
mac tells us something-and gives the other end the ok to change the committment deadline?
mac had better grow up, fast, methinks
if i honestly can't meet a clients deadline because of some shmo i have no control over, you know what i do?
i give the client their money back, or at least offer to, and i make sure i won't be put in a position to rely on the shmo who seems to think that the word and committment i gave to others isn't worth an extra effort on their part, to keep me happy
but then again, i've always tried to be moral, ethical and responsible when i'm handling other peoples money :idea:
just how dumb/naive/childish does mac think we all are, that they can still keep playing the 'throw out a promise to keep 'em appeased a little while longer so we can collect our fat salary's while we can' game?
i have nothing personal against you, john
but you haven't one iota of respect for me, or from me, when you wear the mac hat, and the same goes for anyone affiliated w/mac-end of story
vitz,,
Thanks for speaking out above !!!!!!
Nice to hear there are still others out there who have ethics and practice them !!!! Continued excuses for placating people,just doesnt cut it for those of us who still believe our word means something !!!
Thanks for speaking out above !!!!!!
We are supposed to say something constructive here and not critizise, so my constructive suggestion for MAC and any other organization would be, if you are going to say anything, let it be HONEST and have substance behind it !!!!!
We do not want to hear platitudes and pie in the sky ideas.
We are real people who work hard, want to make things honest, clean, decent and be worthwhile in life- please remember that when you talk to us !!!! I am speaking for those of us who are honest dealers and for the fisherfolk who supply us.
Dont pass the buck off as someone elses fault ,as an excuse when you cant deliver on what you say. If you promise something, know AHEAD of time that you can deliver on that promise. Have your word mean something we can believe in.
We do not want to hear platitudes and pie in the sky ideas.
We are real people who work hard, want to make things honest, clean, decent and be worthwhile in life- please remember that when you talk to us !!!! I am speaking for those of us who are honest dealers and for the fisherfolk who supply us.
Dont pass the buck off as someone elses fault ,as an excuse when you cant deliver on what you say. If you promise something, know AHEAD of time that you can deliver on that promise. Have your word mean something we can believe in.
vitz":uxuri2pd said:
Don't forget, this is the SECOND extension. The "original" date was May 31, and that got pushed to June 15. I said then I wasn't holding my breath.... good thing, eh?
The fact that the CDT should have been in place BEFORE certifications ever began, is notwithstanding......
I also see that MAC fish are still available in Los Angeles to any reseller.... and that would have been a no-brainer to fix.
My constructive criticism: MAC.... stop giving yourself calloused hands from patting yourselves on the back, and start DOING.... the chain of custody for certified fish is something that can be fixed instantly, yet it has been discussed since, what? April? I think I only saw 2 or 3 species on the list this week :lol: I don't think it would make a huge dent in the wholesaler's sales if they could only sell to the handful of certified retailers.....
The longer it takes to do the simple stuff, the less faith we have in the big stuff....
Still not holding my breath, but still curious to see of Mary and Kyle's questions will ever be answered?
Jenn
In all fairness you should know that the MAC document I posted to start this thread: http://reefs.org/phpBB2/viewtopic.php?t=30064 was a briefing and update from MAC to its board of directors on the progress and status of the CDT. This was not some official public proclamation by MAC. I asked MAC if I could post this briefing on RDO, and I did get permission. I was warned that the 'RDO crowd' would probably be overly critical (especially of the pre-imposed dates). Feel privileged (if you will) that it was posted at all, as it is not a public document. Those dates that you are calling 'deadlines' are simply goals that MAC has set for its own progress on the issue. It is not unreasonable to think that an undertaking with so many components would have delays. In this case there are delays that are not caused by MAC, nor can all delays be anticipated.
With something as important as a proper CDT, the issue of time and deadlines takes a backseat to the accuracy and integrity of the process. IOW, getting it right is more important than getting it done by a certain date. MAC will not allow RDO members' collective anxiousness to force any hurried slipshod progress.
Below is a copy of the memo:
Cyanide Detection Testing and MAC Certification
April 30, 2003
1. Background
The use of cyanide in the marine aquarium trade is not allowed under MAC Certification. Cyanide use is included in the term “destructive collection and fishing practices”, which covers the use of any toxic chemicals such as sodium cyanide. The MAC Standards define "destructive collection and fishing practices" as: the collection and fishing of live marine aquarium organisms through methods that are environmentally destructive or harmful, including but not limited to practices such as the use of poison/toxins, other deleterious materials, and explosives; reef dredging; and physical damage to non-target organisms, especially corals or other sessile invertebrates.
At this time the principle destructive practice issue is sodium cyanide and the extent of its use in the Philippines and Indonesia. The MAC Certification of collection and export operations in the Philippines without an approved cyanide detection test (CDT) and a monitoring and sampling program have raised concerns that cyanide caught fish (or fish of unknown origin) are knowingly or unknowingly mixed with organisms coming from MAC Certified collection areas in a MAC Certified export facility.
As we began implementing MAC Certification with collectors and their communities it became more evident that improving and expanding the technical solution to cyanide use (i.e. CDT) was not necessarily the best and most needed response to the issue. The CDT was developed as an enforcement response to the use of cyanide and has its purpose and place, serving as an important threat and deterrent to cyanide use. However, with the advent of MAC Certification, there are other approaches that could be used to create broad scale, longer lasting changes in behavior among fishers.
The long term role and applicability of CDT testing as the principle response to cyanide use has a number of issues: the cost and difficulty of sustainable financing for maintaining an extensive network of CDT labs; the complicated science of cyanide detection; the variations of cyanide presence in fish due to variability in the time it takes to get fish to the lab; the possibility of "false positives" (i.e. fish that were caught without cyanide but have the chemical when tested) due to background cyanide on reefs from pollution or other fishing activities; the difficulty of trying to use the CDT to monitor a significant portion of catch or shipments; the serious constraints to developing and implementing a credible CDT lab network in large archipelagic countries.
With MAC Certification the non-use of cyanide becomes part of a larger context of responsible fishing practices, i.e. one of a range of practices for which individual fishers need to take responsibility for their personal behavior and be able to be held accountable for. In implementing MAC Certification, a significant amount of effort has focused on developing a variety of mechanisms for preventing cyanide use in the first place (see Annex 1), and not only on seeking to detect cyanide after it is has been used. Nonetheless, MAC Certification in locations where cyanide use is known to occur or have occurred must include a program of monitoring, sampling and testing for cyanide by credible, accurate, and reliable methods used by internationally accredited laboratories.
2. Cyanide and the MAC Standards
The MAC Standards and Best Practice Guidance contain numerous references to destructive fishing (i.e. including cyanide use) and the role of testing for cyanide and, if needed, for other chemicals, as listed below.
MAC STANDARDS AND BEST PRACTICE GUIDANCE
[Excerpts in the MAC Standards and Best Practice Guidance regarding the use of destructive collection and fishing practices, which includes the use of cyanide.]
Ecosystem and Fishery Management (EFM)
EFM Standard1.1 Marine aquarium organism collection and fishing shall be managed so that: (inter alia)
1.1.2 destructive collection and fishing practices are prohibited
2.1 Those managing the fishery shall produce and implement a Collection Area Management Plan consistent with the above management principles
EFM Best Practice Guidance
1.1 Principles Related to Marine Fish:
Fish collection should be managed so that: (inter alia)
- the use of chemicals is prohibited in the capture of fish
Collection, Fishing and Holding (CFH)
CFH Standard
2.1.1 Collectors and fishers shall comply with local laws and regulations with respect to access to and marine aquarium organisms taken from the certified collection area.
4.1.1 Collectors and fishers shall have clearly understood work standards or instructions. These may be either produced by the collector or fisher or given to the collector or fisher by the buyer or those managing the fishery. They shall describe best collection and fishing practices including the prohibition of destructive collection and fishing practices.
CFH Best Practice Guidance
4.1.1 Collectors and fishers should be able to demonstrate or document how they ensure that the use of chemical substances to collect fish is prohibited and how they make this known to their buyers.
Collectors and fishers should be able to demonstrate or document that they are fully conversant with the requirements of the Collection Area Management Plan. They can demonstrate to their buyer and the certifier that they are not using destructive collection and fishing methods by having the following: negative CDT results; certificates of training; low DOA records; and the gear that they use for fishing.
EFM, CFH and HHT Annex 3
MAC Approved Chemical Detection Methods and Providers
The MAC Chemical Detection Methods (CDM) Committee will identify, approve, and periodically revise a list of credible, accurate, and reliable test methods for detecting chemicals that are suspected of being used in the collection and fishing of marine aquarium organisms. A MAC Approved CDM is only valid if verified by an International Laboratory Accreditation Cooperation (ILAC) accredited laboratory.
3. Cyanide Detection Testing (CDT)
Although there have been CDT methods and laboratories in use in the Philippines for several years, unfortunately the methods used had not been internationally peer reviewed and the test laboratories not internationally accredited. In the past several years new test methods and equipment that have been developed or adapted for use in salt water tissue sampling for chemicals such as cyanide (e.g. High Performance Liquid Gas Chromatogarphy, Colorimetric, Histopathological, Enzyme).
Cyanide disrupts enzymatic function within respiratory metabolism. Exposing fish to cyanide results in liver, intestine, and reproductive organ damage. Assuming an uncaptured fish exposed to the chemical survives, these deleterious effects consequently impair the fish’s ability to grow, reproduce and fight off disease. Once cyanide-caught fish are placed into holding facilities or aquariums, elevated levels of pH in the water result in residual cyanide in the fish’s organs combining with hydrogen to become the highly toxic hydrocyanic acid.
CN and HCN are highly toxic but are excreted quickly from the body so there is very little prospect of CN being retained in the body. However there are some organisms that bio-concentrate cyanide. Cyanide and chemically related compounds are formed, excreted and degraded in nature by hundreds of species of bacteria, algae, fungi, plants and insects. Cyanide will be found in marine organisms, including fish, when they live in areas of low concentration solutions. Low levels of cyanide in the marine environment can result from pollution, such as from mine tailings rich in iron pyrites. There are significant volumes of mine tailings flowing into Philippines coastal waters in some areas meaning the background level of cyanide in the marine environment must be documented as part of a CDT program.
3. Current and Planned Actions to Establish Cyanide Detection Testing
To address the concerns about possible cyanide use by MAC Certified collectors and possession of cyanide caught fish by MAC Certified exporters, the following action plan is being implemented.
1 Identify and interact with laboratories, government agencies, research institutions and chemical detection equipment manufacturers to create a network and partnerships for evaluating cyanide detection tests (CDT).
Status: Ongoing.
2 Work with target partner laboratories and the BFAR Laboratory to validate CDT method(s) and lab(s) that can be provisionally accepted until fully evaluated by the MAC Board Committee.
Status: Ongoing; planned for completion in May 2003.
3 Work with industry, especially exporters, to obtain commitment to monitoring and sampling for cyanide detection.
Status: Completed for PTFEA in February 2003; ongoing for other industry members.
4 Amend the MAC Standards to more specifically require mandatory monitoring and sampling of fish for cyanide presence at all MAC Certified operations.
Status: Underway; planned for completion in May 2003.
5 Establish the Chemical Detection Methods Committee of the MAC Board.
Status: Planned for completion in May/June 2003.
6 Implement monitoring, sampling and testing program for MAC Certified collectors and exporters, using the provisionally accepted CDT methods and labs.
Status: Planned for implementation in June 2003 and continuing thereafter.
7 Undertake background cyanide level tests for MAC Certified and candidate collection areas.
Status: Planned for implementation in June 2003 and continuing thereafter.
8 Fully evaluate provisionally accepted CDT methods and labs.
Status: Planned for completion in June/July 2003.
9 Publish CDT results on the MAC website.
Status: Planned for commencing in July 2003 and continuing thereafter.
10 Establish a cyanide monitoring, sampling and testing program as part of MAC Certification development in Indonesia.
Status: Planned as part of MAC efforts in Indonesia.
4. Detailed Description of Current and Planned Actions
1. Identify and interact with laboratories, government agencies, research institutions and chemical detection equipment manufacturers to create a network and partnerships on evaluating cyanide detection tests (CDT).
Status: Ongoing.
Over the past several years, MAC has sought out individuals and institutions with expertise and interest in the detection of cyanide in fish or other organisms. This has included university research institutions, government agencies, manufacturers of chemical detection equipment, manufacturers of cyanide and others in the US, Canada, the Philippines, Hong Kong and Australia. In the Philippines, this has included interaction with the laboratory of the Bureau of Fisheries and Aquatic Resources (BFAR). From these efforts, we have been able to identify organizations that are particularly interested in evaluating and testing possible CDT methods.
2. Work with target partner laboratories and the BFAR Laboratory to validate CDT method(s) and lab(s) that can be provisionally accepted until fully evaluated by the MAC Board Committee.
Status: Ongoing; planned for completion in May 2003.
MAC has been in contact with target partner laboratories to plan a series of tests to detect sodium cyanide in fish tissue and sea water that may be provisionally accepted for use in the Philippines and elsewhere. Samples will be produced and divided into several parts and tested by ISE, HPLC and Spectrometry by several of the partner laboratories. Draft test protocols have been agreed and the sample preparation will duplicate the effect of testing a fish across a timeframe of cyanide levels and exposure ranging from several hours to several days.
The test method(s) that perform consistently and provide appropriate, credible and reliable testing for cyanide presence in marine aquarium fish will be submitted to the MAC Board Committee for provisional acceptance while the full evaluation proceeds. The lab(s) that perform consistently with these methods will be submitted to the MAC Board Committee for provisional acceptance while the full evaluation with ILAC proceeds.
3. Work with industry, especially exporters, to obtain commitment to monitoring and sampling for cyanide detection.
Status: Completed for PTFEA in February 2003; ongoing for other industry members.
MAC worked with the Philippine Tropical Fish Exporters Association (PTFEA) to secure the following public commitment regarding CDT: "PTFEA members understand and support the development and implementation of valid and effective cyanide detection testing. All PTFEA operations and facilities will be open to random announced and unannounced monitoring and sampling of stock for cyanide detection, provided that the testing be done at approved laboratories and that the tests be conducted by officially authorized persons." MAC is working with other industry members to obtain a similar commitment.
4. Amend the MAC Standards to more specifically require mandatory monitoring and sampling of fish for cyanide presence at all MAC Certified operations.
Status: Underway; planned for completion in May 2003.
The MAC EFM, CFH and HHT Standards will be amended in the next iteration of the Interpretive Document to require that MAC Certified collectors and exporters subject themselves to the MAC CDT monitoring program as part of maintaining certification. The Board may wish to specify the countries to which this applies.
5. Establish the Chemical Detection Methods Committee of the MAC Board.
Status: Planned for completion in May/June 2003.
The committee will be established, operate to ‘terms of reference’ and have its members chosen based on a process and criteria determined by the MAC Board of Directors. The committee will report directly to the MAC Board and will likely consist of 7 members representative of the following constituents: test laboratories, test equipment manufacturers, marine conservation NGOs, research institutions, an independent observer, a MAC Board Member, and the International Laboratory Accreditation Cooperation (ILAC) program. The committee will elect a Chair and Vice Chair. The Committee Secretary will be the MAC Certification Systems Director. The Committee will conduct its work via email.
6. Implement monitoring, sampling and testing for MAC Certified collectors and exporters, using the provisionally accepted CDT methods and labs.
Status: Planned for implementation in June 2003 and continuing thereafter.
MAC is already working with its certified exporters and collectors to ensure that the volume and variety of collected species is in line with the requirements of the CAMP and creates the responsibility and traceability of each collector to the organisms they harvest. MAC will initiate a program of sampling and testing for cyanide at all MAC Certified collectors and exporters in June 2003. In addition, we are working with the concerned government agencies (e.g. BFAR in the Philippines) to accept the results of this program in the context of their own efforts to eliminate cyanide fishing.
The cyanide monitoring, sampling and testing program will be mandatory for MAC Certified collectors and exporters. Any other collectors associations or exporters in the Philippines may join the program should they wish to test their fish for cyanide presence.
7. Undertake background cyanide level tests for MAC Certified and candidate collection areas.
Status: Planned for implementation in June 2003 and continuing thereafter.
Background cyanide levels in sea water within MAC Certified and candidate collection areas will be sampled and tested using the provisionally accepted methods and labs, and re-tested using the fully evaluated and approved methods and labs.
8. Fully evaluate provisionally accepted CDT methods and labs.
Status: Planned for completion in June/July 2003.
The test method(s) that were provisionally accepted as performing consistently and providing appropriate, credible and reliable testing for cyanide presence in marine aquarium fish will be fully evaluated by MAC Board Committee. MAC will work with ILAC and partner laboratories on achieving accreditation for the laboratories involved in the cyanide monitoring, sampling and testing program.
9. Publish CDT results on the MAC website.
Status: Planned for commencing in July 2003 and continuing thereafter.
Positive CDT test results will be given to MAC Accredited Certifiers and published on the MAC website.
10. Establish a cyanide monitoring, sampling and testing program as part of MAC Certification development in Indonesia.
Status: Planned as part of MAC efforts in Indonesia.
A number of the steps above will ensure that the cyanide monitoring, sampling and testing program will be mandatory for MAC Certified collectors and exporters in Indonesia. We will work with target partner laboratories to validate lab(s) that can be provisionally accepted for using the approved CDT methods in Indonesia and will work with ILAC and partner laboratories on achieving accreditation for the laboratories involved in the cyanide monitoring, sampling and testing program.
=========================================================================
Annex 1: Preventing Cyanide Use though MAC Certification
Implementation of the MAC Certification is based not only on seeking to detect cyanide after it is has been used but also on a variety of mechanisms for preventing cyanide use in the first place. This includes significant effort on developing criteria for documenting and tracing of the organisms caught by MAC Certified collectors operating in MAC Certified collection areas---"traceability" is to create accountability and link each collector to the fish that they collect. Accountability allows us to develop a whole range, or "basket," of measures that focus on preventative level behavior change with collectors, as described below.
Individual Responsibility Of Collectors:
With certification, fishers are required to use logbooks to document their catch and have these reviewed by the collector's coordinator. Each collector's catch is identified to the individual. The quality and acceptability is evaluated both by the collectors' coordinator and by the exporter. Poor quality fish are linked to the individual who collects and/or handles them.
Peer Pressure:
The collectors are certified as a group (usually they form an association to get the group certified), linking the group to the continued performance and compliance of each member. If one member violates the MAC Standards, the continued certification of the whole group (and their access to the improved market and its benefits) is at risk.
Community Involvement:
The development of the Collection Area Management Plan (CAMP) for compliance to the Ecosystem and Fishery Management (EFM) Standard is a multi-stakeholder effort that links the community to the fishery and the collectors. Creating a sense of belonging and pride of the community in the success and commitment of the certified fishers through a major community awards ceremony for them enhances this link.
Local Government Surveillance And Enforcement:
There is already often a village level system for surveillance and enforcement, e.g., local government fishing permits, fisheries patrols, etc. These are being linked with the certification, e.g., in some instances local municipalities allow only MAC Certified fishers to fish in the area.
Economic Incentives:
The financial return and income stability of fishers is improved by supplying the consistent quality that results from certified practices, creating an incentive to continue achieving compliance. MAC Certified collectors are now given new nets, jars, etc. on a regular basis and earn more regular income by NOT using cyanide. MAC is also developing market demand for certified products that creates added incentive for collectors to continue to comply.
With something as important as a proper CDT, the issue of time and deadlines takes a backseat to the accuracy and integrity of the process. IOW, getting it right is more important than getting it done by a certain date. MAC will not allow RDO members' collective anxiousness to force any hurried slipshod progress.
Below is a copy of the memo:
Cyanide Detection Testing and MAC Certification
April 30, 2003
1. Background
The use of cyanide in the marine aquarium trade is not allowed under MAC Certification. Cyanide use is included in the term “destructive collection and fishing practices”, which covers the use of any toxic chemicals such as sodium cyanide. The MAC Standards define "destructive collection and fishing practices" as: the collection and fishing of live marine aquarium organisms through methods that are environmentally destructive or harmful, including but not limited to practices such as the use of poison/toxins, other deleterious materials, and explosives; reef dredging; and physical damage to non-target organisms, especially corals or other sessile invertebrates.
At this time the principle destructive practice issue is sodium cyanide and the extent of its use in the Philippines and Indonesia. The MAC Certification of collection and export operations in the Philippines without an approved cyanide detection test (CDT) and a monitoring and sampling program have raised concerns that cyanide caught fish (or fish of unknown origin) are knowingly or unknowingly mixed with organisms coming from MAC Certified collection areas in a MAC Certified export facility.
As we began implementing MAC Certification with collectors and their communities it became more evident that improving and expanding the technical solution to cyanide use (i.e. CDT) was not necessarily the best and most needed response to the issue. The CDT was developed as an enforcement response to the use of cyanide and has its purpose and place, serving as an important threat and deterrent to cyanide use. However, with the advent of MAC Certification, there are other approaches that could be used to create broad scale, longer lasting changes in behavior among fishers.
The long term role and applicability of CDT testing as the principle response to cyanide use has a number of issues: the cost and difficulty of sustainable financing for maintaining an extensive network of CDT labs; the complicated science of cyanide detection; the variations of cyanide presence in fish due to variability in the time it takes to get fish to the lab; the possibility of "false positives" (i.e. fish that were caught without cyanide but have the chemical when tested) due to background cyanide on reefs from pollution or other fishing activities; the difficulty of trying to use the CDT to monitor a significant portion of catch or shipments; the serious constraints to developing and implementing a credible CDT lab network in large archipelagic countries.
With MAC Certification the non-use of cyanide becomes part of a larger context of responsible fishing practices, i.e. one of a range of practices for which individual fishers need to take responsibility for their personal behavior and be able to be held accountable for. In implementing MAC Certification, a significant amount of effort has focused on developing a variety of mechanisms for preventing cyanide use in the first place (see Annex 1), and not only on seeking to detect cyanide after it is has been used. Nonetheless, MAC Certification in locations where cyanide use is known to occur or have occurred must include a program of monitoring, sampling and testing for cyanide by credible, accurate, and reliable methods used by internationally accredited laboratories.
2. Cyanide and the MAC Standards
The MAC Standards and Best Practice Guidance contain numerous references to destructive fishing (i.e. including cyanide use) and the role of testing for cyanide and, if needed, for other chemicals, as listed below.
MAC STANDARDS AND BEST PRACTICE GUIDANCE
[Excerpts in the MAC Standards and Best Practice Guidance regarding the use of destructive collection and fishing practices, which includes the use of cyanide.]
Ecosystem and Fishery Management (EFM)
EFM Standard1.1 Marine aquarium organism collection and fishing shall be managed so that: (inter alia)
1.1.2 destructive collection and fishing practices are prohibited
2.1 Those managing the fishery shall produce and implement a Collection Area Management Plan consistent with the above management principles
EFM Best Practice Guidance
1.1 Principles Related to Marine Fish:
Fish collection should be managed so that: (inter alia)
- the use of chemicals is prohibited in the capture of fish
Collection, Fishing and Holding (CFH)
CFH Standard
2.1.1 Collectors and fishers shall comply with local laws and regulations with respect to access to and marine aquarium organisms taken from the certified collection area.
4.1.1 Collectors and fishers shall have clearly understood work standards or instructions. These may be either produced by the collector or fisher or given to the collector or fisher by the buyer or those managing the fishery. They shall describe best collection and fishing practices including the prohibition of destructive collection and fishing practices.
CFH Best Practice Guidance
4.1.1 Collectors and fishers should be able to demonstrate or document how they ensure that the use of chemical substances to collect fish is prohibited and how they make this known to their buyers.
Collectors and fishers should be able to demonstrate or document that they are fully conversant with the requirements of the Collection Area Management Plan. They can demonstrate to their buyer and the certifier that they are not using destructive collection and fishing methods by having the following: negative CDT results; certificates of training; low DOA records; and the gear that they use for fishing.
EFM, CFH and HHT Annex 3
MAC Approved Chemical Detection Methods and Providers
The MAC Chemical Detection Methods (CDM) Committee will identify, approve, and periodically revise a list of credible, accurate, and reliable test methods for detecting chemicals that are suspected of being used in the collection and fishing of marine aquarium organisms. A MAC Approved CDM is only valid if verified by an International Laboratory Accreditation Cooperation (ILAC) accredited laboratory.
3. Cyanide Detection Testing (CDT)
Although there have been CDT methods and laboratories in use in the Philippines for several years, unfortunately the methods used had not been internationally peer reviewed and the test laboratories not internationally accredited. In the past several years new test methods and equipment that have been developed or adapted for use in salt water tissue sampling for chemicals such as cyanide (e.g. High Performance Liquid Gas Chromatogarphy, Colorimetric, Histopathological, Enzyme).
Cyanide disrupts enzymatic function within respiratory metabolism. Exposing fish to cyanide results in liver, intestine, and reproductive organ damage. Assuming an uncaptured fish exposed to the chemical survives, these deleterious effects consequently impair the fish’s ability to grow, reproduce and fight off disease. Once cyanide-caught fish are placed into holding facilities or aquariums, elevated levels of pH in the water result in residual cyanide in the fish’s organs combining with hydrogen to become the highly toxic hydrocyanic acid.
CN and HCN are highly toxic but are excreted quickly from the body so there is very little prospect of CN being retained in the body. However there are some organisms that bio-concentrate cyanide. Cyanide and chemically related compounds are formed, excreted and degraded in nature by hundreds of species of bacteria, algae, fungi, plants and insects. Cyanide will be found in marine organisms, including fish, when they live in areas of low concentration solutions. Low levels of cyanide in the marine environment can result from pollution, such as from mine tailings rich in iron pyrites. There are significant volumes of mine tailings flowing into Philippines coastal waters in some areas meaning the background level of cyanide in the marine environment must be documented as part of a CDT program.
3. Current and Planned Actions to Establish Cyanide Detection Testing
To address the concerns about possible cyanide use by MAC Certified collectors and possession of cyanide caught fish by MAC Certified exporters, the following action plan is being implemented.
1 Identify and interact with laboratories, government agencies, research institutions and chemical detection equipment manufacturers to create a network and partnerships for evaluating cyanide detection tests (CDT).
Status: Ongoing.
2 Work with target partner laboratories and the BFAR Laboratory to validate CDT method(s) and lab(s) that can be provisionally accepted until fully evaluated by the MAC Board Committee.
Status: Ongoing; planned for completion in May 2003.
3 Work with industry, especially exporters, to obtain commitment to monitoring and sampling for cyanide detection.
Status: Completed for PTFEA in February 2003; ongoing for other industry members.
4 Amend the MAC Standards to more specifically require mandatory monitoring and sampling of fish for cyanide presence at all MAC Certified operations.
Status: Underway; planned for completion in May 2003.
5 Establish the Chemical Detection Methods Committee of the MAC Board.
Status: Planned for completion in May/June 2003.
6 Implement monitoring, sampling and testing program for MAC Certified collectors and exporters, using the provisionally accepted CDT methods and labs.
Status: Planned for implementation in June 2003 and continuing thereafter.
7 Undertake background cyanide level tests for MAC Certified and candidate collection areas.
Status: Planned for implementation in June 2003 and continuing thereafter.
8 Fully evaluate provisionally accepted CDT methods and labs.
Status: Planned for completion in June/July 2003.
9 Publish CDT results on the MAC website.
Status: Planned for commencing in July 2003 and continuing thereafter.
10 Establish a cyanide monitoring, sampling and testing program as part of MAC Certification development in Indonesia.
Status: Planned as part of MAC efforts in Indonesia.
4. Detailed Description of Current and Planned Actions
1. Identify and interact with laboratories, government agencies, research institutions and chemical detection equipment manufacturers to create a network and partnerships on evaluating cyanide detection tests (CDT).
Status: Ongoing.
Over the past several years, MAC has sought out individuals and institutions with expertise and interest in the detection of cyanide in fish or other organisms. This has included university research institutions, government agencies, manufacturers of chemical detection equipment, manufacturers of cyanide and others in the US, Canada, the Philippines, Hong Kong and Australia. In the Philippines, this has included interaction with the laboratory of the Bureau of Fisheries and Aquatic Resources (BFAR). From these efforts, we have been able to identify organizations that are particularly interested in evaluating and testing possible CDT methods.
2. Work with target partner laboratories and the BFAR Laboratory to validate CDT method(s) and lab(s) that can be provisionally accepted until fully evaluated by the MAC Board Committee.
Status: Ongoing; planned for completion in May 2003.
MAC has been in contact with target partner laboratories to plan a series of tests to detect sodium cyanide in fish tissue and sea water that may be provisionally accepted for use in the Philippines and elsewhere. Samples will be produced and divided into several parts and tested by ISE, HPLC and Spectrometry by several of the partner laboratories. Draft test protocols have been agreed and the sample preparation will duplicate the effect of testing a fish across a timeframe of cyanide levels and exposure ranging from several hours to several days.
The test method(s) that perform consistently and provide appropriate, credible and reliable testing for cyanide presence in marine aquarium fish will be submitted to the MAC Board Committee for provisional acceptance while the full evaluation proceeds. The lab(s) that perform consistently with these methods will be submitted to the MAC Board Committee for provisional acceptance while the full evaluation with ILAC proceeds.
3. Work with industry, especially exporters, to obtain commitment to monitoring and sampling for cyanide detection.
Status: Completed for PTFEA in February 2003; ongoing for other industry members.
MAC worked with the Philippine Tropical Fish Exporters Association (PTFEA) to secure the following public commitment regarding CDT: "PTFEA members understand and support the development and implementation of valid and effective cyanide detection testing. All PTFEA operations and facilities will be open to random announced and unannounced monitoring and sampling of stock for cyanide detection, provided that the testing be done at approved laboratories and that the tests be conducted by officially authorized persons." MAC is working with other industry members to obtain a similar commitment.
4. Amend the MAC Standards to more specifically require mandatory monitoring and sampling of fish for cyanide presence at all MAC Certified operations.
Status: Underway; planned for completion in May 2003.
The MAC EFM, CFH and HHT Standards will be amended in the next iteration of the Interpretive Document to require that MAC Certified collectors and exporters subject themselves to the MAC CDT monitoring program as part of maintaining certification. The Board may wish to specify the countries to which this applies.
5. Establish the Chemical Detection Methods Committee of the MAC Board.
Status: Planned for completion in May/June 2003.
The committee will be established, operate to ‘terms of reference’ and have its members chosen based on a process and criteria determined by the MAC Board of Directors. The committee will report directly to the MAC Board and will likely consist of 7 members representative of the following constituents: test laboratories, test equipment manufacturers, marine conservation NGOs, research institutions, an independent observer, a MAC Board Member, and the International Laboratory Accreditation Cooperation (ILAC) program. The committee will elect a Chair and Vice Chair. The Committee Secretary will be the MAC Certification Systems Director. The Committee will conduct its work via email.
6. Implement monitoring, sampling and testing for MAC Certified collectors and exporters, using the provisionally accepted CDT methods and labs.
Status: Planned for implementation in June 2003 and continuing thereafter.
MAC is already working with its certified exporters and collectors to ensure that the volume and variety of collected species is in line with the requirements of the CAMP and creates the responsibility and traceability of each collector to the organisms they harvest. MAC will initiate a program of sampling and testing for cyanide at all MAC Certified collectors and exporters in June 2003. In addition, we are working with the concerned government agencies (e.g. BFAR in the Philippines) to accept the results of this program in the context of their own efforts to eliminate cyanide fishing.
The cyanide monitoring, sampling and testing program will be mandatory for MAC Certified collectors and exporters. Any other collectors associations or exporters in the Philippines may join the program should they wish to test their fish for cyanide presence.
7. Undertake background cyanide level tests for MAC Certified and candidate collection areas.
Status: Planned for implementation in June 2003 and continuing thereafter.
Background cyanide levels in sea water within MAC Certified and candidate collection areas will be sampled and tested using the provisionally accepted methods and labs, and re-tested using the fully evaluated and approved methods and labs.
8. Fully evaluate provisionally accepted CDT methods and labs.
Status: Planned for completion in June/July 2003.
The test method(s) that were provisionally accepted as performing consistently and providing appropriate, credible and reliable testing for cyanide presence in marine aquarium fish will be fully evaluated by MAC Board Committee. MAC will work with ILAC and partner laboratories on achieving accreditation for the laboratories involved in the cyanide monitoring, sampling and testing program.
9. Publish CDT results on the MAC website.
Status: Planned for commencing in July 2003 and continuing thereafter.
Positive CDT test results will be given to MAC Accredited Certifiers and published on the MAC website.
10. Establish a cyanide monitoring, sampling and testing program as part of MAC Certification development in Indonesia.
Status: Planned as part of MAC efforts in Indonesia.
A number of the steps above will ensure that the cyanide monitoring, sampling and testing program will be mandatory for MAC Certified collectors and exporters in Indonesia. We will work with target partner laboratories to validate lab(s) that can be provisionally accepted for using the approved CDT methods in Indonesia and will work with ILAC and partner laboratories on achieving accreditation for the laboratories involved in the cyanide monitoring, sampling and testing program.
=========================================================================
Annex 1: Preventing Cyanide Use though MAC Certification
Implementation of the MAC Certification is based not only on seeking to detect cyanide after it is has been used but also on a variety of mechanisms for preventing cyanide use in the first place. This includes significant effort on developing criteria for documenting and tracing of the organisms caught by MAC Certified collectors operating in MAC Certified collection areas---"traceability" is to create accountability and link each collector to the fish that they collect. Accountability allows us to develop a whole range, or "basket," of measures that focus on preventative level behavior change with collectors, as described below.
Individual Responsibility Of Collectors:
With certification, fishers are required to use logbooks to document their catch and have these reviewed by the collector's coordinator. Each collector's catch is identified to the individual. The quality and acceptability is evaluated both by the collectors' coordinator and by the exporter. Poor quality fish are linked to the individual who collects and/or handles them.
Peer Pressure:
The collectors are certified as a group (usually they form an association to get the group certified), linking the group to the continued performance and compliance of each member. If one member violates the MAC Standards, the continued certification of the whole group (and their access to the improved market and its benefits) is at risk.
Community Involvement:
The development of the Collection Area Management Plan (CAMP) for compliance to the Ecosystem and Fishery Management (EFM) Standard is a multi-stakeholder effort that links the community to the fishery and the collectors. Creating a sense of belonging and pride of the community in the success and commitment of the certified fishers through a major community awards ceremony for them enhances this link.
Local Government Surveillance And Enforcement:
There is already often a village level system for surveillance and enforcement, e.g., local government fishing permits, fisheries patrols, etc. These are being linked with the certification, e.g., in some instances local municipalities allow only MAC Certified fishers to fish in the area.
Economic Incentives:
The financial return and income stability of fishers is improved by supplying the consistent quality that results from certified practices, creating an incentive to continue achieving compliance. MAC Certified collectors are now given new nets, jars, etc. on a regular basis and earn more regular income by NOT using cyanide. MAC is also developing market demand for certified products that creates added incentive for collectors to continue to comply.
John_Brandt":1rqcw5tw said:
John,
The exact words as I recall them were: "You can expect action in six weeks. Just give me six weeks, and you can expect that the CDT will be implemented." These words were spoken by David Vosselar over the IMAC weekend, and were uttered in your presence. As far as I was concerned, this was not private or priviledged communication. It was as official as it gets.
This being said, I agree here with John!!!
People, this is the Philippines we are talking about!!!
There is a cultural trait within the Philippines: They call it 'Filipino time'.
Nothing, and but nothing typically happens 'on-time'.
IF BFAR, which is a government agency of the sovereign nation of the Philippines, decides that they need an extra two weeks to implement something, what exactly do all ya'all think MAC is going to do about it? Call in the US Marines? They will do what anyone would do, which is say, OK, we'll see you in two weeks...
Trust me, I understand the frustration involved here, but we are talking about something they have absolutely zero control over.
This all being said, I would add one thing: If this delay extends and extends, people will have a right to complain.
Regards.
Mike Kirda
John_Brandt":1ubv5ymo said:
Not that I think that MAC is a viable solution to the problems in the industry, but I totally understand what John (MAC) is saying. I work in the software industy (my REAL JOB as most here know about), goals and deadlines are two different things. We rarely make the date for our goals, but if we miss a deadline we have shareholders that having something to say about it.
To be quite honest I don't understand why everyone here is wasting their time screaming about MAC when it is quite obvious that they aren't listening. They only want to hear good things about MAC, its human nature.
In my opinion the only way to stop cyanide use is to train the people in a non confrontational way (The way that Steve is training from what I understand). No one likes being told what they can and cannot do, especially by some American NGO.
Liken it to having your company bought out by some big corporation. The first day the suits arrive and change the way you have been doing business for the last 10 years. The second day the suits lay everyone off that you have worked with for the last 10 years. The third day the suits close the company down because it is not making enough money and YOU are out of a job. NOBODY TRUSTS THE SUITS.
OR
One of your employees knows a guy named Steve that is looking for a job. He sends in his resume and get the postion as manager in charge of making grapple grommits. Everybody likes Steve because he treats everyone with respect and doesn't presume to know everything about your business. People trust him. One day Steve comes up with a better way to make grapple grommits and with his way the area where the grapples are collected is not destroyed and the grapple grommits don't break down after 6 weeks. After about a year word gets out about the quality of your product, you are getting more and more customers and making more money than you ever have before. Life is Good. After 25 years you retire and your Son/Daughter takes over the company. BTW they are still collect the grapples in the same place.
If WE don't trust or like the suits can you imagine what people in a developing country think of them.
MAC will fail, don't worry !
Scott (The other and not so opinionated half)
_________________
Owner:Imagine Ocean
And the folks here will do everything in their power to make sure they do. Pretty sad...
It's also pretty sad to think that any new people that visit this forum are shunned and/or criticized unless they're MAC bashers. Nothing to do with my opinion of MAC...just an observation of the mindset of the people that hang out here.
NS
Nancy,
You make a very good point about it being scary to be a "MAC moderate" or (heaven forbid) a "MAC-backer" here.
I feel that worthwhile change often takes time and many here just simply refuse to understand that. If MAC is capable of helping to change BFAR's opinions and stance regarding the CDT I feel they are making a very worthwhile contribution to ecological reform even if it doesn't meet with many people's timetable.
BTW, it was pretty apparent to me that the information that John posted regarding the CDT timetable was a series of internal goals that he shared with us. Bashing him as the messenger will only serve to disconnect the RDO community from these types of information in the future.
-Lee
You make a very good point about it being scary to be a "MAC moderate" or (heaven forbid) a "MAC-backer" here.
I feel that worthwhile change often takes time and many here just simply refuse to understand that. If MAC is capable of helping to change BFAR's opinions and stance regarding the CDT I feel they are making a very worthwhile contribution to ecological reform even if it doesn't meet with many people's timetable.
BTW, it was pretty apparent to me that the information that John posted regarding the CDT timetable was a series of internal goals that he shared with us. Bashing him as the messenger will only serve to disconnect the RDO community from these types of information in the future.
-Lee
Nancy Swart":afcv17e4 said:
Interesting, I was supporting John's statement about goals.
I am surprised that you would suggest that I am NEW to this forum. Just because I don't post doesn't mean that my voice isn't heard here. (what store do I own ???).
Nancy it is quite obvious why YOU post here.
Posts: 50
Actually I was suggesting that everyone stop wasting their time bashing MAC. This forum's name should either be changed to " Why I hate MAC" or everyone should move on and start discussing other issues .
Scott (The other and not so opinionated half)
_________________
Owner:Imagine Ocean
Really...then why end it the way you did or did I misinterpret that last statement? It SOUNDED as tho some are worried MAC may succeed.
And PLEASE don't presume to know why I post here. Your comment about "50 posts" just gave proof to what I meant about the overall hostile, cliqueish atmosphere here.
Your Jenn's husband Scott, right? Owner of Imagine-Ocean? And what does this have to do with anything?
NS
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