Cyanide Detection Testing and MAC Certification

[naesco]

I believe most reputable LFS and online stores will proceed with certification.

Does this mean you will equate certified with reputable?

I don't plan to become certified anytime soon, but my current customers consider me to be reputable.

I think the question is WHY become certified? Because it's fashionable, or because it really means something? Right now it's the former. Be the first kid on the block to have a sticker - no thanks. I never got into fads as a kid, I'm not about to start now.

I'm already selling net-caught and farm-raised fish, and I'd be comfortable with somebody performing a test on any specimen in my shop - can everybody say the same thing? Methinks not...

Jenn

You guys, Mary, Rover, Jenn and other are more than reputable. You are at the forefront of an important reform. I am sure your customers agree.
There will be loser wholesalers and online and LF stores but they will be outed in time.

 

[JennM]

Well that's nice - we're above "the rest", even uncertified.... we're not alone. I know other owners/operators who read these forums but don't post - that doesn't make them any less reputable if they act accordingly, but not everyone is willing to stand on a soap box and shout.

The point that keeps coming up, is that with certification as it is now, and I'll argue that even with the CDT in place, there will be cheats in the system, it's just TOO easy. That will enable certain facilities to keep on operating as they always have, only now they'll have a certification to justify their practices - the sins will all be greenwashed away.

50 certified Imperators - 2 die - oops the whole batch is "decertified" for what, 3 days? Will the exporter hang on to them for 3 more days and risk more dying? Nuh-uh - if the opportunity arises, he/she MIGHT be tempted to toss in one non-MAC (and possibly juiced) fish, and nobody's the wiser - 1 in 50 odds that that specimen will be the one picked IF that supplier is randomly selected for a CDT - I like to gamble, I'd play those odds, and I'd bet that I'd get away with it.

I'm not suggesting that everybody along the chain is a crook - however, business is business and there are times when folks NEED to cut corners to make ends meet, and that temptation is just too great to believe that nobody would take advantage of that huge loophole.

Jenn

 

[mkirda]

wholesale level

Please clarify what you mean here by 'wholesale level': Importer or exporter?

Regards.
Mike Kirda

 

[naesco]

Rover would you please clarify what you mean by "until the CDT results in verifiable sources of cyanide free fish" We just might agree.

Only after a random CDT test has been put into place at the point of collection, and real penalties and fines implemented for non-compliance, as well as a CDT test at the wholesale level with the same penalties and fines, and only after wholesalers are either selling certified fish or uncertified fish but not both, can we even begin to think that the battle has started.

Thanks Rover for your clarification.
That is certainly a goal I would like to see but would define it as the war not the battle.
As a reformist, I will accept a random CDT that is done on the MAC certified Phillippine exporters. Not perfect but it is a major step forward.
Here is the reason why
If a major online store like Dr. Smith are certified they have to buy from a MAC certified wholesaler out of California like Quality Marine. Quality Marine must buy from a MAC certified Phillippine exporter.
Both the Phillippine exporter and Quality Marine would have a vested interest to ensure there are no CDT test that test positive.
Dr. Smith will not be a happy camper if he finds out his supply is tainted.
MAC has agreed to post the test results monthly on their website and everyone will know. It will go through the boards like wildfire.
IMO therein lies the hammer; not putting a fisher in gaol.
When a test shows cyanide present on the first occasion, I would expect the Phillippine exporter to read the riot act to his people and his suppliers to ensure that it does not happen again.

 

[naesco]

Well that's nice - we're above "the rest", even uncertified.... we're not alone. I know other owners/operators who read these forums but don't post - that doesn't make them any less reputable if they act accordingly, but not everyone is willing to stand on a soap box and shout.

The point that keeps coming up, is that with certification as it is now, and I'll argue that even with the CDT in place, there will be cheats in the system, it's just TOO easy. That will enable certain facilities to keep on operating as they always have, only now they'll have a certification to justify their practices - the sins will all be greenwashed away.

50 certified Imperators - 2 die - oops the whole batch is "decertified" for what, 3 days? Will the exporter hang on to them for 3 more days and risk more dying? Nuh-uh - if the opportunity arises, he/she MIGHT be tempted to toss in one non-MAC (and possibly juiced) fish, and nobody's the wiser - 1 in 50 odds that that specimen will be the one picked IF that supplier is randomly selected for a CDT - I like to gamble, I'd play those odds, and I'd bet that I'd get away with it.

I'm not suggesting that everybody along the chain is a crook - however, business is business and there are times when folks NEED to cut corners to make ends meet, and that temptation is just too great to believe that nobody would take advantage of that huge loophole.

Jenn

For sure some will try to cheat but just like cheating on taxes you have to weigh the consequences and most will not take the risk. I may be wrong but I suspect the industy is closely held and that if a MAC test shows cyanide, it will not be long before everyone in the industry will know.

And to comment on your other post. I think we all agreed that getting a CDT in place was the priority. There are so many other concerns that the CDT would go nowhere fast without trying to nail down issues one by one. In my experience, from what i have learned about the industry, MAC etc., it is so complex that you have to break it down. IMO that is why things did not happen in the past despite a lot of effort and good intentions.

 

[mkirda]

50 certified Imperators - 2 die - oops the whole batch is "decertified" for what, 3 days? Will the exporter hang on to them for 3 more days and risk more dying? Nuh-uh - if the opportunity arises, he/she MIGHT be tempted to toss in one non-MAC (and possibly juiced) fish, and nobody's the wiser - 1 in 50 odds that that specimen will be the one picked IF that supplier is randomly selected for a CDT - I like to gamble, I'd play those odds, and I'd bet that I'd get away with it.

Jenn,

To hear the argument from the other side...

So the batch gets decertified... So what? They are still for sale, and if sold, fine... Whatever is left after three days gets 're-certified' and probably sold for a higher price again. Do you really think it is worth it to the exporter to scoop a fish out of another tank and plop it into the MAC one? For just few pisos??? They would never do this! They would loose money just from their time...

Does anything bother you about this argument?
Blame it on Rob Toonen- I'm applying a lesson from his talk: Be skeptical.

Q: DO I THINK IT WOULD HAPPEN?
A: Absolutely yes.
Q: Why do I think it would happen?
A: Because they ostensibly paid more for the MAC fish, and the selling price for the MAC fish would be higher. If we assume a 10% cost difference, they are now looking at a 10% cut in their profit on every fish from that batch that they sold.
Not to mention that the importers might want 40 MAC fish to ship on Saturday, not next Wednesday. If it is the difference between making the shipment with what the customer wants vs. not making the shipment, guess what? The shipment will be made with what the customer wants. That is just business.
Q: Do I think this problem will run rampant?
A: No, probably not. But if a shipment of the fish has to be made, fish will get mixed if necessary.
Q: Do I think this is the end of the world?
A: No, I don't, as long as there is a CDT in place, and true random testing to ensure that this issue remains very small.

I have a question here: Is this level of mixing strong enough an issue to get your undies in a bunch? Or is it sort of like cheating on your taxes... everyone does a little bit?

To me, with a true random CDT in place, it seems like less of an issue than without a CDT in place.

Am curious to hear the thoughts of others on this.
Regards.
Mike Kirda

 

[naesco]

50 certified Imperators - 2 die - oops the whole batch is "decertified" for what, 3 days? Will the exporter hang on to them for 3 more days and risk more dying? Nuh-uh - if the opportunity arises, he/she MIGHT be tempted to toss in one non-MAC (and possibly juiced) fish, and nobody's the wiser - 1 in 50 odds that that specimen will be the one picked IF that supplier is randomly selected for a CDT - I like to gamble, I'd play those odds, and I'd bet that I'd get away with it.

Jenn,

To hear the argument from the other side...

So the batch gets decertified... So what? They are still for sale, and if sold, fine... Whatever is left after three days gets 're-certified' and probably sold for a higher price again. Do you really think it is worth it to the exporter to scoop a fish out of another tank and plop it into the MAC one? For just few pisos??? They would never do this! They would loose money just from their time...

Does anything bother you about this argument?
Blame it on Rob Toonen- I'm applying a lesson from his talk: Be skeptical.

Q: DO I THINK IT WOULD HAPPEN?
A: Absolutely yes.
Q: Why do I think it would happen?
A: Because they ostensibly paid more for the MAC fish, and the selling price for the MAC fish would be higher. If we assume a 10% cost difference, they are now looking at a 10% cut in their profit on every fish from that batch that they sold.
Not to mention that the importers might want 40 MAC fish to ship on Saturday, not next Wednesday. If it is the difference between making the shipment with what the customer wants vs. not making the shipment, guess what? The shipment will be made with what the customer wants. That is just business.
Q: Do I think this problem will run rampant?
A: No, probably not. But if a shipment of the fish has to be made, fish will get mixed if necessary.
Q: Do I think this is the end of the world?
A: No, I don't, as long as there is a CDT in place, and true random testing to ensure that this issue remains very small.

I have a question here: Is this level of mixing strong enough an issue to get your undies in a bunch? Or is it sort of like cheating on your taxes... everyone does a little bit?

To me, with a true random CDT in place, it seems like less of an issue than without a CDT in place.

Am curious to hear the thoughts of others on this.
Regards.
Mike Kirda

I think you hit the nail on the head, Mike.
With any certification, all the concerns raised will occur. That is why it is so important an annoucement to have a CDT in place.
It keeps everyone mostly honest. We cannot test each fish.

 

[MaryHM]

Points to ponder:

Pretty much the only MAC certified fish right now anyway are fish that are never/rarely juiced. So to run a test on a batch of mandarins is kind of retarded. I worry about the other 150 species. I would assume MAC would only be doing randome testing of MAC certified fish. How a company can be MAC certified and still carry cyanide caught fish just blows my mind.

 

[MaryHM]

Mike,

Can you get an explaination from David about why they have finally decided to go ahead with the IMA test they have been publicly denouncing as not credible for so long? What has changed? Is it credible now, or are they just desparate to get something into place to shut us all up? Has the test finally met all of the MAC criteria for a CDT??

 

[mkirda]

Mike,

Can you get an explaination from David about why they have finally decided to go ahead with the IMA test they have been publicly denouncing as not credible for so long? What has changed? Is it credible now, or are they just desparate to get something into place to shut us all up? Has the test finally met all of the MAC criteria for a CDT??

Mary,

In your heart of hearts, you already know the answer to that question.
You have been heard.

More than this, I cannot say. David is not really the point person on the CDT.
As Naesco suggested, give your recommendations to John Brandt.
He will give them to David, who promises that they will all be looked at and given due consideration by the CDT committee.

With all due respect to everyone, this seemed to be an olive branch. They are hearing you, at least on the CDT. Now is the time to make any suggestions you may have as they will be heard.

Peter, I know you have a stake in this. You want to see it happen too. Now is the time as they will listen to you.

This posting is also not at the request of anyone: David learned a lot (seemingly) from Steve and I as we talked about the CDTs now and in the past. He was very receptive to the information: Some of it seemed new to him. He seemed quite interested in hearing that there may be other methods on the horizon.

Regards.
Mike Kirda

 

[PeterIMA]

Comments concerning the MAC and CDT.

It is encouraging to see that the MAC is finally willing to tie MAC Certification to cyanide testing. This is a step in the right direction. My main concern is that the sampling for CDT would only apply to MAC Certified export facities. I believe that sampling and testing needs to be comprehensive (across the country and from all exporter facilities-similar to the way it was previously done by IMA under contract with BFAR).

I agree with Mary that "The priority is a CDT that is properly implemented and enforced." However, I disagree with her statement that "There were serious problems with implementation (testing not being done randomly, cyanide target species not being tested)." These two statements are incorrect; if she meant to imply this was the case with the testing done by IMA (it may be true with the more recent testing done by BFAR).

The IMA though its Marine Inspection Sampling (MIS) used biologists deputized as Fish Wardens by the Bureau of Fisheries and Aquatic Resources (BFAR) to conduct random sampling from collectors at sea, at their villages, at transportation points within the Philippines (eg. airports) and from export facilities. Testing was done in six CDT laboratories located in Manila, Puerto Princesa, Cebu City, Zamboanga City, Davao City, and Palo (Leyte). It is not true to imply that the testing was not conducted randomly(presumably this means based on random sampling) or that target species were not tested. For example, there were over 800 specimens of angelfish tested including over 80 Emperor angelfish and over 30 Blueface angelfish. I can provide a breakdown of the results for over 950 fish species in an Excel spreadsheet for those interested in seeing actual results by species.

I have recently published a paper titled "Trends Determined By Cyanide Testing On Marine Aquarium Fish In The Philippines" Pages 327-340 In the book Marine Ornamental Species Collectio, Culture, and Conservation, Iowa State Press. This is based on a presentation I made at the Second Marine Ornmentals Conference held at Lake Bueno Vista, Florida Nov. 25-29, 2001. I can email this paper to anyone who wishes to read it. My email address is [email protected].

The methods used by the IMA/BFAR CDT labatories are fully documented in four Standard Operating Procedure (SOP) manuals that I helped to prepare. These can be supplied to interested parties like the MAC (the MAC incorrectly implied during 1999 that the CDT SOP was unreliable)

I appeciate Mike Kirda's comments about my willingness to help reinstitute CDT in the Philippines. I am willing to help make this happen.
I told Wayne Ryan, that IMA can get a CDT laboraory up and running in 30-60 days, when funding becomes available. I submitted a proposal to NOAA in mid-March by which IMA and BFAR would work together to reimplement a full CDT laboratory in Manila (the present BFAR Manila is inadequate). The proposal is still pending.

In addition two grants (that I helped prepare in conjunction with other scientists) were approved and research is being conducted on evalution of a test for thiocyanate by Iowa State University. The research is underway.

The cyanide test presently being done by BFAR is the one previously done by IMA (personal communication Ms. Sandra Acamo of BFAR, 2003). The picrate paper test was used briefly by BFAR during the spring of 2002. Fortunately, BFAR stopped using it, since that test method is not reliable.

Sincerly,
Peter J. Rubec, Ph.D.

 

[JennM]

You're missing my point. Sure I'm glad that a step is being taken forward - the CDT test - however it's not implemented yet so I'm not doing the happy dance - and it seems that the test being used has some controversy attached to it - I thought MAC was holding out for some other sort of test...could the OUTCRY have caused them to lower their standards a bit just to speed things up, and perhaps shut us up? :roll:

But in the interest of expeidency, something is better than nothing right? Sure - once it's being done. I HOPE that the CDT issue doesn't just die when the test is implemented - if the current test is flawed, I hope it is just an interim solution until a more appropriate and accurate test is found. I haven't heard that in the huge treatise that JB posted - but if it's in there, please do share. And, is there a timetable for the "new improved" test? Or will that just be popped onto the back burner?

My point is that just because "a" CDT is "soon" to go into place, we should all sit back and pat ourselves on the back for a job well done. It ain't over. So we've made a bit of headway on a problem that should have been resolved BEFORE certifications were made - whoopee. If we hadn't put on the pressure that we did, perhaps the CDT would have taken even longer (and I keep reminding myself and others, it's not a done deal YET... ) so we need to address OTHER issues now - and there are lots. But we still have a lot of follow-up to do with regards to the CDT to be implemented this month, and any improvements that must be made to it, in the weeks and months to follow. Don't think this will all be swept under the rug - it won't.

I don't equate the occasional cyanide fish to tax cheating - those two issues are totally unrelated. I'm Canadian - I know what being taxed is about, so let's not go there. However, if I order "MAC CERTIFIED" fish, and there is still the possibility that I get juiced fish, there should be some sort of disclaimer to let the consumer know that no system is perfect - that there is some risk associated with this, since MAC facilities can still carry juiced fish.

More accurate comparison: Buying "organically grown" produce, but it's mixed in with pesticide, herbicide sprayed, hormonally treated produce - I am paying a premium for the "organic" stuff, because I've got my reasons for not wanting to get the adulterated stuff. If the organic produce comes from a farm that ONLY grows organic produce, and that's verified by the Department of Agriculture (betcha they didn't certifiy organic produce without testing for certain residues first...) then there's no danger of other stuff being mixed in - if I buy from a store that only sells organic, then I don't have to worry about another person along the way, mixing non-organic stuff in with the organic... IMO that's a more accurate comparison.

I don't think anybody here expects the system to be perfect. I certainly don't but I still think there are key things that should have been in place beforehand, that weren't such as the CDT and other safeguards, to make the process easier to monitor.

In my opinion, the fact that MAC certified facilities can still carry cyanide caught fish is a huge testament to the full scope of the problem - one could assume that those facilities couldn't get by on "only" MAC fish, they need the others to stay afloat. Tells me that the problem is still HUGE.

Jenn

 

[dizzy]

"I have a question here: Is this level of mixing strong enough an issue to get your undies in a bunch? Or is it sort of like cheating on your taxes... everyone does a little bit?

Am curious to hear the thoughts of others on this.
Regards.
Mike Kirda

Mike,
I actually don't think the cheating on this end of the chain will be as harmful as cheating on the other end. After reading Ferdie's letters it sounds like the net caught, better fish movement is growing. It is quite possible that cheating on this end may be nothing worse than taking a generic netcaught fish and using it to replace a certifed netcaught fish. Don't tell anyone, but they are basically equal anyway.

I'm afraid people are placing unrealistic expectations on the MAC fish. They will not be bullet-proof. They will still be affected by shipping stress and parasites. Here's a news flash for ya. Some of the MAC fish have already died. Is it possible? Yes in fact in talking to some of the MAC retailers they admitted MAC fish vary in quality from order to order, much like non-MAC fish. The goal of the CDT should be to raise the quality of all the fish from the Philippines and eventually Indo. It should not be used as a tool to try and force people into joining the MAC. I personally want better fish, but do not want to see a monoply created that effectively destroys the free market system.

 

[PeterIMA]

Jenn,
I am not sure that your last posting is related to my posting (the one preceding yours). I reiterate there was nothing wrong with either the sampling or the CDT work previously done by IMA under contract to BFAR.
The IMA has the expertise, the methodology, and the willingness the implement CDT. Funding is needed.


I agree with many of your points. The MAC CDT approach will only ensure that cyanide testing is done on MAC Certified fish. This is a very limited supply of fish at the moment. We are willing to talk to the MAC. So far, no MAC staff member has contacted IMA about CDT. It is not clear how they expect to implement the CDT they proposed.


Peter Rubec, Ph.D.
International Marinelife Alliance

 

[JennM]

Well I've read conflicting opinions about the CDT that was used in the past - not being firsthand privvy to it all, I can only take what I read at face value - seems to me that MAC had a problem with the IMA's CDT and that was why it wasn't implemented right out of the starting gate (or so that's what I was told by David Vosseler...) so they were looking for alternatives. Guess those alternatives weren't found so they fall back on the old standby - which begs the question, if it wasn't "good enough" to be used right away, is this a temporary fix, or is something "better" in the works? Inquring minds want to know.

"If at first you don't succeed, lower your standards" is what springs to my mind.

I'm not personally passing judgement on the testing that the IMA used, just reiterating what I was told... too many conflicts here for my simple little mind to grasp.

So no MAC rep has contacted the IMA yet about implementing this? Hmmm, how long will it take to put into place when they do make that contact? OR does MAC have another way to implement it, bypassing IMA?

Glad I'm not holding my breath, but I'm still on the edge of my seat

Jenn

 

[dizzy]

Jenn,
It sounds to me like MAC may have finally eaten a piece of that humble pie some of us were offering. (Inside AMDA joke) Perhaps Peter's test was never really that bad to begin with. Perhaps there was some of that professional jealousy that scientists are so famous for, at play here. Not invented here syndrome so to speak. Regardless of the reasons it should be considered welcome news. If an even more effective test can be developed in the future that will be even better news. Congratulations to Peter for receiving the reputational reprieve he deserves.

 

[mkirda]

Perhaps Peter's test was never really that bad to begin with. Perhaps there was some of that professional jealousy that scientists are so famous for, at play here. Not invented here syndrome so to speak. Regardless of the reasons it should be considered welcome news. If an even more effective test can be developed in the future that will be even better news. Congratulations to Peter for receiving the reputational reprieve he deserves.

Mitch,

Well put.

Jenn,
Does it really matter what their reasons were?

In talking to Peter Rubec, even he will admit that the test they used was not perfect. Cyanide ion gets metabolized into thiocyanate, which their test did not register particularly well. Cyanide itself is excreted and metabolized, so the selective ion test is only good for a few days after capture. It is far better than the earlier alternatives. But to say that some new method might not show better promise would be wrong. (Peter, correct me if I am wrong in any of this.)

One thing was abundantly clear to me- MAC is pissed off at themselves for being so far behind where they wanted to be right now. They wanted a CDT in place already, but no laboratories have stepped up and applied for certification. If they are going to put in place the best test available to them at the moment, and are looking to the future where a 'better' test can be put in place, are we going to harp on them for this? Heck, we got what we wanted. (Assuming it all gets implemented properly...)

I was given a timetable of 6 weeks. So the time for input is NOW.
Don't waste your time and energy on figuring out the reasons WHY.
Instead use it to give them your hopes and concerns: How to do it and do it right.

Regards.
Mike Kirda

 

[PeterIMA]

Mike,

You asked me to correct you about your last message. The IMA was able to detect cyanide ion in marine fishes 2-3 weeks after they were collected. It is totally wrong to state (as a flawed report prepared by the MAC stated) that cyanide ion was only detectable for a few hours after the fish were collected.

I can provide letters from Dr. Ellen Gonter (who helped develop the test used by IMA and approved by American Society of Testing and Materials-ASTM), Dr. Martin Frant (Thermo-Orion who developed the Ion Selective Electrode-ISE), and Dr. George Dixon (University of Waterloo). They all agreed that the the conclusions reached in the MAC report were flawed, and that the test conducted by IMA (documented by ASTM) was reliable.

I have sent documentation to Lee Morey and to Wayne Ryan and others (forget who) substantianting what I am saying. The MAC lacks the expertise. So far, they have not provided any information to Reefs.org explaining what cyanide test method will be implemented, and who will do it.

Peter Rubec

 

[mkirda]

The MAC lacks the expertise. So far, they have not provided any information to Reefs.org explaining what cyanide test method will be implemented, and who will do it.

Peter Rubec

Thanks for the correction, Peter.

MAC will probably not post here anyway- Methinks they would prefer us all to go on an extended holiday. LOL.

John, someone from the MAC should call Peter.

Regards.
Mike Kirda

 

[JennM]

Well forgive me if I'm not quite ready to celebrate until the test is implemented. Saying and doing are different things, although I'm willing to acknowledge that postive steps are apparently in the works. There is so much conflicting information floating around out there, it's hard to keep score.

6 weeks - that puts us into Mid-June, not May like the initial post in this thread says. The rest remains to be seen.

That will be step one....when it happens. There are still many obstacles to overcome - and yes, the journey of a thousand miles begins with a single step, but meanwhile there are other fires to be tended....

Jenn