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.
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.
Wayne
