SEAT Global

Posted on October 26, 2011 by admin

Public Consultation on the 2^nd Draft Fairtade Standard for Shrimp Small Producer Organisations (SPO) and Processors

Consultation response on behalf of the Sustaining Ethical Aquaculture Trade (SEAT) research project (www.seatglobal.eu)

Submitted by Dr Francis Murray, SEAT research project co-ordinator

Institute of Aquaculture, University of Stirling, FK9 4LA.  Email: fjm3@stir.ac.uk

Introduction

Comments are given separately on the SPO standards (Section A-1 = comments on specific standards, Section A-2: responses to the consultation questions) and processor standards (Section B). Finally we also comment on the stakeholder engagement process underpinning the dialogue (Section C)

The comments incorporate the opinions of SEAT consortium members from Bangladesh Agricultural University – Bangladesh, Kassetsart University – Thailand, Can Tho University – Vietnam and Shanghai Ocean University – China.

SEAT context and contribution

Where possible comments are informed by analysis of results of a survey of 200 shrimp farmers recently conducted by the SEAT consortium over 2010/11, in each of the following four countries Bangladesh, Thailand, Vietnam and China. In Bangladesh the 200 farmers included both shrimp and prawn farmers. Opinions of other value-chain actors, including those involved in processing were canvassed through key-informant interviews and stakeholder workshops.

Our definition of small-scale summarised in the table below is very consistent with that proposed by Fairtrade.

	Scale classification criteria	Small farms
1	Ownership of business (NOT land)	Household or extended family
2	*Full-time labour  (non-family)	None
3	Farm management	Household or extended family

SEAT survey scope: Farm selection for the SEAT survey (referred to above) was based on stratified random sampling with farm-scale (small, medium and large) as a primary stratification factor. Asian farmer systems are very diverse – to improve generilsability, farm selection followed a multi-phase sampling strategy based on the following sample-frames:

Bangladesh – UNID0 registration records for over 170,000 shrimp and prawn farms in SW and SE   Bangladesh – validated at Mouza or Para level.

Thailand – Aggregate DoF data to district level – followed by extrapolation of geographical data embedded in Fish Movement Documents (FMD) of the national export traceability scheme.

Vietnam – Aggregate DoF data to district level – followed by collection of commune level farmer lists.

China – Aggregate DoF data to district level – followed farm identification using Google Earth satellite images and ground-truthing.

A-1. Comments on the SPO standards

Title: ‘Fairtrade Standard for Shrimp Small Producer Organisations’

The standard applies to both (peneid) marine shrimp and (macrobrachium) freshwater prawn – consistent with FAO definitions of shrimp and prawn. To avoid confusion we suggest that this is reflected in the title of the standard i.e. standards for shrimp and prawn producer organisations.

Geographical scope:

We note the proposed limitation of the scope of the Fairtrade standard in China i.e. excluding hired labour, contract production etc. While we appreciate their may be sound reasons for this it would be helpful to know the justification.

1.2 Small-scale definitions

We think these boundaries are reasoned and internally consistent – we suggest the following amendments:

1.2.5 (Year 0) – ‘…10% of the total number of ponds registered as part of the Fairtrade organisation’

- Presumably this requirement refers to each individual SPO – phrasing should be clearer

- Membership should be limited to one SPO to prevent farmers with more widely distributed farming interests avoiding the 10% pond and other proportionality limits.

– Pond size and capital requirements can be very variable – at one extreme ponds could be taken to include small nursery structures. We suggest the definition should include an area dimension.

- More bio-secure operations also use storage ponds for water treatment. Although more common in larger farms – this is still to be encouraged i.e. by differentiating dedicated treatment ponds (not used for alternating production) from the total culture area.

The industry in Thailand has already undergone significant consolidation over recent years and we the great majority of farmers here although family-run, farm intensively and can be classified as medium-sized by hiring permanent staff. They will therefore be excluded from Fairtrade participation under its definition of small-scale as well as other standards supporting less intensive production. Of the four countries in the SEAT project, based on current status, we see greatest need and relevance for Bangladesh, followed by Vietnam.

Some of the smallest farms (1-2ponds) in Thailand are operated on a franchise or bonus system by migratory labour; often families or couples living on-farm. Such workers, typically from Laos, Burma or Isaan in NE Thailand seem to be representative of the groups whose lives Fairtrade are trying to improve. However they will probably be excluded if simply viewed as full-time workers for absentee owners. We suggest further contextualisation of the range in terms of engagement for these groups to explore potentials for bringing them under the standard.

1.2.2 (Year 0) ‘Farm work is mostly done by your family’

Family definition requires further clarification i.e. how inclusive can this be in terms of extended family. In Bangladesh, homestead living arrangements incorporate a range of resource sharing arrangements by extended family units – under such circumstances limiting work to immediate family may be too restrictive.

1.3 You are part of the community

1.3.1 (Year 0) – ‘Shrimp farming is conducted with the agreement of the legal and traditional local community authorities’

We find it very positive that legal pluralism is explicitly considered – but how will tensions between systems be dealt with in practice? – this is a particularly important issue in Bangladesh

1.3.2 (Year 0) – ‘You must grant access to communities traditional collection grounds’

- Requires a precise definition of traditional and community? For example does this include access to wild-sourced shrimp/prawn PLs (if so there is potential for contradiction with other standards)?

1.3.3 (Year 0) ‘… you must draw a community map….’

We think the mapping is a very good approach – however we are aware that leasing arrangements can be very fluid in some cases – we suggest a requirement for revision of the maps on a yearly basis. The maps should also specifically show polders (dams), drainage and distribution canals. Shrimp farmers Bangladesh are routinely criticised for causing salinisation, preventing alternative agricultural land-use. However cause and effect are often unclear (shrimp farming can be an important mitigation response to climate induced salinisation). We therefore suggest that it important consider impacts of SPOs on other communities/ land-users within the same polder enclosures.

1.3.4 (Year 0) ‘register of producers, third parties etc’ 1.3.5 ‘grievance procedures etc’

Our Vietnamese partner felt there could be difficulties implementing this and other social requirements  – if they were perceived to interfere with or over-ride commune-based administrative functions in any way.

1.4.5 (Year 1) ‘As a Fairtrade group, you must collectively purchase all inputs for your farming recommendations’.

We agree that this requirement can help deal with traceability difficulties that can become increasingly acute with decreasing farm-scale – furthermore this will be particularly important in Bangladesh where feed contamination has been a major issue (see comments on 3.2.1 below).

Other standards (i.e. capping the extent of individual farm ownership of members) that aim to limit potential for elite-capture should also have positive spill-over effects in relation to input procurement. However we feel further procurement-specific safeguards should be considered, that place limits on individual business links to input provision.

There may context-specific difficulties in applying this standard to ‘all inputs’. For example, where the spatial and temporal requirements for micro-distribution of inputs are especially pronounced in the absence of effective long-term storage or cold-chain systems.  Impacts on the diffuse networks of small-scale vendors who often meet these requirements should also be considered.

2 Trade

2.1 Traceability and 2.5 Premium Payments

2.1.5 (Year 0) ‘Records… ref to sales docs….’, 2.1.6 (Year 0) ‘Records… amount before and after processing’ 2.1.7 (Year 0) ‘…Fairtrade mark…’

Just as the Bangladesh shrimp and prawn farming sector is highly segmented so are post-harvest value-chain segments involving large-numbers of intermediaries in the auctioning, pre-processing and cold-chain delivery of products to processors. We think that implementation of a workable traceability chain of custody system under these conditions – and there transmission of the Fairtrade premium based on the ‘pass through model’ (2.5.2) will be an almost impossible challenge. Furthermore this model could not operate within the prevailing auction-system based on micro-distributed chatals (collective auction houses). The growth of these decentralised businesses is a recent innovation that has added value and brought demonstrated benefits to farmers compared to the earlier depot system based on farm-gate sales. This leaves the ‘direct payment model’ based on direct contracts with (certified) processors as the only practical option. Consideration should be given to how such a direct contract system will affect small-scale intermediaries – particularly the diverse range of stakeholders relying on chatals for their livelihood.

We suggest detailed mapping of the existing post-harvest value-chain segments between producer and processor as an SPO requirement.

3. Environmental Protection

3.1.4 (Year 6) – ‘You must have improved your production practices to become certified to an ISEAL or IFOAM members standards for shrimp production”

Given the Fairtrade goal of proactively seeking to support small-scale farmers we have some concern on reliance on other ISEAL or IFOAM compliant standards to ensure environmental compliance.

WWF for example has a broad goal of targeting the 20% of the best performers with an (unproven) assumption that the remaining 80% will also be encouraged to progressively improve their standards. The response of these and most other standards setters to small-scale exclusion is to make provision for collective groups to share the transaction costs of certification. While there is a clear synergy here with Fairtrade’s approach (and their SPO expertise) – many of these costs will still accrue to individual farmers and will therefore have to be met by a sufficiently high price premium.  Six years is a generous allowance for progressive improvements – but this still appears to be an arbitrary decision. Our survey results show that only 5% and 20% of small-scale farmers in Bangladesh and Vietnam respectively presently keep any form of written records – a fundamental traceability requirement, while other factors such as feed contamination (see below) are beyond their control in the absence of fully vertically integrated standard. We suggest the decision (whether and how long to delay compliance) should be based on demonstrably better understanding of the compliance costs of available ISEAL compliant schemes to individual SPO members based on required changes to their current practice. This should be contextualised to broad recommendation domains i.e. small-scale Bangladeshi farmers are likely to require considerably longer to adapt their management practices (if economically feasible) compared to small-scale Thai farmers.

3.2.1 (Year 0) ‘You may not use antibiotics on your farm’.

We think a clear justification is required as to why the standard does not allow for the prudent use of legal antibiotics, which can have positive impacts on animal welfare as well as economic outcomes. This ban also seems somewhat inconsistent with the permissible use of pesticides i.e. organic status is clearly not an aim here.

From a food safety perspective – the imposition of adequate withdrawal times should involve relatively straightforward recommendations as should public health recommendations relating to safe handling and usage.

We suggest the main justification would be due to the poor diagnostic capacity of small-scale farmers (or access to such capacity) which in turn leads to indiscriminate, even prophylactic applications. However, this would logically then apply to the use of many other therapeutants directed at pathogenic agents with none-specific gross clinical indications. This being the case, standards could realistically only aim to reduce usage through recommendations on efficient delivery. Levels of environmental and indirect human health risks relating to antibiotic microbial resistance (AMR) are very difficult to determine and poorly researched – however some basic recommendations could also be made in this respect.

If the main justification is to counter the negative image of the industry due to food-scares resulting from contamination with residues of banned antibiotics – such a recommendation is unlikely to have significant effect in Bangladesh where the problem is also most persistent. Here, the main source of antibiotic residues in shrimp and (especially) prawn is from contaminated feedstuffs. As this adulteration occurs ‘upstream’ of farmers they cannot reasonably be held accountable – rather this points to the need for a feed standard. This is also likely to be a problem in India where some of these contaminated raw materials originate – though lower export levels may have masked the problem to some extent.

3.3 Pest management

We are finalising a risk analysis of chemical use in Bangladesh, Thailand, Vietnam and China – we propose to comment further on both pesticide use and Annex 2 (Prohibited materials list) when this is completed. Interim comments are given below:

3.1.2 It is difficult to envisage how persons without some appropriate training (according to 3.1.1) would be able to make a reliable farm risk analysis? This is a complex task and can lead to vague plans whereby farmers do not understand what exactly they have to do. We suggest a more specific definition of risk analysis is given to encompass what could be reasonably expected. Could the standard also incorporate a mechanism to support appropriate training?

3.2.1 A complete ban on antibiotics could lead to imprudent use of other chemicals including probiotics for which a risk assessment cannot yet be done in part because of the ambiguity of their chemical and bacterial formulations – or fungicides (with anti-microbial action) which may be more environmentally hazardous than antibiotics. As it will be a challenge to monitor use of antibiotics and there are good reasons for their use in some instances – we suggest that antibiotics approved and registered for aquaculture-use, be permitted. If so – recommendations should also be made on prudent use including dosages, frequencies of application, and avoidance of prophylactic use where possible (contingent on available diagnostic capacity).

One of the objectives of the PRA within SEAT is to rank antibiotics according to their potential environmental hazard, to support such decision-making.

3.3 It is unrealistic to expect SPO members to reliably know which pesticides are ‘less toxic’ than others as farmers will generally think in terms of efficacy, rather than in terms of environmental persistence or effects on non-target organisms or humans.

3.4.1 We suggest modifying the 3rd bullet point to: How to prevent and how to handle accidents and spills when applying pesticides. Standard 3.4.3 should be similarly modified.

3.4.4 Many of the pesticides listed are commonly used in rice production. If you also plant rice, does it mean farmers are no allowed to use them anymore as this could compromise rice productivity?

3.4.6 We suggest this refers not only to water courses that might be used by human activities – rather all kind of watercourses, in order to prevent toxicity to aquatic ecosystems.

3.4.8 (Year 3) ‘You must compile a list of pesticides used on your farm and keep it update, min 3yrs’

All extensive shrimp and prawn farms are integrated production systems. Levels of fish production and in the case of prawn farms, pond-dyke crops and alternating or concurrent rice production are likely to exceed shrimp or prawn production in volume if not value. We suggest the standard should explicitly state that this requirement refers to pesticides applied for all crops whether farmed concurrently or alternately.

There can be significant interaction effects associated with the application of chemical ‘cocktails’. We also suggest that combined use practices are also documented and recommendations given on the avoidance of especially adverse combinations.

Comments on Annex 2: Prohibited Materials List

Amoxicillin is an antibiotic, so antibiotics are banned this could be deleted from the list to avoid redundancy.

Dichlorvos (red list) is the by-product of Trichlorfon (amber list). It implies that farmers can use trichlorfon. If so, they will have some dichlorvos residues in their farms.

3.5 Soil and Water

3.5.1 (Year 0) ‘You must not practice saline/brackish shrimp water farming in fresh water habitats …(salinity <1ppt).

We endorse the exclusion clause ‘where farmers can demonstrate the that the salinity of the main receiving water body is >1ppt outside the peak rainy season….’ This makes provisions for alternate shrimp / prawn farming in transition areas – which can represent a sustainable mitigation strategy.

However many of the salinisation conflicts relating to bund cutting etc are concentrated in transition areas – so we suggest a more precise definition and refinement of this standard is required – what constitutes the peak rainy season for example – and who would be responsible for measurements?

3.5.2 (Year 0) – Typological error:  In the guidance section – ‘The use of surface freshwater for salinity control….” – should read the use of ‘sub-surface water’?

3.5.5 (Year 0) ‘…>2,000kg/ha/cycle… implementation of effluent treatment and sedimentation systems…’ &

3.5.6 (Year 0) ‘…>2,000kg/ha/cycle implementation of… pond sludge removal and deposit on their farms’

Our survey results in Bangladesh indicate the following production averages for small-scale farmers as follows: prawn farmers 0.07/ha/cycle   (SD 0.07) and for shrimp farmers 0.12kg/ha cycle (SD 0.13). While In Vietnam the figure for small shrimp farmers was 0.09kg/ha/cycle (SD 0.09). Therefore in terms of avoiding unreasonable additional financial burden on the small-scale farmers – the cited level of 2,000kg/ha/cycle appears to be a reasonable cut-off point for requirement of ‘effective sludge-removal systems’.

However a better definition is required as to exactly what “effective” (3.5.5) and “proper” (3.5.6) means e.g. settlement times, permissible discharge suspended solid loads etc. and how this should be monitored.

Finally the requirement to ‘deposit sludge on their farms’ is vague; does this mean the owner’s farm, any SPO farm, or any local farm including none SPO members? The first definition would be most rigorous from a bio-security perspective.

3.5.7 (Year 1) ‘…shared water way maintenance…’, 3.5.8 (Year 3) ‘… water quality monitoring….’, 3.6.1 (Year 0) ‘…where water used in production comes from….’

In Bangladesh this requirement is complicated by the relative lack of dedicated distribution and drainage structures compared to other countries – notably Vietnam.

In their absence – many extensive shrimp farmers will periodically fill and drain ponds through their neighbour’s ponds. This potentially complicates requirements for individual compliance against the above standards.

3.5.8 (Year 3) ‘You must monitor and document effluent water quality…’

What is the purpose of the monitoring, choice of parameters – and against what limits?

Effective monitoring regimes require careful consideration of sampling protocols in space and time – monthly point measurements taken to fulfil this criterion are likely to be of limited value. Small-scale farmers in Bangladesh and Vietnam are also unlikely to have capacity to measure many of the suggested parameters. We suggest that greater consideration be given to the practical utility/ interpretation of such measures and that they also be limited to farms with harvest biomass >2,000kg/ha/cycle. Extensive shrimp farmers adding little or no direct feed input to their ponds could also be excluded from this requirement.

3.7 Waste

3.7.2 (Year 6) …Waste disposal… Farmers should be encouraged and rewarded for the value-added recycling of waste and co-products e.g. composting or anaerobic digestion of mortalities or culls – as these techniques should also enhance bio-security.

3.8.1 (Year 0) ‘You and your members must not use genetically modified shrimp….’

The following statement in the intent and scope to this standard: ‘GM organisms do not contribute to the sustainability of producers in the long run’ – appears to be an ideologically rather than evidence-based statement. We feel this should be phrased more neutrally. For example – work on disease resistant transgenic shrimp could potentially have positive sustainability impacts. There are complex environmental, food safety and consumer acceptance factors that can be used to justify a precautionary stance – but we feel that this should not be taken to imply that transgenic organisms could never be sustainable.

3.9.1 (Year 0) ‘…you must not farm P. monodon or M. rosenbergii with stocking densities above 10 PL/m2 or L. vannamei with stocking densities above 60PL/m2’

On page 4 it is stated that the standards refer to “Penaeid shrimp and M. rosenbergii – yet this particular standard refers specifically to stocking of P. monodon and P. vannamei. Does this mean other pennaeids could be stocked at any level – or does it imply they are only permissible if naturally recruited?

Otherwise the stated levels appear consistent with the discrimination of small-scale farmers as in standard 1.2.5 – though it should be made clear that these levels are over and above any natural recruitment of PLs.

3.10 Feed

Re. Intent statement – see comments on feed contamination against standard 3.2.1 v potential restrictions on market access for certified feeds.

3.10.1 (Year 0) ‘You must be currently be measuring FFER and eFCR’ &

3.10.4 (Year 0) ‘… from feed supplier… declaration of all species used in feed production…’ &

3.10.6 (Year 0) ‘Economic feed conversion’ &

3.10.7 (Year 0) ‘Feed Fish Equivalence Ratio’

Suggest changing to ‘you must immediately commence measurement…  etc. – if you are not doing so already’. In our survey only 20% and <5% of small-scale farmers in Vietnam and Bangladesh currently report keeping written records of feed usage – where feeds are manually applied.

While eFCR and FFER practically combines quantitative and qualitative dimensions of feed use efficiency – we think it will be very difficult to produce reliable FFER measurements – particularly in Bangladesh given problems with feed adulteration, labelling and provenance etc (3.10.4).

eFCR retains a useful qualitative dimension by discriminating against use of more polluting on-farm ‘wet’ feeds compared to ‘dry’ commercial pelleted feeds.  In our survey in Bangladesh, only 47% of small-scale shrimp farmers reported use of either commercial pellets or on-farm feeds (made from raw materials). Of this proportion just under half (47%) used commercial pellets in an (estimated) range of 20-375kg per cycle, whilst 85% used on-farm feeds in a range of 20-850kg per cycle. The supplementary application of these feeds in naturally productive flood plain and or fertilised systems means very few extensive farmers should struggle to achieve the specified eFCR levels for either P. monodon (2.1) or L. vannamei (1.7). In our Vietnam survey only 5% of small-scale P. monodon farmers the specified level – conversely it is unlikely discriminate significantly between more extensive small and more intensive medium or large scale farmers – most of whom already farm within these levels by using higher levels of commercial feed inputs and lower levels of ‘wet’ feeds.

By incorporating stock losses, eFCR is also a useful indicator of effective disease management – however it could unfairly penalise farmers subject to high poaching levels. Prawn farmers in Bangladesh may be relatively badly affected due to the high value of large individual animals close to harvest and their relative ease of capture.

3.10.8 (Year 3) You must source feed containing only fish from a fishery that is MSC certified, … or IFFO improvers programme… once such fish becomes available in your area’

The caveats applied by Fairtrade to this requirement clearly reflect the practical difficulties that most small-scale farmers will face in compliance within the stipulated 3-year period. We suggest this be extended to 6 years – and the last clause be extended ‘once sufficient quantity of such fish becomes available in your area’.

Here again we question how far farmers can be held accountable for the composition of commercial diets – and again we suggests this points to the need for integrated feed producer standards.

3.10.5 (Year 1) ‘… must plan to source none-GM ingredients within 5 years…’

The rationale for this is not clear and like the anti-biotic ban (3.2.1) appears to be precautionary rather than evidence-based. As with the antibiotic ban this is inconsistent with standards on pesticide use that already precludes organic status. Furthermore soya represents one of the most likely substitutes for fishmeal – yet most internationally traded soya already has GM status.

3.11.9 (Year 3) – Our survey results show that in Bangladesh no small-farmers were aware whether or not their fry had been PCR tested. In Vietnam, Thailand and China the proportions were 24% 78% 95% respectively. We feel this requirement should be adjusted to reflect national development status. Thailand and China have SPF programmes – Vietnam is in transition and this could support positive development – however we feel it should be relaxed in Bangladesh – where 99-97% of medium and large farms (themselves a small proportion of the total farm number) also responded negatively.

Small-scale (P. monodon) shrimp farmers in Vietnam still rely heavily on wild-sourced broodstock (i.e. none-SPF) while in Bangladesh small shrimp and prawn farmers use wild sourced fry and hatchery raised fry from wild-sourced broodstock.  While wild fry sourcing has negative environmental consequences – most small Bangladesh farmers consider hatchery-reared fry to be more risky than wild in terms of survival rates (extensive shrimp farmers also still rely partially on natural recruitment through water-exchange). Furthermore the value-chain configuration i.e. most shrimp nurseries in the SE and most production in the SW means it is very difficult for farmers to reliably know whether fry are PCR tested – the standard of testing is also likely to be highly variable. It therefore seems unreasonable to hold farmers accountable to this requirement – even over the proposed 3 years – in the absence of vertically integrated standard – which also covers hatcheries, testing laboratories and other value-chain intermediaries involved in seed distribution.

3.13 Animal welfare

3.13.0 (Year 0) ‘You must stun all shrimp immediately after harvesting by hypothermia…’

Amongst seafoods, shrimps are particularly susceptible to rapid decomposition – thus taken togethor with this welfare requirement – icing at harvest appears pragmatic. However, the remoteness of many extensive farmers in Bangladesh, lack of electricity, combined with micro-harvesting patterns would make this very difficult under current value-chain conditions. Most icing currently takes place immediately after at auction – at auction centres typically located within an hours transport distance from harvest points. Shrimp are transported live or dead to these points; mainly by farmers themselves using a diverse range of locally available transport.

The implementation of this requirement combined with icing at source would be contingent on collective harvesting of economically viable transport units for direct sales to processors i.e. to avoid re-icing. As indicated above this implies a significant value-chain reconfiguration (see comments on section 2) potentially including establishment more localised collection/ ice-distribution points for remoter SPOs (could the Fairtrade premium (section 5) contribute here?).

We also suggest or more precise definition of what exactly constitutes ‘immediately’ after harvest?

4 Labour conditions

4.5.6 (Year 3) ‘Where possible you and the members of your organisation must assign all regular work to permanent workers’

This appears to contradict standard 1.2.2 – ‘you must not hire permanent workers all year round’

4.6.5 (Year 0) ‘… must provide clean drinking water, clean toilets, hand washing facilities close-by, clean showers for workers handling pesticides.

Provision of such facilities is likely to be very difficult in Bangladesh – many shrimp farms lack even road access.

A-2. Response to consultation document questions (if not answered above)

Q1/2. See comments on 3.3 (response pending)

Q3. Do you agreed with the proposal to introduce this category without a Fairtrade minimum price?

Yes – this would also result in less market distortion for none-SPO farmers.

(although we disagree agree with the assumption that different sizes cost the same to produce)

Q4.  … Farmgate or ex-works should be used as the reference of Fairtrade premium levels?

Yes – though please see concerns regarding potential impacts on the auction-base trading norm in Bangladesh (comments on section 2)

Q5. … which of the amounts below do you feel is the appropriate level of Fairtrade premium…?

Shrimp and prawn are low-volume high value products – as volumes for extensive production are particularly low and potentially erratic – we suggest a level toward the upper end of the suggested range.

The level could also be proportionate in part to development status – either (most crudely) at national level – or linked to suitable local indicators for which data will be collected as part of the standard i.e. levels of farming intensity.

Q6. … Should workers in factories processing Fairtrade shrimp also benefit from the Fairtrade premium…?

Yes.

The high ratio gearing of labour intensive processing compared to farming jobs means there are usually more individuals occupied in the former sector. Processing, unlike farming also includes a high proportion of female workers. The re-distributive potential of a processor Fairtrade premium is therefore clear. Mechanisms for effective female decision-making in the utilisation any such funds should also be stipulated.

By targeting processing employees – the interventions would presumably focus on measures to improve working conditions or other social benefits i.e. rather than direct product quality improvements – an option for producer-owners. Weighing this against the relative numbers of actors involved – the overall premium level could be slightly lower than that paid to farmers.

The precise level of premiums for Q4 and Q6 – should be sufficient to cover the transaction costs of collective management of the scheme as well as providing sufficient incentive for individuals to directly or stimulate value-chain improvements. This in turn requires an understanding of existing socio-economic and livelihood characteristics.

B. Processor Standards

4. Freedom of association and right to collective bargaining

In Bangladesh there are documented cases of factory operators undermining Union representation through intimidation or constructive dismissal of representatives.

Finding and effective mechanism for monitoring and enforcement of the above sub-set of standards, especially standard 4.4 will therefore be especially critical.

5. Conditions of employment

5.11 (Year 0) ‘Maternity leave shall be no shorter than 8 weeks inc. annual leave….’

5.17 (Year 6) ‘Maternity leave if <12wks must be inc. by 1 wk/yr until 12 weeks is reached’

These are particularly important requirements given the high level of female employment in the processing sector. The financial cost of progressive increased leave allowance could therefore also be considerable – particularly countries with high birth-rates such as Bangladesh. Could this be an area to which the Fairtrade premium could provide additional useful support?

5.13 (Year 0) ‘All regular work is undertaken by permanent workers.’

Most processors in Bangladesh are working at significant under-capacity; levels as low as

15-20% are unexceptional, with poorly targeted processing and export subsidies contributing to weak performance. Extensive farming is also more subject to seasonal production fluctuations (though there is some synergy between shrimp and prawn availability) than more intensive systems. Consequently demand for processing labour can also be very seasonal. Under these conditions a more precise definition is required as to exactly what constitutes regular work.

C. Comments on the standards development process

We have observed that effective stakeholder participation in standards setting dialogues, even those achieving ISEAL compliance is complicated in practice by a range factors including

-          Access to electronic communications

-          The dominant language of the dialogue both technical and vernacular.

-          The opportunity cost of voluntary participation in time and forgone labour

These factors tend to discriminate against the small-scale enterprises that are the main focus of these particular standards. We commend Fairtrade for it’s recognition of these difficulties and their responses including local language translations and country missions to solicit the opinion of local stakeholders and key informants.

However to assess how far such opinions can be generalised, it also important to know how stakeholders were selected and likely gaps in coverage along with other methodological detail. This is particularly critical given the diversity of shrimp farming-systems in Asia. To better understand such variability, SEAT has applied a multi-phase sampling strategy in its work with farmers in four Asian countries. Results are currently being analysed and we hope that they can continue to help inform development of the Fairtrade standards.

Secondly, given the voluntary nature of participation it is inevitable that institutions with greater financial resources and vested interests in the outcomes of the standards will have a disproportionate contribution to the dialogue process. To improve transparency – in addition to the current aggregate summaries – we request that Fairtrade list the institutional affiliations of all those contributing comments.

The current standard relates only to farmers in SPOs and processors.  There are substantial numbers of other small-scale intermediaries servicing the micro-dispersed extensive farming systems in question.  The collectivisation of farmers into SPOs is itself a form of consolidation, which could have significant consequences on the livelihoods of these actors (and potentially none-SPO farmers). We suggest some assessment of the likely impact and possible mitigation strategies is incorporated into the design process e.g. through value-chain mapping and analysis.

Finally in our experience of contributing to other (ISEAL compliant) standards dialogues we found the decision-making process to determine which comments were or were not acted on to be very opaque. We suggest standardisation of the following responses to specific recommendations: i) further clarification required or suggested adaptation, ii) adopted or not adopted, iii) justification for adoption or none-adoption.