We are deeply concerned with the proposed policy to include labor standards into MSC's Fishery and Chain of Custody (CoC) programs. With a carefully structured approach, the MSC could serve a positive role in this space by encouraging transparency in fishing supply chains and using your position as a well-regarded environmental certification program to encourage meaningful social dialogue that could address labor problems in the industry. However, the voluntary self-declaration approach currently proposed is utterly insufficient. It carries a serious risk, in fact a near certainty, that fisheries will paper over serious abuses and has the potential to seriously undermine implementation of genuine reforms that might be more effective in addressing labor concerns.

It would be nearly impossible to determine that “the client/applicant fishery or supply chain is free from forced and child labour in their operations,” even with a comprehensive and ongoing monitoring process. Noting that the MSC is undertaking work to “simplify and reduce the cost of the assessment process,” it is irresponsible of the MSC to allow certified fisheries to make such a sweeping claim about absence of forced or child labor based on the limited methodology proposed. The consequences for workers of certifying poor working conditions as safe has been dire in other sectors. A paper published in 2015 found that in the previous decade 1,800 workers had died in factory fires and building collapses in garment-producing facilities that had been audited and certified as compliant with voluntary corporate codes.[1]

We believe this proposal poses a significant risk to the credibility of the MSC and urge a more measured approach. If MSC is not going to invest the resources required to implement an effective labor monitoring mechanism (more on how to develop effective labor monitoring is included in our detailed comments below), it would better serve its mission by either not entering into the labor space at all or working with worker organizations to incentivize particular changes that could reduce the likelihood of workers being trafficked, such as mandatory vessel tracking systems with public reporting on ship movement and prohibition on transshipment at sea.