1 Frithside Street
Fraserburgh
Aberdeenshire
AB43 9AR

Ms Lynn Beverley 26 March 2009
Food Standards Agency Scotland
6th Floor, St Magnus House
25 Guild Street
Aberdeen
AB11 6NJ

Dear Ms Beverley

Review of Agency's Advice on Fish Consumption

This response is on behalf of the Scottish Pelagic Sustainability Group (SPSG) after consultation with its member organisations. The Member organisations of SPSG are:

• Scottish Pelagic Fishermen's Association representing all the owners and crews of Scotland's pelagic vessels

• The Scottish Fishermen's Organisation representing the majority of Scottish fishing vessel owners in all fishing sectors

• The Shetland Fish Producers Organisation representing all sectors of the fishing fleet based in Shetland

• Shetland Catch Ltd a major processor and exporter of pelagic fish

• The Herring Buyers Association representing the major UK primary and secondary processors of pelagic fish

Further details of SPSG are available on the website at www.scottishpelagicsg.org
There is no re-examination of the current advice on fish consumption viz. two portions per week, one of which should be oily fish. A portion is stated to be 140 grams.

The real question posed by the review is as to whether the Agency should enlarge its scope to advising on sustainability issues. As part of the argument for this, the point is made that to reach the consumption of one portion of oily fish per week would require an additional 237,000 tonnes of oily fish and this could put pressures on sustainability sources. This is unlikely as it is unrealistic to extrapolate that consumption will rise in an orderly fashion towards this. One suspects that the public are no more likely to eat two portions of fish per week than they are to eat five portions of fruit or vegetables per day.

In the unlikely event that consumption of oily fish did reach the FSA guidance level, we contend that the supply of fish is available to meet such a demand as the Atlanto-Scandian herring (ASH) quota alone is in excess of 1.6 million tonnes per year and presently a fair proportion of landings from that fishery go for reduction to meal and oil because there are insufficient human consumption markets. The spawning stock biomass of Atlanto-Scandian herring is estimated to be over 12 million tonnes and the stock is fished well within precautionary limits.

There is no doubt that to extend the Agency's remit to sustainability issues would go beyond Professor Philip James' recommendations and the subsequent Food Standards Act. Both clearly expressed the over-riding objective as "the protection of public health in relation to food".

The question then is whether this is justified and/or desirable. The opinion of the pelagic industry we represent is negative for the following reasons:

• Cost - no doubt more staff will be needed to provide this information. At present the tax payer pays for the Agency and, especially in these straightened times, no additional costs to the tax payer can be justified. As the review rightly says, most of this information is handled adequately by organisations more closely involved with fish.
• The provision of sustainability information to the public requires knowledge and expertise. There are sensitivities which cannot be foreseen by the unwary. For example a major food retailer is questioning whether any sustainability information should be put on product packaging as the size of the pack or label would have to be increased to carry the information and that has its own environmental implications. It is worth noting that no less than Saatchi and Saatchi are working with the Marine Stewardship Council on communication to the public.
• We would feel that industry and their customers are more able to handle the sustainability information responsibly.
• Focus - the Agency should not allow its focus to be diverted from food safety issues. Bad publicity on a food safety issue can be devastating to the industry concerned. The areas of the condition of the fish stocks, scientific advice, etc would require considerable effort to master.

For these reasons we do not consider that the FSA should enlarge its scope to sustainability issues and given the strong views of the SPSG on this subject we take this opportunity to request a meeting with the FSA to discuss these issues in greater detail.

Yours sincerely

Derek Duthie
Company Secretary