16. Water Certification (Pt. 2)

The four certifiers examined here also have different approaches to dealing with the potential diversity of water characteristics. Water can be a complex issue and the way in which a certifier chooses to deal with this can speak more gore generally how they perceive the system they are trying to govern. Upon cursory examination the standards appear to fit into two basic forms, one that sets fixed and quantifiable standards for water or, in the case of GlobalGAP, a more process based approach that requires the applicant to define their situation and provide the solution to it. The SQF, PAD and to a lesser extent Naturland fall into this first category with very clear numerical standards for some of the parameters presented in table 1. The SQF standard lists four biochemical water quality parameters and imposes strict limits on them and PAD lists at least six. Reducing water to a number of fixed parameters is a very simple and clear way to deal with issues of water quality. Naturland discusses the same kinds of water quality parameters as SQF and PAD, but only in a relative sense, stating:

“Water quality of source water should not become significantly deteriorated (standard value <10% of the parameters determined) due to the farming operation.”
(Naturland 2008)

This is a slightly more complex measure that allows for some differences in source water quality between different sites. I should mention that PAD also includes this <10% clause in addition to their strict water parameters. Naturland and PAD also look beyond simple water quality. PAD includes requirements about the total volume of water used per tonne of fish produced, and prohibiting the discharge of pond sludge to public waters. Naturland also instructs farmers in farm construction, things like inlet and effluent placement and the construction of settling ponds to minimize effluent nutrient concentration. The approach of these three certifiers appears relatively insensitive to potential diversity amongst farms applying for certification.

GlobalGAP takes a different approach to the problem of water quality. In their standard they mention the same kinds of biochemical water parameters and instruct applicants to assess their local situation and devise a plan for dealing with it. They have requirements for a written Environmental Impact Assessment, Environmental Management Plan, and a Water Quality Monitoring Program. The standards provide some guidance as to what elements these written plans should include, but in the end it is the responsibility of the applicant to write their own standards. This approach certainly allows for sensitivity to the local situation, but also introduces other potential complications in the form of a complex and long process of applying and obtaining certification, discussed later in this section. These different approaches of prescriptive and process standards may demonstrate different philosophies of the certifiers. The prescriptive standards reduce water to simple resource that does not vary in order to be able to implement the standard in a simple way. The GlobalGAP methodology does not make as many presuppositions about water quality, but allow the applicant to describe it, a process that is not very simple.

The same approach seems to be in play as regards flexibility of the governing system. The strict prescriptive standards do not leave any space for changes in the system, particularly unexpected, short-term and cyclical changes. The GlobalGAP system provides some flexibility to deal with expected short term and cyclical changes, but unforeseen changes are harder to compensate for. All of these different certification systems provide for a standards review process, a way to change the standards to reflect changes in reality. However, I was not able to determine what the timeline would be for these reviews, how quickly could a standard be changed? My involvement with the WWF PAD over one and a half years demonstrates that the generation of standards can take quite some time. The multi-stakeholder process of PAD may be a little different from the other processes, so standards generation cycles could potentially be quite a bit shorter. However, a lack of good observational data of these certification schemes in operation means that any discussion about their ability to change the standards themselves is highly speculative. In practice the GlobalGAP approach appears to allow a little more operational flexibility, so long as the applicant is cognizant of how and why their water quality can change over time.

There are also some differences between the certification schemes in how they include different kinds of knowledge in the system. Measuring water in terms of biochemical parameters and volumes reduces water to a simplistic system, but requires a certain level of technical knowledge. This is relatively simple technical knowledge, but may not be based on the knowledge systems of the applicants. Additionally the simplified prescriptive water standards exclude local knowledge about water quality and impacts on local environments. Most importantly all of these standards introduce a requirement for a new kind of knowledge, bureaucratic knowledge of certification schemes. How does a farmer obtain certification? Who do they have to pay? What kinds of documentation do they need and how do they obtain it? GlobalGAP with their contextually sensitive and flexible methodology also create the greatest need for this kind of knowledge. Generation of the various water management plans not only requires farming knowledge, but also usually requires the hiring of various consultants to help applicants translate practice into a process document. GlobalGAP is clear about the necessity of outside consultants and provides links to various certification services from their website. The truth is that all of these certifications will likely require hiring a technical consultant, but none more so than the GlobalGAP process. The choices of these certifiers delimit what is appropriate and valuable knowledge for farmers to have.

Although it is implicit in all of the standards, it is not explicitly mentioned that the target for these interventions is the farmer. It may not seem to be important to mention this, but there is a tension between the action of the farmer and the existence of a wider system that has an impact on and is impacted by water quality and pollution. GlobalGAP is very clear in the introduction to their aquaculture standards that they “recognize that other land uses, people and species depend on these same ecosystems” (GlobalGAP 2009b). The core ethical principles of IFOAM and the introductory remarks of PAD documents also acknowledge that aquaculture is part of a wider system. Interestingly SQF introduces their environmental and social responsibility modules from the perspective of a market demand for these kinds of certification, not a fundamental ethical principle. Regardless, despite these certifiers initial justifications, the standards themselves are devoid of references to existence of other systems, except insofar as the farm is having an impact on them. The Naturland quote above is probably the simplest, clearest example of this. By doing this, standards setters appear to including only farmers in the system and none of the other potential system actors who participate in water quality.

In this section I have examined how certification systems deal with the issue of water quality, and summarized my basic findings in table 2. The certification schemes that I examined using guidance documents and their technical standards can tell us something about how certifiers choose to include, and how to be sensitive and flexible when addressing the perceived problems related to water quality in aquaculture operations. Specifically the certification systems focus on different internal and external impacts of water quality and pollution and may or may not allow for diversity and dynamism in water. Also, and perhaps more significantly, these standards require very specific kinds of knowledge, and focus their attention exclusively on farmers, despite acknowledging that fish farmers are part of a wider system. This is a simple but important observation about how certification schemes define the limits of the systems they are trying to impact. In the following section I will examine another production issue addressed by these standards, hatcheries and seed, using the same methodological perspective I have applied to the issue of water quality.