The SASSI Initiative (2021)

THE SASSI INITIATIVE, AND ITS RELEVANCE IN 2021

Under the auspices of the WWF, the Southern African Sustainable Seafood Initiative came into being in 2005. It mirrors similar overseas Initiatives of the same calibre. It purports to rate seafood produce in relation to the individual resources or species sustainable strength, recommending to consumers as to whether such resources are in good health and well managed, or over fished, or fully protected, to prevent their possible demise. I have great reservations as to its effectiveness, accuracy, and practicality.

This is not to say that I do not support the overall principle of what they wish to achieve. I am in fact entirely in favour thereof, particularly if it will assist in reducing the illegal catching and sale of fish species that for the most part are under very real threat. These should be listed by the regulations, as most are, as species that may be caught only by Recreationals but never sold! Obviously, their exploitation will be subject to strict conditions.

Over the years, I have criticised this list in a manner that I believe has always been supportive, proactive, and logical; never negative towards the initiative in any way. However I have never had any response, positive or derogatory, from SASSI, the Fisheries Department, Business, or Recreational body. This list, aimed at the general public, retailers and restaurants, should be a very valuable tool towards protecting our very valuable inshore marine line-fish resources and other related species. Its supporters claim that many use the list continually, but I am aware, through my connections, that many more, including retailers, laugh at them pointing out the anomalies, inaccuracies, and conflicts with existing regulations, let alone pure logic.

They clearly do not listen to me. Therefore, I must assume that they do not consider it worth listening to anything I have to say! Then, the next obvious question probably is, why should they listen to me?

Well for a start, I am 83 years old, and, for 77 of those years, most of what I have done and achieved has been on, around, or related to the marine environment and its resources. I only retired from my last business in 2014, and ceased most recreational fishing, circumstantially, in about 2016. I spent many of those years as a skipper mainly in the Pelagic Purse-seine Fishery. However, I have also personally fished the following industry sectors: inshore line-fish, inshore trawl, crayfish, tuna, including pole caught, inshore and offshore crustacean, both locally and in four other African countries. Perhaps, as important as my experience, is that, from the age of twenty, the layman’s study of the Marine environment, its species, biodiversity, and its management towards sustainable exploitation, became my lifelong hobby!

Back to SASSI. It is simply that if you are going to influence the public, particularly when claiming to be supported by so many well-known sponsors, you have a duty, both to them and to the general public, to make absolutely sure that your facts are correct.

I am, of course, aware that the promoters of SASSI must depend on other bodies for their information. We all know that Scientists, by their very nature, are cautious in committing themselves towards the positives of many situations. Asking a Scientist to make a decision on anything, is always difficult, but that, after all, is the nature of the circumstances when one, in effect, is asking them to play God. However, remember that without them, we would never be able to make the extraordinary advances we do to our knowledge and technical abilities.

Their other main source should be the Fisheries section of the Department of Environmental Affairs, Fisheries, and Forestry. Like so many other Government Ministries, with one or two notable exceptions, they are run by incompletely educated, unskilled, and incompetent individuals. I will refrain from noting certain areas were other skills abound, but not towards their required responsibilities.

All I ask of SASSI, is to please be pragmatic; please don’t depart from your chosen path: but equally please don’t confuse the public at the cost of legitimate industry, and the jobs they create, as well as the public’s right to choose correctly. Below is their current listing, admittedly some five years old but the latest I can lay my hands on, which we will dissect through my admittedly limited layman’s scientific knowledge, but with significant anecdotal experience and logic.

THE SASSI LIST BIT BY BIT:

Generalisations

Only deal with edible fish or other marine species caught in waters off our coastline, with the exception of northern hemisphere salmon because we import so much. All other imports are insignificant in amount, and as a percentage of their source’s biomass. Other countries must deal with their own problems.

Only deal with edible species that are sold, or not allowed to be sold.

1. List the Recreational List, together with only the relevant Prohibited List edible species, as you do, in Red.

2. Forget about excluding some of the species allowed to be caught through the Departments list of allowable species that can be sold. There is scientific logic in saying that any resource, where there is enough of a biomass remaining to predate upon, can be sustainably harvested. Then the limit on landings must be scientifically calculated, strictly enforced with adequate regulations applied. Off course, the catch limits should allow for the anticipated remaining populations to replace the landings, less a reasonable % to ensure growth of the re-propagated biomass year on year. All Permitted Commercial species should be listed under “Green.”

3. There are two other factors to be taken into account about certain species on your Orange list, over and above their legislated acceptance as harvestable. The first is that market demand for them so far exceeds their availability, that the suggestion that anyone should think twice about eating them becomes irrelevant. There will, unfortunately, always be more than enough people, who do not subscribe to the list, wanting to eat them. The second is that, in a country as poor as ours with so many unemployed, should you have the right to try and negate an individuals legislated right to earn a living. I realise that the question becomes academic because of my first point, but the principle should always be remembered!

4. The fact is that both the last two points, in addition to putting you in conflict the Fisheries Department, simply cause confusion in the eyes of so many of us, who then simply ignore the List, and it’s potentially so very important message.

5. Please ignore three of your continually harped on points – the method of catching – farmed or sea caught – bycatch reservations. It has been reliably estimated that more than 50% of all edible fish landed is caught by bottom trawling with bycatch, and a so called, but mostly unproven, level of damage to the seabed environment. How would you replace that needed protein in an already underfed world population? Let the scientists and Government Authorities all over the planet deal with those problems, of which they are well aware! Then, to add to your lists confusion, you wish to ban or reduce landing of only some trawled species, but with the majority allowed! Lastly, who the hell knows what is farmed, wild caught, or any other necessary identification. Certainly not the man in the street who must be your main target, and almost certainly not many of the restaurants or any other retailer!

6. Let us now start with the Red List:

a) This List should be confined to Non-saleable species, as per Point 3 above.

b) It is clear that, until science can properly evaluate the current state of the specie, the “Seventyfour’s” resource, at least anecdotally, is more than sufficiently abundant to place it on the Recreational Primary (non-saleable) list. It has, after all, been on the Prohibited List for far too many years, because a proper re-evaluation has not been carried out! Five years of statistical records and other methods of research would then give us a true picture!

c) All the other items, except for “Biscuit Skate” and “Shortfin Mako Shark” are neither targeted intentionally, nor sought after as edible fare. Their bycatch landings are insignificant, and their resource mass unknown in SA waters, so it is unnecessary to list them at all.

d) Certain species here are, or will be, removed from all exploitation shortly, other than Recreational No Sale species. (See attached Recreational lists). You should therefore list “Black Musselcracker” and “Dagerard” under your New No Sale Red List accordingly.

e) “Kob is on the Green List already.

f) “Abalone” is a difficult question and highlights the many unavoidable problems encountered with your overall Initiative. Everyone knows it is potentially under threat. However, there is a strong belief that in many localities it has not returned to shallower waters due to illegal exploitation on a massive scale. Despite this, as a resource it has proved very resilient, and the Commercial dive quota remains. Furthermore, a large and growing aqua cultural industry exists. For the public to identify the difference between illegal, commercially harvested, and farmed product is impossible, so, despite logical misgivings, it must return to the Green List. The real answer is not to discourage people from eating same, when it is very expensive anyhow, but to see the relevant Authorities enforcing the law!

g) All the other Red List species belong, for all the reasons given above, on your Green List.

7. The Yellow list follows:

a) “Atlantic Salmon,” or any other pink salmon, is dealt with and should be returned to Green.

b) Who claims that wild harvested “Oysters’ are under threat, and they are harvested legally!

c) Namibia’s “Hake” resource is their problem. One knows it is a straddling resource with SA’s, but it is only conjecture as to how much exploitation of the one might affect the other.

d) Longlining for “Kingklip” almost certainly risks the sustainability of this species more than bottom trawling. It concentrates predation on the breeding stock of larger individuals that are located over the natural protection of rocky bottoms that the trawlers cannot access. The same goes for longline Hake.

e) SA’s “Prawn” and other trawled Crustacean resources are very fast growing, and, as has been demonstrated all over the world, broadly territorial. Please ignore bottom damage, as no one has yet being able to properly assess it, nor its importance, nor its rate of natural rehabilitation. These resources fluctuate dramatically year on year due to natural and manmade variations to their overall environment, rather than over-fishing.

f) Neither the inshore, nor offshore resource of “Octopus” have been properly evaluated, and offshore, being a different species, is inevitable bycatch. The inshore specie’s intertidal presence has been disturbed by the pure fact of an increasing population, up eightfold from one hundred years ago; not enough reason not to eat it!

g) “Sole” is much more prevalent off SA’s East coast, where its distribution is in areas generally heavily impacted by rocky reef intrusion with limited favourable bottom trawl conditions. One could have expected these circumstances to have afforded this resource adequate protection. However it is generally anecdotally seen as been over-fished, as catch rates have seriously reduced over recent years. It is, however, legally targeted, and, whether or not other factors can be determined as causing the decline in landings, should still be able to be caught, subject to effective quota limits.

h) Off the west coast, it is not directly targeted, representing only an apparently acceptable degree of bycatch.

i) “Swordfish” and other “Billfish” are caught of the SA coast in such small amounts making it quite unnecessary to consider they need protection. There local level of availability is completely an unknown factor.

j) Therefore all species on the Orange List should be on the Green List with Orange disappearing.

8. Now your Green List:

a) This is now complete, and I presume, adequately covers all (but not all) of the species either sold to the general public in supermarkets and fish shops, or consumed by them in restaurants, hotels, takeaways, etc.

b) One would then further presume that all edible fish not on the No Sale lists do not need to be listed, and are free to be eaten. Your Pocket Card should state this to avoid the public’s confusion. Otherwise that risks ending up negating your excellent intentions of preventing the sale of over-fished or vulnerable species.

c) As has already been covered, leave out all the additional small print comments. I hope that it now could be accepted that they are no longer relevant. They, also, then only add immeasurably to the possibility of the public’s confusion and resulting practical rejection of the Lists’ intentions.

I sincerely hope that all above criticisms and comments will be taken in the spirit that is intended. That is to improve SASSI’s very important effort to protect mainly our In-shore Marine Resources so seriously under the threat of over-exploitation. This is, for the most part, as a result of an under skilled, incompetent and under staffed, Department of Fisheries, being part of a dysfunctional Government.

I guess that in the ”Extremist” worldwide environment in which we find ourselves, WWF needs to also be extremist, to an extent, to ensure they are listened to. However, it appears to me that SASSI, with all the good intentions in the world, has set themselves up as both Judge and Jury with their advisory panels of “Experts” (Maybe?). This is a very dangerous route to follow, particularly if you do not seek truly independent advice!

ANNEXURES.

COMMERCIAL LINEFISH PERMITTED SPECIES LIST

INCORPERATING SIZE AND LANDING LIMITS

 

	COMMON NAME	SIZE	NUMBER	NOTES
		LIMIT>
1	BILLFISH	—	1
2	SWORDFISH	—	1
3	TUNA (THUNNUS SPP)	—	2
4	DORADO	—	_
5	YELLOWTAIL	—	_
6	WAHOO	—	_
7	KING MACKEREL (NATAL COUTA)	—	_
8	QUEEN MACKEREL (QUEENFISH)	—	_
9	LITTLE TUNA	—	_
10	LITTLE MACKEREL	—	_	ALL
11	CAPE SNOEK	600mm	_
12	SHAD (ELF)	350mm	_
13	SHARK	—	1	Excluding those on Prohibited List
14	RAYS	—	1
15	SKATE	—	2
16	MAASBANKER (HORSE MACKEREL)	—	_
17	KOB	600mm	_
18	GELLBEK (CAPE SALMON)	600mm	_
18	BAARDMAN (BELLMAN)	600mm	_
19	SILVERFISH (DOPPIE & GELOPENER)	300mm	_
20	PANGA	300mm	_
21	FRANSMADAN (KARELGROOTOOG)	200mm	_
22	HOTTENTOT	200mm	_
23	STEENTJIE	200mm	_
24	STREEPIE (KARENTINE	200mm	_
25	SANTER (SOLDIER)	300mm	_
26	HAKE (STOKVIS)	—	_
27	ROCKCODS	300mm	5
28	WRECKFISH	300mm	_
29	WHITE STUMPNOSE	250mm	_
30	BLACKTAIL (DASSIE)	250mm	_
31	DANE	300mm	_
32	ENGLISHMAN	300mm	5
33	RED ROMAN	300mm	10
34	RED STUMPNOSE	300mm	5
35	SCOTSMAN	300mm	5
36	SLINGER	300mm	_
37	SQUID	—	20
38	OCTOPUS	—	2
39
40

1) A Commercial Line-fish Permit holder shall be entitled to catch an unlimited amount of

fish from a vessel, not exceeding 30 metres in length, as listed in the above table as well as in the

Fish-bait list below, unless either list indicates a daily limit. Minimum sizes are also indicated.

2) The vessel’s crew shall not exceed the number for which it is registered and surveyed,

and only consist of certificated commercial fishers.

3) The vessel shall only depart and land at its nominated listed landing site or harbour. On

landing all catches, they shall be obliged to complete the relevant catch return forms,

submitting same to the attending compliance officer.

4) Fishing shall only be carried out in terms of the legislated Regulations, with rods and reels,

or handlines.

FISH-BAIT LIST

41	ALL SARDINES
42	ANCHOVIES
43	MULLETS/HARDERS
44	CUTLASSFISH//WALLA WALLA
45	GARFISH AND HALFBEAKS
46	WOLFHERRING
47	PINKY//ORGIE
48	GLASSY
49	MACKEREL(Scomber japonicas)
50	MAASBANKER//HORSE MACKEREL
51	SQUID
52
53
54
55

5) No nets may be used by a Commercial Line-fish, Artisanal, or Recreational Permit holder,

other than a Throw-net subject to Applicable Regulations.

6) Baitfish Catch Limits:

There shall be no catch limits applied to Commercial Line-fish or Artisanal Permit holders.

Recreational Permit holders shall be entitled to catch 20 in total of Baitfish, which entitlement

shall be over and above their daily catch limit of 5 fish.

INTERTIDAL BAITS AND OTHER ORGANISMS LIST

		SIZE	NUMBER	COMMENT
56	OCTOPUS		2	By gaff.
57	CUTTELFISH		2	By line.
58	MUD CRAB	140 mm	5	Carapace width.
59	MOLE CRAB		20	By hand.
60	ALL OTHER CRABS		10	In total. By hand.
61	MUD PRAWN		50	By suction pump, or presser.
62	SWIMMING PRAWN		50	By throw-net
63	SAND PRAWN		50	By suction pump.
64	BLACK MUSSELS		30	By hand.
65	SAND MUSSELS	35 mm	10	Shell width. By hand.
66	PENCIL BAIT/MUSSELS		10	By hand or suction pump
67	OYSTERS		30	By hand.
68	ALIKREUKEL//GIANT PERIWINKLE	40 mm	5	Shell diameter. By hand.
69	VENUS EAR//SIFFIE		2	By hand
70	ALL OTHER SHELLFISH		25	In total.
71	BLOODWORM		5	By suction pump or hand
72	ALL OTHER WORMS		10	Each. By hand or suction pump.
73	REDBAIT		2 KGS	Cut weight. By hand or gaff.
74
75

7) Intertidal baits may only be collected by Recreational and Artisanal//Subsistence Fishing

Permit holders subject to the applicable Regulations and Licence endorsements.

8) No size limits unless stated.

9) By hand. Where applicable, an appropriate small hand tool is permissible, but never a spade.

ARTISANAL//SUBSISTENCE PERMITTED CATCH LISTS.

10) Permitted species shall consist of the following lists. Please note the prohibited species.

a) The Primary Marine Recreational List, subject to a bag limit of FIVE fish in total per day,

and may not be sold.

b) The Commercial Line-fish species list may be sold, however with a limit of two only per

day for each of the following species: GEELBEK–KOB–ENGLISHMAN–SCOTSMAN—

RED ROMAN–RED STUMPNOSE–ROCKCODS—SHARKS.

c) SHAD–SLINGER shall be limited to 5 each.

11) Artisanals shall not be allowed to fish from a boat.

 

RECREATIONAL FISHING LISTS

1. Recreational Fishing may only be carried out by the holder of a valid Recreational Fishing Licence,

whether from a boat or other flotation device, or from the seashore beach or rocks, in an estuary,

or river, or dam, and by rod and reel, or handline.

2. No person fishing in terms of a Recreational Fishing Licence is allowed to sell their catch.

3. A prohibited specie shall not be targeted, and, if caught by chance, may not be landed.

4. The holder of a Recreational Fishing Licence is allowed only to land and retain a total of

FIVE fish per day, except for Baitfish as indicated on that List.

5. Fish species listed on the Primary Recreational list may never be traded or sold commercially.

6. Non-compliance with the above, or size and quantity regulations as indicated on the List, shall

result the cancellation of the fisher’s licence forthwith, and/or the imposition of a fine, and/or the

confiscation of angling equipment, and/or boat, and/or vehicle.

PRIMARY RECREATIONAL LIST

—	—-COMMON NAME—-	——–SPECIES——	SIZE>	NUM
			N/A
1	BAARDMAN-//-BELLMAN	Umbrina spp		2
2	BLACKTAIL-//-DASSIE	Diplodus sargus capensis		5
3	BRONZE BREAM	Pachymetapon grande		2
4	CAPE STUMPNOSE-//-RIVER BREAM	Rhabdosargus holubi		2
5	DAGERAAD	Chrystoblephus criticeps		1
6	GALJOEN	Dichistius capensis		2
7	GARRICK-//-LEERVIS	Lichia amia		2
8	JOHN BROWN	Gymnocrotaphus curvidens		2
9	KINGFISH	Caranx & Carangoides spp		5
10
11	LAMPFISH	Dinoperca petersii		5
12	POMPANO-//-WAVE GARRICK	Traehinotus botla		2
13	NATAL STUMPNOSE	Rhabdosargus serba		2
14	PERCH-//-RIVER BREAM	Acanthopagrus berda		2
15	P0ENSKOP-//-BLACK STEENBRASS	Cymatoceps nasutus		1
16	RED STEENBRAS	Petrus rupestris		1
17	ROCK SALMON	Lutjanus argentimaculatus		1
18	SEVENTY FOUR	Polysteganus undulosus		2
19	SPOTTED GRUNTER-//-TIERVIS	Pomadasys commersonnii		2
20	SPRINGER-//-TEN POUNDER	Elops machnata		2
21	STONE BREAM	Neoscorpis lithophilus		2
22	WEST COAST STEENBRAS	Lithognathus aureti		1
23	WHITE MUSSELCRACKER-//-BRUSHER	Sparodon durbanensis		1
24	WHITE STEENBRAS	Lithognathus lithognathus		1
25	WRASSES	Anchichoerops spp		1
26	WILDERPERD-//-ZEBRAFISH	Diplodus cervinus hottentotus		2
27
28
29

7. Commercial and unlisted species may be caught subject to the bag limit of FIVE fish per person per

day with the exception of those species listed with their limits below.

30
31		BILLFISHES	Istiophoridae spp		1
32		CAPE SALMON-//-GEELBEK	Atractoscion aequidens		2
33		ENGLISHMAN	Chrysoblefus anglicus		1
34		LITTLE MACKEREL	Various spp		2
35		KABELJAUW-//-KOB(SHORE)	Argyr0somus spp		2
36		KABELJAUW-//-KOB (FROM A BOAT)	Argyrosomus spp		2
37
38		NATAL COUTA-//-KING MACKEREL	Scomberomorus commerson		5
39		QUEENFISH-//-QUEEN MACKEREL	Scomberomorus plurinilineatus		5
40		RED ROMAN	Chrysoblephus laticeps		2
41		RED STUMPNOSE-//-MISS LUCY	Chrysoblephus gibbiceps		2
42		ROCKCODS	Cephalopholis & Epinephelus spp		2
43
44		SCOTSMAN	Polysteganus praeorbitalis		1
45		SHAD-//-ELF	Polysteganus umdulosis		5
46		SWORDFISH-//-BROADBILL	Xiphias gladius		1
47
48		TUNA	Thunnus spp		3
49		SQUID	Loligo vulgaris reynaudii		10
	50
	51
	52
	53
	54
	55
	56
	57
	58
	59

8. You may not land, disturb, harass, or have in your possession, these Marine Species listed below.

60	SEAL OR SEALIONS
61	WHALES OR ORCAS
62	PENGUINS AND SEABIRDS
63	ANY OTHER SEA OR ESTUARINE BIRDS
64	PORPOISES OR DOLPHINS
65	TURTLES
66	SEA OR RIVER OTTERS
67	WHALE OR BASKING SHARKS
68	BRINDLE OR POTATO BASS
69	COELECANTH
70	PARROTFISH (KNIFEJAW)
71	PIPEFISH OR SEAHORSE
72	SAWFISH
73	SUNFISH
74
75
76
77
78
79
80

9. Shark, rays, and skates may be landed, measured, and immediately thereafter returned to the

water.

10. Apart from the commercial fish denoted with limits above, you may land any commercial listed

fish within the confines of your bag limit. Your total landings of all fish caught must not exceed

FIVE in number. However you may land a combined total of 20 Baitfish, which will fall outside

your limit for other species!

11. No size limits will apply to recreationally caught fish.

12. The commercial list with size and number limits, where applicable, is attached for your information.

13. Crayfish, (Spiny Rock Lobster) everywhere along our coastline, 5 per person per day, subject to

permitted seasons.

14. Abalone, (Perlemoen) 1 per person per day, subject to same seasons as apply to Rock Lobster.

15. Arlikrikel, (Giant Periwinkle) 5 per person a day.

16. Bait regulations as they are presently.