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GOVERNMENT RESPONSE TO THE FOURTH REPORT OF THE STANDING COMMITTEE ON FISHERIES AND OCEANS

Ensuring a sustainable and humane seal harvest


PREAMBLE

The Government of Canada welcomes the opportunity to respond to the 4th Report of the Standing Committee on Fisheries and Oceans on Ensuring a Sustainable and Humane Seal Harvest.

There are six species of seals found off the Atlantic coast of Canada – the harp, hooded, grey, ringed, bearded, and harbour. Of these six, harp and hooded seals account for almost all the seals harvested commercially. Seals have been harvested for food, fuel, shelter, fur and other products for hundreds of years. Seal products consist of leather, oil, handicrafts, and meat for human and animal consumption as well as seal oil capsules rich in Omega-3.

In recent years, commercial licences issued to sealers averaged 11,000 per year, although not all licences may be used in a given year. The seal harvest is an economically viable activity and therefore not subsidized by the Government of Canada. Seals are a valuable natural resource that provides income to between 5,000 and 6,000 individuals and their families in remote towns and villages at a time of year when few other economic opportunities exist. Seals are also an important source of food -- and a focus of social and cultural life – for Aboriginal communities throughout Atlantic Canada, Quebec, Nunavut, and the Northwest Territories.

Although sealing may seem to be a minor industry within the larger economy, many locally-important industries share this characteristic. For example, crop production and forestry each account for less than 1% of Canadian Gross Domestic Product, but their local economic importance is undisputable.

Sealers’ income depends on the market value of seal pelts and report that the income derived from sealing can represent 25-35 per cent of their total annual income. Markets for seal pelts are subject to significant variation from one year to the next. The 2006 seal harvest was one of the most profitable in memory; the landed value of the harp seal harvest was $33 million. Sealing presents economic benefits to remote, coastal communities where employment opportunities are limited.

The seal harvest is closely monitored and tightly regulated to ensure the animals are killed in a quick and humane manner. Fishery Officers monitor sealing activity on the ice, ensure humane harvesting practices, and enforce regulations and licence conditions. Fisheries and Oceans Canada works with veterinarians, experienced sealers and industry representatives to ensure the animals are dispatched and processed in the most humane way possible. The Government of Canada has strict regulations to ensure a humane harvest. Canada’s Royal Commission on Seals and Sealing found that the methods currently used in harvesting seals compare favourably to those used to kill any other wild or domestic animals. In addition, an independent veterinarians report published in the Canadian Veterinary Journal also found that the large majority of seals taken during the seal harvest – 98% -- are killed in an acceptably humane manner.

The Canadian seal harvest is a sustainable, economically viable activity based on sound conservation principles. The Government of Canada takes seriously its role as steward of the environment and of wildlife. It is committed to the sustainable management of its renewable resources. The Government of Canada generally agrees with the Committee’s recommendations and is pleased to say that we are already actively working on a number of the recommendations of the Standing Committee on Fisheries and Oceans and we will continue to actively defend and promote our interests at home and abroad.

Recommendation 1
In response to the observation made by the European Commission with respect to the use of humane harvesting standards in the Canadian seal harvest, the Committee recommends that the Minister of Fisheries and Oceans and the Minister of Foreign Affairs invite their European counterparts to participate in the establishment of a joint Canada-Europe inter-parliamentary working group to examine the Canadian seal harvest in the context of broader wildlife welfare and management issues.
Furthermore, the Committee recommends that the Government of Canada, as a NAFO member state, request that the ICES/NAFO Working Group on Harp and Hooded Seals review the findings of the various expert working groups on the Canadian seal harvest, and provide scientific advice on the humaneness of the harvest.
Response

The Government of Canada’s Embassies and High Commissions in Europe use diplomacy and advocacy to demonstrate that the seal harvest is humane, sustainable, well-managed and regulated, and assert Canada’s opposition to boycotts and bans on seal and seafood products. Since Non- Government Organizations (NGOs) have targeted legislators in Europe, Canada has become more active in this area. Canada received a delegation of European Parliamentarians in November 2006 and Canadian Parliamentarians have been very active in promoting our interests at the Permanent Assembly of the Council of Europe. The Canadian government will continue to engage European Parliamentarians by inviting them to view the Atlantic seal harvest so that these activities are well understood. The Government of Canada offered its full cooperation to the European Commission in its assessment of the degree to which the seal harvest is humane. The Government of Canada agrees that the establishment of a joint Canada-Europe inter-parliamentary working group would provide another valuable forum designed to give a more balanced view of the Canadian harvest and therefore, likely to have a positive influence on European Parliamentarians. The Government of Canada has conveyed to Europeans that the methods used in harvesting seals compare favourably to those used to harvest any other wild or domesticated animal.

The ICES/NAFO working group on harp and hooded seals would not be the proper body to provide advice regarding the humaneness of the harvest. The members of this group are not veterinarians and do not have the proper expertise required to determine whether seals are being killed according to veterinary standards. The group’s primary role is to provide advice on the status of populations and catch quotas. However, we continue to rely on the advice from the Independent Veterinarians Working Group (IVWG).

Recommendation 2
The Committee recommends that Inuit and other seal harvesters be invited to participate in Canadian delegations whose mandate is to discuss the matter of the Canadian seal harvest abroad.

Response

In March/April 2007, DFAIT organized a delegation mission to Europe to discuss the seal harvest in five European capitals, headed by Loyola Sullivan, Ambassador for Fisheries Conservation. Among many others, the delegation included 2 sealers from Quebec (one Aboriginal sealer) and 3 sealers from Newfoundland and Labrador, as well as the president of Inuit Tapiriit Kanatami and the Government Leader of Nunavut. The participation of harvesters and Inuit representatives was invaluable to the delegation’s messaging and Department of Fisheries and Oceans (DFO) and Department of Foreign Affairs and International Trade (DFAIT) will continue to work with them to communicate the importance of the harvest to their families and their communities.

Recommendation 3
The Committee recommends that the Department of Foreign Affairs and International Trade play a more proactive role in promoting the value of the seal harvest in Europe, particularly in the areas of public diplomacy, information and public awareness. The Committee further calls on the Government of Canada to reinstate adequate funding to public diplomacy programs to foster the ability of our missions in Europe to promote the value of the seal harvest.
Response

Foreign Affairs and International Trade Canada work in partnership with Fisheries and Oceans Canada to deliver messages on Canada's seal harvest to European audiences through both diplomacy and advocacy. DFAIT is committed to playing a proactive role in promoting the importance and value of the seal harvest in Europe. Canada's Ambassador for Fisheries Conservation, Loyola Sullivan, and DFAIT representatives will take advantage of every opportunity to raise the issue of bans against Canadian seal products, and importance of the seal harvest for coastal communities.

DFAIT has raised Canada’s concerns with the European Commission during the course of our regular consultations, at the Trade and Investment Sub-Committee and at the Joint Cooperation Committee. Canadian missions have called upon and written letters to the relevant Parliamentarians and Commissioners of the European Commission, and Ministers and Parliamentarians in Germany, the Netherlands, Belgium, Austria, France and the United Kingdom, among others, to express the Government of Canada’s serious concerns. Canada’s concerns were also raised by Prime Minister Harper with European leaders including Dutch Prime Minister Balkenende, German Chancellor Merkel and French President Sarkozy, and by Minister of Foreign Affairs MacKay and Minister for International Trade Emerson. In 2006, DFAIT held an information session for European Ambassadors to Canada to dispel myths and demonstrate that the seal harvest is humane, sustainable, well managed and regulated in Canada.

In 2004, 2005 and 2006, DFAIT, in cooperation with DFO, arranged for Canadian scientists to speak to audiences in Rome, Berlin, Brussels, The Hague, London and Bern outlining the facts and figures on seals in Canada, scientific studies and resource management analyses. In 2006 and 2007, DFAIT created and implemented an extensive advocacy plan on Canada's seal harvest, which sent a multi-disciplinary team to Europe led by Ambassador for Fisheries Conservation, Loyola Sullivan. This team was comprised of Aboriginal and Inuit representatives, provincial, territorial, industry and federal government officials.

The advocacy plan included targeted web content, as well as screenings of two films on the seal harvest: “My Ancestors were Rogues and Murderers” and “Phoque, le film” to audiences of European officials, members of non-governmental organizations, trade groups and the general public. DFAIT continues to build on the results of this advocacy plan as it considers advocacy activities on the seal harvest for 2007-08.

No reductions have been made to the amount of resources allocated to advocacy activities related to Canada’s seal harvest in Europe and elsewhere. In 2006-2007, DFAIT spent more on this issue than in previous years.

Recommendation 4
The Committee recommends that the federal government provide financial and logistical support to exhibitions on the Canadian seal harvest travelling in Europe and the United States.
The Committee further recommends that the federal government support financially the operations of the Seal Interpretative Centre in the Magdalen Islands, and examine the feasibility of establishing a similar centre in Newfoundland and Labrador.
Response

As part of its review of the most effective and appropriate advocacy activities for 2007-08, DFAIT will obtain additional information on the traveling exhibit of the Magdalen Islands Seal Interpretative Centre.

DFAIT, working with provinces, territories and industry, provided logistical and financial support for training and briefings of Canadian Embassy and consulate staff in the US on seal harvest issues in 2006 and would support continuation of this program in future years as required.

Recommendation 5
The Committee recommends that the Department of Fisheries and Oceans ensure that the seal harvest is managed and monitored more effectively, in particular by resolving technical problems that have allowed the harvests in some areas to exceed the Total Allowable Catch in 2006. The Department should allocate more financial and human resources to achieve this goal.
Response

In 2007, DFO implemented a number of management measures including increased monitoring to decrease the likelihood of quota overruns. These included: shorter and more controlled opening periods (possibly half-days for some fleets); coordinated regional management and monitoring plans; monitoring at dockside; mandatory hail-outs on departure for some fleets; and daily hails of catches for all sealing vessels, among other measures.

Cumulatively, these initiatives have had a positive effect. All allocations were respected in 2007.

Recommendation 6
The Committee recommends that the federal government promote a greater utilization of harvested seals, particularly marketing the meat and rendering the carcasses.
Responses

DFO will take this recommendation under advisement.

It is the Government of Canada’s ongoing policy to encourage full-utilization of seals taken in the commercial harvest. However, DFO has not been involved in product support or promotion activity in recent years. Its role is not to subsidize, but rather to regulate by ensuring sustainable and humane harvests.

The seal industry has had challenges developing markets for meat. Markets have developed over the years for other products such as leather, oil, handicrafts as well as seal oil capsules rich in Omega-3.

Seal fat is currently recovered at a high rate, attached to the pelts when they are landed. This is adequate supply for the burgeoning market for seal oil and nutriceuticals.

Recommendation 7
The Committee recommends that the Department of Fisheries and Oceans bring amendments to the Marine Mammal Regulations in time for the 2008 season, to implement the Independent Veterinarians’ Working Group’s recommendations. The Committee further recommends that the Department of Fisheries and Oceans investigate with added diligence infractions of the Marine Mammal Regulations.
Response

The Department of Fisheries and Oceans will continue to consult with industry stake holders for the purpose of developing appropriate amendments to the Marine Mammal Regulations, in order to implement the Independent Veterinarians’ Working Group’s recommendations. The Government of Canada has begun the process towards regulatory changes with the objective of having them in place prior to the 2008 harvest.

The sealing industry and DFO respect the intent of these recommendations and will continue to consult with the Independent Veterinarians Working Group on the practical application of some recommendations, such as a prohibition of shooting seals in the water which could have a detrimental effect on the fishery when poor ice conditions prevail.

DFO considers compliance with seal harvest management measures to be a high priority. It plans to continue to direct significant resources to monitoring of seal harvests in order to deter and detect violations. The Marine Mammal Regulations and license conditions relating to sealing (in particular humane killing rules) will continue to be strictly enforced.

Recommendation 8
The Committee recommends that the federal government continue to support the work of the Independent Veterinarians’ Working Group, while ensuring that its independence from the department or NGOs is preserved.
Response

The Government of Canada will continue to work with the Independent Veterinarians’ Working Group. This will be accomplished through consultations with the IVWG, logistics planning and provision of information as may be required.

The Government of Canada values the continued independence of the IVWG.

Recommendation 9
The Committee recommends that the Department of Fisheries and Oceans continue to allow the use of the hakapik in the seal harvest under conditions set forth by the Marine Mammal Regulations.
Response

The Department of Fisheries and Oceans continues to authorize the use of the hakapik under the conditions set out in the Marine Mammal Regulations.

A change in ice conditions can affect a sealer’s chosen harvesting method. Sealers in the Gulf of St. Lawrence, where about 25% of the harvest occurs, use both rifles and hakapiks. Sealers on the ice floes on the Front, where 75% of the harvest occurs, primarily use rifles.

DFO will be reviewing additional harvesting methods with a view to authorizing those that are humane. Any changes to existing regulations will be subject to the regulatory amendment process.

Recommendation 10
The Committee recommends that the Department of Fisheries and Oceans explore management and regulatory mechanisms to accommodate the short window of time that is available for the seal harvest.
Response

As an initiative in 2007, in consultation with sealer representatives, DFO established pre-determined 24 to 48 hour openings. This approach allowed sealers to plan their harvest within the timeframe allowed. In addition, a period of 48 hours between openings was established to allow DFO to compile numbers of seals harvested

This approach allows DFO to satisfy harvest requirements as well as its conservation and management objectives.

Recommendation 11
The Committee recommends that the Department of Fisheries and Oceans amend the Marine Mammal Regulations to specify the distance to be maintained between Seal Fisheries Observation Licence holders and the seal harvesting. The Committee recommends that the buffer zone be set at 100 metres. The Committee further recommends that where a rifle is used to take seals, the buffer zone be increased to 400 metres.
Response

Consultations began this year with respect to distances to be maintained between Seal Fishery Observation Licence Holders and seal harvesting activities. DFO is looking at appropriate distances given changing trends in the harvest and developing technologies and the need to balance the rights and interests of all involved. The courts have recognized that the observation of the harvest is a fundamental freedom enjoyed by observers under s. 2(b) of the Charter, which protects freedom of expression, and that, in regulating observation of the harvest, the Government of Canada must strike an appropriate balance between the observers’ constitutionally protected freedom of expression and the rights of sealers to legally pursue their livelihood without disruption. DFO recognizes that safety is also an important consideration which will be factored accordingly into its determination of appropriate distances.

Recommendation 12
The Committee recommends that the Department of Fisheries and Oceans amend the Marine Mammal Regulations to include a new wildlife observation licence to observe seals during the whelping period prior to the harvest opening. The new licence would specify that the observer not be permitted to disturb the seal and its pup by touching or approaching the animals closer than 10 metres.
Response

DFO will take this recommendation under advisement and raise this with stakeholder groups in forthcoming consultations.

The Committee is aware that there is a provision currently in the Marine Mammal Regulations which prohibits the disturbance of marine mammals. However, research published in the peer reviewed literature has shown that any disturbance caused to harp seals by typical tourist activities has little long term impact.

DFO is currently in the process of developing a regulatory proposal to control marine mammals watching as a recreational activity. Under these proposed regulations, DFO plans to establish a schedule whereby an approach distance for a given species in a given area can be specified.

Recommendation 13
The Committee recommends that the Seal Fisheries Observation Licence state clearly the condition that the observer obtain the express and informed consent of seal harvesters for any photographic material taken during the course of performing their activity.
Furthermore, the Committee recommends that all observers be clearly identified on the sealing grounds.
Response

As the Committee points out, seal fishery observation licences do include the following statement: "…it is recommended that photographs of fishers, identifiable as to a person, not be made without the express consent of the fisher involved." This is a matter that concerns the individual privacy rights of sealers and the constitutional rights of observers and is a matter to be resolved between the parties. For the purpose of the seal fishery observation licence, the current method of addressing this issue appropriately balances the rights and interests of all involved.

The Committee’s recommendation that all observers be clearly identified on the sealing grounds will be taken under advisement. DFO is generally satisfied that observers are sufficiently identifiable as such when on the sealing grounds, given their normal dress, activities and mode of transport; however, to the extent that this recommendation relates to visibility and any attendant safety concerns, DFO will take these concerns into account when setting the licence conditions, since increased visibility may be desirable for both observers and sealers depending on, among other things, the type of harvest and weather conditions.

Recommendation 14
The Committee recommends that the Department of Fisheries and Oceans re-examine the fees charged for Seal Fisheries Observation Licences to reflect the human, material and financial resources which are drawn upon for its monitoring.
Response

The Government of Canada will take the Committee’s recommendation under advisement.

The Minister of Fisheries and Oceans announced in April that the Government of Canada would undertake a review of commercial licence fees. The Government believes that a re-examination of Seal Observation Licences should not precede the commercial licence fee review.

Recommendation 15
The Committee recommends that the Department of Fisheries and Oceans ensure that the annual forum to discuss the seal harvest is held at a time and locations that are convenient for sealers and fishermen.
Response

It is indeed vital to engage the sealing industry in a timely manner in locations that are convenient for sealers and fishermen. For this reason, regional and local meetings are held to provide sealers additional opportunities to participate in discussions related to the harvest and management plans. In recent years, improved DFO web based media have facilitated increased participation with stakeholders.

The forum to discuss the seal harvest on an annual basis is through the Atlantic Seal Advisory Committee. The meetings are usually held in January each year as the harvest is prosecuted in March. The location of the meetings is rotated and takes into account the proximity, mobility and cost to sealers.

Recommendation 16
The Committee recommends that the Department of Fisheries and Oceans continue to set a total allowable catch of seals for personal consumption. Harvesters should be trained, hold the proper licence, and be able to sell the pelts of the animals they have harvested.
Response

The Department of Fisheries and Oceans will continue to set an allocation for personal consumption, first introduced in 1997. Sealers are already licensed for Personal Use and have received some training in humane harvesting methods.

With respect to the sale of pelts, the Government of Canada will take the Committee’s recommendation under advisement and will raise this with stakeholders in forthcoming consultations. Allowing sealers licensed for Personal Use to sell pelts will necessitate a change in license designation that would require widespread consultations with stakeholders to address such matters as governance, sharing, participation, eligibility and seasons.

Recommendation 17
The Committee recommends that, as a matter of priority, the Department of Fisheries and Oceans fund research to fill the gaps in our knowledge of the grey seal, to ensure that this species is properly managed.
Response

DFO Science has an ongoing research program on the population dynamics and ecology of grey seals in Eastern Canadian waters. This program has the dual objectives of providing advice on sustainable harvest levels of grey seals and understanding the role of grey seals in marine ecosystems, including their impact on prey species, such as Atlantic cod. Over the past several years, DFO Science has conducted studies on grey seal distribution and habitat use, on seasonal diet composition and in January 2007, carried out surveys to provide current estimates of pup production.

The Government of Canada recognizes that there is increasing debate about the possible negative impacts of seals on fish populations. The source of this debate is the growth in seal populations in eastern Canadian waters over the past several decades and the declines or, in some cases, collapse of fish populations to the point where fishing has been stopped.

As a result, DFO is planning an international workshop on the impacts of seals on fish populations of Eastern Canada. This workshop will be held in two parts, the first in November 2007 and thes second in the Fall 2008 to review new analyses and modeling results arising from recommendations of the first workshop. Six objectives have been identified for the workshop:

    1. to review research to estimate seal predation mortality on fish stocks in eastern Canada, with a focus on grey and harp seals,
    2. to review similar research conducted elsewhere that may help us to understand the effects of grey and harp seal predation on fish stocks,
    3. to review research on the effects of seal-transmitted parasites as a source of fish mortality,
    4. to review research on the negative indirect effects of seals on spawning success and feeding behaviour of fish,
    5. to review evidence that reductions in seal population size result in corresponding increases in fish population size and exploitable biomass, and
    6. to consider the design of experimental or other research that would clarify the impact of seals on the dynamics of cod stocks.

Although these presentations will focus on recent data from the NW Atlantic, experts from other countries will be invited to present information on these issues to provide a broad international perspective on the impacts of seals on Atlantic cod and other species of commercial importance. Participants from the Canadian fishing industry and resource management will also be invited.

The workshop will provide an up-to-date assessment of our understanding of the impacts of grey seals predation on fish stocks. In addition to the workshop, DFO continues to deliver the current science program on grey seals.

Recommendation 18
The Committee recommends that the grey seal harvest be allowed to take place on Sable Island and the Gulf of St. Lawrence.
Response

There currently is a TAC/harvest for the Gulf of St. Lawrence, but a harvest on Sable Island presents a challenge.

In 2004, a Total Allowable Catch (TAC) for 10,000 grey seals was established, to be harvested over a two year period in the waters of the Gulf of St. Lawrence and off Nova Scotia but excluded Sable Island. This TAC was further extended for a subsequent two years. This extension expired as of March 2007 with approximately 8,000 seals remaining in the TAC. Only a few hundred seals were taken annually. The TAC was extended to encourage the fishing/sealing industry to develop products and markets.

Although there has been considerable effort on the part of the industry, it appears that the market interest for grey seal product is limited and at best would only support a niche market at this time. There also appears to be a lack of interest at certain levels within the industry to pursue this initiative. This is evident by the level of unused TAC.

While there are no conservation concerns in respect to the development of a limited grey seal harvest on Sable Island, there are, however, a number of regulatory and environmental issues as well as the public concern for the islands flora and fauna that would have to be addressed prior to initiating any grey seal harvest program on Sable Island. These include, but are not limited to, the need to review and amend regulations associated with the Canada Shipping Act and Migratory Birds Convention Act, and issues within the Species at Risk Act.

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