MSC-Consultation-Survey-Export-CoC-Program-Review · Web view20. 20. 20. MSC - Chain of Custody...

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MSC - Chain of Custody Program Review public consultation - August 2018

Welcome to the MSC August 2018 public consultation

Thank you for your interest. This consultation forms part of the CoC program review and the outcomes will be included in revised CoC standards and requirements which are due for release in February 2019.

All feedback will be made public after the consultation closes on the MSC Program Improvements website. Comments will be unattributed but may be grouped by stakeholder type (e.g. Industry, CAB) where there are more than five comments for a stakeholder group.

Please add your contact details below before choosing which project you would like to provide feedback on. To avoid any issues with returning to the survey to edit your responses, please try to complete the survey in one go, ensuring to press 'Done' on completion.

* 1. Contact Information

First name*

Organisation*

Country*

Email Address*

Phone Number

* 2. I am responding as an:

* 3. Please confirm you agree to your responses being made available (unattributed) to the public on the MSC Program Improvements website?

I agree to my unattributed responses being published on MSC Program Improvements website

* 4. Please state the stakeholder category type which best describes you?

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The following topics are open for public consultation

There are four program developments in this consultation which make up the Chain of Custody program review. When you tick the program development you wish to provide feedback on, you will be directed to the relevant questions. You will also find a link to the associated consultation materials.

Once you have completed those questions you will have a choice of providing further feedback on other projects. Depending on your decision you will either be directed back to this menu page, or to the end of the survey.

* 5. Please select which consultation project you would like to provide comments on.

CoC Default Standard

CoC Group Standard & related requirements

CoC Consumer-Facing Organisation (CFO) Standard & related requirements

CoC Certification Requirements (CR) & General Certification Requirements (GCR)

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Consultation topic - CoC Default Standard

Here we seek feedback on the proposed text for the revised standard, which will be incorporated into a version of the MSC Chain of Custody (CoC) Default, Group and CFO Standards planned for release in February 2019. All changes can be viewed in the CoC default Standard draft here, and you can review other consultation materials her e . There are 4 significant additions since the September 2017 consultation summarised below in Page 1 with a consultation question on each. Page 2 then asks for your feedback on the other changes.

View the CoC Default Standard consultation materials >Read all the available consultation resources on the MSC Program Improvements website

Introducing a requirement that products shall not be mislabelled by species or fishery or farm origin.The objectives are to assure product integrity and improve clarity, by:

Supporting MSC and ASC's oversight work, which includes tracebacks and product tests that can identify mislabelling by species or origin. Such mislabelling can be indicative of risks which could also result in mislabelling of certified statusProvide clarity on how an auditor should handle such mislabelling, where currently there is inconsistency from no action to full suspension, this introduction requires at least a non-conformity and corrective actionAssure retailer/ brand owner claims on pack

This clause is specifically targeted at two defined claims is order to address the most relevant risk areas, whilst not significantly increasing audit burden. To see this clause in context open the CoC Default Standard and search #Mislabelling

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6. The proposed clause on mislabelling and associated guidance

Neither agree norStrongly agree Agree disagree Disagree Strongly disagree

Achieves its objectives

Is possible to implement

Has your support

Has clear guidance

If you selected disagree or strongly disagree for either of the above, please detail your concerns and suggestions for improvement

Requiring all subcontractors to provide access to products or records as needed. The amendment to this clausealigns subcontracted transport with existing requirements for subcontracted storage facilities, without burdening the clients with putting in place new agreements or requiring routine auditor verification. The objective is to assure product integrity by providing appropriate assurance at every step in the supply chain. To see this clause in context open the CoC Default Standard and search#subcontractors.

7. The proposed amendment to clause on subcontractors


Achieves its objective


Has your support


Requiring that CoC holders do not to have any association with illegal fishing.This relates to organisations with a link to fisheries, shipments, exports or imports. The objective is to align with industry trends where fishery managers, regulatory authorities and traceability systems increasingly prioritise prevention of illegal fishing. This proposal achieves this by

Requiring companies to have systems in place to reduce risks of association with illegal fishing, this relates to their whole business and is not limited to certified seafoodA non-conformity process relating to this which can lead to suspension if not addressed within the timeline (normally 30 days)

Note that individual non-certified transactions only need to be reviewed by an auditor where a risk is identified. To see this clause in context open the CoC Default Standard and search #IUU.

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8. The new proposed clause on no association with illegal fishing and associated guidance




Is auditable

Has your support

Aligns with systemsmost companies will have


Requiring exclusion of antibiotics or banned substances in products originating from certified farms. This relates to cases where the farm origin standard refers to such exclusion (e.g. ASC shrimp cannot be sold as certified where antibiotics have been applied, or substances banned by the country receiving the product cannot be applied to ASC Salmon). The objective is to assure product integrity. Specifically the requirements:

Mitigate the risks to farm product integrity where demand for a certified farmed product may exceed supply and therefore incentivizes substitution in the supply chainAddress stakeholder concerns relating to receiving product which is identified as farm certified but does not conform with the farm standard requirements for antibiotic or banned substance exclusion (especially regarding antibiotic detectionin ASC shrimp)

It requires companies which transform products to mitigate the risk of these containing the antibiotics or banned substances excluded by the origin standard (e.g. through product testing and contamination prevention). To see this clause in context open the CoC Default Standard and search #ASC.

9. The new proposed clause on exclusion of antibiotics and banned substances in farmed products and related guidance




Is auditable

Has your support


The changes you have just reviewed relating to association with illegal fishing, mislabelling by origin/ fishery/ farm and prevention of antibiotics and banned substances; extend the scope of the MSC CoC Standard beyond verifying traceability

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records back to a certified supplier. These changes are proposed to address stakeholder concerns and integrity risks. This will require additional auditing activities and in some cases additional systems/ costs for certificate holders.

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10. The additional effort is justified by the risk for

Justified Partly justified Not sure Hardly justified Not justified

Mislabelling by fishery/farm/ origin (2.3.1)

Association with illegal fishing (5.19)

Antibiotics/ banned substances in farmed products (5.21)

If you selected 'hardly justified' or 'not justified' please explain what you think MSC should do, and if MSC can address the risk in a different way

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Consultation topic - CoC Default Standard

Please give your feedback on other changes to the CoC Default Standard below, this includes those included in the 1-30 September consultation. You can review consultation materials, including the previous consultation here.

View the CoC Default Standard consultation materials >Read all the available consultation resources on the MSC Program Improvements website

Requiring verification of receipts from a fishery or farm are from the Unit of Certification (UoC).The objective is to assure product integrity at the start of the Chain of Custody. This shall be done by:

First Chain of Custody holders after the fishery or farm verifying that they can trace any product they wish to sell as certified to the relevant UoC.

For a fishery the UoC can include the gear type, catch area, harvest date and client group member, and potentially agents or auctions defined in the fishery assessment report on the MSC website.For a farm the UoC can include the sites, production units, ponds and harvest dates defined in the farm audit report on the ASC website.

MSC is working to make information on Units of Assessments more readily available on the MSC website to support the implementation of this clause. To see this clause in context open the CoC Default Standard and search #First receiver.

11. The new proposed clause on receiving from a fishery or farm and related guidance

Neither agree norStrongly agree Agree disagree Disagree Strongly

disagree Achieves its objective

Is possible toimplement

Is auditable

Has your support


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The CoC default Standard also includes other substantive changes, which can be found by opening the CoC Default Standar d and searching #general. These are identified in the draft document with comments boxes stating 'substantive change' and a rationale in each case, and in some cases additional questions. You can respond to these, or give any additional feedback below. All changes unrelated to the questions above can be found by searching #general.

12. Please enter additional comments below

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Would you like to provide further feedback?

* 13. Would you like to provide feedback on any of the other projects during this consultation?

Yes

No

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Consultation topic - CoC Group Standard

The objective of this consultation is to determine if the proposed changes to the CoC Group Standard and related CoC Certification Requirements sections are enhancing the accessibility for all users of the CoC Group Standard, in particular independent restaurants and fishmongers. It is intended to make these accessibility improvements without compromising integrity. In addition, we tried to address inconsistencies throughout the requirements and provide further clarification where needed.

View the CoC Group Standard consultation materials >Read all the available consultation resources on the MSC Program Improvements website

Question topic: Changes in the CoC Certification Requirements

It is proposed to reduce unnecessary complexity of the Group requirements by removing some of the mechanisms that trigger suspensions. The proposals only remove one out of five possibilities for an entire group certificate to be suspended.

Proposal A: Remove the need for all site non-conformities automatically to be raised against the Group Management. This requirement is especially burdensome for groups of independent entities.

Proposal B: Remove “major non-conformity reject table 10” and all related clauses. This requirement is adding unnecessary complexity and has not been effective.

Please refer to the detailed changes marked with #Group directly in the draft CoC Certification Requirements .

14. The suggested changes reduce unnecessary complexity

Strongly Agree Agree Not sure Disagree Strongly

Disagree Proposal A

Proposal B

15. Do you think that the balance between maintaining integrity and improving accessibility is maintained for the two proposals?

Maintains balance between

Causes a definite Causes a possible accessibility and Achieves Does not achieve integrity risk integrity risk integrity accessibility

partly accessibility

Proposal A

Proposal B

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16. Please enter any further comments and suggestions here, particularly if you have concerns about possible integrity risks caused by proposal A or B.

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Consultation topic - CoC Group Standard

View the CoC Group Standard consultation materials >Read all the available consultation resources on the MSC Program Improvements website

Question topic: Changes in the CoC Group Standard

We have received feedback that the Group Requirements are not always clear and in some cases even inconsistent. We have tried to address these problems via the four proposed changes below.

Please refer to the detailed changes marked with #Group directly in the draft CoC Group Standard.

17. The suggested changes improve clarity within the Group Standard

Strongly agree Agree Not sure Disagree Strongly Disagree

Clarifying mandatory internal on-site audit prior to adding new sites

Removing inconsistencies

between reasons for exempting a site from internal on-site audit

Clarifying process for internal audit findings

Including non- conforming product procedure to improve consistency

18. If you have any further comments on the Group Standard changes listed above, please let us know by referring to the relevant change.

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19. The CoC Group Standard is also used by fisheries/vessels. Do you see any unintended negative implications of the suggested changes specifically to fisheries/vessels/at sea entities using the CoC Group Standard?

Yes

No

Not sure

20. If yes, please specify any negative implications you could foresee, and any suggestions to mitigate this.

21. Do you have any other comments, suggestions or concerns about the changes proposed in the CoC Group Standard or relevant group section in the CoC CR?

Yes

No

22. If yes, please identify the relevant clause and explain your concerns including any suggestions you have for improvement.

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Yes

No

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Consultation topic - CoC Consumer Facing Organisation (CFO) Standard

Stakeholders, auditors and consumer-facing organisations such as caterers, restaurant chains, retailers and independent restaurants are invited to input on the revised MSC Consumer-Facing Organisation (CFO) Standard version 2.0 for release in February 2019.

Version 2.0 of the CFO Standard aims to provide greater efficiencies, accessibility and integrity to companies serving MSC/ ASC products at the end of the supply chain. Key changes can be viewed by searching ‘#CFO and #General’ in the CFO CoC Standard and CoC Certification Requirements.

There are two parts to this questionnaire:PART ONE: CFO Standard - relevant to consumer-facing organisations and certification bodies; PART TWO: CFO auditing and certification requirements - relevant to certification bodies, auditors and ASI.

View the CoC CFO Standard consultation materials > Read the details of the proposed changes to the CoC CFO Standard on the MSC Program Improvements website.

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PART ONE: CFO Standard

The main revisions to the CFO Standard were consulted on 1-30 September 2017. Following stakeholders feedback, we aim to present the final revisions for your endorsement.

Search '#CFO' in the CFO CoC Standard draf t >

A summary of key CFO Standard changes:1. Greater clarity on central management and eligibility for entry (CFO Standard p.6);2. Streamlined traceability requirements including better distinction between ‘operations’ and

‘consumer-facing’ sites and the removal of non-certified product record keeping for similar looking species (clauses 4.1-2);

3. An increased reporting on scope changes including notifying Conformance Assessment Bodies (CABs) when there is ≥ 25% site number increase, and to received CAB approval on new ‘operations’ site and sites in new country prior to site being added (clauses 5.8-9); and

4. Wider issues from Default CoC Standard revisions - To comment please select 'Yes' to other topic at the end of this CFO survey

View the CoC CFO Standard consultation materials >Read the details of the proposed changes to the CoC CFO Standard on the MSC Program Improvements website.

* 24. The changes on eligibility for certification to the CFO Standard


Improve clarity on eligibility

Have your support

Create no unexpectedbarriers to entry


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* 25. The changes on CFO Principle 4


Improve clarity for traceability requirements

Are possible to implement

Have your support


* 26. The change on reporting site number increase at ≥ 25% threshold


Is fit for purpose in maintaining integrity oversight


Has your support


* 27. The changes to seek Conformity Assessment Bodies (CABs) approval for new 'operations' sites and sites in new countries prior to being added


Are fit for purpose in maintaining integrity oversight


Have your support


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28. The CoC CFO Standard also includes other '#General' and substantive changes. These are identified in the CFO CoC Standard draf t with comments boxes stating 'substantive change' and a rationale in each case. We recommend that you respond on these points by entering the Default CoC Standard section of the survey. You can also give additional feedback below.

* 29. The overall CFO Standard improvements


Are fit for purpose

Have your support

Create no unexpectedbarriers to entry


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PART TWO: CFO auditing and certification requirements

Significant improvements are proposed to the CFO Certification Requirements to streamline auditing, maintain the Standard's credibility and effectiveness. Unlike the CFO Standard, this will be the first and only public consultation for all CFO audit process changes proposed for release in February 2019. These can be found by searching '#CFO' in CoC Certification Requirements and General Certification Requirements suspensions extrac t .

A summary of key changes:Additional CFO auditor competencies to demonstrate knowledge on management system auditing and sampling technique (CoCCR Table 1);New option for stratification by location (CoCCR 7.2.1-4) and limit critical non-conformity or suspension to a specific stratum (CoCCR 9.2-9.3 and GCR 7.4.9);Only audit operations sites involved in storage or distribution once during 3-year certification (CoCCR 7.2.9);Additional risk assessment criteria: (1) other accredited certifications and (2) CPI score (CoCCR Table 6);Changes to ‘Standard Risk’ CFO auditing activities including the removal of DNA sampling and increase the number of site audited (CoCCR Tables 8-9); andCAB approval of new operations sites and sites in new country (CoCCR 11.2.4).

View the CoC CFO Standard consultation materials >Read the details of the proposed changes to the CoC CFO Standard on the MSC Program Improvements website.

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30. The additional CFO auditor competency requirements



Are everything needed

to conduct a multiple site CFO audit

Create no unexpected barriers


31. The new option for CFO stratification


Is fit-for-purpose

Is clear and logical

Is possible toimplement

Has your support


32. The revised process of raising non-conformities and suspensions, including for stratified samples


Is clear and logical


Has your support


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33. The changes introduced to CFO risk auditing (tables 8-9)


Are logical and clear


Have your support



34. The CoC Certification Requirements also include other substantive changes. These are identified in the draft document by searching '#CFO' with comments boxes stating 'substantive change' and a rationale in each case, and in some cases additional questions. You can respond to these, or give any additional feedback below.

* 35. The overall CFO auditing and certification requirements


Are fit for purpose

Are clear for implementation

Have your support



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Yes

No

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Consultation topic - CoC Certification Requirements (CR) and General Certification Requirements GCR

The purpose of this consultation is to seek feedback on the proposed revisions to the MSC Chain of Custody Certification Requirements and MSC General CertificationRequirements planned for release in February 2019. These changes are intended to create efficiency, improve integrity and clarity.

View the CoC Certification Requirements (CR) consultation materials > Read the details of the proposed changes to the CoC CR on the MSC Program Improvements website.

Topic: Efficiency

To increase efficiency a review of approved variations was conducted, with the intention to incorporate these into the requirements where appropriate. As a result, the following changes have been proposed:

Proposal A: Extending the window for surveillance audits from 90 to 180 days on each side of the audit due date, with more specificity on the due date.Proposal B: Allowing CAB judgement on increased audit frequency or the need to go onsite when a company is eligible for remote audits, to be justified in the audit checklist.Proposal C: Simplifying the post audit steps by not requiring a report within 10 days of the audit.Proposal D: Not requiring subcontractor activities to be considered when determining if a trader can be audited remotely, as subcontractor compliance is verified separately.

The proposed clause edits can be read by opening CoC Certification requirements and searching #efficiency.

37. The proposed changes will achieve the objective of improving efficiencies


Disagree Proposal A

Proposal B

Proposal C

Proposal D

38. If you have selected “disagree” or “strongly disagree”, please explain why and provide suggestions for improvement.

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39. Do you think that the proposed changes add undue integrity risks?

Yes Not sure No

Proposal A

Proposal B

Proposal C

Proposal D

40. If you have selected “Yes” for any above, please explain your concerns and suggestions for improvements.

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Topic: Recertification

The MSC is committed to alignment with the Global Sustainable Seafood Initiative (GSSI) benchmarking tool requirements. These requirements (GSSI B.2.03.) state that a certificate can only be extended beyond 3 years in exceptional circumstances. It is therefore necessary to remove the reference to allowing 90 day certificate extensions on a general basis.

This means that certificate extensions can only be requested via variation requests in exceptional cases going forward and that certificates will automatically become invalid once their expiry date is reached.

With the increased flexibility now proposed in surveillance audit dates a CAB can hopefully prioritise recertification scheduling. Where CABs are seeking to conduct combined audits a reduced certificate validity could be considered.

In the CoC CR requirement s you can find these changes by searching #recertification.

View the CoC Certification Requirements (CR) consultation materials >Read the details of the proposed changes to the CoC CR on the MSC Program Improvements website.

41. Do you see any challenges implementing these requirements?

Yes

No

Not sure

42. If yes, please detail your concerns and any suggestions for improvement.

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Topic: Incidents/Fraud

As the food industry seeks to better address misclaims and fraud, we need to ensure our CoC program has robust mechanisms to deal with them. As a result, the following changes are proposed for inclusion:

Proposal A: New companies to declare association with previously withdrawn or suspended companies so the CAB can determine if certification can be issued.Proposal B: Applicants being required to declare any claims/logo misuse prior to certification. If evidence of misuse is provided for companies that have not declared it the CAB shall withhold certification or suspend it.Proposal C: Introducing mechanisms for MSC to escalate issues to a CAB between audits, and to allow non-conformities to be raised between audits.Proposal D: Reducing the timeline for a CAB to raise a non-conformity where a CoC holder fails to provide traceback data to MSC or ASC.Proposal E: Ensuring there are mechanisms for an auditor to follow product at every step of handling it, including verifying records of subcontracted storage facilities and accessing product in transport if an identified risk requires this.Proposal F: Increasing the use of unannounced audits on a risk basis, allowing a sufficiently big sample for MSC to review their effectiveness at improving integrity before considering if it is relevant to introduce more widely.

The relevant clauses can be found by opening theCoC Certification requirement s and the General Certification Requirements contract extrac t and searching #incidents/fraud.


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43. These changes achieve their objectives

Strongly Agree Agree Not sure Disagree Strongly Disagree

Proposal A

Proposal B

Proposal C

Proposal D

Proposal E

Proposal F

44. If you have selected “disagree” or “strongly disagree”, please explain your concerns and suggest improvements.

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Topic: Need for CoC

In this proposal we seek to improve clarity on the need for chain of custody, specifically in the following areas:

Proposal A: Clarifying that although a subcontractor may seek their own CoC, the legal owner must always be certified. This should be confirmed as part of the application.Proposal B: Requiring the first CoC buyer in the supply chain to verify the prescribed start of CoC in the relevant fishery or farm assessment/audit report.

These changes can be found by opening the CoC certification requirement s and searching #need for CoC


45. The proposed amendments provide the clarity intended


Disagree Proposal A

Proposal B

46. If you selected “disagree” or “strongly disagree”, please explain why and suggest improvements.

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Topic: Suspensions

In this proposal we seek to improve clarity regarding non-conformity and suspension processes. Specifically as follows:

Proposal A: Removing the allowance to downgrade a non-conformity.Proposal B: Adding a 'critical' non-conformity process to single/multisite and CFO to align with group.Proposal C: Specifying that for multisite certificates, where every site is audited, a suspension can be site specific.

The relevant clauses can be found by opening theMSC CoC CR and searching #non-conformity and MSC CoC GCR suspension extracts searching #suspensions.


47. The proposed changes improve clarity


Disagree Proposal A

Proposal B

Proposal C

48. If you have selected “disagree” or “strongly disagree” please explain why and suggest improvements.

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49. Are the proposed changes implementable?

Yes Not sure No

Proposal A

Proposal B

Proposal C

50. If you have selected “no” please explain why and suggest improvements.

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Topic: General

The CoC Certification Requirements also include other substantive changes. These are identified in the draft document with comments boxes stating 'substantive change' and a rationale in each case, and in some cases additional questions. You can respond to these, or give any additional feedback below.

You can find all substantive changes not covered by the questions above or other topics by opening the CoC Certification Requirements and General Certification Requirements contracts and suspensions extract and searching #general.

Other changes include:

1. Removing the reference to „exceptional circumstances” for reducing the 1.5 day audit of high risk clients.

2. Clarification on how to apply the CPI index to vessels in the Group Sampling Table.3. Clarification on how to add a site to an existing single or multisite certificate.4. Clarification on how to check the validity of an MSCI License Agreement prior to the audit.


51. Do you have any specific concerns with the other changes proposed in the CoC CR or GCR?

Yes

No

Not sure

52. If yes, please add any additional comments here, referencing the document and requirement they are referring to.

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Yes

No

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User information

To help us improve our communications, please complete the two questions below before pressing 'Done' and completing the survey.

* 54. Would you like to receive MSC updates on any of the following topics (tick all that apply)?

MSC fisheries topics

MSC Chain of Custody topics

MSC accessibility and data limited topics

All MSC policy development topics

None

* 55. How did you hear about our current public consultation (tick all that apply)?

MSC stakeholder email announcement

MSC Program Improvements website (improvements.msc.org)

MSC main website (msc.org)

MSC email signature banner

Social media (e.g. Facebook; Twitter)

MSC Newsletter (e.g. CAB Newsletter/Update; Community Catch; Fishery Updates)

Industry media

Event attended by MSC

Other (please specify)

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