RINA · recommendation from RINA) for up to 90 days providing that the risk is low and adequate...

RINA Audit and Certification of fishery

products against Marine Stewardship

Council Chain of Custody Standard

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Table of Contents

1. PURPOSE AND FIELD OF APPLICATION ........................................................................................................ 3

2. TERMS AND DEFINITIONS .................................................................................................................................. 3

3. SOURCES .................................................................................................................................................................. 4

4. THE MSC CHAIN OF CUSTODY PRINCIPLES ................................................................................................ 5

5. LAWS AND REGULATIONS ................................................................................................................................. 5

6. CERTIFICATION OPTIONS ................................................................................................................................. 6

7. TRANSFER OF CERTIFICATE TO ANOTHER CERTIFICATION BODY ................................................... 7

8. VARIATION REQUEST .......................................................................................................................................... 8

9. CHANGE TO THE CERTIFICATE ....................................................................................................................... 8

10. ASC - AQUACULTURE STEWARDSHIP COUNCIL ........................................................................................ 9

11. RECORD-VERIFICATION EXERCISES ........................................................................................................... 10

12. NON-CERTIFIED SEAFOOD INGREDIENTS .................................................................................................. 12

13. MSC LOGO MANAGEMENT .............................................................................................................................. 12

14. DESCRIPTION OF THE MAIN PHASES OF THE CERTIFICATION, SURVEILLANCE AND RE-

CERTIFICATION PROCESS ............................................................................................................................................. 14

Section 1: CLIENT Contact, Exchange of Information, CLIENT Decision, and Offer. ................... 14

Initial contact CLIENT-RINA-MSC ................................................................................. 14

Application for Certification ............................................................................................. 14

Preparation of the Audit Offer ........................................................................................... 15

Control - Signing of the Audit Offer ............................................................................... 22

CLIENT’s Audit Offer Acceptance .................................................................................. 23 Opening of Job ...................................................................................................................... 23

Section 2: Audit and Certification Decision. ................................................................................... 24

Audit Team Selection........................................................................................................... 24

Audit Planning ....................................................................................................................... 24

Dispatch of the On-Site Audit plan .................................................................................. 27

On-site Audit ......................................................................................................................... 27

Preparation of CoC Audit Report ...................................................................................... 32

Certification phase ............................................................................................................... 34

Surveillance Plan .................................................................................................................. 39

Section 4: Post-Monitoring Evaluation (Surveillance and Re-Certification) .................................... 40

Surveillance Audit ................................................................................................................ 40

Surveillance Report Approval and Communication to the Client ............................. 41

Re-certification ..................................................................................................................... 43




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15. GROUP CERTIFICATION ................................................................................................................................... 45

Eligibility for Group CoC certification ........................................................................................... 45

RINA eligibility to perform group certification .............................................................................. 45

Group CoC auditors ....................................................................................................................... 45

Sample stratification ....................................................................................................................... 45

RINA decides sample plan to be used ............................................................................................. 46

Site sample plan ............................................................................................................................. 46

Sample selection ............................................................................................................................ 47

Audit findings at Group CoC audits................................................................................................ 47

Adding new Sites to the Group ....................................................................................................... 49

16. CONSUMER FACING (CFO) CERTIFICATION ............................................................................................. 50

Eligibility for Consumer-Facing (CFO) certification ...................................................................... 50

Audit planning for CFO clients ...................................................................................................... 50

Evaluation for CFO audits .............................................................................................................. 51

Interviews ...................................................................................................................................... 52

Verifying traceability ..................................................................................................................... 53

Product sampling ........................................................................................................................... 53

Verifying use of the ecolabel, logo and other trademarks ................................................................ 54

Closing meeting ............................................................................................................................. 54

Additional requirements for major non-conformities at CFO audits ................................................ 55

17. TABLES AND FIGURES ....................................................................................................................................... 56

Figure 1: Decision tree for consumer-ready tamper-proof packaging (CRTPP) ............................... 56

Table 1: Activity scope definition ................................................................................................... 57

Table 2: Sample plan allocation ...................................................................................................... 58

Table 3:Allocation to sample table ................................................................................................. 59

Table 4:Sample selection hierarchy ............................................................................................... 59

Table 5:Reject number of sites following major non-conformities .................................................. 60

Table 6: Reject number of sites – Group CoC ................................................................................. 61

Table 7: Sample plan for Group CoC – High Risk .......................................................................... 62

Table 8: Sample Plan for Group CoC – Medium Risk .................................................................... 63

Table 9: Sample plan for Group CoC – Low Risk ........................................................................... 64

Table 10: Sample Plan for Group CoC – Very Low Risk ................................................................ 65

Table 11 : Risk assessment scoring for CFOs ................................................................................. 66

Table 12: Risk scoring .................................................................................................................... 67

Table 13: Risk-based audit activities for CFOs ............................................................................... 67

Table 14: Site sampling for Consumer-Facing Organisations .......................................................... 68




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1. PURPOSE AND FIELD OF APPLICATION

The aim of the present document is to define the procedures and the methods which will be applied by RINA

to assess an organization, according to the current MSC Chain of Custody Certification Standard.

The aim is to provide a guarantee for suppliers, who will be able to demonstrate and claim that a certain product

originates from an MSC certified Fishery, thus minimizing the risk of public confusion with fish and fish products

originating from non-certified fisheries. To achieve this, a full product traceability system is required, so that

products can be traced from their suppliers and tracked to their buyers.

2. TERMS AND DEFINITIONS

For all definitions related to the MSC Fishery standard please refer to the current version of the “MSC-

MSCI Vocabulary”.

Follow definitions and abbreviations specific for RINA certification processes:

ANACLI: Software used to codify the customer

AR (Application Reviewer): Responsible for application review

ASCESI: Software used for the technical management of the management system certification

activity

CAI-C: Software used for the economic management of management system certification

activities

CCPLS: Sustainability & Food Certification Compliance

CM: Certification Manager (Operative office Responsible)

CT: Technical Committee

DM (Decision Maker): Responsible for the certification decision

DO: Organizational Structure Document

GVI: Auditing Team

LA: Lead auditor, person who, on the basis of his/her competences and knowledge, is able to:

• prepare, organize and carry out management system audits;

• coordinate the activities of the components of the audit group;

• train the auditors as regards the operative procedures and conduct and monitor the

operation;

• draw up and control the audit reports;

• maintain the interface relationship with the organization during the audit execution.

NEWAGE: Software used for competence management of the personnel involved in the

management

system certification process

OU: Operative Unit




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PR (Program Reviewer): Responsible for the audit program, he/she has technical/management

responsibility related to the certification files that have been assigned to him/her and is responsible

for the implementation of the three year audit program for the file assigned

PVI: Audit plan

PVP: Three year surveillance audit program (general planning document, indicating the audits to

be

performed during the validity of the certificate)

RVI: Audit Report

SEG: technical secretariat

TL- Team leader: Responsible for the audit group, person who has all the competence

requirements

foreseen for the Lead Auditor role, to whom responsibility for the audit has been assigned

VETO POWER: Person who has competence as regards the local legislation or technical areas

applicable to schemes that require knowledge of the applicable local legislation and a high level

of competence of the process/product. Veto Power shares responsibility with the DM for the

decision to issue management system certification

CONTROL OBJECTIVE: the reason for the existence of the control

CONTROL AND RESPONSIBILITY: the activity needed to obtain, with reasonable confidence,

the achievement of a goal

Follow definitions of main responsibilities in the certification process.

3. SOURCES

MSC Chain of Custody Standard v 4

MSC General Certification Requirements v 2.1

MSC Chain of Custody Certification Requirements v2.0

MSC-MSCI Vocabulary, v 1

ISO/IEC 17065:2012 – Conformity assessment – Requirements for bodies certifying products, processes

and services (ISO 17065)

ISO 19011:2011 Guidelines for auditing management systems”

IS-CRT-SYS-00

IS-CRT-SYS-01

IS-CRT-SYS-02

IS-CRT-SYS-03

IS-CRT-SYS-04

IS-CAF-FCT-01, rev 1

IS-CAF-CER-01, rev 1




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4. THE MSC CHAIN OF CUSTODY PRINCIPLES

The guiding principle at the basis of the MSC Chain of Custody Standard is the possibility of assuring

complete traceability of the products carrying the MSC logo from the fishery to the final consumer.

An efficient Management System (as set out in ISO 9001:2008) is required in order to ensure an efficient

Chain of Custody, which can confirm certified inputs and outputs and which is capable of managing

certified and non-certified products by separating and/or demarcating them, operating a secure labeling

procedure, and finally maintaining appropriate and efficient recording procedures.

The scope of the MSC’s Chain of Custody Certification Requirements (CoC CR) includes activities that

all CABs shall undertake in carrying out Chain of Custody (CoC) certification and audit activities for

organisations in the supply chain. CoC certification is required for all organisations trading in certified

products that wish to make a claim that the seafood they are buying or selling comes from a well-managed

and sustainable source that has been certified to the MSC’s Fsheries Standard, or to other standards as

recognised by the MSC.

Once a certified product is placed into consumer-ready tamper-proof packaging, CoC certification is no

longer required for organisations trading or handling these products.

Where the MSC has a formal agreement with other certification schemes (such as the Aquaculture

Stewardship Council, or ASC) to share the MSC’s CoC Standards, products from sources certified

against these standards can also utilise the MSC CoC system, provided each organisation has the

appropriate products in their CoC scope.

The MSC has one Default Chain of Custody Standard and two variants: one version for Group

organisations and one version for Consumer-Facing Organisations (CFOs). Further information on

eligibility for each version of the CoC Standard can be found below.

Five core principles form the MSC Chain of Custody Standard:

Principle 1: Certified products are purchased from certified suppliers

Principle 2: Certified products are identifiable

Principle 3: Certified products are segregated

Principle 4: Certified products are traceable and volumes are recorded

Principle 5: The organisation has a management system

5. LAWS AND REGULATIONS

Regulation (EC) No 178/2002 of the European Parliament and of the Council of 28 January 2002 laying

down the general principles and requirements of food law, establishing the European Food Safety Authority

and laying down procedures in matters of food safety.




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Regulation (EC) No 2065/2001 laying down detailed rules for the application of Council Regulation (EC)

No 104/2000 as regards informing consumers about fishery and aquaculture products.

Regulation (EC) No 2508/2000 laying down the detailed rules for the application of Council Regulation

(EC) No 104/2000 as regards operational programmes in the fisheries sector.

Regulation (EC) No 104/2000 on the common organization of the markets in fishery and aquaculture

products.

6. CERTIFICATION OPTIONS

There may be several certification options available to an applicant.

RINA shall evaluate each applicant to determine which certification option(s) the applicant is eligible for and

which option will be best suited to their needs:

For some clients, multiple certification options will be applicable. For example, a small restaurant chain

with 3 sites could be audited against the Default CoC Standard as a multi-site, the Group CoC Standard

or the CFO CoC Standard. It is up to RINA and client to decide which CoC Standard and certificate




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option is the best fit for the organisation. For both single and multi-site certificates, the client is certified

against the Default CoC Standard.

Eligibility for interim certification:

RINA shall determine if the applicant is seeking interim certification against any of the certification

options. The interim certification option is available in cases where exceptional circumstances make it

impossible or highly impractical to carry out an audit prior to allowing the applicant to sell certified

products. Permission for interim certification may be granted by the MSC (on the basis of a

recommendation from RINA) for up to 90 days providing that the risk is low and adequate controls are

in place.

If interim certification is being sought, RINA shall verify that:

- There are exceptional circumstances making it impossible to carry out an on-site audit.

- A risk assessment has been completed considering all potential risks of substitution or mixing

between certified and non-certified products and how these risks will be mitigated.

The MSC intends that CABs use their own judgment to determine risk factors as they may vary

significantly between cases where interim certification is requested.

- Risks to the integrity of certified products have been determined to be minimal.

If RINA is satisfied that interim certification is appropriate it shall:

- Inform the applicant that the MSC is not responsible for any costs associated with lapsing of an

interim certificate prior to a CoC certificate being obtained.

- Apply for interim certification on the scheme database, providing the following:

a. The proposed scope of certification;

b. A written justification of the exceptional circumstances and risk assessment as per 6.2.5; and

c. A full timetable for further action, including timing of audit(s) to be held within 90 days.

Once the MSC has decided whether to allow the interim certificate, RINA shall inform the client of this

outcome.

Eligibility for Group CoC certification are described in chapter .

Eligibility for Consumer-Facing (CFO) certification are described in chapter .

7. TRANSFER OF CERTIFICATE TO ANOTHER CERTIFICATION BODY

RINA recognizes certificates issued by other ASI Accredited Certification Bodies (CABs). The MSC standard

admits the transfer of a certificate to another CAB on the Client’s request in the following specific cases:

the encharged CAB is under accreditation and the Client needs an accredited certificate previous

the forecasted time for RINA accreditation;




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suspension or withdrawal of CAB’s accreditation;

Client requests to transfer the certification to another CAB during the evaluation period or at the

re-audit stage.

In order to assure the continuity and consistency of the evaluation and the certificate during this phase, RINA

applies IS-CERTI-MSC-TRASFCB-00.

8. VARIATION REQUEST

When requesting approval, variation and/or exemption as allowed under the MSC Certification Requirements,

RINA shall apply in writing and shall:

1. Specify which clause of the MSC Certification Requirements, variation is applied for.

2. Provide a justification for the variation that addresses each of the criteria (if any) given for accepting a

variation request.

3. Explain how the request does not alter the conformity of the applicant or certificate holder with the

relevant MSC standard.

4. Submit “MSC Variation Request Form” found at htt://www.msc.org/documents/scheme-documents to

the relevant MSC team (CoC) and upload it on the MSC database.

When submitting a variation as allowed under the MSC Certification Requirements (current version), shall be

considered that:

a) The decision to accept a variation request is usually made by MSC within 14 days of receipt of the

request.

b) In considering whether to grant the variation request, the MSC may seek expert views, including those of

the chair of the TAB, other TAB members identified by the chair of the TAB and other experts as felt

appropriate by the MSC.

c) The MSC will use the justification in the variation request and explanation on how the request does not

alter the conformity with the MSC standard (points 2 and 3 above) to determine if the variation request

shall be accepted.

d) The MSC will post variation requests and responses on the MSC website if the variation concerns a

fishery in assessment or certificate holder (this clause does not apply when assessing ASC scope).

e) RINA shall only submit variation requests in advance of the circumstances occurring. The MSC will not

accept retrospective variation requests.

RINA shall keep records of variations submitted and the MSC’s responses.

9. CHANGE TO THE CERTIFICATE

Changes to a certificate may come about due to:

1. New sites being added

2. New subcontractors being used

3. Scope extension for a new species

4. Scope extension for a new activity

5. Purchasing certified products from a new supplier




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6. Scope extension to handle products certified against recognised certification schemes that share MSC

RINA shall check continued eligibility where a change to the certificate adds a new entity.

RINA shall inform the client that for any changes to scope, suppliers, subcontractors, product certified to

another certification scheme or contact details the client should notify RINA as detailed in the relevant

CoC Standard.

In the event of the client adding a new subcontractor, RINA shall visit the subcontractor if required.

RINA shall use its own judgement to determine if further on-site visits are required when notified that

the number of sites within a CFO certificate has increased by over 50%.

a. On receiving a request for an extension to scope that includes new activities, or the first scope

extension to handle products certified to recognised certification schemes that share MSC CoC,

RINA shall:

b. Review available information;

c. Consider if the client’s existing management system is suitable for the proposed new scope of

operations;

d. Consider if eligibility for the respective version of the MSC CoC Standard will be maintained;

If a client is no longer eligible to be certified under the same version of the CoC

Standard, RINA shall inform the client they must be re-certified against the appropriate

CoC Standard within 6 months.

e. Consider if the client is no longer eligible for remote audits and determine whether future audits

will need to be on-site;

f. Decide whether an on-site audit is required before the scope can be extended and record the

rationale for this decision.

Upon approval of the first scope extension for the client to buy product certified against recognised

certification schemes that share MSC CoC, RINA will need to issue a certificate against this scheme and

update information in the relevant scheme’s database.

- RINA shall not process an extension of scope to add products certified under another scheme into the

client’s CoC scope if the client has a valid CoC certificate issued by another CAB. Where an organisation is CoC-certified with MSC products in scope, they must use the same CAB to

process a scope extension to handle products certified by ASC (or other schemes that also share MSC

CoC). A client cannot have one CAB for their ASC scope and another CAB for their MSC scope.

- RINA shall update the scheme database within 10 days of a reported change to:

1. Scope;

2. Subcontractors;

3. Suppliers;

4. New contact person;

5. Sites.

- Where relevant, RINA should update and document the risk assessment and the sample table and plan

for the client.

10. ASC - AQUACULTURE STEWARDSHIP COUNCIL




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The MSC CoC Standard is made available for use by selected organisations that operate certification schemes.

At the time these requirements were issued, the Aquaculture Stewardship Council (ASC) has elected to use the

MSC CoC Standard for all certified seafood products originating from ASC-certified farms. This allows supply

chain companies to handle both MSC-certified and ASC-certified seafood with a single CoC audit, although

separate CoC certificates are issued and each standard has distinct trademarks.

The Aquaculture Stewardship Council (ASC) uses the MSC Chain of Custody requirements. Although this is an

important collaboration, the ASC remains a separate organisation that uses a different logo. All requirements are

the same for ASC certificate holders except where stated.

The ASC logo, the name ‘Aquaculture Stewardship Council’ and the initials ‘ASC’ are trademarks that

are owned the by Aquaculture Stewardship Council.

Where applicants intend to handle products originating from fisheries or farms that are certified under

schemes other than the MSC (but which share the CoC Standards) this will be treated as a scope

extension. For example, if the applicant wants to handle ASC-certified products, RINA will need to issue

a separate ASC certificate for the client but can complete a single CoC audit.

Where an organisation is CoC-certified with MSC products in scope, they must use the same CAB to

process a scope extension to handle products certified by ASC (or other schemes that also share MSC

CoC). A client cannot have one CAB for their ASC scope and another CAB for their MSC scope.

All CoC audit checklists can be found on the MSC website. In general, one CoC audit checklist can be

prepared for audits of companies that seek both MSC-certified and ASC-certified products within their

scope. There is no need to complete a separate checklist.

For a client handling both MSC- and ASC-certified products, separate certificates and certificate codes

are issued for MSC and ASC, even though only one CoC audit and checklist are needed.

11. RECORD-VERIFICATION EXERCISES

Auditors shall conduct the following record-verification exercises, relating to certified products (or similar non-

certified product):

Traceability tests on a batch or batches of product sold or ready for sale.

a. The test shall link input to output or vice versa through unique lots or delivery numbers, internal

traceability records, purchase records (that identify the supplier(s), the lots or batches of purchase),

handling records and supply records.

Cross-checks of a sample of purchase records with delivery records and where possible, against the actual

product received.

a. Include the following records where relevant: bills of lading, invoices, delivery notes, health certificates

/ veterinary checks, catch certificates, purchase orders and packing list / loading records.




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Input-output reconciliation based on a time-period and/or batch of product.

a. This exercise shall include calculation of the yield if relevant, and consideration of whether this is

justifiable

Auditors shall determine the number of samples or products to use for record verification exercises, ensuring this

sample is:

- Of the auditor’s choice and obtained whilst on-site, or during the same day as a remote audit;

- Of sufficient number to:

a. Take into consideration the range of different handling processes, species in scope and

responsible parties;

b. Be confident that the system is effective for all the products listed in the potential scope;

c. Include checking traceability and/or volume records for product sent to and received from

subcontractors, if applicable;

d. Include records of any contract processing where relevant.

For records requested above, the auditor should set a time limit for receipt during the audit and raise a non-

conformity if this is not met.

A traceability test is a record-based trace of a batch sold / ready for sale back to its related purchase(s). The

traceability test shall test that these records are available and link the batch through each step where it is

handled, including handling at any subcontractors or off-site facilities.

An input-output reconciliation may be carried out between 2 time periods, in relation to one batch, or in

relation to one batch within a defined time period. The purpose of the input-output reconciliation is to

demonstrate that certified outputs are not greater than the inputs, except as related to added ingredients, and

that where product is transformed the yield (conversion rate) is accurate and justifiable. In verifying justifiable

yields it is recommended to cross check the product specification with the factory records and with yields

reported at previous audits.

Wherever possible, it is recommended that samples for record checks are selected from product the auditor

views on-site, and physical product identification and quantities can then be cross-checked with traceability and

volume records. It is recommended to look at traceability records and input-output reconciliation records in situ,

i.e., on the factory floor, wherever possible.

In selecting the sample size, an example of different processes would be a primary processor that is filleting both

pollock and salmon in different workshops. In this case, a traceability test and input-output reconciliation would

typically be carried out for both a salmon and whitefish product.

The time limit set by the auditor for records may for example be aligned with the client’s product recall

timeframe. The time to produce input-output reconciliation documents may require longer but would still need to

be obtained and reviewed whilst on-site. The auditor can alert the client to the expected time limits for gathering

records at the time of sending the audit plan.

At an unannounced audit, records for the traceability test and input-output reconciliation shall be verified on-site,

but other management system records may be requested after the audit. This is intended to address situations where management personnel are not present and so certain records

(e.g., contracts with subcontractors, licensing agreement, etc.) cannot be obtained. It is important that

records relating to traceability, identification and input-output reconciliation are verified on-site, as this

is where an unannounced audit may better identify product integrity risks.




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At the MSC’s written request, the auditor shall also verify records available at the audit with information that

was supplied by the client to the MSC previously. This could be used to verify that information provided to the MSC for the purposes of tracebacks or

supply chain reconciliations is consistent with records checked during the audit.

12. NON-CERTIFIED SEAFOOD INGREDIENTS

The certificate holder shall apply to MSCI ([email protected]) if it wishes to use non-certified seafood

ingredients on a product bearing the MSC ecolabel/ASC ecolabel , moreover those non-certified seafood

ingredients shall not exceed 5% of the total seafood ingredients in the final product.

The percentage of non-certified seafood ingredients in a product carrying the MSC ecolabel/ASC ecolabel shall

be calculated by:

a. Dividing the total net weight (excluding water and added salt) of non-certified seafood ingredients by the

total weight (excluding water and added salt) of the combined certified and non-certified seafood

ingredients in the finished product; or

b. Dividing the fluid volume of all non-certified seafood ingredients (excluding water and added salt) by

the fluid volume of the combined certified non-certified seafood ingredients in the finished product

(excluding water and added salt) if the product and ingredients are liquid. If the liquid product is

identified as being reconstituted from concentrates, the calculation should be made based on single-

strength concentrations of the ingredients and finished product;

c. For products containing non-certified seafood ingredients in both solid and liquid form, dividing the

combined weight of the non-certified seafood solid ingredients and the weight of the liquid ingredients

(excluding water and added salt) by the total weight (excluding water and added salt) of the combined

certified and non-certified seafood in the finished product;

d. The percentage shall be determined by the organisation who affixes the MSC ecolabel/ASC ecolabel on

the consumer package. The organisation may use information provided by other suppliers in determining

the percentage .

13. MSC LOGO MANAGEMENT

MSCI approval is required in advance for any use of MSC Logo.

Ecolabel only version, either landscape or portrait, with approved explanatory text to the right or left of the

ecolabel, may also be accompanied to RINA logo.

Approved explanatory text:

“RINA Services S.p.A. is a certifier accredited to carry out MSC chain of custody certifications to the

MSC standard.”

“RINA Services S.p.A. is in the process of obtaining accreditation to carry out fisheries certifications to the MSC

standard.”




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CCPLS SEG is responsible for the MSC Logo management, and, on regular basis, performs the following

activities:

Every 3-6 months verifies on the MSC website if any changes to MSC logo and/or its use have occurred;

Once a year contacts MSCI to request updates about the MSC logo and its use.

As result or the updating activity the review of the documentation containing the MSC Logo (i.e. brochures,

certificates) will be properly implemented and submitted to MSCI for approval.

RINA Audit and Certification of fishery products against

Marine Stewardship Council Chain of Custody Standard

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NOTE: The official language for MSC is English, MSC may request that all reports and annexes to reports be translated into English. From this point forward all

documents and forms to be used during the process are highlighted yellow

14. DESCRIPTION OF THE MAIN PHASES OF THE CERTIFICATION, SURVEILLANCE AND RE-

CERTIFICATION PROCESS

Section 1: CLIENT Contact, Exchange of Information, CLIENT Decision, and Offer.

This section provides a description of the activities needed to prepare the Audit Offer, according to the MSC Certification

Requirements and based on the CLIENT’s characteristics and requests.

Pt.. PHASE INPUT DESCRIPTION OF ACTIVITIES OUPUT/

OBJECTIVE

CRITICAL

FACTORS

1 .

In it ia l contact

CLIENT-RINA-

MSC

CLIENT-RINA

contact

MSC website for

further information

RINA CCPLS CU appoints a designed responsible - CCPLS SEG - provided

with the basic training and the updated information on the scheme to ensure

that any potential CLIENT receives full information about:

MSC,

MSC CoC requirements,

MSC Logo Licensing,

the process of MSC CoC certification,

the benefits and responsibilities of MSC certification.

In any case, if further assistance shall be necessary, the potential CLIENT

will be addressed to contact RINA MSC Scheme Responsible or will be

addressed to the MSC’s website for consultation.

In case the contact leads to an interest to certification, CCPLS SEG will send

to the applicant the RINA MSC COC Application Form (MSC-COC-

APPLICATION FORM)

RINA MSC COC

Application Form

(MSC-COC-

APPLICATION

FORM)

RINA’s main

responsibility is to

make the

information

available to all

parties, or,

otherwise, to

assist upon

request

2 .

Appl icat ion for

Cert if icat ion

RINA MSC COC

Application Form

(MSC-COC-

APPLICATION

FORM)

provided to the

CLIENT

CCPLS SEG will send the applicant the RINA MSC COC Application

Form, in order to get all relevant information on its characteristics and

activity in view of the preparation of the Offer.

In order to keep the Applicant/Certificate holder informed about all possible

changes to MSC requirements and/or standard approved by MSC, the main

changes or updating will be communicated by RS FISH to CCPLS SEG who

will send them by e-mail to the Applicants/Certificate holder.

Completion of RINA

Chain of Custody

MSC Application

Form by CLIENT

RINA Chain of

Custody MSC

Application Form

shall provide the

CLIENT with

different options.

RINA shall



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OBJECTIVE

CRITICAL

FACTORS

Where there is an amendment to MSC scheme documents, RINA shall

communicate this to all certificate holders within 60 days of the amended

version being issued.

RINA shall include the summary of changes provided by the MSC in this

communication.

RINA shall maintain a list or equivalent, identifying the document and its

version sent to applicants and certificate holders.

To this purpose a folder will be organized in the customer or client MSC

CoC folder.

discuss and agree

the appropriate

certification

option with the

CLIENT.

3 .

Prepa rat ion of the

Audit Offer

RINA MSC CoC

Application Form fully

filled in by the

CLIENT

Prior to entering into a contract, RINA shall check the MSC website or

check with the applicant to verify that the applicant is not already certified.

If the applicant is already certified: a. RINA shall not enter into a contract for certification without

following certificate transfer requirements (IS-CERTI-MSC-TRANSCB00)

b. RINA may inform clients that if they have any questions

concerning the ecolabel, logo or other trademarks they should

contact MSCI: [email protected]. RINA shall check if applicants for CoC certification:

1. Have had their certificate withdrawn within the last 2 years.

a. RINA shall not issue a new certificate until at least 2 years

from the date that the certificate was withdrawn.

2. Have had their certificate suspended within the last 6 months:

a. For intentional and/or systematic causes RINA shall not issue a

new certificate until at least 6 months from the date of suspension.

b. Where the certificate holder has cancelled their certificate

during suspension, RINA shall not issue a new certificate until at

least 6 months from the date of suspension.

CoC certificates are withdrawn only after a second suspension during a 3

year CoC certificate. The certificate statuses of “withdrawn” and

“suspended” are visible on the MSC website. Find a Supplier page. IS-

CERTI-MSC-TRASCB00 details requirements to be followed for certificate

transfers between CABs.

MSC-COC-CNTRW

MSC-COC-OFFER



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RINA shall require the applicant to declare any association to entities that

have been successfully prosecuted for a forced labour violation.

If an entity belonging to or currently contracted by an applicant

has been successfully prosecuted for violations of laws on forced

labour in the last 2 years, this entity shall not be allowed to

continue in the CoC certification process.a. Where an applicant no

longer holds a valid contract with a subcontractor that fulfils the

above criteria , the applicant shall be allowed to continue in the

CoC certification process.

CU, in cooperation with FM, performs the following activities:

makes sure the resources needed to carry out the audit process within

the deadlines are available;

defines the audit times;

calculates the cost of certification and relative maintenance bearing in

mind the effective time required to perform the service in man days;

for multi-site organisations, prepares an appropriate sampling plan;

records the data required to prepare the offer in the contract review

form (MSC-COC-CNTREW);

records all the non-documented information from the client (for

example information acquired over the phone) in the application

form;

verifies the opportunity to apply a specific CoC application field (see

Chapter 6 above ) among the following:

Single Certification

Multisite Certification

Group Certification

Consumer-facing Organization Certification

Interim certification

ASC CoC Certification;

Potential clients shall be invited to apply for certification under the most

appropriate option selected by RINA.



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Records of discussions and correspondence with potential clients shall be

kept, as well as the application form.

RINA shall work with each applicant to confirm the:

need for certification;

certification option (see Chapter 6)

Need for certification

Certification is a requirement for all organisations that take legal ownership

of certified products except in the following circumstances:

Organisations are considered to be legal owners if they issue invoices

related to the sale of certified products and collect payment for the sale of

certified products, or are able to demonstrate their financial ownership of

certified materials based on other documentation (such as internal transfer

slips, contracts or deeds). Applicants that do not take ownership can choose

to become certified if they wish. Organisations that are trading or handling

products from certified fisheries or farms but do not ever identify or sell

these as products as ‘certified’ or with the certified claim will not require

CoC certification.

a. Organisations that only purchase, handle, and sell certified products in

consumer-ready tamper-proof packaging (CRTPP).

i. RINA shall use the decision tree in Figure 1 to verify whether

products are in CRTPP.

b. Organisations that receive certified product in CRTPP and open the

package only for the purpose of heating or placing on a plate before

serving to a final consumer. This might include airlines that receive individually portioned meals and

only open the packaging for heating and serving to passengers. If an

organisation receives product in CRTPP, but opens the package for other

purposes. This could happen for example where a restaurant buys

CRTPP product from a wholesale retailer and then opens the product for

further preparation before serving

c. Entities that are identified by reference to or on a valid fishery or farm

certificate. Entities identified by reference to or on a fishery certificate could consist

of agents, auctions, unloaders or others that handle certified fish in the



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proximity of the point of landing or first sale. The Public Certification

Report for the fishery will clearly state that these entities are included in

the fishery certificate and either list the specific entities, the eligibility

criteria or where to find this information. The Public Certification Report

will also clearly state the point in the supply chain from which CoC is

required. Any similar entities not specifically referenced in the fishery

certificate will require CoC certification.

Certification option

RINA shall evaluate each applicant to determine which certification

option(s) the applicant is eligible for and which option will be best suited to

their needs (see Chapter 6)

APPLICATION:

Scope of certification

Having established the recommended option for CoC certification and

confirmed the applicant’s eligibility to proceed with certification, RINA

shall request information from the applicant to determine:

a) The proposed scope of certification;

b) The names of certified suppliers, if known;

c) Names of subcontractors that would handle certified product;

d) The proposed list of sites to be covered by the certificate, if relevant.

RINA shall define the proposed scope of the certification with the applicant

by identifying:

1. the certified species that are to be purchased or handled;

2. the activities to be undertaken, with respect to the certified products, as

per the definitions found in table 1. 3. Whether the applicant intends to handle products certified under other

recognised certification schemes that share the MSC’s Chain of Custody

program.

The specific certified fisheries/farms from which the applicant is sourcing do

not need to be included in the scope of certification. Species and activities

can be recorded without association to each other in the certification scheme

database and the CoC audit checklist.



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Where applicants intend to handle products originating from fisheries

or farms that are certified under schemes other than the MSC (but

which share the CoC Standards) this will be treated as a scope

extension. For example, if the applicant wants to handle ASC-certified

products, RINA will need to issue a separate ASC certificate for the

client but can complete a single CoC audit.

Proposed suppliers

RINA shall identify whether the applicant’s proposed suppliers are certified.

If the applicant has listed suppliers that are not certified, RINA

shall inform the client that suppliers need to be certified before the

applicant can identify or label any products from the supplier as

‘certified’ or with trademarks.

Use of subcontractors

RINA shall document the names of any proposed subcontractors

(excluding transportation) that would be handling certified product

and whether each subcontractor is certified.If the applicant intends

to use certified subcontractors, RINA shall check that the proposed

subcontractor’s scope includes the relevant activities.

Site list

For all certificates that are to cover more than one site, RINA shall ask the

applicant for a current site list that provides both physical and postal

addresses.

For CFO certificates the list shall classify sites as consumer-facing sites,

operations sites or sites that do both and provide contact details for each

site.A consumer-facing site is a discrete physical location that sells or serves

certified seafood directly to a final consumer (such as a restaurant or

catering site).

An operations site is a discrete physical location that is involved in

processing, storage, distribution, packing or repacking of certified products

(such as a central warehouse).

A site can be both consumer-facing and operations; for example, a retail site

with a fresh fish counter and a warehouse function.



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For group certificates the list shall include a name or position, and email or

phone for a designated contact at each site who is responsible for ensuring

the site conforms to Group CoC requirements.

OFFER PREPARATION

The proposed scope and option of certification shall be confirmed with the

applicant.

On the application form and contract review base CCPLS CU establishes

quotations, conditions and terms for the Audit Offer which will be prepared

by CCPLS SEG on the specific MSC-COC-OFFER format containing:

CLIENT name and address,

RINA Reference person,

date and location,

object,

MSC’s Principles,

certification schedule,

option of certification,

scope of certification,

sites or entities under certification,

timeframe,

quotations and possible auditor expenses,

extra inspections,

invoices issued and payment terms,

RINA manager signature

The MSC-COC-OFFER contains also:

1. rights and responsibility of the parties;

2. relevant rights of MSC including: the MSC’s right to change MSC

standards and certification requirements and that continued

certification may be conditional on conforming with any new or

revised standards or requirements;

3. information about the relationship with the MSC, between MSC,

RINA and certificate holders.

4. information about authorized claims that can be made about the

certification and the use of the MSC logo.

5. in case of changes to certification requirements approved by the



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MSC Board of Trustees or Technical Advisory Board AFTER

certificates have already been issued:

the amended MSC standard or certification requirement

shall take precedence over any previous version;

the MSC has the final word in these matters;

the MSC Technical Advisory Board shall determine the

timescales for certificate holders to be assessed against

and conform fully to the revised standard or certification

requirement (RINA, in conjunction with the MSC

Executive may be consulted).

Contract with CoC clientsRINA shall inform applicants for certification or

certificate holders of these changed requirements and that the MSC will not

be held liable for any costs or loss of certification arising out of changes to

MSC standards or certification requirements.

RINA’s contract for certification shall include the requirement that the client

conform to the MSC Chain of Custody Standard

If the Client is a different legal entity to the certificate holder RINA shall

have a written assessment/audit agreement with both parties.

RINA’s contract shall specify a description of the steps that shall be taken by

the client before it can be authorized by MSCI to use the trademarks.

RINA shall have procedures in place to ensure that applicants for

certification are fully informed of, and have contractually agreed in writing

to, the accreditation body's right to publish on their website RINA witness

audit reports

Once entered as an applicant on the database, RINA shall inform the client

that it can use the ecolabel, logo, or other trademarks:

Once a license agreement has been signed; and

Providing the client complies with the licensing agreement.

Where 2 or more legal entities apply for a certificate, RINA shall sign a

contract with all legal entities.

RINA’s contract with CoC clients shall specify that:

1. The client is required to conform to the relevant MSC CoC Standard.



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2. RINA shall suspend or withdraw certification if RINA finds reason for

suspension or withdrawal as established in IS-CERTI-MSC-

SUSPWITH00.

3. The client shall provide information requested to assist in a traceback or

supply chain reconciliation conducted by the MSC.

4.The client shall provide to the MSC, upon request, purchase and/or sale

records for certified products that will be shared with RINA of their

immediate supplier or customer, in the event that inconsistencies in records

need to be verified.

5. The client shall accept expedited audits, including unannounced audits,

from RINA and accreditation body. In the case of an unannounced audit,

clients shall provide access to their site within 30 minutes of the auditor’s

arrival.

6. The client agrees to allow samples of seafood to be taken from their

operation by the MSC, the accreditation body or RINA when requested for

the purposes of product authentication testing

Moreover, RINA shall issue an Offer for certification and shall maintain a

record of all agreements.

3 .

Contro l - S ign ing

of the Audit Of fer

Completed MSC-

COC-OFFER

CCPLS SEG shall ensure the applicant is informed on all current MSC

standard and certification requirements by sending: the CoC Applicant Doc

List Form (MSC-COC-DOCLIST-FORM) including a list of the applicable

updated MSC COC documents and the relative revision, to be filed with

offer.

CU CCPLS shall check and sign the offer, CCPLS SEG shall dispatch the

following documents:

MSC-COC-OFFER

Certification Rules for the MSC-Marine Stewardship Council

Standard:

a. policies and procedures for the resolution of complaints,

appeals and disputes;

b. description of the rights and duties of certificate holders;

MSC-COC-OFFER

signed by CU

CCPLS and sent to

the CLIENT,

enclosing:

MSC

Certification

Rules For

Customers,

MSC Logo Use,

MSC-COC-

DOCLIST-

FORM,

MSC CoC



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MSC/ASC Logo Use

MSC-COC-DOCLIST-FORM

MSC CoC Standard (current version)

Standard (current

version) and

4 .

CLIENT’s Audit

Offer Acceptance

Signed offer (MSC-

COC-OFFER) sent to

the CLIENT

The MSC-COC-OFFER signed by the CLIENT is evidence of the

CLIENT’s acceptance.

WARNING - RINA shall, within 10 days of receiving a signed contract for

certification, record the applicant on the scheme database. So the Scheme

Manager must update the MSC database within 10 days from the receipt of

the email from offices containing the MSC offer accepted by the client. The

MSC database cannot be updated without having received the evidence of

the offer accepted by the client that is considered as contract signed.

RINA may give the applicant their assigned MSC CoC certification code at

this stage or later in the certification process.

CLIENT’s accepted

MSC-COC-OFFER

5 .

Open ing of Job CLIENT’s accepted

offer

CU CCPLS examines the offer sent back by the CLIENT to ensure it is

complete and fully signed; allocates job responsibility to the RPC FISH and

informs CCPLS SEG accordingly.

Offer accepted and

signed by the

CLIENT and

accepted by CU

CCPLS

Allocation of job

Formatted: English (United States)



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Pt. PHASE INPUT DESCRIPTION OF ACTIVITIES OUPUT/

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6 .

Audit Tea m

Se lect ion

Signed Audit Offer

Filled MSC CoC

Application Form

IS-CERTI-MSC-

HRES-00

On the basis of the MSC COC Application Form and of the signed Offer

and following the provisions of IS-CERTI-MSC-H-RES-00, RPC FISH

shall appoint a GVI (according to the information obtained) suitable for the

audit, in order to ensure that the audit is performed on an independent basis.

RINA shall ensure that:

1. CoC auditors shall audit an individual client for a maximum of six

consecutive years; an alternative auditor shall be appointed in the

seventh year.

2.At least one of their CoC auditors shall be designated as RINA Lead

Auditor.

3. RINA lead auditor has the qualifications and competencies detailed

in IS-CERTI-MSC-H-RES-00

4. RINA lead auditor mentors and/or trains all other CoC auditors at

RINA to ensure they are familiar with third party management system

conformity assessment auditing techniques;

5. Auditors undertaking Consumer-Facing Organisation (CFO) audits

are not new auditors as described in IS-CERTI-MSC-H-RES-00

Group CoC auditors who audit the central office’s operations shall, in

addition to requirements above, comply with:

Group CoC central office auditor qualification and competency criteria as

detailed in IS-CERTI-MSC-H-RES-00

Where there is more than one auditor conducting a group central office CoC

audit, at least one auditor shall meet each of the requirements in IS-CERTI-

MSC-H-RES-00

GVI Appointment

7 .

Audit Plann ing Signed Audit Offer

Filled Application

Form

After the formal agreement stipulation, with the CCPLS CU acceptance of

the signed Offer, CCPLS CU shall appoint a RPC FISH in charge of the

process.

On the basis of the Application Form, the signed Offer, and following the

provisions of IS-CERTI-MSC-H-RES-00, RPC FISH shall prepare the

Audit plandispatch it along with the Audit Communication.

The plan for evaluation activities shall be provided to all personnel involved

Audit Plan,

Audit

Communication



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in the audit prior to commencing the work.

The plan shall:

Specify division of responsibilities between team members where

relevant;

Nominate a team leader responsible for carrying out the

assessment or audit in conformity to MSC requirements and good

audit practices;

Set out processes to be undertaken by team members:

- Prior to evaluation

- During evaluation (including consultations with stakeholders,

where undertaken).

To ensure that the client has sufficient information before the end of the

planning phase RINA shall provide to the client with the following written

information:

Expected scope of evaluation;

Draft work schedule;

Names and affiliations of proposed team members;

Sufficient information about the evaluation process, including a

summary list of the objective evidence that may be required by the

team.

RINA shall plan on-site and off-site audit activities taking account of:

a) The proposed or actual scope.

b) The management system used by the client.

c) The CoC Standard the client will be audited against.

d) Any other certifications held.

e) The need to allow sufficient time to verify the effectiveness of the

client‘s management system for the proposed scope.

f) Opportunities to synchronize and combine CoC audits with other

on-site audits where possible and appropriate.

g) Visits to non-certified subcontractors

RINA shall determine the number and type of sites to be audited as follows:

1. For single and multi-site certificates, every site shall be audited.

2. For CFO CoC certificates, sites shall be audited according to section

above and additional audit planning shall be define according the

chapter 16.



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3. For Group CoC certificates, sites shall be audited according to section

above.

RINA shall plan an audit duration of at least 1.5 days on-site for single and

multi-site clients that:

1. Include processing or contract processing in their scope as per Table

1; and

2. Are located in a country with a score below 41 in Transparency

International’s latest Corruption Perception Index

(http://cpi.transparency.org);

3. Handle both certified and non-certified seafood; and

4. Purchase in excess of 5,000 MT of seafood or more than 20 seafood

batches annually.

In exceptional circumstances, the planned audit duration for a company

meeting the above criteria may be less than 1.5 days. In these cases, RINA

shall document a justification for the reduced audit time in the audit

checklist.

1) RINA shall ensure that audits are carried out on-site, except for

cases described below:For initial audit:

Clients are eligible to become certified through a remote certification audit,

provided they meet both the following criteria:

a. Do not carry out any activities with respect to certified products

other than trading (buying and selling) as defined in Table 1; and

b. Do not use any subcontractors to handle certified products,

except for transport and/or storage subcontractors, as defined in

Table 1

A trading operation or site within a multi-site

certificate which meets this criteria could also be

audited remotely. 2) Surveillance audit:

Surveillance audits can be remote for certificate holders that meet all of the

following criteria:

- Conduct only ‘trading’ activities directly

- Do not take physical possession of certified products;

- Do not use contract processors or packers for certified products;



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- Are located in a country with a Transparency International CPI

score of 41 or above (http://cpi.transparency.org).

Trading companies that are eligible for remote surveillance audits can use

contracted storage or transport companies, but cannot use subcontractors

that do processing or packing/repacking.

RINA shall verify if the client holds other accredited certifications issued by

an accredited CAB to a relevant nationally or internationally-recognised

standard.

If the client does hold accredited certifications, RINA may use this as a

substantive indication of conformity with relevant elements of the MSC

CoC Standard by:

a. Requesting the most recent audit report from the client;

b. Undertaking a gap analysis of the differences between the MSC

CoC Standard and the other standard;

c. Using knowledge of conformity demonstrated by the other

certification to support RINA’s audit and certification decision.

8 .

D ispatch of the

On-Site Audit p lan Audit Plan,

Audit

Communication

The Audit Plan and communication shall, when applicable, be send to the

client before the audit date.

Audit Plan,

Audit

Communication

9 .

On-s it e Audit Audit Plan,

Audit

Communication

The auditor shall use the relevant CoC audit checklist to evaluate the client

at initial, surveillance and recertification audits.

Auditors shall evaluate the client against the same requirements for initial,

surveillance and recertification audits.In general, one CoC audit checklist

can be prepared for audits of companies that seek both MSC-certified and

ASC-certified products within their scope. There is no need to complete a

separate checklist.

One CoC audit checklist can be completed for a multi-site certificate by

verifying only the relevant requirements at each site. For example, the

auditor can assess segregation of certified and non-certified seafood at sites

taking physical possession of certified products, but may not be able to

conduct a full input/output reconciliation at this site if all records are held

http://cpi.transparency.org/



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at the trading office.

Opening meeting, gathering information, and procedures

All audits shall begin with an opening meeting, at which auditors shall

confirm with the client all of the following as a minimum:

1. Continued eligibility for CoC certification;

2. Continued eligibility for group certification where relevant;

3. Participant introductions and roles;

4. The purpose of the audit

5. The audit plan, including how the audit activities will be

undertaken and any visits to other sites and/or subcontractors;

6. The access required and the type of information needed;

7. Confidentiality of the information shared during the audit;

8. The proposed scope of certification;

9. The list of certified suppliers;

10. The list of any subcontractors that are or will be handling certified

products and which ones are independently certified.

a. If applicable, the list of certified companies for which the

client conducts contract processing of certified products.

For each of the CLIENT activities listed in the potential scope, the Audit

Team shall review and collect evidence proving that the CLIENT's

management system procedures below, as recprded and implemented, meet

the requirements of the relevant version of the MSC CoC Standard.

If, at the time of the audit, the CLIENT is not handling all of the products

listed in the proposed scope, RINA shall collect evidence of the system in

operation conforms to the MSC CoC Standard for one or more sample

products similar to products in the proposed scope.

Auditors shall review the content and implementation of procedures relevant

to CoC.

Examples of procedures could include written protocols for maintaining

segregation, procedures of purchasing of certified products, employee

training manuals, etc. If the client is carrying out contract processing activities for certified

products, the auditor shall review the relevant procedures to ensure that

contract processing is undertaken in conformity with CoC

requirements.

During the audit, auditors shall review records relating to the receipt, sale



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and any applicable physical handling of the products listed in the proposed

scope

Interviews

Auditors shall interview responsible personnel to verify their competency in

understanding and applying the relevant MSC CoC Standard.

The number of interviews carried out shall reflect the size of the

organisation, the complexity of operations, and the range of staff

who could affect the integrity of certified products.

Interviews shall be used to determine if personnel understand the

relevant process or procedure which ensures conformity with the

CoC Standard.

Interview questions shall not be leading.

Interviews may include (but are not limited to) management staff as well as

employees who are responsible for buying and selling certified products,

conducting goods-in checks at point of receipt, applying product

identification or labels, selecting batches of certified products for

production, managing traceability records, and selecting packaging for

certified products.

Segregation

Auditors shall establish that appropriate measures are taken by the client to

segregate, identify and prevent mixing between:

Certified and non-certified seafood;

Where relevant, between seafood certified to other recognised

schemes sharing MSC CoC.

If subcontractors are used, auditors shall verify that appropriate systems are

in place to ensure identification and traceability of certified products at point

of dispatch and receipt.

Record-verification exercises

See chapter 11 .

In case of initial certification, if the organization does not have MSC

labelled products/packaging on site at the time of the audit, a sampling of

those products/packaging will be requested at certificate issue and/or as

soon as they are available.

Verifying use of the ecolabel, logo or other trademarks



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If the client uses the ecolabel, logo or other trademarks on their own

products or for a customer, the auditor shall verify that the client is

permitted to use the trademarks by confirming that:

The client can show a license agreement with MSCI signed by

both parties; and/or

The client can show proof of product approval from MSCI for

packaging designs for a sample of products.

Where the client includes non-certified seafood ingredients in products sold

as certified, the auditor shall verify the client’s calculation for all or a

sample of products to which this applies, as specified in chapter 12.

All use of the MSC ecolabel requires a licence from MSCI.

The acronym “MSC’’ and “ASC” can be used without a license from

MSCI only in a business-to-business context and only for product

identification or employee training purposes.

Applicants for certification may use the name “Marine Stewardship

Council” or “Aquaculture Stewardship Council” and the letters “MSC” or

“ASC”to inform stakeholders about the assessment or audit process and

invite participation without having a licence agreement.If there is any doubt

about whether a licence is required, RINA shall refer to MSCI for advice.

RINA shall verify that an applicant has not used the MSC trademarks

without a licence or sold products as certified prior to be certified.

If the applicant has used the MSC trademarks without a license

agreement or sold products as certified prior to be certified RINA shall

raise a non-conformity, and shall instruct the applicant to immediately

cease use of the MSC trademarks and selling products as certified..

A copy of the non-conformity shall be sent to MSCI within 7 days.

RINA shall have documented procedures for the issue and use of any logo

or trademark of RINA (ISO 17065 4.1.3, 7.9.3 and 7.9.4) for the

certification program, including procedures for pre-publication review and

authorisation by RINA of:

1. All uses of the RINA's logo by certificate holders; and

2. All public claims made by certificate holders referring to their

certification.

Closing meeting



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Auditors shall conduct a closing meeting at the conclusion of each audit

with the client’s representative(s) to verify that the client understands:

1. That until its certification status and information, including scope

of certification, is displayed on the MSC website, the client is not

certified and cannot make any claims concerning certification;

2. Any actions the client may have to complete and their timeframes

before certification can be awarded;

3. Any findings or non-conformities that have been identified during

the audit and their likely categorisation (subject to approval by

RINA’s decision-making entity), timeframes to address these

findings and the process for verifying their completion;

4. That the client must inform RINA of any significant future

changes that affect certification, as specified in the contract;

5. That the scope, subcontractor and supplier list is correct and

agreed;

6. The reporting timeframes for changes as detailed in the MSC CoC

Standard.

Evaluation of subcontractors

RINA shall require the client to provide details of how the client will retain

full control of each subcontractor.

Non-certified contract processors or repackers shall be visited on-site prior

to being used by the client for certified product, and thereafter at least

annually.

During the on-site visit the auditor shall:

1. Verify that Principles 2, 3, and 4 in the CoC Standard have been

met, covering traceability, identification and segregation;

2. Carry out an on-site traceability test and input-output

reconciliation;

3. If the subcontractor is already handling product for the client,

cross-check a sample of dispatch and receipt records, product

details and volumes from the client and subcontractor;

4. Verify the agreement between client and subcontractor meets

clause 5.3.1 in the Default/ Group CoC Standards.

The auditor shall visit non-certified storage subcontractors at least once

during their client’s 3-year certificate validity if the subcontractor is:

Located in a country with a Transparency International CPI score

below 41 (http://cpi.transparency.org); and



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Handling product that is part-processed by the client, but not yet

in the form in which it will be sold by the client.

During this visit the auditor shall verify that a sample of certified products

can be identified as certified.

In addition to requirements above, the auditor should visit non-certified

subcontractors, excluding transport subcontractors, when there is any

concern relating to product integrity.

The auditor may perform other checks, such as cross-checking records from

the certificate holder and subcontractor, reviewing dispatch and receipt

records, or carrying out an input-output reconciliation of certified product

handled by the subcontractor.

RINA may conduct just one visit to a subcontractor used by more than one

of their clients, but will still need to cross check the records relating to each

client and raise non-conformities with each client where appropriate. A

RINA will still need to visit a subcontractor used by their client even if the

subcontractor was recently visited by another CAB.

REMOTE AUDIT

- Remote audits shall assess applicants against the same criteria and

requirements as an on-site audit.

- If the audit is remote, this may be carried out either on a call, video

conference or through an initial email exchange.

- In a remote audit, segregation and identification may be demonstrated

by photographs or a description of the procedures.

EVALUATION FOR CFO AUDITS is detailed on chapter 16

10 .

Prepa rat ion of

CoC Audit Report

Audit evidences The Audit Team shall complete the MSC CoC Audit Checklist for all audit

findings and shall send the checklist or a certification report to the client

within 10 days of the certification decision.

As audit report, the Audit Team shall use the current version of the “Chain

of Custody checklist” developed by MSC (found at

http://www.msc.org/documents/scheme-documents/forms-and-templates),

The Audit team shall use the appropriate version of the MSC CoC Audit

Checklist.

The completed checklist shall be uploaded to the MSC database after

Audit Report

http://www.msc.org/documents/scheme-documents/forms-and-templates



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completing each audit. Any non-conformities observed during an audit shall be classified as minor

or major, as follows:

Minor non-conformity (condition for ongoing certification): the client

does not comply with the Standard, but those issues do not jeopardize

the integrity of the CoC

For initial certification, RINA may recommend an applicant for

certification:

- If no non-conformities are observed at an audit; or

- When an action plan satisfactorily addresses all minor and major non-

conformities

For minor non-conformities raised during initial certification, RINA

shall not grant certification until the applicant has submitted an

effective action plan to address all minor non-conformities.

The action plan shall include a description of:

The corrective actions intended to address the non-

conformity; and

An appropriate timeframe to implement corrective action.

Major non-conformities: the integrity of the CoC is jeopardized and

certification cannot be granted or maintained. RINA shall require that

major non-conformities are closed or downgraded according to the

timeframes below.

Major non-conformities raised during initial certification shall

be closed or downgraded before RINA can grant certification.

a. If within 90 days of the date of the initial audit, RINA cannot

close or downgrade the major non-conformity, a full re-audit

shall be required.

RINA shall inform the client that an effective action plan is required in

order to close or downgrade major non-conformities.

The action plan submitted by the client shall include a description

of: The root cause of the non-conformity;

The corrective actions intended to satisfactorily address the non-

conformity;

An appropriate timeframe to implement corrective action

For audit findings and additional certification requirements for Group CoC

audits see chapter 15.



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OBJECTIVE

CRITICAL

FACTORS

For clients certified against the CFO CoC standard, an incident of selling

or identifying non-certified product as certified or with the trademarks at the

point of sale or serving to the final consumer shall be considered:

As a major non-conformity only if the auditor determines that the

cause of the mislabelling was due to an individual not following

established internal procedures.

As a cause for suspension (see IS-CERTI-MSC-SUSPWITH00) in

all other cases.

For CFO clients, the auditors shall raise all non-conformities only against

the central office, even if detected at site level. The process for CFO clients

is distinct from Group CoC, where non-conformities detected at site level

are raised against both the site and the group.

For additional requirements for major non-conformities at CFO audits see

chapter below .

For multi-site CoC clients, non-conformities found at different sites are all

raised against the certified entity (the organisation which holds the CoC

certificate).

The site name, address and date of detection shall be recorded in the

CoC audit checklist.

RINA may close out or downgrade non-conformities found during the audit.

Where RINA’s decision-making entity disagrees with auditor

classification of non-conformities RINA shall record the rationale for

those changes in the checklist.

RINA shall raise any non-conformities found at a non-certified

subcontractor with the client.

Within 10 days from the audit date, RINA shall update the CoC audit

checklist with details of activities undertaken by the client to accept the

action plan and/or close out or downgrade major non-conformities.

11 .

Cert if icat ion phase Application form

Audit report

With SEG’s assistance, RPC shall prepare the documentation which needs

to be sent to the appointed Decision Maker (DM).

N.B.: The DM shall be an MSC Lead Auditor, whose competence shall be

shown through at least three audits in the scheme or one audit in the scheme

Audit Report

Certification

proposal

Certification



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and an experience as DM in equivalent schemes such as ISO 22000, FSSC

22000, BRC, IFS.

The documentation attached to the certification proposal shall include:

Audit Report

Audit plan

PVP

Application Form

Certification proposal signed by RPC

Sheet related to the non conformities issued signed by the

client (if any)

Supplier form signed by the client

These documents are sent to DM for the review and the certification

decision.

The DM (RINA‘s decision making entity):

a. Review and confirms the grading of any non-conformity found

during the audit,

b. make a decision on whether the scope of the certificate should

include all categories listed in the potential scope, based on the

confidence RINA has in the client‘s system,

c. make a decision on certification within 30 days of the audit date,

unless further evidence has been requested.

a. If further evidence has been requested from the client to

demonstrate that non-conformities were satisfactorily closed,

RINA shall make a decision on certification within 30 days of

receiving this evidence.

d. verifies and approve (following directives of IS-CAF-FCT-01) the

certification proposal or defines the proper changes to be made in

the Audit Report

The DM approval of the certification proposal is registered in the

Certification Proposal and inside the “certification decision” sheet of the

CoC audit check list filled in (at least the date of the certification decision

and the name and surname of the DM) and signed.

awarded

CERTIFICATE



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The “certification decision” sheet filled in and signed is the evidence of the

independent technical review done and certification decision taken.

For Group CoC clients and CFO clients with multiple sites, in addition to

the above, RINA’s decision-making entity shall not make a decision on

certification or recertification until they are satisfied that:

The sample table and sampling plan selected was appropriately

selected for the client;

All requirements of the Group or CFO CoC Standard have been

audited, either at that site or, if centrally managed, at the central

office;

Evidence contained in audit reports demonstrates that the client is

operating in a competent manner;

Sites are in conformity with requirements, and that any major non-

conformities have been addressed within the allotted timeframes

For all CoC clients RINA shall, within 10 days of the certification decision:

-Submit the finalised CoC audit checklist to the client.

a. RINA shall ensure that the client signs-off on the accuracy of specific

sections of the CoC audit checklist, including:

1. The schedule of certified suppliers;

2. Any statements made by the certificate holder indicating that

the certificate holder was not handling any certified products at

the time of the audit;

3. Where collected, the complete list of the certificate holder’s

purchases of certified products or the list of certified batches

processed since the previous audit.

- Record the following details onto the MSC database:

a. The client’s confirmed and/or updated scope;

b. List of subcontractors;

c. List of suppliers;

d. List of sites (where applicable);

e. The finalised CoC audit checklist;

f. Audit date;

g. The CoC certificate for initial certification and recertification

audits.



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h. the certification decision sheet of the CoC audit checklist, filled in

(at least the date of the certification decision and the name and

surname of the DM) and signed.

- Issue the certificate(s) to the client for certification or recertification

audits.

The finalised checklist that is uploaded onto the MSC database needs to

detail the findings of the audit and include RINA’s decision on the

outcome, independent of the individual auditor’s.

a. For group and CFO CoC certificates, RINA shall issue the

certificate to the central office under the name of the group or

organisation.

b. When a client’s scope of certification includes products certified

under other recognised certification schemes that share MSC CoC,

RINA shall issue a separate certificate for each scheme with the

relevant scopes.

When one certificate is issued on a different date than the other,

the second certificate shall be issued with the same expiration date

as the first certificate.

For a client handling both MSC- and ASC-certified products, separate

certificates and certificate codes are issued for MSC and ASC, even though

only one CoC audit and checklist are needed.

RINA shall submit to the MSC a copy of the contact details (found in msc

website) for all participating fishery clients within 10 days from the date the

fishery certificate is issued. RINA need to send the completed form to

[email protected], placing their specific fishery client name in the subject

line of the email.

Interim certification

RINA shall inform the applicant that an interim certificate may be issued for

up to 90 days, should the MSC approve the interim certification .

If after 90 days an on-site audit has not been completed and there has not

been a CoC certificate issued, RINA shall:

1. Cancel the certificate in the database;

2. Inform the applicant that the interim certificate has expired;

3. Inform the applicant that any use of the trademarks and/or claim

of CoC certification shall cease immediately.



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OBJECTIVE

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FACTORS

CERTIFICATE:

RINA shall issue an English language certificate, which as well as

requirements in ISO 17065, 7.7, shall contain:

- The latest published version of the ecolabel or logo.

- a unique CoC certificate code that is automatically generated by the

certification scheme database.

RINA may issue certificates in other languages as well as the English

version providing they bear a disclaimer in at least 10 point font that the

certificate is an unverified translation of the English certificate, and in case

of differences the English version shall take precedence.

RINA’s CoC certificates may include the address of the client’s other

office(s) if these differ from the site where the main audit activity took place.

If additional addresses are listed, the main activity performed at these

addresses shall be noted on the certificate to avoid confusion with the main

audit activity taking place.

The CoC certificates shall include:

1. A statement confirming that the organisation conforms to the

requirements of the relevant MSC CoC Standard with the version

number specified;

2. A statement to the effect that the buyer of the fish or fish products

sold as certified may, after gaining approval to do so from MSCI,

apply the trademarks to certified products within their scope of

certification; and

3. A statement referencing the certification scheme’s website as the

authoritative source of information on the validity of the

certificate as well as its scope.

The date of expiry.If RINA issues a certificate covering Group CoC

certification:

1. The central office shall be issued a certificate under the name of

the group.

2. A list of the sites or a website link to the current list of sites shall

be included on the group certificate or on a schedule attached to it.

RS FISH shall check the text of the certificate and, following the successful

outcome of this control, and shall sign the certificate.



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Within 10 days of the certification decision, details of the certification of

the client shall be recorded on the MSC database/ASC sections of the MSC

database.

RINA shall submit to the MSC a copy of the contact details for all

participating clients, within 10 days from the date certificate is issued.

RINA should use the MSC Contact Details Submission form.

Within 10 days of the date the certificate is issued, RINA need to send the

completed form to [email protected], placing their specific fishery client

name in the subject line of the email.

For any change of scope of certification see chapter 9.

12 .

Surve i l lance P lan Previous Audit Report

RINA shall determine the surveillance frequency for certificate holders after

each certification, surveillance and re-certification audit according to the

following criteria:

A frequency of 18 months for single or multi-site CoC certificate

holders that meet at least one of the following criteria:

a. 100% of the seafood handled at all sites is certified seafood; or

b. Conduct only ‘trading’ activities directly as defined in Table 1 and

do not use any contract processors to handle certified product (contract

transport and storage is permitted); or

c. Only handle certified product in sealed boxes or containers and do

not repack, process repackage or alter sealed boxes in any way.

A frequency of 12 months for all other certificate holders.

(All Group and CFO CoC certificate holders require annual

surveillance audits)

For Group CoC clients and CFO clients with multiple sites, the

central office and a sample of sites shall be audited as dictated in

chapter respectively.

The surveillance audit's timing may be advanced or delayed by up to 90

days before or after the due date as necessary to coordinate a suitable date.

Surveillance Process

opened



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Section 4: Post-Monitoring Evaluation (Surveillance and Re-Certification)

No. PHASE INPUT DESCRIPTION OF ACTIVITIES OUPUT/

OBJECTIVE

CRITICAL

FACTORS

13 .

Surve i l lance Audit PVP The surveillance audit will be communicated to the client following the

same procedures described for the certification audit.

NON CONFORMITIES:

RINA may close out or downgrade non-conformities found during the audit.

Where the RINA’s decision-making entity disagrees with auditor

classification of non-conformities RINA shall record the rationale

for those changes in the checklist.

RINA shall require that:

Minor non-conformities raised during surveillance audits are

satisfactorily addressed no later than the next scheduled audit.

Major non-conformities raised during surveillance audits (or any

other time after initial certification) shall be closed or downgraded

within 30 days of detection.If the major non-conformity is not

addressed within the 30 day maximum timeframe, suspension or

withdrawal of the certificate and a full re-audit may be initiated.

RINA shall inform the client that an effective action plan is required in

order to close or downgrade major non-conformities.

The action plan submitted by the client shall include a description of:

a. The root cause of the non-conformity;

b. The corrective actions intended to satisfactorily address the non-

conformity; and

c. An appropriate timeframe to implement corrective action.

UNANNOUNCED AUDIT

RINA shall carry out unannounced, on-site surveillance audits at a

minimum of 1 or 1%, whichever is greater, of all their clients each year.

RINA shall prioritise clients that have been identified at high risk for

product substitution by the MSC, the accreditation body or through receipt

of a complaint.

RINA may inform the client of a 6 month surveillance window in which the

audit can occur, but shall provide no notice of the actual date.

Surveillance Report



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Unannounced audits are intended to provide a more accurate picture of a

client’s day-to-day conformity with MSC CoC Standard, as the client will

not have any time to prepare specifically for the audit. For unannounced

audits, entry must be granted to the auditor within 30 minutes of their

arrival. Entry cannot be refused on the basis of a responsible person not

being available, or another audit being conducted on the same day, and time

limits for document provision can still be set. At least on an annual basis,

RINA will calculate the number of unannounced audits. This number is

calculated as 1% of the current number of clients (rounded to the nearest

whole number), or 1 in the case RINA has fewer than 100 clients. If RINA

has not had any clients identified as high risk due to information received by

the MSC or accreditation body, or a complaint, then RINA can use their

own risk assessment to select clients or can choose randomly.

EXPEDITED AUDIT

RINA shall have a documented procedure to determine when it should do

any of the following:

Conduct expedited audits and/or request and examine documentation related

to a client’s operations.

RINA’s procedure shall take account of information received including:

- Complaints;

- Notification of changes in personnel, site or management system

procedures;

- Information from the MSC, the accreditation body and/or MSCI.

The MSC can require RINA to conduct an expedited audit when

information has been received indicating a potential risk to the Chain of

Custody, but where responsibility is not clear. In this case:

1. The MSC will provide RINA with a written request to conduct the

audit which shall include any relevant information or evidence;

2. The MSC and RINA shall agree on the full cost of the audit in

writing in advance of the audit;

3. The MSC will reimburse RINA for the full cost of the audit;

4. The MSC can require that these audits be attended by the

accreditation body or a representative of MSC.

14 .

Surve i l lance

Report Approva l

and

Surveillance Report RINA shall update the CoC audit checklist with details of activities

undertaken by the client to accept the action plan and/or close out or

downgrade major non-conformities.

Approved

Surveillance Report

DM certification

decision form filled

in and signed



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Communicat ion to

the Cl ient

The finalised checklist that is uploaded onto the scheme database needs to

detail the findings of the audit and include RINA’s decision on the outcome,

independent of the individual auditor’s.

WARNING - It’s important to appoint a DM person who performs the

independent technical review and take the decision about the maintenance of

the certification, also during the surveillance audits.

This activity is formalized filling in (date of approval, name and surname of

the DM person) and signing the “certification decision” sheet, that is one sheet

of the CoC audit check list.

RINA’s decision-making entity shall:

- Review and confirm the grading of any non-conformity found during the

audit;

- Make a decision on whether the scope of the certificate should include all

categories listed in the potential scope, based on the confidence RINA has in

the client’s system; and

- Make a decision on certification a within 30 days of the audit date, unless

further evidence has been requested.

a. If further evidence has been requested from the client to demonstrate that

non-conformities were satisfactorily closed, RINA shall make a decision on

certification within 30 days of receiving this evidence.

For Group CoC clients and CFO clients with multiple sites, in addition to

the above, RINA’s decision-making entity shall not make a decision on

certification or recertification until they are satisfied that:

- The sample table and sampling plan selected was appropriately

selected for the client;

- All requirements of the Group or CFO CoC Standard have been

audited, either at that site or, if centrally managed, at the central

office;

- Evidence contained in audit reports demonstrates that the client is

operating in a competent manner;

- Sites are in conformity with requirements, and that any major non-

conformities have been addressed within the allotted timeframes.

RINA’s decision-making entity may seek and review relevant data

not contained in reports, including, but not limited to, interviewing

the client’s personnel.

For all CoC clients, RINA shall, within 10 days of the certification decision:

Submit the finalised CoC audit checklist to the client.



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a. RINA shall ensure that the client signs-off on the accuracy of

specific sections of the CoC audit checklist, including:

i. The schedule of certified suppliers;

ii. Any statements made by the certificate holder indicating that

the certificate holder was not handling any certified products at

the time of the audit;

iii. Where collected, the complete list of the certificate holder’s

purchases of certified products or the list of certified batches

processed since the previous audit.

The client’s sign-off can be electronic or provided, for example, via a

record of email correspondence if a signature on the audit checklist is

not practical.Record the following details onto the scheme database:

a. The client’s confirmed and/or updated scope;

b. List of subcontractors;

c. List of suppliers;

d. List of sites (where applicable);

e. The finalised CoC audit checklist;

f. Audit date;

g. The CoC certificate for initial certification and recertification audits.

Issue the certificate(s) to the client for certification or recertification

audits.

a. For group and CFO CoC certificates, RINA shall issue the certificate

to the central office under the name of the group or organisation.

b. When a client’s scope of certification includes products certified under

other recognised certification schemes that share MSC CoC, RINA shall

issue a separate certificate for each scheme with the relevant scopes.

When one certificate is issued on a different date than the other, the

second certificate shall be issued with the same expiration date as the

first certificate.

a) For a client handling both MSC- and ASC-certified products,

separate certificates and certificate codes are issued for MSC and

ASC, even though only one CoC audit and checklist are needed.

15 .

Re-cert if icat ion Previous Surveillance

Reports

All CoC certificates shall remain valid, subject to satisfactory performance,

for a maximum of 3 years..

RINA may extend a client’s certificate by up to 90 days in order to

accommodate audit scheduling by placing a request in the scheme’s

database.

RINA shall perform a complete recertification audit at the end of each

On-Site Evaluation

Program

Audit Report

Certificate renewal



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certificate’s period of validity.

RINA shall follow all relevant sections of the MSC CoC CR as for an

applicant.

For Group CoC clients, the site sample plan shall be determined as for

initial audits.

For CFO clients with multiple sites, the site sample plan shall be the same

as for surveillance audits.

RINA Audit and Certification of fishery products

against Marine Stewardship Council’s Chain of

Custody standard

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15. GROUP CERTIFICATION

This section covers additional requirements that only apply for Group CoC clients, such as stratification of the

group and determining the sample size of sites to be audited. For any other type of certification, general

requirements apply, as defined in the standard procedures of above.

Eligibility for Group CoC certification

RINA shall determine that an applicant is eligible for certification against the Group CoC Standard if all the

following criteria are met:

1. The proposed group’s central office is a legal entity with whom a contract can be made.

2. All sites undertake substantially similar activities as defined by MSC Chain of Custody activities; or if

they do not, the group can be stratified for sampling according to the requirements specified below.

3. The entire group operation is within one geographic region; or if they are not, the group can be stratified

for sampling.

4. The same written language is used at all sites and can be read by all site managers or, if translations are

provided, adequate document control procedures are in place to ensure version consistency across

different languages.

5. The proposed group’s central office is capable of objectivity in audit and decision making.

6. The proposed group’s central office can demonstrate through their application an understanding of the

Group CoC Standard such that it is likely that they will be able to qualify for certification.

RINA eligibility to perform group certification

Prior to accepting an application for group certification, RINA’s documented procedures for conducting group

certification shall have been assessed by ASI during a desk review or an on-site audit.

RINA shall conform to any conditions ASI may have imposed on the audit of group certification schemes, which

may include without limitation a:

Requirement for ASI to witness the first group audit undertaken.

Requirement for ASI to review the audit records of the first group certification undertaken.

Limit on the number of group certifications that may be undertaken.

Limit on the number of sites permitted within a group scheme.

All activities covered by the scope of the certificate shall be covered in the scope of RINA’s site audits.

RINA shall audit the central office and a sample of sites, as dictated by sections below.

Group CoC auditors

Group CoC auditors who audit the central office’s operations shall, in addition to requirement to CoC auditors

comply with other qualification and competency criteria as detailed in IS-CERTI-MSC-HRES00 (Table 3).

Sample stratification

RINA shall allocate each applicant group (or sub-group) to one of 4 sampling plans in Table 2, 3, 4 or 5 and

shall review the group to make a decision on whether sample stratification is required.

Stratification shall take place:



Custody standard

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where the group’s sites can be classified into distinct sub-groups according to the activity shown in

Table 1;

where manufacturing and/or processing activities occur within a group where all sites do not perform

these activities.

If stratification is required, RINA shall:

divide the group into two or more sub-groups;

follow the sampling procedure for each sub-group independently.

keep records of the sample stratification process and decisions.

RINA decides sample plan to be used

RINA shall complete the risk assessment in Table 2, and allocate one score for each risk factor; if it appears there

are two scores within the same sub-group, RINA shall allocate the higher score.

RINA shall allocate the applicant group or sub-group to a sample table following Table 3.

Site sample plan

RINA shall perform the initial audit following the initial audit-sampling plan within the sample table selected

(Table 7, 8, 9 or 10)..

Following an audit RINA shall decide whether sampling sizes for the next surveillance audit should be increased

or decreased from the current sampling plan.

RINA shall increase the sampling plan for the next surveillance audit by one level according to Table 3 if the

group meets at least one of the criteria below:

a. One or more critical non-conformities were raised against sites or more than three major non-

conformities were raised against the group entity at the last audit conducted by RINA.

b. Internal audits or internal control system not operational and corrective or preventive actions are

inappropriate

c. The group’s CoC certification was suspended or withdrawn in the last 12 months.

Where the group is already in the High Risk Sample Plan and meets at least one of the criteria in of above, the

sample size shall be multiplied by 1.5 and rounded up for the next surveillance audit.

If the group does not meet any of the criteria , and meets at least one of the criteria below, RINA may decrease

the sampling plan for the next surveillance audit by one level as according to Table 3:

a. No major or critical non-conformities with the Group CoC Standard demonstrated at last RINA audit

of the group entity and sample of sites

b. Internal audits or internal control system are operating well, identifying issues and applying

appropriate corrective and preventive action.

Where the group is already in the Very Low Risk Sample Plan and meets at least one of the criteria of above, the

sample size may be multiplied by 0.5 and rounded up for the next surveillance audit.

The sampling plan shall not be reduced by more than one level during the lifetime of a certificate



Custody standard

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Sample selection

RINA shall select the sample of sites to be audited following the hierarchy set out in Table 4: from criterion 1

before criterion 2, from criterion 2 before criterion 3 and so on.

RINA shall not inform the client of the sample of sites selected until as close to the audit date as practicable, and

in all cases not more than 20 days prior to the proposed audit dater.

Audit findings at Group CoC audits

Grading the non-conformities found on sites

Non-conformities found during site audits shall be notified to the group CoC client, and shall be referenced to

the SITE at which they were found,

The AUDITOR who raised the non-conformities shall analyze and grade them into one of three categories:

Site Critical non-conformity – product is labeled or has been sold as MSC(or ASC)-certified but is

shown not to be certified;

Site Major non-conformity – there is a system breakdown which could result in non-MSC(or ASC)-

certified fish being sold as certified

Site Minor non-conformity – there is a system breakdown which is unlikely to result in non-MSC(or

ASC)-certified product being sold as certified product.

Where major and minor non-conformities are identified by RINA during site audits, the RINA shall raise a

further non-conformity (with the same grading) against the management system of the central office..

RINA shall determine whether the number of sites with major non-conformities exceeds the limit in Table 6, and

if so raise a group critical non-conformity.

Where a stratified sample is audited (i.e., 2 or more sub-groups are sampled):

a. The number of sites with major non-conformities from each sub-group shall be added together; and

b. The number of sites sampled from each subgroup shall be added together; and

c. The total number of sites with major non-conformities and the total number of sites sampled shall be used to

determine the point above.

Where critical non-conformities are identified by RINA during site audits, the RINA shall determine if the non-

conformity is either:

A site-specific non-conformity, which is limited to the specific site impacted and does not

indicate a failure of the group’s management or control systems, or

A systemic non-conformity, which indicates a possible or likely failure of group-level control or

verification systems, and/or has the potential to impact more than one site

If the critical non-conformity is determined to be systemic, RINA shall raise a critical non-conformity against the

group’s central office, except in the following case::

If the critical non-conformity is determined to be site-specific, RINA shall raise a major non-conformity against

the group’s central office.

If site-specific critical non-conformities are detected at 2 or more sites during an audit, RINA shall:

a. For a stratified group, in addition to above, suspend all sites in the stratum/sub-group where non-conformities

are detected.

For a stratified group, if site-specific critical non-conformities are found at 2 or more different sites within the

same subgroup during an audit, the group is not automatically suspended – only the sites within the subgroup are

suspended and a major non-conformity is raised against the central office’s management system. This allows

stratified groups to mitigate against the risk of a full group suspension if non-conformities are limited to only a

specific subgroup.

b. For a non-stratified group, raise a group critical non-conformity.



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Actions following site non-conformities

For initial certification, RINA shall not grant certification until all major and minor non-conformities are closed

out.

RINA shall verify that the group has taken actions on non-conformities raised on individual sites according to

their severity

Site Critical non-conformities shall result in the immediately suspending the site from the group until the non-

conformity has been fully addressed..

Site Major non-conformities shall be corrected within 30 days of their identification; if not corrected within

those timeframes, the site shall be immediately suspended from the group.

Site Minor non-conformities shall be corrected within 12 months of their identification if not corrected within

this timeframe, the non-conformity shall be immediately re-graded as site major, and there shall be 30 days given

to correct it. RINA may adjust the timeframes for the site to address non-conformities if the site is not handling

certified product during this timeframe.

Grading the non-conformities found against the group’s central office

The auditor who raised the non-conformities classify them into one of three categories:

Group critical:

1. there is a complete breakdown of the the management system such that the organisation’s assurances of

site conformity with the Group CoC Standard cannot reasonably be relied upon;

2. the number of sites where one or more Site Major non-conformities are raised meets or exceeds the reject

number shown in Table 6 ; or

3. Site critical non-conformities have also been raised against the central office .

Group major :

there is a breakdown of activities related to one element of the organisation’s internal management or

auditing system.

Group minor:

there is a partial lapse or partial breakdown of activities related to one element of the organisation’s

management or auditing system.

Where more than 4 group major non-conformities are raised during any one audit, a group critical non-

conformity shall be raised.


out.

Actions following central office non-conformities


out.

RINA shall address Non-Conformities raised on the group’s central office in the following manner according to

their severity:

Group critical non-conformities shall result in the immediate suspension of the group.

Group major non-conformities shall be corrected within 30 days of their identification; If not corrected

within this timeframe, the group shall be immediately suspended.



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Group minor non-conformities shall be corrected within 90 days of their identification.; If not corrected

within this timeframe, the non-conformity shall be re-graded as a major against the central office, and

there shall be 30 days given to correct it.

Adding new Sites to the Group

Approval of new sites where the increase in the number of sites is greater than 10% of the initial number

RINA shall inform the client that RINA approval is required prior to adding:

New sites totaling more than 10% of the number of sites included in the certificate at the most recent

audit; or

Sites with new activities to the group not already covered in the group’s CoC scope.

RINA shall approve the proposed new sites providing:

1. There is objective evidence (such as an internal audit report) that the new sites comply with

relevant sections of the Group CoC Standard;

2. Details required for the site register have been provided; and

3. RINA is confident that the central office has the required resources to manage the increased

workload.

If any of the elements above are not met, RINA shall not add the new sites to the group until the central office

has satisfactorily demonstrated how it will address the requirement(s) of concern.

If RINA requires an audit to be performed, the sample table and plan currently used for the group shall be used

to determine the number of new sites to be audited, unless RINA justifies why a different sample size is

appropriate.

The central office shall also be audited to address (point 3 above) if RINA is not confident that the group has the

required resources to manage the increased workload.

Approval of new sites totalling equal or less than 10% of the previous number

RINA shall require the group to notify it in writing of the addition of up to 10% of the number of sites present at

the most recent audit.

RINA shall verify that the new sites do not add new activities to the scope of the certificate.

a. If new activities are added, RINA may conduct an audit of the new activities if deemed necessary.

RINA may at its discretion require additional audit work to be undertaken.



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16. CONSUMER FACING (CFO) CERTIFICATION

Eligibility for Consumer-Facing (CFO) certification

RINA shall determine that an applicant is eligible for certification against the CFO CoC Standard if all the

following applicable criteria are met:

The organisation sells and/or serves certified seafood exclusively or primarily to final

consumers.

In general, the CFO CoC Standard is designed for organisations selling to final consumers only.

However, in some specific cases organisations that sell to both businesses and final consumers may be eligible to

be certified against the CFO CoC Standard (this might include ‘cash and carry’ wholesalers or fish mongers that

sell to a small number of restaurants as well as final consumers). In these cases, to be eligible the client needs to

demonstrate that sales to final consumers (i.e., by volume or value) are greater than sales to other businesses.

1. Any sites that carry out processing or repacking of certified seafood do so exclusively on behalf

of the applicant organisation.

2. If the organisation uses contract processors or repackers, these organisations have their own CoC

certification.

4. If the applicant has more than one site handling certified seafood:

a. All sites are under the control of a common management system maintained by the

organisation’s central office;

b. The central office has an ownership or franchise relationship with each site, or a temporary

right to manage all sites and staff where certified seafood is handled; and

c. Purchases of certified seafood are controlled by the central office, with controls to ensure

that all sites can only order certified seafood from certified suppliers.

Applicants for consumer-facing certification may have sites that carry out processing or repacking activities;

however these sites must be dedicated to handling certified seafood on behalf of the applicant organisation only.

Sites cannot process or repack certified seafood for other organisations or customers – otherwise they need to be

certified against the Default CoC Standard. A temporary right to manage a site means the organisation has direct

control over the staff working at site level. This is mainly applicable to catering operations.

Audit planning for CFO clients

RINA shall complete a risk assessment prior to each audit against the CFO CoC Standard, to determine the audit

activities to be carried out.

Where the client handles exclusively certified seafood at all sites, RINA shall score the client as Low

Risk and plan audit activities in accordance with Table 13.

In all other cases RINA shall:

a. Score every risk factor using Table 11 and sum the total;

b. Use the total score from Table 6 to determine in Table 12 whether the client is Low Risk or Standard

Risk;

c. Plan audit activities in accordance with Table 13, taking into account all the activities listed in Table

13.

RINA shall inform the client that for organisations with multiple sites, the central office and a sample of sites

will be audited.

Prior to each audit, RINA shall use Table 14 and the site list provided by the client to determine the number of



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sites to be visited.

RINA shall select the sites based on the factors below, in decreasing order of importance:

Site determined for sample by the accreditation body or MSC;

Likelihood that certified seafood will be handled on-site;

Same site not to be selected for consecutive visits where possible;

Logistical considerations: combination of trips, availability of auditors, geographic proximity;

Any additional criteria or constraints that would prevent sites from having short notice audits.

All operations sites that carry out processing or repacking activities of certified products shall be visited in

addition to the sample size determined by Table 14.

The sample size for site visits can include both operations sites, where relevant, and consumer-facing sites.

However, all operations sites that carry out processing or repacking activities need to be visited in addition to the

sample size from Table 14. If a site carries out both operations and consumer-facing activities, this counts as one

site for sampling.

For clients falling into the Standard Risk category, RINA shall:

- Ensure all auditors can demonstrate knowledge of the latest version of the MSC Seafood Sampling

Procedure.

- Compare the species handled by the client with the ‘Priority’ and ‘Optional’ species specified in the

MSC Seafood Sampling Procedure to determine if sample collection will be applicable.

If the client is not handling any of the Priority or Optional species identified in the MSC Seafood

Sampling Procedure, samples do not need to be collected, however this needs to be clearly documented

in the CoC audit checklist.

Where site visits are carried out at short notice as dictated by Table 13, RINA shall notify the client not more

than 48 hours in advance of the specific sites to be visited.

RINA can inform the client of the day or day(s) when the short notice visits will take place, but can only

communicate the names or addresses of the specific sites within 48 hours of the start of the site visits.

The 48 hours refers to 2 working days; this means that over a weekend RINA should notify the client on

a Thursday at the latest for sites to be visited on a Monday. If short-notice visits are not practicable at

some sites (e.g., closed catering sites without public access), then RINA can select sites for short-notice

visits from the remaining sites if possible.

If there are exceptional circumstances preventing sites being visited at short notice, such as access constraints,

RINA may reduce the number of short-notice site visits but shall provide a full justification in the audit checklist.

Evaluation for CFO audits

Opening meeting, gathering information and procedures

All audits shall begin with an opening meeting, at which auditors shall confirm with the client as a minimum:

Continued eligibility for CoC certification as per clause 6.2.9;

Continued eligibility for certification against the CFO CoC Standard as per clause 6.2.3;

Participant introductions and roles;

The purpose of the audit;

The audit plan, including how the audit activities will be undertaken and any visits to sites and/or

subcontractors;

The access required and the type of information needed at central office and site level, where applicable;

Confidentiality of the information shared during the audit;



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The proposed scope of certification;

The list of certified suppliers;

The list of any subcontractors that are or will be handling certified products and which ones are

independently certified;

The accuracy of information provided during the audit planning stage to complete Table 11 (Risk

Assessment Scoring for CFOs).

For each of the activities listed in the proposed scope, RINA shall collect and review evidence that the client's

management system and procedures as recorded and implemented, meet the requirements of the CFO CoC

Standard.

For clients with multiple sites, the auditor shall cross-check evidence seen at the central office with procedures

and activities observed at consumer-facing and operations sites.

During the audit, auditors shall review records relating to the receipt, sale and any applicable physical handling

of the products listed in the proposed scope.

The auditor should set a time limit for when these records are expected during the audit and raise a non-

conformity if this is not met.

At the MSC’s written request, the auditor shall also verify records available at the audit with information that

was supplied by the client to MSC previously.

This could be used to verify that information provided to MSC for the purposes of tracebacks or supply

chain reconciliations is consistent with records checked during audit.

If subcontractors are used, auditors shall verify that appropriate systems are in place to ensure identification of

certified products at point of dispatch and receipt.

Auditors shall establish that appropriate measures are taken by the client to segregate, identify, and prevent

mixing between:

Certified and non-certified seafood; and

Where relevant, between seafood certified to other recognised certification schemes sharing

MSC CoC.

Interviews

Auditors shall interview responsible personnel to verify their competency in understanding and applying the

CFO CoC Standard:

Auditors shall interview at least one individual per site visited and shall record their name or role and an

assessment of their level of competency in the audit checklist.

a. Additional interviews should be carried out as necessary based on the size of the organisation, the

complexity of operations and the range of staff who could affect the integrity of certified products.

Interviews shall be used to determine if personnel understand the relevant process or procedure which ensures

conformity with the CoC Standard.

Interview questions shall not be leading.

Refer to ISO 19011 for guidance on interviewing. Interviews will include (but are not limited to)



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management staff and employees who are responsible for buying and selling certified products,

conducting goods-in checks at point of receipt, applying product identification or labels, selecting

certified products for cooking, and managing traceability records.

Verifying traceability

During the audit, auditors shall carry out traceability tests on products that are identified or labelled as certified

to verify these products are traceable back to a certified source.

- At consumer-facing sites, the traceability test shall verify that any products sold or labelled as certified at

the time of the audit can be traced back to either a certified delivery or purchase.

- For single-site CFO clients, the traceability test shall verify that any products sold or labelled as certified

can be traced back to a certified purchase.

At a single site CFO client, the traceability test at site level will need to trace products from the point of

selling / serving back to purchase from a certified source (e.g., supplier invoice / delivery note).

However, at a consumer-facing site that is part of a larger organisation, the site may only be able to

demonstrate traceability back to a delivery received from a central operations site. In this case, the

remainder of the traceability test (back to point of purchase) must be completed from the central

operations site or central office. At a consumer-facing site, it may be possible to determine how the

product can be linked to a certified delivery by interviewing the responsible person. The staff might

explain how they selected the product that day, for example using a first-in-first-out policy, which allows

the delivery to be confirmed as coming from a certified receipt note. If no certified product is on-site

during the audit, the auditor can run a traceability test on a product similar to the certified products in the

client’s scope.

Where the organisation includes operations sites, the auditor shall also trace certified products received at a

consumer-facing site from the point of receipt back to the point of purchase, including any internal transfers,

processing, transport, subcontractor or storage steps.

The auditor shall carry out at least one traceability test involving an operations site during each

audit.

Additional traceability tests can be carried out based on the auditor’s judgement.

The total number of traceability tests shall:

Be determined in accordance with the guidelines in Table 13;

Be sufficient to verify the traceability systems are effective for all sites under the CFO certificate;

Ensure that a traceability test is always carried out back to point of purchase for any products selected

for product sampling.

Auditors shall use the template in the CFO audit checklist to complete all information for the traceability test,

and shall clearly detail how the product can be linked across different traceability records.

For example, if the client’s traceability system uses unique lot codes to trace products back from receipt

at a kitchen site to the central processing facility, this system and the specific lot codes would need to be

included in the traceability test description.

Product sampling

Where a client has been determined to be Standard Risk according to Table 12, the auditor shall also collect

product samples during surveillance and recertification audits.

The auditor shall:



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- Use Table 13 to determine whether product samples are to be collected at each consumer-facing site.

- Follow the MSC Seafood Sampling Procedure to determine which species to select for sampling and

how to collect the samples.

a. If no Priority or Optional Species are available at any sites visited, the auditor does not need to

collect seafood samples but shall record the justification in the CoC audit checklist.

- For each sample collected, make sure a traceability test has been completed as per 8.3.11.3 and all

product details are recorded in the CoC audit checklist.

The reason for having a traceability test back to suppliers conducted in combination with product

sampling is to make sure that the MSC has full information on the product or batch in the event that a

product authentication test indicates mislabelling and a full supply chain traceback will need to be

carried out by the MSC.

Verifying use of the ecolabel, logo and other trademarks

If the client uses the ecolabel, logo or other trademarks, the auditor shall verify that the client is permitted to use

trademarks by confirming that:

- The client can show a valid license agreement with MSCI signed by both parties; and/or

- The client can show proof of product approval from MSCI for packaging designs for a sample of

products, if using the trademarks on packaging or menus.

Where the client has used non-certified seafood ingredients in a product, the auditor shall verify the client’s

calculation for all or a sample of products to which this applies, as specified in the MSCI’s Certified Ingredient

Percentage Rules (www.msc.org).

Closing meeting

Auditors shall conduct a closing meeting at the conclusion of each audit with the client’s representative(s) to

verify that the client understands:

1. That until its certification status and information, including scope of certification, is displayed on

the MSC website, the client is not certified and cannot make any claims concerning certification.

2. Any actions that the client may have to complete and their timeframes before certification can be

awarded.

3. Any findings or non-conformities that have been identified during the audit and their likely

categorisation (subject to approval by RINA’s decision-making entity), timeframes to address

these findings and the process for verifying their completion.

Major non-conformities raised at surveillance and recertification audits result in a follow-up visit

within 90 days of the audit at which they were raised.

4. That the client must inform RINA of any significant future changes that affect the certification,

as specified in the contract.

5. That the scope, subcontractor and supplier list is correct and agreed.

6. The reporting timeframes for changes as detailed in section 5.3 of the CFO CoC Standard.

The auditor may allow other personnel to witness the site visits. Any diverging opinions

regarding the audit findings and/or conclusions between the auditor and the auditee can be

discussed and if possible resolved at this stage. If not resolved it is recommended to record all

opinions in the audit checklist.



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Additional requirements for major non-conformities at CFO audits

For CFO clients with multiple sites, where the number of sites with major non-conformities detected at

surveillance or recertification audits equals or exceeds the reject numbers in Table 5, RINA shall suspend the

certificate.

For CFO clients, where major non-conformities are detected at a surveillance or recertification audit, and the

certificate is not suspended, RINA shall carry out follow-up site visits within 90 days of the original audit:

1. Site visits should include at a minimum a review of the non-conformity, a traceability test and personnel

interviews, but do not need to cover the full CFO CoC Standard.

2. The sites to be visited shall include at least each site where a major non-conformity was detected, plus:

a. For clients with 6 or more sites, one additional site should be visited.

b. More sites may be visited where RINA deems it necessary.

3. Where an additional major non-conformity is raised against the same clause in the CFO CoC Standard

during the follow-up visits, RINA shall suspend the certificate and follow requirements in GCR 7.4.

4. Where a major non-conformity is raised against a different clause, or clauses, during the follow-up visits,

RINA shall follow the procedures above.

a. The aim of the follow-up visits is to help the auditor verify whether the major non-conformity

was a one-off issue or could indicate a problem with the CFO’s central management system (i.e.,

employee training, site-level procedures, etc.).



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17. TABLES AND FIGURES

Figure 1: Decision tree for consumer-ready tamper-proof packaging (CRTPP)



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Table 1: Activity scope definition

Activity Definition 1 Trading fish

(buying/selling)

This will likely be in nearly every company's scope, with the exception of contract processors that

do not take ownership of the product. In most instances, an additional activity will also be

selected for this client, unless they are solely a 'trader'. If they will take possession, they will also

need to have 'storage', 'wholesale' or 'distribution' selected.

2 Transportation This shall be used if a client is responsible for the transport of certified product from their

supplier, to their customer or between their sites. This is not used if the client subcontracts all

transportation.

Transportation companies are not required to be certified for CoC, unless they also take

ownership. In some cases, however, using a transport company could increase the risk to such a

level that you would require your client to ask a company to be certified - for example a vessel

involved in transhipping.

3 Storage This refers to product being held in a storage area by a company before

processing/distributing/selling it and after processing it. This will also likely be included in many

of the clients' scopes as they will be storing fish before processing/distributing/selling it and after

processing it.

4 Distribution Distribution shall be used for companies that receive sealed containers, pallets, etc., that may or

may not be broken down into smaller sealed units, and DELIVER them to customers or other

members of their group. I.e. they take possession, but not ownership.

5 Wholesale Wholesale shall be used for companies that receive sealed containers, pallets, etc., that may or

may not be broken down into smaller sealed units, and SELL them to customers or other

members of their group. I.e. they take ownership and possession.

6 Harvest This shall be used when the fishing vessels are being certified. If they are processing on board,

processing should also be recorded.

7 Packing or

repacking

This shall be used when the packaging is changed but the product remains the same. It is assumed

that companies processing will also be packing, so it is not necessary to select packing as well as

processing. If a company receives product from a processing company for the sole reason of

packing it into a specific type of pack, this scope category applies.

8 Processing To include all examples of processing including primary processing, secondary processing, value

added processing, fish preparation or any other activity where the product is changed (excluding

activities undertaken by ‘10’ or ‘11’ below).

Primary processing – the first time seafood is changed from its original form as it was harvested.

This includes heading and gutting, filleting, de-scaling, shelling etc.

Secondary processing – After primary processing, subsequent changes are made to the form of

the seafood. This includes preparation of the seafood with other ingredients to manufacture

products for foodservice or retail such as breading, adding sauces or breaking down the seafood

into smaller components (e.g. loins, mince, oil etc.)

Preservation – the long term conservation of seafood. This includes smoking, drying, canning and

freezing. This can be done at both primary and secondary processing.

Other processing – please specify.

9 Contract

processing

This refers to any certificate holder that carries out processing on behalf of the product owner

(does not take legal ownership of the product).

10 Use of contract

processor

This refers to any certificate holder that uses a contract processor to process, repack or transform

certified product on their behalf.

11 Retail to consumer This includes fresh fish counters at retailers, fish mongers, markets selling direct to consumers,

etc. where the product will be taken away and prepared before being eaten by a consumer, or

when sold in a traditional 'retail' environment.

12 Restaurants/

Take away to

consumer

This includes any foodservice situation fish and chip shops, standard restaurants, quick service

restaurants, etc. where the product is prepared on-site and sold directly to consumers as 'ready to

eat', or eaten on-site..



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13 Other Must be clearly defined and explained how it does not fit into another category.

14 Aquaculture Shall be used for any entity involved in the farming of aquatic organisms.

Table 2: Sample plan allocation



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Table 3:Allocation to sample table

Score from Table 12 Sample Table

80 or more 100% of sites audited

55 to 80 Sample Table 7

40 to 69 Sample Table 8

30 – 45 Sample Table 9

Under 35 Sample Table 10

The ranges in Table 3 intentionally overlap. Where this occurs (for example, a score of 30-35) RINA can make the decision on which

table to use and record this decision in the checklist.

Table 4:Sample selection hierarchy



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Table 5:Reject number of sites following major non-conformities

The reject number (Table 5) applies only for surveillance or recertification audits. The reject number is the total number of sites where at

least one major non-conformity was detected. The first column in the table refers to all sites visited (including the central office and all

operations and consumer-facing sites).

If 3 sites were visited, and one major non-conformity was detected at the first site, 2 major non-conformities at the second and only a

minor non-conformity at the third site, the reject number would be 2 and the certificate would be suspended.



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Table 6: Reject number of sites – Group CoC



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Table 7: Sample plan for Group CoC – High Risk



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Table 8: Sample Plan for Group CoC – Medium Risk



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Table 9: Sample plan for Group CoC – Low Risk



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Table 10: Sample Plan for Group CoC – Very Low Risk



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Table 11 : Risk assessment scoring for CFOs

Fulfilling the Risk Factors in questions 6 and 7 are not mandatory for CFO clients but will affect their risk scoring and the audit activities

that will be carried out.



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Table 12: Risk scoring

Total Score from Table 11 Risk level

1 - 12 Low Risk

13 - 18 Standard Risk

Table 13: Risk-based audit activities for CFOs

The MSC has developed a specific MSC Seafood Sampling Procedure, available for download from the MSC website. This document

establishes how auditors need to collect and send product samples for product authentication testing, and identifies the Priority and

Optional species that can be tested.



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Table 14: Site sampling for Consumer-Facing Organisations

These site numbers are in addition to the central office audit. Large organisations with over 1024 sites, falling in the last category, have a

relatively lower number sample size using the indicated calculation. This is due to the fact very large organisations generally have

advanced control and monitoring systems already in place, which can justify a lower number of site visits.

RINA · recommendation from RINA) for up to 90 days providing that the risk is low and adequate...

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