The best environmental choice in seafood

1. Disclaimer If any interpretive issues arise in relation to the issues covered in these presentations, the text of the English MSC Scheme Documents will prevail in all instances. The MSC is not responsible for any issues arising to any parties as a result of consulting these presentations. If you are unsure of any details on any of the subjects covered, please consult the relevant MSC scheme documents or contact the MSC at standards@msc.org. MSC Executive September 2011 The best environmental choice in seafood

2. Group Certification

3. What is a group? • In pairs discuss some criteria for what makes a group. • Share criteria

4. Learning Objectives • To understand what makes a group. • To understand the requirements for group chain of custody • To understand the intent of the revision

5. Content • Introduction to group certification • Requirements for groups (Annex BC) • Requirements for CABs (Annex BB) • Exercises

6. Who qualifies for group certification? A group is defined as a group entity and its associated individual sites For examples • Trade association • Fully owned industrial groups • Franchises

7. Group certification in short • Not all sites are audited by external CAB • Group entity responsible for conformity of each site • Each site is internally checked by group entity to ensure conformity with MSC requirements • Importance of internal communication and control • Existing procedures can be adapted to MSC requirements

8. General Principles Role of the Certification Body • Checks the competency of the group entity to decide whether the group members comply with: • MSC CoC standard • Annex BD • Annex BC • Group procedures relevant to MSC requirements • CABs audit Group Entity and a sample of sites

9. Why a group certification? • Increase accessibility to program • Group audited consistently • MSC has followed international good practices

10. MSC requirements • Requirements clearly distinguished between • CABs (annex BB) • Groups (annex BC) • Requirements clearly separated for ‘group entity’ and ‘site’ • Check list for groups (annex BC) • Set risk assessment table • Set sampling rates (number of sites to be audited)

11. Content • Introduction to group certification • Requirements for groups (Annex BC) • Requirements for CABs (Annex BB) • Exercises • * this indicates expected updates toAnnex BB and BC with the October publication

12. Requirements for groups (Annex BC)

13. Scope • The proposed group entity is a legal entity which can sign contracts • Sites undertake same activities • Entire group operates with one geographical region OR can be stratified

14. Management responsibility The group entity shall establish, implement and maintain management system • Policy Manual • Appoint an MSC representative 3. Sign an agreement between group entity and sites *other commitments see BC1.3 4. Maintain a register of sites 5. Use of subcontractors Notifying CAB of sites leaving or Joining

15. Internal control system 1. The group entity shall implement and maintain an internal control system to ensure site conformity with MSC requirements: • CoCStandard + • Annex BC + • Annex BD + • Group procedures (as relevant to MSC requirements)

16. Internal control cont. • Input and output reconciliation • Personnel management • Relevant personnel • Internal auditors • Documentation requirements • Appropriate to the scale of operation • Control of NC products • Importance of identifying batches

17. Internal control cont. • Corrective and preventive actions • Importance of evaluating the effect of a NC to other sites • Records • Management review • At least once a year • Include review of major and critical NC

18. Internal audits Internal audits of sites* formats/off site BC3.2 and BC 3.5.1.2 System must be documented • There must be • a programme of internal audits • a defined process to carry out conformity check • documents and tools to be used by Internal auditors • Auditors must be trained • How decision of conformity is reached must be decided • System can be internal audits or other

19. Internal audits cont. • Group checks conformity • Of sites against MSC requirements and internal procedures • Group against BC and internal procedures • Internal audit each site pre-initial certification

20. Non Conformity management System for managing non-conformities in the group • Internal and external • Corrective and preventative action • Grading of nonconformities • Timing of corrective actions for site nonconformities • Suspensions and withdrawal of sites

21. The group entity shall perform Internal audit and management review of their Internal control system prior to initial certification audit

22. Exercise: What must the group do before its certification audit?

23. What must the group do before its certification audit? • Is the policy manual written? • Has the MSC representative been appointed? • Are there agreements between sites and group entity?*BC1.3 4. Is the register of site up to date? 5. Does the control system comply with MSC requirements? 6. Has there been a management review? 7. Have all sites been checked? 8. No outstanding critical or major nonconformities? • OK for certification audit by CAB

24. Questions & Answers Questions?

25. Break

26. Content • Introduction to group certification • Requirements for groups (Annex BC) • Requirements for CABs (Annex BB) • Exercises * this indicates expected updates toAnnex BB and BC with the October publication

27. Stratification procedure • Why? • One or a few sites of high risk might impact the sample rate for the rest of the group • Same systems & procedures means ease of auditing • When? • Sites not undertaking the same activities • Sites are not in similar geographic region • How? • By following the Group’s natural organisation • By category shown in Table BB1 • Own judgment • Generally by activity or region (business unit)

28. Stratification example Group with head office in Thailand • 7 processing sites in Thailand • 12 distribution sites in Thailand • 5 processing sites in Vietnam • 15 retail to consumer sites in Vietnam How many strata? Which one(s)? Four strata – different activities and different countries/languages

29. CAB defines sampling plan • Remember – if there are more than one strata, follow this process for each strata *see BB4.3.1.4 variations

30. Complete Table BB1 Sample plan allocation. When multiple choices possible, use the highest score

31. Identify correct sample table using Table BB2 *New sample table D as below

32. *New sample table D also (now shown) Determine number of sites certifier will visit (table BB6,7,8 and 9), according to total number of sites per strata

33. Choosing sites for on-site audit • Number of sites given • is the minimum number of sites to be visited • varies if it is for initial or surveillance audit • Factors determining the sites to choose:

34. Certifier assesses • The compliance of the Group Entity with • Group procedures • Annex BC • The ability of group entity to ensure conformity of each site with • CoC Standard • Annex BD • Group procedures • Annex BC

35. Certifier role at Group Entity level • CAB checks • If internal systems are implemented and conform to Annex BC • Internal audit reports • Qualification of internal auditors • Management of non conformities • Decision making process on site conformity • Impartiality of decision making body

36. Certifier role at Site level • CB compares its conclusion on conformity of sites with group entity’s own decision • Conformity to MSC standard • Conformity to internal procedures (as relevant) • Conformity to annex BC • Conformity to annex BD • MSC representative must not be present on site during audit, unless CB allows it

37. Exercise: what types of non-conformities can you raise at group audits?

38. Non conformities: Sites • Depend on conformity with the CoC Standard • 3 grades • Site Critical • Site Major • Site Minor

39. Non Conformities: Sites -> Group Entity • If CAB found major or critical NC during site visit • CAB must assess responsibility of group entity • CAB must assess if other sites could be affected by the Nc • CAB must raised additional NCs accordingly

40. Non Conformities: Group Entity Depend on the severity of breakdown in the internal control system • Entity Critical • Complete breakdown of internal control system or verification activities • Site Major NC exceeds reject number (table BB5) • The site sanction procedure has not been correctly followed • Entity Major • Entity Minor

41. Questions & Answers Questions?

42. Adding new sites to the group • If less than 10% existing number: group to notify CAB; no further actions • If more than 10%: group to notify CAB and CAB to approve following assessment of • Objective evidence sites have implemented requirements • Group has resources to handle increase in workload to control and check sites • Register of sites must be updated within 10 days

43. Content • Introduction to group certification • Requirements for groups (Annex BC) • Requirements for CABs (Annex BB) • Exercises

44. Thank you Please send comments, queries, suggestions to: Alison.roel@msc.org www.msc.org