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Home Program improvements database Chain of Custody Accessibility Consultations Consultation (June 2012): Chain of Custody (CoC) Accessibility.

Chain of Custody Accessibility

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Consultation (June 2012): Chain of Custody (CoC) Accessibility.

Start date: 24 June 2012
End date: 10 August 2012


Operating a credible, robust, and effective Chain of Custody (CoC) program is critical for the Marine Stewardship Council (MSC) to achieve its' strategic objectives and to support continued certification of sustainable fisheries.  Over the past several years, the MSC has received increasing feedback from stakeholders suggesting that the current CoC certification requirements (particularly for group CoC) are overly complex and create significant internal costs, and that requirements do not adequately account for different levels of risk posed by different types of companies. The CoC accessibility project was initiated in response to these concerns, with the aim of ensuring better retention of existing certificate holders and increasing uptake of the CoC program for new companies, particularly those in the following categories: restaurant chains, contract caterers, fresh fish counters at retailers, traders (only buy and sell seafood) and broadline distributors (i.e. ‘box-in/box-out’ distributors who handle products only in sealed boxes).


The MSC is seeking stakeholder input on a number of proposed changes to the CoC certification requirements resulting from this CoC accessibility project. These changes are intended to reduce complexity and internal costs associated with group CoC certification through an overall simplification and restructuring of the group requirements (currently Annex BC in the Certification Requirements). These changes also aim to better account for varying risk levels posed by different types of groups, through introducing streamlined certification requirements for ‘reduced risk groups’ (RRGs)  that have very good management systems and a high degree of control over all sites.

Who can comment?

This consultation is open to any interested stakeholders.

Documents out for consultation

CoC accessibility consultation document (pdf, 421kb) .

Proposed changes

As part of the CoC accessibility project, the following changes are recommended for sign-off by the Technical Advisory Board (TAB) in October 2012. The detailed changes can be found in the consultation document, and a summary of changes is below:

  1. Introduction of a new set of eligibility criteria to identify RRGs or those that do not do any processing and have a high degree of management control over all sites.  Eligible groups will have the option of becoming certified against a streamlined set of certification requirements, which are more outcome-based and better account for existing management systems and processes  (refer to Annex A).
  2. An overall simplification and restructuring of the Group CoC certification requirements (refer to Annex B) in order to :
    1. Reduce unnecessary complexity and process.
    2. Enable consistent understanding and application of the requirements.
    3. Better account for varying risk levels of different groups, through introducing specific requirements applicable only for Reduced Risk Groups or standard (non-Reduced Risk) groups, and waiving selected requirements for groups that only handle certified seafood (i.e. minimal risks of mixing or substitution).
  3. A revision of the process for addressing critical non-conformities found at conformity assessment body (CAB) audits of sites (refer to Annex C).
  4. A revision of the process used by CABs to determine sampling plan allocation for group certification (refer to Annex D).
  5. Enabling certain types of traders to become certified through a remote audit rather than requiring an onsite audit (refer to Annex E).

Consultation questions

The MSC is seeking stakeholder views on any aspect of the proposed guidance and requirements, included in Annexes A-E in the consultation document.  We are interested in getting feedback on the following:

  1. Referring to Annex A: Are the eligibility criteria for RRGs clear, auditable, and effective at distinguishing between groups with different risk levels?
  2. Referring to Annex B:
    1. Will the revised group CoC certification requirements successfully reduce complexity and internal costs for companies?
    2. Will this revision have negative impacts on the credibility of the Chain of Custody program?
    3. With consideration to the format, would you recommend developing two sets of separate requirements (one for RRGs and one for standard groups) or does the current ‘modular approach’ work well (i.e. one set of group CoC requirements, where certain sections or clauses apply only to RRG’s or standard groups)?

Note: The MSC also intends to develop separate sets of certification requirements for RRGs and standard (non-RRG) groups – these would not be normative, but would have guidance against each clause and be available on the MSC website; intended for use by companies and MSC outreach staff (rather than certifiers).

  1. Referring to Annex C:
    1. Do you support this change to the current process for addressing critical non-conformities found at site audits by CABs?
    2. What other concerns or risks would this change introduce, and do you have recommendations for better ways to address this issue?
    3. Referring to Annex D:
      1. Do you believe the current process for determining sample sizes should be changed, or could current issues be addressed through improved guidance on using Table BB3?
      2. Are there potential concerns or considerations related to this proposed change that have not been fully considered?
      3. Referring to Annex E:
        1. Is there a risk in removing initial onsite audits for traders who do not take physical ownership of products and do not use subcontractors?
        2. Do you have recommendations on how the requirements around remote audits can be more specific in order to ensure that remote audits are an effective verification method?

How to comment

Stakeholders may submit their comments using the contributor form (Word, 136kb) or in other format to, with the subject heading ‘CoC Accessibility.’

Next steps

Following this consultation, changes to the CoC requirements will be drafted, based on stakeholder input received and the results of pilot projects conducted. These draft changes will be submitted to the MSC’s Technical Advisory Board for final approval and subsequent publication in December, 2012.

Further information

Please direct any enquiries to:
Chelsea Reinhardt

Consultation documents

The following supporting documents are available for this consultation.