Result of consultation (March-April, 2012)

Start date: 10 May 2012
End date: 10 May 2012

Introduction

Under the Marine Stewardship Council’s (MSC’s) existing Chain of Custody (CoC) requirements, all operators that take ownership of MSC certified products (up until the point of consumer-ready-tamper-proof-packaging) must be certified against the MSC’s Chain of Custody standard. This process helps to ensure that every operator in the supply chain complies with the seafood traceability standards and that all the products bearing the MSC ecolabel originated in a MSC certified fishery.

Under the current CoC Standard and Requirements, certification of each operator (or group) requires an onsite audit by an independent, accredited certifier against the CoC standard. The frequency of and format of surveillance audits are determined by the certifier using a standard risk assessment table. The MSC also offers a group Certification programme, which enables large companies or groups of organisations to become certified as a group entity. Under this programme, the group appoints an MSC representative and takes responsibility for internal controls and management across the entity.

Feedback from stakeholders suggests that the current CoC requirements may need to be adjusted in order to increase accessibility for foodservice operators, such as restaurants, fresh fish counters, caterers, or broadline distributors. Some foodservice operators have voiced concerns about the high costs and complex process required for CoC certification, particularly those companies that perceive themselves as low risk (for example, they only source MSC certified products, they have highly-centralised controls in place, or they don’t transform MSC products during ownership).

In response to these concerns, the MSC is undertaking an internal project to identify possible alternative solutions that will improve the accessibility of Chain of Custody certification in the foodservice sector, without compromising the credibility of the standard or the MSC ecolabel.

Purpose

The purpose of this consultation was to seek stakeholder input on the project plan.

Results of the consultation

Many useful comments relating to the implications of this project were received. Some concerns were raised about potential risk of substitutions for end-of-chain operations. Commenters also indicated their support for this initiative, and an interest in the results of the risk assessment work.  MSC provides specific responses via email to consultees on comments received.

Next steps

The MSC presented the reviewed project plan to the Technical Advisory Board Working Group (TABWG) in April. The TABWG agreed for the MSC to pursue a two-phased approach to CoC Accessibility:

1. Short-term changes to improve CoC Accessibility(for Technical Advisory Board review in October), which will incorporate the following:

  • Overall simplification of group CoC requirements.
  • Introducing new, streamlined certification requirements for ‘highly-centralised groups’ (such as major retailers or restaurant chains), which are more outcome based and eliminate unnecessary processes.
  • Enabling remote certification audits for traders who do not take physical ownership or have sub-contractors.
  • Introducing additional controls such as an unannounced audit requirement and publicising the DNA testing programme.
  • Developing training materials for MSC group representatives.
  • Providing improved guidance and communication materials for Conformity Assessment Bodies (CABs) and MSC ‘outreach’ teams to use with clients.

These proposed changes will be piloted over the 2012 and submitted to public consultation from June-August 2012.

2. Longer-term investigation of other operating models:

In parallel, the MSC will work on defining an alternate ‘licensing and inspection’ model for end-of-supply chain operators to possibly replace the need for CoC certification for these operators, including:

  • Determining the details of the licensing agreement and verification model, including selecting an inspection body or CAB to conduct verification.
  • Conducting a cost/ benefit/ risk assessment.
  • Developing a pilot programme with a very limited set of operators, to begin later in 2012.

Further information

Please direct any enquiries to:

Chelsea Reinhardt

Product Integrity Manager

chelsea.reinhardt@msc.org