Background

This program improvement involves review of three overarching section: (1) Harmonisation of Conditions Timelines and (2) Definition of Unit of Certification and (3) Fishery Traceability. All of these projects have previously been involved in the early stage public consultation held on 22 April - 1 June 2013 as part of an on-going Fisheries Standard Review (FSR) MSC has committed to undertake in 2013-2014.

Harmonisation of Conditions Timelines

The requirements for harmonisation are currently covered under Annex CI of the MSC Certification Requirements V1.3 (previously TAB D-15v2). These note that the timeframe and milestones required in conditions are an important factor in delivering the outcome of the condition; and that harmonisation of condition timeframes should be at least considered by Conformity Assessment Bodies (CABs) when examining harmonisation with other fisheries. The research carried out suggests that in the majority of cases (86%) CABs took timelines into consideration in their harmonisation work. In April 2013 the TAB agreed that further guidance should be included to help CABs to make informed decisions on whether to harmonise condition timelines. It was agreed that CABs should consider the time difference involved between two clients’ certifications and whether the deliverables for the later client can still be achieved during the same timeframe. The original policy proposal that went to early stage consultation was that guidance would be added to Annex CI. The feedback received during early consultation, along with findings from impact assessments and further research have all been taken into consideration when devising the current proposals.

To find out more about the history of development for the Harmonisation of Conditions Timelines, please click here.

Definitions of Unit of Certification

Revisions to the CR/GCR are proposed for a number of definitional and procedural issues relating to the UoC, as outlined below. These were discussed with a Working Group of the Technical Advisory Board (TAB) at a meeting in April 2013.

1) Definitions:  MSC’s current guidance on the specification of the UoC is confusing to clients and stakeholders.  Clarifications are needed of the definitions of terms such as ‘UoC’, ‘client’, ‘client group’ and ‘other eligible fishers’ such that the options for certificate sharing and the eligibility of different ‘entities’ to access the certificate are clearer.  These definitions were previously revised with the release of the Certificate Sharing TAB Directive 10 (v2 issued Feb. 2009). Experience since then has indicated that further revisions would be valuable.  A small clarification was also made to the definition of UoC in the vocabulary in CR v1.3 in January 2013, distinguishing between the UoC and a conceptual ‘UoA’.

2) Scoring elements in P1:  Clarification is needed as to the permissible options for defining the UoC, such as whether multiple species or stock units can be included as separate scoring elements within a single UoC, and the implications in these cases if some species or units fail the assessment.  The CR is currently unclear in this respect.  Some CR sections suggest that the treatment of multiple species as ‘scoring elements’ is only applicable in P2, while others suggest this is also possible in P1.  Most MSC fisheries assign only one species/stock and gear to each UoC and score them separately; however, some fisheries have also assessed multiple species (and gears) in single UoCs.

3) UoCs based on catch content:  CR additions are needed to confirm that fisheries may not decide which fishing hauls will be counted as part of UoC after the catch is landed or on the basis of the content of the catch.  If such UoCs were allowed, any haul that caught a high-profile bycatch or ETP species could just be ignored in scoring as an impact of the fishery.

4) Gear variations in UoCs:  Clarifications are needed on whether more than one gear type, or some variation of a gear type, can be included within a single UoC.  As in the species case above (issue 2), most fisheries do assess distinct gears as separate UoCs.  However, guidance has been requested for a case where some ‘secondary’ fishing activity happens only rarely, and the impacts of that gear are expected to be much less than the main gear.

5) Quota trading:  MSC has also been asked how CABs should assess the practice of ‘quota trading’, particularly in cases where it results in increased access to a fishery from outside the certified clients.  No guidance is currently provided as to how a CAB should treat and assess such activities.

To find out more about the history of development for the Definitions of UoC, please click here.

Fishery Traceability

Currently, during the fishery certification process traceability for MSC-certified products within a fishery is assessed and reported on. The point at which products ‘may enter further MSC Chain of Custody (CoC)' is determined by the fishery assessment team and is noted in the Public Comment Draft Report (PCDR) and subsequent Public Comment Report (PCR) and Final Report.

The section for traceability at the fishery in the Certification Requirements, Part C, was updated in August 2011. These changes helped clarify how the certifier should determine on a risk basis if the traceability systems are sufficient to allow the MSC certified product to enter the chain of custody.

In most cases, the fishery assessment determines that fishery traceability systems are sufficient up until the point of landing or point of sale, although this can vary for some fisheries. Beyond this specified point, all subsequent operators taking ownership of the product must have CoC certification to sell it onward as MSC-certified. However, if the fishery assessment team judges that traceability in the fishery is inadequate, they may require a separate Chain of Custody certification for the fishery in order for products to be sold onward as ‘MSC-certified’.

To find out more about the history of development for the Fishery Traceability, please click here.