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Agenda Item 11: Group Certification Nicolas Viart Traceability Manager

Overview Objectives for the methodology What’s new? General principles Stratification and sampling plan Assessment Sanctions and non-conformances Adding sites Exercises

Objectives Consistent quotes for applicant groups Clients audited consistently Clients held to the same standard

What’s new? Requirements clearly distinguished between – CBs (appendix B) – Clients (appendix C) Requirements clearly separated for ‘group entity’ and ‘site’ Set risk assessment table Set sampling rates (number of sites to be audited)

Overview Objectives for the methodology What’s new? General principles Stratification and sampling plan Assessment Sanctions and non-conformances Adding sites Exercises

General Principles 1.Eligibility as a group – Ensure the potential Group qualifies with MSC definition of Group and criteria set in Appendix B 2.Stratification – Methodology is designed to assess homogenous groups – stratification is used if this is not the case 3.Role of the group entity – Overall manager and ‘certifier’ of the sites

General Principles 4. Role of the Certification Body Verifies the competency of the group entity to decide whether the group members comply with the MSC CoC standard, Group procedures and Appendix F CBs audit Group Entity and a sample of sites

Overview Objectives for the methodology What’s new? General principles Stratification and sampling plan Assessment Sanctions and non-conformances Adding sites Exercises

Prior to certification audit Group entity and sites must comply with Appendix C “Requirements for Groups”

Requirements for Groups (App. C) Group Entity – Designated MSC representative – Maintains register of sites + sign agreement with all sites – Defines and implement internal control system Purchasing Traceability Personnel management Records keeping – Sets up the system for managing non conformities within the group

Requirements for Groups (App. C) Group Entity – Ensures sites comply with CoC Standard – Defines the process of internal auditing Procedures Team of qualified auditors Management of non conformities Decision making on conformity of sites System verified by – Internal auditing (minimum once a year) – Input / output reconciliation at site level

Requirements for Group (App. C) When Group – Has defined management system & procedures – Trained all sites; and, when all sites & group entity have been internally audited; and, when a management review has been performed OK for certification audit

Auditors qualification criterias CB follows requirements of Appendix B CB requires minimum qualification (section 7) Certification audit

Stratification procedure Let’s see an example – Group made of Production facilities Storage facilities – Production facilities are working the same way – Storage facilities are working the same way – Storage is less risky than Production Sampling rate is lower – Stratification: Production strata Storage strata – Homogenous subgroup – Reduce overall sampling rate – Increase chance of successful audit

Stratification procedure Why? – One or a few sites might impact the sample rate for the rest of the group – Ease the certification process 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 1 – Own judgment – Generally by activity or region

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 Four strata – different activities and different countries/languages How many strata? Which one(s)?

Stratification - Conclusion The use of stratification shall be presented to client Stratification ensures assessment is – Fair – Relevant Strata remain during the whole life of the group, unless major changes occur.

CB defines sampling plan Remember – if there are more than one strata, follow this process for each strata Complete Table 1 Sample plan allocation. When multiple choices possible, use the highest score Identify correct sample table using Table 2 Determine number of sites certifier will visit (annex 1, table A, B or C), according to total number of sites per strata

Complete Table 1 Sample plan allocation. When multiple choices possible, use the highest score

Identify correct sample table using Table 2

Determine number of sites certifier will visit (annex 1, table A, B or C), according to total number of sites per strata

Choosing sites for on-site audit Number of sites given by Annex 1 – is the minimum number of sites to be visited – varies if it is for initial or surveillance audit Factors determining the sites to choose: Criterion 1 MSC/ASI sends specific request Criterion 2 site is part of investigation Criterion 3 logistical consideration Criterion 4 If more than 4 sites, 25% are chosen randomly

Overview Objectives for the methodology What’s new? General principles Stratification and sampling plan Assessment Sanctions and non-conformances Adding sites Exercises

Certifier assesses The compliance of the Group Entity with – Group procedures – Appendix C The ability of group entity to ensure conformity of each site with – CoC Standard – Group procedures – Appendix C

Certifier role at Group Entity level CB checks – If internal procedures are implemented and conform to Appendix C? – Internal audit reports – Qualification of internal auditors – Management of non conformities – Decision making process on site conformity – Impartiality of decision making body

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 – Conformity to appendix C MSC representative must not be present on site during audit, unless CB allows it

Overview Objectives for the session Scheme document and definitions General principles Audit, stratification and sampling plan Sanctions and non-conformances Adding sites Exercises Wrap up

Sanctions: Sites Depend on conformity with the CoC Standard 3 grades – Site Critical – Site Major – Site Minor

Sanctions: Sites -> Group Entity If CB found NC during site visit If Group had not identified it, then CB must raise – minimum 1 additional NC (same grading) Internal control system in place is not performing – Potential 1 additional NC (same grading) Surveillance system in place is not performing (if the the NC had not been detected during annual audit)

Sanctions: Sites -> Group Entity Example: – During site audit, CB found that site had been buying fish from supplier not listed on central buying list for more than a year NC raised against site NC raised against group entity’s control system: the group was not controlling purchase made by site NC raised against group entity’s verification system: the group had not detected this during last annual audit

Sanctions: 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 5) The site sanction procedure has not been correctly followed – Entity Major – Entity Minor

Correcting Non Conformances raised by CB or internal auditor

Correcting non-conformities – site Internal / CB audit Non ConformanceActions by GroupTime Frame Site CriticalSuspension of siteImmediate Evaluate - change1 month / 20 days* Check6 months Site MajorEvaluate1 month Change2 months Check6 months Site MinorEvaluate - change - check12 months Appendix C, a) determine root cause b) evaluate changes needed c) evaluate extent of the problem (other sites?) d) identify and implement changes e) record f) verify efficiency Evaluate Change Check * If raised internally

Correcting non-conformities – Group Internal / CB audit Non ConformanceActions by GroupTime Frame Entity criticalSuspension of GroupImmediate Entity majorEvaluate – Change - Check1 month/2 months* Entity minorEvaluate – Change - Check3 months/12 months* Appendix C, a) determine root cause b) evaluate changes needed c) evaluate extent of the problem (other sites?) d) identify and implement changes e) record f) verify efficiency Evaluate Change Check * If raised internally

Overview Objectives for the methodology What’s new? General principles Stratification and sampling plan Assessment Sanctions and non-conformances Adding sites Exercises

Adding sites: 10% rule When is CB pre-approval required? Addition is < 10% of the total for the stratum AND activities already included in group certificate – just written confirmation sent to certifier Addition is >10% OR activities not already on group certificate – certifier must approve the inclusion All sites shall be audited internally before joining the group certification

Scope Site c AK Salmon: Activity: Processing Presentation: Smoked Scope of Group Scope (11 sites) AK Salmon: Activity: Trading Presentation: Smoked AK Salmon: Activity: Trading Presentation: Smoked Scope of Group Scope (11 sites) Scope Site c AK Salmon: Activity: Trading, Processing Presentation: Smoked, Canned AK Salmon: Activity: Trading Presentation: Smoked AK Salmon: Activity: Processing Presentation: Canned Adding sites: scope extension Group Entity wants to add Site C Two points to consider if group needs CB auditor approval: >10%? New activity?

E-Cert implications: managing sites Upload list of sites (.xls) Add 1 or more sites Date a site leaves the group Display on MSC website

Conclusion

Objectives Consistent quotes for applicant groups Clients audited consistently Clients held to the same standard

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