MSC Group Chain of Custody (CoC) Guidance for Non-Reduced Risk Groups

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1 MSC Group Chain of Custody (CoC) Guidance for Non-Reduced Risk Groups 1. About this document This document is a non-normative guidance document intended to help companies understand CoC requirements. The official, normative version of MSC s Certification s, including group CoC requirements is available at: Please contact your certifier or local MSC Outreach staff with any questions about CoC certification: 2. Overview of Group CoC Organisations that wish to become certified as a group against the MSC s Chain of Custody (CoC) standard have to meet certain requirements set out by the MSC. When you are certified as a group, you take on some responsibilities to make sure all sites meet MSC requirements. Your certifier (or Conformity Assessment Body/ CAB) will then only audit your head office (called the group entity in MSC requirements) and a sample of your sites, rather than all sites. The MSC distinguishes between two types of groups Reduced Risk Groups (RRGs) and all other groups (non-rrgs). To be certified as a RRG, the group must meet 4 eligibility criteria this will allow the group to become certified against a slightly streamlined set of requirements. For RRGs, some requirements are waived and there is less need to create or document MSC-specific procedures. In general, certification for RRGs is designed to require less time and effort than certification for non-rrgs. 3. Certification s for Non-Reduced Risk Groups: This table sets out the requirements that your group will need to meet in order to become CoC-certified as a non-reduced Risk Group. You, the group, will be responsible for making sure all sites meet these requirements and this will be checked by your certifier (CAB) at the certification and surveillance audits. Key terms: Policy: A policy statement defines a general commitment, direction, or intention Process: A process is a set of activities that are interrelated or that interact with one another Certification requirements for Non-Reduced Risk Groups (Non-RRGs) and guidance for companies BC1 BC1.1 Management Responsibility Management systems and documentation BC1.1.1 The group entity shall establish and maintain management systems that provide assurance that every site covered in the group certificate conforms with the MSC group CoC requirements Your head office needs appropriate systems and policies so that your sites meet the requirements in this document and the MSC CoC standard, as well as Annex BD of the MSC Certification s. You are responsible for making sure sites comply with these requirements. MSC Group CoC Guidance for Non- Reduced Risk Groups 1

2 BC1.1.2 The group entity shall appoint one person ( the MSC representative ) who irrespective of other duties, is responsible for ensuring the group s conformity with all MSC group CoC requirements. The name, position and contact details of the MSC representative shall be documented and communicated to the CAB The group needs to appoint one person as the MSC representative and give the name and details to the CAB (certifier). It is recommended that you also have an MSC deputy or a back-up person in case your primary MSC contact is out of the office. BC The CAB shall be advised of changes of MSC representative within 10 days If you change the MSC representative, let your certifier know via or phone within 10 days. BC1.1.3 The group entity shall document the roles and responsibilities of the MSC representative, internal auditors, and other key personnel at the group entity and site level For each person responsible for the MSC program, you need to write down their roles and responsibilities. For example, the MSC representative might be responsible for maintaining the site list and scheduling internal audits. It may be useful to go through these requirements and identify a specific owner for each one. BC1.1.4 The group entity shall ensure that all documents demonstrating conformity with the MSC group CoC requirements are stored for a minimum of three years You need to keep relevant MSC records for at least 3 years. They can be stored in electronic or hardcopy, and can be stored at sites or at the head office. This includes traceability records for MSC products (invoices, bills of lading, etc.) as well as documentation of the group entity review (see BC3.3.2) and internal audit records (see BC3.6). BC1.1.5 The group entity shall establish and maintain documented policies and procedures covering the following: BC Division of roles between the group entity and sites, including how any changes to MSC group CoC requirements and internal group policies or documents will be communicated to sites BC The process for ensuring that all internal auditors and other key personnel are trained on MSC group CoC requirements and relevant internal policies to ensure competence in performing functions related to the MSC group CoC requirements You need to have written policies that cover specific aspects of how you manage your group CoC programme. If you already have policies developed for other purposes that meet a specific requirement, there is no need to develop a new MSC specific policy. In many cases, these policies may simply require minor changes to your existing standard operating procedures. You need to write down the respective responsibilities of the head office (group entity) and the sites in terms of managing the group CoC programme. For example, the group entity might be responsible for developing group-wide policies and training materials, scheduling internal audits, collecting ecolabel licence fees, and training internal auditors. The sites might be responsible for training site employees, providing sales data to the group entity, and following up on any non-conformities found during site audits. It is also important that you have a procedure for making sure any changes to MSC requirements or your internal policies are communicated to the sites in a timely manner. This policy should describe how you will train the necessary staff, including internal auditors, on MSC requirements. For example, you could include MSC information into existing training courses, or you could train all your site managers on MSC requirements and have them train their relevant kitchen staff. You may not need to train all employees about MSC requirements, but the MSC requires that key personnel are competent to perform functions related to the MSC group CoC requirements. Competence shall be based on appropriate training, skills, and experience. MSC Group CoC Guidance for Non- Reduced Risk Groups 2

3 BC The process for ensuring MSC certified products are purchased, received, and handled in conformity with MSC requirements in section BC2.2 This policy should cover all points in section BC2.2 of this document. For example, this policy should specify how your group will control purchasing to ensure that only valid CoCcertified suppliers are used for sourcing MSC products. The policy should also explain how MSC products will be checked at the point of receipt to make sure they came from a genuine MSC certified source. The policy will also need to specify how your sites will be able to keep MSC products identifiable as MSC at all stages of handling. BC The process for ensuring that traceability is maintained throughout all stages of product handling so that that all MSC certified products are traceable back to a certified supplier and forward to the immediate customer, and to enable an input/ output reconciliation as required in sections BC2.3 and BC3.2 BC The process for ensuring that if the MSC ecolabel is applied by sites and/or the group entity, it is used in conformity with the requirements set out by MSCI and the licence agreement, as required in section BC2.5 BC The process for verifying the effectiveness of internal control systems, which shall include procedures for the following: a) Conducting input/output reconciliations at site level as per BC3.2.3 b) Conducting internal audits of sites and documenting audit results as per BC3.1 c) Identifying non-conformities and issuing corrective actions and sanctions as per BC3.4 This policy should describe how your group s traceability system works. A sample policy might look like this: (please note this is an example only every organisation s systems will be different): Incoming products are assigned a batch number which is then recorded in the internal inventory database along with the invoice number of the incoming raw materials. This batch number is carried through all stages of processing and is linked with a six-digit product code that identifies the final product and whether it is an MSC certified product. This product code and the expiration date are recorded into the central inventory system along with the sale invoice when the product is sold. This policy should set out how your group will make sure that sites are only using the MSC ecolabel on MSC certified products and are following all MSCI requirements. These requirements can be found at. This policy should also cover how your group will manage product approval forms (for new products that want to use the MSC ecolabel), collect turnover declarations (on sales of MSC products) and pay any relevant fees to MSCI for use of the ecolabel. This policy should describe how your group will make sure that your internal control systems (policies and procedures related to MSC products) are working and effective. This policy should describe how you will conduct input/ output reconciliations as per requirement BC3.2.3 (for example, will each site be responsible for comparing all their sales and purchases of MSC products over the past year? How will this information be reviewed by the group entity?). The policy should also describe how you will conduct internal site audits (i.e. will you build some MSC criteria into existing audits, or create new audits specific to MSC? Who will conduct the audits?) Finally, this policy will also need to describe how any problems found during internal audits will be identified and corrected. BC1.2 Group Control BC1.2.1 The group entity shall demonstrate its ability to ensure that all sites conform with MSC group CoC requirements, including that: a) For each site there will be a designated contact who is accountable for ensuring the site complies with all MSC group CoC requirements and relevant internal policies b) Sites will conform with the terms of the contract between the group entity and the CAB c) Sites will allow the group entity, CAB, MSC, and ASI access for purposes of conformity audits to the site s premises and records and approval to speak with The head office (group entity) needs to demonstrate how it will control sites and impose requirements when needed. For each site, you need a designated contact who will oversee the MSC program. This can be a specific person or a defined role (i.e. restaurant manager). You also need to demonstrate how the head office will ensure all sites meet the specific points a) through d) of this requirement. For example, the group may own all sites, you may already have a contract in place with each site that will cover these points, or you may have to implement a new agreement with each site in order to guarantee these requirements are met. MSC Group CoC Guidance for Non- Reduced Risk Groups 3

4 personnel d) Sites will accept any sanctions applied to the site by the group entity or CAB in the case of non-conformity BC1.2.2 The group entity shall sign a certification contract with the CAB and shall be responsible to the CAB for the following related to the group entity and all sites: a) Conformity with MSC group CoC requirements b) Fulfilment of any conditions on sites or the group entity raised by the CAB c) Payment of all certification costs related to sites and the group entity d) All communication with the CAB (excluding expedited or unannounced site audits) Your contract with your certifier (CAB) will specify that the head office is responsible for the group s overall compliance with requirements, and making sure any certifier conditions are met. The head office is accountable for managing the certifier contract on behalf of all sites, including payment and communication to the certifier. BC1.2.3 Sites shall not use subcontractors to handle MSC certified products unless subcontractors hold their own CoC certificate, are part of the group, or perform only storage or transport activities. Sites can only contract with subcontractors directly if these are transport or storage companies, if the subcontractor is listed as a site in the group, or has its own CoC-certification. Other subcontractors are allowed as long as they are contracted and managed by the group entity (head office), rather than an individual site. BC All subcontractors shall be used in conformity with Annex BD4 of the MSC Certification s. All subcontractors used by the group (both at the head office and site level) must be managed in line with requirements in Annex BD4 of the MSC Certification s. For example, some subcontractors will need signed agreements in place, and there are specific timelines for notifying the certifier when new subcontractors are used. BC1.2.4 The group entity shall enter into an agreement with each site, which will set out as a minimum: a) That the site will meet all requirements in BC1.2.1 b) The responsibilities of each site and key personnel with respect to MSC group CoC requirements c) That the site agrees to be listed as a site in the group s application for MSC certification and may be listed on the MSC website d) In the case of sites that are not part of the same legal entity as the group entity, the agreement shall contain the name and/or legal identify of each party, contact name and addresses, and be legally binding on the group entity and the site s owner. To demonstrate how the group entity (head office) will control all sites, you will need some type of agreement in place with sites that covers the points in this requirement and explains how sites will conform with requirements in BC This agreement should set out the respective responsibilities of each site in terms of managing the MSC group CoC programme. For example, the site may have specific duties such as carrying out employee training or conducting the input/ output reconciliation. Note, as per clause BC1.2.5, depending on your group s ownership and contracts already in place with sites, you may not need a specific agreement with each site for MSC. See BC1.2.5 for more information. MSC Group CoC Guidance for Non- Reduced Risk Groups 4

5 BC1.2.5 The group entity shall demonstrate the implementation of the agreement in BC1.2.4 in one of the following three ways: a) The sites are fully owned by the group b) The group entity has a contract with each of the sites requiring the site s compliance with decisions made by the group entity c) The group entity has other evidence of a commitment from each of the sites as outlined in BC In order to demonstrate that your group entity (head office) has full control over sites with respect to MSC requirements, you will need to prove that one of the following is true: All sites are owned by the group (i.e. one restaurant chain, with every site owned by the same company), or The group entity has a contract with each site that makes sure the site must comply with decisions made by the group entity (this may be common for franchise type arrangements), or You have a commitment with each site that includes the points in BC1.2.4 In the first two cases (own all sites or contractual agreements in place with each site) you don t need to create a separate agreement specific to MSC to meet requirements BC1.2.4 and BC The fact that you own your sites or have contracts in place making sure sites must abide by group entity decisions should be sufficient. BC1.3 Site Register BC1.3.1 The group entity shall maintain a register of all sites included in the group certificate, which shall be provided to the CAB before the initial audit and shall include for each site: a) Name or position, , or phone for a designated contact at each site who is responsible for ensuring the site conforms with MSC group CoC requirements b) Physical and postal address of the site c) Status of each site (current, suspended, or withdrawn) d) Date of joining and (if applicable) leaving the group certificate. You need to maintain a list of all sites in the group covering the information in this requirement for each site. Your certifier will need to collect the site list before your initial certification audit, and may also request to review the site list later on. There is no defined format for the site list but many companies choose to maintain a spreadsheet with all the site details in one place. BC1.3.2 The group entity shall keep the site register up to date and notify the CAB within 10 days of any sites added or withdrawn, by sending the CAB details for new or withdrawn sites as specified in BC Once you are certified, if you add new sites to the group certificate or take sites off, you need to send your certifier the details for each new or withdrawn site within 10 days of the change. BC If the number of sites added since the last CAB audit is in excess of 10% of the number of sites at the time of that audit, or if the additional sites add new activities to the scope of the certificate, the CAB must provide written consent before new sites can be added. You may wish to add a large number of sites to the group all at once (e.g. your company purchases a new division with many sites). If the total number of new sites is more than 10% of the number during your last certifier audit, you need to inform your certifier and get approval before you can add these sites. You must also get written or approval from your certifier before adding any sites that introduce new activities not covered in your current scope of certification. BC When the CAB is notified of new sites to be added, the CAB may decide to conduct additional audit activities if deemed necessary. Your certifier has the right to conduct additional audits if they feel new sites affect the risk level of your group. MSC Group CoC Guidance for Non- Reduced Risk Groups 5

6 BC1.3.3 When sites are withdrawn from the group certificate, the group entity shall notify the site that they may no longer continue to use the MSC claim or ecolabel anywhere on the site, including packaging and menus When sites are removed from your group certificate for any reason, you need to notify the site they can no longer use the MSC claim, ecolabel, or any MSC packaging. You may want to reclaim any unused packaging, or otherwise verify that the site understands this requirement. BC2 Internal Control System BC2.1 The group shall be able to demonstrate that procedures covering requirements in BC2 are implemented, either through written documentation or evidence of existing procedures and management systems (these may not be MSC specific). You do not need to create new, MSC-specific procedures for all requirements in this section. But, you need to be able to show your certifier that these procedures are implemented ( working in practice ). Some MSC requirements may be covered by existing systems or procedures in place (such as Standard Operating Procedures). Your certifier may also verify the implementation of procedures through observation on site and discussions with employees. BC2.2 Purchasing, Receiving, and Handling BC2.2.1 The group shall have an implemented process to ensure that MSC certified products shall only be purchased from certified suppliers that have a valid MSC certificate Your head office (group entity) needs to control the purchasing of MSC products by all sites on the certificate. The head office can either purchase all MSC products directly, or it can maintain an approved supplier list, and ensure sites can only buy or receive MSC products from these approved suppliers. The head office is responsible for making sure all suppliers of MSC products have a current CoC certificate. This can be validated on the MSC s Find a Supplier website: BC2.2.2 The group shall have an implemented process for confirming that all MSC certified products delivered or received at all sites are verified as MSC certified. When MSC products are received (either at the head office or sites), there needs to be a system to verify that the product delivered is in fact genuinely MSC-certified. This may mean that invoices or delivery notes are checked against the product itself or package labels upon at the point of product delivery/ receipt. The key is to make sure that if a product ordered as MSC certified is received and appears not to be MSC certified, or cannot be proven to be MSC, this should be identified as such. This product cannot be sold or labelled as MSC until it is verified as genuine MSC certified (refer to section BC2.2.4). BC2.2.3 The group shall have an implemented process to ensure that all MSC certified products are identifiable as such at all stages of purchasing, storage, processing, packing, labelling, selling and delivery. MSC products need to be identifiable as MSC at every stage of handling. This doesn t necessarily require labelling products or packages with MSC any internal coding or labelling system is sufficient as long as it is effective. Some companies may use an internal bar-coding or unique numbering system, which can be referenced against a list of product descriptions that indicate which products are MSCcertified. Other companies may choose to apply a unique label to all MSC products. The important point is that your system keeps MSC products identifiable at all steps i.e. thawing, transport, repacking, etc. MSC Group CoC Guidance for Non- Reduced Risk Groups 6

7 BC2.2.4 The group shall have an implemented process for product that is labelled or identified as MSC certified but cannot be verified as such (non-conforming product), which shall include the following: a) The group MSC representative shall be alerted within two days of non-conforming product being identified at a site. b) The group MSC representative shall determine the underlying cause of the issue and shall issue corrective actions against all sites potentially impacted. c) Non-conforming product shall be quarantined, relabelled, or otherwise prevented from being sold as certified or labelled as certified until its certified status can be verified. d) If there is a risk that non-conforming product has been sold or shipped as certified, the CAB shall be alerted within two days of identifying the issue and recall or relabeling procedures shall be followed where needed to prevent affected product being sold as MSC certified. If you receive product that should be MSC certified but isn t identifiable, or cannot be proven to come from an MSC source, there are specific requirements you need to follow. For example, this might be the case if you ordered some MSC fish but when you receive the product, it isn t labelled as MSC on the delivery note or packaging. Or, this could happen if your supplier substituted a different product from the original order, or if the label fell off a product or can t be read for any reason. In these cases, product is referred to as non-conforming and you will need to follow requirements a-d in this section to make sure that no product is sold or labelled as MSC if there is a chance the product is from a genuine MSC-certified source. If useful, you can copy the wording from this requirement into your own policy or procedure documents. BC2.2.5 Records shall be kept of any incidence of nonconforming product and the corrective actions taken as per section BC If you discover non-conforming product at any site, you need to document this instance and record how you followed requirements in BC2.2.4 (for example, you can retain any records you sent to alert your certifier or the various sites of the issue). These records may be requested by your certifier or reviewed at the next audit. BC2.3 Traceability BC2.3.1 There shall be a system to ensure that all MSC certified inputs can be traced back to the immediate supplier, and MSC certified outputs can be tracked forward to the immediate customer. If the group entity or site is a retail or foodservice site dealing with final consumers, forward traceability to each consumer is not required, however total volumes of certified products sold must be recorded to enable an input/ output reconciliation. The MSC CoC standard requires all MSC products to be traceable from the point of purchase from your supplier all the way through to the point of sale to customers. (note: if you sell directly to final consumers, such as a restaurant chain, you don t need to keep traceability through the point of sale). The MSC does not require you to use any specific traceability system, but the system must be effective at allowing MSC products to be traceable. Your system can be electronic, paper-based, or a combination. The certifier will verify that the traceability system is effective, is implemented in practice, and covers all MSC products handled by your organisation. BC2.3.2 Where product is transformed or repacked, inprocess traceability shall be established so that all MSC certified product will be identified and segregated during all handling and storage operations. If your organisation does any repacking, processing, or otherwise transforms MSC certified products, your traceability system must ensure that all MSC products are traceable and identifiable throughout all stages of handling. BC2.4 Personnel and training MSC Group CoC Guidance for Non- Reduced Risk Groups 7

8 BC2.4.1 There shall be an implemented process to ensure that all key personnel are competent to perform functions related to the MSC group CoC requirements. Competence shall be based on appropriate training, skills, and experience for the relevant functions performed. Personnel who are responsible for managing your organisations MSC program and handling MSC certified products need to be adequately trained to ensure they comply with MSC requirements. The MSC does not specify how you should train employees or contractors, but the certifier will verify that any people responsible for developing or implementing MSC processes have an adequate level of competency to meet requirements. BC2.4.2 All internal auditors shall be able to demonstrate competence in carrying out internal audits, including knowledge of the MSC group CoC requirements, internal audit processes, identification and grading of non-conformities, and issuing corrective actions as defined in sections BC3.1 and BC3.4. BC2.4.3 The group entity shall maintain a record of MSC training completed and shall be able to demonstrate that all key personnel receive training at a frequency as required to maintain knowledge of current MSC requirements. BC Training records covering all sites shall be accessible by the Group entity when requested by the CAB, MSC, or ASI. Internal auditors need to understand relevant MSC requirements and be competent at carrying out audits and identifying and grading non-conformities. This is true whether your internal auditors are employees of your organisation or are part of another auditing company. You will likely need to provide some specific training for internal auditors on Chain of Custody and group CoC requirements, and make sure they stay up-to-date with any changes in requirements. The MSC no longer requires a specific length of experience for internal auditors. You will need to document any MSC training that is completed for internal auditors and other employees. This training can be delivered through any effective format or incorporated into other training (e.g. food safety topics) and does not need to be MSC specific. BC2.5 Ecolabel use and licensing BC2.5.1 The group entity shall be responsible for ensuring that all sites using the MSC ecolabel shall do so in conformity with all MSCI licensing requirements as found at The group entity (head office) is accountable for making sure any sites using the MSC ecolabel follow all ecolabel rules and guidelines. BC2.5.3 If the group entity and all sites are part of the same legal entity and the MSC ecolabel or MSC claim are to be used, the group entity shall sign the licence agreement on behalf of the group. The group entity shall coordinate required ecolabel applications for approval and turnover declarations and shall be responsible for fee payments for all sites in the group. BC2.5.4 If the group entity and sites are not all part of the same legal entity and the MSC claim or MSC ecolabel are to be used by individual sites, then each site shall sign a licence agreement with MSCI. Each site shall be individually responsible for their ecolabel applications for approval, turnover declarations, and payment of ecolabel fees. If the site fails to comply with MSCI licensing requirements, MSCI will notify the group entity, which shall audit the site and if necessary, issue a non-conformity against the site. This clause applies if the group entity and all sites are part of the same legal entity (for example, one restaurant or supermarket chain). This clause applies if the head office and all sites are not part of the same legal entity. For example, this might be the case if your group is a collection of independent restaurants managed by a third-party group manager. In this case, if sites are using the MSC ecolabel or selling products with the MSC certified claim, the sites will need a licence agreement directly with MSCI. Each site will then be individually responsible for all requirements related to product approvals, turnover declarations, and payment of any applicable fees to MSCI. However, if a site does not fully abide by MSCI licensing rules, then the group entity is expected to take some action MSC Group CoC Guidance for Non- Reduced Risk Groups 8

9 and issue a non-conformity against the site. BC3 BC3.1 Verification System Internal site audits BC3.1.1 An onsite internal audit shall be conducted of every site before initial certification to ensure the site conforms with the MSC group CoC requirements. BC The group entity shall ensure that all nonconformity identified during internal audits is recorded and corrective actions are verified as completed and effective before the certificate is issued. It is the responsibility of the group entity to ensure internal audits have been carried out at every site before the initial certification audit. These do not need to be MSC-specific audits (for example, they could be food safety or hygiene audits), but you will have to show that the audit still evaluates conformity with the relevant MSC Group CoC requirements. The aim is to make sure all your sites are fully prepared to handle MSC certified products in line with MSC requirements before the group is certified. Internal audits can be conducted either by internal auditors that are part of the group (for example, employees of the sites or the group entity), or they can be carried out by an external auditing company (not your MSC certifier). Any non-conformities found during the internal audits before certification must be fully addressed before the group can become certified. It is the responsibility of the group entity (head office) to ensure this happens. You will probably want to keep a record of all the internal audit reports/ findings and any corrective actions taken. You don t need to personally verify that each site has implemented corrective actions, but you will need to work closely with your site representatives to get documentation that all non-conformities have been fully corrected before certification. You will want to keep a record of these non-conformities and the corrective actions in case your certifier asks to review it. BC3.1.2 The group entity shall conduct an internal audit of all sites at least once per year after the initial certification to verify that each site is in conformity with MSC group CoC requirements. This requirement does not apply to the group if all seafood handled by the group entity and its sites is exclusively MSC certified seafood. The requirement does not apply to all sites in a stratified subgroup if all seafood handled by the stratified subgroup is exclusively MSC certified At least once a year, after certification, you will need to make sure all sites are audited to make sure they meet all MSC requirements. This does not need to be an MSC-specific audit, and can be conducted either by internal auditors that are part of the group, or an external auditing company (not your MSC certifier). If all seafood handled by your certified sites is MSC certified, then you do not need to conduct internal audits. If all sites in a designated subgroup (stratification) handle only MSC certified seafood, these specific sites do not require internal audits. These sites may still be audited by your certifier during your regular certifier audits. If you start handling non-certified seafood for the first time, you will need to alert your certifier. MSC Group CoC Guidance for Non- Reduced Risk Groups 9

10 BC3.1.3 If during an internal site audit the group entity discovers that the site is not in conformity with an MSC requirement, the non-conformity shall be graded as follows: a) Critical non-conformity: Any incidence where product is found to be labelled or sold as MSC or MSC certified but is shown not to be MSC certified shall be graded as a critical non-conformity and the group entity shall follow procedures as set out in BC3.4.1 and BC b) Non-conformity: All other cases where the site is not in full conformity with an MSC requirement shall be graded as a non-conformity and the group entity shall follow procedures as set out in BC Where an internal audit discovers that a site does not fully meet MSC requirements, the internal auditor must grade these as either a critical non-conformity (where product has been sold as MSC but is found not to come from an MSC certified source) or as a non-conformity for all other cases. The process for addressing each type of non-conformity is laid out in section BC3.4. For a critical non-conformity, you may also need to follow guidelines for non-conforming product in BC BC3.1.4 There shall be an annual schedule for internal audits for sites which shall contain: a) The proposed date of the next internal audit b) The date of the last internal audit c) The result of the last internal audit, specifying open non-conformities and the dates by which they must be closed d) The name of the internal auditor who performed the last internal audit e) The site s current status (current, suspended or withdrawn). The group needs to keep a schedule of all internal audits, which covers all points in this requirement. This schedule can be kept in electronic copy or hardcopy. The group entity (head office) should be able to access a copy at all times and it will likely be reviewed by your certifier during audits. If a site has been suspended or withdrawn from the group, this should be indicated on the schedule (all other sites will have a status of current ). BC3.2 Input/output reconciliation BC3.2.1 The group shall ensure that records are retained to enable a reconciliation of MSC certified inputs/ outputs of any certified product, over any given timeframe, for a designated shipment or group of shipments. You must maintain documents that allow you to show all MSC certified products purchased, processed, and sold over any given timeframe. You must also be able to demonstrate (based on records) the total volume of MSC product purchased, processed, and sold for any designated shipment of raw materials or finished product. These records will often include invoices, bills of lading, processing records, etc. Records may be maintained in hardcopy or in electronic version. MSC Group CoC Guidance for Non- Reduced Risk Groups 10

11 BC3.2.3 The group entity shall verify conformity with BC3.2.1 through reviewing records of input/ output reconciliations from every site on an annual basis. a) BC3.2.3 does not apply to the group if all seafood handled by the group entity and its sites is exclusively MSC certified seafood. The requirement does not apply to all sites in a stratified subgroup if all seafood handled by the stratified subgroup is exclusively MSC certified The head office (group entity) is responsible for making sure that an input/ output reconciliation is carried out at all sites at least once per year. The input/output reconciliation involves comparing purchase and sales records from each site (such as invoices) and will also need to account for any conversion factors if the product is transformed. The objective is to make sure the volume of MSC product sold over any time period is less than or equal to the volume purchased by the site. The input/output reconciliation can be done by each site individually using records from the site. In this case, the head office (group entity) is responsible for reviewing records of the input/output exercise to make sure it was completed successfully and that no problems were found. Or, the head office can collect records from each site and conduct an input/output reconciliation centrally across all sites however, the head office still has responsibility to make sure the input/output reconciliation has been done at each site at least once/year. The MSC does not specify the timeframe or products for the input/output reconciliation. You may look at records over any given time period (i.e., one month, etc.), or all records relating to one designated shipment of raw material. You can include all MSC products in the input/output reconciliation or you can choose a sample of products. You will need to keep documentation of this exercise, as per requirements in BC3.6. BC3.2.4 The group entity shall be confident that systems used for input/ output reconciliation are effective for all MSC certified products handled by the site If all your sites (or a specific stratified subset of sites) handle only seafood which is certified, you do not need to conduct this input/output reconciliation for those sites. The group needs to make sure that input/output reconciliations conducted for sites are applicable for all MSC certified products handled by the site. This is relevant where a site may have different record-keeping systems for different types of products (i.e. frozen fish might be purchased in bulk and broken down into portions, while fresh seafood might be purchased through a different process and sold as whole fish). If the site has very different systems in place for recording sales and purchases of different MSC products, then the site may need to include a range of products in their input/output reconciliation. Or, the site could complete a separate reconciliation for a different product category. BC3.3 Internal review of the group entity BC3.3.1 At least once a year (and before initial certification) the MSC representative shall conduct an internal review to verify the group s conformity with MSC group CoC requirements and the effectiveness of the group s management system. The internal review is intended to make sure your group MSC system is functioning well, to understand any problems, and make necessary changes to policies or procedures. This is a fundamental aspect of group certification. You can combine this review with other similar management reviews, for example ISO, BRC, etc., as long as it covers all points in requirement BC3.3.2 below. The MSC representative is responsible for conducting the internal group review. Where possible, the internal review should include other key personnel responsible for the MSC programme, but there are no specific requirements on who must participate. This will also help you to be prepared for your next certifier audit. MSC Group CoC Guidance for Non- Reduced Risk Groups 11

12 BC3.3.2 The internal group entity review shall include: a) An assessment of the group s ability to conform with MSC group CoC requirements b) A review of the latest versions of MSC group CoC requirements, including any changes since the previous review and how these will be incorporated into procedures c) A review of internal and CAB audit reports from the previous year, non-conformities identified, corrective actions issued, and whether non-conformities have been closed d) A review of any complaints received relating to the MSC programme and actions taken as a result e) Identification of any systemic issues or recurring sitelevel non-conformities, and proposed changes to the group s systems to address these issues f) Documentation that all relevant sections of BC3.3.2 have been completed The internal review needs to cover parts a) through f) listed in this requirement. The overall effectiveness of the CoC programme and related policies/ procedures are to be reviewed, along with relevant internal and certifier audit reports, and any internal or external complaints that were raised relating to the CoC programme. If any problems or systemic issues are identified with the CoC system, the review can then identify changes to policies, systems, or training that can address these issues. The MSC representative should keep a record of each internal review conducted and have at least brief documentation of how it covered all necessary elements. If any sections of the internal review are not relevant for any reason (e.g. no complaints were raised), this should be noted in the documentation of the review. For the initial group entity internal review (before certification) points c- f may not be relevant for Reduced Risk Groups if internal site audits have not been completed. BC3.3.3 Any proposed management changes arising from the group internal review and the timeline for their implementation shall be documented and communicated to the group entity s management If the internal review produces any changes to systems, policies, or procedure, the MSC representative needs to make sure these changes are communicated to the appropriate contacts in management to help ensure they are implemented. This can be documented through correspondence, or a documented meeting or phone call, for example. BC3.4 Non-conformities and sanctions BC3.4.1 If a critical non-conformity is identified, the group entity shall follow the procedure below: a) Within two days of detection, issue a critical nonconformity against all sites affected and alert the sites, MSC representative, and CAB b) Within two days of detection, suspend the site from the group certificate until the CAB and group entity are confident that all underlying causes of the nonconformity have been addressed c) Identify whether this is a site-specific non-conformity or if it has the potential to affect other sites and may indicate a breakdown in the group s systems or processes d) Issue corrective actions to address the non-conformity, including actions that must be taken by any affected sites and the group entity to prevent reoccurrence e) Ensure that the non-conformity has been corrected within 30 days of detection f) Ensure that the site makes no claim relating to MSC certified products during the suspension g) Record evidence of the information in parts a-f above for all critical non-conformities identified. Where a critical non-conformity is detected, during an internal audit or any other time, the group is responsible for following requirements in this section. This is part of the internal control system for group CoC that allows certifiers to audit only a sample of sites, rather than all sites. Part of this process requires identifying the cause of the nonconformity, if possible, and determining if the issue could have affected other sites (e.g. the problem was related to a group-wide policy). If this is the case, even if nonconformities haven t yet been detected at other sites, corrective actions must address all sites potentially affected. The aim is to ensure the problem does not spread to other sites and will not reoccur. Any sites where a critical non-conformity is detected must be suspended from the group, which means during the suspension the site cannot use the MSC ecolabel or sell any products as MSC. The suspension cannot be lifted until all causes of the problem have been fully addressed, but there is no minimum time period. However, all critical nonconformities at sites must be corrected within 30 days. MSC Group CoC Guidance for Non- Reduced Risk Groups 12

13 BC3.4.2 If a non-conformity is identified, the group entity shall follow the procedures below: a) Issue a non-conformity against all sites affected and ensure the sites are alerted within four days of the nonconformity being detected b) Investigate the cause of the non-conformity c) Identify whether the cause is a site-specific nonconformity or if it has the potential to affect other sites and may indicate a breakdown in the group s systems or processes d) Issue a corrective action to address the nonconformity, including actions that must be taken by any affected sites and the group entity to ensure similar non-conformity does not occur at other sites e) Verify that the non-conformity has been corrected within 90 days of detection f) Record evidence of the information in parts a-e above for all non-conformities identified. For any site non-conformities found by the group or internal auditors that are not graded as critical, you must follow procedures in this section: a) You will need to inform any sites that may be affected by the non-conformity, even if it hasn t been detected at each site yet b) You need to understand what caused the nonconformity c) Does it have the potential to affect any other sites? (even if this hasn t happened yet) d) You need to put in place corrective actions to fix the problem for all potentially affected sites, and to help ensure it doesn t reoccur. This may include changes to processes, training, etc. e) You need to make sure the non-conformity has been fully resolved within 90 days f) Keep a written record of the issue including when & how these steps were completed. This can be done through records or any other documentation BC3.4.3 If a non-conformity detected at the site level has not been fully corrected within 180 days of detection, a critical non-conformity shall be issued against the site and the group entity shall follow procedures as outlined in BC If a non-conformity has not been fully corrected within 180 days, the group is responsible for re-grading this as a critical non-conformity and following procedures for a critical nonconformity. BC3.5 Decision on site conformity BC3.5.1 The decision on whether a site is in conformity with MSC group CoC requirements shall be made by a person or a committee who has not been involved in the site audit (a decision maker ), and shall be based on the objective evidence provided by the site audit and all other evidence that may be available to the decision maker. The MSC representative shall be notified of all decisions related to site conformity. The requirement states that you need a designated person or committee to review internal audit reports and other relevant evidence for each site to determine if that site meets MSC requirements and can remain on the group certificate. The person or committee cannot be the same as those conducting the internal site audits, as this would be a conflict of interest. If a site is found not to meet MSC requirements based on this review, then appropriate actions will need to be taken either to issue non-conformities and/or to suspend the site from the group certificate. Any findings need to be communicated to the MSC representative and the site s status should be updated on the site register (i.e. current, suspended, or withdrawn). The MSC is not specific on the frequency of this decision on site conformity, but it is recommended this occurs at least once per year after the internal audits are completed. BC3.5.2 If the group entity does not have a person that was not involved in the site audit, a committee of key personnel from sites may make the conformity decision, excluding themselves from decisions affecting their own site. This clause refers to a case where the committee or people reviewing site conformity must be the same as those conducting internal site audits. In this case, it is possible to form a committee of people from the sites to make this decision on site conformity, provided that they don t give input on their own site. MSC Group CoC Guidance for Non- Reduced Risk Groups 13

14 BC3.6 Verification records BC3.6.1 The group entity shall maintain the following records related to the internal verification system, which may be in electronic or hard copy and may be kept at the group entity or site level: a) Schedule of all internal audits completed, including date of the audit and site name or number b) Internal audit results, including objective evidence, audit notes, non-conformities, corrective actions, and evidence that the non-conformities have been closed out within the designated timeframe c) Records of all input/ output reconciliations performed as specified in BC3.2, including the site number (if applicable) and date, volumes of inputs/ outputs, supporting documentation, and any non-conformities resulting d) Records of all traceability exercises performed as per section BC2.3 and any non-conformities resulting. You need to maintain certain records related to your CoC programme and your control over sites. These records may be kept in a central location or at sites, but the MSC representative should be able to access these records if needed to share with the certifier or during audits. These records include the internal audit schedule and all internal audit reports or results, along with any evidence collected from internal audits. Records of non-conformities should be maintained, along with the corrective actions applied. Records should also be kept of any input/output reconciliation exercises performed, and electronic or paper copies of records are acceptable. MSC Group CoC Guidance for Non- Reduced Risk Groups 14

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