MSC - Marine Stewardship Council Consultation … · MSC - Marine Stewardship Council Consultation Document – Auditor Competencies Consultation Dates 1–30 September 2017 MSC Contact

MSC - Marine Stewardship Council Consultation Document – Auditor Competencies Consultation Dates 1–30 September 2017

MSC Contact Graham Bruford

FOR CONSULTATION

Consultation Document – Auditor Competencies 1

1. Executive summary Stakeholder feedback is sought on proposals to strengthen the ISO 19011 (guidelines for auditing management systems) training requirements for fishery assessment teams due to concerns being raised about their impartiality and objectivity. Corresponding changes for ISO 19011 training for CoC auditors are also proposed. Stakeholders are also requested to respond to proposals to amend the fishery team competencies to decrease the amount of experience required for assessment team members and introduce additional competencies specific to the areas of harvest control rules, harvest strategies and ecosystem impacts.

2. Purpose of the consultation To seek stakeholder views on proposed options to:

• Strengthen the ISO 19011 training requirements for both fishery assessment teams and CoC auditors.

• Amend the fishery team competencies to: o reduce the experience requirements from five to three years; and, o include additional competencies on harvest control rules, harvest strategies and ecosystem

impacts. 3. Background 3.1 ISO 19011 – guidelines for auditing management systems1 To ensure compliance with the Global Seafood Sustainability Initiative (GSSI) benchmark, a requirement for one fishery team leader per CAB to be ISO 19011 trained in ‘appropriate auditing techniques’ and ‘the impartial objective role of the assessor’ (with responsibility to cascade this to other team leaders within the CAB), was agreed by the Technical Advisory Board (TAB) in June 2016. This requirement will be published in the General Certification Requirements (GCR) March 2018 release. However, concerns have recently been raised over the impartiality and objectivity of fishery assessors following the Executive’s observation of fishery assessment site visits. Additional concerns have also been raised by other stakeholders. The adequacy of the agreed ISO 19011 training requirement to address these recent concerns has therefore been questioned. In response, three options to strengthen ISO 19011 training requirements are being explored and are presented in Section 4.1. Strengthening ISO 19011 training requirements would apply to CoC auditors. Currently CoC CAB Lead Auditor ISO 19011 training requirements exist for one CoC auditor per CAB to undergo ISO 19011 training, and then train and/or mentor all other CoC auditors at the CAB. This requirement could be extended to apply to all CoC auditors in line with any changes agreed for fisheries. As these CoC auditors tend to work

1 ISO 19011 provides guidance on auditing management systems including the principles of auditing, managing and conducting audits, and the competence of individuals involved in the audit process.

Key points - Proposed re-focusing of fishery team competencies to emphasise the importance of auditing

skills alongside marine science expertise. - Associated strengthening of auditing skills requirements for CoC auditors to mirror those for

fishery teams. - Addition of new fishery team competencies to ensure all key qualifications and competencies

are covered by the assessment team.

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FOR CONSULTATION – 1-30 September 2017


independently, having this additional auditor training would further enhance the assessment rigour of the MSC program. 3.2 Fishery expertise and auditing skills There have been ongoing discussions about creating a balance between fishery expertise and auditing skills within the fishery assessment team. The Executive recognises that auditing requires a specific skill set, and that a high level of expertise in marine science does not necessarily include auditing skills. The Executive also recognises that prospective fishery team members with auditing expertise but a lower level of expertise in marine science, can develop their marine science expertise through appropriate training and participation in MSC assessments. This balance can be achieved by introducing amendments to both the fishery team member and the fishery team qualifications and competency criteria. Proposals for these amendments are presented in Section 4.2. These amendments may help to increase the pool of prospective assessment team members to carry out fishery assessments in the future. 3.3 Fishery team competency requirements in specific areas of expertise Several Technical Oversight (TO) findings have been raised in relation to the scoring and setting of conditions for harvest strategy and harvest control rule Performance Indicators (PI 1.2.1 and PI 1.2.2). This contrasts with comparatively few TO findings being raised for stock assessment PIs. Fishery team qualification and competency criteria could therefore be amended to include explicit reference to specific areas of expertise such as harvest strategy and harvest control rules. 4. Considerations Sections 4.1 to 4.3 present the options and changes being proposed which will address the issues outlined in Sections 3.1 to 3.3. 4.1 ISO 19011 training requirements The options being considered to strengthen ISO 19011 training requirements are:

1. At least one member of every assessment team should undertake detailed ISO 19011 training of at least three days’ duration. Details of the proposed content of this training are given in Appendix A Table x on p.6.

2. All fishery team leaders should undertake the detailed ISO 19011 training. 3. All team members should undertake a basic level of ISO 19011 training e.g. as an online module or

from a colleague who has undergone the detailed training. An additional proposal is to strengthen the CoC CAB Lead Auditor ISO 19011 training requirements to apply to all CoC auditors in line with any changes agreed for fisheries. As noted above, this would further enhance the assessment rigour of the program, as most of these auditors tend to work independently. Appendix A presents these proposed changes to the ISO 19011 training requirements. 4.2 Length of experience required to meet fishery team member and fishery team competency criteria

(Tables PC 2 and PC 3) The Executive seeks to introduce a balance between auditing skills and marine science expertise in the fishery assessment teams to ensure that assessments are consistently carried out within the scope of the MSC fisheries standard. The proposal of increased ISO 19011 training requirements (options 1–3 in Section 4.1) is accompanied by a reduction in the number of years of experience required in the fishery team member and fishery team qualifications and competency criteria (Tables PC2 and PC3 in the Fisheries Certification Requirements). The proposal is to reduce the number of years of experience from five years to three years where assessors can demonstrate competence in undertaking assessments against the MSC Fisheries Standard. These two proposals (Section 4.1 and 4.2) should be considered as part of the same project in the policy development process. 4.3 Fishery team qualifications and competency criteria (Table PC 3) There are two additional proposals relating to fishery team qualification and competency criteria. These are:

1. Amend fish stock assessment qualifications to include specific reference to harvest strategy and harvest control rule expertise



2. Clarify the qualification and competency criteria for assessing the ecosystem impacts of the fishery The Executive is also interested to receive feedback on any other topics or areas of the fishery team qualifications and competency criteria (Table PC 3) that should be amended. Appendix B presents the proposed changes to the Annex PC of the Fisheries Certification Requirements as outlined in Section 4.2 and 4.3. 5. Potential interactions with other work The changes proposed here would need to be reflected in the MSC’s future submissions to demonstrate compliance with the Global Sustainable Seafood Initiative (GSSI) benchmark, the ISEAL Assurance Code and other benchmarks including the WWF Comparison of Wild Capture Fisheries Certification Schemes. 6. Next steps If there is clear support for the proposed changes during this consultation, then the additional ISO 19011 changes can be included in the March 2018 GCR release and the fishery competencies in the FCR August 2018 release, subject to TAB and MSC Board of Trustees approval. However, if further development time is needed following stakeholder feedback, the strengthened ISO 19011 changes would go out for further consultation in February to April 2018, be reviewed and signed off by the TAB and the MSC Board in June 2018 and the final requirements included in the August 2018 GCR and FCR releases. There will also be opportunities for further consultation on the proposed changes, particularly with CABs and ASI during a CAB workshop in September 2017 and the Tripartite meeting in March 2018, if needed. All consultation feedback will be anonymised and published in a report on the MSC Program Improvements website after the consultation closes. This will also be emailed to all respondents. 7. Who can comment? How do I give feedback? This consultation is public and open to all interested parties. The online feedback survey allows you to respond to specific questions on this topic. We also welcome any more detailed comments that you wish to make on this consultation which can be emailed directly to: [email protected] 8. Consultation Questions Please follow the link to the Survey Monkey questions regarding this consultation item which are: i. Do you agree that MSC should strengthen the ISO 19011 auditing skills requirements for fishery

teams? (Yes/No) ii. If yes which option do you prefer:

a. Every assessment team member should have a basic level of ISO 19011 auditing skills training (Yes/No)

b. Every assessment team should have at least one team member who has undertaken detailed ISO 19011 auditor skills training of at least 3 days’ duration. (Yes/No)

c. Every assessment team leader should undertake detailed ISO 19011 auditor skills training. (Yes/No) d. Other (please specify)

iii. Do you agree with the proposal to strengthen the CoC Lead Auditor ISO 19011 training requirements to apply to all CoC auditors in line with any changes agreed for fisheries? (Yes/No)

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iv. Fishery team competencies a. Do you agree with the proposal to reduce the current fishery team member and fishery team competency requirements from five years’ experience to three, where assessors can demonstrate familiarity with the MSC Fishery standard. (Yes/No) b. Do you agree with the proposal to include a new fishery team competency criteria to cover harvest control rules and harvest strategies? (Yes/No) c. Do you agree with the proposal to include clarification of the qualifications and competencies of team members responsible for assessing the ecosystem impacts of the fishery? (Yes/No) d. Please give details of any alternative wording you’d like to propose for the harvest control rules and ecosystem impacts competencies. e. Please give details of any additional amendments to the fishery team competencies which have not been specified in this consultation, which you think should be considered for further development.

v. Please provide any further comments on this consultation item not covered by the other questions.



Appendix A: Proposed GCR Changes

Please note that the changes shown below are to the requirements agreed by TAB in June 2016 for Fishery Team Leader ISO 19011 training. Insertions are shown in red, and deletions in strikethrough (example: strikethrough).

6.1 Personnel 6.1.1 CABs shall ensure that CAB lead auditors for CoC all CoC auditors, Group CoC central office auditors, CAB lead auditor for fisheries fishery team leaders and members:

6.1.1.1 Have signed the MSC’s Code of Conduct (available on the MSC website) confirming that they will comply with the Code; and

6.1.1.2 Conform to the competency and qualification criteria listed in section 5 of the CoC CR and Annex PC of the FCR, as appropriate for CoC audits, Group CoC audits and fishery assessments.

6.1.2 CABs shall use one or more of the verification mechanisms in each qualification and competency criterion listed in Tables 1, 2, 3 of the CoC CR and Tables PC1, PC2 and PC3 of the FCR to verify that allCAB lead auditors for CoC, CoC auditors, CAB lead auditors for fisheries, fishery team leaders and members each comply with the qualification and competency criteria.

6.1.2.1 For examination results, the pass mark shall be 70% for new and existing CoC auditors and fishery team leaders and members. 6.1.2.2 CoC auditors and fishery team leaders and members shall have a maximum of three attempts to obtain the pass mark. 6.1.2.3 CABs shall provide a contact to the MSC to whom the results of the examination will be sent. 6.1.2.4 Should CoC auditors, fishery team leaders or members fail to obtain the pass mark after three attempts, the CAB shall contact the MSC to agree on a training action plan for these individuals.

a. The auditor, team leader or team member shall be unable to conduct MSC CoC audits or fishery assessments until the MSC has approved the satisfactory completion of the plan and the auditor, team leader or team member has successfully passed the failed module on their third attempt.

6.1.3 CABs shall ensure that:

6.1.3.1 All CoC auditors have the qualifications and competencies detailed in Table x below in addition to those listed in Table 1 in the CoCCR.

At least one of their CoC auditors is designated as the CAB lead auditor for CoC; 6.1.3.2 The CAB lead auditor for CoC has the qualifications and competencies detailed in Table x below in addition to those listed in Table 1 in the CoCCR; 6.1.3.3 The CAB lead auditor for CoC mentors and/or trains all other CoC auditors at the CAB to ensure they are familiar with third party management system conformity assessment auditing techniques;

(Option 1:) 6.1.3.4 All Fishery Team Leaders have the qualifications and competencies detailed in Table x below in addition to those listed in Table PC1 in Annex PC1 in the FCR; At least one of their fishery team leaders is designated as the CAB lead auditor for fisheries



(Option 2:) 6.1.3.4 At least one member of each assessment team has the qualifications and competencies detailed in Table x below in addition to those listed in Table PC1 in Annex PC1 in the FCR. Table x: CAB lead auditor for CoC and CAB lead auditor for fisheries qualification and competency criteria 1. Third-Party Product and Management System Conformity Assessment Auditing Techniques

Qualifications a. Pass International Register of Certificated Auditors’ (IRCA) / Exemplar

Global recognised Environmental Management Systems (EMS) / Quality Management Systems (QMS) or Global Food Safety Initiative (GFSI)-approved standards or Hazard Analysis Critical Control Point (HACCP) lead assessor training course; or

b. Registration as an EMS / QMS auditor with IRCA or Exemplar Global; or

c. Pass a course on auditing based upon ISO 19011 with a minimum duration of three days.

i. The content of an ISO 19011 course shall include: •principles of auditing •managing an audit programme •audit programme objectives and extent •audit programme implementation •audit programme records •audit programme monitoring and reviewing •audit activities:

o initiating the audit; o conducting document review; o preparing for the on-site audit activities; o conducting on-site audit activities; o preparing, approving and distributing the audit report;

completing the audit; and o conducting audit follow-up

•practical audit examples from the MSC context.

Guidance If the MSC develops ISO 19011 training, then this qualification could be met by completing it.

Competencies a. The ability to apply appropriate audit principles, procedures and techniques to the planning and execution of different fishery assessments so that fishery assessments are conducted in a consistent and systematic manner;

b. The ability to verify the accuracy of collected information and be aware of the significance and appropriateness of assessment evidence to support assessment findings and conclusions;

c. The ability to understand and assess those factors that can affect the reliability of the assessment findings and conclusions;

d. The ability to manage a fisheries assessment team in accordance with the MSC requirements.

Verification Mechanisms

a. Certificate of passing auditor training course recognised by a reputable auditor registration organisation e.g., IRCA, Exemplar Global;



Guidance Additional verification evidence may include:

a. Fisheries assessment and/or CoC audit reports;

b. Accreditation body witness or office audits CAB on-site observations, review of fishery assessment and/or CoC audit reports and feedback from clients.

6.1.3.5 The CAB lead auditor for fisheries has the qualifications and competencies detailed in Table x below in addition to those listed in Table PC1 in Annex PC1 in the FCR; 6.1.3.6 The CAB lead auditor for fisheries mentors and/or trains all other fishery team leaders at the CAB to ensure they are familiar with third party management system conformity assessment auditing techniques. 6.1.4 3 Personnel appointed as reviewers or decision makers by the CAB shall be sufficiently experienced and qualified to evaluate the verification processes, working papers and associated evidence and recommendations made by the assessment / audit team (ISO 17065 7.5).

Guidance 6.1.4

For fishery reviewers and decision makers, CABs are reminded that the criteria of ISO 17065 clause. 6.1.2.1 will apply. The CABs will still have to demonstrate the reviewer and/or decision maker is competent. One way of demonstrating this competence would be for the reviewer and/or decision maker to pass the online training module for fishery team leaders.

6.1.4 3.1 For CoC audits against the Default CoC Standard or the Consumer-Facing Organisation CoC Standard, the reviewer shall be a qualified CoC auditor (see section 6.1.2 of this document and section 5.1 of the CoC CR).

6.1.4 3.2 For Group CoC audits, the reviewer shall be a qualified Group CoC auditor (see section 6.1.2 of this document and section 5.1 of the CoC CR).

6.1.5 4 The CAB shall ensure the satisfactory performance of all personnel involved in the audit and certification activities.

6.1.5 4.1 There shall be documented procedures and criteria for monitoring and measurement of the performance of all persons involved, based on the frequency of their usage and the level of risk linked to their activities.

6.1.5 4.2 The CAB shall review the competence of its personnel in light of their performance in order to identify training needs.

Commented [SK1]: Consultation note: For both options, clauses 6.1.3.4 and 6.1.3.5 would be deleted:

Commented [SK2]: Consultation note: Also, Table 2 on CAB lead auditor requirements in the CoCCR would be deleted at the next publication to remove duplication with the GCR.



Appendix B: Fishery Team Competency Changes in FCR proposed for consultation Table PC 2 Amendments

PC2 Fishery Team Member Qualification and Competency Criteria

Table PC1: Fishery Team Member Qualification and Competency Criteria

1. General

Qualifications a. University degree in fisheries or marine conservation biology, or natural resources or

environmental management or relevant field e.g., economics, mathematics, statistics; or b. Three years’ management or research experience in a marine conservation biology or fisheries,

natural resources or environmental management position.

Verification Mechanisms • CVs • Certificates 2. Understanding of MSC Fisheries Standard and relevant MSC Certification Requirements

Qualifications a. Pass the MSC’s fishery team member training course every five years and b. Pass new versions of the training when new versions of the standard are published prior to

undertaking assessments against the new standard;

c. Pass new modules on modifications to the standard before undertaking assessments using these modifications such as enhanced bivalves, salmon and other modifications that may be developed in the future;

d. Review any updates to the fisheries requirements at least annually.

Guidance 2.d The review of any updates to the fisheries requirements may take the form of a search of the MSC website for new updates issued during the preceding year.

Competencies To be able to describe the intent and requirements of the MSC Fisheries Standard.

ii. To be able to score a fishery using the default assessment tree.

iii. To be able to describe how conditions are set and monitored.

Verification Mechanisms • Examination pass • CAB records

Deleted: 5

Deleted: 3

Deleted: or

Deleted: Have undertaken at least 2 MSC fishery assessment or surveillance site visits in the last 5 years.



Table PC 3 Amendments

PC3 Fishery Team Qualification and Competency Criteria

PC3.1.1 CABs shall ensure that the fishery team collectively complies with the qualification and competency criteria listed in Table PC3. ◙

Table PC2: Fishery Team Qualification and Competency Criteria

1. Fish stock assessment ◙

Qualifications a. Three years or more experience applying relevant stock assessment techniques being used by

the fishery under assessment; or b. Primary authorship of two peer reviewed stock assessments of a type used by the fishery under

assessment.

Competencies i. Ability to undertake a stock assessment using stock assessment techniques relevant to the

fishery

Verification Mechanisms • CV with full publication list • Employer’s reference letter • CAB witness audits 2. Harvest Control Rules (HCRs) and harvest strategies

Qualifications a. 3 years or more experience of developing or applying HCR and/or harvest strategies being used

by the fishery under assessment. Competencies

i. Ability to analyse the impact of the HCRs and/or the harvest strategies using techniques relevant to the fishery

Verification Mechanisms • CV with full publication list • Employer’s reference letter • CAB witness audits

3. Fish stock biology / ecology ◙

Qualifications

a. Three years or more experience working with the biology and population dynamics of the target or species with similar biology.

Competencies i. Demonstrate knowledge of, and ability to interpret, scientific information relating to the biological

processes of the target species, or species with similar population dynamics.

Verification Mechanisms • CV with full publication list • Employer’s reference letter • CAB witness audits

Deleted: 5

Deleted: 5



4. Fishing impacts on aquatic ecosystems

Qualifications Three years or more experience in research into, policy analysis for, or management of, fisheries impacts on aquatic ecosystems including at least two of the following topics:

• Bycatch • Endangered Threatened Protected (ETP) species • Habitats • Ecosystem interactions.

Competencies i. Demonstrate knowledge of and ability to interpret scientific data relating to fishery impacts on at

least two of the topics listed in a. above.

Verification Mechanisms • CV • Employer’s reference letter • Witness or office audits by MSC’s accreditation body • CAB witness audits

5. Fishery management and operations

Qualifications

Three years or more experience as a practicing fishery manager and/or fishery/ policy analyst / consultant.

Competencies

Ability to: i. identify likely problems for fishery under P1 and P2 that would arise from poor management

ii. demonstrate a good understanding of the types of management system(s) and laws applicable to the fishery under assessment

Verification Mechanisms • CV with full publication list • Employer’s reference letter • Witness or office audits by MSC’s accreditation body • CAB witness audits

6. Current knowledge of the country, language and local fishery context ◙

Qualifications

a. Knowledge of a common language spoken by clients and stakeholders; and either b. Two years’ fishery work experience in the country or in a relevant fishery in the last 15 years; or c. Two assignments in the country or region in which the fishery under assessment is based in the

last 10 years; or d. Primary authorship of at least one published paper in a journal or grey literature in the last five

years on a fishery issue in the country or region in which the fishery under assessment is based.

Competencies

Ability to: i. Communicate effectively with stakeholders in the country in a common language

ii. Explain the geographical, cultural, and ecological context of the fishery under assessment.

Verification Mechanisms • CV

Deleted: 5

Deleted: the ecosystem

Deleted: 5



• Employer’s reference letter • Journal extracts • Witness or office audits by the MSC’s accreditation body • CAB witness audits

7 Understanding of the CoC Standard and CoC Certification Requirements

Qualifications

a. Pass the MSC’s Traceability training module every five years b. Pass new versions of the training when new traceability requirements are published prior to

undertaking assessments against the new requirements c. Review any updates to the traceability requirements at least annually

Guidance 7.c The review of any updates to the traceability requirements may take the form of a search of the MSC website for new updates issued during the preceding year.

Competencies

i. To be able to explain the elements of traceability which are relevant to fishery assessments.

Verification Mechanisms • Examination pass • CAB records • CAB witness audits

8 Use of the RBF (when applicable)

Qualifications a. Pass the MSC’s RBF training course every 5 years.

b. Pass new versions of the training when new RBF requirements are published prior to undertaking assessments against the new requirements

c. Review any updates to the RBF requirements at least annually

Guidance 8.c The review of any updates to the RBF requirements may take the form of a search of the MSC website for new updates issued during the preceding year

Competencies

Demonstrate an understanding of: i. when the RBF can be used ii. how to implement RBF components iii. how to engage stakeholders effectively when the RBF is used iv. how Performance Indicators are scored when the RBF is used v. the reporting of the RBF process and outcomes

Verification Mechanisms • Examination pass • CAB witness audits

Deleted: 3

Deleted: three

Deleted: Pass MSC’s annual RBF training on updates to the RBF requirements within 3 months of the effective date of the FC

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MSC - Marine Stewardship Council Consultation … · MSC - Marine Stewardship Council Consultation Document – Auditor Competencies Consultation Dates 1–30 September 2017 MSC Contact