march 4, 2014 • seafood processors association, seattle wa · - social, environmental, oh&s...
TRANSCRIPT
Ethical Sourcing
March 4, 2014 • Seafood Processors Association, Seattle WA
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Ethical Sourcing
Scheme Organization
• Ethical Sourcing Code, 2nd edition
- Social, Environmental, OH&S
• Appendices:
1. Certification Assessment Requirements
2. Implementation and Auditing Guide
Glossary of Terms and Definitions
3. Audit Methodology
4. Auditor Competency
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Major Changes, 2nd ed.
• Better alignment of requirements / guidance with
internationally recognized standards (e.g., ISO
14001, OHSAS 18001)
- Supports certification if desired
• Emphasis on compliance with national, state/
provincial/ local laws vs. int’l. conventions - Expanded / strengthened OH&S requirements
• Three certification levels reflecting sensitivity to
resource constraints of small locations
• Greater emphasis on continual improvement
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Major Changes continued
• Audit methodology patterned after SQF Code
- Scoring – major, minor, critical nonconformities
- Minimum score for certification
- Requirements for root cause analysis and
corrective / preventive actions
- Annual recertification
- Movement between levels
• Drafted auditor qualifications and developed an
auditor training program
• Added business management principles for
senior management.
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Assessment Requirements Example – Appendix I
12.0 Checking to Support Continual ES Performance Improvement (Continued) [Reference: ES Code §4.5]
Requirements Level 1 Level 2 Level 3
12.4 Does the
organization
have a
procedure for
identifying and
documenting
corrective and
preventive
actions?
The organization has developed and
implemented a procedure(s) to guide root
cause identification and the development of
corrective and preventive actions with regard
to deviations from policies/ procedures,
accidents, incidents, employee concerns,
internal audits findings, etc.
The procedure(s) indicates which appropriate
personnel have been assigned responsibility
by top management to assist in the
investigation and resolution of deviations and
consequences, especially in the areas of:
- supplier/ subcontractor issues,
- human resource/ social issues,
- employee concerns,
- environmental incidents, and
- occupational health and safety incidents.
The procedure(s) addresses how complaints
are to be recorded, tracked and closed out,
and provides guidance on evaluating the
effectiveness of corrective and preventive
actions.
All proposed corrective and
preventive actions are reviewed
through the risk assessment
process prior to implementation.
Post-incident investigations also
include a review of whether the
aspects/ impacts/ hazards/ risks
and controls were properly
evaluated (i.e., why they did not
prevent the incident from
occurring/ recurring).
Communication and training focusing on gaps identified are delivered at all site levels.
Scheduling of internal audits gives
consideration to whether ES-
related incidents are recurring.
(See §12.1.)
An incentive system is in place for management based on performance in relation to proactive and preventative remediation actions.
The types of incidents occurring
at the facility, as well as corrective
and preventive actions to prevent
recurrence, are shared with
relevant stakeholders during
periodic communications
meetings.
A process is in place to ensure
that results of supplier/
contractor audits and associated
corrective action plans are
factored into decisions for
selection and contract extension/
renewal. (See §5.0.)
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• Hazardous chemical inventory
• Noise prevention (community impact)
• Groundwater
• Land and soil
Auditing Guidance Appendix II
4.4 Environmental and Occupational Health and Safety (EHS) Management Programs
4.4.1 Environmental Management Plan
The company shall evaluate and prioritize its environmental impacts and develop an Environmental
Management Plan (EMP) for priority Impacts identified through this process. The EMP must specify:
management objectives, targets and program activities intended to eliminate,
control and/or reduce priority impacts and to identify/ comply with applicable regulatory and other
requirements (e.g., trade association or community commitments). The tasks, time frames, resources
and responsibilities required to meet the nominated objectives and targets shall be identified. At a minimum,
the EMP shall include specific details on the following topics, if applicable to the scope of the organization’s ES Program:
4.4.1.1 Energy use and air emissions;
•Inventory energy usage and air emissions, including greenhouse gases (GHG) and ozone-depleting
substances (ODS).
4.4.1.2 Water consumption
4.4.1.3 Wastewater treatment and effluent
management
4.4.1.4 Waste management
•Proper identification and handling of waste containers
•Compliance with regulations/ ordinances governing on-site burning/ landfilling
•Implementation of recycling/ waste reduction programs
4.4.1.5 Pollution prevention
4.4.1.6 Land use and biodiversity - Impacts on the local environment and communities
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Implementation Guidance 4.4.1
What does it mean?
Environmental Management Plans (EMPs) relate to the significant or priority environmental impacts you have
identified through the initial Environmental Review and/or subsequent Management Reviews. Generally, they include
specific objectives and targets to be met within stated timeframes for the priority areas backed up by procedures to
eliminate, reduce and control the risks identified along with procedures for internal auditing and review. They also
will define the necessary records and documentation needed to demonstrate that the EMP is operating effectively.
What do I have to do?
Your Environmental Management Plan is the core of the systems management approach. It is the strategic plan for
key areas of environmental impacts caused by your business. Some EMPs are applicable to all businesses in the
agrifood chain, while others are specific to key stages, types of business or even geographical location.
In developing your EMP, you should focus on the following:
Where local regulations describe objective or targets, the supplier must ensure that these are utilized and met. Where
no regulatory requirement exists for the area of concentration, the supplier should utilize best industry practice.
Many countries have developed guidance on good agricultural practices. These can be used to help develop your
Environmental Management Plan. Food sectors in some countries also have developed environmental guidance.
See Annexes 3 and 4 for guidance on performing an environmental aspects and impacts analysis.
Auditing Guidance Appendix II
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Auditing Guidance Appendix II
Auditing Guidance 4.4.1
The auditor may look for evidence of:
1. A documented environmental management plan that includes objectives and targets for
achieving each area of concentration.
2. Objectives and targets which are relevant to the priority areas and capable of being
realized through the application of the documented procedures and management.
3. Procedures which are capable of eliminating or reducing the identified environmental
impacts to an acceptable level.
4. Operators following these procedures including those for normal, abnormal, accident and
emergency situations. This may mean that auditors will interview operators to evaluate
their understanding of procedures.
5. The documented plan must include energy use and air emissions, water consumption,
waste water treatment, waste management, pollution prevention and land use.
See Appendix 1, §7.0 for specific requirements related to Environmental Aspects/ Impacts
and EMPs.
See Appendix 1, §7.3 for details on graduated requirements (i.e., Levels 1, 2 and 3) for each
EMP aspect.
Ethical Sourcing
Audit Methodology
Certification Levels* Appendix III
1. Awareness and Compliance
- Understanding of and compliance with applicable
laws and regulations
- Understanding of Environmental impacts and Social/
OH&S risks
2. Proactive Management/ Performance Improvement
- Management system-like approach
3. Leading Practices
- Best management practices
- Alignment with int’l. conventions where appropriate
* Sourcing organization or supplier selects desired level of certification.
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• Starting point is 100
Minor nonconformity = 1 point reduction
Major nonconformity = 10 point reduction
Critical nonconformity = 50 point reduction
• Minimum score for certification = 70*
Minor nonconformity - Omission or deficiency that produces unsatisfactory conditions that if
not addressed may lead to an ES-related risk but is not likely to cause
a system element breakdown
Major nonconformity - Omission or deficiency producing unsatisfactory conditions that carry
an ES-related risk and is likely to result in a system element
breakdown
Critical nonconformity - Breakdown of a critical control, regulatory requirement or process step
that is judged to cause a significant ES-related risk
* Certification to the ES Code is voluntary and is not required for SQF Code certification.
Audit Methodology Scoring – Appendix III
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• Pre-Assessment Audit: Gap analysis to determine
readiness. (Could be 1st, 2nd or 3rd party assessor.)
• Desk Audit: Performed by a registered SQF ES auditor
to determine if the ES plan and documentation are
appropriate for the selected level of certification, and
that the organization is ready for a certification audit.
• Facility Audit: On-site audit by a registered SQF ES
auditor to determine implementation/ effectiveness of
the requirements of the selected ES certification level.
Audit Methodology Audits – Appendix III
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Audit Methodology Duration – Appendix III
• Audit duration will be patterned after the SQF Code,
Edition 7. Factors that can impact on the audit
duration include:
- Scope of the audit (certification level)
- Size and complexity of the site/ operations
- Complexity of the ES system design/ documentation
- Whether the ES-related risks are considered to be
high or low
- Ease of communication with company personnel
(e.g., languages, distance, etc.)
- Cooperation of the organization’s personnel
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Auditor Competency - Appendix IV
• Qualifications for auditors based on the following
criteria:
- Education
- Professional Experience
- Audit Experience
- Knowledge, Skills and Abilities
- Competencies and Behaviors
• Requirements will be further defined by SQFI.
• Auditor certification is desirable (RABQSA/ IRCA).
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GSCP Code Alignment
