Ethical Sourcing. March 4, 2014 Seafood Processors Association, Seattle WA

Transcription

1 March 4, 2014 Seafood Processors Association, Seattle WA 1

2 Scheme Organization Ethical Code, 2 nd 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

3 Major Changes, 2 nd 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

4 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.

5 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 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 ESrelated 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.)

6 Auditing Guidance Appendix II 4.4 Environmental and Occupational Health and Safety (EHS) Management Programs 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: Hazardous chemical inventory Groundwater Energy use and air emissions; Noise prevention (community impact) Land and soil Inventory energy usage and air emissions, including greenhouse gases (GHG) and ozone-depleting substances (ODS) Water consumption Wastewater treatment and effluent management Waste management Proper identification and handling of waste containers Compliance with regulations/ ordinances governing on-site burning/ landfilling Implementation of recycling/ waste reduction programs Pollution prevention Land use and biodiversity - Impacts on the local environment and communities 6

7 Auditing Guidance Appendix II What does it mean? Implementation Guidance 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. 7

8 Auditing Guidance Appendix II Auditing Guidance 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. 8

9 Audit Methodology Ethical 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 * organization or supplier selects desired level of certification.

10 Audit Methodology Scoring Appendix III 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.

11 Audit Methodology Audits Appendix III Pre-Assessment Audit: Gap analysis to determine readiness. (Could be 1 st, 2 nd or 3 rd 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.

12 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

13 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).

14 GSCP Code Alignment

15 Robert Garfield Senior Vice President Food Marketing Institute 15