In general stakeholders were in favour of the overall proposal. Key issues and concerns raised are specified below:

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1 ASC Aquaculture Stewardship Council MSC Marine Stewardship Council MSC-ASC Seaweed Certification Process Summary of consultation feedback and MSC-ASC response Public Consultation: 1 March to 30 April Introduction The Marine Stewardship Council (MSC) and Aquaculture Stewardship Council (ASC) are developing a joint international standard for the certification of environmentally sustainable and socially responsible seaweed production. A joint certification process will be developed to assess compliance against the Seaweed Standard by combining the best elements of the existing ASC and MSC processes. In addition, alternative options may be explored as a means of further increasing effectiveness while reducing complexity and cost in the assessment process. The certification process will aim to minimise time and costs, while ensuring credibility and compliance with best practices. 2. Stakeholder Consultation The draft Seaweed Certification Process was subject to 60 days public consultation. Comments were received from 11 stakeholders including NGOs, industry and a fisheries association. All of the feedback received and MSC responses are listed in section 5 below. 3. Summary of stakeholder feedback In general stakeholders were in favour of the overall proposal. Key issues and concerns raised are specified below: Pre-Assessment (PA): All agree PA is relevant to identify key issues of the fishery. Most of the consultees suggested keeping PA optional giving the possibility to client, consultants or local auditors to undertake the PA in addition to the accredited assessment body. Further revisions were suggested by the Association for Sustainable Fisheries (ASF) in considering this stage as a mandatory stage of the assessment where all the information required is submitted by the client and made available to inform stakeholders prior to the audit, replacing the Public Comment Draft Report (PCDR) stage. Assessment timelines: Announcement timelines were supported by stakeholders. However, concerns were raised about the limited time awarded for the release of PCDR and stakeholder comments. In addition it was claimed that the timelines should be shortened through a simplified process, rather than through imposed deadlines. Site visit: All stakeholders agreed that at least two auditors should attend the site visit. One stakeholder raised concern over site visits when a fishery (or operation) consisted of over 100 sites in different locations. Scoring system: In general there was support for the proposed non-conformity scoring system, with an aspirational performance level defined. Simplified reporting: It was suggested to simplify reporting as much as possible and to investigate software to aid this. Stakeholder engagement: Earlier engagement with stakeholders and potential for stakeholders to review information at the site visit to allow the PCDR stage to be removed. Objections: Mixed views. Most stakeholders supported the replacement of this stage by the complaint procedure (ASC). However, some stakeholders raised concerns about credibility issues if this stage was removed. Certificate duration: Most consultees supported a 3 year certificate duration. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 1

2 4. Response from the MSC and ASC Thank you very much for all of the feedback received. The feedback received through this consultation will be presented to the Seaweed Standard Committee (SSC) in June. The SSC will provide additional feedback and recommend a process for further consultation. The seaweed assessment process will be revised following future consultation and the final assessment process will be signed off in July MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 2

3 5. All Consultation feedback and MSC-ASC response Seaweed Certification Process 1. Using Appendix A for reference please indicate if you agree with the proposal for the following elements of the proposed Seaweed Standard certification process? Feedback received Pre-Assessment - It would be good to do pre-assessment in order to figure out if one qualifies in the first place - If it is an option, maybe give the possibility to the client to do the PA itself or to be assessed through consultants - possibility to conduct the pre-assessment by the local auditor - Pre-audit done by client decrease cost but will limit access to certification to small clients who do not have capabilities to do pre Assessment by themselves - possibility to conduct the pre-assessment by the local auditor - Pre assessment can assist in ironing out any issues before certification starts. The stages of certification need to be plainly written for licensees. We support the idea of a gap analysis, or similar preparation of materials prior to the commencement of an assessment, carried out by clients, consultants/fips or CABs (e.g. as a pre-assessment). We would also suggest that this be considered in combination with the ongoing simplification proposals made that this stage provides all the information required by the assessment team, and which is also made available to inform stakeholders prior to the audit this would make this gap analysis/ initial appraisal an effective PCDR available for review by stakeholders and the assessment team. No - Should be mandatory, possibly guided by CAB. Audit team requirements - Two comments, indeed expertise very important and keep in mind cost implications. Many small companies harvesting seaweed! - The audit team should have competencies regarding which system is evaluated (harvesting or aquaculture), which are different - the local audit should be included/part of the audit team who has best understanding on local context and local wisdom - the local audit should be included/part of the audit team who has best understanding on local context and local wisdom - As seaweed is a specialist area, then assume both auditors will have been trained accordingly regarding seaweed production. Social competences are mentioned but not technical competences - 2 auditor minimum The proposal seems appropriate and is supported. MSC-ASC Response We will explore the suggested options We will consider these points when developing the policy options. Assessment timelines Is ok. - I agree with the Pros and Cons - Compared to organic certification which requires an annual inspection, 5 years is a considerable time. However it is understood that spot visits may take place in order to maintain integrity Assessment Timelines. A period of 30 days between announcement and site visit is supported. We would prefer that timelines are shortened through a simplified process, rather than through imposed deadlines. A period of 30 days from audit to Draft Report seems rather short, especially if this time is to include review of drafts by the client and preparation of Action Plans to address and non-conformances. Sixty (60) days as for MSC surveillance audits, or removal of timelines altogether, Noted. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 3

4 may be more appropriate, especially as stakeholder input may be greater for wild capture operations. No - in some cases longer timeline may be needed No - Audits should be unexpected to insure proper follow-through. Consider a restaurant health inspector: she shows up anytime and without notice. Timelines. If it is correctly understood then SV to PRDR is 30d, PCDR to stakeholders for 15d, PCDR to FR 20d. If these are the maximum times available then they are unrealistically tight Site visit - But this might be virtually impossible using our own situation as example. We have over 100's of sites (in order to comply with organic standards for sustainability) we do this in many countries globally. So how are you going to judge on one site visit?? - 2 auditors could be enough for on-site visit so that the costs are not too expensive and to minimize risks of having only 1 auditor - Site visits are a must regarding the production of seaweed. Agree with requirement. I'd like to see frequency of inspections increased. So more frequent than every 5 years. - Bring everyone to site is correct. Site Visit. The proposal seems appropriate and is supported, providing there is flexibility to cater for differences in wild capture operations. A team is much stronger if there are 2 persons on site. Information is not missed and the benefit of discussing matters with another is invaluable Stakeholder input requirements This seems sound. - We don't disagree with stake holders inputs regarding the certification process - Notification is critical. As per suggestions on MSC simplification proposals, we would propose that the release of the pre-assessment/gap analysis to stakeholders prior to the site visit would remove the requirement for further consultation on the draft report, especially as the Peer review process is retained this will provide an objective review of the assessment. This allows timescales to be achievable without undue external delays. The consultation document indicates two difference possible timelines for stakeholder comments to be submitted on the draft report - 20 days or 15 days. Either is too short. While, these reports will be less dense than the MSC reports are, the current 30 days is sometimes even insufficient for stakeholders to submit comments. As indicated in the other consultation documents on MSC process, the majority of stakeholder submissions are by ENGOs. ENGOs tend to have limited staff and time for engagement with the certification process. It is not the density of the report that matters as much as the other commitments staff is already taking on. You must keep in mind that stakeholders, unlike, the assessors and MSC staff are not working on these certifications full time and have to juggle the time to engage amongst other priorities. At least 30 days should be maintained for stakeholder comment into the draft report. Audit findings - This starts to look like duplication of the organic standards and GMP+. Secondly MSC currently does not have expertise in house re seaweed. It almost looks that MSC is jumping the band wagon not to miss involvement in this Industry - The performance indicators, scoring system and principles of the Seaweed Standard might be difficult to understand (complex) and apply at first by a client or any entity from which it is its first approach on MSC/ASC Thanks for your comments we will consider these on the new proposal We will consider these points when developing the policy options. Note that how sites will be audited will depend on how the unit of certification is defined and the group certification requirements currently being developed. MSC and ASC are looking to simplify the scoring system, so it s more straight forward and easy friendly. As this is a joint project between MSC and ASC, elements of both scoring system will be considered. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 4

5 Including the aspirational level of scoring, as well as minimum and target, to encourage best practice. This is included in the recommendations in the certification consultation document, but appears not to have been adopted. The FairWild Standard performance indicators give guidance on best practice that has been determined for wild plant harvesting, as well as minimum and norm requirements required for certification, a progressive model that we find helps operations move to best practice. There should be an aspirational SG 100 level for improved performance similar to the MSC standard, or at minimum an explanation for why this is not included. Evaluation (audit findings) this could be an areas for dispute but it has merits. A major NCR leading to withholding certification is a great way to motivate change which is something MSC lacks at the moment. The success of the next years of MSC will be in engaging potential clients in projects such as FIPS that take the fishery on a journey leading to certification No - ok with at least 3 levels defining non conformity / average performance (no negative impact) / aspirational level (positive impact) No - This should be kept as simple as possible in order that non compliances and the required actions are understood. No - Prefer a scoring method. We would suggest a simpler evaluation process more akin to the ASC model. Not achieving minimum requirements (current MSC SG60) would be a major nonconformities. Not meeting requirements (SG80) would be minor non-conformity. A maximum number of NCs could be specified, if this number were carefully calibrated with existing MSC scoring outcomes. A period of (for example) 3 months to address major NCs could be explored in this seaweed-orientated system. Conditions timelines and action plan Ok The proposal to adopt a 5 year certificate/action plan durations seems appropriate, given that this will include wild-capture operations. No - 5 years is a long period between inspections No - Timelines to fix are too long. Major and minor should be 30 days. From my reading of the certification consultation document, I was not clear on the proposed timeline by which certified operations must move from the minimum to target level. The Executive Summary states that The new process will adopt timelines that reflect the certificate duration and definition of the unit of assessment, i.e. 5 years. However, it later states in Appendix A that ASC timelines will be followed (1 year for minor non-conformities, 3 months for major). Allowing 5 years to move from minimum to target would seem in some cases too long. Reporting Requirements Seems ok - Importance of the vulgarization of reports for clients. Reducing the steps and number of reports should be applied Agree Earlier comments apply we would prefer informed stakeholder input at the site visit rather than comment on a report afterwards. This would mean removal of the PCDR stage, making timelines predictable and achievable. We suggest retention of the client review stage is necessary, not least to allow for development of Action Plans. Report template. We would also suggest making the report template significantly simpler (more akin to an MSC surveillance report) with an introduction setting out scope etc, and an evaluation table setting out whether or not PIs are met. No - 10 days is definitively too short in some cases for stakeholder input - 20 days is a minimum - 30 days ok No - Seems as though this process could be expedited with good reporting software. Peer Review We will consider these points when developing the policy options. Noted. This will be revised. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 5

6 - This needs a re-think, peer review college?? Peer review will be done by experts in this field of science, either through University or other recognised institute. A peer -review through a MSC established college is by default biased - It would make sense if the MSC and ASC were the same regarding peer reviews We support retention of this. I also fully support the use of peer reviewers for this standard. The peer review seems to be a very effective part of the MSC process and should be taken up for the joint standard. It will be imperative to have peer reviewers who are knowledgeable about the socio-economic context of seaweed farming as well. No - In my opinion, it is not clear what is suggested here. Maybe one peer review would be sufficient to meet the targets No - who will be defined as peer? If only one PR then there can be an unbalanced PR. Two PR is more robust Certification duration - Rather 3 than 5 years. Especially with natural stocks, climate change and other effects a lot can change in 2 years - 5 years is acceptable to reduce costs and steps and might encourage more clients to be assessed 5 year proposal is supported. No - Within the organic sector certificates run for 12 months and licensees inspected annually. Light touch may be applied in some circumstances such as storage which is 3 years. 5 year certification is very long No - Agree with shorter timelines, even less than 3 years is preferable. Surveillance - propose to conduct maximum twice (2X) surveillance within 5 years (mid of the certificate duration, year 2.5) due to no significant development in seaweed farming that would possibly give impact to 5th principle of the ASC-MSC standard in 5 years. Surveillance can be carried out by local auditor - The requirements for these should allow them to be as flexible as possible considering the period of time a certificate may run for. Ideally licensees could have a spot visit at any time. We support the proposal to adopt the MSC system. No - if certification has been obtained, then the next audit takes place after certification lapse. Surveillance every year seems over the top and a becoming a nuisance No - propose to conduct maximum twice (2X) surveillance within 5 years (mid of the certificate duration, year 2.5) due to no significant development in seaweed farming that would possibly give impact to 5th principle of the ASC-MSC standard in 5 years. Surveillance can be carried out by local auditor No - Agree with AT LEAST annually. Information is not specifically given on under what circumstances the need for an annual onsite audit would be reduced. There is also not much information given about how the audits will be conducted, e.g. for social aspects, a requirement for an independent translator to be present, and for interviews to be conducted without management present, and for the ecological parts, the observation of the Thanks for your comment. The creation of the Peer Review College was the result of consultation with stakeholders and Conformity Assessment Bodies (CABs). It was created to ensure the consistency, independence and impartiality of the MSC fishery certification process, which includes independent input at critical decision points, to standardize the peer review process and to improve the efficiency of peer review within the fishery assessment process g/database/peer-reviewcollege/background The peer review requirements will be revised following your comments. Noted Surveillance is used to monitor compliance against the standard and conditions. The surveillance requirements will be revised based on the comments received. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 6

7 harvesting, visits to the harvesting areas. FairWild audit methodology (developed primarily with terrestrial harvesting sites in mind) may provide a useful reference. Complaints, concerns and objections Seems ok The use of the ASC complaints procedure is supported. We would also suggest adopting clear rules to assist ASI in their decision making process (this could be adapted from the current MSC Objection Process terminology), with decisionmaking processes reviewed by ASC/MSC to ensure compatibility with rules and scheme intent. No - In my opinion, it is not clear what is suggested as the best option here No - in case of disagreement between stakeholder and CAB, ultimately would be good to raise issue for consideration by an independent adjudicator (like MSC) No - A formal objection stage should exist We may love/hate objections but they are impartial, process driven and lead to an outcome that all have to accept. This is a massive strength that should not be dropped Complaints are an adversarial process that can lead to stalemate, meaningless escalation. Importantly there is the decision of what to do with the assessment/certification whilst the CAB complaint, appeal, hearing and then same to the Accreditation body, are occurring! Clients are not very willing to fund team time during complaints. Stick to objections please 2. Are there further efficiencies that could be introduced to the certification process to assess compliance with the Seaweed Standard? Feedback received - Provide sustainable management plans as under organic certification and EU legislation - please include the local consultant during audit and surveillance processes - some prework may be expected from audit team prior to audit visit (for example, existence of wild stock assessment reports, identifying scientific supports) - pre assessment of the supply chain would be needed to ensure audit team has identified all stakeholders to be involved in audit - please include the local consultant during audit and surveillance processes - If visits remain so infrequent then a desk top audit may be one way of checking more frequently. The licensee would be required to forward any requested information. This can then be assessed and if concerns are raised a visit can be triggered. - I truly hope you're considering best practices for reporting through integration of technology and well-designed software. MSC-ASC Response Thanks for your comment. We will explore this option. No 3. Will the proposed certification process to assess compliance with the Seaweed Standard: Feedback received MSC-ASC Response Assure credible assessment outcomes 7 responses No 2 responses Maximise efficiency without compromising credibility of assessment outcome 8 responses No 1 response Provide effective stakeholder engagement opportunities 9 responses No 0 responses Other Comments Expertise needs to be addressed and Peer review needs to be addressed. Once that is solved there will be a credible assessment outcomes It's important that the language used is clear throughout. Documents such as these need to be clearly understood to the producer. This then can aid in reducing certification and compliance issues that further add an administrative burden to both ASC, MSC and the producer and increases costs. MSC-ASC Seaweed Certification Process - Consultation feedback and MSC-ASC response 7