Consultation Document: Surveillance Audit Frequency for Certified Fisheries

Transcription

1 MSC - Marine Stewardship Council Consultation Document: Surveillance Audit Frequency for Certified Fisheries Consultation Dates: 1 st April-3 rd May, 2011 MSC Contact: Maylynn Nunn Introduction FOR CONSULTATION At the 18th Technical Advisory Board (TAB) meeting, the TAB agreed for the MSC to develop a risk analysis to determine an altered cycle that allows for off-site and reduced frequency in low-risk situations. Under this approach, the certifier will be afforded the opportunity to omit certain s where the performance of the certified fishery is high relative to minimum requirements for certification. The information regarding the categories approved is provided in the background section below. This will reward strongly performing fisheries with reduced costs of and, assuming appropriate criteria for determining frequency of are in place, should ensure rigour in the process by reducing only in those situations where the performance of the fishery against the standard is strong. Purpose MSC is now looking to develop the criteria to determine under which category a particular fishery shall be monitored. The following factors are proposed for use in determine the category: Aggregate scores at the principle level, number of Performance Indicators (PIs) attracting conditions, number of conditions, whether conditions are being closed or addressed according to agreed timescales and scores against outcome PIs. This information is given in the background section of this consultation document. Recommendation Based on the given information MSC proposes the following option: Table 1: Preferred criteria option Surveillance category Criteria Normal Default Reduced 1: Principle-level scores of at least 85, and no more than 5 conditions in total, with no conditions on outcome indicators. Reduced Surveillance 2 No PI scores below 80 on any PI and therefore no conditions

2 Considerations When developing criteria to determine the frequency in low risk situations, consideration was given to the performance of a fishery. Criteria developed included aggregate scores at principle level, number of PIs attracting conditions, number of conditions, scores against outcome based PIs (see background for more details). For example, a fishery certified with no conditions would fall under different category than a fishery certified with 4 conditions. Linking frequencies to performance of a fishery creates incentives for certified fisheries to close out conditions and maintain performance over the certification period. The criteria option proposed is based not only on the number of conditions and aggregate scores, but also on the scores on the outcome PIs. Thus, this option is considered the most effective. As outcomes PIs have to be evaluated, categories shall apply to fisheries having been assessed using the default tree or a modified default tree (i.e. no pre- FAM fisheries). The system is such that if a fishery s performance changes then the fishery could transition into another requirement during the lifetime of the fishery certificate. Similar risk based is being used in Chain of Custody (CoC); the particular company is subject to frequency appropriate to the risk identified for that certified operation. The CB shall perform a documented risk analysis to determine the appropriate level of required (FCM V.7). Similar criteria to the ones proposed in this document are used to determine risk in CoC. CoC risk assessment uses the number of minor and major non conformance issued at the last MSC as one of the factors to determine risk. Stakeholder comments will still be invited as normal on an annual basis. In addition to the stakeholder interactions, the assessment team will need to find ways to coordinate and cross-check their individual assessments, as normal, but using remote approaches. Furthermore, the proposal will not remove the clients obligation to notify the CB of any changes in the fishery that might require it to move to one of the more frequent levels. This aims to provide incentive to fisheries to work towards closing conditions, recognize good performance and reduced unnecessary costs while maintaining the transparency, rigour and objectiveness of MSC process. Background fishery frequency At the 18th TAB meeting, TAB agreed for the MSC to develop an altered cycle that allows for off-site and reduced frequency in low-risk situations. Under this approach, the certifier will be afforded the opportunity to omit certain s where the performance of the certified fishery is high relative to minimum requirements for certification The Categories of approved are the following: Consultation Document: Fishery frequency 2

3 1. Normal Surveillance: Annual on-site s, as per current requirements. 2. Reduced Surveillance 1 (for well performing certifications): a. s on the 2 nd and 4 th anniversaries of certification b. Off-site s on the 1 st and 3 rd anniversaries of certification 3. Reduced Surveillance 2 (for best performing certifications): a. s on the 2 nd and 4 th anniversaries of certification b. On the 1 st and 3 rd anniversaries of certification, the lead or/certifier should request new information from stakeholders and complete a desktop review of that information. If information suggests the need for an, then an off-site commissioned. Similar process to that established in TAB Directive 028, para 7.3. Table 1: Approved categories Year 1 Year 2 Year 3 Year 4 Normal Surveillance & recertification site visit Reduced Surveillance 1 Off-site Off-site & recertification site visit Reduced Surveillance 2 Review of new information (& possible off-site ) Review of new information (& possible off-site ) & recertification site visit However the criteria to determine under which scenario a fishery should be monitored has not been defined yet. The following factors are proposed for use in determine the category: Aggregate scores at the principle level, number of Performance Indicators (PIs) attracting conditions, number of conditions, whether conditions are being closed or addressed according to agreed timescales and scores against outcome PIs. The aim of this work is to create efficiencies in the system of annual where warranted, without compromising the robustness of the process. Factors used in deciding Consultation Document: Fishery frequency 3

4 which options to consider were the distribution of fisheries falling into each category as the use of criteria that best reflect the performance of a certain fishery. It is expected that as fisheries head into the second and third certification, the number of fisheries with no or few conditions to increase over time. Thus, the number of fisheries falling under reduced categories is expected to increase as fisheries improve their performance through the certification period. Methodology Information was collected regarding PI scores, number of conditions and types of condition on the certified fisheries. Taking into account the TAB recommendation, three different alternative criteria were developed to determine under which category a fishery should be monitored. Once the criteria were developed, they were tested, evaluating the number fisheries that would fall under each category. Results Criteria developed: The three different options that were developed following the recommendation provided by the TAB. are as follows: Table 2: Criteria to determine categories Reduced 1 Reduced Surveillance 2 No PI scores below 80 on any PI and therefore no conditions. Option 1 PI scores nearly all over 80, with principle-level scores of at least 90, and no more than 5 conditions Option 2 PI scores nearly all over 80, with principle-level scores of at least 85, and no more than5 conditions Option 3 PI scores nearly all over 80, with principle-level scores of at least 85, no more than 5 conditions in total, and no conditions on outcome indicators (i.e. all outcome indicators scoring 80 or greater) No PI scores below 80 on any PI and therefore no conditions. No PI scores below 80 on any PI and therefore no conditions. Number of fisheries falling under each category The recommended options were tested and the results are shown in Table 1 below. Note that these results are from when fisheries are first certified. Following initial certification and Consultation Document: Fishery frequency 4

5 after each, certified fisheries shall be classified or reclassified by the CB into one of three categories for continuing depending on number of open conditions, etc. In this way the use of categories may result in an incentive for fisheries to close conditions sooner. Table 3: Comparison of Criteria developed. Option 1 and 2 n=101; option 3 n=41 Type of Option 1 (%) Option 2 (%) Option 3 (%) Normal Reduced Reduced Option 1 is the most rigorous as almost 90% of the fisheries fell under the normal category. When revising the criteria of the aggregate Principle score to 85 (option 2), 56% of the fisheries remain on the normal category, but 37% fell under reduced 1. As the criteria for reduced 2 is the same for the two options, the difference shown are between normal and reduced 1 (see Fig. 1). 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% 1 2 reduced 2 reduced 1 normal Figure 1: Percentage of fisheries under option 1 and 2 Within the fisheries falling in reduced 2, five out of the seven fisheries are using the default Assessment Tree with standardised Performance Indicators. Option 3 was developed taking into account the number of the conditions issued and the PIs attracting such conditions (e.g. outcome, performance or information). This option could only be tested in fisheries using default assessment tree and standardized PIs. However, as all Consultation Document: Fishery frequency 5

6 fisheries in the MSC assessment are meant to make the transition to the FAM, in the future it could be used in all fisheries. 100% 90% 80% 70% 60% 50% 40% 30% 20% 10% 0% reduced 2 reduced 1 normal Figure 2: FAM fisheries under option the three criteria options A comparison of the three options developed was tested on fisheries using the default assessment tree as shown in Fig. 2 above. Case study: Aker Biomarine Antarctic Krill fishery for instance, under option 1 and 2 fell under reduced 1. However, when taking into account the conditions issued in the outcome PIs, fell under normal. Criteria developed in option 3 are more sensitive to the performance of a fishery, as not only the number of conditions issued is taken into account but the PIs that have attracted the conditions. Fishery N. of conditions Aker 4 Biomarine (3+1volunt Antarctic ary) krill N of PI attracting condition P1 score P2 score P3 score Categories of Criteria N/A reduced 1 Figure 3: Comparison of categories for Aker Biomarine Antarctic Krill Categories of Criteria 2 Categories of Criteria 3 reduced normal 1 Conclusions Consultation Document: Fishery frequency 6

7 Option 1 uses the tightest criteria, with most of the fisheries falling under normal (90%). When allowing more flexibility as shown in option 2 (when the requirement for aggregate score of the PI is reduced to 85), 56% of the fisheries fall under normal. Option 3 can be considered more selective than option 1 and 2. Option 3 has the criteria described in option 2, but taking into account the PIs that have attracted the conditions. This option allows not only taking into account the number of conditions and aggregate scores, but also to differentiate outcome PIs. Thus, option 3 is considered more selective than the two other options. However, as outcome PIs have to be evaluated, fisheries having been assessed before the default assessment tree was available would not be eligible for using reduced categories. At the moment there are a total of fifty six pre-default-tree fisheries, twenty five of them are coming into reassessment and switching into a default assessment tree within the next 2 years. Recommendations It is recommended to adopt option 3 as it is the option that best reflects the performance of a fishery, considering not only the number of conditions but the type of PIs attracting the conditions. The objective of increasing efficiency for well performing fisheries is met, while meeting the objective of creating incentives for certified fisheries to close out conditions and maintain performance over the certification period. As when assessing pre-default-assessment tree fisheries option 3 can not be used, it is recommended that either option 1 is used for these fisheries until they become assessed against the default tree, or that pre-default-tree fisheries are not eligible for reduced until this time. FOR CONSULTATION Consultation Document: Fishery frequency 7