MSC COVID-19 Additional Guidance for CoC Conformity Assessment Bodies (CABs)

The Marine Stewardship Council (MSC) has implemented specific guidance to support Conformity Assessment Bodies (CABs) in maintaining the integrity of the Chain of Custody (CoC) program during the COVID-19 pandemic. This guidance is designed to ensure that supply chain certification remains robust even when physical site visits or traditional auditing procedures are constrained by travel restrictions and health protocols.

Overview of the Guidance

The core objective of the MSC COVID-19 guidance is to allow for the continuity of certification services while prioritizing the health and safety of audit personnel and client staff. The guidance provides flexibility regarding remote auditing techniques and the extension of certificate validity where necessary.

Remote Auditing Procedures

In circumstances where on-site audits are not feasible, CABs are permitted to utilize remote auditing methods. To maintain the rigor of the assessment, the following conditions must be met:

• Risk Assessment: CABs must conduct a documented risk assessment to determine if a remote audit is appropriate for the specific client, considering the complexity of the supply chain and the volume of MSC-certified product handled.
• Information and Communication Technology (ICT): Auditors must ensure that the technology used provides sufficient connectivity and visual clarity to verify facility infrastructure, processing lines, and documentation systems.
• Document Review: All essential records, including traceability logs, mass balance calculations, and invoices, must be submitted electronically and verified against the physical inventory systems during the remote session.
• Verification of Practices: Auditors are encouraged to use live video feeds to observe current operational practices and ensure that physical segregation measures are effectively implemented.

Handling Certificate Extensions

Where the pandemic situation prevents an audit from being completed before a certificate expires, the MSC allows for time-bound extensions. CABs are required to:

• Document the specific reasons why the audit could not be performed, citing local health restrictions or logistics challenges.
• Evaluate the performance of the client during the previous certification cycle to ensure there is no significant risk of non-conformity.
• Inform the MSC of any extensions granted to ensure that the public information on the MSC database remains accurate.

Integrity and Scope

Despite the flexibility provided, the fundamental requirements of the MSC Chain of Custody Standard remain unchanged. CABs are reminded that:

• Mass balance records must still be reconciled accurately.
• Traceability of certified products must be clearly demonstrable from the point of receipt to the point of dispatch.
• Any instances of non-conformity identified during remote audits must be managed through the standard corrective action process.

Communication and Reporting

CABs play a critical role in communicating these requirements to their clients. It is essential that certified organizations understand that remote auditing is a temporary measure and that on-site verification will resume as soon as circumstances allow. CABs must maintain transparent communication with the MSC regarding the impact of COVID-19 on their audit schedules and provide regular updates on the status of their certified clients.

By adhering to these guidelines, CABs ensure that the MSC program continues to provide consumer confidence in the traceability and sustainability of seafood products, even amidst global logistical challenges.