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Food safety legislation equivalence consultant

Responsible to: Head of Supply Chain Assurance

Department: Programme Assurance

Contract: Short-term, approx. 3 months part-time

Location: Remote, flexible

ASC is an independent, not-for-profit organisation established in 2010 to set and operate global standards for responsible aquaculture. Certified farmed products are promoted to consumers through the use of the ASC logo.

The aquaculture industry is growing strongly and is already supplying more than half of all seafood consumed worldwide, but this growing demand increases the environmental and social footprint associated with this expansion. The ASC certification and labelling programme incentivises improved farming practices by promoting the benefits of responsibly farmed seafood and encourages an industry towards achieving environmental sustainability and social responsibility.

We work across the globe with aquaculture producers, seafood processors, retail and foodservice companies, scientists, conservation groups and the public to make it very easy to recognize and buy farmed seafood that meets the highest environmental standards.


Since 2012, ASC has used the Marine Stewardship Council’s Chain of Custody (CoC) programme for all ASC certified products. On 30 May 2022, ASC released the ASC Chain of Custody (CoC) Module, which adds additional requirements to the MSC CoC system, and applies to ASC CoC certificate holders from 30 May 2023.

The food safety eligibility requirement of the CoC Module (Part A, Eligibility, p.8) requires ASC CoC certified processors and packers to have a Global Food Safety Initiative (GFSI) recognised or ISO 22000 certification covering the scope of their supply chain activities throughout the period of their ASC CoC certification.

Since the release of the CoC Module, some companies have indicated that they would be unable to meet the food safety requirement for various reasons. In response, ASC provided a one-year grace period which means that relevant companies do not need to meet the food safety requirement until audits after 30 May 2024 (the rest of the CoC Module is effective as of 30 May 2023).

ASC has received feedback that some companies with locations in Switzerland, France and Spain consider that they are subject to already strict food safety regulations in the EU which are sufficiently equivalent to GFSI-recognised or ISO 22000 certification. Further, companies in Japan have enquired about the acceptability of the Japan Food Safety Management Association (JFSMA) level B, as compared to JFSMA-C, which is GFSI-recognised.

ASC seeks to explore the possibility of recognizing potentially equivalent EU food safety legislation, and possibly JFSMA-B, in lieu of the CoC Module food safety requirement to obtain GFSI-recognised or ISO 22000 certification.

Role Summary

Based on the context above, ASC seeks to engage a consultant to complete a desk-based exercise to conduct and record an equivalency comparison of the applicable GFSI Benchmarking Requirements (Part II and Part III C0 and C1) and certification with:

  • EU food safety laws and regulations that are relevant and applicable to ASC CoC certified processors and packers, including how the laws and regulations are verified, enforced and reported,
  • Country specific food safety laws and regulations in Switzerland, France and Spain, including how the laws and regulations are verified, enforced and reported, and
  • Japan Food Safety Management Association (JFSMA) level B (as opposed to JFSMA-C which is GFSI-recognised).

The aim is to methodically identify the overlaps and differences through a detailed comparison that would allow ASC to conclude whether each of the above can be considered acceptably equivalent to the ASC CoC Module food safety requirement.


  1. Complete a desk-based assessment of the overlaps/ similarities and the gaps/ differences between the applicable GFSI benchmark requirements and ISO 22000 and (1), (2) and (3) above.
    • Associated verification and enforcement processes must also be evaluated to provide an understanding of equivalence with a food safety certification program (GFSI requirements part II). For example, addressing the question of how and to what extent applicable food safety laws are monitored, verified, reported and enforced.
  • The output could be in the form of a table or matrix, though this is flexible based on what seems appropriate as long as the comparisons are presented clearly.
  1. Provide a summary of conclusions and initial insights or recommendations on the degree of equivalence as described in this ToR.
  2. If important elements are missing in the laws and regulations in comparison with GFSI applicable requirements and ISO 22000, provide a proposal of requirements that could be evaluated during CoC audits to cover the gap detected.

Desired Skills and Experience

  • Relevant professional background and knowledge of food safety legislation, GFSI Benchmarking Requirements and ISO 22000.
  • Knowledge of how certification schemes work
  • Ability to produce specified deliverables
  • Attention to detail
  • Experience with chain of custody and/ or food safety certification
  • Ability to understand and write detailed written English

ASC works globally across multiple time zones so the pattern of hours is flexible and may vary.

Application and Selection

Please send your cover letter and CV in English by e-mail to:

Your CV and cover letter will be reviewed, and a short list of candidates will be invited for initial interviews. Successful candidates may be asked to prepare additional written materials and/or a presentation.

ASC takes data protection very seriously. We only use any personal data that you provide to us in connection with your application for this position. If your application is unsuccessful, we will retain your personal data for 6 months in case other vacancies arise for which we believe you are suitable. For more information, please read our Privacy Policy, which you can find here;

We want to be an inclusive and diverse employer of choice that reflects the global community and therefore welcomes applications from all underrepresented groups.


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