ASC Response to SeaChoice’s “Global Review of the Aquaculture Stewardship Council’s Salmon Standard”

The Aquaculture Stewardship Council (ASC) is a tool for responsible aquaculture management. All of our standards include provisions for the protection of workers and the community, and criteria to both measure and improve farm performance.

Over the last several years, in partnership with dedicated stakeholders including SeaChoice, ASC has helped to establish best practice and bring a new level of transparency and accountability to the global aquaculture industry.

Farms that choose to become ASC certified do so voluntarily, thereby committing to meet requirements that distinguish them from other producers in terms of both farm performance and level of scrutiny. This achievement, and the accompanying distinction, compels them to match our ambition and advance as our standards and process advance.

At present, approximatly twenty-five percent of salmon farms worldwide have achieved ASC certification. Globally recognised as the most challenging, transparent independent third-party farm certification to attain, ASC is the only standard for salmon aquaculture that has achieved benchmarks to Monterey Bay Aquarium’s Seafood Watch Program and the Global Sustainable Seafood Initiative (GSSI)—earning further distinction from the GSSI by achieving 52 ‘supplementary components’, more than any other aquaculture certification scheme.

However, no standard is perfect. For this reason, the Salmon Aquaculture Dialogues (SAD), which included active participation by many stakeholder groups including those that comprise SeaChoice, required Operational Reviews be undertaken at least every five years or sooner as necessary. Contrary to the assertion in the report, the reviews of ASC processes and standards allows the programme to capture advances in technology and knowledge, apply lessons learned, reconcile the gaps between theory and reality and ensure the standard can be meaningfully and effectively applied. In fact, it was the conclusion of the recent Operational Review of the salmon standard which updated or added 10 indicators to further improve the performance of farms in the programme—including a reduction in the amount of wild fish allowed in aquafeed—that led to recognition by Seafood Watch.

Additionally, regular reviews of all standards are required by ISEAL. ASC is the only aquaculture certification recognised as a full member. We follow the Code of Good Practice for Standard Setting, including ISEAL, ISO/Guide 59 and FAO technical guidelines for aquaculture certification, amongst other acknowledged practices. All amendments to ASC standards are open to public consultation—this includes the current review of the parasiticide treatment index (PTI) and the review of the Salmon Standard which was completed in 2017—and will remain so. Furthermore, ASC remains dedicated to the multistakeholder approach and actively seek the input and contributions of SeaChoice and other stakeholders to continually advance our standards and process. Despite this, the nature of multistakeholder processes means while all contributions are considered, not all views will be reflected in the final revision.

As those familiar with certification schemes well know, a standard is not a stand-alone document. Farms must meet the certification requirements set in the ASC Certification and Accreditation Requirements (CAR) that together with the standard determine if a farm can be certified. Introduced and operational at the same time as the Salmon Standard in 2012, the CAR allows farms to be certified provided no major non-conformities are open and minor non-conformities are closed in a defined timeline. This is not unique to ASC or ASC-certified salmon farms, but is in force and consistent for all species that ASC certifies. Strict ‘100% compliance’ may not be possible for a variety of reasons—these reasons are often highlighted in the rationale of the standards’ requirement—nor is it compatible with the spirit of the ASC vision and mission to transform aquaculture towards sustainability.

Change happens through active and direct engagement with producers and other stakeholders. The standard as applied has the net effect of requiring farms to perform to transparent criteria—collected in a report that is then posted publicly on the ASC website—that is unmatched by any national governing body or any other single aquaculture certification scheme.

However, as previously acknowledged, no standard is infallible or able to be applied strictly as written in every jurisdiction. In circumstances where the standard cannot provide a solution, both ISEAL’s Standard Setting and Assurance Codes allow for exceptions, which in ASC’s terms is known as a variance request (VR). ASC’s VR process is consistent with Section 6.4 of the former, related to ‘local applicability’, while Section 5.1.5 of the latter Code allows standard setters to allow exceptions for application of their standards, including in situations where a requirement is not applicable in a certain case. Because the ASC Salmon Standard is applied in the most diverse conditions—on different continents and in two hemispheres—it receives the most requests for variations and interpretations.

Importantly, it was also acknowledged by participants in the SAD and the ASC Technical Advisory Group (TAG) that the lack of data on farm performance created challenges in calibrating metrics for certain aspects of farm performance when the salmon standard was developed. Therefore, contrary to the case made in the report, the VR process is not only appropriate, but necessary. It allows ASC to improve applicability of its standards in a robust way that will increase engagement and spur further benefit in improved environmental outcomes.

The scrutiny arising from the unrivalled level of transparency embedded in the ASC standards, and in the Salmon Standard in particular, has over the years had significant industry-wide beneficial effects including – but not limited to – making salmon farmers and ASC more accountable. The many transparency requirements (see Appendix VI of the Salmon Standard) have been driving global salmon farming industry improvements and has facilitated constructive criticisms by various stakeholders, including SeaChoice. By providing such accountability and transparency, and enabling in-depth scrutiny, the ASC provides insights than can increase the public’s confidence in the fish they eat and drive greater improvements over time.

ASC is constantly monitoring multiple issues and, as acknowledged by SeaChoice in the recently published report, has independently taken many steps to bring further improvements to the programme. We have not only initiated a review of the Interpretation Platform, we have also initiated a review of sea lice limits currently implemented globally to establish current best practices used in salmon producing regions. The review will provide data on limit levels of sea lice abundance and prescribed actions farms should take for treatments or other remedies. The review is ongoing, and in keeping our dedication to transparency, progress on this work can be followed on the ASC website.

The ASC Improver Programme which SeaChoice confusingly alluded to was launched in early October 2018. It is separate from, and should not be conflated with, the ASC standards. While we are dedicated to continually progressing our standards, we draw a distinction between farms that are certified and those engaged in the Improver Programme. It should be noted that ASC feels that the assertion that we want to see farms improve is not a denigration, but is instead a core part of our mission. To have more fish produced by farms updating their operations to meet responsible practices is a benefit to all. Such activity reduces the negative impacts of fish farming and brings our shared goal of a sustainable aquaculture industry closer.

ASC remains engaged in an ongoing and open dialogue with Seachoice, based on a shared interest to bring further improvements to the aquaculture industry. We welcome SeaChoice’s constructive criticisms—and take due note of them—despite some showing a lack of understanding of how the ASC and other certification schemes work. We will strive to clarify the issues creating confusion, and continue improving the stringency of the ASC programme, in line with our Mission to transform current aquaculture practices towards environmental sustainability and social responsibility.

 

ASC response to recommendations made by SeaChoice

Auditing Processes

1. Strengthen the Quality Assurance (QA) framework: Continue to monitor and ensure that Certification Assessment Bodies (CABs) are providing the required metrics within audit reports to demonstrate compliance; are assessing standard indicators correctly; raising and closing non-compliance appropriately; applying variances suitably and posting audit reports on time.

ASC Response:

ASC have several improvement initiatives in place to strengthen quality assurance (QA) work and the quality of auditor training since the formation of our Programme Assurance team in 2017.

SeaChoice has agreed that the level of detail has already improved due to QA work and continues to improve over time. However, information related to some indicators was not recorded in detail in some of the reports completed just after the ASC Salmon Standard become operational. ASC acknowledges that it is imperative to give further instruction to auditors so they know exactly how to report metrics within audit reports and has taken steps to improve instruction to CABs.

In addition:

• In 2017 ASC brought the QA reviewers together to evaluate the current process and seek improvements for the first time. A second meeting is planned with the reviewers later this year to ensure that they are up-to-date with changes in the system, including updates to the standards, CAR requirements and interpretations. Going forward, these meetings will be part of an annual event for both our trainers and QA
• ASC has begun using two methods to review audits reports, adding a risk-based approach to review additional
• We have created a database of QA reviews, which has provided an overview of the reporting performance of individual CABs. The information serves two purposes, providing CABs with information to inform improvements and strengthening ASI’s oversight of CABs.
• ASC is improving the quality of auditor training by introducing case studies and providing more information on the CAR. Furthermore, we are providing instruction on how use the audit report template— especially how to fill out metric data—to improve reporting
• Since 1 January 2017, an audit report template has been provided to CABs. The template contributes to improving consistency and improved report quality, as mentioned by SeaChoice. ASC is working to further improve this process by creating a web-based reporting format, with a template that can only be submitted if all metric information is properly 

ASC recognizes that the challenges in defining major and minor NCs are multi-fold and need to be addressed over time with the assistance of the TAG. Underlying challenges to these definitions include, but are not limited to:

• Inconsistencies in standards developed by different Aquaculture Dialogues over time. Some standards set clearer requirements than the others, whereas other standards give guidance for auditors within the
• Inconsistencies within the same standards regarding types of indicators (metric-based, performance-based, practice-based). Setting well- functional level of non-conformance to different types of indicators requires both data and
• The difference in reporting requirements by ASC in contrast to those required by other global aquaculture certifications. The performance based compliance criteria introduced by ASC requires a more robust level of reporting than the practice-based standards schemes that auditors were accustomed

Major changes to the current process of raising NCs will likely take place during the next CAR review and revision in 2019, in connection with the first phase of the aligned standard.

Despite these realities, the ASC wishes to improve consistency across all of our standards and is developing further auditor guidance to provide clarity on when to raise a non-compliance and how to judge its severity. The guidance in development includes feedback on lessons learned from farm certification reports to illustrate different interpretations and to foster better understanding of the process by developing a baseline for future reference that can be used by CABs.

2. Clarify the application and consequence of non-conformities: Validate the standard’s stated 100 per cent compliance requirement by reinforcing that farms are either ‘conforming’ (i.e. meets the standard) or ‘non-conforming’ (i.e. does not meet the standard). Minor non-conformities should only be non-critical in nature (e.g. administrative). Farms in major non-compliance to the standard should not be certified. If a major non-compliance is raised after the initial certification, the farm should not be able to use the label. Provide further rules in regard to suspension, re-instatement and withdrawal of certificates.

ASC Response:

ASC scheme documents do not define any indictors as “non-critical in nature”. The programme prohibits the issue of a certificate in cases where a major non-conformity remains open after 3 months. While the independent programme maintained by ASC requires that CABs make the final certification decision, if ASC finds that a farm with open major NCs has become certified ASI will take action.

No scheme can provide 100% guarantees, however, the oversight provided by ASI and ASC as a third-party certification scheme provides a high level of assurance regarding CAB’s performance. This level of assurance is further supplemented due to the transparency of the scheme, whereby stakeholders have full access to audit reports and are actively invited to provide feedback.

ASC has already provided some guidance on differentiation between suspension and withdrawal on the interpretation platform. Further guidance, potentially including new requirements, will be considered in the next CAR revision, which will start in 2019.

Standard Compliance and Performance

3. Revise the PTI proposal to reflect actual global best practice: The standard should continue to 
define what is the top global performance and not allow regional variations that substantially weaken the standard. Do not remove the potential lobster impacts from the criteria. Establish an acceptable ABM parasiticide load and number of allowed treatments within the ABM.

ASC Response: 

The PTI revision is scheduled to be completed by early 2019. The majority of these recommendations have been received from SeaChoice via the stakeholder comments during the public consultation period. ASC will reflect on these additional recommendations.

4. Consider further reductions to the Fishmeal and Fish Oil Forage Fish Dependency Ratios: 1.0 FFDRmand 2.30 FFDRowhichreflectcurrentbestpractices.

ASC Response: 

The current FFDRm/o scores were revised and released in April 2017. Although it is too early to introduce a new revision at this moment, we do appreciate the numerical insights SeaChoice has provided. ASC will reflect on these numbers during the next revision of FFDRm/o.

5. Require further performance indicators be publicly reported: These should include, but not limited to:escapes,parasiticideand antibiotic use.

ASC Response: 

ASC is developing a reporting portal for (salmon) farms which will enable us to collect and report date in a more systemic manner. We appreciate the recommendations from SeaChoice and will review them during the development of the portal.

6. Develop an ABM approach to all standards: Establish requirements for potential cumulative impacts in relation to standards’ environmental indicators.

ASC Response:

An ABM approach for all ASC farms is not foreseen at this time. However, the recommendation has been registered and will be considered in due time.

Variance Requests and Q&A Interpretations

7. Improve the variance request process and its application: Incorporate expert and stakeholder 
input into the variance request approval process. At approval, the scope (e.g. applicable farm, area and dates) should be defined to avoid incorrect application by CABs. Eliminate variances that permanently change a standard requirement (metric, indicator, procedure) unless specifically envisioned in the standard.

ASC Response:

ASC is reviewing, and where needed revising, the VR-process. We appreciate the recommendations from SeaChoice and will review them during the further review/revision of the VR-process.

8. Ensure the Interpretation Platform is used for clarifications only: The platform should be used strictly for providing clarification to auditors and not for interpretations that amend the intent of the standard or CAR. Rescind the interpretation that states intermediary sites are “out of scope” and align the CAR and Salmon Standard definitions of Unit of Certification to ensure that audits assess the complete production cycle impacts. Correct the interpretation that states the closure of a major non-conformity may be extended without an ASC defined deadline to correctly reflect the CAR’s stipulated timelines for closing a major non-conformance—the one- time three-month extension and suspension after six months.

ASC Response:

The Interpretation Platform was created by ASC to meet many needs. It provides guidance and additional clarification to questions frequently asked by multiple parties. It also serves as a place to provide practical and credible interim solutions, including interpretations regarding standard or CAR requirements in the periods between scheduled review and revision process. The platform thus helps increase both the consistency and transparency of the programme. 

ASC is currently revising and improving the VR process. As soon as the updates are finalized they will be published and made publically available on the ASC website.

Monitoring and Evaluation 

9. Demonstrate that ASC certification is leading to sustainability improvements: Conduct a data driven analysis to determine if certified farms are improving their practices. 

ASC Response:

ASC is developing the M&E programme with the intent to publish periodic reports on the performance of farms in the programme. This data will also allow for improved insights into how the performance of ASC certified farms relate to the performance of the broader industry. As with all ASC documents, these reports will also be made public. The eTOR and framework for the M&E programme can be found on our website.