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Variance request and Interpretation platform

This platform is a searchable database of all Variance Requests (VR’s) and Questions for Interpretation (QA’s) submitted to the ASC. Variance Requests are publicly available to improve consistency in understanding and application of ASC standards and Certification & Accreditation Requirements (CAR).

ASC has revised its Variance Request process and developed a normative Variance Request procedure to maintain its transparency and accountability ethos. The Variance Request procedure allows for stakeholders to submit feedback to VR’s related to the ASC species’ standards. To do so, please follow the steps outlined in The Variance Request Procedure.

CAB BVC
Publication date 2023-11-07
Certificate holder FEED ONE COMPANY LIMITED
Date of submission 2023-11-07
Status Archived on: 2024-09-10
Unit of certification FEED ONE COMPANY LIMITED
Species
Country Viet Nam
Reference to other VRs
Document reference Feed
Version Feed RUoC v1.0.1
Indicator 16.4.1.
Other relevant indicator/clause
Background info

We have conducted the ASC Feed Audit for the client FEED ONE on 02 – 04 Aug 2023. This was the first ASC Feed Audit in Viet Nam for BVCH.


The audit resulted in some Major NCs related to the Due Diligence assessment (Indicator 2.2.6, 3.2.1, 5.1.3) and competencies of individuals conducting Due Diligence (RUoC 4.1.1.1.).

Request/Recommendation Considering the specific situation of this client, is it possible that ASC can accept an additional extension of six (6) months as per requirement 21.5.2.2. from the ASC-CAR-002_v1.0.1., despite the requirement 16.4.1. indicated on the ASC-RUOC-002_v1.0.1.
Supporting evidence Since this is the first audit on this new standard, the client has difficulties in closing these Major NCs within the 3 months-period.
We initially decided that we could extend the timeline to close the major NCR, using the requirement 21.5.2.2. (Major non-conformities may be extended once for a maximum period of six (6) months after the Detection Date.) from ASC-CAR-002_v1.0.1.     
But after reading the requirement of the ASC-RUOC-002_v1.0.1, it seems that this is not possible.
Decision of the request Variation NOT Approved – Do not agree that there is a rationale for a variance against the ASC Standard or CAR
Release date November 23, 2023
Effective date November 23, 2023
Rationale The VR is not approved.The request for an extension of the NC closure timeline is denied based on the following:There are open Major NCs against the following indicators: 2.2.6, 3.2.1, 5.1.3, 4.1.1.1. All of which directly relate to the Feed Standard Due Diligence and eligibility status of the feed ingredients.The audit determined there was no evidence that a full and comprehensive Due Diligence Assessment was conducted by the mill. This is a core step in demonstrating low risk for the risk factors in Annex 3 and Annex 6 of the Feed Standard.In addition, the UoC did not determine which ingredients were eligible, again a core element of the standard is to identify eligible ingredients for manufacture in ASC Feed.A third related NC indicates the team conducting the Due Diligence did not fully meet the competency requirements of annex C.
A thorough and complete Due Diligence process is the cornerstone for demonstrating the eligibility status of feed ingredients which is ultimately used to manufacture ASC complaint feed.
The combined impact of these non-conformities indicates a significant failure to meet a fundamental element of the Feed Standard.
Feed CAR v1.0.1. / 21.5.1. The CAB shall classify an initial audit as a failed audit if major non-conformities are not closed within three (3) months from the Detection Date.Feed CAR v1.0.1. – 5.1.2. The CAB shall not accept the application if the applicant has failed an initial audit conducted by a different CAB and it has been less than 12 months since that previous CAB audit was categorised as failed.However, this does not prevent the mill having a re-audit with the same CAB.
Targeted technical consultation findings
Stakeholder Comment Date published Submitted by Documents
No comments available
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