MSC Chain of Custody Single Multi Site Pre Audit Checklist v0

THE BEST ENVIRONMENTAL CHOICE IN SEAFOOD
Marine Stewardship Council Chain of Custody program
Pre-audit checklist for single and multi-site organisations (Version

2.0)
About this checklist
The pre-audit checklist allows you to determine how much of the MSC Chain of Custody (CoC) Standard: Default Version your organisation currently meets and
where you will need to make adjust your operations before the certification audit to ensure full compliance. This checklist can also be used if you are handling ASC
certified products. Please check that your organisation meets the eligibility criteria for this Standard – the criteria can be found in the preface of the CoC Default
Standard and in the Get Certified! Your guide to the MSC and ASC Chain of Custody certification process.
Disclaimer: This checklist is intended as guidance only. Following this document is not a fully comprehensive way of preparing for an audit against the MSC
Standard. The MSC recommends that all organisations read the MSC Chain of Custody Standard: Default Version 5.0 in full and evaluate the procedures specific to
your organisation. This checklist and its content are copyright of Marine Stewardship Council – © Marine Stewardship Council 2019. All rights reserved. The official
language of this checklist is English. The definitive version is maintained on the MSC’s website www.msc.org. Any discrepancy between copies, version or
translations shall be resolved by reference to the definitive English version and the English MSC scheme documents. If you are unsure on any subject covered, or
would like to provide feedback on how we can improve this tool, please contact the MSC at [email protected]
Table 1: The MSC Pre-Audit Checklist
Does my organisation
Requirement What to do? meet this already? What changes need to be made?
Yes | No
Principle 1: Certified products are purchased from certified suppliers
1.1 A process to ensure that all Check which of your suppliers are Chain of Custody
certified products are purchased certified on MSC Find a Supplier or ASC Find a Supplier.
from certified suppliers, fisheries When placing orders, MSC/ASC certified seafood must
or farms be specifically requested.
1.2 A process to confirm the You should have a system in place for managing ‘goods-
Page 1 of 15
MSC Pre-audit Checklist for MSC Chain of Custody Standard: Default Version 5.0 – published 28 March 2019 © Marine Stewardship Council 2019.
Yes | No
certified status of physical in’. Can your staff identify when certified seafood is
products on receipt coming into the business? What steps do your staff
take to identify and check certified against non-certified
seafood on arrival?
1.3 Products in stock at the time You should be able to prove to your auditor that
of initial certification can be certified product in inventory is from a certified
proven to come from a certified supplier. As your organisation bought this product
supplier, fishery or farm and before seeking certification you may have to go back to
comply with the relevant your supplier for proof.
sections of the MSC Chain of
Custody Standard
Principle 2: Certified products are identifiable
2.1 Certified products are Your staff must take steps to label and clearly identify
identified as such at all stages of certified seafood once it is in your business and until it
purchasing, receiving, storage, is sold and/or delivered. Walk through your premises
processing, packing, labelling, and/or review online systems – is labelling sufficient for
selling and delivering, except for anyone to differentiate certified from non-certified
sales invoices to final consumers seafood in records and on physical products?
2.2 Products that are sold as Your invoices should allow for specific identification of
certified are identified as the certified seafood that you sell. This can be done by
certified on the line item of the using the acronym MSC or ASC, the Chain of Custody
related invoice, except for sales code, or a unique product code (which is
invoices to final consumers communicated to your customer). Check that it’s easy
for you to identify certified product on your suppliers’
invoices.
2.3 Your organisation operates a You must have processes and/or systems that prevents
system to ensure packaging, staff/equipment from using the wrong packaging and
labels, menus and other labels now. Can these also be used effectively for
Page 2 of 15
Yes | No
materials identifying product as certified and non-certified seafood?
certified can only be used for
certified products
2.3.1 & 2.3.2 Products sold as If you identify the seafood species or catch area/origin
certified must be labelled with on the product label, you must follow the labelling
the correct species, catch area legislation of the country where the product will be
and origin, if this information is sold. What steps are taken to verify label information?
shown.
2.4 Your organisation can only If your organisation wants to use the MSC or ASC label,
promote products as certified or follow the MSC Ecolabel User Guide or ASC Logo User
use the MSC/ASC label if granted Guide and get written approval and a licence
approval under the terms of the agreement from MSCI (Marine Stewardship Council
licence agreement International).
Principle 3: Certified products are segregated
3.1 Certified products must not You must keep certified products physically segregated.
be substituted with non-certified It is not specified how this must be done but it can be
products as simple as using different colour boxes or different
refrigerator spaces for certified seafood. You should be
aware of the risk of your staff picking the wrong
product and have procedures built into their workflow
to avoid this.
3.2 Certified and non-certified If you wish to use the MSC or ASC label on a product
product cannot be mixed if your you must have systems in place to prevent mixing of
organisation wishes to make a certified and non-certified product.
claim, except in 3.2.1 below
3.2.1 If non-certified seafood is The MSC does allow the use of non-certified seafood
used as an ingredient in certified ingredients provided they do not exceed a given
Page 3 of 15
Yes | No
products, this must comply with proportion of the product’s seafood component. Make
the non-MSC/ASC certified sure product development staff are familiar with the
seafood ingredients rules MSC rules and ASC rules, and keep records of these
calculations for the auditor to check.
3.3 Products certified against The MSC shares its Chain of Custody Standard with the
different recognised certification ASC. To make a claim about the certified status of a
schemes that use the MSC CoC product, your systems for segregation must also work
Standard must not be mixed if for other schemes. MSC and ASC certified salmon
the organisation wishes to sell should be clearly segregated and not mixed.
the product as certified, unless
3.3.a or 3.3.b apply
3.3.a Your organisation has Products may show both the MSC and ASC label if
permission to do so approved by MSCI. For example, a fish pie containing
MSC haddock and ASC prawns can show both labels if
MSCI approval has been granted as part of the product
approval process. See the MSC Ecolabel User Guide or
ASC Logo User Guide for more information.
3.3.b The same product is If the seafood comes from a source that is certified to
certified against multiple two or more schemes that also use MSC Chain of
recognised certification schemes Custody, then both labels can be used – with
that use MSC Chain of Custody permission from MSCI. For example, a seaweed fishery
that is certified to both MSC and ASC Standards.
Principle 4: Certified products are traceable and volumes are recorded

4.1 Your organisation has a Check that your organisation’s existing traceability
traceability system that allows system can meet these requirements and if not,
4.1.a and 4.1.b below identify what changes you need to make.
4.1.a Any product or batch sold Follow your product flow records – can someone
Page 4 of 15
Yes | No
as certified can be traced back external to your organisation identify the flow of
from the sales invoice or point of product from the point of sale back to your supplier?
serving to the certified supplier Can this system be used for all your certified products?
4.1.b Any product bought as Follow your product flow records – can someone
certified and identified as external to your organisation identify the flow of
certified upon receipt can be product from your supplier to the point of sale? Can
traced forward from point of this system be used for all products specifically
purchase to point of sale or purchased as certified?
serving
4.2 Traceability records must Identifiers and codes used by your organisation must
link certified product at every show certified product flow through your operations.
stage between purchase and This must be clear to someone external to your
sale/serving organisation (i.e. the auditor).
4.3 Records of certified product Keep product records in the same state as sent by your
must be accurate, complete and supplier. This also applies to records created by your
unaltered organisation.
4.3.1 Where records are If your organisation needs to make changes to internal
changed, this must be clearly or external records (e.g. for a product rejection), mark
documented including the date these changes with the date and name of the person.
and name or initials of the
person making the changes
4.4 Records must be maintained These records must allow the auditor to conduct an
that allow quantities of certified input-output reconciliation (which is also called a mass
products bought and sold (or balance calculation).
received and dispatched) to be
calculated
4.4.1 If selling to final If your organisation sells to final consumers as well as
consumers, all records of to other businesses and can distinguish between these
Page 5 of 15
Yes | No
purchases and receipts need to sales (for example, a fishmonger selling mostly to the
be kept but sales records to final catering trade but also out of a small shop at
consumers do not need to be weekends) - you do not need to record the sales to final
recorded consumers.
4.5 If processing or packing / Your organisation must be able to calculate conversion
repacking occurs, records must rates (yield) when processing, packing or repacking
allow for conversion rates to be takes place. This also applies if these activities are
calculated for certified outputs subcontracted.
over certified inputs for any
batch or time period
4.5.1 These conversion rates The actual conversion rate is not important for Chain of
must be justifiable and accurate Custody as long as your organisation can demonstrate
why and how it has been calculated.
4.6 Only sell products as Whoever is responsible for procurement/buying must
certified that are covered by be knowledgeable of when a scope extension is
your scope of certification necessary, the timeframes for doing so, and who at
your certification body these changes must be
communicated to.
Principle 5: The organisation’s management system addresses the requirements of this Standard
5.1. Management and training
5.1.1 Your organisation operates This includes the systems, policies and procedures used
a management system that to ensure your organisation meets the Chain of Custody
addresses all requirements in Standard. For small or straightforward operations,
this Standard written documentation may not be necessary.
5.1.2 Responsible personnel are These are members of staff/contractors/volunteers
trained and competent to who make decisions or carry out procedures that can
ensure conformity with this affect the integrity of certified seafood. They need to
Page 6 of 15
Yes | No
Standard be able to explain to an auditor what their role is in
ensuring product integrity and the auditor will
interview staff to check this. You should keep evidence
to show that training exists and/or has been carried
out.
5.1.3 Maintain records that These records typically include purchase records of
demonstrate conformity with certified products, internal traceability records, staff
this Standard for a minimum of 3 procedures, and training documentation.
years or for the duration of the
product’s shelf life, if longer
than 3 years
5.1.4 Appoint a CoC contact Preferably just one staff member communicates with
person who is responsible for all your auditor and/or certification body on behalf of your
communication with your organisation (this can be the same person responsible
certification body and can for your Chain of Custody certification).
respond to any requests for
information or documents
relating to Chain of Custody
conformity
5.2 Reporting changes
5.2.1 Inform your certification Make sure whoever is responsible for communicating
body in writing or by email with your certification body is aware of these timelines.
within 10 days of the changes
described in 5.2.1.a, 5.2.1.b, and
5.2.1.c below
5.2.1.a New CoC contact person Within 10 days of assigning a new person to be
responsible for managing your Chain of Custody
certificate and/or communicating with your
Page 7 of 15
Yes | No
certification body.
5.2.1.b New supplier for Within 10 days of receiving certified product from a
certified products new supplier (as defined in your supplier list at the
latest audit).
5.2.1.c New certified species Within 10 days of receiving product made from a new
received (scope extension) certified species (as defined in your certificate scope list
at the latest audit).
5.2.2 Gain written approval from Make sure whoever is responsible for communicating
your certification body before with your certification body is aware of these
making any of the following requirements and timelines.
changes in 5.2.2.a, 5.2.2.b, and
5.2.2.c below
5.2.2.a Undertake a new activity Get approval from your certification body before
related to certified products starting a previously undeclared activity with certified
(scope extension) seafood (i.e. an activity not listed in your certificate
scope at your last audit). For example, if your
organisation has been trading products but is now
going to open a distribution warehouse, this counts as a
new activity (please see definitions for scope and
trading in Table 2).
5.2.2.b Selling or handling Get approval from your certification body for ASC
product certified against certified products or other schemes that use MSC Chain
different recognised certification of Custody.
schemes that share MSC Chain
of Custody (scope extension)
5.2.2.c Using a new Get approval from your certification body before using
subcontractor that will process, a new processing or packing subcontractor for certified
Page 8 of 15
Yes | No
pack or repack certified products seafood.
5.2.2.d Handling seafood that is Get approval from your certification body before using
under MSC fishery or ASC farm seafood that is not yet certified (only if your
assessment if your organisation organisation is part of the fishery or farm assessment)
is part of the fishery/farm
5.2.2.e Adding or changing a site Get approval from your certification body before
address or company name adding a new site or changing a site or company name
5.3 Subcontractors, transport and contract processing

5.3.1 All subcontractors handling A subcontractor by MSC definition is an organisation
certified product comply with that does not legally own, buy or sell certified product.
the relevant requirements of The auditor will check your organisation has control
this Standard over subcontractors to ensure they comply with the
MSC CoC Standard.
5.3.2 Maintain an up-to-date Keep one list of all subcontractors that you can show
record of the names and the auditor.
addresses of all subcontractors
handling certified product,
except for transport
5.3.3 Inform any non-certified The auditor will conduct at least one traceability test
contract processors that they and input-output reconciliation with your contract
will be audited before your processor. If there is certified product onsite the
organisation can use them for auditor will also cross-check dispatch and receipt
certified product and once a records, product details and volumes between your
year thereafter organisation and the processor.
5.3.4 Be able to request certified The auditor may wish to see traceability records for
product records and give your certified product or check certified products
Page 9 of 15
Yes | No
auditors access to products handled by your subcontractors.
handled by subcontractors
5.3.5 Have a signed agreement The following requirements can be written into a new
with all subcontractors that or existing contract but must cover all points. This
transform, process or repack applies even if your subcontractors have their own
certified products – covering the Chain of Custody certification.
points in 5.3.5.a and 5.3.5.b
below
5.3.5.a The subcontractor has Your organisation needs to be confident that
systems in place to ensure subcontractors are identifying, segregating and tracing
traceability, segregation, and your certified product throughout their operations and
identification of certified are able to describe how they are doing this to the
product at every stage of certification auditor.
handling
5.3.5.b The subcontractor allows The MSC or certification auditor may need to make a
the MSC (or designated agent) site visit (for example, for the annual audit of a contract
and the certification body to processor or for an investigation).
access the site and to check
records of certified products
5.3.6 Your organisation does not If you receive seafood directly from fishing vessels, or
knowingly ship or receive use vessels in shipping, you can check RFMO websites
product transported on or for up-to-date lists of IUU (illegal, unreported and
received from vessels on RFMO unregulated) vessels.
blacklists
5.3.7 Maintain records of all These records enable the input-output reconciliation
contract-processed certified and traceability test to be conducted across the
products, including: subcontractor and your organisation. This applies if you
 Received product subcontract to processors or if you do contract
Page 10 of 15
Yes | No
(volumes and product processing for others.
details)
 Dispatched product
(volumes and product
details)
 Dates of dispatch and
receipt
5.3.8 If your organisation This happens when your organisation is subcontracted
performs contract processing by another organisation with Chain of Custody,
you must record the name and whereby your organisation does not own or buy/sell
Chain of Custody code for all the certified product.
customers since the previous
audit
5.4 Non-conforming product
5.4.1 Have a process to manage This can happen when:
non-conforming product that  Your organisation cannot confirm product with the
includes 5.4.1.a to 5.4.1.e below. MSC ecolabel is from a certified source, for
example, if the purchase order states MSC but the
invoice received does not
 Your supplier informs you that they accidentally
sold you non-conforming product
 A staff member realises at the end of the run that
the production line packed non-certified seafood
into boxes with the ASC logo
If you have a recall system in place you can use this as a
model to deal with non-conforming product for Chain
of Custody.
5.4.1.a Immediately stop selling Hold the product in question. This can refer to a batch,
Page 11 of 15
Yes | No
non-conforming product as pallet, box, shipment, etc. depending on the specific
certified circumstances.
5.4.1.b Inform your certification Relevant information to provide to the certification
body within 2 days of detecting body is likely to include delivery notes, invoices,
the non-conforming product and product specification instructions, and product run
provide your certification body reports.
with information to check the
certified status of the product
5.4.1.c Identify why the product Preventative actions should reflect the source of
is non-conforming and problem and may involve, for example, re-training staff
implement measures to prevent or re-writing ‘goods-in’ procedures.
re-occurrence, where necessary
5.4.1.d Where the non- Change the status of any remaining product from that
conforming product cannot be batch/pallet/box/shipment to non-certified.
proven to come from a certified
source, re-label/re-pack this
product so it cannot be sold as
certified
5.4.1.e Inform all affected Contact customers you have sold product to (identified
customers within 4 working days as certified) but have been sent non-certified product
of detecting the non-conforming instead.
product if it has already been
sold or shipped as certified
5.5 Requests for traceability and supply chain assurance
5.5.1 Cooperate with the MSC The MSC or your certification body may ask for these
and certification body requests records in the event of a supply chain investigation.
for traceability documents or
Page 12 of 15
Yes | No
sales/purchase records for
certified products
5.5.1.1 Provide documentation Financial details may be removed but otherwise
within 5 calendar days of records must be unaltered. If, in exceptional
request circumstances, you cannot meet this deadline you can
ask for a justified extension.
5.5.2 Allow the MSC or the Product samples may be taken by an auditor as part of
certification body to collect the MSC’s annual DNA testing or for an investigation.
certified seafood samples for the
purposes of DNA testing
5.5.3 If the test identifies If a test result shows the seafood to be non-conforming
product as non-conforming,, (see 4.5.1), you must conduct an internal investigation.
your organisation must: This is to see if the problem emerged within your
 Investigate the potential operations or came from further up the supply chain
source (for example, the product was sold mislabelled by a
 Present the findings from certified supplier). If the problem originated within
this investigation to your your operations, your organisation will need to have a
certification body corrective actions plan to address it.
 Cooperate with further
sampling and investigation
5.6 Specific requirements for under-assessment product
5.6.1 Organisations can only buy Before buying under-assessment seafood, check if your
seafood that is under organisation is the MSC fishery or ASC farm, or a named
assessment if they are, or are member of the fishery client group / same legal entity
part of, the MSC fishery or ASC as the farm, which is undergoing assessment for
farm that is undergoing certification.
assessment
Page 13 of 15
Yes | No
5.6.2 If handling under- Ensure that any products from an under-assessment
assessment seafood, the MSC fishery or ASC farm are identified and kept
organisation must; separate from all other products.
a. identify and segregate all Keep records that show full traceability of the product
under-assessment products back to the fishery or farm’s Unit of Certification,
b. keep traceability records of including the date of harvest.
under-assessment products back Not sell any products from an under-assessment MSC
to date of harvest fishery or ASC farm until the Public Certification Report
c. ensure under-assessment is published on the MSC or ASC website, announcing
products are not sold as certified that the fishery or farm is certified.
until the fishery or farm is
certified
5.7 Specific requirements on forced and child labour
5.7.1 Sign the CoC Certificate If your organisation is in a ‘standard risk country’ (ask
Holder Statement of your certification body or check the ‘Country Labour
Understanding of Labour Risk Scoring Tool’ in the Certification Requirements),
Requirements agreeing to you must sign the Statement of Understanding in which
complete a labour audit you agree to complete a recognised third-party audit
on forced and child labour.
5.7.2 Provide evidence that your Your labour audits must comply with the MSC Third-
relevant sites and Party Labour Audit Requirements and be completed by
subcontractors have completed your next CoC audit.
an on-site labour audit
Table 2: Scope activity definitions
Page 14 of 15
Activity Definition
Trading fish (buying/selling) This will likely applicable to all companies, except for subcontractors that do not buy certified product
Storage Product held in a storage area
Distribution Companies that receive sealed containers, pallets, etc. and deliver them to customers or other members of their group
Wholesale Companies that receive sealed containers, pallets, etc. and sell them to customers or other members of their group
Packing or repacking When the packaging is changed but the product remains the same
Processing Includes primary or secondary processing value added processing, fish preparation or any other activity where the product is changed
(except for ‘retail to consumer’ and ‘restaurant/take away to consumer’)
Contract processing Any certificate holder that carries out processing on behalf of the product owner (does not legally own the seafood)
Use of contract processor Any certificate holder that uses a non-certified contract processor to process, repack or transform certified product on their behalf
Retail to consumer Where the product is purchased, taken away and prepared by the consumer. This includes fish counters at retailers, fish mongers, and
markets selling directly to consumers
Restaurant/take away to Any foodservice situation where the product is prepared on-site and sold directly to consumers
consumer
Page 15 of 15

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THE BEST ENVIRONMENTAL CHOICE IN SEAFOOD

Marine Stewardship Council Chain of Custody program

Pre-audit checklist for single and multi-site organisations (Version

Principle 4: Certified products are traceable and volumes are recorded

5.3 Subcontractors, transport and contract processing

Table 2: Scope activity definitions

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