Strengthening Verification in Sustainability Standards: the Development of the ISEAL Assurance Code

1. Strengthening Verification in Sustainability Standards: the Development of the ISEALAssurance Code Patrick Mallet ISEAL Credibility Director Paddy Doherty ISEAL Code Development Manager

2. Components of Assurance • All-encompassing term, as defined by ISEAL to include: • Auditing • Competencies, training, evaluation • Certification • 1st party • 2nd party • 3rd party • Accreditation

3. Role of Assurance in a Standards System • Three core functions • Setting the standard • Assessing compliance with the standard • Measuring the impacts of compliance • Proxy for direct relationship between producer and consumer • What does credible assurance look like?

4. Prioritizing Issues for an Assurance Code • Strong ISEAL member support drives development • Scoping exercise as consultation opportunity • Online critical issues survey – 86 participants • Semi-structure interviews – 36 key stakeholders • Producer group interviews – 11 clients • Background research – report from Richard Bradley • Scope agreed by Stakeholder Council • Steering Committee will oversee the Code development • Technical Committee will help to draft the Code

5. Doesn’t ISO already provide enough guidance? • ISO Standards (65, 17021, 17011) form a strong foundation • Systems-based • Supporting impartial, independent and consistent results • Assurance of sustainability standards requires more • Competence, transparency, accountability, accessibility • ISO acknowledges Scheme-specific guidance is necessary (17067) • Auditor competencies, audit process, decision-making • Assurance Code as scheme-specific guidance for social and environmental standards systems • Potentially includes interpretation of ISO standards

6. Guiding comments • “Certification should be a model for development, rather than a hurdle to overcome” • “[I] Would like to see common agreement on certain practices in assurance – not so much ‘best practice’ but rather common denominators – do not try to be the ‘most credible’”

7. Principles of Credible Assurance

11. 1. Auditor Competence • “Training of auditors is our biggest issue – but developing training modules and delivering them does not automatically produce good auditors – some are good and some aren’t; why?” • “Consistent auditing is a challenge” • “Do not make auditors need ISO 19011” • “I think having ... auditors take the training for another auditing program is waste of time and money (a waste of time/$ for us)”

13. ‘Other’ comments • Focus on key issues- experience of auditor • Comparable audit report format (year after year AND between producers) • No mention in this list of oversight issues, governance, or indeed accreditation focus - or of scheme document requirements • Accessibility of the audit process for stakeholder input • Managing time during the audit process - in many cases certified operations intentionally or unintentionally not providing the information/documents on time

14. Options for addressing auditor competence • Common requirements for training, qualification, monitoring • Common training platform • Central (common) registration/accreditation programme for auditors • Certification of auditors • Guidance notes to ISO 17065

15. 2. Cost and accessibility • The cost of certification is “...way too much for the benefits received” • “Comment regards ISO65 would be cost vs benefit” • “Some innovative thinking and guidance on assurance processes for producers who are a long way from certification is urgently required” • “Costs vary over different fishery – challenges around cost for smaller fisheries” • “Is the current assurance system relevant for small schemes?”

16. Options for addressing cost and accessibility • Use of risk assessment to reduce audit frequency • Finding other benefits from assurance (capacity building, data gathering) • Providing options for the right level of assurance based on risk and stakeholder demand • Increasing transparency while reducing audit requirements • Guidance to ISO 17065 (for capacity building, access for small CBs)

17. 3. Governance and Internal Management • “Sampling rules would be useful. A problem in our programme is the common rating from audit is quite subjective – how can we reduce the subjectivity?” • “There are different kinds of CB decisions; major minor infractions; Code could provide guidance in this area” • “Assurance code could specify who is responsible for auditor training” • “Transparency as a key element for trust-building cannot be overrated”

18. Options for addressing governance and internal management • Guidance to ISO standards (eg: 17065, 17011, 17021) • Clarification of roles: who is responsible for which activity • Audit implementation: • Good practice in audit performance and reporting • Common methodology for risk-assessment & sampling • Requirements for transparency : • Certification decision • Decision-making • Assurance system governance

19. 4. Standard quality/clarity • “Poor standards are an issue – standards development has been reactive. Too much prescription in some standards = auditors not using common-sense” • “Unclear standards can be a problem” • “Guidance on consistent interpretation of a standard (needed)”

20. Options for addressing standard quality • Good practice in crafting standards that provide for consistent interpretation • Requirements for auditors to ensure consistent application of the standard (including guidance)

21. 5. Other issues brought up in the consultation • Claims and labelling • Chain of custody • Efficiency (certification and accreditation body internal management) • Auditing in conflict and disaster zones

22. Assurance Code Development • Multi-stakeholder consultation • 9 member Steering Committee • 9 member Technical Committee • First draft for consultation in September • At least 2 rounds of public consultation • Expected completion June 2012

23. Thank you. To find out more visit: www.isealalliance.org/assurance-code Patrick Mallet ISEAL Credibility Director Paddy Doherty ISEAL Code Development Manager