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Indicator 3.5.8
Requirement
The UoC shall ensure that appropriate and understandable health and safety notices, instructions, and warning signs are visibly displayed.
How Do I Interpret This Requirement?
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Potential hazards and risk areas around the site are clearly identified by warning signs.
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The choice of signs, notices and instructions are informed by the health and safety risk assessment.
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Written safety instructions for equipment use are accessible to all employees who need to use that equipment and are in a language that employees understand.
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Written safety procedures are available to employees and:
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include details on:
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accident prevention and response
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emergency procedures
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are in a language that they understand
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can include pictures or diagrams, which can be helpful.
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Evidence of Implementation
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warning signs around the site
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written safety instructions and procedures that are accessible for employees.
Auditors Should Confirm
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warning signs are clearly visible and potential hazards are clearly marked;
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employees understand where they can access safety instructions and procedures;
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employees understand what the warning signs mean and what they refer to.
Indicator 3.5.7
Requirement
The UoC shall report to ASC any accidents, according to ASC data submission procedures.
How Do I Interpret This Requirement?
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This is a reporting requirement, not a disclosure requirement, which means that all data is held confidentially by ASC, who does not share it publicly.
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Companies should never publicly share personal employee data.
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The information collected through this reporting requirements will enable ASC to:
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gain insights into common incidents and accidents and health and safety risks, which will inform the future development of ASC’s health and safety requirements
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foster open discussions about health and safety risks and how to prevent them.
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Evidence of Implementation
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confirmation of data uploaded to MyASC.
Auditors Should Confirm
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that data uploaded to MyASC is consistent with results of the wage gap analysis.
Indicator 3.5.6
Requirement
The UoC shall maintain written records of health and safety accidents and near misses, determine the cause and implement appropriate corrective actions to prevent recurrence.
How Do I Interpret This Requirement?
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An accident is an unexpected event that causes damage, injury or harm.
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A near miss is an incident that had the potential to cause damage, injury or harm, but was prevented.
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The recording and investigation of both of these is important. By investigating to determine the root cause, the UoC is able to:
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take corrective actions that will allow the incident not to reoccur
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spot potential problems and prevent them from occurring in the first place.
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Corrective actions are actions that the UoC can put in place to ensure that the incident does not occur again. Examples are in Table 4 below:
Table 4. Examples of incidents, their cause and the resulting corrective actions:
Incident | Determine the cause | Implement corrective action
Oil is spilt on the feed barge and an employee slips and hits their head | After working on a mechanism on the barge, an employee left the oil can without a lid on and someone knocked it over without noticing. | Assign a dedicated place to safely store oil cans when they are not being used.
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| | Ensure employees are trained on this and reminded to safely store equipment.
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| | Ensure the appropriate materials are available to clear up oil, if it does spill.
Employee trips over some rope | The rope was left coiled up on the floor. | Set up ropes in a way that people cannot trip over them, or a warning sign in front of any ropes that are a trip hazard.
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There is a difference between immediate corrective action and the corrective actions to take once the root cause has been determined. For example: a fire extinguisher is blocked by a bin being placed in front of the extinguisher:
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staff take immediate corrective action and move the bin
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however, the next day they find that someone has moved the bin back. The immediate corrective action did not prevent reoccurrence
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staff investigate to determine the root cause and find out why the bin was placed there
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the investigation shows that this is the most ergonomic layout of the workstation and the bin will always be moved back to that location by whoever is using the workstation
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staff take long-term corrective action and move the fire extinguisher. This stops the issue from reoccurring.
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Evidence of Implementation
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records of accidents or near misses
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records of corrective actions taken
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training records.
Auditors Should Confirm
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employees feel comfortable to report any accidents or near misses;
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employees understand what the process is for reporting any accidents or near misses.
Indicator 3.5.5
Requirement
The UoC shall ensure that any person working on the site receives health and safety training as required to carry out their job. The UoC shall ensure that training is: a) free of charge; and b) provided in a timely manner; and c) repeated on a regular basis; and d) conducted during regularly remunerated working hours, or the person is compensated for their time; and e) updated as necessary based on new procedures or equipment; and f) documented, and records maintained.
How Do I Interpret This Requirement?
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Training is important because it contributes to shared responsibility for health and safety, and a workplace where everyone is protected.
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Training is delivered in a format and language that all employees can understand:
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provisions are made for anyone who is illiterate
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the UoC is responsible for ensuring that all employees have understood the training.
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Training is documented so that it is clear who has attended and what they were trained on.
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Evidence of Implementation
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training records demonstrating regular training sessions and content trained on
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attendance records confirming that all employees have been trained.
Auditors Should Confirm
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employees understand the different health and safety risks present at the site;
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employees understand good practices around health and safety at the site;
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employees have not paid for the training and it has taken place either during working hours, or they have been paid for the time that they have given to the training.
Indicator 3.5.4
Requirement
The UoC shall ensure that any person with a medical condition, or who is pregnant, does not conduct hazardous work as determined by the health and safety risk assessment (see Indicator 3.5.1).
How Do I Interpret This Requirement?
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Hazardous work can include:
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working with chemicals or dangerous substances
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working at heights or in dangerous situations
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heavy lifting or work that is physically challenging
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working with heavy machinery.
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Examples of adjusting working conditions for pregnant women can include:
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reducing physical stress, this includes limiting the weight that employees are lifting:
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week 1-19 of the pregnancy: maximum of 10 kilos at a time
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week 20-29 of pregnancy: maximum of 5 kilos up to 10 times a day
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from week 30 of pregnancy, maximum of 5 kilos up to 5 times a day
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from week 28 of pregnancy, the employee also shouldn’t bend or kneel more than once an hour
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up to 6 months after giving birth, any work involving lifting, carrying, pulling, and pushing objects should be slowly built up
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avoiding pregnant women performing tasks under environmental (atmospheric) pressure, such as diving
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not exposing pregnant and breastfeeding mothers to hazardous substances and bacteria that can harm the (unborn) child.
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Evidence of Implementation
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documented health and safety risk assessments.
Auditors Should Confirm
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whether there are pregnant women or people with medical conditions working at the UoC;
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whether or not they have been included in the health and safety risk assessment;
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that staff responsible for health and safety have an understanding of the particular risks that face pregnant women and people with a medical condition, and how to mitigate those risks.
Indicator 3.5.3
Requirement
The UoC shall allow any person the freedom to remove themselves from an unsafe situation without seeking permission and without fear of retribution. **
How Do I Interpret This Requirement?
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This requirement is applicable to both the workplace and any accommodation facilities provided by the UoC.
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An employee could decide that a workplace is unsafe if there are significant risks to health or safety due to, for example:
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inadequate safety measures
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faulty equipment
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lack of training
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hazardous substances
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non-compliance with safety laws
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anything that makes the employee feel unsafe.
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If an employee feels unsafe, they do not need to ask prior permission to remove themselves from the situation.
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Retribution can take many forms and can be:
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obvious punishment, for example:
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physical threats
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verbal threats or warnings
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hidden punishment, for example:
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being ignored for a promotion
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being refused requests that are unrelated to the unsafe situation
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hostile treatment.
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Management can communicate to employees that they are able to remove themselves from any unsafe situations, for example through:
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training
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information in their contracts
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verbal explanations.
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Evidence of Implementation
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employee contracts
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health and safety training records
Auditors Should Confirm
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employees understand that they are able to remove themselves from unsafe situations without fear of retribution;
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employees understand what unsafe situations may occur and are aware of escape routes and emergency procedures;
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management understand that employees have the right to remove themselves from unsafe situations without fear of retribution.
Indicator 3.5.2
Requirement
The UoC shall ensure that the person conducting the site-specific health and safety risk assessment has the necessary competencies, experience and training. In cases where regulatory requirements are defined, the UoC shall ensure that the person conducting the site-specific health and safety risk assessment complies with these requirements.
How Do I Interpret This Requirement?
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To demonstrate competence, the person carrying out the health and safety risk assessment should:
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understand the:
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different steps of a risk assessment process
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health and safety risks inherent in aquaculture operations
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context of the UoC
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number of employees and their roles
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variety of different activities carried out across the site and what they involve;
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be able to:
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record risks in a clear and consistent way
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identify risks in all of the different areas of the site and operations of the UoC
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identify preventative measures for risks
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identify mitigation measures for risks
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have experience conducting health and safety risk assessments
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have undergone training on conducting health and safety risk assessments. This training can be:
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ASC training
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training from an external provider
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on-the-job training from someone experienced in conducting health and safety risk assessments.
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Evidence of Implementation
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training records
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qualifications of the person conducting the health and safety risk assessment
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health and safety risk assessment.
Auditors Should Confirm
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what applicable legal requirements there are for health and safety risk assessments;
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the qualifications and experience of the person conducting the health and safety risk assessment;
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how effective and thorough the risk assessment is that is in place.
Indicator 3.5.1
Requirement
The UoC shall carry out a site-specific health and safety risk assessment, approved by a member of senior management, following the method outlined in Appendix 3 (3.4).
How Do I Interpret This Requirement?
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“A risk assessment is simply a careful examination of what, in the workplace, could cause harm to people”.
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The ILO identifies five steps in a risk assessment:
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Step 1: Identify the hazards
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Step 2: Identify who might be harmed and how
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Step 3: Evaluate the risk — identify and decide on the safety and health risk control measures
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Step 4: Record who is responsible for implementing which risk control measures and the timeframe
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Step 5: Record the findings, monitor and review the risk assessment and update when necessary.
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The risks assessment should:
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cover all site activities;
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result in contingency or prevention measures for all risks identified.
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The risk assessment should be reviewed and revised:
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prior to starting a new activity;
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following feedback on major issues from employees;
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when a new site is added to the UoC;
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when there has been a significant change to the process;
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following accidents or near misses;
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annually.
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Evidence of Implementation
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documented health and safety risk assessments
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list of contingency and preventative measures to mitigate the risks.
Auditors Should Confirm
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the member of staff that is responsible for conducting and maintaining the risk assessment has a good understanding of the different risks on site, and the actions taken to mitigate them.
Useful Resources
Indicator 3.4.6
Requirement
The UoC shall, when requiring medical tests (see Indicators 3.4.4 and 3.4.5), ensure that: a. employees understand the reasons for the tests; and b. employees’ medical information is confidential; and c. employees have access to their test results; and d. employees have the right to use a medical professional of their own choosing, if preferred; and e. employees are not charged for the tests.
How Do I Interpret This Requirement?
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Any reasons for medical tests are clearly communicated to the employee or prospective employee, at time of recruitment where necessary.
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The employee or prospective employee has the right to their test results and the UoC ensures that the results are kept confidential.
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The cost of medical tests is paid by the UoC and is not a cost that is charged to the employee or prospective employee.
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In some situations, the UoC may have an on-site doctor, or a doctor that there is an established relationship with, who regularly conducts the necessary medical tests. However, an employee or prospective employee is allowed to choose to consult an independent doctor, who could be their own doctor, or someone completely unrelated to the UoC.
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Costs incurred by employees or prospective employees towards medical tests, if using an independent doctor, are to be reimbursed within an agreed time period.
Evidence of Implementation
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terms of service between recruitment agencies and the UoC
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documents from recruitment processes
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information about which medical tests are required
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evidence of provision of copies of medical tests to employees.
Auditors Should Confirm
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employees understand the reasons for the medical tests;
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employees have access to their test results and they are confidential;
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employees understand that they are able to use an independent doctor if they prefer;
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there are no costs incurred by employees for any medical tests.
Indicator 3.4.5
Requirement
The UoC shall only require medical tests during employment if justified by a healthy and safety or food safety risk assessment.
How Do I Interpret This Requirement?
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There are occasional situations where the UoC, or the agency involved in recruitment may need to perform medical tests. For example:
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it is required by law
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if the function of the job requires it
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for health and safety reasons.
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Determining whether a medical test is necessary happens through a health and safety risk assessment (Indicator 3.5.4).
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Examples of when medical tests may or may not be allowed are:
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An example of when the function of a job might require a medical test is the recruitment of divers, a diver may have to undergo a chest x-ray to demonstrate that they are fit enough to dive regularly.
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An example of when a medical test might be necessary is if an employee is asked to test for Covid-19 before coming into the workplace, to avoid the spread of the disease.
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An example of when a medical test is not allowed is an STI test, which could lead to discrimination about someone’s sexual practices and / or ability to work.
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An example of when a test may be required by national law is the existence of laws in 25 countries that have a law that makes HIV testing mandatory to obtain a work or residence permit: <https://lawsandpolicies.unaids.org/topicresult?i=25&lan=en>. Outside of these 25 countries, an HIV test is not necessary and would not be conducted as it is not relevant for the function of any jobs in aquaculture.
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Evidence of Implementation
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terms of service between recruitment agencies and the UoC
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documents from recruitment processes
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health and safety and food safety risk assessments that require medical testing
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information about which medical tests are required.
Auditors Should Confirm
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where medical tests are required, the decision for these tests has been based on the outcome of a risk assessment;
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employees understand the reasons for the medical tests.
