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Indicator 3.1.3
Requirement
The UoC shall facilitate the establishment of employee representation to support the implementation and maintenance of the human rights policy.
How Do I Interpret This Requirement?
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Employee representation:
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can vary with the size and context of the UoC. It can be a committee or nominated representatives
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ensures that the voices and perspectives of employees are heard and considered in matters related to human rights.
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A committee structure preferably:
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represents the composition of employees, enhancing inclusivity
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holds elections for the employee committee, allowing all employees to nominate and vote for members.
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Meets on a regular basis and occasionally on a more ad-hoc basis, where need arises.
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A committee’s role includes:
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assisting in the development of strategies, initiatives, and activities that promote human rights within the organisation
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helping to monitor the UoC’s human rights performance
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identifying areas where the policy might not be effectively implemented or where issues arise
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engaging in dialogue with management to address concerns, propose improvements, and ensure that the policy remains relevant and effective
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raising awareness among their colleagues about the UoC’s human rights policy, principles, and procedures.
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The UoC should ensure that any employee representative or committee:
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has knowledge about the human rights policy
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understands what their role involves. This can include ensuring that they have access to training.
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Evidence of Implementation
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list of members of the employee committee or employee representation
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records of meetings and actions
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records of election procedures.
Auditors Should Confirm
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employees are aware of who represents them and how to contact them;
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the employee representation understands their role and the human rights policy.
Indicator 3.1.2
Requirement
The UoC shall have at least one named member of management who is responsible for the implementation and maintenance of the human rights policy.
How Do I Interpret This Requirement?
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Implementing and maintaining the human rights policy means that the named member of management is responsible for:
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translating the policy statement into practical actions and initiatives within the UoC and in day-to-day operations
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monitoring the UoC’s human rights performance, including:
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identifying areas of improvement
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reporting progress or issues to senior management or relevant stakeholders
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overseeing continuous improvement
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overseeing training and awareness programmes aimed at educating employees and stakeholders about human rights principles, policies, and procedures
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updating the policy regularly or when there are changes at the UoC.
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The named member of management should also commit to working with employee representation in the implementation of the policy, ensuring that employees’ views are taken into account.
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Evidence of Implementation
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records that allow for the verification of the named member of management
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plan of actions involved in implementing the policy
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plans for monitoring implementation of the policy
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evidence of any remediation or corrective actions that have taken place
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plans for regularly updating and revising the policy.
Auditors Should Confirm
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that the named member of management understands their responsibilities in implementing and maintaining the policy;
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that employees are aware of the named member of management responsible for the human rights policy;
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that the human rights policy is being implemented, which can include checking:
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progress against any action plans and monitoring plans,
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if employees are aware of and understand the contents of the policy,
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evidence of any remediation or corrective actions where there are negative human rights impacts.
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Indicator 3.1.1
Requirement
The UoC shall have a written human rights policy, approved by senior management, with the intent of publicly demonstrating its commitment to at least the following: – freedom of association and the effective recognition of the right to collective bargaining; and – the elimination of all forms of forced or compulsory labour; and – the effective abolition of child labour; and – the elimination of discrimination in respect of employment and occupation; and – a safe and healthy working environment; and – being a good neighbour and respecting the rights of surrounding communities.
How Do I Interpret This Requirement?
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A human rights policy:
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is the “company’s public expression of its commitment to meet its responsibility to respect internationally recognized human rights standards”
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is appropriate to the strategic direction, context and purpose of the organisation
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provides a framework for setting quality objectives
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includes an explicit commitment to respect all other internationally recognised human rights standards that apply to people that may be impacted by the UoC’s operations
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includes stipulations concerning the company’s expectations of personnel, business partners and other relevant parties
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includes information on how the company will implement its commitment
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is aligned with the requirements in the ASC Farm Standard, and local and international human rights laws and standards
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is signed by senior management
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is understood by all employees.
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Each company will need to determine for itself which human rights may need to be prioritised in its policy because this will depend on the risks associated with the:
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company’s location
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type of farming practices
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composition of the workforce.
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The content of the human rights policy may vary according to the UoC’s size and national legal frameworks, and could also include the following topics:
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recruitment and termination (see Indicators 3.2.3-3.2.8, 3.3.3-3.3.6, 3.4.1, 3.4.3, 3.4.4, 3.7.1-3.7.4)
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employee representation (see Indicator 3.1.3)
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loans and advances (see Indicator 3.2.9)
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remediation (see Indicators 3.2.2, 3.3.2)
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anti-discrimination (see Criterion 3.4)
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training (see Indicators 3.1.4, 3.5.5)
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freedom of association and collective bargaining (see Criterion 3.6)
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transparent contracts (see Criterion 3.7)
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fair wages (see Indicators 3.8.1, 3.8.4, 3.8.5, 3.8.6)
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working hours (see Criterion 3.9)
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performance and workplace conduct (see Criterion 3.10)
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employee accommodation (see Criterion 3.11)
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grievance mechanisms (see Criterion 3.12)
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community relations and Indigenous rights (see Criterion 3.13).
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Evidence of Implementation
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human rights policy
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evidence that senior management have signed it off
Auditors Should Confirm
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that the human rights policy is in place, approved by a member of senior management;
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where the policy is communicated and available publicly;
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whether the policy is available to all relevant stakeholders;
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that the human rights policy is consistent with other company policies and procedures.
Useful Resources
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Some examples of human rights policies can be found here.
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United Nations (2011), Guiding Principles on Business and Human Rights. Available at: <https://www.ohchr.org/sites/default/files/documents/publications/guidingprinciplesbusinesshr_en.pdf>
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ILO (2022), ILO Declaration on Fundamental Principles and Rights at Work and its Follow-up. Available at: wcms_716594.pdf (ilo.org)
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International Bill of Human Rights, A Brief History and the two International Covenants. Available at: International Bill of Human Rights | OHCHR
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United Nations Global Compact (2015), A Guide for Business: How to Develop a Human Rights Policy. Available at: How to Develop a Human Rights Policy 20151013.indd (ohchr.org)
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OECD (2023), OECD Guidelines for Multinational Enterprises on Responsible Business Conduct. Available at: <https://www.oecd-ilibrary.org/docserver/81f92357-en.pdf?expires=1729687419&id=id&accname=guest&checksum=62CA2A98BB5F19532709D450D88B4404>
Indicator 2.12.6
Requirement
The UoC shall annually report to ASC the feed properties, feed use and calculated feed efficiency values per site, according to ASC data submission procedures. !A group of people standing next to each other Description automatically generated!
Indicator 2.12.5
Requirement
The UoC shall adhere to the species-specific limits on feed efficiency, according to Appendix 2 (2.2).
How Do I Interpret This Requirement?
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To facilitate compliance with the feed efficiency requirements the UoC should consider:
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Using feed formulations:
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With a high percentage of marine by-products and trimmings.
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That includes alternatives to fishmeal/fish oil.
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Implementing on-site feed management measures, for example:
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The use of:
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Feed trays.
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Cameras.
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Pellet sensors.
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Staff training on the use of feed management measures.
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Verification process to confirm management measures are operational and continuously meet their intent, for example, documented records of visual feed response.
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Evidence of Implementation
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Records:
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Feed purchased (including % of whole fish ingredients, EPA and DHA).
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Feed fed.
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Feed efficiency calculations.
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Visual feed response.
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Staff training.
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Stocking biomass.
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Production (weight harvested).
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Auditors Should Confirm
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Feed efficiency metrics are met.
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Records:
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Feed purchased (including % of whole fish ingredients, EPA and DHA).
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Feed fed.
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Feed efficiency calculations.
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Visual feed response.
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Staff training.
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Stocking biomass.
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Production (weight harvested).
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Indicator 2.12.4
Requirement
The UoC shall not feed wet feedstuffs, moist pellets, or uncooked/ unprocessed marine raw materials.
How Do I Interpret This Requirement?
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Wet feedstuffs used as binders for probiotics and other feed additives in top-coating or top-dressing applications are allowed.
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Wet feedstuffs can be used as carbon sources for water quality control i.e., anaerobic fermentation or biofloc technology.
Evidence of Implementation
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Records:
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Feed purchased.
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Feed fed.
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Auditors Should Confirm
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Wet feedstuffs, moist pellets, or uncooked/ unprocessed fish are not used by the UoC by cross-checking records with observations and personnel interviews.
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Records:
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Feed purchased.
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Feed fed.
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Indicator 2.12.3
Requirement
The UoC shall not use feed containing protein derived from the same genus as the species being farmed. An exception applies where it can be demonstrated that same-species protein hydrolysates are verified to be <10,000 daltons, in which case use is allowed.
Evidence of Implementation
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Records:
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Feed purchased (including information on species/genus used as marine ingredients for fishmeal).
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Feed fed.
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Auditors Should Confirm
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Records:
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Feed purchased (including information on species/genus used as marine ingredients for fishmeal).
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Feed fed.
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Useful Resources
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Although the science behind prion diseases, infectivity and pathogenicity in fish in association with Transmissible Spongiform Encephalopathies (TSEs) is not very well developed, ASC has taken a precautionary approach and followed the guidelines of FAO (2011) Aquaculture Development. 5. Use of Wild Fish as Feed in Aquaculture Principle 9.1 “For biosecurity reasons, intraspecies recycling is an unacceptable practice that should be prohibited”.
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Protein hydrolysates verified to <10,000 daltons are allowed as controlling the molecular weight provides a good verification of the appropriateness of an applied transformation process. This is in line with Regulation (EU) 142/2011 regarding the use of animal by-products.
Indicator 2.12.2
Requirement
Indicator applicability: every UoC using seaweed as a direct feed source. The UoC shall only use seaweed from regulated sources.
How Do I Interpret This Requirement?
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Regulated source means that there are national/international laws, agreements or policies governing the harvesting or farming of seaweed and that these are complied with, or the seaweed is from a certification scheme which addresses the responsible management of seaweed, whether wild-harvested or farmed.
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Seaweed certified to the following standards meet this ASC requirement on regulated sources:
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Standards approved in the IFOAM Family of Standards Organic Standards
Evidence of Implementation
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Legislation which stipulates responsible harvesting or farming.
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Supplier harvesting or farming permits.
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Certification documentation.
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Records:
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Harvest.
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Transport to the UoC.
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Auditors Should Confirm
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Legislation which stipulates responsible harvesting or farming.
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Presence and validity of permits.
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Certification documentation.
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Records.
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Harvest.
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Transport to the UoC.
Indicator 2.12.1
Requirement
Indicator scope: every UoC using compound feed. The UoC shall only use ASC-conforming compound feed.
How Do I Interpret This Requirement?
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ASC-conforming compound feed is sourced from feed mills certified to the ASC Feed Standard.
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It includes feeds produced under the mass balance model, as well as feeds produced under the segregation model.
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This requirement does not apply to non-certifiable species (e.g., cleaner fish).
Evidence of Implementation
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Documented process to confirm feed is ASC-conforming that includes verification of (see Indicator 1.4.3):
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The feed mill certification against the ASC Feed Standard.
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The documentation that identifies:
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The feed as ASC-conforming.
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The feed production model applied (i.e., mass balance or segregation).
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In the case of segregated feed, a distinct feed name which is also listed on the schedule to the feed mill certificate.
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Whether the feed is traceable as ASC-conforming throughout all steps between the feed mill and site.
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Records:
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Feed purchased and type.
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Feed delivery notes – confirming traceability between feed mill and site.
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Feeding records.
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Auditors Should Confirm
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Documented process to confirm feed product is ASC-conforming that includes verification of (see Indicator 1.4.3):
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The feed mill certification against the ASC Feed Standard.
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The documentation identifies:
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The feed as ASC-conforming.
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The feed production model applied (i.e., mass balance or segregation).
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In the case of segregated feed, a distinct feed name which is also listed on the schedule to the feed mill certificate.
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Whether the feed is traceable as ASC-conforming throughout all steps between the feed mill and site.
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Records
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Feed purchased and type.
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Feed delivery notes – confirming traceability between feed mill and site.
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Feeding records.
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Indicator 2.11.20
Requirement
The UoC shall clean up waste from the receiving shoreline or land surrounding the site.
Evidence of Implementation
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Records of regular litter collection activities and the responsible disposal of any items recovered.
Auditors Should Confirm
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Regular litter collection activities have taken place.
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Alternatively, conduct a visual inspection to demonstrate low levels of waste are present on the receiving shoreline or land surrounding the site.
Useful Resources
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Global Ghost Gear Initiative (2021) Best Practice Framework for the Management of Aquaculture Gear. Prepared by Huntington, T. of Poseidon Aquatic Resources Management Ltd. for GGGI. 81 pp. plus appendices: GGGI_Best_Practice_Framework_for_the_Management_of_Aquaculture_Gear.pdf
