General Interpretation Guide Group Certification Standard
© Sustainable Agriculture Network
March 2013
Sustainable Agriculture Network (SAN): Fundación Interamericana de Investigación Tropical, Guatemala · Fundación Natura, Colombia · ICADE, Honduras · IMAFLORA, Brazil · Pronatura Sur, Mexico · Rainforest Alliance · SalvaNatura, El Salvador · Nature Conservation Foundation, India · Conservación y Desarrollo, Ecuador
Sustainable Agriculture Network
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TABLE OF CONTENTS
INTRODUCTION ____________________________________________________________________ The Sustainable Agriculture Network _________________________________________________ Function of SAN General Interpretation Guides _________________________________________ Objective and Scope of this Guide ___________________________________________________ Group Certification and Farm Certification ____________________________________________ When can a group apply for a Group Certification Audit? _________________________________ INTERPRETATION GUIDE _____________________________________________________________ Principle 1: Training ______________________________________________________________ Principle 2: Risk Assessment ________________________________________________________ Principle 3: Internal Management System _____________________________________________
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INTRODUCTION The Sustainable Agriculture Network Mission The Sustainable Agriculture Network promotes efficient agriculture, biodiversity conservation and sustainable community development by creating social and environmental standards. The Sustainable Agriculture Network (SAN) is a coalition of independent non-profit conservation organizations that promote the social and environmental sustainability of agricultural activities by developing standards. Standard and certification policy development and review is coordinated by the SAN secretariat based in San José, Costa Rica. Farms and group administrators that comply with SAN standards can apply to use the Rainforest Alliance Certified™ seal for products grown on their certified farms. For more information about the Sustainable Agriculture Network, visit our webpage: www.sanstandards.org.
Function of SAN General Interpretation Guides SAN General Interpretation Guides explain the sense of the SAN Standard criteria and apply them to particular situations. There are two types of interpretation guides: General: Primarily for guiding auditors to facilitate the audit; it is also a resource for technical assistance as well as for producers and group administrators on how to implement SAN standards on their farms. Local: Interprets selected criteria of the standard for local conditions and a specific crop. Local interpretation guidelines are developed by local working groups to consider and reflect best the local conditions in light of the SAN standard. A General Interpretation Guide contains the criteria’s objectives and indicators for correct interpretation of and compliance with the standard. It is also important for implementing good agricultural practices on farms and for providing more detailed orientation during audit processes. The General Interpretation Guide is NOT binding for certification processes. A Local Interpretation Guide is developed by local working groups in coordination with the SAN Secretariat. The meetings of these working groups are organized by the local SAN representative. This process ensures a balance of interests among the various stakeholders that may be affected by this guide. The SAN Secretariat coordinates writing of the interpretation guide drafts and approves its final version. This guide was developed with the participation of the SAN technical teams in Latin America, Asia and Africa, SAN’s Technical Operations Committee and SAN’s International Standards Committee.
Objective and Scope of this Guide
This guide provides additional information and interpretation for SAN accredited auditors that conduct group certification audits, based on the SAN Group Certification Standard, March 2011. However, the binding requirements for group administrators are defined in the SAN Group Certification Standard and the SAN Group Certification Policy. It is also useful for group administrators to implement the SAN Group Certification Standard and the Group Certification Policy within the scope of the internal management system, group members and their farms. We encourage the different users of the standard to read the general interpretation guides and act in accordance with them, as much as feasible. However, the reference documents on binding criteria for farm certification are defined in the SAN Group Certification Standard and the SAN Group Certification Policy.
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Group Certification and Farm Certification What is the Difference between Group Certification and Farm Certification? The fundamental concept of group certification schemes is based on two key qualities: RELIABILITY and DELEGATION. The group scheme is based on DELEGATING to an Administrator the responsibility of evaluating 100% of the members. For this reason, only a sample of the farms is evaluated. This responsibility may only be delegated if the internal management system is RELIABLE to ensure compliance with SAN Standard requirements. Therefore, within the SAN group certification framework, evaluation of compliance with the Sustainable Agriculture Standard by each group member farm, is the responsibility of the group administrator. The SAN external auditor does not review compliance with the Sustainable Agriculture Standard by each group member farm, but does evaluate the operation of the group administrator’s internal management system, based on the Group Certification Standard. In addition, the SAN external auditor visits a representative sample of group member farms to verify the information on the internal inspections by the group administrator to ensure compliance by these farms. During a group certification audit, the audit team: a) Evaluates the capacity of the group administrator to train, evaluate and manage the performance of the group members regarding the SAN Sustainable Agriculture Standard. b) Visits a representative sample of group members and their farms. This sample reflects the overall performance of all group members and member farms. This includes a representative sample of infrastructure, production lots and ecosystems; also interviews with a significant sample of workers, worker representatives, supervisors, management staff, residents of neighboring communities and local government authorities, if applicable. c) The SAN accredited auditor does not visit each member farm and group member, but at least a square root of the total number of member farms. In some cases, the size of the sample may increase up to 1.4 times the square root, provided this scenario proposed by the certification body is approved by the group administrator. d) Evaluates compliance of the group administrator with the SAN Group Certification Standard. In this case, only one certificate is issued to the group administrator with an updated reference list of the group members and the member farms in the certification scope. During a SAN farm certification audit, the SAN approved audit team audits each farm. For example, under the figure of a multi-site owner with several farms, but without an internal management system, the farm by farm audits apply. Due to the absence of a formal internal management system, a group audit is not justified. Compliance with the Sustainable Agriculture Standard is reviewed within the limits of each farm, visiting a representative sample of the infrastructure, production lots and ecosystems, as well as interviews with a significant sample of workers, worker representatives, supervisors, management staff, residents of neighboring communities and local government authorities, if applicable.
When can a group apply for a Group Certification Audit?
A minimum of two members is required for a group administrator to qualify for group certification. An organization with two or more farms may choose to apply for individual farm certification audits or a group certification audit. Within the context of group certification, a farm is defined as a legal unit of land. Farms of the same owner but with different management, are not considered to be a single farm.
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INTERPRETATION GUIDE Principle 1: Training The purpose of this principle is to provide a frame of reference for the group administrator’s training programs. Training includes group members as well as internal management system personnel; it is conducted in the local language and in accordance with the education and culture of the participants in the training program events. 1.1 The group administrator must implement a training program for its group members to comply with Sustainable Agriculture Network standards. The people actually doing the job must be those trained. To implement a training program for member farmers and other people who work on the farms and enable implementation of SAN Objective standards. Interpretation Guidance The program may have several levels: the group administrator trains people directly and in turn they can train others. Not all training events must necessarily be presented by first level trainers. The program covers training of new members, as well as continuous training or updating of affiliated members that participated previously in training events. The training program has clear objectives and thematic contents. The quality of the training program is measured from two angles: the group administrator and the members. 1.2 The group administrator must train its internal management system personnel to enable them to fulfill their roles. To provide the internal management system team (including internal inspectors, technical and administrative advisors) with the Objective knowledge of the SAN Standards and necessary skills to visit member farmers and monitor the facilities of the group administrator. Interpretation Guidance The main training topics are the contents of the ten principles of the Sustainable Agriculture Standard, applicable contents of the Group Certification Standard, rules of the applicable Certification Policies, as well as internal requirements of the group administrator. The group administrator selects the most appropriate method to achieve this objective. 1.3 The group administrator must document the following elements of its trainings: date and location, summary of contents, name and qualification of the trainer, and names and signatures of the participants. To provide written support to demonstrate conducted training events to the external auditor, and to have documentation to analyze the Objective success of the training program. Interpretation Guidance SAN has no minimum requirements for the group administrator’s internal management system trainers, but compliance with the objectives of the training program must be guaranteed. An external auditor may identify insufficient competency of a trainer in a specific topic, for example, pesticide management. Records should include, at minimum, the elements mentioned in this criterion. There may be physical or electronic records.
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Sustainable Agriculture Network 1.4 Trainings must be conducted in participants’ local languages or dialects, at educational levels and with cultural characteristics enabling successful communication. To achieve the objectives of the training events, by conducting those in the language and with the methodologies appropriate to the Objective culture of participating farmers. Interpretation Guidance Each group administrator schedules trainings in accordance with the characteristics and needs of the participants. Effective training methods are used for each group that consider educational levels and local cultural characteristics. The trainings are conducted in the languages or dialects of the participants.
Principle 2: Risk Assessment The purpose of this principle is to reduce the risk of non-compliance with the SAN standards and ensure the traceability of Rainforest Alliance Certified™ products. It provides a tool for the group administrator to assess internal and external risks, through analysis, planning and implementation of corrective actions. This enables the maintenance of a good internal management system and traceability of certified products. 2.1
The group administrator must create an annual risk identification and assessment for compliance with Sustainable Agriculture Network standards aiming for continuous improvement considering no less than internal inspections, external audits, new group members, farm production, chain-of-custody, compliance costs and performance of the internal management system. To establish, via the group administrator, a risk evaluation system that will enable taking preventive and/or corrective and/or mitigation Objective actions to improve the performance of the entire group. This evaluation is based on the analysis of information about trainings, internal inspections, external audits, traceability system evaluation and change of membership, among other pieces of information. Interpretation Guidance A written document exists to demonstrate that an analysis meeting was held at internal management system level. Depending on the complexity and the performance, it may be a one-page meeting record or a more complex document. The mentioned documents are the basis for the evaluation, are analyzed and related in order to take preventive and/or corrective and/or mitigation actions; preferably, the technical team participates in this analysis. This analysis focuses on the most important aspects: an analysis of the findings of internal inspections and external audits (both frequent findings as well as anything that, if not addressed, may result in critical non-conformities), challenges caused by the acceptance of new members into the group, changes in the production systems or higher costs of the system, in general. The specific details may be addressed once the main aspects are covered. In addition, planning of internal inspections, changes in group administration, entry of additional members with larger volume and consequent risk to traceability, may be covered. 2.2
The group administrator must implement measures to prevent or minimize risks identified in the assessment.
Objective
To implement corrective actions based on the risk evaluation under criterion 2.1.
Interpretation Guidance These measures are based on the results of the risk evaluation explained for criterion 2.1. Without a risk evaluation, there can be no corrective actions. The external auditor evaluates whether all risks are covered with the corrective measures, as well as the implementation level of these actions, for example: Are the measures only defined or also implemented in all cases? Are there sufficient human and financial resources to implement the measures? SAN-G-21-1
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Sustainable Agriculture Network 2.3 Critical Criterion. The group must have a system for avoiding the mixing of certified products with non-certified products in its facilities, including harvesting, handling, processing and packaging of products, as well as transportation. All transactions involving certified products must be recorded. Products leaving the group as certified must be identified and accompanied with the relevant documentation. a. The group administrator must establish procedures to ensure that non-certified production is not brought into the group’s certified production. b. Group members must not individually sell their products as certified, however their product can be segregated as a certified product for sale by the group administrator. To ensure the integrity of the product by avoiding mixing of certified product, registering the transactions and accompanying the product Objective with the relevant documentation. Interpretation Guidance A system exists that prevents mixing of products, with special emphasis on procedures to control critical points for the integrity of the product. All certified product purchase and sale transactions have a record, whether digital or printed. All product leaving the certified group is visually identified and is accompanied by the supporting documentation showing date, type and volume of product and name of the certified group. Sub-paragraph b: When a member farm wishes to sell its certified product separately, a written agreement is established with the group administrator and segregation of said product is guaranteed. The commercial transaction is conducted through the group administrator. If a group administrator processes, packages, stores, manipulates or sells certified products together with non-certified products, the Certification Body is notified and a Chain of Custody audit is conducted. This critical criterion 2.3 may be scored as a regular criterion in the following case (see sub-paragraph 4.3.c of the Group Certification Policy): - Products that are not commercialized as Rainforest Alliance Certified™ don’t need to be segregated by the group administrator. However, control of the respective product volumes must exist. This Criterion 2.3 is replaced by a Chain of Custody audit only if the group also sells or manipulates non-certified product.
Principle 3: Internal Management System The purpose of this principle is to establish the necessary elements that comprise a good group administration system, including definition of responsibilities, conflict of interest management, internal inspections, sanction system and necessary documentation. The management system ensures annual tracking of compliance by the members with the rules of the group administrator. 3.1
Critical Criterion. The group administrator must implement an effective internal management system, including the following: a. Organizational chart with details of committees, positions and job responsibilities, including those serving; b. Responsibilities, required qualifications and competencies of personnel, elected persons, and committees; c. Governance procedures for: i. Approval of new group members and annual status of each member farm; ii. Group and group member record keeping requirements; iii. Internal inspections; and iv. Sanctions and appeals. Objective To guarantee that the main elements of the internal management system are implemented and documented.
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Sustainable Agriculture Network Interpretation Guidance This first criterion provides a reference framework for the general documentation required for an internal management system. The external auditor focuses on evaluating compliance with this criterion at documentation level, since the following criteria of this principle provide more detailed requirements on how internal inspections, sanctions and records occur. For sub-paragraph b., external implementers are included. 3.2
Critical Criterion. Each group member must sign or mark an agreement with the group administrator. Each group member must be informed of their right to resign. The group administrator must assure that each group member understands the agreements’ contents including group members’ duties to: a. Comply with Sustainable Agriculture Network standards and group administrator’s internal requirements; b. Provide the group administrator with required information; c. Cooperate with internal inspections and external audits; d. Report their intentional and unintentional non-compliances with Sustainable Agriculture Network standards and group administrator’s internal requirements. To ensure that the group administrator informs the group members about their obligations and rights and that there is support for these Objective agreements, signed by both parties. Interpretation Guidance The most important elements are the existence of an agreement signed or marked by the group members and that each group member understands the contents of the agreement and their right to withdraw from the group. The farmers understand, accept and commit to respecting these agreements. The external auditor does not audit how sub-paragraphs a, b, c and d are implemented, but only makes sure that the producers understand the contents of the agreement that each one signed or marked. The copies of the agreements may be stored in the office only. It is not necessary for each farmer to have a copy. It may also be a general agreement for all farmers with an attached list of names and signatures. For the case in sub-paragraph c., compliance is not audited, but rather if the member was informed of this concept. 3.3
The Internal Management System personnel and procedures must be resourced with competent personnel and sufficient finances, and must reflect the group members’ characteristics and composition, including its geographical and cultivation diversities. To guarantee that the group administrator establishes a management system, with procedures and personnel, that reflects the Objective complexity of the group (geographic, climate, cultural and composition characteristics). Interpretation Guidance Guidance questions: Are there enough internal inspectors to conduct visits that guide compliance with the SAN standards? Do the technicians that visit the group members speak the different dialects and do they know the challenges of the different crops? It is important to consider this topic in the risk evaluation process of criterion 2.1. 3.4
The group administration must manage conflicts of interest with impartiality and independence, including decision makers’ absence of their own actual or potential conflicts of interest. Objective To prevent that important issues of managing a group of certified producers are influenced by conflicts of interest. Interpretation Guidance
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The focus of this criterion is potential large conflicts, such as decisions on the acceptance or exclusion of members and controls of product volume, at the different level of the internal management system. Instead, technical assistance and internal inspection processes are not necessarily mutually exclusive. The agricultural extensionist that conducts technical visits to the member farms may also conduct internal inspections in the same visit. The technical assistance and the process of internal inspections conducted by the same person does not represent a conflict of interest. However, it is not the most appropriate practice due to possible bias in the inspection, and therefore it is better to avoid it.
3.5
Critical Criterion. Prior to an external audit, the group administration must internally inspect all group member farms. They must be internally inspected no less than annually, preferably at different times of the year. New group member farms must be internally inspected before being included in the group subject to certification. To highlight the importance of internal inspections as one of the main tools to monitor performance of members and their farms, Objective regarding compliance with Sustainable Agriculture Network standards. Interpretation Guidance The criterion summarizes the three main situations the group administrator covers regarding internal inspections: a) as a condition to accept new members, b) as a condition to apply for a group certification audit, and c) with a minimum frequency of 12 months in the future. The 12 month frequency is calculated from the first internal inspection. There may be different modes in internal inspections. Farms do not always have to be visited. Depending on the findings of previous internal inspections or external audits and the scoring history of the farmer, meetings with the farmers can be convened to discuss pending issues. It is only during the first year that it is necessary to review the entire checklist based on the applicable criteria of the Sustainable Agriculture Standard. Subsequent internal inspections emphasize the review of the most common corrective actions and the priority issues, which can receive feedback from the risk evaluation (see Principle 2). In order to measure the effectiveness of internal inspections, in addition to interviewing the farmers, the external auditor may cross-reference the information of internal inspections and external audits. If there are very large differences between them, this may serve as the basis for increasing the sample size in subsequent audits. 3.6
The Internal Management System must have policies and procedures for sanctioning individual group members for non- compliance with Sustainable Agriculture Network standards or internal group administrator requirements. a. Progressive sanctioning measures must be established, concluding with the exclusion from sales of certified products; b. Each group member must be informed of the sanctioning system; c. Records must allow for the easy identification of sanctioned group members; d. Each group member must have the right to appeal findings of non-compliance and its resulting sanctions. Objective To establish the elements that comprise a sanction system.
Interpretation Guidance It is important to have a clear, fair and non-discriminatory sanction system known by all, as a key element to delegate evaluation of the farms to an administrator. A well-defined sanction system allows members to know the causes for sanctions and their consequences. The administration staff knows the sanctions, knows when to apply them and relevant established procedures. There is a record of the sanctions applied, the causes that justified them and the follow-up for resolution. Sub-paragraph a. represents the maximum sanction, equal to, for example, exclusion of a member.
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Upon group member’s request, the group administrator must facilitate a group member’s ability to create records.
Objective
To establish a supporting system for farmers to keep the farm’s documentation, when needed.
Interpretation Guidance It is important for the group administrator to define what records must be filed and kept at farm level. The assistance to keep the farm’s documentation applies to small farmers with illiteracy problems, but not to plantations with qualified technical personnel. 3.8 The group administrator’s documents must be consistent with group members’ language and level of understanding. To establish the guidelines for the group administrator to find the design and drafting of documents that is most appropriate to the Objective language and level of education of all its farmers. Interpretation Guidance This criterion refers to farm records and public information documents (like posters, instructions, etc.). It is important that the design includes record formats and templates that are useful for the farmers. 3.9 Critical Criterion. The group administrator must keep accurate group member records, including: a. A list of group members with their names, date of entry to the group, any assigned identification and certification status; b. Information on certified member farms with location, total area, total production area, annual production volume, farm maps or sketches indicating location of natural ecosystems; c. Regional maps or sketches of all the member farms’ locations, including access roads and main natural ecosystems; d. Volumes of certified products at the following stages: buying, handling, processing, packaging and selling; e. External audits and internal inspection reports, dates, and any complaints received; f. Prior non-compliances, including sanctions, follow-up actions and appeals. Objective To establish which are the documents to be handled by group administrators in their internal management systems. Interpretation Guidance The respective documents may be filed in the farm or in the main office, in digital or printed format. The list of group members is the official list presented by the certification body. Sub-paragraph d. applies to all certified farms in the group.
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