ASC is strengthening its Variance Requests (VR) process with greater opportunity for stakeholders such as local communities and NGOs to contribute to decisions on local variances to ASC standards.
The new process for VRs to ASC standards, published today (October 29, 2020) and due to go live on 15 December 2020, also requires that decisions about requests involve a technical analysis.
Variance Requests are a vital part of any credible global certification programme. They provide the necessary means to adapt a global standard to specific local conditions without lowering requirements.
One of the most significant changes to the process is the inclusion of stakeholder consultation – including proactively notifying relevant stakeholders of a VR so they can provide feedback based on their relevant knowledge or experience. This addition was itself based on stakeholder feedback which ASC sought as it developed the new process, and it means that NGOs or local community groups can have their say on any proposed variances to the standard.
Requests are made by Conformity Assessment Bodies (CABs), the independent bodies that carry out audits against the ASC standards. CABs are now encouraged to familiarise themselves with the new process, along with a new process for variance requests made to ASC’s Certification and Accreditation Requirements (CAR), before both go live on December 15, and additional guidance documents and training from ASC will help them with this.
Javier Unibazo, ASC Head of Standards said: “Variance Requests play an important part in any credible global certification programme, so it’s only right that they are based on technical analysis and meaningful stakeholder consultation.
“ASC has always taken Variance Requests seriously, but this update provides a checklist and process that is consistent, efficient, and most of all maintains the very high requirements of the ASC standards.
“The policy itself has also been shaped by feedback we received from stakeholders ranging from NGOs to auditors, based on their experience of the variance request process, as part of multiple rounds of public consultation. It’s easy to ask for feedback but at ASC we will always take it into account when making decisions or updating the programme.”
The new process for VRs to ASC standards allows variances to be requested in a way that is consistent, inclusive, and requires that all decisions are the result of a technical analysis. This analysis will be carried out taking into account stakeholder input, and will be presented to the VR Committee, made up of independent members of the ASC’s Technical Advisory Group with additional independent oversight. The addition to the process of strict and defined timelines should also improve the process for CABs and ensure decisions that are timely as well as evidence-based.
In line with ASC’s commitment to transparency, all decisions and the reasoning and analysis behind them will be published, along with all evidence and feedback submitted in the process. These decisions, published in a consistent way, will also make clear if or how variances might be applicable to other situations, improving consistency in future requests.
Stakeholders can also now contact ASC at any time about variance requests, which can be re-assessed by ASC if new evidence or information is provided which makes this necessary.
Varience Requests to Certification and Accreditation Requirements (CAR)
Also published today is a separate new policy for variance requests made to the ASC’s CAR. Whereas ASC standards set out the requirements that must be met by farms to be certified, the CAR is a document that sets out requirements for the independent Conformity Assessment Bodies. It provides requirements on how standards should be applied, and ensures that all CABs operate in a consistent manner.
Just as with the ASC standards, the CAR is applied in widely varying circumstances all over the world and as a result sometimes variances will be required, but as a different document the updated process for variance requests to the CAR is slightly different.
Unlike variance requests to the ASC standards, requests to the CAR are not science-based and less likely to require detailed technical reviews, and as they are limited in scope to the operation of CABs the number of relevant stakeholders is much smaller. For these reasons, VRs to the CAR will not require the same stakeholder consultation, but all requests must be approved by the independent VR Committee and made public on the ASC website. Importantly, such requests cannot relate to the compliance of an aspect of one of the ASC standards, which much go through the ASC Standards VR process.
Required by All Credible Certification Schemes
Variance Requests are so important to the effective running of a global certification programme that they are required of all members of ISEAL – the member organisation for the world’s most credible certification schemes. Importantly, they do not allow farms or auditors to weaken standards, but are intended to allow the ASC’s robust requirements to be applied in diverse situations, which cannot all be prescribed in one global standard.
Training will be provided for CABs, and a flowchart has also been produced to clearly show the new processes one step at a time. The documents have been published six weeks before the new process goes live on December 15, to allows CABs enough time to familiarise themselves with it.
The new processes can be downloaded from the Programme Assurance Team page on the ASC website, or using the direct download links below.