Kapitel 2: Mindestkriterien
Topic: Assurance SystemC.1.06 - Assessment reports availability
new MiK
Art.43
CRITERIA QUESTION
Does the scheme owner make, or require assurance providers to make, summary of certification/verification reports (with personal and commercially sensitive information removed) available?
RESPONSE OPTIONS
Accepted: Yes (on request) / Yes, publicly
Not accepted: No
REQUIREMENTS
- The scheme owner defines this requirement in certification requirements/methodologies, or in the contract/agreement between the scheme owner and the assurance provider, or in a separate accreditation manual. The report should be made available in a UN and local language.
- For schemes where assessment reports are not publicly available online, request a summary reports from assurance providers to verify availability
- If assessment reports cannot be shared by the scheme or by assurance providers due to confidentiality, chose "no, confidential"
- If no assessment reports are written at all, choose "no, no reports"
GUIDANCE
Note: For ISO Type I labelling programmes, the equivalent requirement is transparency on (nonconfidential) "evidence on which the awarding of the label is based" (see ISO 14024 clause 5.11).
Art. 43: These criteria are particularly relevant for (sustainable) public procurement and are based on the EU Procurement Directive 2014/24/EU (Art. 43, para. 1). For this reason, content-related feedback on criteria marked with this keyword can only be considered to a very limited extent.
Christina Endemann, FSC
We welcome this criteria when it comes to the primary sector. We fully support the idea of requiring UN and local language. This will increase accessibility enormously.
We recommend though to restrict this criterion to the primary sector as the amount of information to be published when including the supply chain is immense.
Experience shows that it can be difficult to impossible to actually receive reports that have to be requested by the Assurance provider. We strongly suggest removing the option to make audit reports accessible upon request, but that only the only accepted response it “Yes, publicly”.
Reports can be redacted to solve confidentiality issues, therefore claiming confidentiality should not be accepted. It could be used as an easy way out.
WalterSchmidt
If the response options are opened up to "no, confidential" this MIK looses its teeth, since it is then always possible to avoid sharing the reports or report summaries by claiming confidentiality issues.
I think therefore that it is meant, that "no, confidential" still means the non-compliance with this criteria. But then it would be good to make this more explicit in the "response options" section by saying:
Accepted: Yes (on request) / Yes, publicly
Not accepted: No / No, confidential / No, no report
I think, too, that if there are no reports at all, it is difficult to assume how the compliance with mandatory criteria have been checked in any form of assessment. Hence, I would list "No, no report" also under the "Not accepted: No" response.
NICLASRYDELL
There is a BIG difference if assessment reports are not written at all or if they are written but not available publically.
I believe it must be a requirement that compliance with all mandatory criteria can be proved by an assessment report even if it is a confidential report.
Summary reports of several certified products are also useful but not mandatory in my opinion.
SebMue_AbTF
Though an Art 43. criteria we would like to point out that option ‘no, confidential’ and “no, no reports” as mentioned in requirements is not listed as response options. Response options “no, confidential” should be listed as accepted, as far as reports are available to scheme owner, and accordingly the scheme owner can take actions according the report findings. This would align with the requirement to request for summary reports from assurance provides. In some cases, reports might be confidential but are shared with and accessible by the scheme owner (see also C.1.17 schemes owners gathering information from audit/assessment reports) who might produce summary reports. Accordingly the requirement clause should be adopted and include the opportunity to request a summary report from the scheme owner as well, accordingly it should read: For schemes where assessment reports are not publicly available online, request a summary report from assurance provider or scheme owners to verify availability.
OEKOTEX(R)
We agree with this comment. The other option should be added.