In the last few months, retailers in Belgium and Germany have recalled products due to the detection of antibiotics or have had shrimp batches from Vietnam and India rejected at European Union borders. The Aquaculture Stewardship Council (ASC) shrimp standard does not allow shrimp that has been treated with antibiotics to be sold as a certified product. However, the organization confirms that an ASC-certified product was among the items recalled. ShrimpTails has asked ASC’s head of program assurance, Mrs. Vân Roetert, to talk about the challenges of maintaining the integrity of the program in a complex supply chain.
ShrimpTails: Can you briefly introduce yourself?
Vân Roetert: The Netherlands has been my home for many years. However, I am originally from Vietnam, where I started my career in 1996 at the Directorate for Standards, Quality and Metrology (STAMEQ). I’ve been working in sustainability standards schemes in various sectors ever since, and eventually secured a role with ASC Standards team in 2014. At that time, my responsibilities included bringing the organization into compliance with the ISEAL Codes of Good Practice and developing our multisite and group certification methodologies, among other things. I was asked to lead the Program Assurance team in early 2017.
ShrimpTails: When did the ASC create the program assurance team and what is its purpose?
Vân Roetert: We have been doing this work all along. However, as we continue our rapid growth and transition out of the start-up phase, it was decided that a dedicated team should be charged with ensuring the program remains strong and, at the same time, gives stakeholders confidence that ASC Standards are effectively implemented and audited. To that end, Program Assurance was created in 2017.
Members of the team are based around the world to cover the global scope of the program and our responsibilities encompass many things. One of our aims is to continuously improve ASC certification and accreditation methodologies to add more value to stakeholders; we are constantly developing, implementing and improving tools and methodologies to deliver a meaningful program. We are also tasked with investigating violations of the ASC’s regulations and we train auditors to ensure all audits meet ASC’s intent and market demand.
ASC works closely with Accreditation Services International (ASI) to effectively and efficiently oversee the performance of accredited certification bodies and their auditors, and we also collaborate with the MSC, which runs the Chain of Custody (CoC) certification program, to ensure product integrity.
ShrimpTails: Is it correct that according to the ASC shrimp standard, ASC-certified shrimp must not contain antibiotics?
Vân Roetert: The ASC’s shrimp standard prohibits the use of the ASC logo on antibiotic-treated shrimp. However, the use of veterinary medicines approved for aquaculture by the relevant authorities in a country is permitted under the ASC standard for animal welfare reasons. In the event that an animal health expert determines that using antibiotics is unavoidable, a withdrawal period must be observed before the shrimp product is put back on the market to ensure that no trace of the antibiotic remains in the product. It is important to note that those antibiotics on the World Health Organization’s list of critically important antimicrobials for human medicine are not allowed on any ASC certified farm. The use of such antibiotics would result in suspension or withdrawal from the ASC program.
This restriction is in line with our goal of defining conditions that lead to responsible aquaculture production. Regarding the shrimp standard, this also includes protection for mangroves, use of more sustainable feed, biosecurity and habitat protection. ASC Standards also include social components that forbid child or forced labor. Farms in the program must treat employees fairly and ensure that community concerns are also addressed. We are an improvement-driven program dedicated to bringing positive change and ensuring transparency in both our own operations and for those engaged with us through ASC certification.
ShrimpTails: What actions are undertaken by ASC when a supplier is found to have exported ASC-certified shrimp containing antibiotics?
Vân Roetert: The ASC has guidelines and procedures in place to both investigate and remedy infractions. To assess a potential infraction and take appropriate actions, our team works closely with our appointed accreditation body, ASI; the MSC, the administrator of our CoC certification program; and the conformity assessment bodies (CABs) that perform farm audits, as well as on supply chain partners and other impacted partners.
One current example of the Program Assurance team in action is our investigation involving a mistake made by a Vietnamese company. This company had an ASC-certified shrimp farm and processing plants, all of which had CoC certification permitting them to process ASC-certified shrimp. This case was brought to our attention due to a market recall by a retailer. We immediately launched our own investigation, which resulted in the suspension of the license agreement, which allows the company to use the ASC logo. The suspension was effective immediately and prevented them from using the ASC logo on any product processed by the facilities. In addition, the certification body that performed the audit has also suspended the certificates of both the factories and the farm. This company is no longer allowed to sell their products as ASC-certified, nor can they use the ASC label on any of their products.
As the owner of the ASC certification scheme, our investigation included a range of activities and we took actions such as notifying the CAB – which carried out its own investigation as per the certification framework – the MSC and ASI of the incident. We mapped the supply chain to trace the product back to its origin and consulted with the retailer directly to better understand the circumstances that led to the recall decision. We also conducted lab tests for antibiotics and other substances on a similar shrimp product. We suspended the logo license agreement with the company, performed volume checks, trace-backs on several batches of shrimp to the farm of origin, and reconciliation checks. The final results of the investigation will be available on our website.
Investigations may vary depending on the case and they can be a lengthy process, but it is important that we are thorough to protect our partners and remedy the problem while reducing the likelihood of a similar breach in the future. In this particular case, the investigation has so far taken about two months and is still ongoing.
ShrimpTails: Is the ASC currently undertaking any activities to look into this issue of antibiotics from a more structural perspective?
Vân Roetert: Due to the complexities involved with independent, third-party certification schemes such as ours, we actively collaborate with multiple supply chain partners, agencies and governments to get to the bottom of any incident reported to us. While such infractions are rare, we take each seriously and employ multiple approaches and tools to tackle the issue on a country-specific basis to prevent reoccurrences. One of our more powerful prevention tools is to make certificates that have been suspended for non-conformance reasons for both farms and factories more prominent on our website’s Program Assurance page where we publish the names of farms or companies that are found to be responsible for creating damage to the reputation of the program and its partners by deviating from the ASC Standard. Transparency is foundational to ASC and, although we have always posted suspended certificates, they may have been difficult to find in the past.
Furthermore, we are raising awareness about issues of concern within our network, adding new training modules and working more closely with certificate holders to avoid additional problems. ASC is working to create tools that will help companies better manage the operations of farms supplying them with raw materials via contract farming. We are also working together with the MSC on a Key Data Elements project to make it possible to trace products back to each harvest batch on a particular farm. These are just a few of the initiatives being undertaken by ASC.
Our investigation procedures are thorough and allow us to find the problem at its source. However, just as we are dedicated to continually updating our farm standards, these improvements are part of our dedication to constantly revise and update our investigation procedures as necessary. While no standard is perfect, and no process can be absolutely foolproof, we believe the ASC is a stringent program. We intend to maintain the trust of the market by addressing relevant issues and rooting out violations wherever they occur.
ShrimpTails: Do you have any recommendations to buyers that raise concerns about the issue of antibiotics and ASC-certified products?
Vân Roetert: The supply chain works best when buyers and retailers establish mutually beneficial and long-term relationships with farmers and other suppliers. This builds trust and can provide a significant incentive to consistently operate in compliance with aquaculture best practices. We invite all stakeholders to check our website regularly for the latest information, including updates on sanctioned entities. Importantly, we also encourage anyone with concerns about the program or any ASC-certified product to contact us. We make it easy to reach us through the dedicated Program Assurance page on our website because we are committed to ensuring that farms and CoC certificate holders comply with the ASC standard. Anyone who contacts us can be confident their information will be kept strictly confidential.
Moving forward: A shared responsibility
It is clear from ShrimpTails’ interview with Mrs. Van Roetert that while independent, third-party certification provides a tool to mitigate the risk of antibiotics in the shrimp supply chain, no system can guarantee complete elimination of antibiotics; it is generally accepted that chains of custody are not always perfect. It is therefore crucial for buyers to look for suppliers that can prove that they have complied with a set of rigorous standards or use an integrated system with greater controls on input suppliers (feed and postlarvae). It is also clear that it is important for processors and exporters to have close connections to the independent farmers in their supply chains.
