FIA PNG Participating Company Compliance:
Internal Audit Report
For Audit Taking Place in July 2021 Relating to Marine litter and Fishing gear requirements & procedure v4.0
December 2021
1. Introduction
As part of our commitment to improving the sustainability of the Papua New Guinea tuna fisheries, Fishing Industry Association (FIA) PNG participating companies (PC) agree to carry out audits annually on their conformance with the Responsible Sourcing Policy (RSP) pillars measures.
FIA PNG office, FIA PNG members internal auditors, and the FIA PNG Sustainability Director review audit protocols and coordinate audits on-site, after the management system implementation, training, and awareness. Participating companies were audited based on the FIA PNG Marine litter and Fishing gear policy v5.0, and procedure v4.0 in effect during the audit period.
To support tuna stock and tuna ecosystem sustainability, FIA PNG Participating Companies have committed to meet RSP measures designed to improve the long-term health of tuna fisheries that includes sustainability, Marine litter & Fishing gear, Traceability, and Social Responsibility, and human rights at Sea.
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This document describes the protocol for the auditing of fishing companies’ compliance with those RSP measures in effect for Q2 of 2021.
Per the FIA PNG MoA in place, Participating Member Companies are obliged to respond fully, accurately, and promptly to all reasonable requests made during the audits. Participating Member Companies shall provide appropriate supporting documents, verifiable evidence, data, photos, or other support. Appropriate confidentiality obligations will be established and observed by FIA PNG Office staff. The FIA PNG Sustainability Director will provide a Final Audit Summary report and data analysis to the FIA PNG Chairman and hold a one-by-one meeting with Participating Companies to evaluate results and documentation support.
The FIA PNG office will publish the compliance status report on the FIA PNG website after a peer review of the results with each PC, and all the requirements of the Compliance RSP Policy have been dully and fully satisfied.
2. Participating Companies Compliance
PCs commit to undergoing internal audits against all the in-effect RSP pillars’ measures. The pillars are:
Marine litter and Fishing gear mitigation
Social Responsibility and Human Rights at Sea
Traceability
Sustainability of tuna stocks – MSC certification
Each pillar is supported by a procedure and audit tool, in the case of the MSC certification we will undergo a third-party surveillance audit each year. Procedure contains the lists of the conservation measures in effect for Q2 of 2021 through Q4 of 2022 to be audited under this protocol, guides the required action and/or information and describes the means of verification that will be used to assess conformance.
The FIA PNG member internal audits will generally follow the principles of ISO 19011:2018. The FIA PNG member internal auditor ensures audits are compliant and consistent with the in-effect RSP conservation measures.
In advance of the annual audit, company details including contact information for the designated contact person will be confirmed with each company. The annual audit will describe the following information.
Scope:
RSP Pillar/ Standard/ Policy/ Requirement:
Auditor team:
Date:
Place:
3. Summary of FIA PNG Internal Audit Outcomes – Marine litter and Fishing gear Q2 - 2021
The Marine litter and Fishing gear requirements & procedure v4.0, contains 7 principles, and 41 questions to assess KPI per fishing company. This is a summary per principle.
3.1 Internal audit
After fully development, design, training & awareness, and implementation of the FIA PNG ML&FG, the FIA office requests FIA PNG fishing company members to carry out an Internal audit from March to July 2021 based on the FIA PNG Marine litter and Fishing gear procedure and using the audit tool that captures KDE to assess the level of progress of each fishing company member against this comprehensive set of best practices.
It was necessary to remark that every answer shall be supported by verifiable evidence that may include photos, procedures, codes of documents to consider a robust answer.
In this specific case interviews have not been carried out initially, but FIA PNG office internal auditor team will follow up later in 2022 to bring awareness among fishing company management but also on Crew members on board fishing vessels
Seven (7) fishing companies provided the internal audit report and results that include a fleet of 41 tuna purse seiners. It is important to clarify that this internal audit was carried out at the fishing company central office and in 1 fishing vessel on-board (PNG ports) at this stage.
Graph # 1 Internal audit performance per company per principle of Marine litter and Fishing gear v4.0
*In this way or example how each FIA PNG participating company was assessed per KPI
Principle # 1 Management System Mechanism
At the initial internal audit, members seem to have a good level of implementation of their management system that includes Marine litter and Fishing gear. Besides the FIA PNG Marine litter and Fishing gear procedure, members have in place several MARPOL procedures also including waste and garbage procedures, control sheets, recording of waste disposal.
At the time of the internal audit, some members still have not formally appointed a responsible person to look after these issues. While other members even have included it in an Environmental policy and responsible person.
Principle # 2 Voluntary Schemes
Members using Fishing Aggregating devices are highly following PNG FAD management plan; each drifting FAD or anchored FAD shall be marked, monitored, reported, controlled, and recorded on the e-logbook. Also, FIA PNG members are using partial or fully biodegradable material for the construction of FADs (cotton ropes and canvas, manila hemp, sisal, coconut fiber) so that they degrade without causing harm to the environment and negatively impacting ecosystem(ISSF, GTA, Tuna NGO practices).
We see the need to set up scientific research to assess the impact of FADs in the PNG EEZ and PNG AW. One company member is in the Testing phase for improving under the ISSF best practices for biodegradable FADs.
Several tuna purse seiners are not using FADs (drifting and anchored) for the FIA PNG MSC trip, therefore there are several requirements in the second principle that are not applicable for that fishing operation. Friend of the Sea is also auditing these requirements to FIA PNG members in FOS audits.
Principle # 3 Best Practice framework for the management of fishing gear (based on GGGI practices) – Onboard
Electronic buoys are attached to FADs for electronic tracking and easily recover fish of FADs. Also, FAD location and last position in case FADs are lost, always is reported to the PNG authority.
Only one company is still not marking fishing gear (FADs) because they rely fully on the buoy. The rest of the fleet members are marking fishing gear following FAO guidance and GGGI best practices.
Members have a procedure in place to recycle and reuse fishing gear components when they cannot be used anymore in a fishing operation.
Principle # 4 Best Practice framework for the management of fishing gear (based on GGGI practices) – at Landing sites or the Port
As required by MARPOL Annex V, IMOs signatory states should provide adequate facilities (national and local government officials), also regional administrators, commercial interests, and local waste disposal infrastructure managers to develop landside waste disposal strategies, including waste segregation, that encourage reduction, reuse, and recycling of ship-generated wastes landed ashore at PRFs” (IMO, 2009). (Development of agreements with both local gear manufacturers and recycling businesses to maximize opportunities for the cost-effective and environmentally responsible disposal of landed waste.)
These requirements request local government support for handling fishing gear and marine litter. FIA PNG members have set up their facilities, therefore the performance of this indicator is very high among FIA PNG fishing companies’ members.
FIA PNG tuna fleet has in place a disposal procedure where is recorded the following information:
Fishing vessel name, the date on Port, assorted garbage (tin, can, plastic, ashes, used cooking oil, damaged fishing gear, papers/ cartoon, used rags among others)
When the FIA PNG member has their privately owned wharf and facilities to comply with these requirements, the score is 100%
Principle # 5 Marine litter management onboard
In general, there is a lack of a contingency plan to reduce the risk of loss of gear by a fishing company, however, there is a high performance and scoring for garbage management, separation, and treatment onboard. It is important to remark that until now there has not been any event that requires the application of a contingency plan (i.e. oil spill).
FIA PNG members have been applying MARPOL regulations for decades reducing the impact of any type of garbage including Single Used Plastic (SuP) and synthetic garbage. It would need an improvement on the SuP awareness and reduction in some FIA PNG fishing vessels’ members.
Principle # 6 Verification of fishing company process
In addition to the internal audit’s scope items included in this ML&FG evaluation, FIA PNG fishing companies’ members undergo an annual inspection for authorities looking at MARPOL regulations. This combination of authority inspections and Marine litter & Fishing gear internal audits provide a robust due diligence system to track failures and improve the management of Marine litter and Fishing gear in an FIA PNG fishing company.
Principle # 7 Training & Awareness
Nevertheless, there is a high-performance score about awareness and training, it is important to clarify that this FIA PNG ML& FG due diligence process started with one fishing vessel per company, and it would take time to complete the full awareness and training of the entire FIA PNG tuna fleet and more than 1600 Crew members working onboard about this topic, therefore is a work in progress.
Graph # 2: Performance of all FIA PNG Participating Companies in Internal Audits Q2 – 2021 Marine litter & Fishing gear mitigation
*Series = FIA PNG companies audited (6 fishing companies - series)
Accountability and reporting of Marine litter and Fishing gear
Participating Member Companies have a good practice in place for monitoring, reporting and recording Marine litter and Fishing gear within a garbage management plan of disposal worksheet control at the Port, this has been recorded for decades and it is based on MARPOL guidance.
Among the items reported and recorded including weight (m3 or Kg) are: tins, cans, plastic, ashes, used cooking oil, damaged fishing gear, papers/ cartoon, domestic waste or food waste, used rags, used drums, among others.
The FIA PNG office is planning to carry out a desk review to see the impact of tuna purse seiners when it comes to ML&FG mitigation.
4. Audit Determination and Reporting
The auditing described in this document serves as an assessment of conformance by FIA PNG PCs. Any significant gaps in conformance and where corrective actions may be necessary will be specified by each FIA PNG PC. Timelines for remedial action will follow the FIA PNG RSP Policy v5.0. Depending on the nature of the non-conformance and the required corrective action, a follow-up audit may be required
4.1 Non-conformances
Conformance is categorized into grades (Conformance, Observation, Minor Non-Conformance, or Major Non-Conformance). Non-conformances must be raised against specific FIA PNG RSP pillars/conservation measures. The severity of the non-conformance – will determine which non-conformances are raised. The full definition of non-conformance, degree, consequences, and timelines can be found in the FIA PNG RSP policy v5.0.
4.2 Audit Reports
The I.A reports were sent directly to the FIA PNG office by the FIA PNG PC contact person via email. The FIA PNG office carried out data analysis and assessed the non-conformance as well as timelines for carrying out a follow-up audit to check the conformance of the FIA PNG pillars conservation measures. Meetings with each PC to evaluate the final results and the need for any clarification and/or more evidence were carried out. A Final Audit Report that summarizes the FIA PNG PC performance will be generated by the Sustainability Director for peer review and publication on the FIA PNG website.
FIA PNG fishing companies members have in place a corrective action plan and preventive measures plan for each finding or non-conformity.
5. Confidentiality and data security
Much of the information needed to confirm conformance with FIA PNG pillars conservation measures may be confidential to the PC being audited.
The FIA PNG office understands that the fishing and management operations they assess may include proprietary fishing strategies, locations, data, and business information and practices. All FIA PNG office staff, TDG, and TWG members have signed a non-disclosure agreement (NDA) in which they undertake not to discuss or communicate any confidential information to third parties, only when all involved parties agreed to do so. Data are not to be released, reproduced, distributed, or published without prior approval of FIA PNG involved members.
For questions please contact: Marcelo Hidalgo – Sustainability Director
Email: contact@seafoodmatter.eu
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