SCS Global Services Report Aquaculture Stewardship Council Salmon Standard Full Assessment Report Tassal Operations Pty Ltd Macquarie Harbour MF 266 Franklin Tassal Operations Level 9, 1 Franklin Wharf, Hobart 7000, Australia Client Contact: Heidi Hanson – [email protected] USING: ASC Salmon Standard V1.0 June 2012 AUDITORS: Dr. Christine Crawford, D.B. O’Sullivan, Todd Frank and Dr. Sabine Daume ONSITE DATES: 11-15th May 2015 REPORT RELEASED: 16th October 2015 Prepared by: SCS Global Services Sustainable Seafood Program NATURAL RESOURCE DIVISION SCS Global Services, 2000 Powell Street, Suite 600, Emeryville, California, 94608 USA +1.510.452.8000 main | +1.510.452.8001 fax| [email protected] www.SCSglobalServices.com Table of Contents Acronyms ....................................................................................................................................................... 2 1. Summary .............................................................................................................................................. 5 2. Historical Background of Farm and Farming Area ................................................................................ 6 3. Scope .................................................................................................................................................... 7 4. Audit Plan ............................................................................................................................................. 8 4.1 Previous Audits ..................................................................................................................................... 8 4.2 Names of the Auditors .......................................................................................................................... 8 4.3 Audit Plan as Implemented................................................................................................................. 10 4.4 Staff Interviews ................................................................................................................................... 10 4.5 Stakeholder Submissions .................................................................................................................... 11 5. Grading of Findings ............................................................................................................................ 12 6. Certification Determination – Pending ............................................................................................... 13 7. Evaluation Results .............................................................................................................................. 13 8. Determination of the Start of the Chain of Custody (CoC) ............................................................... 144 9. Non- Conformity Reports ................................................................................................................. 147 10. References ....................................................................................................................................... 153 Appendix 1. Stakeholder Comments Assessment Team Responses ........................................................... 156 1 Acronyms ABM Area Based Management ADAS Australian Diver Accreditation Scheme ADD Acoustic Deterrent Device AHD Acoustic Harassment Device AGD Amoebic Gill Disease AMA Area Management Agreement AMAMG Area Management Agreement Management Group AMBI AZTI Marine Biotic Index APC Australian Packaging Covenant APVMA Australian Pesticides and Veterinary Medicines Authority AS Atlantic salmon ASC Aquaculture Stewardship Council ASI Accreditation Services International ASX Australian Stock Exchange ATO Australian Taxation Office ATP-ase ATP-ase is an enzyme that is produced by the chloride cells in the gills when fish undergo smoltification AWU Australian Workers Union AZE Allowable Zone Effect BAP Best Aquaculture Practices BEMP Broadscale Environmental Monitoring Program BET Bigeye Tuna BMP Best Management Practices BOD Biochemical oxygen demand BQI Benthic Quality Index CAB Conformity Assessment Body CMF Compound Manufactured Feed CoC Chain of Custody CSIRO Commonwealth Scientific and Industrial Research Organisation DHI DHI Water and Environmental Consulting Company DNA Deoxyribonucleic Acids DO Dissolved Oxygen DPIPWE Department of Primary Industry, Parks, Water and Environment DTL Dive Team Leader EIS Environmental Impact Statement EMP Environmental Management Plan EPA Environmental Protection Authority EPBC Environment Protection and Biodiversity Conservation Act EPIRB Emergency Position Indicating Radio Beacon EPN Environmental Protection Notice EPO Eastern Pacific Ocean ERP Emergency Response Plan EUL Estimated Unexplained Loss FCR Food Conversion Rates FFDRo Fish Oil Forage Fish Dependency Ratio FFDRm Fishmeal Forage Fish Dependency Ratio FFEMP Fish Farm Environmental Management Plan FFL Fish Farm Licence (Freshwater Operations) 2 FHMP Fish Health Management Plan FHT Fish Health Team FIP Fisheries Improvement Project FL Franklin Lease FM Fish meal FO Fish oil FRDC Fisheries Research & Development Corporation FY Financial Year GG CFM GlobalGAP Compound Manufactured Feed standard or certification GHG Greenhouse Gas GMO Genetically Modified Organism GO Gordon Lease GPS Global Positioning System GWP Global Warming Potential HAC Huon Aquaculture, another member of AMA HO Head Office HoS Head of Sustainability IALA International Association of Marine Aids to Navigation and Lighthouse Authorities IFFO RS The International Fishmeal and Fish Oil Organisation - Responsible Supply IFS Inland Fisheries Service IMAS Institute of Marine & Antarctic Studies, University of Tasmania ISEAL International Social and Environmental Accreditation and Labeling Alliance ISO International Organization for Standardization ITI Infaunal Trophic Index IUCN International Union for Conservation of Nature IUU Illegal, Unregulated, and Unreported JSA Job Safety Analysis LCA Life Cycle Analysis/Assessment MAS Marine Aeromonad Disease of Salmonids MAST Marine & Safety Tasmania MDS Multidimensional scaling MF Marine Farm MFB Marine Farming Branch (DPIPWE) MFDP Marine Farm Development Plan MH Macquarie Harbour Region MHAMA Macquarie Harbour Area Management Agreement MiH Middle Harbour Lease MOP Marine Operations MSC Marine Stewardship Council MSDS Material Safety Data Sheet MUP Minor Use Permit NATA National Association of Testing Authorities NC Nonconformity NCR Non-conformance report, sometime NC Register NES National Employment Standard OH&S Occupational Health and Safety OIE World Organization for Animal Health OT Ocean Trout Onchorhynchus mykiss OTC Oxytetracycline PA Petuna Aquaculture PPE Personal Protective Equipment 3 QA Quality Assurance RAF Ridley Aqua Feed RCD Residue Current Device RM Regional Manager ROV Remotely Operated Vehicle RTRS Roundtable for Responsible Soy SAD Salmon Aquaculture Dialogue SAI Social Accountability International SARDI South Australian Research and Development Institute SCAT Southern Coastcare Association of Tasmania SCSG SCS Global, a certification body SDS Safety Data Sheets (new term for MSDS) SKA Skretting Australia SMFH Senior Manager, Fish Health SOP Standard Operating Procedure SPP Special Plumbing Permit SRAC Sustainability Report Advisory Committee SROI Social Return on Investment TAB Tasmanian aquabirnavirus TARFISH Tasmanian Association for Recreational Fishing Tassal Tassal Operations Pty Ltd, another member of AMA Tas-SR Tasmanian Salmonid Rickettsiosis TBM Toolbox Meeting TCT Tasmanian Conservation Trust TFDA Tasmania Fisheries Development Authority TIMS Tassal’s Integrated Management System TSGA Tasmanian Salmonid Growers Association TSHSP Tasmanian Salmonid Health Surveillance Program TSIC Tasmanian Seafood Industry Council TWG Technical Working group TWWHA Tasmanian Wilderness World Heritage Area USA United States of America VHF Very High Frequency WCC West Coast Council WDP Waste Disposal Plan WHS Work Health and Safety WHO World Health Organization WIP Wildlife Interaction Plan WPA Workplace Partnerships Agreement YC Year Class 4 1. Summary The Tassal Operations Pty Ltd.’s (Tassal) salmon culturing site within the scope of this full-assessment, MF 266 Franklin in Macquarie Harbour, demonstrates good overall compliance to the ASC salmon standard. The assessment team evaluated the operations against the ASC Salmon Standard v1.0 June 2012. Seven minor non-conformities (NCs) were identified during the full assessment. Overall, Tassal showed 93% compliance against the 152 compliance criteria of the ASC salmon standard v1.0. A proportion of these (17%) are in the not applicable (N/A) category. None of the non-conformities identified are graded as Major and therefore do not preclude award of certification. The client has provided SCS with a root cause analyses and an action plan to address the minor non-conformities (see Table 2). Progress against the action plan will be assessed at the first surveillance audit. The assessment team identified two minor non-conformities in Principle 2 (Conserve natural habitat, local biodiversity and ecosystem function), one pertaining to non-compliance with licence conditions because of significant visual impact at compliance sites showing presence of numerous opportunistic polychaetes on the sediment surface outside lease areas and extending into the Tasmanian Wilderness World Heritage Area, one related to average weekly dissolved oxygen levels and monitoring at reference sites. Two NCs were identified in Principle 7 (Be a good neighbour and conscientious citizen), the first one related to informing the community regarding antibiotics treatments, in particular that the community forum had not been notified of antibiotic use, and the second NC was raised because there was no policy for resolution of complaints by community stakeholders. Three non-conformities were identified in Principle 8 (Requirements for smolt suppliers); the first related to hatcheries with total phosphorus values greater than ASC standards at Russel Falls and no data from Saltas, the second was raised because no quarterly water quality monitoring of river outlets from SALTAS was conducted in February 2015, and the third is related to two biomonitoring reports for the Florentine hatchery in 2014 not being in compliance with ASC Salmon Standards for aquatic macroinvertebrates. Three recommendations were also made: 1. that a standard method of feed sampling and testing be used at each Tassal lease every quarter; 2. that results of the IMAS studies on low DO and 3. on polychaete ecology and abundance in Macquarie Harbour and the effects on benthic ecology in general be examined. Table 1. Summary of ASC criteria where a non-conformance was identified, the general aspect of the standard that the criteria relate to and the designation of whether the non-conformity was identified as a minor or major. Criterion Related to Rating 2.1.2 Visual impact near compliance sites, re. Licence conditions, Schedule 3. minor 2.2.1 d DO reading at lease site minor 7.1.3.c informing the public during therapeutic treatment periods minor 5 7.1.1d 7.1.2.a policy for the presentation, treatment and resolution of complaints by community minor stakeholders 8.3.2 Water Quality monitoring for the two rivers outlets minor 2. Historical Background of Farm and Farming Area The Tassal site assessed during this full-assessment, the MF 266 Franklin, is located in the Macquarie Harbour farming region – Strahan, Tasmania, Australia (Figure 1). The lease is located closest to the head of MH estuary and 1-5 km from the World Heritage Area. Tassal Group Ltd is an ASX 300 public company listed on the Australian Securities Exchange. Tassal is the largest salmon aquaculture company in Australia, employing over 900 people. A vertically integrated company, Tassal operates two salmon hatcheries, three processing facilities, two retail outlets and marine farms in six regions throughout the state. Tassal is producing salmon predominately for the Australian market, and has a retail presence in over 2,000 outlets around Australia. Tassal farms Atlantic salmon (Salmo salar) in open net cage farming systems that are polar circles with 120 m circumference, and maximum stocking densities of 15 kg/m3. Tassal holds BAP salmon certificates for the Macquarie Harbour farm sites as well as for their processing facilities in Dover. Marine farming of salmonids in Macquarie Harbour has been occurring for almost three decades. The Marine Farm Development Plan (MFDP) for Macquarie Harbour was approved in 1998 and production of salmonids grew to approximately 9,000 tonnes by 2011, when industry requested an increase in allowable production. Macquarie Harbor has advantages over SE Tasmania for salmonid production because AGD is not present, the water is generally cooler and there are fewer interactions with wildlife. The three salmonid producing companies in MH, Tassal, Huon Aquaculture and Petuna, together prepared an EIS for expansion which included detailed hydrodynamic and biogeochemical modelling. The Tasmanian Government approved an amendment to the MFDP in 2012 which permitted an increase in farming area from 564 ha to 926 ha and an increase in production to 29,440 tonnes, based on modelling of peak biomass and effects on the environment. It also included relocation of several leases and the establishment of one new zone. However, the modelling did not include effects on bottom waters. A monitoring program for water quality was established with interim trigger levels, initially determined by the commonwealth under the EPBC Act, and later accepted as statutory limits after a review of the environmental data that had been collected. An interim biomass limit of 52.5% of the modelled maximum sustainable biomass was also agreed to by the three companies as expansion occurred and environmental data necessary to the recalibration of models were collected. Compliance monitoring as part of annual licence agreements commenced in 2011. Each marine farm licence includes Schedule 3 with conditions relating to environmental management of a fish farm. Compliance conditions include visual impacts and indicators and limits for nutrients (ammonia, nitrate) and 6 dissolved oxygen concentrations. 11 sites around the harbor are monitored, including in the Tasmanian Wilderness World Heritage Area (TWWHA) and methods of monitoring and frequency of sampling are described in Schedule 3 BEMP (Broadscale Environmental Monitoring program) Macquarie Harbour in the MF licence. Annual video surveys required at each lease are also documented in the MF licence. Macquarie Harbour MF 266 Franklin A B Figure 1. Map A: Area that contains the site (MF 266) in Macquarie Harbour (indicated by black box), Tasmania, Australia. Map B: Close-up location of the lease site (266 Franklin). MH Franklin lease 266 is the newest of three Tassal farms in Macquarie Harbour. Tassal commenced farming at the site in January 2014. Macquarie Harbour is one of six farming region sites. The Franklin lease has 46 available pen bays and the maximum leasable area is 120 ha. 3. Scope Reference ASC Salmon Standard V1.0 June 2010 Audit Standard & Manual, ASC Salmon Standard V1.0 Guidance Scheme ASC Certification and Accreditation Requirements V1.0 Documents Audit Scope Single site, farm-level production (Atlantic salmon - Salmo salar) Macquarie Harbour region, Franklin Lease (MF 266) Receiving water Macquarie Harbour, Tasmania, Australia body 7 4. Audit Plan 4.1 Previous Audits Tassal Operations Pty Ltd (Tassal) Macquarie Harbour Sites Lease 214 Middle Harbour and Lease 219 Gordon received ASC certification (cluster certification1) on 4 April, 2014. Lease 266 Franklin, the subject of this report, was not audited at the time because it had not yet been stocked with fish. All aspects of the assessment process were carried out under the auspices of SCS Global Services (SCS), an ASC-accredited conformity assessment body (CAB), and in direct accordance with ASC requirements. 4.2 Audit Team Members The following auditors comprised the assessment team: Dr. Sabine Daume, Dr. Christine Crawford, D.B. O’Sullivan, and Todd Frank. Dr. Sabine Daume, SCS Global Services – MSC and ASC lead auditor Dr. Daume is responsible for leading SCS’s Sustainable Seafood Certification program in Australia, which includes aquaculture, and fishery certification under the auspices of both the Aquaculture Stewardship Council and the Marine Stewardship Council (MSC). She has been part of the global steering committee for the Abalone Dialogue to develop the Abalone standard for ASC and sits on the Technical Advisory Group for the Aquaculture Stewardship Council. Prior to joining SCS Dr. Daume worked as a Senior Research Scientist at the Research Division of the Department of Fisheries in Western Australia and at Deakin University in Victoria, Australia. Past research conducted by Dr. Daume has focused on invertebrate aquaculture and fisheries. She has led several nationally FRDC funded, multi-year research grants on abalone broodstock conditioning and improvements to hatchery and nursery production as well as fisheries enhancement. Dr. Daume is a certified lead auditor under the ISO 9001:2008 and SAI’s training for SA 8000 (social accountability) and trained to conduct ASC audits against the salmon and abalone standards. She has led numerous pre- and full- MSC assessments of various size and scale, including many fisheries in Australia. She also has experience working with diverse stakeholder groups, often in remote marine environments. Sabine has published in the peer-reviewed scientific literature (e.g. Aquaculture Research, Journal of Shellfish Research) as well as produced research reports and produced interactive training materials for the industry and led industry workshops. 1 A cluster under the ASC CAR v 1.0 is defined as a number of cages, pens or beds used for aquaculture production that meet one or more of the following criteria: 1 Are located within one (1) kilometre of each other. 2 Discharge into the same receiving water or into waters that demonstrate hydrographic connectivity. 3 Are maintained using the same equipment. 8 David Bruce “Dos” O’Sullivan, Dosaqua Pty Ltd – Technical Expert Dos O’Sullivan is a Director and Principal Consultant with Dosaqua Pty Ltd. He has been involved in information dissemination since 1986, not only through industry workshops and seminars but also as a lecturer at three universities and several TAFE colleges. His consulting specialties include project development and downstream management; industry status and potential; freshwater crayfish production; expert witness; environmental management / impact assessment; education, feasibility and risk analyses; industry liaison and extension; and independent analysis. With AusAID funds PSM established a 100- tonne/yr. marine finfish farm in Philippines in 1999. For 5 years he was non-technical director of a large (800 tpa) Barramundi farm located in NE USA which was listed on the Australian Stock Exchange, this company has also developed a 2,000 MT capacity barramundi sea pen farm and hatchery in Vietnam. Until 2012 Dos wrote annual reports on the status of aquaculture in Australia and he is recognised as the major commentator on industry issues and trends. He also has a major interest in promoting Aboriginal aquaculture and training; he is currently working with communities in Tasmania and South Australia. For the past four years Dos has been specializing in the establishment, implementation or improvement of Management Systems including effective Internal Audits and Management Reviews as well as training of auditors (RABQSA certified). In addition, he has been providing contract Third Party Certification for Environmental Systems (ISO 14001, EMAS, Ecomapping), Food Safety (ISO22000) & HACCP, Quality (ISO 9001) and OH&S (AS4801/OHSAS 18001), MSC Chain of Custody, GAA BAP (Hatcheries, Farms, Seafood Processing – GFSI standard) and Global GAP (Farms and Aquaculture). Dr. Christine Crawford – Technical Expert Dr. Christine Crawford has over thirty years’ experience in shellfish and finfish aquaculture, including hatchery and intertidal shellfish production, and effects of aquaculture on the environment, both in Australia and overseas. She is currently a Senior Research Fellow at the Institute for Marine and Antarctic Studies, University of Tasmania. Dr. Crawford has also lead research projects investigating the ecology and health and monitoring of estuaries, including environmental flows and links between changing climatic conditions and estuarine water quality. Dr. Crawford has worked for the Tasmanian government for many years. In recent years she has conducted ecological sustainability assessments for aquaculture operations in Australia and overseas for WWF. Dr. Crawford has published widely in the international peer-reviewed literature, including 38 papers, 6 book chapters, book co-editor and over a hundred reports to industry and government. Her work has also a diverse range of stakeholders, often in remote locations. Todd Frank – SCS Global Services Mr. Frank is the Director of SCS Southeast Asia and President Director of PT SCS Indonesia. Mr. Frank represents SCS at the regional level and provides daily oversight, management and business development for the subsidiary. In this role, he has helped establish a strong presence for SCS in the region across a wide range of industries with a focus on forestry and timber legality. Mr. Frank also serves as lead auditor for a range of certification programs and has conducted audits in 13 countries. Previously Mr. Frank helped to establish the SCS Greenhouse Gas Program during which time he was the founding manager and lead the program to become a global leader in the areas of forest carbon and REDD+ verification, carbon footprint verification and industrial carbon offset verification. Mr. Frank also helped lead the initiative to establish 9