The Rainforest Alliance is proud of our assurance system – assurance is a fundamental strategy to maintain the rigour and credibility of any certification system. The conduct of regular third party audits is a key element of this system. For the Rainforest Alliance, the safety and security of our Certificate Holders and their communities and the auditors working for our partner Certification Bodies is our principle concern. From 7 March a policy is in place to govern exceptions arising from disruptions to audit activities due to corona virus or public health measures and travel restrictions related to it.
Currently, due to restrictions on travel and access to certain sites due to public health risks related to COVID-19 (Coronavirus), cases are arising in some localities where it is not possible to follow the planned schedule of audits in the annual audit cycle. The current Coronavirus pandemic is a situation of force majeure which affects the normal implementation of our certification program and we are implementing special measures to address this. The details of the policy can be found here: https://www.rainforest-alliance.org/business/resource-item/audit-exception-policy-for-covid-19/
The policy is valid until May 31, 2020. We will review the situation regularly and any further extension or modification of the policy will be communicated before the end of that period.
We request that all CHs and CBs respect the public health measures in place in each country. Travel advisories are available from the US and Dutch governments with links to country specific information. Advice on measures to combat corona virus are also available at World Health Organization and the CDC.
Questions and requests for further information should be sent to certification@ra.org.
General Questions
Do Certification Bodies need to apply to RA first for permission to do a remote audit for each case or is this a general permission?
As per the policy, CBs need to inform Rainforest Alliance via certification@ra.org when the policy is enacted for desk audits and certificate extensions. CBs do not need to ask for permission, but RA reserves the right to have an overview and ask for clarification or deny it accordingly. In case there is any doubt about the applicability of the policy, certification bodies are welcome to contact Rainforest Alliance for final agreement/advice.
With regards to geographical applicability of the policy, can you clarify where information on yellow and red level of infections are taken from?
Rainforest Alliance is using the Travel Advisories from the US and Dutch governments when country own policies do not exist. There are also constant updates by the World Health Organization and the CDC. If you are unsure of any destination or steps to take or cannot find information you are welcome to contact certification@ra.org.
Does the policy also cover national measures blocking external entry and national lockdowns?
Yes, these are considered public health advisories from the origin country.
Why does the AUDIT EXCEPTION POLICY FOR COVID-19” (SA-P-GA-2-V1) mention in the summary page that the validity is until 31st May 2020, while the text in page 2 mentions "This is a temporary measure currently valid until end of June 2020".
The inconsistency in the dates mentioned in the first version of the policy has been corrected. Always refer to latest version of the policy, which can be found at this link: https://www.rainforest-alliance.org/business/resource-item/audit-exception-policy-for-covid-19/
Is the deadline for time extensions up to 30th August applicable only to farm or also to Chain of Custody?
The deadline for time extensions is applicable to all certificates/licenses
Under the COVID-19 exception policy, the current CB should request both a time and a volume extension. Which CB will conduct the extension audit: the current CB or can the member contract a new CB?
Under the COVID-19 exception policy the current CB will conduct the extension audit as it includes both time and volume. Extension requests to RA have to be processed by the current CB free of charge. The physical extension audit and related contracting thereafter will be done between the member and the CB, RA does not interfere with this.
UTZ Code of Conduct & Rainforest Alliance Farm Standard
How is the 50% volume extension for Certificate Holders calculated? Is it based on the previous year’s harvest estimation or a new harvest estimation?
The 50% volume extension will be calculated from the previous year’s harvest estimate. When the on-site audit is finally conducted, this 50% will then be subtracted from the new certified volume.
Why are licence extensions limited to 50% of the previous annual certified volume?
Rainforest Alliance takes the credibility of our certification seriously and we therefore need some level of assurance to be conducted, even in this force major situation, before granting a license for the whole volume. RA considers that granting 50% volume without an audit is an acceptable risk that allows producers to continue to trade while safeguarding the credibility of our certification system. This rule already exists in the current RA Certification Rules and we are now extending it to the UTZ program and applying it specifically for the COVID-19 situation.
What will happen if the member has sold all of the 50% volume given in the extension, the product has already physically gone through the supply chain, and then they fail the on-site audit when finally conducted?
If this happens then the member will be decertified and usual RA or UTZ rules will apply for recertification based on the fact that this is a critical NC. Volumes already sold cannot realistically be retracted in the RA traceability systems.
A company/group would like to be certified against the RA agricultural standard/UTZ Code of Conduct. Their physical audit was already planned before the policy came into effect but could not be conducted due to travel restrictions. Can they still receive a remote audit and be certified?
The risk in these cases is too high if the producer has never been physically audited before. Therefore no new certified producer members will be allowed into the RA/UTZ programs while the policy is in effect/until such time an on-site audit can be conducted.
There are audits from 2019 that are still pending conclusion. In some cases a physical verification of NCs should have been done to close the NCs and finally award the certificate. Would it be possible to do a remote verification of proper closure of NCs?
It is possible for the CB to carry out remote verification of corrective actions to close an NC, if the member is able to send good evidence of closure also online. We do realize that in some cases it will be almost impossible to check all aspects of the closure for example if worker interviews were required. In these cases we will have to allow the CB to make the best decision with regards to whether or not the member should receive the certificate based on the information they can gather. However in ALL cases, the CB still needs to check these NCs onsite as soon as possible once travel bans have been lifted. If at that stage there is evidence that the NCs were not properly closed, this will still serve as a binding part of the audit and the certificate will be suspended or cancelled in line with the normal RA/UTZ procedure.
What is meant by short-harvest window crops?
A ‘short harvest window’ is five weeks or less. Please see a reference to this in section 2.i of the RA Certification Rules. Some examples are certain vegetables and wild harvest products, such as rosehip.
UTZ Chain of Custody
If a site was previously certified as Small Volume (no physical audit required), and now has increased the volumes processed above what is prescribed in the standard, can it also receive a remote audit given that it will be the first physical audit they receive?
The revised policy 3/30/2020 states that a desk audit is allowed for these companies. Once the travel restrictions are lifted and an onsite audit can be performed again, the CB will need to verify the audit findings onsite.
In 2.5.3.a. – it states that the first audit should shall be conducted no later than 4 months after the SCA has received their first purchase of UTZ product. SCAs may not sell UTZ product until they have received a valid certificate.
In this instance if the 4 months will now expire and no physical audit can take place, the same rule applies as for small volume operators that have now passed the minimum threshold. In other words CBs can perform a desk audit for these companies. Once the travel restrictions are lifted and an onsite audit can be performed again, the CB will need to verify the audit findings onsite.
Rainforest Alliance Chain of Custody
A company has already received RFA approval for the labels through Marketplace, but audit is not likely to be completed within 1 year of CRA issuance. If audit is done by 31st May (current end date of COVID-19 exception policy), is the company allowed to use the logo after the date that marks 1 year of CRA issuance?
Yes, if you have been granted an extension for completing your audit, you are still within the application process for certification and can continue to use the Seal through this time as long as you have received the proper approvals for your design in Marketplace.
In 2.2 c) – it states that licenses can be extended until 30 August 2020, does that also include certificates, since in RA CoC certification we don’t work with licenses?
Yes it also includes certificates in the case of the RA program. Please send a request to certification@ra.org with the following information: Certificate #, Country of member, Certified crop, Original certificate end date. The time extension will then be issued by us in Salesforce.
What is a Participating Operators (CoC POs), and why is there a clause specifically for them in the new policy?
CoC POs are the equivalent of SCAs in the PM RA chain of custody program.
