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Sustainably Farmed Barramundi Sustainably Farmed Prawns Certification Program Management Program and Policy Manual Certification Procedures Policies and Processes Auditing and Integrity Logo Control and Use Continual Improvement

Sustainably Farmed Barramundi Sustainably Farmed … · Sustainably Farmed Barramundi Sustainably Farmed Prawns Certification Program Management Program and Policy Manual Certification

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Sustainably Farmed Barramundi Sustainably Farmed Prawns

Certification Program Management Program and Policy Manual

Certification Procedures

Policies and Processes

Auditing and Integrity

Logo Control and Use

Continual Improvement

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28 April 2016 2 © EcoSustainAbility Version 4.1

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EcoSustainAbility Pty Ltd Mobile 61 (0)407 391211

[email protected] PO Box 230 Yorkeys Knob QLD 4878 Australia

ACN 098560126:

© EcoSustainAbility 2016 Copyright and ownership of the intellectual property contained in the report remains with EcoSustainAbility unless otherwise agreed. The moral rights of authorship by Guy Chester and EcoSustainAbility are asserted.

The development of this certification program and criteria for sustainably farmed prawns is fundamentally based on existing intellectual property developed by EcoSustainAbility for the Australian Barramundi Farmers Association to establish the Australian Sustainably Farmed Barramundi Certification Program. EcoSustainAbility and ABFA have agreed:

1. ABFA engaged EcoSustainAbility to help develop the Australian Sustainably Farmed Barramundi Certification Programme including to develop the Certification Criteria and Certification Manual and associated documentation for this programme, which has and will continue to be revised and updated from time to time.

2. Ownership of copyright and moral rights for the Australian Sustainably Farmed Barramundi Certification Criteria and Certification Manual including all versions, updates and associated documents (the ‘Manual’) vests and remains with EcoSustainAbility.

3. EcoSustainAbility grants ABFA an irrevocable, royalty free, worldwide licence to use the (Australian Sustainably Farmed Barramundi Certification Program) Manual for any purpose. This licence is exclusive with respect to any use associated with the fish species Lates calcarifer (Barramundi) but otherwise non-exclusive.

4. ABFA will cooperate and assist EcoSustainAbility and the Australian Prawn Farmers Association (APFA) to develop a complementary certification programme for Australian farmed prawns and is so doing is prepared to consider the two certifications programmes having a shared and combined manual, management committee and certification panel.

5. Potential exists to extend this or a similar arrangement to other species or geographic region in future but EcoSustainAbility undertakes not seek to do so without the prior agreement and cooperation of ABFA.

Once completed, EcoSustainAbility will provide ABFA and APFA a licence to use this report for the purposes of their joint certification program. Other uses prohibited without permission.

Work undertaken by EcoSustainAbility for the development of the Australian Sustainably Farmed Prawns Certification Program for the Australian Prawn Farmers Association has been funded by the Fisheries Research and Development Corporation. Use of the new intellectual property developed for this project is subject to the APFA-FRDC Agreement and the Terms and Conditions of EcoSustainAbiliy's engagement.

ABFA owns the registered trademark of the Sustainable Barramundi logo.

Once Finalised APFA will own and register the trademark of the Sustainable Prawn logo (once the draft is finalised)

.

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1.  Introduction .................................................... 4 1.1.  Background ....................................................... 4 

1.1.1.  Sustainably Farmed Barramundi Certification Program  4 1.1.2.  Barramundi and Prawn Partnership  4 1.1.3.  Integrated Program Management and Policy Manual4 1.1.4.  Beyond Compliance  4 

1.2.  This Manual....................................................... 4 1.3.  Status ................................................................ 4 1.4.  Sustainability Vision .......................................... 5 

2.  Program Overview .......................................... 6 2.1.  Key Components ............................................... 6 2.2.  Key Steps .......................................................... 6 

2.2.1.  Awards Program  6 

2.3.  Administration .................................................. 7 2.4.  Integrity ............................................................ 7 

2.4.1.  Independence  7 2.4.2.  Appeals  7 

3.  Program Integrity ............................................ 8 3.1.  Certification Policy and Protocol ........................ 8 3.2.  Key Components ............................................... 8 3.3.  Key Steps .......................................................... 8 

3.3.1.  Awards Program  9 3.3.2.  Independence  9 3.3.3.  Appeals  9 

3.4.  Appointing Auditors ........................................ 10 3.4.1.  Auditor Qualifications  10 3.4.2.  Appointment of Auditors  10 

3.5.  Certification Panel ........................................... 10 3.6.  Annual Ecoefficiency Benchmarking ................ 11 3.7.  Certification Application Process ..................... 11 

3.7.1.  Compliance  11 3.7.2.  Application by Farmer  11 3.7.3.  Supporting Evidence  12 

3.8.  Initial Offsite Audit .......................................... 12 3.9.  Certification Panel ........................................... 13 3.10.  Onsite Audit .................................................... 13 

3.10.1.  Annual Return  13 

3.11.  Certification and Audit Policy .......................... 13 3.11.1.  Rejection or Withdrawal of Certification  15 3.11.2.  Review of Decision Not to Grant or Withdrawal of Certification  15 3.11.3.  Appeals  16 

3.12.  Re-audits ........................................................ 16 3.12.1.  Audit Policy Review  16 3.12.2.  Defining a Sustainable Farming On‐Site Audit  16 

3.12.3.  Fundamental Basis of Audit – the Principles  17 3.12.4.  Fundamental Approach  17 3.12.5.  Auditor Discretion  17 3.12.6.  Continual Improvement Approach  17 3.12.7.  Continual Improvement of Criteria  18 

3.13.  Audit Types ..................................................... 18 3.13.1.  Site Audit  18 3.13.2.  Offsite Audit  18 

3.14.  ABFA/APFA Administration Responsibilities ..... 18 3.14.1.  Ongoing Office Administration  18 

3.15.  Auditors Responsibilities ................................. 19 3.15.1.  Notice to Auditee (Farm)  19 3.15.2.  Managerial Interview  20 3.15.3.  Site Inspections  20 3.15.4.  Documentation  20 3.15.5.  Offsite Audits  20 3.15.6.  Audit Findings  21 3.15.7.  Corrective Actions  22 3.15.8.  Audit Effort  22 

3.16.  Withdrawal of Certification ............................... 22 3.16.1.  Appeals ‐ ABFA/APFA President  22 3.16.2.  Supporting Evidence  23 

3.17.  Verification ...................................................... 23 3.18.  Program Validation .......................................... 23 

4.  Support and Training ..................................... 24 4.1.  Ongoing Support ............................................. 24 4.2.  Annual Training and Development Workshop .. 24 

5.  Promotion ..................................................... 25 5.1.  Logo ................................................................ 25 5.2.  Promotion of Program ..................................... 25 

6.  Annual Awards .............................................. 26 6.1.1.  Prawn/Barramundi Farming Sustainability Awards  26 6.1.2.  Certificates of Merit  27 

7.  Continual Improvement ................................. 28 7.1.1.  Initial Tweaking  28 7.1.2.  Phase In  28 7.1.3.  Independent Review  28 

8.  Trade Mark Rules .......................................... 29 8.1.  Introduction ..................................................... 29 8.2.  Use of the Logo ............................................... 29 8.3.  Standards to Gain Certification ........................ 29 

8.3.1.  Criteria  29 8.3.2.  Process to Gain Certification  30 8.3.3.  Withdrawal of Certification  30 8.3.4.  Annual Ecoefficiency Survey and Annual Return  30 8.3.5.  Review of Decisions and Appeals  30 

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The sustainably farmed certification program for prawns has been developed following the successful launching of the Barramundi certification program. The two programs each have specific criteria but will be managed together as one overall program.

1. Introduction

1.1. Background 1.1.1. Sustainably Farmed Barramundi Certification Program The Australian Barramundi Farmers Association has developed a certification program addressing economic, social and environmental aspects of sustainability including hygiene and quality aspects of production. The system includes an approach which is applicable at the various scales of the industry and one that sets minimum standards whilst recognising best practice.

1.1.2. Barramundi and Prawn Partnership The development of this certification program and criteria for sustainably farmed prawns is fundamentally based on existing intellectual property developed by EcoSustainAbility to establish the Australian Sustainably Farmed Barramundi Certification Program for the Australian Barramundi Farmers Association. ABFA and APFA have a partnership approach to the ongoing management of the certification program. The two programs each have specific criteria but will be managed together as one overall program.

1.1.3. Integrated Program Management and Policy Manual This Manual is the integrated manual for the management of the Australian Sustainably Farmed Barramundi Certification Program and the Australian Sustainably Farmed Prawn Certification Program

1.1.4. Beyond Compliance Aquaculture is an Environmentally Relevant Activity in Queensland and requires environmental and/or fisheries licences in other states. The Prawn and Barramundi farming industry has had over 30 for prawns of the discipline of complying with and reporting on performance of the required standards. The proposed approach now builds on compliance and statutory reporting requirements to address much wider aspects of sustainability that are not just compliance based. It is proposed to take holistic approach to environmental responsibility (due diligence) beyond what is required by strict compliance.

1.2. This Manual This Manual provides an overview of the integrated management program and policies for the Australian Sustainably Farmed Barramundi and Australian Sustainably Farmed Prawns certification programs.

1.3. Status The Management Program and Policy Manual set out the policy and procedures approved by the ABFA and APFA Boards on XXX Month 2016 for the Australian Sustainable Farmed Barramundi and Prawns Certification Programs. NOTE This DRAFT version has yet to be approved by the ABFA and APFA Boards.

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l1.4. Sustainability Vision The vision is:

The farming of Barramundi and Prawns in Australia is ecologically sustainable, ecoefficient and produces a quality product that is internationally competitive.

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l1.5.

2. Program Overview

2.1. Key Components The key components of the certification program are:

Annual Ecoefficiency Benchmarking

Certification Application, including the:

o Sustainability Checklist; and

o Risk Assessment

Certification offsite assessment and onsite assessment.

Annual return

2.2. Key Steps There are 6 major steps in the certification process:

Submission of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment along with other supporting evidence to support with the application for Sustainability Certification to the ABFA Sustainability Auditor.

An initial offsite assessment is undertaken by the approved ABFA Sustainability Auditor on the basis of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment and supporting evidence.

The Certification Panel considers the Auditors recommendation and confirms Certification, Certification Subject to Corrective Actions or declines Certification.

An onsite audit will then be required within two years of the initial certification.

An Annual Return and annual Ecoefficiency Benchmarking is required each year. Re-completion of the whole checklist is required every 2 years, along with a recertification process including an offsite assessment.

An onsite audit is required every 2-3 years.

2.2.1. Awards Program As a further aspect of the program an annual awards system is being establish to encourage and recognise best practice sustainability and ecoefficiency in Australian barramundi and prawn farming.

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l2.3. Administration The Australian Sustainable Farmed Barramundi and Australian Sustainable Farmed Prawn certification programs are administered jointly ABFA and APFA. ABFA and APFA have appointed:

A four member independent Certification Panel to confer Certification, suggest administrative policy and interpretation to the ABFA/APFA boards and advise the ABFA/APFA boards on annual awards.

A Sustainability Auditor to compile ecoefficiency benchmarking results, undertake an initial and then biennial offsite assessments, and as required on-site assessments.

2.4. Integrity The establishment of a Sustainability Certification program needs to have solid integrity in its processes and policies. There are a variety of global standards and guides which may apply. The Prawn and Barramundi certification program is relatively small, given the limited number of Prawn and Barramundi farms in Australia and as such complete application of these international norms for multi sector conformity assessment bodies would be beyond the resources of APFA and ABFA. This Certification program has been developed with reference to ISO 14024 Environmental labels and declarations Type 1 environmental labelling Principles and Procedures and ISO 17065 Conformity Assessment - Requirements for Bodies certifying products, processes and services.

2.4.1. Independence One key aspect of the integrity of the Sustainability Certification system is to have an independent assessment (the audit) and a separate independent Certification Panel. This model allows ABFA/APFA to own and administer its Sustainability Certification System whilst maintaining independence and integrity.

2.4.2. Appeals A formal appeals process allows an independent review in the event of any dispute.

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3. Program Integrity

3.1. Certification Policy and Protocol This chapter forms the basis of the Australian Barramundi Farmers Association (ABFA) and Australian Prawn Farmers Association (APFA) certification and audit policy and protocol. It establishes a framework for auditing and certifying Barramundi and Prawn Farms against the relevant certification criteria. The processes include an approach based on Farmer self assessment, off-site audit prior to certification and then regular onsite auditing.

3.2. Key Components The key components of the certification program are:

Annual Ecoefficiency Benchmarking

Certification Application, including the:

o Sustainability Checklist; and

o Risk Assessment

Certification offsite assessment and onsite assessment.

Annual return

3.3. Key Steps There are 6 major steps in the certification process:

Submission of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment along with other supporting evidence to support with the application for Sustainability Certification to the ABFA Sustainability Auditor.

An initial offsite assessment is undertaken by the approved ABFA Sustainability Auditor on the basis of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment and supporting evidence.

The Certification Panel considers the Auditors recommendation and confirms Certification, Certification Subject to Corrective Actions or declines Certification.

An onsite audit will then be required within two years of the initial certification.

An Annual Return and annual Ecoefficiency Benchmarking is required each year. Re-completion of the whole checklist is required every 2 years, along with a recertification process including an offsite assessment.

An onsite audit is required every 2-3 years.

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l3.3.1. Awards Program As a further aspect of the program an annual awards system is being established to encourage and recognise best practice sustainability and ecoefficiency in Australian Barramundi Farming.

3.3.2. Independence One key aspect of the integrity of the Sustainably Farmed Barramundi/Prawn Certification system is to have an independent assessment (the audit) and a separate independent Certification Panel. This model allows ABFA/APFA to own and administer its Sustainability Certification System whilst maintaining independence and integrity.

3.3.3. Appeals A formal appeals process allows for review should there be a dispute.

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l3.4. Appointing Auditors 3.4.1. Auditor Qualifications In accordance with the ABFA/APFA's Certification Audit Policy, the following requirements are considered essential:

A thorough understanding of the principles of sustainability and ecoefficiency as it applies to finfish aquaculture, and the intent of the Australian Sustainable Barramundi and Prawn Farming Certification criteria.

Experience with aquaculture and specifically practical experience in achieving sustainability and ecoefficiency.

Experience in undertaking environmental audits.

A graduate or post graduate degree in ecology, environmental science or similar.

3.4.2. Appointment of Auditors Auditors will be appointed collaboratively by the Presidents of ABFA and APFA in consultation with the Chair of the Certification Panel.

NOTE: It is envisaged that one auditor will be appointed initially.

3.5. Certification Panel A certification panel of four independent experts will be appointed by ABFA and APFA.

The experts should have experience in aquaculture, ecoefficiency and primary production sustainability. The Panel should have a variety of expertise and backgrounds from working in industry, research or government policy/development roles. The panel will need to offer their support in an honorary, volunteer role.

It is intended that the Panel can include:

A person with substantial experience in aquaculture (most likely not a barramundi/prawn farmer owing to potential conflict of interest, but perhaps a Queensland farmer not currently engaged in barramundi/prawn farming).

A person from the seafood retail industry.

A person with aquaculture technical knowledge and or research experience.

Other member(s) with an understanding of practical best practice sustainability for primary industries and /or an understanding of government policy.

The ABFA/APFA Presidents are ex-officio but NON VOTING members of the Panel.

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lThe commitment required from each panel member should not exceed 20 hours per year. This assumes a maximum of a monthly one hour teleconference meeting and other time for review of emails, commenting on issues, approving minutes etc.

ABFA/APFA intends to offer complimentary registration at their annual conference in recognition of the role of panel members.

The Certification Panel shall have a chairperson. The Chair shall have a deliberative and if required, a casting vote. A quorum of the four member Panel should be two.

The Auditor may facilitate Panel meetings.

3.6. Annual Ecoefficiency Benchmarking The annual ecoefficiency benchmarking will be undertaken by all farms annually around October each year for the previous financial year. This allows an overall industry benchmarking and comparison for each farm against their previous years and within the industry.

The Auditor will send out the Ecoefficiency Benchmarking surveys and compile the results. NOTE: The auditor must keep the individual farm results confidential and reporting must report indices without identifying farms. Records must be kept to allow reporting back to each farm of comparison from their most recent years’ and previous year’s results.

To avoid any doubt, the Ecoefficiency Benchmarking should normally happen in October each year, regardless of the anniversary of a farm’s certification process.

3.7. Certification Application Process 3.7.1. Compliance To gain Sustainable Barramundi/Prawn Farming Certification a farm must meet all criteria unless the criteria is irrelevant and could not be applied to the farms type or situation. In the event that a farm considers it not practical or financially viable to meet or partially meet a criteria it may seek an exemption, but in such circumstance must still show how it achieves the relevant principle for that aspect.

The claim for any exemption must be noted on the audit report and specifically considered (and accepted or rejected) by the Certification Panel.

3.7.2. Application by Farmer The application process involves submission to the ABFA/APFA Sustainability Certification Auditor of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment along with other supporting evidence to support with the application for Sustainability Certification to the ABFA/APFA Sustainability Auditor.

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l3.7.3. Supporting Evidence The Farm must also submit supporting evidence with the Certification Application assessment checklist. Such evidence may include (but is not limited to):

The Farm’s signed Sustainability Policy

Available evidence of ecoefficiency benchmarking records and calculations of benchmarking data;

Any environmental program, action plan or environmental management system;

Evidence of staff awareness and training (for all but micro-businesses with few staff);

Evidence of compliance (e.g. copies of permits licences and any required records, monitoring or reporting to authorities);

In addition to documentation, photographs/maps/plans are highly desirable:

Photographs of the sites (also any plans of the site, ponds and buildings);

Photographs of Chemical/fuel storage(s);

Photographs of solid waste storage and disposal (if on site);

Photographs of settlement ponds and discharge points.

Photographs supporting claims made in the checklist (e.g. energy efficiency measures etc.).

3.8. Initial Offsite Audit An initial offsite audit is undertaken by the approved ABFA/APFA Sustainability Certification Auditor on the basis of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment and supporting evidence.

The Auditor firstly ensures the application is complete and adequate supporting evidence is provided, if not, the Auditor send a request by email to the farm for further information.

The initial offsite audit involves thorough review of the application and supporting evidence and an interview with the farm manger and at least one key staff. Wherever practical the Auditor should seek other verification of the compliance with the Sustainable Barramundi/Prawn Farming Certification criteria.

The Auditor makes a recommendation to the Certification Panel.

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l3.9. Certification Panel The Certification Panel considers the Auditors recommendation and confirms Certification, Certification Subject to Corrective Actions or declines Certification. The Certification Panel does not undertake any primary investigation but relies on the Auditors Report, in exceptional circumstances the panel may review the application and relevant supporting evidence.

3.10. Onsite Audit An onsite audit will then be required within two years of the initial certification. After this initial audit a further onsite audit is required every 2-3 years. The Auditor makes a report which is considered by the Certification Panel and continued certification is offered (which may be conditional on corrective actions).

3.10.1. Annual Return An Annual Return and annual Ecoefficiency Benchmarking is required each year. Re-completion of the whole checklist is required every 2 years, along with a recertification process including an offsite assessment.

3.11. Certification and Audit Policy The ABFA and APFA Boards adopt the following policy:

1. Auditing is considered an essential component of the Australian Sustainable Barramundi/Prawn Farming Certification programs.

2. Recognising the significant cost of audits, the ABFA/APFA will endeavour to implement as comprehensive and cost effective audit program as ABFA/APFA resources allow.

3. Audits may take a number of forms:

Site Audits: inspecting attractions and accommodation products, accompanying tour products.

Offsite Audits: mainly involving interviews with key staff and review of documents.

4. A formal interview with senior management (e.g. the owner or farm manager) addressing all claims made against the criteria is a fundamental aspect of site and off-site Audits.

5. Interviews with farm staff that undertake farm management activities should be included in all audits, to ascertain staff awareness of ecoefficiency and sustainability best practices for the farm and risk and compliance management procedures.

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l6. Auditor(s) will be appointed by the Presidents of ABFA/APFA in

consultation with the Certification Panel chair. The following requirements are considered essential:

A thorough understanding of the principles of sustainability and ecoefficiency as it applies to finfish aquaculture, and the intent of the Australian Sustainable Barramundi/Prawn Farming Certification criteria.

Experience with aquaculture and specifically practical experience in achieving sustainability and ecoefficiency.

Experience in undertaking environmental audits.

An degree in environmental studies or similar.

Further to the above, auditors must be available to travel to sites and undertake audits at times convenient to farms promptly provide reports to both the farms and Certification Panel.

7. After the initial offsite audit for first certification, audits should be scheduled on an essentially random basis. However, audits may be scheduled opportunistically when an auditor is travelling in an area. Audits may also be scheduled where the ABFA Board or Certification Panel have reason to believe that there may be non-compliance (e.g. neighbour complaints).

8. Farms will receive a minimum of 14 days notice of a pending audit. Farms may suggest audit times that suit harvesting and processing operations and other farm imperatives, but must attempt to meet the Auditors travel itinerary. It is not intended that specific operations or arrangements be made for audits, however all relevant staff and machinery must be available for inspection/interview. If a mutually agreed time cannot be agreed within 30 days of receiving notice of a pending audit, certification may be withdrawn.

9. The Auditor must make findings that address compliance with criteria and the risk assessment. Auditors should identify areas of best practice and if there is any aspects worthy is a potential award or certificate of merit.

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l10. Where an auditor makes findings of non compliance with criteria there are

three options:

Where a principle of sustainable barramundi/prawn farming is not being addressed and/or there is a blatant disregard for particular criteria, which were claimed as being addressed, the Auditor may recommend not granting or the immediate withdrawal of certification.

Where a principle of sustainable barramundi/prawn farming is not being addressed as evidenced through non-compliance with particular criteria (which were claimed as being addressed), but the non-compliance is essentially minor or an oversight the Auditor may

recommend a corrective action process by the certified farm (usually to achieve compliance within 3 months).

NOTE To avoid any doubt, if there is major non-compliance with more than one principle of sustainable Barramundi/Prawn farming not granting or withdrawal of certification should be recommended.

11. Where corrective action is required, the farm must agree in writing to the corrective action program within 14 days of receiving written notice by the Auditor.

3.11.1. Rejection or Withdrawal of Certification 12. Rejection of certification or withdrawal of certification may only be made

by a decision of the Certification Panel. The Panel must make such a decision in consultation with the auditor and may consult the President of ABFA on matters of policy and interpretation of criteria.

NOTE: Should any member of the Panel have a conflict of interest in the decision, an ABFA/APFA Board member (as relevant) without a conflict of interest conflict of interest may be co-opted to the Panel for the deliberations.

3.11.2. Review of Decision Not to Grant or Withdrawal of Certification

13. A farm may request a review of a decision to not to confer or to withdraw their certification (or of the pre-assessment or post assessment certification processes) in writing to the President of the Australian Barramundi or Prawn Farmers Association (as relevant) within 28 days of receipt of the decision to withdraw certification. The President will review the original Panel decision and then make a decision within 28 days of receiving the appeal. The President must consult with the Chair of the Certification Panel regarding the reasons for not conferring or withdrawal of certification and may consult with the Auditor.

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lNOTE: Should the relevant President have a conflict of interest in the decision. They shall delegate the decision to another office holder without a conflict of interest (the first of the Vice President, then Secretary, then Treasurer of the ABFA/APFA without a conflict of interest must conduct the review and then make the decision).

3.11.3. Appeals If a farm or another member of ABFA/APFA is dissatisfied with a decision to confer, not confer or withdraw certification (or of the pre-assessment or post assessment certification processes) the dissatisfied member may request an appeal.

The Presidents of ABFA and/or APFA shall appoint an independent mediator who is a member of the Institute of Arbitrators & Mediators Australia to adjudicate.

All appeal costs borne by the appellant and ABFA/APFA shall be met by the appellant regardless of the outcome.

3.12. Re-audits Should there be a need for re-auditing to confirm compliance after a corrective action program, the Farm must meet all associated costs of the re-audit. Wherever possible the Auditor should seek offsite verification by the Farm (photographs, documents etc.) to verify corrective actions.

3.12.1. Audit Policy Review This policy will be reviewed and reaffirmed at each Annual General Meetings of the Australian Barramundi Farmers Association and the Australian Prawn Farmers Association.

3.12.2. Defining a Sustainable Farming On-Site Audit A Sustainable Barramundi/Prawn Farming Audit is an assessment of the level of compliance by a Farm with the criteria claimed as being met in an Farms certification application. Further, it involves an assessment of the product against current best practice barramundi/prawn farming. In essence, the purpose of an Sustainable Barramundi Farming audit is to accomplish the following:

Assess the achievement of the principles of Sustainable Barramundi/Prawn farming.

Verify compliance of the Farm’s operations and practices with the certification criteria.

Assess the risks of environmental harm and identify obvious adverse environmental, social, economic and cultural impacts from practices conducted by the Farm and therefore verify the adequacy of the risk assessment.

Identify opportunities for continual improvement to achieve the principles of sustainable barramundi/prawn farming.

Recognition of best practice.

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lNOTE: The Auditor’s role is not to undertake a legal compliance assessment, however the auditor needs to be satisfied the Farm meets its statutory obligations and permit conditions. Attention is drawn to Environmental Duty and obligations to notify imposed by local legislation (such as those established by Queensland’s Environmental Protection Act 1994) which may require an Auditor to formally notify a farm if they observe environmental, harm, the potential form environmental harm or statutory non-compliance.

3.12.3. Fundamental Basis of Audit – the Principles The fundamental test for the Audit is whether the principles of sustainable barramundi/prawn farming are being met by the farm. The framework to evaluate the compliance with the principles is the criteria as set out in the Certification manual, however where a criteria is not applicable and where a farm has an alternative approach, the assessment of fundamental compliance should be against the principles.

3.12.4. Fundamental Approach A Sustainable Barramundi/Prawn Farming audit involves analysis, confirmation of procedures and practices by observation, inspection of the farm and infrastructure, review of documentation and obtaining oral confirmation and commitment by manager(s) and/or staff.

3.12.5. Auditor Discretion Auditing is a very sensitive process and must be undertaken on the basis of identifying opportunities for compliance with criteria implementing best practices rather than focussing on non-compliance. Having said that, the Auditor has limited discretion, auditors must apply the sustainable Barramundi/Prawn farming criteria in a consistent and equitable way. In this light the Auditor has discretion only to evaluate compliance with criteria, when there is any doubt, the criteria must be interpreted literally. There is likely to occasionally be doubt owing to the unique circumstances of a particular farm, in this instance the auditor may exercise discretion where it is not prudent or feasible for the product to meet the criteria. This discretion must be implemented to the extent that the product must still be achieving the principles of sustainable Barramundi/Prawn farming.

3.12.6. Continual Improvement Approach The identification of opportunities for improvement of a Farm toward achieving best practice in each of the principles sustainable Barramundi/Prawn farming is an important aspect to an audit. Further, the Auditor should identify where the audited farm is implementing best practices.

The Auditor should raise new or innovative best practices for the attention of Certification Panel.

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l3.12.7. Continual Improvement of Criteria A further and important aspect of auditing is feedback on the criteria. Often a criterion doesn’t apply to a Farm, or the literal meaning of a criterion results in it being difficult or onerous to comply with for a type of farm or activity. Auditors should note these and they will be taken into account when the criteria are revised.

3.13. Audit Types One aspect of the Sustainable Barramundi/Prawn Farming Certification program is the ability to undertake various two types of audits with a view to rigorous, yet cost effective audit methodologies are applied.

3.13.1. Site Audit The site audit involves actually experiencing the tourism product first hand.

The fundamental assumption with a site audit is that the auditor has personally experienced and observed the Farm to the extent necessary to enable conclusions to be drawn about compliance with the Sustainable Barramundi/Prawn Farming criteria.

The site audit involves an interview with Farm management and at least select staff.

This audit type is the most rigorous and most preferable, however is not always possible owing to the cost and logistical practicalities.

3.13.2. Offsite Audit The Offsite Audit is essentially an office-based review of the products compliance with certification criteria. It involves offsite review of documentation and systems to provide evidence of compliance with the criteria. The offsite audit relies heavily on management interview and secondary evidence of compliance (e.g. photographs of sites, documents such as plans and monitoring data etc).

3.14. ABFA/APFA Administration Responsibilities 3.14.1. Ongoing Office Administration The administrative systems in the ABFA/APFA office need to include:

Keeping complete files of certification applications, other supporting information and the results of certification (including requests for and verification of corrective actions) must be maintained in the ABFA’s office. NOTE: Apart from Certification Panel use, these should be kept confidential.

ABFA requesting and compiling Annual returns and followed up after 30 days.

Once the audit is completed and the auditor has sent the audit findings to the Certification Panel, the ABFA office keeps records of the Panel's deliberations and sends the notice of Certification (subject to any corrective actions) or decline of certification to the Farm.

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l3.15. Auditors Responsibilities The Auditor has a unique responsibility; they are often the first ABFA/APFA related person who has visited a site. The auditor must remember that they are essentially an ambassador of the Sustainably Farmed Barramundi/Prawn Certification Program and they should do their utmost to encourage ongoing support for the program.

The Auditors responsibilities for offsite and onsite audits are:

Confirm that they do not have a conflict of interest in undertaking the audit.

Make arrangements with the Farm to undertake the audit at a mutually acceptable time (by email/telephone).

Advise the Farm by email of the confirmed date of the audit and the auditors understanding of any travel/logistical arrangements.

Reconfirm the audit with the Farm not less than 24 hours of the audit (by phone/email).

Ensure the package of copies of the original certification application, any supporting evidence supplied and details of the original assessment

and/or results of previous audits have been received from the ABFA Office and are reviewed prior to the audit.

Undertake the audit in accordance with this protocol and in a professional and courteous manner.

Provide oral advice of the preliminary Audit Findings to management at completion of the audit.

Report the Audit Findings in the agreed format within 7 days of undertaking the audit.

Provide further advice (if requested) to the Certification Panel in the event of a recommendation for withdrawal of certification and/or an appeal against audit findings.

3.15.1. Notice to Auditee (Farm) Scheduling of each audit should be undertaken by the Auditor, initially by email or telephone, then confirmed with an email. When the audit notice exceeds two weeks, a confirmatory email/fax should be sent 24 hours before the audit.

The process of scheduling audits is time consuming, and auditors should ensure they allow sufficient time for this task in the period of the lead time prior to undertaking the audit.

Auditors should be as flexible as possible particularly when the Farm has limited capacity or is in peak periods.

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l3.15.2. Managerial Interview Management interviews are an essential component of all Audits. The most senior manager should be interviewed about the Farm’s compliance with criteria. The process usually involves going through the criteria and asking management to explain how criteria are met:

The primary management interview should be with the owner, chief executive officer, managing director or farm manager. In other words the highest level of management possible.

Where another person completed the original application for certification, wherever possible they should be available.

Where practical it is best to complete the management interview prior to undertaking a tour or site inspection.

Where the audit is an offsite one, evidence of compliance with criteria needs to be requested as much as possible. This may include, pictures, data, reports etc.

The auditor should insist on undivided attention in a quiet location for the interview.

In addition interviews with other staff often provide important inputs to the Audit. Such incidental interviews of staff should be fairly casual and relate to the individuals responsibilities. No staff member should be put into a position of incriminating the Farm in front of a manager/supervisor.

3.15.3. Site Inspections The site inspection is a very important component of on-site audits. For farms, the inspection enables review of the actual infrastructure establishing compliance with criteria. The day chosen for the site inspection would ideally be one in which all of the key site personnel that are to be interviewed are on site and normal activities are being undertaken.

3.15.4. Documentation The review of documentary evidence of compliance with criteria is a key aspect of the audit methodology. Auditors will often have to have the documents sent after the audit, however it is far preferable to just sight the documents rather than keep copies. Where copies are required, if possible just copy the table of contents or specific excerpts.

3.15.5. Offsite Audits The off-site audits essentially need rigorous managerial interviews, these types of audits are not preferable and should be augmented with on-site audits as soon as practicable..

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l3.15.6. Audit Findings It is important that audit findings are recorded accurately, based on facts, not biased opinion and are repeatable. That is to say that should another auditor undertake an audit and find the same facts that the audit findings would be similar.

The following template should be used for audit findings. NOTE many paragraphs will not be relevant, use those that are.

Example Audit Findings (Insert Farm Name)

Auditor: Name Site/Desk Audit

On xxxdate a Sustainably Farmed Barramundi/Prawn Certification audit of XXXFarmname was undertaken by site inspection, and/or interviewing the XXXposition (XXXName ).

The audit was undertaken against the claims made by XXXFarmname in their application for certification dated XXXdate, with investigations based on reference to documents provided at the audit, observations and discussions.

XXXinsertgeneraldescription andcommentshere

The audited Farm XXXproductname was found to comply with all necessary criteria required for certification under the Sustainable Barramundi/Prawn Farming Certification Program.

OR

The audited Farm XXname was found to comply with most criteria required for certification under the Sustainable Barramundi/Prawn Farming Certification Program. However, identified non compliance with criteria includes:

XXXdescribecriteria; and

XXXfinalcriteria.

There are numerous areas where XXXcompanyname is exhibiting innovative best practice, these include:

XXXdescribebestpractice; and

XXXfinalcriteria.

In terms of ecoefficiency benchmarking ... XXXinsert results of Farm benchmarks against industry norms and against change from previous years for the farm’s reporting.

It is recommended that the Sustainable Barramundi/Prawn Farming Certified status of XXfamrname be granted/retained/ withdrawn/ subject to the following corrective actions:

XXXcorrectiveaction and due date; and

XXXcorrectiveaction and due date.

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lFrom the audit, there is an opportunity to improve the achievement of sustainable barramundi/prawn farming principles by:

XXXimprovementsaction; and

XXXfinalimprovementaction. 3.15.7. Corrective Actions The Recommendation of the Auditor to the Certification Panel may be conditional upon corrective actions being remedied within certain timeframes. The farm may comment on the corrective actions or provide additional information, and must formally accept and undertake to remedy any corrective actions prior to certification being granted.

3.15.8. Audit Effort The actual time and effort undertaken by Auditors to undertake an audits varies widely depending upon location, types of audit and preparedness by the auditee. Some audits require almost a day’s travel each way for the auditor, then a day to undertake the farm inspection, whereas other audits could be undertaken with minimal travel time and four hours for a thorough site inspection and management interview.

The write up of results takes about two to six hours after the audit. There is often some additional time required to chase then review additional documentation from auditees (where essential documentation isn’t provided at audit) or to undertake staff interviews.

In summary, some audits take a total effort of less than one day, whereas others take two or more days! Unfortunately, the remoteness of some barramundi/prawn farms results in a need for travel, and it is often the remote sites, which are the most important for site inspections owing to the conservation values of such areas.

3.16. Withdrawal of Certification The Certification Panel has a unique responsibility for withdrawal of certification, this may only be made by a decision of the Panel in consultation with the relevant President of ABFA/APFA.

3.16.1. Appeals - ABFA/APFA President An accredited operator may appeal a decision to withdraw their certification in writing to the President of ABFA/APFA. The President has a responsibility to make a decision within 28 days of receiving the appeal. The President must consult with the Certification Panel regarding the reasons for withdrawal of certification and may consult with the Auditor regarding policy and interpretation of criteria. The President’s decision is binding, and may not be appealed. The President must provide written advice of the decision to the appellant, the auditor.

NOTE: should the President have a conflict of interest in the decision, the Vice President, then Secretary then Treasurer of the ABFA/APFA, the first without a conflict of interest has the responsibility to make the decision.

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l3.16.2. Supporting Evidence The Farm must also submit supporting evidence with the Certification Application assessment checklist. Such evidence may include (but is not limited to):

The Farm’s signed Sustainability Policy

Available evidence of ecoefficiency benchmarking records and calculations of benchmarking data;

Any environmental program, action plan or environmental management system;

Evidence of staff awareness and training (for all but micro-businesses with few staff);

Evidence of compliance (e.g. copies of permits licences and any required records, monitoring or reporting to authorities);

In addition to documentation, photographs/maps/plans are highly desirable:

Photographs of the sites (also any plans of the site, ponds and buildings);

Photographs of Chemical/fuel storage(s);

Photographs of solid waste storage and disposal (if on site);

Photographs of settlement ponds and discharge points.

Photographs supporting claims made in the checklist (e.g. energy efficiency measures etc.).

NOTE: Some farms may opt to pay for the optional on-site audit for initial certification. In this case the above documentation does not need to be submitted with the Certification Application, rather it must be available to be sighted and reviewed by the Auditor.

As part of the off site assessment and on site audit process the Assessor/Auditor may identify corrective actions and/or observations.

3.17. Verification Verification of procedures and records should be undertaken by the ABFA CEO on a regular and ongoing basis.

3.18. Program Validation To satisfy itself of the validity of the program undertaken by its Auditors and certification panel the ABFA/APFA board should have a separate open discussions with the Auditor and/or the Certification Panel at least annually.

When resources permit and the program is well established (say at least 20 farms certified). ABFA/APFA should seek a third party review of the administration and validity of the program.

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4. Support and Training

4.1. Ongoing Support Whilst it is acceptable for an Auditor to provide training, it is inappropriate for the Auditor to provide an advisory service to potential auditees. Given this, the ABFA/APFA CEOs and board members will need to provide any ongoing support to Farms.

4.2. Annual Training and Development Workshop It is suggested that a half day session on the Barramundi/Prawn farming certification system be held annually concurrently with the annual conference or the regular research and development workshops.

The session should be attended by the Auditor, Certification Panel (at least the Chair), the ABFA/APFA CEO's and ABFA/APFA Boards (at least the Presidents). Performance of the current program, administration policies and criteria should be discussed. The Auditor should be asked to provide overall feedback on the Ecoefficiency benchmarking and observation for best practice innovation and potential criteria change after their experience auditing.

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5. Promotion

5.1. Logo The Logo forms the functional recognition for certified products and needs to clearly depict environmental/sustainability endorsement to the retail chain and end consumers.

NOTE: International practice is to include a date on logos to indicate when the product was last re-certified. We suggest that the use of the logo be restricted to products whilst they are certified (e.g. for placing stickers on consumer packaging) and for other material (e.g. boxes) the logo must not be used six months after certification ceases.

5.2. Promotion of Program ABFA/APFA will need to undertake a wide range of media promotion to gain editorial level publicity of the program. It is suggested that a launch occur once at least four-five farms are certified. The publicity will also serve to encourage ABFA/APFA members to be certified and may even encourage other barramundi and prawn farmers into ABFA/APFA membership and certification.

Individual promotion of each farm as it gets certified can aid publicity in the early days whilst the program is still new and gains editorial support.

Should resources permit ABFA/APFAs’s promotion should focus on the seafood distribution and retail industry to encourage their preference for certified product owing to its quality and sustainability credentials. Seeking major retailers endorsement would be a major benefit but is unlikely until the program is established and has a modicum of recognition and a history of integrity.

The annual awards also provide a potential ability to gain editorial coverage of the programs and the sustainability of farmed barramundi/prawns.

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6. Annual Awards

As a key part of the overall Sustainable Barramundi and Prawn Farming Certification Program there will be annual awards. The current awards given out are....

Need to insert details from current ABFA awards

From 2016 it is proposed to have two major annual awards:

Barramundi Farming Sustainability Award

Prawn Farming Sustainability Award

Sustainability Certificates of Merit

The purpose of these awards to promote innovation with sustainability and ecoefficiency and the sharing of information between farms.

Farms that have achieved Sustainability Certification are eligible for the awards.

It is intended that this award is awarded to one farm every year.

A logo (similar to the Certification logo) with the words “Australian Barramundi/Prawn Farming 20xx Ecoefficiency Award” will be provided and may be used by the farm on its product the for two years immediately following the granting of the award. The farmer may use the award on farm and product promotion material and may (at their own cost) provide retailers with small stickers with the logo for consumer packaging. The logo may be in dark solid colour (blue/black etc.) on a plain background.

6.1.1. Prawn/Barramundi Farming Sustainability Awards NOTE: Farms do not specifically apply for this award, they are automatically assessed when they submit their ecoefficiency benchmarking data. This will add an incentive for farmers to lodge their ecoefficiency benchmarking data in a timely manner.

Farms must have had a recent audit and completed their most recent ecoefficiency survey to ensure the overall sustainability of the farm and to avoid embarrassment of ABFA/APFA and bring the integrity of the awards system and/or the Sustainability Certification program into disrepute.

The key criteria is that:

For the 20xx year the XXX farm exhibited innovative best practice sustainability (and/or) ecoefficiency in the framing of prawns/barramundi which provides a model for the Barramundiand Prawn Farming Industry in Australia.

The Farm must also be certified, have been recently audited and provide adequate evidence of their claims of best practice and its success in achieving ecological sustainability and/or ecoefficiency.

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lAn award does not need to be made every year, and should the Certification Panel decide that no applicant or nominee meets the key criteria no award should be issued. Similarly, if in any one year two or more farms have exceptional applications/nominations the Certification Panel may chose to award two (or more) Sustainability Awards in any one year, however this should be only in exceptional circumstances.

The Certification Panel must make a specific citation for each award and recommend this to the ABFA/APFA boards (whichever is relevant) for endorsement prior to issuing the award. The chair of the Certification Panel shall communicate directly with non-affected board members in the event that a board member is a potential recipient or in any other way has an overt conflict of interest in the recommended award.

A logo (similar to the Certification logo) with the words “Australian Prawn/ Barramundi/Prawn 20xx Sustainability Award” will be provided and may be used by the farm on its product the for two years immediately following the granting of the award. The farmer may use the award on farm and product promotion material and may (at their own cost) provide retailers with small stickers with the logo for consumer packaging. The logo may be in any colour including gold embossed where appropriate.

6.1.3. Certificates of Merit The Certification Panel may nominate certificates of merit to Farms which make application for or are nominated the sustainability award and/or from the outcomes of the Ecoefficiency award process. The criteria should be as above with a lower level threshold and issues for encouragement/recognition rather than full attainment.

Farmers may also nominate key staff for their role in suggesting or implementing sustainability and/or ecoefficiency initiatives. The Certification Panel will consider these and may interview the nominee.

There are no limits to the number of certificates of merit that may be issued in any one year.

The Certification Panel must make a specific citation to go with each certificate.

No logo or seal is applicable and farms may only list in promotional material that the farm was awarded a certificate of merit and the citation for the award.

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7. Continual Improvement

7.1.1. Initial Tweaking It is usual for that the initial Audits and certification procedures raise many aspects requiring clarification. As such it is suggested that there be a planned review of the criteria once at least ten farms have been audited and certified, with at least five on-site audits undertaken.

This should be primarily about clarification, rather than any strengthening of criteria.

7.1.2. Phase In It is suggested that any new criteria involving additional or more onerous aspects have a lead in time of two years. This timeframe has proven to be the minimum acceptable with other similar programs. By allowing an adequate lead in time, the criteria can be steadily strengthened to ensure that the criteria always represent best practice without causing undue hardship on the industry.

By committing to this longer lead time now, for any future program criteria change, participants can have confidence and business certainty in their investments etc.

7.1.3. Independent Review It is suggested that after three or more years of operation, ABFA/APFA seek funding for and commission an independent review of the program and its effectiveness for achieving beyond compliance best practice sustainability and ecoefficiency Barramundi and Prawn farming.

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8. Trade Mark Rules

8.1. Introduction This section sets out the rules for the use and administration of the Sustainable Barramundi/Prawn logos.

8.2. Use of the Logo Once a Farm is approved as certified by the Certification Panel the Farm will be provided with a licence to use the “Sustainable Barramundi” or “Sustainable Prawns” Logo. The key aspects of the license are:

The “Sustainable Barramundi” or “Sustainable Prawns” Logo may only be used for the farm and product from the farm that has been the subject of the Audit and certification.

The ““Sustainable Barramundi” or “Sustainable Prawns” Logo may only be used on the colour and mono forms as provided by ABFA.

“Sustainable Barramundi” or “Sustainable Prawns” Logo may be used on printed material, documents, digital media and on the internet for the farm provided it is clearly only relating to the activities of that Farm.

“Sustainable Barramundi” or “Sustainable Prawns” Logo may be used by the farm on product packaging (boxes, consumer/retail labels etc.).

The Farm must keep an original copy of each form of material the logo is used on (is. Box, label, document templates).

In the event the Farm has its certification withdrawn by ABFA/APFA, the Logo must be immediately withdrawn from all digital and internet media, not used on any documents or promotional material. Existing stock of product packaging with the logo may only be used until the stock runs out of for six months, whichever is earlier.

8.3. Standards to Gain Certification 8.3.1. Criteria The criteria for certification are set out in the Sustainably Farmed Barramundi Certification Program Manual, version 2.0 or as revised and approved by the ABFA Board or the Sustainably Farmed Prawn Certification Program Manual, version X.x or as revised and approved by the APFA Board.

A Farm which is already certified will have two years to comply with any new or amended criteria.

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l8.3.2. Process to Gain Certification The process to gain certification is:

1) An application for certification is made by the Farmer as per section 3.9.

2) Annual certification benchmarking survey has been completed as per section 3.8.

3) An initial onsite or offsite audits are undertaken by an ABFA/APFA approved auditor in accordance with sections 3.10 or 3.12 and in compliance with the ABFA/APFA Audit Policy as per section 3.14.

4) The certification Panel considers the Audit report and confers certification (which may be subject to corrective actions) in accordance with section 3.11

8.3.3. Withdrawal of Certification Certification may be withdrawn as per section 3.18.

8.3.4. Annual Ecoefficiency Survey and Annual Return The ongoing certification requires the completion of the ecoefficiency survey and the annual return each year in accordance with sections 3.8 and 3.12.1.

8.3.5. Review of Decisions and Appeals The processes for a request for a review of decision and appeals are set out in sections 3.13.2 and 3.13.3.

Sustainably Farmed Prawns

Certification Manual 2016 Version 1.1

Initial Draft for Industry Consideration

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EcoSustainAbility Pty Ltd +61 (0)407 391211

[email protected] PO Box 230 Yorkeys Knob QLD 4878 Australia

ACN 098560126:

© EcoSustainAbility 2016 Copyright and ownership of the intellectual property contained in the report remains with EcoSustainAbility unless otherwise agreed. The moral rights of authorship by Guy Chester and EcoSustainAbility are asserted.

The development of this certification program and criteria for sustainably farmed prawns is fundamentally based on existing intellectual property developed by EcoSustainAbility for the Australian Barramundi Farmers Association to establish the Australian Sustainably Farmed Barramundi Certification Program. EcoSustainAbility and ABFA have agreed:

1. ABFA engaged EcoSustainAbility to help develop the Australian Sustainably Farmed Barramundi Certification Programme including to develop the Certification Criteria and Certification Manual and associated documentation for this programme, which has and will continue to be revised and updated from time to time.

2. Ownership of copyright and moral rights for the Australian Sustainably Farmed Barramundi Certification Criteria and Certification Manual including all versions, updates and associated documents (the ‘Manual’) vests and remains with EcoSustainAbility.

3. EcoSustainAbility grants ABFA an irrevocable, royalty free, worldwide licence to use the (Australian Sustainably Farmed Barramundi Certification Program) Manual for any purpose. This licence is exclusive with respect to any use associated with the fish species Lates calcarifer (Barramundi) but otherwise non-exclusive.

4. ABFA will cooperate and assist EcoSustainAbility and the Australian Prawn Farmers Association (APFA) to develop a complementary certification programme for Australian farmed prawns and is so doing is prepared to consider the two certifications programmes having a shared and combined manual, management committee and certification panel.

5. Potential exists to extend this or a similar arrangement to other species or geographic region in future but EcoSustainAbility undertakes not seek to do so without the prior agreement and cooperation of ABFA.

Once completed, EcoSustainAbility will provide the Australian Prawn Farmers Association with a licence to use this report for the purposes of its Australian Sustainably Farmed Prawn Certification Program. Other uses prohibited without permission.

Work undertaken by EcoSustainAbility for the development of the Australian Sustainably Farmed Prawns Certification Program for the Australian Prawn Farmers Association has been funded by the Fisheries Research and Development Corporation. Use of the new intellectual property developed for this project is subject to the APFA-FRDC Agreement and the Terms and Conditions of EcoSustainAbiliy's engagement.

ABFA owns the registered trademark of the Sustainable Barramundi logo.

Once Finalised APFA will own and register the trademark of the Sustainable Prawn logo (once the draft is finalised)

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1.  Introduction ......................................................................................................................................... 4 Background ................................................................................................................................................................ 4 Sustainability Vision .................................................................................................................................................... 5 

2.  Certification Program Overview ........................................................................................................... 6 2.  Certification Program Overview ........................................................................................................... 6 

Program Management Manual ..................................................................................................................................... 6 Key Components ......................................................................................................................................................... 6 Key Steps .................................................................................................................................................................... 6 Administration ............................................................................................................................................................ 7 Integrity ...................................................................................................................................................................... 7 To Gain Certification ................................................................................................................................................... 8 Certification Application Process ................................................................................................................................. 8 Withdrawal of Accreditation ...................................................................................................................................... 10 

3.  Basis of Criteria ................................................................................................................................. 11 Development ............................................................................................................................................................ 11 

4.  Principles ........................................................................................................................................... 12 5.  Applicant Details ................................................................................................................................ 13 6.  Fundamental Eligibility ....................................................................................................................... 14 7.  Ecoefficiency Benchmarking .............................................................................................................. 15 

Ecoefficiency Benefits ................................................................................................................................................ 15 Ecoefficiency Indices ................................................................................................................................................. 15 Annual Survey ........................................................................................................................................................... 16 Continual Improvement ............................................................................................................................................ 16 

8.  Sustainability Management Checklist ................................................................................................. 17 Sustainability Commitment ....................................................................................................................................... 17 Local Setting ............................................................................................................................................................. 18 Design ...................................................................................................................................................................... 19 Monitoring ................................................................................................................................................................ 20 Environmental Management ...................................................................................................................................... 20 Training and Awareness ............................................................................................................................................ 22 Understanding Potential Impacts ............................................................................................................................... 23 Risk Management ..................................................................................................................................................... 25 Continual Improvement ............................................................................................................................................ 26 

9.  Sustainability Performance ................................................................................................................ 27 Farm Construction .................................................................................................................................................... 27 Ecoefficiency ............................................................................................................................................................. 27 Water ........................................................................................................................................................................ 28 Energy ...................................................................................................................................................................... 30 Soil ........................................................................................................................................................................... 31 Waste ........................................................................................................................................................................ 34 Chemicals ................................................................................................................................................................. 35 Noise and Odour ....................................................................................................................................................... 39 Vegetation and Wildlife ............................................................................................................................................. 40 Pond/Tank/Cage Management .................................................................................................................................. 41 Prawn Management ................................................................................................................................................... 43 Feed Sustainability .................................................................................................................................................... 44 

10.  Product Quality .................................................................................................................................. 47 Hygiene Food Safety ................................................................................................................................................. 47 Quality ...................................................................................................................................................................... 47 

11.  Risk Assessment ................................................................................................................................ 48 Introduction .............................................................................................................................................................. 48 

12.  Annual Awards ................................................................................................................................... 58 Prawn Farming Sustainability Program Award ............................................................................................................ 58 Certificates of Merit .................................................................................................................................................. 59 

Appendix One ............................................................................................................................................ 60 Eco-efficiency Survey ................................................................................................................................................ 60 

Appendix Two ........................................................................................................................................... 61 Example Policy .......................................................................................................................................................... 61 

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1. Introduction

Background Prawn Farming Certification Program The Australian Prawn Farmers Association has developed the certification program addressing economic, social and environmental aspects of sustainability including hygiene and quality aspects of production. The system is designed to include an approach which is applicable at the various scales of the industry and one that sets minimum standards whilst recognising best practice.

Beyond Compliance Aquaculture is an Environmentally Relevant Activity in Queensland and there are similar protocols in place in all other mainland states and the Northern Territory. The Prawn farming industry has had over 30 years of the discipline of complying with and reporting on performance of the required standards. The proposed approach now builds on compliance and statutory reporting, with a holistic approach to environmental responsibility (due diligence) beyond what is required by strict compliance.

Barramundi and Prawn Partnership The development of this certification program and criteria for sustainably farmed prawns is fundamentally based on existing intellectual property developed by EcoSustainAbility to establish the Australian Sustainably Farmed Barramundi Certification Program for the Australian Barramundi Farmers Association. ABFA and APFA have a partnership approach to the ongoing management of the certification program, the two programs each have specific criteria but will be managed together as one overall program.

Fisheries Research and Development Corporation. Work undertaken by EcoSustainAbility for the development of the Australian Sustainably Farmed Prawns Certification Program for the Australian Prawn Farmers Association has been funded by the Fisheries Research and Development Corporation.

Version Status This version is version 1.1 which is the draft of the criteria taking into account initial comments by the APFA Executive..

Criteria Approval Status:

The criteria are in draft form for consultation with stakeholders, the APFA board and for peer review. THE CRITERIA ARE NOT YET APPROVED BY THE APFA BOARD FOR IMPLEMENTATION

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Sustainability Vision The proposed vision is for:

The farming of Prawns in Australia is ecologically sustainable, ecoefficient and produces a quality product that is internationally competitive.

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2. Certification Program Overview

Program Management Manual The overall management of the program is governed by the Policies and procedures as set out in the:

Australian Sustainably Farmed Barramundi and Prawn Certification Program - Management and Policy Manual (version as adopted by ABFA and APFA boards from time to time).

This section provides an overview only of these detailed procedures.

Key Components The key components of the certification program are:

Annual Ecoefficiency Benchmarking

Certification Application, including the:

o Sustainability Checklist; and

o Risk Assessment

Certification offsite audit and onsite audit.

Annual return

Key Steps There are 6 major steps in the certification process:

Submission of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment along with other supporting evidence to support with the application for Sustainability Certification to the ABFA/APFA Sustainability Auditor.

An initial offsite assessment is undertaken by the approved ABFA/APFA Sustainability Auditor on the basis of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment and supporting evidence.

The Certification Panel considers the Auditors recommendation and confirms Certification, Certification Subject to Corrective Actions or declines Certification.

An onsite audit will then be required within two years of the initial certification.

An updated Sustainability Checklist and annual Ecoefficiency Benchmarking is required each year.

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An onsite audit is required every 2-3 years.

Awards Program As a further aspect of the program an annual awards system has been established to encourage and recognise best practice sustainability and ecoefficiency in Australian Prawn Farming.

Administration The A u s t r a l i a n S u s t a i n a b l y F a r m e d P r a w n C e r t i f i c a t i o n P r o g r a m ( S F P CP ) is administered by jointly between APFA and ABFA. ABFA and APFA have appointed:

A four member independent Certification Panel to confer Certification, suggest administrative policy and interpretation to the ABFA/APFA board and advise the ABFA/APFA board on annual awards.

A Sustainability Auditor to compile ecoefficiency benchmarking results, undertake an initial and then biennial offsite assessments, and as required on-site assessments.

Integrity The establishment of a Sustainability Certification program needs to have solid integrity in its processes and policies. There are a variety of global standards and guides which may apply. The Prawn and Barramundi certification program is relatively small, given the limited number of Prawn and Barramundi farms in Australia and as such complete application of these international norms for multi sector conformity assessment bodies would be beyond the resources of APFA and ABFA. This Certification program has been developed with reference to ISO 14024 Environmental labels and declarations Type 1 environmental labelling Principles and Procedures and ISO 17065 Conformity Assessment - Requirements for Bodies certifying products, processes and services.

Independence One key aspect of the integrity of the sustainability certification system is to have an independent assessment (the audit) and a separate independent Certification Panel. This model allows APFA and ABFA to own and administer the Sustainability Certification System whilst maintaining independence and integrity.

Appeals A formal appeals process allows an independent review in the event of any dispute.

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To Gain Certification Annual Ecoefficiency Benchmarking The annual ecoefficiency benchmarking need to be undertaken by each farm annually around October each year for the previous financial year. This allows an overall industry benchmarking and comparison for each farm against their previous years and within the industry.

The Auditor will send out the Ecoefficiency Benchmarking surveys and compile the results. NOTE: The auditor will keep the individual farm results confidential and reporting will report indices without identifying farms. Records will be kept to allow reporting back to each farm of comparison from their most recent years’ and previous year’s results.

Records will be kept confidential.

To avoid any doubt, the Ecoefficiency Benchmarking should normally happen in October each year, regardless of the anniversary of a farm’s certification process.

Certification Application Process Compliance To gain Sustainable Prawn Farming Certification a farm must meet all criteria unless the criteria is irrelevant and could not be applied to the farms type or situation. In the event that a farm considers it not practical or financially viable to meet or partially meet a criteria it may seek an exemption, but in such circumstance must still show how it achieves the relevant principle for that aspect.

Application by Farmer The application process involves submission to the APFA/ABFA Sustainability Certification Auditor of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment along with other supporting evidence to support with the application for Sustainability Certification to the APFA/ABFA Sustainability Auditor.

Supporting Evidence The Farm must also submit supporting evidence with the Certification Application assessment checklist. Such evidence may include (but is not limited to):

The Farm’s signed Sustainability Policy; Available evidence of ecoefficiency benchmarking records and calculations

of benchmarking data; Any environmental program, action plan or environmental management

system; Risk assessment and any contingency plans; Evidence of staff awareness and training (for all but micro-businesses with

few staff); and Evidence of compliance (e.g. copies of permits licences and any required

records, monitoring or reporting to authorities).

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In addition to documentation, photographs/maps/plans are highly desirable:

Photographs of the sites (also any plans of the site, ponds and buildings); Photographs of Chemical/fuel storage(s); Photographs of solid waste storage and disposal (if on site); Photographs of settlement ponds and discharge points; and Photographs supporting claims made in the checklist (e.g. energy

efficiency measures etc.). NOTE: The annual program will involve a mix of some on-site and some offsite audits such that every farm has an onsite audit every 2-3 years. For initial certification a farm may have an onsite or offsite audit.

Initial Offsite Audit An initial offsite audit is undertaken by the approved ABFA/APFA Sustainability Certification Auditor on the basis of the Ecoefficiency Benchmarking, Sustainability Checklist and Risk Assessment and supporting evidence.

The Auditor firstly ensures the application is complete and adequate supporting evidence is provided, if not, the Auditor send a request by email to the farm for further information.

The initial offsite audit involves thorough review of the application and supporting evidence and an interview with the farm manger and at least one key staff. Wherever practical the Auditor should seek other verification of the compliance with the SFBCP criteria.

The Auditor makes a recommendation to the Certification Panel.

Certification Panel The Certification Panel considers the Auditors recommendation and confirms Certification, Certification Subject to Corrective Actions or declines Certification. The Certification Panel does not undertaken any primary investigation but relies on the Auditors Report, in exceptional circumstances the panel may review the application and relevant supporting evidence.

Onsite Audit An onsite audit will then be required within two years of the initial certification. After this initial on-site audit a further onsite audit is required every 2-3 years. The Auditor makes a report which is considered by the Certification Panel and continued certification is offered (which may be conditional on corrective actions).

Annual Return An Annual Return and annual Ecoefficiency Benchmarking is required each year. Re-completion of the whole checklist is required every 2 years, along with a recertification process including an offsite assessment.

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Withdrawal of Accreditation The Certification Panel has a unique responsibility for withdrawal of certification, this may only be made by a decision of the Panel in consultation with the President of APFA. Withdrawal may only happen after an audit finds major non-compliance with the criteria and this cannot be resolved though urgent corrective actions.

Appeals - APFA President An accredited operator may appeal a decision to withdraw their certification in writing to the President of APFA. The President has a responsibility to make a decision within 28 days of receiving the appeal. The President must consult with the Certification Panel regarding the reasons for withdrawal of certification and may consult with the Auditor regarding policy and interpretation of criteria. The President’s decision is binding, and may not be appealed. The President must provide written advice of the decision to the appellant, the auditor.

NOTE: should the President have a conflict of interest in the decision, the Vice President, then Secretary then Treasurer of the APFA, the first without a conflict of interest has the responsibility to make the decision.

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The sustainably farmed certification program for prawns has been developed following the successful launching of the Barramundi certification program. The two programs each have specific criteria but will be managed together as one overall program.

3. Basis of Criteria

Development The development of the Criteria has been fundamentally based on the Australian Sustainably Farmed Barramundi Program. The criteria have been developed specific for prawn farming based on experience with prawn aquaculture over twenty years and late 2015 inspections and detailed interviews of seven farms (Gold Coast Aquaculture - Mossman, Andrejevic - Kurrimine Beach, Seafarm - Cardwell, Pacific Reef - Ayr, Monogold - Illbilbie, Eimo Aquaculture - Campwin Beach, Australian Prawn Farmers - Ilbilbie).

Global Benchmarking In order to ensure that Prawn farming in Australia is achieving best practice, extensive literature reviews were undertaken and criteria/best practices from a range of other fish farming and prawn farming accreditation and sustainability programs were reviewed. The following codes and guidelines have been reviewed to ensure the practices/criteria developed do represent a reasonable “best” practice for the industry:

ASC Shrimp Standard (published by the Aquaculture Stewardship Council, version 1.0 March 2014).

Sustainable Farming - Australian Prawn Farmers Association (http://apfa.com.au/prawn-farming/sustainable-farming/)

Environmental Standards - Australian Prawn Farmers Association (http://apfa.com.au/prawn-farming/environmental-standards/

Inside Prawn Ponds (undated booklet produced by APFA, CSIRO, QLD government, CRC for Aquaculture, AIMS and others, http://apfa.com.au/prawn-farming/ponds/)

Friend of the Sea Certification Criteria Checklist for Aquaculture Products – Marine Aquaculture (Friend of the Sea, 2010).

Prime Ministers Science, Engineering and Innovation Council, Sustainable Aquaculture (Report from Councils eight meeting in May 2002, report prepared by independent working party chaired by Professor Peter Hoj).

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4. Principles

The Australian Sustainably Farmed Prawns Certification Program is based on the following principles.

Sustainability Management Each farm makes a commitment to sustainability which is communicated to staff, visitors, suppliers and customers. Each farm is developed and managed to achieve sustainability within the local ecology. Each farm monitors their potential impacts upon the natural environment. Farms are located on approved and sustainable sites and new farms do not involve large scale disturbance of marine plants. New farms and expansions are designed to maximise ecoefficiency and the water quality of any discharges. Each farm has a specifically developed environmental management approach or documented environmental management plan which has strategies to minimise environmental risks and maximise sustainability. Farms ensure staff understand the obligations, priorities and strategies to achieve environmental compliance, sustainability and maximise eco-efficiency. Farms have identified key aspects of the local natural environment and potential impacts are understood. Farms have undertaken a specific risk assessment and have developed mitigation strategies and contingency plans which address all foreseeable events. Farms strive for continual improvement in sustainability and eco-efficiency. Sustainability Performance Construction and upgrading works on farms minimise disturbance or re-establish soils, erosion protection and drainage. Farms regularly review their eco-efficiency.

Water quality of receiving waters and any discharge waters is understood and potential effects minimised. Water use from groundwater and surface waters is minimised within the constraints of farm design and efficient operations. Energy use is minimised to achieve the best possible eco-efficiency within the constraints of farm design and efficient operations. Erosion, sedimentation and any acid sulphate soils are managed on site and there is minimal sediment loss or dust from the farm. Waste is minimised to achieve the best possible eco-efficiency within the constraints of farm design and efficient operations, waste disposal is sustainable. Chemicals are used on farm only where their (adverse and beneficial) affects are understood, use is approved, storage is safe and disposal of surplus product and containers is environmentally safe. Off farm noise and odour impacts on neighbours and any surrounding natural environment is minimised. Protected natural vegetation on farm and natural vegetation off farm is not disturbed, weeds on farm are controlled and impacts on wildlife minimised. Ponds and tanks are managed to maximise production, achieve the best possible eco-efficiency and minimise contaminants discharged. Farms manage prawn stocks to maintain prawn health, reduce disease risk and minimise escapes. Farms consider the sustainability aspects of feed used. Product Quality Farms process prawns and deliver to market in a manner which meets all food safety requirements. Prawns are of high quality, presenting undamaged and without any spot or discolouration.

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5. Applicant Details

Farm and Contact Information Details

Farm Name

Location

Physical Address

Lot/Plan number or description(s)

Postal Address

Email Address

Farm Telephone

Directors/Owners Mobile Telephone

Onsite Managers Mobile telephone (if different)

Farm Aspects (tick those that apply)

Pond Recirculation System Open System G Growout N Nursery H Hatchery

Growout Ponds Number Area ha

Settlement Ponds Number Area ha

Nursery (Larval Rearing) Tanks Number Volume kL

Hatchery Tanks Number Volume kL

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6. Fundamental Eligibility

The following are essential aspects for eligibility for certification.

Prawn Farm Applies Comment

The Farm grows prawns on a commercial basis for human consumption and/or is a hatchery/nursery for prawn larvae production for further growout of post larvae to saleable prawns (for human consumption).

ALL

Species grown are: Black tiger prawn Penaeus monodon Brown tiger prawn Penaeus escuentus Banana prawn Fenneropenaeus merguiensis Kurama prawn Penaeus japonicas

ALL

The commitments made against criteria are assumed to be existing and continuing. In some circumstances a farm will make a commitment to meet a criteria in the certification process, yet the process/activity has yet to be implemented. If this is the case the certification process must be considered a contract to implement the process/activity. The Farm commits to implement and undertake all processes and activities claimed in the checklist on an ongoing basis.

ALL

Approved Use Applies Comment

The Farm has all necessary town planning, coastal, marine and environmental approvals.

G N H

The Farm complies with all relevant environmental, marine, hygiene, workplace health and safety and industrial relations/ labour laws.

G N H

APFA Logo and Program Applies Comment

The Farm commits to only using the APFA “Tick” logo in accordance with the logo usage terms and conditions, and further will not otherwise represent that the farm has APFA or other endorsement apart from in accordance with the terms and conditions.

G N H F S

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7. Ecoefficiency Benchmarking

Ecoefficiency Benefits As all Prawn farmers know, a major cost of production is energy. Electricity, fuel, LPG gas, and ice are all forms of energy used on farms. A major benefit of increasing ecoefficiency on farms is to reduce operational costs. Reducing energy and waste is also likely to have major operational cost benefits as well. Water consumption tends to involve pumping on Prawn farms and this of course has a cost for the energy (usually electricity).

The is an old adage that what is measured gets managed. By undertaking annual benchmarking of a farms ecoefficiency it can allow individual farms to measure their ecoefficiency and allow APFA to present the industries overall ecoefficiency. Given the global focus on energy efficiency and carbon emissions even moves toward carbon neutral food it is important for individual farms and the industry overall to be proactive in this area.

Ecoefficiency Indices For Prawn Farms ecoefficiency indices have been developed, these are:

Energy - GJ/kg Prawns: Gigajoules of energy used per kilogram of prawn production (prawns sold at farm gate and increased/decreased biomass over the year). Farms input the kilowatt hours of electricity, litres of diesel etc. And using official rates the gigajoules are calculated.1

Carbon Dioxide kgCO2/kg Prawns: From the amount of energy used by a farm the carbon dioxide emissions can be calculated. The carbon dioxide emission are calculated based on the various type of energy used (e.g. electricity, diesel, gas etc.). 2

1 Energy consumption includes all farm metered kWh of electricity, diesel, petrol, LPG and liquid oxygen. The GJ per kilo of prawns (kWh electricity, LOX, diesel, petrol, LPG) have been calculated based on the following factors, Diesel: 38.68 GJ/m3 (1000L), Petrol 34.66 GJ/m3, LPG: 25.53 GJ/m3 2 The draft National Carbon Offset Standard2 defines scope 1, 2 and 3 emissions as:

Scope 1 emissions: The release of greenhouse gas into the atmosphere as a direct result of activities at a Facility. Emissions also include from the pond waters, from the fish and any wastes.

Scope 2 emissions: The release of greenhouse gas as a result of electricity generation, heating, cooling or steam that is consumed by a Facility.

Scope 3 emissions: The release of greenhouse gas into the atmosphere that is generated in the wider economy as a consequence of a facility’s activities but that are physically produced by another Facility.

In the above framework it is important to understand the diversity of Prawn farms. Hatchery(ies) and nursery(ies) have specific energy needs for tanks filters and oxygenation. Whereas intensive pond farming requires oxygenation mainly achieved using aerators. Pond farms also usually require pumping of water as surface or ground water intake water and occasional pumping of irrigation and discharge waters. As such the scope 1 emissions are: Diesel/petrol/LPG used by farms for vehicles, vessels, pumps, water heating and on-site electricity generation. Scope 2 emissions are: That from electricity consumption for pumps, aerators, icemakers and cold rooms, tanks heating and cooling. Scope 3 emissions include the bringing in of products with embodied energy, specific examples include: Ice, purchased by many farms and the consequential emissions are not included in the ecoefficiency survey results.

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Water kL/kg Prawns: The amount of water used for prawn production and running the farms is measured. This include potable, “tap” water and all groundwater and surface water used for ponds, nurseries etc.

Waste m3/kg Prawns: The waste leaving the site for disposal to landfill is the chosen indicator. Again the 2010 survey found this is often not recorded and farms will need to move towards recording this.

Feed kg Prawns/kg Feed: A common industry measure and used as confirmation of the farms food in food out ratio.

Future Indicators The above set out what APFA propose to measure for the years 2016-2021. During this time further work is proposed to address a better understanding of the carbon emissions from prawn farming in an effort to be able to present prawns to market as carbon neutral or very close to this. Two initiatives may be investigated:

1. Better accounting of what are called Scope 2 and Scope 3 emissions, including addressing transport and storage energy and carbon emissions.

2. Further, the sustainability of feed and carbon footprint from feed is an issue being addressed by other industries and should resources permit APFA will attempt to understand.

Annual Survey Each farm must submit an ecoefficiency survey report by 30 July each year, for the previous financial year. The data is submitted to APFA’s independent appointed consultant who will keep the data confidential and report each farm’s data back in the context of the overall industry results. Further the report will include a farms historical results so each can track their overall ecoefficiency year on year.

Continual Improvement An important aspect of the APFA Sustainability Certification program is for farms to strive for continual improvement in ecoefficiency. The are many potential initiatives for increasing ecoefficiency outcomes (and reduced operating costs!) for pond aquaculture, including:

Increasing re-circulation with bioremediation or indeed managing to have negligible discharge;

Acoustic feed system, reducing waste and the inherent energy and carbon emissions in the feed;

Use of variable speed, axial pumps for more efficient intake water pumping and/or recirculation;

Active aeration management (reducing aeration when not required, by manual or automatic methods).

Farms are encouraged to review opportunities and consider their application. Where a major capital expense is required, there may be government grants available or farms can phase in procedures or bring in efficient machinery as replacements become necessary. In many cases the investment in capital cost is paid back promptly and then provides farmers with potentially greater or more reliable profit margins!

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8. Sustainability Management Checklist

Sustainability Commitment Principle Each farm makes a commitment to sustainability which is communicated to staff, visitors, suppliers and customers. Criteria

Policy Applies Comment

The Farm has a written sustainability policy in place, signed by Owner(s) and/Director(s). NOTE See example at Appendix Two.

G N H

The Farm has reviewed the policy within the last three years.

G N H

The Policy includes a commitment to ecological sustainability, to understand potential impacts and minimise risks of impacts.

G N H

The Policy includes a commitment to ecoefficiency, to reduce energy and water consumption and minimise waste in accordance with best practice.

G N H

The Policy includes a commitment to purchasing eco-friendly and sustainable products where possible.

G N H

The Policy includes a commitment to purchasing locally as far as practicable.

G N H

The Policy includes a commitment to compliance with environmental, planning, safety and hygiene permits, licences and regulations.

G N H

The Policy includes a “good neighbour” approach, recognising aspirations and concerns of neighbours through consultation and avoids practices with impacts.

G N H

The Policy includes a commitment to continual improvement, including adopting or trialling emerging best practices.

G N H

The Policy is posted in a prominent place(s) on the farm at locations(s) where visitors, staff, customers and suppliers may read it.

G N H

The Policy is reviewed at least once a year, resigned and dated by the Farm owner or at least one Director.

G N H

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Local Setting Principle Each farm is developed and managed to achieve sustainability within the local ecology. Criteria

Local Environment Applies Comment

The local environment and its conservation, ecological, social and cultural significance is understood.

G N H

NOTE The following are not criteria but outline the local setting for consideration in assessing the above and other criteria.

The local ecological environment includes: Coastal, dunes, lagoon, mangroves River, lake Wetland Forest/rainforest Coral reef National Park, Marine Park, reserve World Heritage Area Ramsar listed wetland Declared fish habitat area Endangered/migratory species habitat

G N H

The local social and cultural environment includes:

Other farmland/rural land use Urban/residential land Commercial, retail, industrial land Local village, town Park, sports fields, public open space Public beach, esplanade, island Indigenous community

G N H

Consider the immediate farm neighbours and the greater precinct.

Location Applies Comment

The site is approved by local planning, coastal, marine and environmental zoning and regulations.

G N H

New sites (after 2016) have not involved clearing (other than for pipelines/drainage channels and utilities) of mangroves and other marine wetlands. Sites have not involved reclamation of tidal areas or wetlands.

G N H

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Design Principle New farms and expansions are designed to maximise ecoefficiency and the water quality of any discharges. Criteria

Design Applies Comment

Overland flow does not enter ponds or tanks.

G N H

Discharge points are located to maximise dispersion, minimise impacts on hydraulics of receiving waters and disturbance to marine/aquatic ecosystems.

G N H

Ponds/tanks are above the 1:50 year flood level. Tanks are located such that they will not float or lift in a 1:50 year flood.

G N H

Ponds have adequate overflows or spillways to cope with major rainfall events (whilst still allowing some freeboard and with mechanisms to prevent escape of prawns).

G N H

Ponds have an arrangement that allows complete drainage if required.

G N H

Ponds are orientated/designed in relation to the prevailing wind direction(s) to avoid wave fetch and downwind bank erosion. If not, or for larger ponds, banks are stabilised to avoid erosion.

G N H

Initial design avoids (where practicable) disturbance to acid sulphate soils, or there is an Acid Sulfate Soil management plan in place.

G N H

Ponds are impervious (minimal outflow/inflow seepage) and there is a low likelihood of ground water contamination.

G N H

NEW FARMS: Ponds and sediment ponds are designed to ensure recirculation is maximised (with allowance for seasonal variation of saline intake and rainfall salinity consideration etc.).

G N H

The above is applicable to new farms.

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Monitoring Principle Each farm monitors their potential impacts upon the natural environment. Criteria

Monitoring Applies Comment

Where required statutorily, monitoring of the local environment is undertaken (e.g. water quality monitoring of receiving waters, ground water levels).

G N H

Photographic reference points are established and photographs taken annually or seasonally of the immediate environment (i.e. adjoining wetland, discharge creek, treatment pond, pond banks, waste disposal areas, outdoor fuel and chemical stores etc.).

G N H

Rainfall records are kept for the farm.

G N H

Best practice is to undertake a range of local environmental monitoring whether or not required by permits and licence conditions, the scale of the farm and the significance of the local environment will determine the resources and importance of this.

Environmental Management Principle Each farm has a specifically developed environmental management approach or documented environmental management plan which has strategies to minimise environmental risks and maximise sustainability. Criteria

EMP Applies Comment

An environmental management approach is developed and implemented to minimise risks and maximise sustainability (including eco-efficiency).

G N H

Larger farms (more than ten staff) have a specifically prepared EMP. For smaller farms this Certification Manual, the environmental compliance and monitoring register and the risk assessment may form the basis for an environmental management approach.

G N H

Best practice is to have an Environmental Management Plan which is written to meet all aspects of environmental due diligence and is fully implemented.

Suggestions and Complaints Applies Comment

Staff, suppliers and any contractors are encouraged to make

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suggestions to increase eco-efficiency and sustainability or reduce the risk of environmental harm.

G N H

G N H F S

A system is in place to receive, record and respond to complaints from staff, contractors, suppliers, neighbours and community stakeholders.

G N H

A complaint register (which may be part of a more general log book, running file or diary) is kept.

G N H

Incidents and Corrective Action Applies Comment

There is an incident register:

For farms with less than five staff this can be in a log book.

For larger farms there should be a separate incident report form and register.

G N H

There is a corrective action process in place:

For farms with less than five staff this can be in the form of notices on a notice board with a copy held on a file (where all staff can access).

For larger farms there should be a separate corrective action form with sign off by the initiating staff member, the farm manager and at least one company director and/or owner.

G N H

Incident Reporting Applies Comment

There is a process to evaluate the potential for environmental harm or non-compliance with environmental licences and permits in the event of an incident.

Reporting is made when statutorily required or environmental harm may occur.

G N H

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Records Applies Comment

Records on monitoring and compliance are kept for at least five years.

G N H

An Environmental file/register is kept and contains: Copies of all permits, licences and government agency

correspondence The Farms sustainability policy Copies of government environmental agency guides

to best practice. Monitoring information Training records Environmental complaints The Risk Assessment Any Environmental Management Plan Any contingency plans Material safety data sheets for all chemicals

G N H

Monitoring and compliance records should be kept for as long a possible... review of records a decade old can allow better management and detect changing environmental conditions.

Training and Awareness Principle Farms ensure staff understand the obligations, priorities and strategies to achieve environmental compliance, sustainability and maximise eco-efficiency. Criteria

Training and Awareness Applies Comment

All staff know the overall environmental commitment and understand the responsibilities for environmental compliance and environmental protection relevant to their duties.

G N H

For larger operations, best practice is a formal, documented training program with job duty statements, training materials and records of training. Such a program is required for more than twenty staff and desirable for more than ten staff.

G N H

Smaller farms with few staff need to have a general program between supervisors and staff to ensure the training and awareness is undertaken.

G N H

Staff are specifically advised and are aware of the farms

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Sustainability Policy. G N H

Staff are encouraged to report environmental incidents and make suggestions for environmental, sustainability and ecoefficiency improvements.

G N H

Understanding Potential Impacts Principle Each farm monitors their potential impacts upon the natural environment. Criteria

Water Quality Applies Comment

Where there is any discharge of wastewater or effluent from the farm, there is some form of receiving water quality assessment.

G N H

The potential assimilative capacity of receiving waters has been judged (e.g. by the relevant government environmental agency during farm approval) as being able to accept the quality and quantity of wastewater/effluent/nutrient/sediment discharge

G N H

Guidance: Discharges from a prawn farm could have the potential impact on receiving water quality as there are contaminants which include:

nutrients (most as particulate nitrogen and phosphorous from organic material including prawn faeces, algal cells and macrophytes);

dissolved metabolic products from prawn faeces and waste/unused feed and suspended solids. Potential impacts which need specific consideration include turbidity (with consequent issues of light attenuation in receiving waters; and

dissolved oxygen (both through releases of water with higher or lower dissolved oxygen than receiving waters; and through release of water with biological oxygen demand or chemical oxygen demand which affects DO in receiving waters.

Best practice involves a monitoring program which allows background or control site monitoring (i.e. a spatial or temporal control) and “impact” monitoring to detect any significant change in receiving water quality.

Hydrology Applies Comment

The farms hydrology is understood and potential impacts on drainage patterns and surface water volumes and quality have been considered.

G N H

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Groundwater Applies Comment

If any ground water (bores) are used for water supply the levels of groundwater on site and near the supply bore are understood and monitored to ensure an ongoing sustainable supply, including making provision for environmental requirements even in foreseeable dry/drought periods.

G N H

If there is use of salt water in ponds and tanks, there is monitoring of groundwater salinity, at least on an annual basis. Measures are taken to ensure ponds remain impermeable and saltwater is unlikely to infiltrate to groundwater.

G N H

Aquatic/Marine Plants Applies Comment

Locally occurring aquatic and marine plants are known and the potential effects on local native aquatic and marine vegetation is minimal.

G N H

Practices are in place to ensure any disturbance to marine and aquatic plants is minimised and that exotic/weed marine/aquatic plants are not introduced to nearby natural systems.

G N H

Fauna Applies Comment

Local populations of wildlife are understood, particularly any endangered or migratory species.

G N H

Local populations of predator species (e.g. birds, crocodiles etc.) are understood.

G N H

There should not be a need for farms to engage any major outside expertise (such as consultants or scientists) however to local population (particularly any endangered wildlife on farm should be broadly monitored with seasonal surveys or a notebook kept of

sightings etc.

Odour Applies Comment

Local sources of odour (other than the farm) are known and the local situation with regard to odour is understood (in order to place any odour issues from the farm in a local context).

G N H

There can be substantial issues for nearby affected neighbours that are unrelated to the farm, e.g rotting seaweed beds on a nearby foredune).

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Noise Applies Comment

Local sources of noise (other than the farm) are known and the local noise environment is understood (in order to place any noise issues from the farm in a local context).

G N H

Risk Management Principle Farms have undertaken a specific risk assessment and have developed mitigation strategies and contingency plans which address all foreseeable events. Criteria

Risk Assessment Applies Comment

A risk assessment has been undertaken which considers the likelihood, magnitude and reversibility of impacts after practical mitigation strategies has been developed.

See Risk Assessment Proforma at Section 11.

G N H

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Contingency Planning Applies Comment

There are contingency plans in place for foreseeable (even if unlikely) events and practical strategies have been devised to minimise farm production losses and environmental impacts.

G N H

Contingency planning considers:

Power failure (onsite and from grid) Pump and/or aerator failures Filter blockages Contamination of pond water and disease

outbreaks. Excessively high or low groundwater Flood and storm rainfall Cyclonic winds and storm surge Fire Chemical spillage Drought

G N H

Any plant, machinery, vessels or products required for immediate use or during periods of inaccessibility (such as flood/cyclone) to implement contingency plans are held on farm.

G N H

Continual Improvement Principle Farms strive for continual improvement in sustainability and eco-efficiency. Criteria

Best Practices Applies Comment

The Farm operations are regularly reviewed with a view to adopting current best practice for ecoefficiency, sustainability and farm productivity.

G N H

Within the capacity of the Farms resources, new techniques are trialled and support is given to research programs.

G N H

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9. Sustainability Performance

Farm Construction Principle Construction and upgrading works on farms minimise disturbance or re-establish soils, erosion protection and drainage. Criteria

Minimising Disturbance Applies Comment

The construction of the farm should aim to minimise soil and drainage pattern disturbance. In most cases (other than minor works) a soil and water management plan is necessary.

G N H

Prevent overland flow from entering the disturbance area (e.g. use cut off drains and bunds).

G N H

Minimise erosion and ease rehabilitation by stripping and storing topsoil (away from waterways).

G N H

Location, design and construction of coastal support infrastructure, minimises disturbance to coastal processes and the littoral zone.

In the case of existing farms, the above applies for new construction and upgrading.

Ecoefficiency Principle Farms regularly review their eco-efficiency. Criteria

Annual Assessment Applies Comment

There is an ongoing internal ecoefficiency assessment of key indicators for energy, water, waste and feed inputs.

G N H

There is an annual assessment of ecoefficiency which involves benchmarking against industry averages.

G N H

Inputs Applies Comment

Ecoefficiency assessment includes all energy use, including electricity, diesel, petrol, LPG and liquid oxygen.

G N H

Ecoefficiency assessment includes quality and quantity of feed.

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G N H

Ecoefficiency assessment includes assessment of water consumption.

G N H

Ecoefficiency assessment includes waste production.

G N H

Ecoefficiency assessment includes water discharge and net nutrient discharge (best practice).

G N H

Outputs Applies Comment

Ecoefficiency assessment is calculated on inputs per kilogram of prawns produced at farm gate.

G N H

Ecoefficiency assessment includes the calculation of greenhouse gas emissions from the farm (up to the prawns leaving the farm gate).

G N H

Other international standards, such as the Salmon Aquaculture Dialogue currently propose to go even further and propose to require documentation of the greenhouse gas emissions of the feed used to produce fish according to ISO 14040-14043 (ISO1997). The SAD may require that the scope of such a life cycle assessment include growing, harvesting and transportation of raw materials (vegetable and marine) to the feed mill and processing at the feed mill (although it does not require life cycle assessment of vitamin and trace elements inputs). APFA intends to work with the major feed suppliers and may consider requiring an understanding of the greenhouse gas emissions of feed inputs by 2020.

Water Principles Water quality of receiving waters and any discharge waters is understood and potential effects minimised.

Water use from groundwater and surface waters is minimised within the constraints of farm design and efficient operations. Criteria

Receiving Waters Applies Comment

When statutorily required, receiving water quality is monitored.

G N H

When not statutorily required, but there are likely to be discharges annually or more frequently, receiving water quality is monitored at least quarterly (parameters include salinity, pH, turbidity and dissolved oxygen where relevant).

G N H

Where ponds contain saltwater and groundwater is fresh or brackish, there is at least quarterly monitoring of groundwater

G N H

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salinity.

Water Harvesting and Use Applies Comment

Where surface water is used, extraction only occurs in places and at rates approved. Creek and wetland water levels are monitored quarterly.

G N H

Where ground water is used, extraction only occurs in places and at rates approved. Bore levels are monitored quarterly.

G N H

Monitor and record the volume and where practical and/or statutorily required the water quality parameters of intake waters.

G N H

Water Conservation Applies Comment

Ponds and tanks are managed to minimise water use within the constraints of the design.

G N H

Potable water from a utility provider is not used for site irrigation.

G N H

Within the constraints of the design, recirculation, rather than discharge is maximised.

G N H

Discharge Applies Comment

All discharges are approved and planned.

G N H

Discharges do not result in any irreversible or long term increase in nutrients, phytoplankton, suspended solids or salinity levels of receiving (surface or ground) waters outside of the initial mixing zone (in the vicinity of the discharge point).

G N H

Production, treatment and storage tanks/ponds/dams are managed to ensure foreseeable rain events will not result in unplanned discharges.

G N H

When required, discharge water quality is monitored and only complying effluent is released off-farm.

G N H

Environmental agencies are advised where there is a major or regular minor exceedences of volume or quality of discharge

G N H

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waters.

Discharges to receiving waters (creeks etc.) do not occur at times of low flow or incoming tidal flow when water quality impacts and bank erosion may occur.

G N H

Where practicable maximise re-circulation of waters in order to minimise discharges.

G N H

The volume and where practical and/or statutorily required the water quality parameters of discharge waters is monitored and recorded.

G N H

Unless statutory requirements are stricter foreseeable, rain events should be considered to be at least a 1 in 3 year rainfall event.

Energy Principle Energy use is minimised to achieve the best possible eco-efficiency within the constraints of farm design and efficient operations. Criteria

Aeration Applies Comment

Energy efficient paddlewheels are used.

G N H

Aeration aims to ensure dissolved oxygen remains at or above 4 mg/L, additional aeration above this level is avoided.

G N H

Best practice is to have real time monitoring which allows automatic or remote control of aerators to minimise unnecessary aeration.

G N H

Pumping and Filtration Applies Comment

Pumps have been specifically sized and the type is fit for purpose and efficient for its use.

G N H

Energy efficient pumps are used (e.g. axial flow) and/or variable speed where appropriate. If older pumps are in operation, pumps are replaced with more energy efficient pumps as they come out of service.

NOTE: If energy efficient options are not used to replace older pumps, the payback period of more energy efficient pumps must have been assessed and be more than half the expected life of the replacement pump.

G N H

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Pumping and Filtration Applies Comment

In Tank systems consider use of drum filtration.

N H

Filters are sized and design to ensure capture of unwanted material and allow efficient flow rates.

N H

Lighting Applies Comment

Energy efficient lighting is used.

G N H

There is no light pollution off site.

G N H

Security lighting is minimised and the practicality of movement controlled security lighting has been assessed.

G N H

Heating Applies Comment

Heat recovery is used from groundwater, refrigeration compressors wherever financially viable.

N H

Heat pumps are used instead of element style heaters wherever possible.

N H

LPG is used for any specific heating where this is more energy efficient than electric heat pumps or elements.

N H

Diesel is not used for any specific heating unless the net carbon emissions are less or other heating methods are impractical.

N H

Soil Principle Erosion, sedimentation and any acid sulphate soils are managed on site and there is minimal sediment loss or dust from the farm. Criteria

Erosion and Sedimentation Applies Comment

Undertake any new works and construction in accordance with any erosion and sediment control plans required by permits and licences.

G N H

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Erosion and Sedimentation Applies Comment

Minimise erosion and sedimentation by: Limiting the area of disturbance.

Reducing overland flow though disturbed areas.

Stockpiling topsoil (and store in a bunded or silt fence enclosed area).

Implementing erosion control through use of mulching, hydromulching, seeding, and erosion control matts.

Minimise erosion of drainage lines through use of channel protection (e.g. concrete lining), rock rip rap etc. Protect natural drainage lines at the outflow of concentrated stormwater.

Use silt fences, bunds, hay bales, rock check dams and cross drains to ensure silt is not transported to natural watercourses and/or offsite.

G N H

There is no evidence of ongoing gulley, rill or sheet erosion on site or there is an active erosion control program to repair.

G N H

Pond walls subject to wave action from prevailing winds have adequate erosion protection.

G N H

Aerators are placed to avoid scour and erosion of pond walls.

G N H

Discharge channels are lined or managed to ensure there is no ongoing erosion (if needed line below water line and vegetate or protect batters above water line).

G N H

Water velocity in discharge channels is minimised to reduce erosion potential.

G N H

Pond wall batters and caps are vegetated or otherwise protected against erosion.

G N H

Farm discharge points adequately protect against scouring of beds and banks of waterways/drainage lines.

G N H

Acid Sulfate Soils Applies Comment

The likely presence of acid sulfate soils is known.

G N H

Any major disturbance of acid sulphate soils is subject to an acid sulphate soils management plan in accordance with QASSIT guidelines (or other locally approved guidelines).

G N H

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The excavation and disturbance of acid sulfate soils is minimised.

G N H

Any disturbed soils are managed with burial, neutralisation, submersion or other treatment before oxidation and acidification can occur.

G N H

Any leakage of acid leachate is prevented, contained and/or treated.

G N H

Where there are acid sulfate soils known to exist there is an understanding of any groundwater and surface water level issues which could result in drying out and acidification of soils. Steps are taken to avoid acidification.

G N H

The Queensland Acid Sulfate Soils Investigation Team have a range of guidelines for soils management and analysis.

Dust Applies Comment

Farm management practices avoid the creation and release off-farm of dust.

G N H

In dry conditions, major works such as dry pond management and sediment removal/stockpiling is undertaken using methods to avoid dust creation.

G N H

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Waste Principle Waste is minimised to achieve the best possible eco-efficiency within the constraints of farm design and efficient operations, waste disposal is sustainable. Criteria

Minimise Applies Comment

Whenever possible materials are purchased in bulk containers, or if possible in re-useable/refillable containers.

G N H

Feed is purchased in the largest bulk containers possible, or recyclable/reusable feed containers are used.

G N H

Records of putrescibles, non-recyclable and recyclable waste that leave the farm are kept.

G N H

Re-Use and Recycle Applies Comment

Ensure general waste streams are separated and where recycling is undertaken/collected by local government dispose of recyclables (glass, plastic containers, paper etc.) to the recycling system.

G N H

The Farm has identified opportunities for beneficial re-use of wastes and works to ensure these wastes are so used (e.g. sediments for fertiliser, re-use of feed bags etc.).

G N H

All green waste is composted on site.

G N H

Corpses from any prawn mortality are composted on site.

G N H

Waste oil (from farm machinery, vessels and generators etc.) and is collected and disposed of to oil recycling facility.

G N H

Sustainable Disposal Applies Comment

Avoid use of on-site landfill for all wastes except dead prawns, green waste and sediment/sludge.

G N H

Chemical containers (e.g. pesticide containers) are treated as regulated/toxic wastes and disposed of to appropriate local government managed landfill/disposal points.

G N H

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Sustainable Disposal Applies Comment

Dry and wet cell batteries are treated as regulated/toxic wastes and disposed of to appropriate local government managed landfill/disposal points.

G N H

Sediment Applies Comment

Sediment build up is minimised with adequate aeration, pond circulation, stocking densities and feed management.

G N H

Sediment is stored and disposed of appropriately, away from overland flows and in an area where any leaching of nutrients will not enter surface waters off-farm.

G N H

Best practice is on-site reuse of sediment (e.g. placement on pond batters for top dressing etc.)

G N H

Chemicals Principle Chemicals are used on farm only where their (adverse and beneficial) affects are understood, use is approved, storage is safe and disposal of surplus product and containers is environmentally safe. Criteria

Water Quality Applies Comment

In establishing initial and ongoing water quality and bacterial floc/bloom, only the following are used:

fertilizers (e.g. urea, phosphates, mono-ammonium phosphate);

soil conditioners (lime hydrated or agricultural and gypsum);

molasses; food grade dye; hydrogen peroxide; and agents to manage pH (sodium percarbonate, caustic

soda and bicarbonate of soda).

Chemicals restricted for use by the Australian Pesticides and Veterinary Medicines Authority may only be used for Prawn pond aquaculture where the AVPMA has issued a minor use permit to the National Aquaculture Permit. As at early 2016 the NAC hold minor use permits for hydrogen peroxide and formalin.

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Water Quality Applies Comment

Antifouling paints (containing tributyltin, copper or algaecides) are not used on any structures, floating plant or vessels in ponds.

G N H

Animal Husbandry Applies Comment

Chemical use for animal husbandry is minimised and storage and use are in accordance with manufacturers guidelines.

Chemicals restricted for use by the Australian Pesticides and Veterinary Medicines Authority may only be used for Prawn pond aquaculture where the AVPMA has issued a minor use permit to the National Aquaculture Permit. As at early 2016 the NAC hold minor use permits for hydrogen peroxide and formalin.

G N H

Growth hormones are not used in growout.

G N H

Antibiotics (e.g. OTC, oxytetracycline) are only used where necessary for disease control (not used prophylatically).. Use is minimised and dosage rates as per regulator, manufacturer or veterinarian advice.

G N H

Only hormones and antimicrobials approved for use for Prawn production (by the relevant state/territory or Australian governments) are used. As at early 2016, none are approved.

G N H

Best practice is to take part in the annual national residue survey. (NOT MANDATORY FOR CERTIFICATION)

G N H

Herbicides/Insecticides Applies Comment

Where herbicides and insecticides are necessary, only non-residual (biodegradable) products are used (e.g glyphosate based herbicides).

G N H

Herbicides and insecticides are used strictly in accordance with manufacturers recommendations, application rates are kept to a minimum required and procedures are in place to avoid overspray into farm ponds/tanks and natural waterways.

G N H

DDT and other toxic and/or persistent insecticides are not used.

G N H

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Cleaning and Disinfection Applies Comment

Surfactants, corrosive and oxidising cleaners are used sparingly if required for essential farm operations to avoid potential impacts on pond/tank water quality and release to natural waterways.

G N H

Refrigerants Applies Comment

Where there are refrigeration systems (e.g. for icemakers, cold rooms, heat pumps) they are maintained to ensure no release of gas.

G N H

Maintenance of refrigerant systems is undertaken by qualified technicians and involves complete gas recovery. Any on-site refrigerant gas storage is in a secure area and only qualified technicians are allowed to use.

G N H

Refrigerants (including the older chlorofluorocarbons and newer replacement gasses such as R22 are ozone depleting substances and must be handled with zero release techniques, recovering old gasses and avoiding inadvertent release during operation and maintenance. Following the ban on chlorofluorocarbons (CFCs) and hydro chlorofluorocarbons (HCFCs), substances used as substitute refrigerants such as fluorocarbons (FCs) and hydro fluorocarbons (HFCs) have also been having ozone depleting properties (albeit less than the CFC’s).

Knowledge Applies Comment

The material safety data sheet (MSD) should be kept on site for all chemicals.

G N H

Best practice is to have a copy of the MSDS near to the chemical storage (essential) and also a folder of all MSDS’s in the office for reference.

G N H

Staff know the environmental and occupational safety aspects.

G N H

Storage Applies Comment

Chemicals are stored in accordance with the Material Safety Data Sheet.

G N H

Fuels and oils in small (20L or smaller) containers are kept in a roofed, bunded area and drums for ready decanting are located on drip trays.

G N H

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Bulk fuels and oils are kept in bunded areas, preferably roofed. Storage is in accordance with AS 1940-2004.

G N H

Where there is any transfer of fuels and oils (other than in <25L tanks or drums, securely capped) there is a spill kit held nearby.

G N H

Australian Standard 1940 provides guidance on storage and handling of bulk fuels and oils.

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Noise and Odour Principle Off farm noise and odour impacts on neighbours and any surrounding natural environment is minimised. Criteria

Noise Applies Comment

Where there are noise limits on permits and licences, these are complied with.

G N H

Generators, blowers and aerators, machinery, vessels and vehicles have adequate sound suppression (insulated enclosures, mufflers etc.) to avoid noise impacts on neighbours and nearby natural habitats.

G N H

Where practical vegetated buffer zones, buildings and berms are used to buffer obtrusive noise from any nearby noise sensitive places.

G N H

Noise sources are located away from neighbouring noise sensitive places (e.g. generators are not next to neighbouring residences).

G N H

When unusual activities which may create excessive noise are to be undertaken they are planned to be undertaken during normal day time/ weekday business hours and affected neighbours are advised and consulted.

G N H

Odour Applies Comment

Consider the potential impact of odour on nearby odour sensitive places (given prevailing winds).

G N H

Minimise odours from sediments and drying vegetation by the use of cover or burial.

G N H

Pond sediments are dried out prior to removal/disturbance.

G N H

Sediments likely to be malodorous are not disturbed when winds could spread odour and affect neighbours.

G N H

Odour from any disposal of dead prawns after minor or major deaths is minimised though appropriate location of disposal pits (away from odour sensitive places) and soil covering of prawn corpses.

G N H

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Vegetation and Wildlife Principle Protected natural vegetation on farm and natural vegetation off farm is not disturbed, weeds on farm are controlled and impacts on wildlife minimised Criteria

Native Vegetation Applies Comment

Where there is (adjoining) off-farm native vegetation there is no ongoing disturbance of vegetation (especially where is it protected e.g mangroves). Consider the risk of fire, weed invasion, sedimentation, salinity during risk assessment.

G N H

Where there is any statutorily protected vegetation on farm (such as a mangrove area, wetland, remnant vegetation etc.). This is protected and all disturbance is avoided.

G N H

Riparian vegetation on farm is not disturbed and where necessary rehabilitated to protect drainage systems.

G N H

Where there are any coastal or marine plants on farm, disturbance is avoided (and only occurs with any required permits).

G N H

Weeds Applies Comment

Any declared or noxious weeds are controlled as a matter of priority.

G N H

The introduction of topsoil, mulch, straw and hay avoids the introduction of weeds and undesirable plants.

G N H

Where there is a choice, low impact techniques are used for weed control (e.g. non-residual herbicides etc.).

G N H

Wildlife Applies Comment

Where there is likely to be any rare or endangered wildlife likely to be present on the Farm, mechanisms are taken to minimise impacts on the wildlife.

G N H

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Predator Management Applies Comment

Physical barriers are used as far as practical to avoid predation and wildlife becoming accustomed to prawns in their diet.

G N H

Culling of predator species only occurs with approval of wildlife management agencies.

G N H

For bird predation use the following measures only as appropriate:

Overhead netting of cages, tanks, ponds Overhead wires Waterline level nets Repellent sound emissions Repellent light emissions Predatory images or models Hides

G N H

If crocodiles affect the farm:

If occasional, undertake once off removal in collaboration with the State wildlife management agency or their approved handler.

If regular develop exclusion approaches, including if an ongoing constant issue, fences.

NOTE: Crocodiles are not so much a predator of prawns once in ponds, however they do enter ponds and pose a workplace health and safety risk!

G N H

Pond/Tank/Cage Management Principle Ponds and tanks are managed to maximise production, achieve the best possible eco-efficiency and minimise contaminants discharged. Criteria

Pond Structure Applies Comment

Ponds are essentially watertight with impermeable banks and bottoms with adequate lining and/or compaction being maintained when maintenance occurs.

G N H

Drains are managed to avoid any ongoing erosion and discharge of sediment.

G N H

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Pond Structure Applies Comment

Overland flow does not enter ponds.

G N H

Protect ponds walls from erosion caused by wave setup and aerator/circulation induced scour and erosion.

G N H

Each pond has a dedicated monk/drain to the main draingae channel so that it can be isolated and rained in the event of a disease outbreak.

G N H

Pond /Tank Water Quality Applies Comment

Ponds/tanks are managed to maximise prawn health and production AND to ensure discharges are minimised and of acceptable water quality.

G N H

Food conversion rates are maximised. Feed type is considered and fish in- fish out is minimised as far as practical.

G N H

Aeration/oxygenation of ponds is adequate.

G N H F S

Stocking densities are determined in consideration of available aeration, water exchange requirements and feed quality.

G N H

Algal and bacterial bloom is managed to avoid disease and maximise water quality of discharge waters.

G N H

Understand intake water quality as in some cases intake waters can have elevated nutrients, particulates and/or salinity.

G N H

Water quality of the ponds and tanks are a major focus of prawns husbandry. In terms of environmental sustainability, the critical aspect is the quality of discharge waters and the minimization of energy and food inputs.

Treatment Ponds Applies Comment

Where the farm is designed and operated to have treatment ponds there are treatment ponds (usual practice is treatment pond area is 20+% of production pond area).

G N H

Where macrophytes and other marine plants are used for treatment ponds, these are not weeds nor have the potential to become invasive downstream.

G N H

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Treatment Ponds Applies Comment

Treatment ponds are managed and monitored for their ongoing capacity to cope in relation to biomass and sludge build up. Planning is in place for the potential need for sludge removal and or harvesting of plants.

G N H

Best practice is to ensure the beneficial re-use of harvested aquatic plants from treatment ponds (this can range from ornamental use of lilies to producing fertiliser).

G N H

Prawn Management Principle Farms manage prawn stocks to maintain prawn health, reduce disease risk and minimise escapes. Criteria

Harvesting Applies Comment

Harvesting mechanisms are undertaken to reduce erosion disturbance of sediments (particularly if harvest involves wastewater discharge).

G N H

Harvesting methods ensure no escapes.

G N H

If drain harvesting is used, ensure erosion protection of receiving water courses; ensure pond/tank water quality is acceptable.

G N H

If pond sediments are disturbed during trap, trawl or net harvesting, turbid waters settle in the pond or settlement pond prior to discharge.

G N H

Escape Prevention Applies Comment

There are mechanisms in place to ensure there is no escape of cultured prawns at any life stage from the farm.

G N H

Pond/tank discharge structures have appropriate sized screens, mesh or gravel filtration to avoid escapes.

G N H

Pond/tank discharge screens/mesh are regularly maintained.

G N H

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Escape Prevention Applies Comment

Pond walls and tanks should be above 1 in 100 year flood levels.

G N H

Best practice involves the use of strainer dams, the installation and maintenance of gravel filtration/nets or screens on pond discharge structures and chemical treatment of water released from hatcheries.

G N H

Disease and Parasites Applies Comment

Procedures are in place to treat any disease and parasites to avoid release to the natural environment.

G N H

Maintain adequate pond/tank water quality to avoid disease.

G N H

Ensure stocking densities are not excessive.

G N H

Undertake regular monitoring of prawns to gauge existence or levels of disease.

G N H

Quarantine affected ponds/tanks, dry and treat (e.g. lime of ponds and sterilisation of tanks) prior to restocking after major disease outbreaks.

G N H

Any disease affected prawns (including larvae) are not sold or released into the wild

G N H

Any disease affected prawns (including larvae) are not sold or released into the wild

G N H

Where statutorily required, disease specimens are collected and appropriate authorities advised.

G N H

Malachite green is not used for protozoan control.

G N H

Disease and parasites are usually actively managed to maximise farm productivity. The environmental concern is any release of the disease/parasite or control chemicals to the natural environment.

Feed Sustainability Principle Farms consider the sustainability aspects of feed used.

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Criteria

Feed Applies Comment

Feed is used which minimises impacts:

Content from wild caught fish meal is minimised (and only used where the fish meal is sustainable).

Vegetable protein content is maximised.

Vegetable oils are maximised over animal sourced oils (including fish oil).

G N H

Use feeds with a low level of phosphorous, low dust/fines and have a high percentage of digestible ingredients.

G N H

Feed is stored in a cool dry location (and not stored for too long). (This maximises food conversion rates and minimises losses of solids/nutrients which adversely affect water quality).

G N H

Non-locally endemic live feeds are not used.

G N H

Guidance: The sources of fish meal and fish oil in feed is a significant sustainability issue. For other marine farmed fish species the environmental certification requirements require that any wild caught component of feed (fish oil/fish meal) must be from an accredited, sustainable fishery. The Marine Stewardship Council provides certification of some fisheries which are used in fish meal/ fish oil sources. Further traceability and chain of custody is a global issue for farmed prawn feed.

It is expected that the sources of fish meal and fish oil in feed for Australian aquaculture will be more strongly and sustainably managed in coming years and as such it is proposed that a review of the requirements for certification be made by 2018 with a target of introducing a minimum standard by 2020 (e.g. 50% of fish oil and fish meal inputs to feed are form a certified sustainably managed fishery or are bycatch/by products).

The International Fishmeal and Fish Oil Organization Global Standard for Responsible Supply provides current global guidance on the issue.

The Salmon Aquaculture Dialogue require a Forage Fish Dependency Ratio calculation which involves the percentage of fish meal and percentage of fish oil which is derived from a pelagic fishery (e.g anchoveta). The ratios to be calculated use standard factors and the calculation of a farm fish in – fish out (economic feed conversion ratio). APFA plan to monitor industry standards in this regard and move towards such calculations as global practices settles on an appropriate methodology and once Australian feed manufacturers can provide input data.

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Genetics Applies Comment

Strategies are in place to optimise genetic resources and broodstock to maximise production success and to ensure ongoing genetic diversity.

Document spawning rates of individuals. Swap broodstock with other operators. Replenish broodstock with other operators. Rotate broodstock. Maintain records of broodstock and progeny

distribution. Note: some hatcheries rely on wild caught brood stock whilst others have multi-generation captive broodstock. Use of wild caught ensures ongoing genetic diversity.

G N H

.

PL Source Applies Comment

NOTE APFA intends to set a date from which, only PL's sourced from an APFA certified hatchery are used.

G N H

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10. Product Quality

Hygiene Food Safety Principle Farms process prawns and deliver to market in a manner which meets all food safety requirements. Criteria

Food Safety Applies Comment

Prawn processing facility and procedures meet food safety laws and standards (including the processing facility meets Hazard Analysis Critical Control Point (HACCP) approved factory standards).

G

Ice used is made from sterilised potable water.

G

Plants and equipment coming into contact with prawns during harvest and handling between the pond and processing facility (e.g. harvest bins etc.) are corrosion resistant, smooth and easy to clean and disinfect.

G

Quality Principle Prawns are of high quality, presenting undamaged and without any spot or discolouration. Criteria

Prawn Quality Applies Comment

Prawn appearance and physical attributes: whole undamaged prawns; clean, with a hard shell; no black spot; no discolouration; no offensive or spoilage odour present.

Product complies with attributes and/or QIS Score completed. Note of compliance to follow shipment from Farm.

G

Prawns comply with food safety standard limits for antibiotics, chemicals and contaminants.

G

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11. Risk Assessment

Introduction This Risk Assessment Proforma is for Prawn Farms to achieve certification. Farms that have en established Environmental Management System approved and being implemented (or on Integrated Environmental Management System or Site Based Management Plan under Queensland legislation) which lists and evaluates potential environmental risks do have to complete the following proforma risk assessment.

However it is recommended that all farms have such a risk assessment in place.

Environmental and Business Risks An important aspect of the risk assessment is that usually preparedness substantially reduces the risk. The focus in the proforma is on the risk of environmental harm, however farmers are encouraged to use the process and proforma to address all risks and include mitigation strategies to protect both the environment and reduce business risks.

Definitions ASPECT: include activities, events and potential impacts, ensure accidental and emergency situations are considered. The table includes some potential aspects which should be considered, however some aspects may not be relevant and in almost all cases more aspects not included in the example list will need to be included.

POTENTIAL IMPACT: describe the potential ecological, social, cultural and economic impacts, only where impacts are adverse. Where ecological harm may occur, note this as POTENTIAL ECOLOGICAL HARM.

RISK MINIMISATION/MITIGATION STRATEGIES: describe what can be done to minimise the risk and if it occurs to mitigate the potential impacts. Note, it is vital to consider the ability to know that the event/impact has occurred, for example if there is no monitoring of a settlement pond discharge, an impact may be occurring long before it can be mitigated. Put simply, risk minimisation is preventing the event, risk mitigation is preventing harm/fixing the harm if the event occurs.

LIKELIHOOD: The likelihood of the risk occurring and the potential impacts occurring after risk minimisation and mitigation should be identified, this should be UNLIKELY, POSSIBLE, LIKELY. To avoid any doubt, this should be considered as likely over a long term (say at least ten years) and must consider accidental and emergency events for which the organisation cannot control the probability of the event.

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SEVERITY AND REVERSIBILITY OF IMPACT: The impact severity should be considered as to the level of effect on the ecology, social, cultural or economic environment. A social or cultural impact which causes local short term discomfort but no long term impact is not severe, similarly, a minor release of untreated sewage to a river during a flood event is likely to be assimilated within the aquatic ecology without causing great water quality change and is not severe. Whereas an impact which causes health impacts on local people, or the long term release of partially treated sewage which changes a coral reef structure to algae dominated communities is a severe impact. This last example also is one which is very hard to reverse. An oil spill in an alpine lake would also be almost irreversible. Whereas a release of contaminated storm water to the municipal sewage treatment system is not severe and a reversible impact as it can be treated further downstream. To avoid any doubt, an impact on any natural ecosystem, protected area or wildlife species of conservation concern should be considered severe. Severity should be described as MINOR IMPACT, MODERATE IMPACT, SEVERE IMPACT and also as REVERSIBLE OR NOT REVERSIBLE

RISK EVALUATION: The overall risk evaluation shall be set out as MINOR RISK, MODERATE RISK AND HIGH RISK. Obviously many factors must be taken into account to determine the overall risk, as a guide any risk which is possible or likely and has a severe and/or irreversible impact should be considered SIGNIFICANT.

RISK ASSESSMENT CONSIDERS STRATEGIES TO MINIMISE RISK: To avoid any doubt, the risk assessment is undertaken on the basis of risk minimisation/mitigation strategies which are implemented by the organisation.

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Aspect Potential Impact(s) Risk Minimisation/Mitigation Strategy(ies)

Likelihood Severity and reversibility of impact

Risk Evaluation

Example only: Fuel spill whilst fuelling small outboard powered boat used for water sampling.

Petrol and oil contamination of nearby mangroves or creek.

Only fuel using hand pumps from drums on the ramp in good weather, in other cases bring outboard fuel tanks to workshop to fill. Have a absorbent pads ready near the ramp for fuel spill clean up. Train all vessel operators and maintenance staff in fuel handling and spill clean up procedures.

Small spills are LIKELY A major spill is UNLIKELY

A small spill is MINOR IMPACT and REVERSIBLE, a major spill is SEVERE IMPACT and NOT REVERSIBLE

MODERATE RISK

Staff Environmental Awareness

Risk factors to consider: Number of staff and degree of

supervision of staff; Turnover of staff, especially itinerant

staff; Previous experience of staff; and Risks of ecological harm from staff

actions (e.g. low for farm hand but high for engineer responsible for bulk fuel handling or duty manager)… consider other aspects of risk assessment in evaluating this.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Cyclone or Monsoon

Risk factors to consider: Major flooding, raised groundwater,

need to discharge without adequate time in settlement ponds etc.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

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King Tides

Risk factors to consider: Local flooding, raised groundwater,

intake and or discharge when estuarine creeks turbid.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Drought

Risk factors to consider: Need to discharge when local water

course little flow or turibid/poor water quality.

Ability to obtain intake water.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Pump/aerator or power failure

Risk factors to consider: Management of water not meeting

discharge criteria.

Disposal of any dead prawns.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Disease

Risk factors to consider: Disposal of any dead prawns.

Need drain pond (which may exceed discharge quantity or quality limits)

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

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Quarantine requirements.

Algal Bloom

Risk factors to consider: Management of discharge water

quality.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Freshwater Resources

Risk factors to consider: Source of water supply. Downstream ecological and

community needs for the water. Impacts during seasonal dry periods

and irregular drought conditions.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Groundwater

Risk factors to consider: Abstraction causing low groundwater. High groundwater . Impacts during seasonal dry periods

and irregular drought conditions.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Stormwater, erosion and siltation

Risk factors to consider: Pollution of storm water by oil, grease,

litter and sediment. Erosion and sediment, and sensitivity

of watercourses to siltation.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

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Erosion being repaired and siltation controls to prevent effects on water courses.

Ongoing washdown of external paths, areas etc. and vehicle washing without treatment of storm water.

High risks particularly if there is a sensitive aquatic ecosystem downstream (e.g. wetland, mangroves, coral reef, lake etc.).

Any form of untreated waste water enters storm water flows.

Ongoing erosion with sediment being to watercourses off-site.

Storm water is concentrated form a large area into a discharge to a watercourse without erosion protection of the water course..

NOT REVERSIBLE

Local Conservation Issues

Risk factors to consider: Sensitivity of local ecosystems to

impacts from the farm and conservation significance of the natural systems.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Wildlife

Risk factors to consider: Potential for wildlife disturbance and

potential to affect feeding, socialisation or breeding activity.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

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Potential need for removal/control of predators (birds, crocodiles etc.).

NOT REVERSIBLE

Odor

Risk factors to consider: Odors from dead prawns, pond

drainage, sludge, settlement ponds etc. affecting neighbors..

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Noise

Risk factors to consider: Noise impacts on neighbors.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Wastewater

Risk factors to consider: Volume and character of wastewater. Level of treatment. Sensitivity of receiving environment. Other pollutant input to the receiving

environment. Wastewater from treatment baths,

nurseries etc. containing chemicals

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Waste

Risk factors to consider: Types of waste generated.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

MINOR RISK

MODERATE RISK

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Final disposal destination of waste. Low Risk Good recycling, composting and

disposal of other waste to a well managed municipal land fill.

Toxic/regulated wastes such as batteries and chemical containers.

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

HIGH RISK

Chemical Storage and Handling

Risk factors to consider: Quantity and toxicity of substances. Proximity of sensitive ecosystems or

people. Low Risk Small quantities of harmful substances

are stored in accordance with instructions.

Bulk quantities of harmful substances are stored in bunded, roofed areas etc.

Material safety data sheets are not on-site.

Storage of harmful substance(s) are not in accordance with local regulations, international standards or material safety data sheets.

Spill clean up and containment equipment availability.

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Waste Toxic Substances

Risk factors to consider: Disposal of batteries, waste oil (from

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

MINOR RISK

MODERATE RISK

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machinery and kitchens), sewage treatment sludge’s, toxic chemical containers etc.

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

HIGH RISK

Other -_______________________

Risk factors considered: ________________

________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Other -_______________________

Risk factors considered: ________________

________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Other -_______________________

Risk factors considered: ________________

________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Other -_______________________

Risk factors considered: ________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT

MINOR RISK

MODERATE RISK

HIGH RISK

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________________ REVERSIBLE

NOT REVERSIBLE

Other -_______________________

Risk factors considered: ________________

________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

Other -_______________________

Risk factors considered: ________________

________________

UNLIKELY

LIKELY

MINOR IMPACT

MODERATE IMPACT

SEVERE IMPACT REVERSIBLE

NOT REVERSIBLE

MINOR RISK

MODERATE RISK

HIGH RISK

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12. Annual Awards

In addition to the Annual APFA awards, from 2017 there will be a further major award to recognise excellence in sustainability and ecoefficiency, that is;

Prawn Farming Sustainability Program Award.

Prawn Farming Sustainability Program Award The purpose of this award is to promote sustainability and ecoefficiency innovation and sharing of information between farms. Only farms that have achieved Certification are eligible for the awards and they must have had a recent audit to ensure the overall sustainability of the farm and integrity of the awards system and the Certification program.

This award is to be presented to the farm that has exhibited innovative best practice sustainability (and/or) ecoefficiency in the farming of prawns and which provides a model for the prawn farming industry in Australia.

Farms that have lodged their ecoefficiency benchmarking survey shall be automatically eligible and the award will go to the farm that has shown b e s t innovative or sustainability and/or ecoefficiency practices for the year.

As part of their role, the A P F A Sustainability consultant shall s e e k evidence of farms best practice and success in achieving ecological sustainability and/or ecoefficiency and make a recommendation each year to the Certification Panel.

The Certification Panel will act as the award judges and may ask a farm for verification of sustainability outcomes. Where a farm has not been specifically audited the consultant must interview the farmer and may request records to ensure veracity of the benchmarking results.

An award does not need to be made every year, and should the Certification Panel decide that no farm meets the key criteria no award will be issued. Similarly, if in any one year two or more farms have exceptional nominations the Certification Panel may chose to award two (or more) Awards in any one year, however this should be only in exceptional circumstances.

The Certification Panel must make a specific citation for each award and recommend this to the APFA board for endorsement prior to issuing the award. The chair of the Certification Panel shall communicate directly with non-affected board members in the event that a board member is a potential recipient or in any other way has an overt conflict of interest in the recommended award.

A logo (similar to the Certification logo) with the words “Prawn Farming Sustainability Program Award 20XX" will be provided and may be used by the farm on its product for two years immediately following the granting of the award. The farmer may use the award on farm and product promotion material and at their own cost provide retailers with small stickers with the logo for consumer packaging.

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Certificates of Merit In addition to the Prawn Farming Sustainability Program Award, the Certification Panel may issue Certificates of Merit to Farms which are identified through the sustainability award p rocess . The criteria should be as above but with a lower level threshold and issued for encouragement and/or recognition rather than full attainment. There are no limits to the number of certificates of merit that may be issued in any one year.

Farmers may also nominate key staff for their role in suggesting or implementing sustainability and/or ecoefficiency initiatives for a Certificate of Merit. In exceptional circumstances the APFA Auditor may make a personal nomination of a farm employee. The Certification Panel will consider these and may interview the nominee.

The Certification Panel must make a specific citation to go with each Certificate outlining what sustainability or ecoefficiency initiative the certificate of merit has been awarded for.

No logo or seal is applicable and farms may only list in promotional material that the farm was awarded a certificate of merit and the citation for the award.

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Appendix One

Eco-efficiency Survey

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Appendix Two

Example Policy

Example Prawn Farm Sustainability Policy Example Farm is a Prawn Farm located 20km east of Smalltown, on the western bank of the Flowsalot River. There are mangroves one kilometre downstream and a melaleuca forest flanks our northern boundary. The Farm has 24 ponds covering 12 hectares.

Example Farm is committed to ecological sustainability we attempt to understand potential impacts and minimise the risks of any impacts.

Example farm has held an environmental permit for twelve years and we are committed to compliance with environmental, planning, safety and hygiene permits, licences and regulations. This Policy is one part of our Environmental Management Plan.

We are proud to have achieved Sustainable Prawn Farming Certification and willingly provide our Ecoefficiency Benchmarking data and Certification Annual Returns and reports.

Example Farm is striving to improve our ecoefficiency, to reduce energy and water consumption and minimise waste in accordance with best practice, whilst maximising production effectiveness and ensuring we maintain prawn health and farm productivity.

Example Farm purchases eco-friendly and sustainable products where possible. Further, we purchase locally as far as practicable.

Example Farm has a “good neighbour” approach, we recognise talk to and understand the aspirations and concerns of our neighbours and avoid odour, dust and noise impacts as far as possible.

Wherever we can we look for ways for continual improvement, including adopting or trialling emerging best practices.

Signed

XXXX

Director and Owner

Smalltown Prawns

Xx Month 20XX

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