SAAS COVID-19 Notification · 2020-04-24 · Author: P. Scott Social Accountability Accreditation...

Author: P. Scott Social Accountability Accreditation Services Issue: 6

Approval: J. Brookes SAAS Notification 2020:6 Coronavirus Temporary Instruction Effective: April 24, 2020

SAAS COVID-19 Notification Issue: 6 Date: Friday April 24, 2020 To: All SAAS Accredited Certification Bodies (CBs) From: John Brookes, Executive Director, SAAS, New York RE: COVID-19 Temporary Instruction This Notification (Issue 6) supersedes and replaces our earlier notification of March 27 (Issue 5) and previous notifications. 1) General In light of the continuing global Coronavirus pandemic that is now affecting countries worldwide, this temporary Instruction applies to the maintenance of all SA8000 Applicant and Certified Clients globally. The instructions outlined in this Notification temporarily override the requirements defined in SAAS Procedure 200 clause 16.1.6b) for SA8000 certifications. Appendix A “Specific Recommendations for Certification Bodies During COVID-19 Pandemic” provides guidance and recommendations for CBs conducting on-site audits. From time to time, extraordinary events may occur that are beyond the control of a Certification Body (CB) or Accreditation Body (SAAS), such as the current global coronavirus emergency. During these events, SAAS and SAAS-Accredited CBs have a joint responsibility to uphold the credibility of accredited SA8000 certifications by demonstrating appropriate due diligence and reasonable actions to mitigate program risks. In doing so, however, SAAS and CBs must recognize human risks and respect the rights of individuals who may potentially be impacted by the event. To this end, we wish to advise the following: 2) Actions By SAAS a) SAAS personnel are not conducting any on-site accreditation oversight activities globally until such time as this Temporary Instruction is modified or rescinded.

Note: Presently, SAAS aims to resume on-site accreditation activities in countries where its Auditors reside (for example China, India, Pakistan) in the third quarter of 2020. International travel by SAAS staff remains unlikely until the last quarter of 2020 (at the earliest).

b) SAAS personnel are in the process of conducting remote reviews with all CBs individually regarding their programs to maintain certifications in locations impacted by COVID-19 travel restrictions (in accordance with this document).

Social Accountability Accreditation Services

(SAAS)

A division of Social Accountability International

(SAI)

SAAS EXECUTIVE DIRECTOR

John Brookes

SAI BOARD OF DIRECTORS

Dan Henkle, Chair

Timothy Bishop

Dana Chasin

Tyna Coles

Joseph Iarocci

Nicholas Milowski

Steven Newman

David Pauker

Alice Tepper Marlin

SAI ADVISORY BOARD

Amy Hall, Chair

Luna Lee

Eileen Fisher, Inc. (USA)

Sunil Bhaskaran

Vinod Kulkarni

Tata Steel Ltd; Tata Motors Ltd (India)

Laura Chapman Rubbo

The Walt Disney Company (USA)

Annukka Dickens

HP, Inc. (USA)

Christian Ewert

Amfori (Belgium)

Andre de Freitas

Sustainable Agriculture Network (Costa Rica)

Anuj Jain

Shingora Textiles Limited (India)

Dirk Jeschke

Miele & Cie. (Germany)

Stefano Palmieri

Italian General Confederation of Labour (Italy)

Rossella Ravagli

Gucci S.p.A. (Italy)

Alice Tepper Marlin

Social Accountability International (USA)

Michael Toffel

Harvard Business School (USA)

Mary Watson

The New School (USA)

Lara White

Pawel Szalus

International Organization for Migration (Belgium)

(Organization for identification only)



This exercise should be completed by mid-May, 2020.

c) SAAS will review this Temporary Instruction at least every 2 weeks, but may amend or rescind it at any time to meet developing situations.

d) SAAS is also evaluating the possibility of its auditors performing ‘remote office audits’ and ‘witness site audits’ in lieu of regular ‘on-site’ oversight activities.

Note: Such remote SAAS audits would replace some, or all, of the SAAS-required CB oversight for 2020. Such remote SAAS audits will address not only the international travel restrictions, but will also significantly ease the CBs’ economic burden in these COVID-19 times by saving on travel/accommodation costs and auditor travel-day costs. We anticipate a clear directive on this issue by mid-May and commencement of SAAS remote audit activity during Q3 2020.

e) SAAS Market Surveillance Visits in India will resume when the situation in the country permits. The proposed 2020 program will become a combined 2020-2021 program. When this program resumes, a further notification will be sent to those CBs affected.

Note: SAAS was pleased to learn this week of India’s “Lockdown 2.0” arrangements permitting many organizations to resume economic activities (subject to social distancing and other controls). We are carefully monitoring the situation in India before resuming the MSV program there (which will not be until Q3 2020, at the earliest).

f) SAAS is delaying the introduction of Market Surveillance Visits in China and Italy until 2021 (at the earliest). A further notification will be sent to those CBs affected at that time.

3) Actions BY SAAS-Accredited CBs Globally (All Countries) a) Until this Temporary Instruction is amended or rescinded, SAAS strongly recommends that SAAS-

accredited CBs discontinue on-site SA8000 Initial Certification (Stage 1 and Stage 2), Surveillance, Recertification and Transfer Audits globally. Those audit activities routinely handled remotely (such as any report reviews, documentation reviews, nonconformity responses) should remain unaffected. Note: We continue to be encouraged by ongoing reports of a gradual improvement to the COVID-19 situation and associated risks posed to auditors in China and elsewhere. We understand that many certification bodies (CBs) have resumed on-site audit visits, however, on-site visits are not a mandatory SAAS requirement in any locality at this time. While SAAS is not in a position to prevent CBs conducting on-site audits, we urge extreme caution and due respect for the rights and concerns of auditors and client company staff. Please refer to section 4, below, for further information regarding resumption of audit and certification services.

b) In lieu of on-site visits, during the period that this temporary instruction remains in force, current SA8000 certifications for client organizations impacted under 3a) may alternatively be maintained as follows:

1. On-Site Audit Alternative Temporary Measure: From the date of this Temporary Instruction (and when the next on-site visit for each SA8000 certification client becomes due), each CB SHALL perform and document an off-site ‘Follow-up Review’ as defined in SAAS Procedure 200. This ‘COVID-19 Follow-Up Review’ SHALL be repeated every thirteen (13) weeks (or more frequently) during the life of this Temporary Instruction. Where appropriate, the CB auditor SHALL raise and review non-conformities in the normal follow-up manner. Any non-conformity finding demanding auditor review of on-site evidence prior to closure SHALL remain open until a satisfactory review



can take place during a future site visit. If a client organization business closes, making ‘COVID-19 Follow-Up Review’ impossible, this shall be recorded and followed-up periodically. If a client organization’s business remains closed thirteen (13) weeks after an audit visit was due, the CB shall suspend the client’s SA8000 certificate until such time as monitoring has been successfully resumed and satisfactory SA8000 performance demonstrated. A list of SA8000 certificate suspensions because of the COVID-19 situation shall be publicly available upon request as required by ISO17021-1:2015 Clause 8.1.2 b). Note 1: Follow-up reviews are intended to monitor ongoing certification and do not replace on-site audits. Any audits missed should be performed as quickly as possible when working conditions allow, and as dictated by future COVID-19 Temporary Instructions. Please refer to section 4, below, for further information regarding resumption of audit and certification services.

2. Recertification Alternative Temporary Measure: Unless otherwise amended by SAAS through a future Temporary Instruction, a full recertification decision may be deferred for a maximum period of six months from the due date. In the interim period (until such time as a recertification on-site audit is feasible and audit conclusions available), the CB SHALL issue a ‘Temporary’ SA8000 certificate. Such certificates SHALL be numbered and include a temporary suffix of “T” (to indicate an ‘Temporary’ certificate - e.g. Certificate # H4532T)

3. CB Management Oversight Temporary Measure: A report on the credibility of each of the CB’s SA8000 Certifications maintained under 3a) above SHALL be produced every 13 weeks. This report SHALL also include a review of the impact of the coronavirus on the CB, its Certified Clients, and their business. Reports SHALL be provided to authorized SAAS personnel upon request.

c) Potentially conflicting expectations: CBs are advised to also follow recommendations that may be issued by national and other applicable accreditation bodies, and by government authorities. Should a conflict with this instruction arise, please notify SAAS immediately.

d) SAI and SAAS have not yet authorized and do not presently recognize any remote SA8000 audit activities

conducted by CBs as being valid for certification purposes. In order to address those situations where a client is operational, but a CB auditor is unable to conduct an on-site audit, SAAS is presently evaluating the possibility of permitting CBs to conduct ‘remote audit’ processes in lieu of certain SAAS Procedure 200 ‘on-site’ expectations. To be recognized as valid for certification purposes, such audits must be conducted strictly in accordance with the SAAS-defined protocols, which will be published in early May.

Note: SAAS presently believes that (following a careful risk assessment) ‘remote audit’ activities should be viable for ‘routine surveillance’ and/or ‘recertification’ of clients that are well-known to the CB. SAAS will continue to consider the viability of CBs performing remote auditing for other activities within the audit cycle, however this is unlikely in the near future and is not an SAI or SAAS priority in the current situation.

e) Additional ‘General’ SAAS Procedure 200 and Procedure 201 Exceptions

1. SAAS Procedure 200 v4.2 Clause 9.1.1 b) – “Deviations from Procedure 200 Requirements”: This clause permits a CB to deviate from Procedure 200 requirements under exceptional situations. Certain recognized ‘deviations,’ common to multiple CBs, are outlined in the sub-sections below. Other minor deviations may be permissible. Please note that:



a. Significant deviations from Procedure 200 (except as authorized within this document or agreed in writing by SAAS Technical Director or Executive Director) will not be retroactively authorized/accepted by SAAS.

b. CB auditors are not permitted to deviate from SA8000 requirements/interpretations other than as explicitly authorized by SAI in the current version of the SAI document “Responding To COVID-19: Guidance for SA8000-Certified Organizations”.

c. If in doubt about a, or b, above, please contact SAAS in advance for clarification.

Rationale: The current COVID-19 emergency constitutes an exceptional situation.

2. SAAS Procedure 200 Clause 20.2.4 – “Audit Work Day”: Modified as follows until further notice: “CB auditor(s) SHALL work the same length of shift (or management working day - not less than 6 hours), as the client.”

Rationale: It is possible that due to a lack of orders, lack of workers, national or local government mandates, clients may be working less than an 8-hour day.

3. SAAS Procedure 200 Clause 11.1.4 – “Auditing All Shifts”: Modified as follows until further notice: “CB auditor(s) SHALL consider evidence of conformity for all shifts, but SHALL be physically on-site only during the normal day shift working hours.”

Rationale: Reduce infection risks.

4. SAAS Procedure 200 Clause 12.1.1 d) and 12.1.1 e) – “ Audit Team Composition”: Rescinded until further notice.

Rationale: Use of single auditor can reduce infection risks.

5. SAAS Procedure 200 V4.2 Clause 15.3.2 – “Opening Meeting Attendance”: Modified as follows until further notice: “Senior Management of the client organisation SHALL be requested to attend the Opening Meeting. Attendance should be limited to the bare minimum, ensuring that both management and worker interests are represented.”

Rationale: Reduction of non-essential attendees can reduce infection risks

6. SAAS Procedure 200 V4.2 Clause 15.9.2a) – “Closing Meeting Attendance”: Modified as follows until further notice: “Senior Management of the client organisation SHALL be requested to attend the Opening Meeting. Attendance should be limited to the bare minimum, ensuring that both management and worker interests are represented.”

Rationale: Reduction of non-essential attendees can reduce infection risks

7. SAAS Procedure 200 V4.2 Clause 16.1.2 (and references to ‘semi-announced visits’ elsewhere in Procedure 200) – “Semi-announced visits”: Modified as follows until further notice: “Whenever possible, CB shall perform on-site audit visits ‘semi-announced’ in accordance with Procedure 200 requirements. During the time of this COVID-19 emergency, however, if necessary due to COVID-19 restrictions, CB may perform ‘announced’ visits providing the reasons for this are documented within audit records.”

http://www.sa-intl.org/index.cfm?fuseaction=page.viewpage&pageid=1978



8. SAAS Procedure 200 V4.2 Clause 16.1.6 e) – “Combined Visit Effort”: Modified as follows until further notice: “In the case of a 6 monthly surveillance program ONLY, the audit effort of two consecutive COVID-19 ‘recovery audits’ (section 4.d, below, refers) may be combined (In lieu of applying this requirement).”

Rationale: Exceptional circumstances and reduced auditor availability (in some cases) demand a compressed certification program timeline.

9. SAAS Procedure 201A: 2015, Annex A, Clause 7.2.11.1 – CB observation of Auditors: Modified as follows until further notice: “The CB SHALL observe each of its auditors performing an SA8000 audit on-site at least once every 36 months. Witnessed audits by SAAS shall not satisfy this requirement. Such observations SHALL be conducted by Senior Lead Auditors, as identified in SAAS Procedure 201B.”

Rationale: 12 months to avoid the need for an extra CB person attending audit can reduce infection risks.

4) Certification Body ‘Return to Work’ Guidance

SAAS recognizes that some certification bodies (or affiliates thereof) continue to restrict audit and assurance activities (such as in Europe, the Americas, and in India); others (notably China, at present) are planning a gradual return to ‘routine’ CB operations. The guidance below is intended only for those undertaking a return to work. Please refer to Appendix A for further specific recommendations. a) SAAS cautions CBs that that the safety of staff and social distancing within the community and at clients’

premises is still important at this time. CBs need to carefully consider local and national government laws and regulations and plan for the risks before asking Auditors to travel and perform audits. Similarly, auditors and other CB personnel should not be forced to travel or work unwillingly under any circumstance. SAAS would like to remind CBs of the intent of the scope of SA8000 that this should apply to its staff as well as its clients: “………protect all personnel within an organisation’s control and influence who provide products or services for that organisation, including personnel employed by the organisation itself and by its suppliers, sub-contractors, sub-suppliers and home workers………”

b) When a CB, as advised by its governing board or relevant committee, (ISO/IEC 17021-1:2015 6.1.3 &

6.1.4 refer) determines that a full or partial return to work may feasible, it shall conduct a risk assessment to identify all SA8000 Certification risks involved with such a decision and shall specify controls/actions needed to mitigate residual risks. A record of the SA8000 Certification risk assessment (and any subsequent updates) shall be approved by the CB’s governing board or relevant committee and maintained for future review by authorized SAAS personnel upon request.

c) In those cases where residual risks are determined to be unacceptably high, CBs may maintain

certification assurance in accordance with 3b, above (until such time as this instruction is rescinded, or an updated CB risk assessment determines that the risk is acceptable).



d) In those cases where residual risks are determined to be acceptable, CBs should strive to ‘catch-up’ with

surveillance activities impacted by COVID-19 travel restrictions, completing all delayed surveillance audits in accordance with the originally planned certification plan timelines, by the end of the current certification year. If on a six-monthly surveillance cycle ONLY, surveillances may be combined if performed within 2 calendar months of resuming normal work.

e) Appendix A, below, outlines the minimum COVID-19 precautions that CB’s should adopt when returning

to perform on site audits. f) In the case of a first surveillance audit after a Stage 2 or Re-certification audit, a postponement of the

first surveillance audit should not exceed 6 months (12 months from date of initial certification). g) In case of subsequent surveillance audits, a postponement of the audit should not exceed 3 months.

Note: While SAAS prefers that subsequent surveillance and recertification activities be conducted in full, we are seeking to devise an equitable policy which may allow CBs to reduce subsequent audit time based (to some degree) on time spent conducting, and the results of, the alternative certification maintenance processes (see paragraph 3b, above). We anticipate this will be part of a future notification. Please be aware that when specifying these (and all) criteria, SAAS must represent the reasonable expectations of interested parties in these exceptional times, while remaining impartial with respect to CBs’ contractual and financial affairs.

5) Future Actions when this Temporary Instruction is Rescinded When this Temporary Instruction is rescinded, SAAS will issue a further instruction regarding our continuing accreditation oversight program and the actions required of CBs to bring certification clients back in line with Procedure 200 and other requirements.

Sincerely, John Brookes Executive Director SAAS



Appendix A. Specific Recommendations for Certification Bodies During COVID-19 Pandemic

I. CB Obligations to Staff (including auditors)

The following outlines the minimum expectations for a CB. Additional controls should be considered and added as determined by the CB’s risk assessment, or as stated by law. Please refer to WHO “Coronavirus disease (COVID-19) advice for the public” web pages, national government, and other reputable sources for further information.

a. Further to the outcome of CB’s risk assessment (as specified by SAAS COVID-19 Notification

requirement 4b, above), CB management should define, document, communicate,

implement and monitor company policies and requirements with respect to COVID-19 risks

and controls in the workplace (at both CB and client premises). It is recommended that CB

controls include, but not necessarily be limited to:

• Instructions and advice for staff who feel unwell or may have been exposed to

COVID-19. Staff must be symptom-free and no longer contagious before

returning to work (for guidance, see Figure 1).

• Requirements for personal hygiene (for guidance, see Figure 2).

• Requirements for social distancing. 2-metre minimum recommended (for

guidance, see Figure 3).

• Requirements and Instructions for use of personal protective equipment

(PPE).

• Requirements for regular and thorough cleaning of working surfaces etc.

• The right for a member of staff to remove themselves, without penalty or

disciplinary action, from any situation in which the above precautionary

controls are not effectively implemented.

• Other requirements, precautions and instructions promoted by government

and other relevant authorities.

b. Insofar as feasible, and as soon as feasible, facilitate COVID-19 testing (at company cost) to

all staff required to return to duty:

• Testing should be conducted prior to return and immediately thereafter (for

any potentially exposed staff) should potential COVID-19 exposure be

suspected.

c. Require staff to communicate to CB management prior to each workday and maintain

records:

• Current body temperature (as measured that morning).

• Self-declaration: ‘No COVID-19 symptoms observed.’

• Self-declaration: ‘No known exposure to person who may be infected by

COVID-19.’

d. Provide staff suitable equipment as follows and as required by law:

• Accurate body-temperature thermometer.

• Full Facemasks or disposable face mask – N95 or better, if possible.

• Latex gloves.

• Goggles.

• Soap for regular hand washing.

• Alcohol Gel/Liquid for hand sanitization.

https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public



II. Considerations When Planning On-Site Audits and Associated Travel/Accommodation

The following outlines the minimum expectations for a CB. Additional controls should be considered

and added as determined by the CB’s risk assessment, or as stated by law.

a. Audit Planning Considerations: During the audit planning process, the CB personnel should

determine, define, document and communicate (to auditors and client personnel) audit-

specific risks and required risk-mitigation controls. The following requirements/

restrictions/ expectations should be considered:

CB’s COVID-19 policies and processes;

General COVID-19 controls (in accordance with section I, above);

National and local COVID-19 legal and other requirements;

Transportation and accommodation provider policies and processes;

Client policies and processes.

b. Audit Plan: In addition to meeting audit plan requirements of SAAS Procedure 200, each

Audit Plan should address:

The importance of social distancing and that the audit team will be practicing social distancing during the audit.

Personal protective equipment (PPE) requirements (face masks as a minimum for all face to face interactions during the audit).

Personal hygiene.

Meetings/interviews to be held in rooms without recirculated air-conditioning and be

limited to no more than 3 persons at a time for 15 minutes maximum.

c. Additional Planning Controls

Long trips on public transport should be avoided.

Social distancing should be observed in all environments.

The use of recycled air conditioning in any shared space should be avoided.

Auditors should not share hotel rooms with each other.

Wherever possible, auditors should use their own transportation or a van service

provided by the CB or client (if possible, the windows of the transportation vehicle

should remain open).

III. Considerations When At The Clients’ Premises

The following outlines the minimum expectations for a CB. Additional controls should be considered

and added as determined by the CB’s risk assessment, or as stated by law.

a. Opening Meeting



Attendance should be limited to the bare minimum, ensuring that both management and

worker interests are represented.

During the Opening Meeting the CB Audit team and client company representatives should

discuss and agree the importance of adherence to COVID-19 controls throughout the audit (as

outlined above and communicated via the audit plan).

b. Audit Conduct

Auditors should ensure that they, and client representatives, adhere to ALL agreed controls.

Particular attention should be paid to:

Social distancing.

Personal protective equipment (PPE). Face masks as a minimum for all face to face

interactions during the audit.

Personal hygiene.

Meetings/interviews To be held in rooms without recirculated air-conditioning and be

limited to no more than 3 persons at a time for 15 minutes maximum.

c. Closing Meeting

Attendance should be limited to the bare minimum, ensuring that both management and

worker interests are represented.

d. Additional On-Site Controls

Social distancing, good hygiene, PPE and other required controls to be maintained at all

times, including factory tour, mealtimes, etc.

Auditors should avoid entering busy areas such as canteens, dormitories, crèches if

proper social distancing is impractical.

Auditors should use disposable latex gloves when handling equipment, documents etc.

CB/Auditors may promulgate (or accept) a jointly agreed declaration addressing further

specific controls such as:

o Willingness to undergo body temperature check;

o Absence of COVID-19 symptoms;

o No known contact with individuals having COVID-19 symptoms;

o No recent visits to, (or contact with another person known to have visited), a

COVID-19 containment zone or other specified COVID-19 ‘hotspot’;

o Other mutually agreed conditions/declarations, (such as those identified in the

paragraphs above).



Figure 1 – Typical COVID 19 Symptoms

Source: https://www.duluthnewstribune.com/lifestyle/health/5022312-What-symptoms-tell-you-and-why-they-arent-a-sure-thing

https://www.duluthnewstribune.com/lifestyle/health/5022312-What-symptoms-tell-you-and-why-they-arent-a-sure-thing



Figure 2 – Personal Hygiene Source: https://www.gov.sg/article/what-can-you-do-to-protect-yourself-from-covid-19

https://www.gov.sg/article/what-can-you-do-to-protect-yourself-from-covid-19



Figure 3 – Social Distancing

Source: https://www.shrm.org/resourcesandtools/tools-and-samples/pages/social-distancing-guidelines.aspx

https://www.shrm.org/resourcesandtools/tools-and-samples/pages/social-distancing-guidelines.aspx

SAAS COVID-19 Notification · 2020-04-24 · Author: P. Scott Social Accountability Accreditation...

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Transcript of SAAS COVID-19 Notification · 2020-04-24 · Author: P. Scott Social Accountability Accreditation...