On this page
- Understanding asc farm ohs requirements and risk assessment scope
- The hierarchy of hazard controls, PPE, and workplace facilities
- Emergency response, accident logging, and commercial diving rules
- Compliance matrix, execution procedure, and worked example
- Example
- Before your audit
- Questions people ask
- What are the main asc farm ohs requirements under Criterion 3.5?
- What hierarchy of controls must farms apply before issuing PPE?
- Are employees allowed to leave an unsafe workplace without permission?
- What records are required for commercial diving activities under Criterion 3.5?
- Reference documents
The short version
- Indicator 3.5.1 mandates a site-specific health and safety risk assessment approved by senior management following Appendix 3.4.
- Indicator 3.5.2 requires the person conducting the health and safety risk assessment to possess documented competencies and training.
- Indicator 3.5.3 guarantees any person freedom to remove themselves from unsafe situations without permission or fear of retribution.
Understanding asc farm ohs requirements and risk assessment scope
Understanding asc farm ohs requirements under Criterion 3.5 of the ASC Farm Standard mandates that aquaculture facilities establish a site-specific Health and Safety Risk Assessment, provide mandatory employee training, and implement systematic hazard controls. These rules apply to all workers on site to prevent workplace accidents, chronic injuries, and health hazards across every operational phase. Establishing a comprehensive occupational health and safety framework creates a secure work environment, reduces operational risk, and protects human welfare.
The scope of Criterion 3.5 encompasses all personnel working within the unit of certification, including permanent staff, temporary workers, sub-contractors, commercial divers, and visitors. Under Indicator 3.5.1, the facility must execute a site-specific Health and Safety Risk Assessment following the five-step method set out in Section 3.4 of Appendix 3. A member of senior management must formally approve the risk assessment, which must be reviewed annually, prior to starting new activities, following major employee feedback, after accidents or near misses, or when adding new production sites.
Under Indicator 3.5.2, the person conducting the risk assessment must possess documented competencies, relevant experience, and formal health and safety training. Furthermore, Indicator 3.5.3 establishes that any worker must be granted the freedom to remove themselves from an unsafe situation without seeking prior permission and without fear of retribution. This protection applies equally to the workplace and employer-provided accommodation, preventing management reprisals or subtle hostility against workers exercising safety rights.
Quality leads must ensure that occupational health controls align with broader operational procedures, such as integrating welfare monitoring when designing traffic light systems for ASC Farm Standard OWIs or verifying supplier safety risk assessments when documenting Appendix 14 conformance for pre-grow out sites. Under Indicator 3.5.4, the risk assessment must specifically evaluate hazards for pregnant employees or individuals with medical conditions, enforcing mandatory task adjustments and lifting restrictions to prevent physiological harm.
The hierarchy of hazard controls, PPE, and workplace facilities
Implementing effective hazard controls requires compliance managers to apply the five-level hierarchy of controls defined in the guidance for Indicator 3.5.12. Quality leads must prioritize elimination, substitution, engineering controls, and administrative controls before relying on Personal Protective Equipment. Personal Protective Equipment must be provided and maintained free of charge under Indicator 3.5.12, with management actively monitoring its proper and consistent use during hazardous tasks.
Section 3.4 of Appendix 3 outlines specific risk factors that the Health and Safety Risk Assessment must evaluate as a minimum requirement. These factors cover chemical and biological exposures, commercial diving, electrical machinery, compressed air, knife handling, fire hazards, and mechanical lifting equipment. In addition, Indicator 3.5.15 requires providing changing and washing facilities for personnel handling hazardous substances such as disinfectants, herbicides, pesticides, or vaccines.
Facilities provided for employee welfare must meet strict hygienic and structural standards across the site. Indicator 3.5.16 mandates providing clean, hygienic sanitary facilities with adequate privacy measures and gender separation where required. Furthermore, Indicator 3.5.17 requires providing safe, clean drinking water accessible to all workers free of charge, while Indicator 3.5.18 requires a clean area to prepare and consume food during breaks, including adequate shade in warm climates.
Important: Personal Protective Equipment must always serve as the final line of defence; management must demonstrate that elimination, substitution, or engineering controls were evaluated first.
Common finding: Risk assessments frequently fail to evaluate specific chemical exposures or commercial diving hazards listed in Section 3.4 of Appendix 3, resulting in audit non-conformities under Indicator 3.5.1.
Emergency response, accident logging, and commercial diving rules
Emergency preparedness and rigorous incident tracking form core components of a compliant health and safety management system. Indicator 3.5.8 requires displaying clear, understandable health and safety notices, instructions, and warning signs visibly throughout the facility in languages understood by the workforce. Under Indicator 3.5.9 and Indicator 3.5.10, clear emergency and fire safety procedures must be established, with escape routes, fire exits, firefighting equipment, and alarms clearly marked, unobstructed, and maintained in good working order.
Under Indicator 3.5.6, the unit of certification must maintain written records of all health and safety accidents and near misses, investigating root causes and executing corrective actions to prevent recurrence. Indicator 3.5.7 mandates reporting accident data to ASC following official data submission procedures via the MyASC portal. In the event of a work-related injury, Indicator 3.5.13 requires providing immediate first aid and professional medical access, while Indicator 3.5.14 requires covering all medical costs, transport, lost wages, and necessary repatriation for migrant workers.
When commercial diving operations occur, Indicator 3.5.21, Indicator 3.5.22, and Indicator 3.5.23 enforce specialized safety controls. Management must maintain a dedicated diving log recording all diving activities and personnel involved. Any person conducting commercial diving must hold accredited commercial diver certification and undergo annual medical examinations to confirm fitness to dive.
Tip: Schedule regular emergency fire and evacuation drills, retaining attendance logs and timing records to verify worker emergency awareness during external audits.
Compliance matrix, execution procedure, and worked example
Internal auditors and quality leads must evaluate health and safety controls against explicit standard indicators, maintaining verifiable documentation across all site facilities.
| Requirement | What the auditor checks | Evidence to have ready |
|---|---|---|
| Indicator 3.5.1 | Site-specific Health and Safety Risk Assessment approved by senior management following Appendix 3.4 | Signed HSRA document, annual review logs, and senior management approval records |
| Indicator 3.5.2 | Competency, experience, and formal training of the person conducting the HSRA | Trainer qualification certificates, training attendance logs, and CV records |
| Indicator 3.5.5 | Free-of-charge health and safety training delivered during remunerated working hours | Training schedules, attendance sign-off sheets, and native-language training materials |
| Indicator 3.5.6 | Written records of accidents and near misses with root-cause investigations and CAPs | Central accident register, near-miss logs, investigation files, and corrective action records |
| Indicator 3.5.12 | Provision and maintenance of appropriate PPE free of charge following hierarchy of controls | PPE inventory logs, purchase receipts, inspection records, and worker interview statements |
| Indicator 3.5.22 & 3.5.23 | Accredited commercial diver certifications and annual medical fitness certificates | Commercial diver certificates, daily diving logs, and annual medical clearance reports |
Establishing a compliant health and safety program requires quality managers to follow a standardized five-step implementation workflow:
- Appoint a competent person with verified health and safety qualifications to lead the site risk assessment under Indicator 3.5.2.
- Execute a site-specific Health and Safety Risk Assessment covering all risk factors in Section 3.4 of Appendix 3, obtaining formal senior management sign-off under Indicator 3.5.1.
- Implement hazard controls following the hierarchy of controls, providing required Personal Protective Equipment free of charge under Indicator 3.5.12.
- Deliver free, documented health and safety training to all workers in understandable languages during paid working hours under Indicator 3.5.5.
- Establish an active accident and near-miss log under Indicator 3.5.6, investigating root causes, applying corrective actions, and submitting confidential accident data to ASC under Indicator 3.5.7.
Note: Accident reporting under Indicator 3.5.7 is a confidential data submission to ASC via MyASC and does not involve public disclosure of personal employee information.
Example
A quality lead at an ASC-certified land-based trout farm prepares for a surveillance audit and reviews site safety logs. During an internal inspection, the quality lead notes that a processing worker slipped on a wet floor near the gutting table, resulting in a minor knee bruise. While immediate first aid was provided, the shift supervisor failed to log the event in the central register or conduct a root-cause investigation. Recognizing a non-conformity under Indicator 3.5.6, the quality lead logs the incident, investigates the root cause, and determines that an overhead drainage pipe was leaking onto the walkway. Management fixes the pipe, installs anti-slip floor matting as an engineering control, updates the near-miss log, and submits the updated accident report via MyASC under Indicator 3.5.7, ensuring full compliance before external auditor inspection. Similar to maintaining environmental compliance when classifying WUMs and meeting TSS limits under Criterion 2.6, thorough safety logging prevents operational lapses from escalating into major audit findings.
Before your audit
- Confirm that the Health and Safety Risk Assessment follows Appendix 3.4 and bears senior management sign-off.
- Verify that the person who conducted the risk assessment holds documented competencies and training records under Indicator 3.5.2.
- Check that written policies explicitly inform workers of their right to remove themselves from unsafe situations without retribution.
- Ensure hazard controls demonstrate application of the hierarchy of controls before relying on Personal Protective Equipment.
- Validate that all required Personal Protective Equipment is provided and maintained free of charge under Indicator 3.5.12.
- Review the accident and near-miss register to confirm that root causes were investigated and corrective actions implemented.
- Verify that commercial divers hold accredited certifications and current annual medical fitness clearances under Indicator 3.5.22 and Indicator 3.5.23.
Questions people ask
What are the main asc farm ohs requirements under Criterion 3.5?
The main asc farm ohs requirements under Criterion 3.5 mandate conducting a site-specific Health and Safety Risk Assessment approved by senior management, providing free employee training during paid working hours, enforcing the hierarchy of hazard controls, maintaining accident and near-miss logs, and providing appropriate Personal Protective Equipment free of charge.
What hierarchy of controls must farms apply before issuing PPE?
Under guidance for Indicator 3.5.12, farms must apply a five-level hierarchy of controls: 1. Elimination (physically removing the hazard), 2. Substitution (replacing the hazard), 3. Engineering controls (isolating workers from the hazard), 4. Administrative controls (changing work practices), and 5. PPE (protecting the worker with protective gear as a last resort).
Are employees allowed to leave an unsafe workplace without permission?
Yes. Indicator 3.5.3 explicitly requires that any person must be granted the freedom to remove themselves from an unsafe situation without seeking permission and without fear of retribution or penalty.
What records are required for commercial diving activities under Criterion 3.5?
Under Indicator 3.5.21, Indicator 3.5.22, and Indicator 3.5.23, farms must log all commercial diving activities, maintain lists of involved personnel, verify that divers hold accredited commercial diver certifications, and archive annual medical fitness certificates confirming divers are fit to dive.
Reference documents
- ASC Farm Standard V1.0.1A2 - August 2026
- ASC Farm Standard Interpretation Manual V1.0.1 - September 2025
- ASC Farm and Feed CAR V1.0 - May 2025
- ASC Requirements for Units of Certification V1.0.1 - July 2023
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