Prevent Excessive Working Hours Under ASC Feed Standard

Working hour regulations under ASC Feed Standard

The Aquaculture Stewardship Council established mandatory rules on working time, rest periods and overtime under Criterion 1.11 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads, human resources personnel and shift supervisors at certified feed manufacturing facilities. Feed manufacturers must ensure that regular working hours, overtime limits and daily rest breaks comply strictly with standard thresholds or national law. Conformity Assessment Body auditors inspect timecards, shift rosters, payroll records and production capacity calculations during certification audits.

Managing working time effectively prevents workplace fatigue, reduces accident risks and protects employee mental and physical health. The scope of Criterion 1.11 applies across the entire facility from ingredient receiving through processing to final product dispatch. In addition, working hour controls extend to young workers and children conducting light work under specific protective schedules. Failing to maintain accurate time records or exceeding weekly overtime limits indicates a non-conformity.

Regular working hour limits and shift exceptions

Indicator 1.11.1 establishes that regular working hours for adult workers aged eighteen and over must not exceed eight hours per day and forty-eight hours in a normal work week, excluding mandatory breaks. An exception permits exceeding eight hours on certain days by up to one hour if hours on other days are reduced, provided daily limits do not exceed nine hours. Another exception allows shift workers to exceed eight hours per day or forty-eight hours per week if the average over three weeks or less does not exceed eight hours per day and forty-eight hours per week. In addition, feed mills must maintain accurate records of hours worked for all employees under Indicator 1.11.2.

When collective bargaining agreements, industry standards or national laws stipulate shorter regular working hours, those stricter thresholds prevail. In seasonal primary raw material processing where extra travel is required, working hour limitations and rest requirements can be averaged over the year. Auditors compare daily factory production output against recorded working hours to verify whether manufacturing targets depend on unrecorded shift extensions.

Overtime rules and premium wage calculations

Overtime working hours must be strictly managed to protect employee health and prevent chronic fatigue under Indicators 1.11.3, 1.11.4 and 1.11.5:

• Voluntary participation: Overtime must be completely voluntary, occurring under exceptional circumstances during peak production or staff shortages, and workers must not face penalties for refusing overtime.
• Overtime hour cap: Overtime working time must not exceed a maximum limit of twelve hours per week.
• Premium rate compensation: Overtime hours must be remunerated at a premium rate defined by collective bargaining agreements or industry standards, or at a minimum premium rate of one hundred and twenty-five percent of the basic salary.
• Regular overtime prohibition: Management must organize operational planning to avoid requesting overtime regularly, as repeated overtime indicates a need to revise contracted full-time staffing levels.

Mandatory break requirements and daily rest periods

Feed manufacturers must enforce mandatory rest breaks and weekly rest intervals for adult employees under Indicators 1.11.6 through 1.11.10:

• Workday break durations: Employees must receive workday breaks of at least one hour per eight hours of work shift.
• Daily consecutive rest: Workers must receive a daily rest period of at least eleven consecutive hours in every twenty-four-hour period.
• Weekly rest day: Employees must receive at least twenty-four consecutive hours of rest within every seven-day period.
• Annual leave entitlement: Feed mills must comply with collective bargaining agreements or national laws on paid annual leave, providing at least three paid working weeks per year of full-time service as best practice under ILO Convention 132.
• Night work protections: Shift schedules for night work must comply with applicable rules on premium rates, breaks, daily rest and mandatory health assessments.

Specific working time rules for young workers

Indicator 1.11.11 through Indicator 1.11.26 enforce strict limits for young employees aged fifteen to seventeen and children conducting light work. Young employees must not work more than eight hours per day or forty hours per week, with combined school, work and transport time capped at ten hours per day. Overtime hours are strictly prohibited for young workers under Indicator 1.11.13.

Young workers must receive workday breaks of at least thirty minutes per four-and-a-half hours worked, daily rest of twelve consecutive hours, weekly rest of forty-eight consecutive hours, and no night work between 22:00 and 06:00 under Indicator 1.11.18. Children aged thirteen and fourteen conducting light work must not exceed three hours per day or fourteen hours per week, with a daily rest of fourteen consecutive hours and no night work between 20:00 and 06:00.

What to do now

• Audit timekeeping records: Review timecards, electronic attendance logs and production rosters to identify any instances of regular or excessive overtime.
• Reconcile overtime wage calculations: Verify that payroll software applies a minimum premium rate of one hundred and twenty-five percent of basic pay for all overtime hours.
• Inspect shift rotation schedules: Confirm that shift rotations guarantee at least eleven consecutive hours of daily rest between shifts for adult employees.
• Review young worker schedules: Isolate work schedules for employees aged fifteen to seventeen to confirm that overtime and night work are excluded.

Reference documents

• ASC Feed Standard, V1.2, Criterion 1.11, Indicators 1.11.1, 1.11.2, 1.11.3, 1.11.4, 1.11.5, 1.11.6, 1.11.7, 1.11.8, 1.11.9, 1.11.10, 1.11.11, 1.11.12, 1.11.13, 1.11.14, 1.11.15, 1.11.16, 1.11.17, 1.11.18, 1.11.19, 1.11.21, 1.11.22, 1.11.23, 1.11.24, 1.11.26, Appendix 7, Table 6
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.11, Table 7, Table 8, Table 9, Table 10, Table 11