Qualify Internal Auditors Under ASC Feed Standard Appendix 10

Mandatory internal audit qualification rules

The Aquaculture Stewardship Council updated internal audit competency rules under Indicator 1.2.6 and Appendix 10, Table 11 in version 1.2 of the ASC Feed Standard. This affects quality managers, compliance leads and internal auditors at certified feed manufacturing units. Feed mills must monitor compliance against all standard requirements through annually scheduled internal audits using competent auditors. Conformity Assessment Body auditors inspect these qualification records during third-party assessments.

Internal audits verify whether the feed mill implements an effective management system across all standard principles. Feed mills can appoint qualified internal staff or contract external auditors to execute scheduled audits. Failing to demonstrate auditor competency or maintain complete training evidence indicates a dysfunctional management system.

Auditors must evaluate operational activities, interview employees and examine records to verify compliance with internal procedures and standard requirements. When operations deviate from established management controls, internal non-conformities must be recorded with appropriate corrective measures. Internal audit results provide essential inputs for annual management reviews and continuous operational improvement.

Four pillars of internal auditor competence

Feed mills must verify that internal auditors satisfy four distinct qualification pillars defined in Appendix 10, Table 11 before assigning audit duties:

• Education and knowledge: Internal auditors must hold at least a post-high school diploma, demonstrate general knowledge of management systems standards such as ISO 9001, and understand social, economic and cultural relationships in employee communities.
• Work experience: Personnel must possess practical work experience relevant to the scope of certification, including feed manufacturing, milling or animal nutrition.
• Structured training courses: Auditors must complete a sixteen-hour internal auditor training course based on ISO 19011 principles from an accredited provider, along with the official ASC Feed Standard training module.
• Audit observation experience: Candidates must observe at least three management system audits before conducting internal audits independently.

Specialized social auditing requirements

Auditing social and labour criteria under Principle 1 requires dedicated qualification beyond general management systems training. When internal audits evaluate worker rights, working hours, child labour or forced labour provisions, the assigned auditor must complete additional specialised training. This safeguards worker welfare checks and ensures objective evaluation of facility labour practices.

Internal auditors evaluating Principle 1 criteria must successfully complete a social auditing course provided by a certification body or professional training institution specialised in social auditing. Auditors must also understand local social and economic relationships within surrounding employee communities. External auditors or specialised consultants can be contracted if internal staff lack these social auditing credentials.

The management system ensures that personnel receive all necessary instruction to maintain operational compliance across all facilities. Management must maintain centralized records of diplomas, course transcripts and audit observation logs for every auditor. Conformity Assessment Body auditors cross-check these training records during third-party certification audits.

Audit execution and management review

Internal audits must follow a structured schedule that covers all standard criteria and internal management requirements. While general operations require annual monitoring, high-risk areas such as overtime hours, seasonal contract labour recruitment and machinery safety may require more frequent auditing. The audit schedule ensures comprehensive coverage across all operational departments and shifts.

Documented audit reports must identify both conformities and non-conformities, citing objective evidence from interviews, site observations and document reviews. Management must review internal audit findings during annual management reviews to trigger corrective actions and update operating procedures. Effective internal auditing prevents recurring non-conformities and maintains continuous compliance across the Unit of Certification.

What to do now

• Review internal auditor records: Compare the curriculum vitae, diplomas and training certificates of all current internal auditors against Appendix 10, Table 11 requirements.
• Schedule missing training modules: Enrol internal auditors in a sixteen-hour ISO 19011 internal auditor course or a recognized social auditing course if gap analysis identifies missing qualifications.
• Verify audit observation logs: Document logs demonstrating that internal auditors have observed at least three management system audits prior to conducting independent reviews.
• Update internal audit schedules: Ensure the annual internal audit schedule explicitly covers all applicable ASC Feed Standard criteria and assigns qualified auditors to corresponding scopes.

Reference documents

• ASC Feed Standard, V1.2, Indicator 1.2.6, Appendix 10, Table 11
• ASC Feed Standard Interpretation Manual, V1.2, Criterion 1.2