Governance and Implementation

The governance and implementation recommendations set out below are intended to be in place for the first 18 months of SERA’s existence as a not-for-profit organization and shall be subject to the decisions of the interim and long-term governing body.  The recommendations are intended to ensure that implementation of the SERA standard is both cost effective and credible.

Moving forward, the process used to further develop and finalize the SERA approach for implementation will generally follow the ISEAL Alliance’s Code of Good Practice for Setting Social and Environmental Standards (these are summarized in Appendix 3).  The intent is that the SERA governing body will evolve  over its first eighteen months to meet the ISEAL standard. The ISEAL Alliance is a global association for social and environmental standards whose members include the Forest Stewardship Council, Marine Stewardship Council and Fair Trade.  This will require engaging a broader group of stakeholders and establishing a fair and transparent development and implementation process.

Governance

  • The implementation of these standards will require oversight by a larger and more diverse group of interests.  An independent SERA governance body should be established that is credible, transparent and legitimate, consistent with best practices on CSR standards governance.
  • The governing body should:
    • Be overseen by an independent group of people representing a balance of social, environmental and industry interests
    • Have in place an Executive Director to develop and implement strategies
    • Be financially resourced to appropriately carry out its mandate

Certifiers

  • Make use of existing 3rd party certifiers and their auditing systems
  • The certifying team should consist of a biologist/ecologist, a hydrologist/hydrogeologist (depending on the circumstances) and an expert on local stakeholder consultation
  • Certifiers should have proven experience in dealing with the technical aspects of the SERA Standard including but not limited to: ecology, hydrology/hydrogeology, ecological and hydrological/hydrogeological function, impact and mitigation assessment, community engagement and standard operating procedures within the aggregate industry.

Scope of assessments:

  • A company’s actual aggregate extraction sites should be the recipients of certification rather than the company itself.
  • Despite the above, given the nature of the standards themselves, the certification process should have an audit focus that includes both the company’s management systems and policies as well as the on-the-ground operations at the aggregate sites that are being certified
  • In cases where the company does not own the land on which their aggregate operation is located, for the sake of simplicity it is recommended that the operator seek certification for the site (as opposed to the landowner).

Eco-label

  • SERA should give thought to the use of some sort of eco-label that could be used by companies upon successful certification, including green dye to assist the consumer. Any eco-labeling should comply with all applicable laws and regulations. Given that on-product use of an eco-label (i.e. on the aggregate) would be challenging, it is recommended that eco-labeling be used in conjunction with off-product claims (eg promotional material, site signage, etc) and on-product claims on the end-use product (eg signage on a building built with certified aggregate).
  • Rules should be adopted for the use of on and off-product claims and label use.  All SERA certified operators should comply with these rules.
  • The certifier should address the issue of %-based claims (i.e. does level of certified aggregate used in a project have to be 100% in order to be able to use the eco-label and to make on and off product claims)
  • Guidance should be provided to address the issue of off-product/site claims and consider what operators would be allowed to say in general about their overall operations.  This is particularly an issue if a company only has a small % of their operations certified to the standard

Chain of custody

  • To facilitate the use of on and off-product eco-label use and claims, it will be critical to have in place a procedure for tracking ‘chain of custody’ of the aggregate from the site through to its final end use.   As many certifiers have developed rigorous yet flexible approaches to this challenge, this procedure should be developed with their direct input

Performance evaluation

  • The certifier should address the issue of ‘scoring’ and the minimum bar that must be reached in order for an aggregate operation to be deemed to be certified.
  • As with many other 3rd party certification systems, it is recommended that certifiers will not require full compliance with all the requirements of the standards before certification is granted, but rather that some threshold of compliance with the requirements under each Principle be achieved and then time-bound undertakings be issued and completed. Respecting the “No Go” areas is an absolute standard with no allowance for part performance.
  • The SERA governing body should determine which core requirements in the standards are fundamental to responsible aggregate extraction such that an operator’s failure to meet them would prevent certification or result in decertification.
  • Attempts by the applicant to circumvent the spirit underlying the Standards should be taken into consideration by the certifier.

Length of certificate and re-auditing intervals

  • Certifications should be granted upon completion of a successful audit and have a fixed duration period. The fixed period should be determined such that certificate cycles are relevant to the length of time that aggregate facilities are operated.
  • Annual audits should be performed to confirm ongoing compliance with the Standard; to investigate disputes/complaints; and assess the operator’s compliance with any undertakings.
  • Instances of non-compliance that may arise out of the annual audit may result in requirement for undertaking or revocation of certification.  The SERA governing body should consider those circumstances in which a certification may be revoked.
  • A final ‘decommissioning’ audit will likely be needed; however, for efficiency’s sake these could be timed to align with the initial assessments of new aggregate operations that the company is seeking certification of.
  • The SERA governing body should consider those circumstances in which Third Party appeals or intervention in a certification application should be considered, along with the process and transparency for same.