FIAS 2021 Standard, Online Version

G2.1

The Company senior management must be committed to the implementation and maintenance of the FIAS Standard/Certification.

G2.2

The Company shall have a signed and dated policy statement that commits the Company to comply with FIAS.

The policy must be communicated to all Company employees involved in fertiliser related activities and be reviewed as part of the management review or as a result of Company changes to make sure it remains current.

[R] [T]

The policy statement can be a brief document that is prepared and endorsed by a senior person in the Company, for example, Managing Director.

It is acceptable for the Company to use and adapt existing systems, documents, manuals and forms etc. to comply with FIAS.

G3.1

Senior management shall carry out an annual review of systems and procedures including:

• policy statement (G2.2)
• risk assessments
• external and internal audits (G17 and G18)
• incidents and corrective action
• training and processes
• internal procedures

Record of the annual management review must be documented.

[R] [T]

“Annual” means within a 12 month period.

G4.1

The Company shall appoint a designated person who must have authority and responsibility for the implementation and maintenance of the requirements of the FIAS standard.

This member of staff may have other duties but must have clearly defined responsibility for ensuring the Company has a system to comply with FIAS

G5.1

All employees that could affect fertiliser product security, safety, legality, traceability and environmental impact shall be made aware of their responsibilities, the levels/limits to their authority and the organisational structure of the Company. [R]

Job descriptions and a diagram of the Company structure may be helpful.

Consider full time and temporary staff.

G6.1

The Company shall ensure that all personnel, full-time, part-time and temporary employees and agency staff, are trained and competent to carry out their roles and responsibilities related to FIAS.

Records of training and competence shall be kept. [R]
Training records shall show:

• date
• signature and printed name of trainee
• trainer information and/or content details

Training records could show:

• topics covered
• certificates (where held) from
  internal/external training
  organisations
• self-assessment reports where appropriate
• competency records

G6.2

As a minimum, a designated person must complete the relevant AIC i-learning module or equivalent training package (e.g. Driver CPC, internal training).

AIC i-learning modules for Driver, Transport Manager, Merchant and Store are available from www.agindustries.org.uk/fias-scheme Contact [email protected],
01423 878875/878873 for log in details and FIAS Driver CPC training information.

G6.3

The Company shall undertake security screening of staff in relation to FIAS activities and products.
[R]

Staff screening guidance for businesses on ‘Reducing the Insider Risk’ , ‘Pre- Employment Screening’ and additional Personnel Security is available from www.cpni.gov.uk/reducing-insider-risk

G7.1

The Company shall have working procedures and detailed instructions to control activities to meet the FIAS standard.

G8.1

The Company must promptly advise the Certification Body of any significant changes or occurrences within the business that materially affect compliance with the standard such as:

• business ownership
• scope of operations
• change of designated person
• addition or closure of sites
• being subject to a relevant formal investigation by an external body regarding fertiliser safety and/or security

G9.1

The Company shall have an effective means of ensuring that:

• they are aware of all relevant legislation and appropriate systems are in place to ensure full compliance.

• they have a means of identifying any changes in legislation

Sources could include trade associations, government departments, professional bodies and trade journals.

G9.2

The Company shall ensure that authorities are notified and approvals obtained for products held at their sites, where relevant. [R]

COMAH/NAMOS Regulations See Appendix 1 and Appendix 7.

G10.1

The Company shall undertake and document a thorough business process risk assessment of its operations in the manufacturing, merchanting, storage and transport of fertilisers in order to identify the hazards and risks related to legal compliance, security, product safety and traceability within those operations.

[R] [T]

The assessment shall:

• be carried out by a person or team who have a breadth of knowledge and expertise of all aspects of the operation and are competent in the understanding and practical application of risk assessment principles

• define the scope of the fertiliser operations to be considered and lists or charts the process steps. Include all business processes that have an impact on the assessment criteria, such as sales orders, recruitment etc

• identify hazards in the areas of legal compliance, product safety, security and traceability at every step of the business process

• evaluate the risk associated with the hazard(s)

• identify and implement controls required to prevent or reduce any identified risks to an acceptable level

• establish corrective action procedures to be implemented when identified risks are deemed to be out of control

In the case of a small business with limited management resources, the FIAS designated person would be expected to have the appropriate experience and knowledge to undertake the business process assessment. External expertise may be required.
Ideally the assessment leader should have attended a recognised training course.

Note: when considering safety, make sure this relates to product safety and not occupational health and safety.

Guidance on completing a FIAS business process risk assessment, example forms and further information are available on the AIC website, www.agindustries.org.uk/fias-checklists/

FIAS i-learning modules include information on business process assessment and risk levels.

G11.1

The business process risk assessment shall be reviewed by the assessment team/designated person annually and in response to any changes in products, processes, legislation or any other factors that may affect the safety and security of the finished product.

The business process assessment review shall be recorded and findings implemented. [R]

The outcomes of the business process risk assessment review should be included in the management review required in G3.1.

G12.1

The Company shall ensure when purchasing goods and services that all relevant FIAS and statutory requirements are satisfied.

Services may include contract manufacturing, storage, transport, product handling, merchanting.

G13.1

The Company shall ensure that:

• all purchased raw materials, and finished products are obtained from business approved suppliers [R]

• raw materials, packaging and finished products are purchased against specifications which comply with applicable Statutory requirements and enable it to meet its FIAS obligations [R]

• records are kept of all purchased goods [R]

Material or product specifications may include:

• description of material or product
• technical parameters
• safety data
• packaging
• quantity
• storage information

G14.1

Businesses contracted to manufacture, blend, pack or otherwise change the nature or format of a product must be FIAS certified.

G15.1

The Company shall ensure that businesses contracted to provide storage, transport, or merchanting of fertiliser product supplied by the Company are FIAS certified to the relevant standard. [R]

G16.1

A derogation from G15 is available where the Company wishes to use non-FIAS certified contractors for storage and transport or merchant customers for onward sales of fertilisers and Explosive Precursors where used as a fertiliser product (as defined within FIAS scheme rules 1.1).

G16.2

To qualify for this derogation, before first use of the contractor or sales to the merchant customer, the Company must undertake an initial audit of the contractor’s or merchant’s systems, processes and past operating performance (where available) covering all aspects of the relevant FIAS standard.

For storage operations this audit must include an inspection of the storage facilities.
The findings of this audit shall be submitted to the Certification Body in a written report for review to determine whether or not the contractor or merchant can be authorised for use in accordance with Clause G15.1.

Where granted, authorisation will be confirmed to the Company in writing. [R]

The audit should be carried out by a competent person, either within the

Company or an external auditor. Audit checklists are available on the AIC website, www.agindustries.org.uk/fias-checklists/
[T]

G16.3

To maintain on-going authorisation to use the contractor or merchant services, the Company shall undertake an annual audit of the contractor’s /merchant’s performance and inspection of storage facilities as part of its FIAS internal audit programme.

This audit shall cover all relevant aspects of the FIAS Standard. Audit findings including non-conformances and corrective actions taken shall be recorded. [R]

The Company shall review FIAS performance of the contractor or merchant annually and include in the management review. [R]

G16.4

The Company’s annual FIAS audit will include review of the contractor or merchant audit reports and schedule.

G16.5

It is NOT permitted for the approved non- FIAS contractor to further subcontract storage and/or transport of Company owned product or in the case of approved merchants, to undertake wholesale sales to third parties.

G16.6

Where there are approved non-FIAS contractors or merchants providing services for more than one FIAS certified Company, they should be expected and encouraged to join the FIAS scheme.

Annual volumes and location should be taken into account.

G16.7

A list of the Company’s current non-FIAS contractors and merchants approved under this derogation, will be held by the Certification Body. Details may be provided on request to UK authorities.

The Company must notify the Certification Body of any removals from the list.

The derogation applies to the Company and its approved non-FIAS contractors / merchants only. The approval is not valid for the non-FIAS contractor / merchant with any other FIAS company.

The current FIAS status of a company may be checked on the AIC Trade Assurance Checker: www.agindustries.org.uk/trade-assurance-checker. Approval status of a contractor/merchant may be checked by contacting the Certification Body, 01423 878873 or [email protected]

G17.1

When the Company conducts an audit of a supplier of goods or services, they must ensure that:

• the audit is completed at a defined frequency based on risk assessment and supplier performance with the exception of approved non-FIAS storage and transport contractors and merchant customers who must undergo an audit initially and annually as per clause G16
• the audit covers all relevant aspects of the FIAS Standard
• an audit report that records findings against each clause of the relevant standard is produced and retained
• the supplier provides evidence that all non compliances have been resolved
• supplier performance in respect of FIAS requirements forms part of the annual management review

The FIAS certification body will require evidence that the audit has been completed competently and records demonstrate that the supplier will and does comply with the relevant FIAS standard and Company requirements. Audit templates are provided on the AIC website, www.agindustries.org.uk/fias-checklists/. [T]

G18.1

The Company shall plan and conduct internal audits as a means of determining compliance with safety, security, legal, FIAS and Company requirements.

An internal audit may be carried out by a competent person, either within the Company or an external auditor.

Audit checklists are available on the AIC website, www.agindustries.org.uk/fias-checklists/ .
[T]

G18.2

Audit findings, including any non-conformances, shall be recorded and acted upon in a timely manner [R].

G19.1

The Company must ensure that only the current versions of documents are in use.

[R]

This may be achieved by adding:

• a document reference number
• issue date
• version number
• archiving system

G19.2

Documents and records (handwritten or electronic) must be designed and prepared such that:

• their title and purpose are clear
• they are dated
• inadvertent use of superseded documents is prevented (G19.1)
• records are legible
• handwritten records are in ink
• the name of the person making any entry, alteration or deletion is identifiable

G19.3

All records must be retained for a period not less than two years, or as required by legislation and be available to auditors at the next FIAS audit.

Records must be legible and kept in suitable conditions that allow ready retrieval and prevent deterioration.

FIAS records required are listed in Appendix 4.                              

G20.1

The Company shall have a documented procedure that outlines the actions to be taken in the event of a product related incident where it is established that product safety, legality, security or traceability has been compromised.

The management procedures must be reviewed or practiced annually to ensure details remain up to date and effective. [R]

This relates to all sectors of the FIAS supply chain, and should cover foreseeable incidents such as:

• fire
• theft/loss
• major spills
• flood

G20.2

The Company shall have a documented procedure that outlines the actions to be taken in the event of any suspicious or unusual activity.

It is essential that the Company reports any suspicious activity to the Police or other enforcement agency as soon as possible. It is mandatory to report to the authorities, suspicious activities relating to fertilisers containing Ammonium Nitrate (>16%N), Potassium Nitrate, Sodium Nitrate, Calcium Nitrate and Calcium Ammonium Nitrate and other substances listed in the Poisons Act 1972 (Explosive Precursors) legislation.

See Appendix 5 Contact details for the Anti-Terrorist Hotline: Tel 0800 789321.

G20.3

The Company shall record actions taken in the event of an incident, emergency or suspicious activity. [R]

G21.1

All parts of the fertiliser supply chain shall understand and support the requirements of a product recall.
Responsibility for initiation and implementation of product recall lies with the product supplier i.e. the manufacturer or merchant.

Transport and storage companies shall support the recall process as required by provision of traceability records or data. [R]

Transport and storage operators are not expected to complete a recall exercise but shall be able to supply evidence that they have traceability records.                        

G21.2

The Company supplying product shall have a document recall procedure.

This should be sufficiently detailed to explain the recall process and identify the management function responsible for implementing the procedure.

G21.3

The Company shall take prompt action to advise and inform those affected by a product recall.

Depending on the nature of the product incident, this may include suppliers, customers and end users.

G21.4

The Company shall plan for the recovery and final disposal or use of affected product and stock reconciliation.

G21.5

The Company shall test their product recall procedures at least annually and in a way that ensures their effective operation. Results of the test should be used to review the recall procedures and implement improvements, as necessary.

A recall test is a theoretical exercise which does not require the physical return of product. It should confirm that all aspects of the procedure work e.g. staff awareness of responsibilities, correctness of contact details, where to find traceability information.

G21.6

All product recalls and tests of the procedure shall be documented and form part of the Company’s management review. [R]

G21.7

Storage and transport participants shall at all times maintain comprehensive records to demonstrate traceability of product whilst in their possession. Such records shall be accessible and retained as specified by the contracting Company and in accordance with FIAS requirements.

The traceability records may be required during a product recall or recall test by the product supplier.                                                       

G22.1

The Company shall establish and implement a system for recording customer complaints.

G22.2

All complaints shall be reviewed promptly and appropriate action taken.
The review shall consider the potential effect of the problem on other products or services.

G22.3

The Company shall keep records of the complaint review and any actions taken. [R]

G23.1

Suitable and sufficient security measures shall be put in place for the Company site(s) and operations. These shall be determined by risk and threat assessment including consideration of:

• unauthorised access
• theft/loss
• terrorism
• insider threat

Appropriate and proportionate security measures need to be implemented to control access and prevent theft or loss of the product commensurate to the risk and threat identified.

These measures may include physical security, site access control, CCTV, control of visitors/contractors etc. Guidance is available from NaCTSO website: www.gov.uk/government/publications/se cure-your-fertiliser/secure-your-fertiliser or alternatively from the CPNI www.cpni.gov.uk.

G23.2

Data and Cyber Security
The Company shall ensure that data computers, networks, servers, mobile devices and electronic IT systems are protected from unauthorised access and malicious attacks.

Guidance on cybersecurity is available from www.ncsc.gov.uk.

G24.1

A formal contract must exist between all parties to the transaction. This must clearly lay down the terms on which the product is purchased. [R]

This will typically be under current INCO Terms.

G24.2

The Company shall ensure that fertiliser imports meet the agreed requirements of customer, user, Company and legal product and packaging specifications. [R]

The Company shall comply with all relevant legislative and FIAS requirements for the import of fertiliser.

For example, a manufacturer or merchant importing fertiliser materials for processing or sale, is responsible for ensuring that the receipt, unloading of those materials at port and subsequent storage and transport of those materials until used or sold, meet the requirements of FIAS.

G25.1

A DRT certificate is required for material containing AN (including mixtures) in which the nitrogen content from AN exceeds 28% by weight. Quantities less than 500 kg and material classified as an explosive are exempt.

An audit trail for the product from manufacture to final user must be maintained, evidenced by certificates and/or transaction records. These must be retained for a period of at least 2 years after the date of supply. [R]

Refer to: Appendix 1
Where AN is not being used as a fertiliser, an exemption certificate must be granted by HSE as per clause 10 of SI1082/2003.