MSPO CoC Biomass – Certification Audit Exercise

Group Discussion Scenario #

MSPO CoC Biomass – System Integrity & Risk-Based Judgement #

A manufacturing company produces pillows using oil-palm biomass–based materials.
The company claims that its raw material supplier is MSPO CoC certified, but cannot clearly demonstrate whether the upstream biomass origin is from MSPO-certified plantations or mills.

The company operates with:

• A non-certified Quality Management System but implement according to ISO 9001:2015
• Basic OSH implementation, limited to compliance with OSHA 1994
• Environmental compliance limited to regulatory requirements under Environmental Quality Act 1974
• Total workforce: 100 employees
  • 75% foreign workers
  • They lived in company-provided living quarters

During an MSPO CoC Biomass audit, the following situations were observed:

Observed Situations #

1. Risk Management Approach
   Risk management is documented using PESTLE analysis only.
   Management believes this is sufficient and decided not to implement Business Continuity Planning (BCP) due to company size.
2. HIRARC
   The company uses a HIRARC format based on Department of Occupational Safety and Health guidelines prior to the OSHA 1994 (2022 Amendment).
   They have not adopted the Draft HIRARC ICOP format.
3. Training Needs Analysis (TNA)
   TNA records only cover direct employees.
   Management stated that contractor training is handled verbally through contractors’ top management, without documented verification.
4. Measurement Equipment
   One measurement instrument was found not calibrated.
   Management justified that:
   • It is not critical to product quality
   • Customers do not require it
   • It is not specified in product specifications
5. Environmental Aspect & Impact
   The Industrial Effluent Waste Treatment Facility was not listed in the Environmental Aspect & Impact Register.
   Management explained that the facility is in the process of ceasing operation.
6. Scheduled Waste Management
   Scheduled waste records were properly maintained.
   However, the competent person resigned 3 months before the audit, and no replacement had been appointed.
7. Quality Manual
   Quality Management System manual was not updated since the beginning due to no longer consultant being engaged in system maintenance.
8. Living Quarters
   The company provides living quarters for foreign workers, located just outside the main plant premises.
   During the audit, the auditor was not allowed to access or enter the living quarters, as management stated that:
   • The living quarters are outside the audited plant boundary
   • The visit was not included in the audit agenda
   • Observation was allowed from outside only, without physical inspection or worker interviews

Expected Outcome for Participants #

Justify each audit finding and decide whether it constitutes a non-conformity, based on MSPO CoC Biomass intent, sufficiency of evidence, level of operational control, and risk to chain-of-custody integrity.