3.2.1 General Chain of custody requirements for the supply chain
Clause Requirement
5.1 Applicability of the general chain of custody requirements for the supply chain 5.1.1
The General Chain of Custody requirements of the RSPO Supply Chain Standard shall apply to any organization throughout the supply chain that takes legal ownership and physically handles RSPO Certified Sustainable oil palm products at a location under the control of the organization including outsourced contractors. After the end product manufacturer, there is no further requirement for certification.
The audit area done to palm oil mill which takes legal ownership and physically handling on the whole product. Product transporting and storing are handed to the third parties (bounded contractors) but the entire activities and process are under control of the mill. The agreement which describes the term and condition with the entire contractor are explained in the clause of 5.6 of this Chain of custody summary.
Status: Comply 5.1.2
Traders and distributors require a license obtained from RSPO Secretariat to sell RSPO certified product but do not themselves require certification. When selling RSPO certified products, a licensed trader and/or distributor shall pass on the certification number of the product manufacturer and the applicable supply chain model.
The audit are done to the palm oil mill which is only sell its product. This requirement are not applicable.
Status: Comply 5.1.3
Either the operator at site level or its parent company seeking certification shall be a member of the RSPO and shall register on the RSPO IT platform.
The mill has been registered as RSPO member and on RSPO IT Platform, as detailed below:
Sub License ID CB73404
Member Name Sime Darby Plantation - Pondok Labu POM, PT PSA
Member ID RSPO_PO1000000327
RSPO Membership Number 1-0008-04-000-00 (Sime Darby Plantation Berhad)
Issued On 15-09-2018
Issued By PT Mutuagung Lestari
Start Date 20-09-2018
End Date 19-07-2019
Status: Comply 5.1.4
Processing aids do not need to be included within an organization’s scope of certification.
There are no processing aids in the operational Pondok Labu POM.
Status: Comply 5.2 Supply chain model 5.2.1
The site can only use the same supply chain model as its supplier or go to a less strict system. Declassification/downgrading can only be done in the following order: Identity Preserved -> Segregated -> Mass Balance.
The mill are applied the SC Module D - IP, all the transaction are done in correct supply chain.
Page 53 Status: Comply
5.2.2
The site can use one (1) or a combination of supply chain models as audited and certified by the CB.
The mill are applied the SC Module D - IP, all the transaction are done in correct supply chain.
Status: Comply
5.3 Documented procedures 5.3.1
The site shall have written procedures and/or work instructions or equivalent to ensure the implementation of all elements of the applicable supply chain model specified.
No changes to the procedure since ASA 1.1.
The certificate holder has a written procedure to ensure the implementation of all elements of IP supply chain model on Manual RSPO SCCS reff. No. SCCS-Std/RSPO/PSQM/02, Rev 1 dated on 02 January 2018, covering:
The implementation of all elements of the supply chain model.
Records and reports that compliance with supply chain model (including training records)
Person having overall responsibility for and author over the implementation of supply chain requirements.
Observation are conducted to station of FFB reception and product delivery, as well as interview to the personnel involve, it was seen that all personnel has aware regarding to the SOP of SCCS and was able to demonstrate the SCCS process.
Status: Comply 5.3.2
The site shall have a written procedure to conduct annual internal audit
In the procedure of SCCS No. SCCS-Std/RSPO/PSQM/02 clause of 4.2.3 mentioned that internal audit for SCCS are done one a year (two months before external audit), audit conducted by Dept of PSQM.
The latest internal audit are done in 7 Jan 2019, there was as much as 7 NCR raised, the action plan has been prepared by the mill, status of NCR are closed.
Status: Comply
5.4 Purchasing and goods in 5.4.1
The receiving site shall ensure that purchases of RSPO certified oil palm products are in compliance and the following minimum information for RSPO certified products is made available by the supplier
The mill does not purchase RSPO certified product from outsider, it only sell its own product.
Status: Comply 5.4.2
The site shall have a mechanism in place for handling non-conforming oil palm products and/or documents
The mill does not buy products from outsider, however in the SOP of SCCS has been explained that if there are non- conformance on products or documents, verification will be carried out by the mill manager and Marketing Dept in Jakarta Office, if the document or product quality is not suitable it will be returned to the supplier.
Status: Comply 5.5 Outsourcing activities 5.5.1
In cases where an operation seeking or holding certification outsources activities to independent third parties (e.g.
subcontractors for storage, transport or other outsourced activities), the operation seeking or holding certification shall ensure that the independent third party complies with the requirements of the RSPO Supply Chain Certification Standard. A CPO mill and independent mill cannot outsource processing activities like refining or crushing.
Page 54 The mill does not hire refinery and/or crusher facility.
The mill outsourced some of its activities to the third parties which is bounded by the agreement. In each agreement has been stated that the third party facilities hired are ready to be visited and inspected by the auditor at any time if needed.
Status: Comply 5.5.2
Sites which include outsourcing within the scope of their RSPO Supply Chain certificate shall ensure the following:
a. The site has legal ownership of all input material to be included in outsourced processes;
b. The site has an agreement or contract covering the outsourced process with each contractor through a signed and enforceable agreement with the contractor. The onus is on the site to ensure that certification bodies (CBs) have access to the outsourcing contractor or operation if an audit is deemed necessary.
c. The site has a documented control system with explicit procedures for the outsourced process which is communicated to the relevant contractor.
d. d) The site seeking or holding certification shall furthermore ensure (e.g. through contractual arrangements) that independent third parties engaged provide relevant access for duly accredited CBs to their respective operations, systems, and any and all information, when this is announced in advance
The mill outsourced some of its activities to the third parties which is bounded by the agreement. The mill shows document of agreement of all contractors hired:
- Agreement no.: 014/Jasa Penyimpanan/LMR-PSA/VI/2017 dated 30 June 2017, regarding to CPO storage, heating and pumping, between PT PSA and PT LMR (address in Jakarta, Indonesia). In the document written that the PT LMR only do storing, heating and pumping the CPO upon orders from PT PSA, the product legally remains owned by PT PSA - Agreement no.: 015/Jasa Pengangkutan/PSA-ARU/X/2017 between PT PSA and PT Asta Rekayasa Unggul (address in
Balikpapan, East Kalimantan, Indonesia), regarding to the palm kernel transportation. The agreement states that the transporter will only deliver to the destination set by the mill.
In each agreement has been stated that the third party facilities hired are ready to be visited and inspected by the auditor at any time if needed.
During visit to Pondok Labu mill, there is no transport activity for CPO and PK.
Status: Comply 5.5.3
The site shall record the names and contact details of all contractors used for the processing or physical handling of RSPO certified oil palm products.
The below are contractors of mill, all the information required including names and address has been written in the agreement document:
- Agreement no.: 014/Jasa Penyimpanan/LMR-PSA/VI/2017 dated 30 June 2017, regarding to CPO storage, heating and pumping, between PT PSA and PT LMR (address in Jakarta, Indonesia).
- Agreement no.: 015/Jasa Pengangkutan/PSA-ARU/X/2017 between PT PSA and PT Asta Rekayasa Unggul (address in Balikpapan, East Kalimantan, Indonesia), regarding to the palm kernel transportation.
Status: Comply 5.5.4
The site shall at its next audit inform its CB of the names and contact details of any new contractor used for the processing or physical handling of RSPO certified oil palm products
There is no new contractors since ASA 1.1 Status: Comply
5.6 Sales and goods out 5.6.1
The supplying site shall ensure that the following minimum information for RSPO certified products is made available in
Page 55 document form: The name and address of the buyer
Information of CSPO and CSPK buyers required such as name and address of buyer, volume, transporter, loading and unloading date, RSPO certificate and SC Model are listed in the document of contract sales, delivery order and official record of CSPO shipping. During the license period there was three (3) buyer of CSPO and one of CSPK buyer:
- PT Golden Hope Nusantara, address in Kota Baru, South Kalimantan, RSPO IP, 999.496 MT - PT Musim Mas, address in Medan – North Sumatera, RSPO IP, 1,099.420 MT
- PT Berkah Emas Sumber Terang, address in Semarang - Indonesia, RSPO IP, 999.494 MT
- PT LMI (KCP), address in Penajam Paser – South Kalimantan – Indonesia, SC Model RSPO IP, volume 2000 MT.
Status: Comply
5.7 Registration of transactions 5.7.1
Supply chain actors who:
• are mills, traders, crushers and refineries; and
take legal ownership and/or physically handle RSPO Certified Sustainable oil palm products that are available in the yield scheme of the RSPO IT Platform (Figure 2 and 3, refer Annex 1) shall register their transaction in the RSPO IT platform and confirm upon receipt where applicable
The audit are done to palm oil mill namely Pondok Labu POM, which has been registered as RSPO member and on RSPO IT Platform, as detailed below:
Sub License ID CB73404
Member Name Sime Darby Plantation - Pondok Labu POM, PT PSA
Member ID RSPO_PO1000000327
All the product are legally owned by the mill and all physically handling are done by the mill. The mill has been register all its transaction through RSPO IT Platform, confirmation are done upon shipping.
Status: Comply 5.7.2
The involved supply chain actors mentioned in 5.7.1 shall do the following actions in the RSPO IT Platform:
• Shipping Announcement / Announcement: When RSPO certified volume is sold as certified, the volumes of products that are in the yield scheme (Figure 2 and 3, refer Annex 1) shall be registered as a Shipping Announcement / Announcement in the RSPO IT Platform. The declaration time to do Shipping announcement / Announcement is based on members' own standard operating procedures.
• Trace: When RSPO certified volumes are sold as RSPO certified to actors in the supply chain beyond the refinery, the volume shall be traced at least annually. Tracing triggers the generation of a trace document with a unique traceability number. Tracing can be done in a consolidated way at least annually.
• Remove: RSPO certified volumes sold under other scheme or as conventional, or in case of underproduction, loss or damage shall be removed.
• Confirm: Acknowledge the purchase of RSPO certified volume by confirming Shipping Announcements / Announcements.
Based the SCCS SOP, the mill will announce and reporting the transaction upon the receipt/delivery.
During the license there is no CSPO and CSPK sales under other scheme (mill not applied other scheme such as ISCC), and no sales under conventional. During the license the mill has delivered and sell the CSPO product as much as 45,016.48 MT and CSPK 10,517.59 MT. buyer for CSPO i.e PT GHN and PT BEST,buyer for CSPK i.e PT LMI (KCP)
All the CSPO and CSPK transaction has been announced through RSPO IT platform, for example:
- CSPO transaction no.: TR-3f7da74c4185 on 1 Feb 2019, volume : 1,516.27 MT to PT GHN, confirmed as shipping - CSPK transaction no.: TR-3a7e863fed99, volume: 1,788.47 MT, on 4 Dec 2018, to PT LMI (KCP).
Status: Comply
Page 56 5.8 Training
5.8.1
The organization shall have a training plan on RSPO Supply Chain Standards requirements, which is subject to on-going review and is supported by records of the training provided to staff
The mill has been set the training plan for SCCS namely once a year, the personnel involve in training is foreman, WB operator, press operator, clarification operator, dispatch operator, production clerk, assistant and Head Adm. of mill.
For 2019, planned to be done Feb 2019.
Status: Comply 5.8.2
Appropriate training shall be provided by the organization for personnel carrying out the tasks critical to the effective implementation of the supply chain certification standard requirements. Training shall be specific and relevant to the task(s) performed
Sighted the SCCS training report which held in 7 Feb 2019, the report informs the training material, attendances and photo documentation. Based on list attendance seen that the personnel’s involved is: Mill Manager, PSQM Staff, WB operator, production clerk and production assistant.
Status: Comply 5.9 Record keeping 5.9.1
The organization shall maintain accurate, complete, up-to-date and accessible records and reports covering all aspects of these RSPO Supply Chain Certification Standard requirements
All the records and document related to the SCCS are stored and keeping in the mill office, based on verification it was up-to- date, accurate and accessible. According to the mill SOP, the retention of document is minimum 2 years.
Status: Comply 5.9.2
Retention times for all records and reports shall be a minimum of two (2) years and shall comply with legal and regulatory requirements and be able to confirm the certified status of raw materials or products held in stock
There is no change since ASA 1.1. Based on a written procedure to ensure the implementation of all elements of IP supply chain model on Manual RSPO SCCS reff. No. SCCS-Std/RSPO/PSQM/02, Rev 1 dated on 02 January 2018, the retention time for financial and transaction records are 10 years and non-financial records are min 2 years.
Status: Comply 5.9.3
The organization shall be able to provide the estimate volume of palm oil / palm kernel oil content (separate categories) in the RSPO certified oil palm product and keep an up to date record of the volume purchased (input) and claimed (output) over a period of twelve (12) months.
The mill only applied one SC module, namely Module D – IP. The estimate of volume that can be produced for 12 months (during license) is listed in the ASA 1.2 certificate, detailed are describes in the following table:
Estimation for the next 12 months
FFB 225,220
CSPO 47,296
CSPK 11,261
Status: Comply 5.10 Conversion factors 5.10.1
Where applicable a conversion rate shall be applied to provide a reliable estimate for the amount of certified output available
Page 57
from the associated inputs. Organizations may determine and set their own conversion rates which shall be based upon past experience, documented and applied consistently. Guidance on conversion rates is published on the RSPO website (www.rspo.org); RSPO Rules for Physical Transition of Oleochemicals and its Derivatives. This is relevant for derivatives of Palm Oil and Palm Kernel Oil, as used in the oleochemical and personal care industries
The audit are conducted to palm oil mill which is convert FFB to crude palm oil and palm kernel. The mill has been defined the conversion rate based on FFB, CPO and PK produce on daily basis, for example average of rate of product on Feb 2018 – Jan 2019 namely :
OER : 19.60%
KER : 4.78%
Status: Comply 5.10.2
Conversion rates shall be periodically updated to ensure accuracy against actual performance or industry average if appropriate.
The mill has been defined the conversion rate based on FFB, CPO and PK produce on daily basis.
Status: Comply 5.11 Claims
5.11.1
The site shall only make claims regarding the use of or support of RSPO certified oil palm products that are in compliance with the RSPO Rules on Market Communications and Claims.
The mill are use trademark on the product sales document, the trademark use is option 2 for IP & SG claims label options, it has been in accordance with the RSPO Rules on Market Communications and Claims. The Pondok Labu POM has had a trademark license under Sime Darby Plantation Berhad, number: RSPO-1106024.
Status: Comply 5.12 Complaints 5.12.1
The organization shall have in place and maintain documented procedures for collecting and resolving stakeholder complaints.
No changes to the complaint mechanism, it has been stipulated in the Manual RSPO SCCS ref.: No. SCCS- Std/RSPO/PSQM/02, Rev 1 dated on 02 January 2018. Up to ASA 1.2 audit, there’s no complain on the submitted by buyer to Pondok Labu POM.
Status: Comply 5.13 Management review 5.13.1
The organization is required to hold management reviews annually at planned intervals, appropriate to the scale and nature of the activities undertaken
Based on Manual RSPO SCCS reff. No. SCCS-Std/RSPO/PSQM/02, Rev 1 dated on 02 January 2018, the management review are planned to be done once a year. The latest management review are held in 21 Jan 2019.
Status: Comply 5.13.2
The input to management review shall include information on:
• Results of internal audits covering RSPO Supply Chain Certification Standard.
• Customer feedback.
• Status of preventive and corrective actions.
• Follow-up actions from management reviews.
• Changes that could affect the management system.
• Recommendations for improvement.
All the input required has been discussed in the latest management review, such as: internal audit result including its NCR status, stakeholder complaint, process and product performance and follow up from the previous management review.
Page 58 Status: Comply
5.13.3
The output from the management review shall include any decisions and actions related to:
• Improvement of the effectiveness of the management system and its processes.
• Resource needs.
The output of the management review on January 21, 2019 has included improvement of the effectiveness of the management system and its processes and resource needs, such as plans to identify personnel who will attend SCCS training, create customer complaint register books and improve communication with marketing related to transaction reporting in palm trace.
Status: Comply
Page 59 3.2.2 (Module D) CPO Mills – Identity Preserved Requirements
Clause Requirement
D1 Definition D.1.1
A mill is deemed to be Identity Preserved (IP) if the FFB used by the mill are sourced from plantation/ estates that are certified against the RSPO Principles and Criteria (RSPO P&C), or against the Group Certification scheme.
Certification for CPO mills is necessary to verify the volumes and sources of certified FFB entering the mill, the implementation of any processing controls (for example, if physical separation is used), and volume sales of RSPO certified products. If a mill process certified and uncertified FFB without physically separating them, then only Module E is applicable.
Pondok labu POM are received and processed FFB only from certified sources (own estate and PT LMR Smallholder Scheme). In this case, the POM will applied RSPO SCC Module D – IP.
Status: Comply D.2 Explanation D.2.1
The estimated tonnage of CPO and PK products that could potentially be produced by the certified mill must be recorded by the certification body (CB) in the public summary of the P&C certification report. For an independent mill, the estimated tonnage of CPO and PK products must be recorded in the RSPO IT platform, supply chain certificate and public summary audit report. This figure represents the total volume of certified oil palm product (CPO and PK) that the certified mill is allowed to deliver in a year. The actual tonnage produced shall then be recorded in each subsequent annual surveillance report
The estimate of volume that can be produced for 12 months (during license) is listed in the ASA 1.1 certificate, the actual volume since the license issued up to audit of ASA 1.2 has been verified by the auditor, verification are done to the estimate for the next 12 months (next license) as well. The detailed are describes in the following table:
Previous Certificate Claim (tons/year)
Last year actual certified product
(tons/year)
Estimation for the next 12 months
FFB 208,636 222,525.45 225,220
CSPO 48,900 45,260.77 47,296
CSPK 12,000 11,046.30 11,261
Status: Comply D.2.2
The mill must also meet all registration and reporting requirements for the appropriate supply chain through the RSPO supply chain managing organization (RSPO IT platform).
The mill has meet the requirement regarding to the reporting of its supply chain, as it has been registered as RSPO member and on RSPO IT Platform:
Sub License ID CB73404
Member Name Sime Darby Plantation - Pondok Labu POM, PT PSA
Member ID RSPO_PO1000000327
RSPO Membership Number 1-0008-04-000-00 (Sime Darby Plantation Berhad)
Issued On 15-09-2018
Issued By PT Mutuagung Lestari
Status Active
During the license there is no CSPO and CSPK sales under other scheme (mill not applied other scheme such as ISCC), and no sales under conventional. During the license the mill has delivered and sell the CSPO product as much as 45,016.48 MT and CSPK 10,517.59 MT. buyer for CSPO i.e PT GHN and PT BEST, buyer for CSPK i.e PT LMI (KCP)