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[PDF] Review of audit arrangements in FSA approved meat

21 fév 2014 · the FSA and Food Business Operators (FBOs) in FSA approved meat establishments What is the subject of controls and assurances within the meat supply chain The proposals are in Independent Meat Suppliers, Scottish Association of Meat Wholesalers, British ASIA HALAL MEAT SUPPLIER LTD

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www.food.gov.uk

FOOD STANDARDS AGENCY CONSULTATION

Title: REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT

ESTABLISHMENTS WITHIN THE UK

CONSULTATION SUMMARY PAGE

Date consultation launched: Closing date for responses:

21 February 2014 16 May 2014

Who will this consultation be of most interest to? Enforcement bodies carrying out official controls (competent authorities) on behalf of the FSA and Food Business Operators (FBOs) in FSA approved meat establishments.

What is the subject of this consultation?

Key changes are being considered for official control audits in FSA approved meat establishments - i.e. Slaughterhouses, Cutting plants (Co located and Stand Alone) and Game Handling Establishments subject to veterinary controls across the UK. The proposals include changes to audit risk ratings, use of evidence, audit outcomes, audit frequencies. An initial impact assessment on the proposed changes is included in the consultation.

What is the purpose of this consultation?

To seek stakeholders' views on the key elements of the draft audit proposal and evidence towards our initial impact assessment (Annex B) of the proposals on UK stakeholders. The audit process is due fundamental review as it has been in place since 2006 and the proposals are intended to make the current official control audit system in the UK more proportionate to the risks posed by meat production, by taking into account additional controls and assurances within the meat supply chain . The proposals are in line with from the FSA's strategic outcome that enforcement is effective, consistent, risk-based, proportionate and focused on improving public health and engagement with industry representatives and FSA has developed the proposals in line with the following objectives :

Understandable, fair and effective audit system

Assure confidence (both internal and external) in the accuracy and consistency of audit assessments; Leads to appropriate enforcement action and drives FBO compliance Provides the basis for understandable meat plant audit outcomes and for the application of earned recognition benefits for better performing plants with the extension of audit frequencies. If you would prefer to receive future FSA consultations by e-mail, or if you no longer wish to receive information on this subject please notify the named person in this consultation. Following implementation of the new audit system in Ju ly 2014, pending consultation results, It is expected that all meat establishments will have undergone an audit under the new arrangements by February 2015

Responses to this consultation should be sent to:

Name Kenneth Thoresen

Division/Branch Operations Assurance

Division

FOOD STANDARDS AGENCY

Tel: 07789877601

Fax: Postal address: Food Standards Agency

Operations Change and Support Team

Foss House

Kings Pool, 1-2 Peasholme Green

York YO1 7PR

Email:

Is an Impact Assessment included

with this consultation? Yes No See Annex A for reason. 2 REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED MEAT ESTABLISHMENTS WITHIN

THE UK

DETAIL OF CONSULTATION

Introduction

1. The current audit system for FSA approved meat establishments was

introduced in January 2006, with the introduction of the EC Food Hygiene legislation. While refinements have been made to the system over the years, we believe that it is now appropriate to undertake a more fundamental review of effectiveness. The FSA Board discussed audit arrangements in September

2013, as part of wider considerations on compliance in the meat industry [FSA

13/09/06

], and, acknowledging concerns raised by industry representatives, there was support for early improvements to strengthen audit arrangements.

2. Flexibilities within the EU legislative framework have been considered to inform

proposals, with consideration of official control audit systems in other Member States and third countries, including scoring, frequency of audit, and patterns of visits.

3. A UK-wide review of audit arrangements has been carried out on basis

(following the FSA Board meeting in September 2013
) with consideration towards the differences within each of the four countries - including that meat official controls delivered by the Department of Agriculture and Rural Development (DARD) in Northern Ireland on the FSA's behalf, and the establishment of the National Food Body in Scotland, in April 2015 -potentially influencing how changes might be implemented in these countries.

4. There are 1,401 approved meat establishments in GB and 59 in Northern

Ireland outlined as follows:

Establishments

England Scotland Wales Northern

Ireland

Slaughterhouses 274 33 27 20

Game Handling

Establishments 44 18 0 3

Cutting Plants (&

Market Stalls)

741
(55 Market Stalls)

93 57 36

5. The Food Standards Agency (FSA) system of audit in approved meat plants (slaughterhouses, cutting plants and game handling establishments) has been

in place since 2006. Some refinements have been made since then - most recently in October 2012 where a greater emphasis was placed on food safety in terms of scores awarded, and audits for slaughterhouses with co -located cutting plants were combined - but audit arrangements have largely stayed the same.

6. A strategic review of audit arrangements has been under way, with the FSA

working in collaboration with meat industry stakeholders to come up with proposals for change and consultation in relation to the following key underpinning audit requirements:

Risk ratings

Use of evidence

3

Audit outcomes

Audit frequencies

Audit Proposals

7. Who carries out the audit function -Recital (9) of Regulation (EC) 854/2004 0F 1 requires that Official Veterinarians must carry out the audit role in approved meat establishments, given their specific expertise. Drawing on industry feedback and also previous Board discussions, it is clear that we need to ensure that audits are carried out objectively, and by competent and suitably-qualified auditors, to ensure a consistent approach , and that audit findings are accepted and trusted. Most industry stakeholders consider that the auditor should be separate to Official Veterinarians involved in routine (daily) official controls and inspections, and we developed the proposals on this basis. 8. Risk Rating -Regulation (EC) 854/2004 outlines the requirements for auditing of meat establishments as follows; "the nature and intensity of auditing tasks in respect of individual establishments shall depend upon the assessed risk. To this end, the competent authority shall regularly assess: (a) public and, where appropriate, animal health risks; (b) in the case of slaughterhouses, animal welfare aspects; (c) the type and throughput of the processes carried out; and (d) the food business operator's past record as regards compliance with food law."

9. The current auditing system is in two parts, with the first applying scores based on potential hazards (or pre-set factors), and the second based on effectiveness of

systems in place. Scores are combined to give an overall audit score which determines how frequently an establishment is audited. Taking potential hazards into account, many premises end up on frequent audits because of their throughput, or because they are processing more than one species of animal or due to the processes carried out. This is regardless of how well these risks are minimised or how effective control systems are. The proposal is that scoring of risk will be thoroughly assessed through appropriate questions and assessments during the actual audit process, and not based on potential hazards. This consultation asks for stakeholder views on that proposal.

10.Use of evidence - To strengthen how evidence may be drawn upon and used

to assess overall food business operator performance, the current descriptors of active, broad, weak or poor compliance are considered vague in terms of objectivity in scoring and they are not easy to understand. A number of audit systems have been looked at to inform an alternative approach including:

SAI Global (formally EFSIS)

British Retail Consortium

Red Tractor

Canada

Australia

New Zealand

4

Definitions proposed

Score Description

Compliant Compliance with a food safety programme, food regulatory requirements and animal health and welfare regulations (in the case of slaughterhouses) is achieved if the food business is operating in accordance with its food safety management systems, food safety standards and has met the requirements of the regulations. Minor non A non-compliance that is not likely to compromise public health

compliance (including food safety), animal health and welfare, or lead to the handling of unsafe or unsuitable food. A minor non-compliance

is an isolated low risk situation and does not compromise achieving control measures of the food safety program i.e. overall the food safety program is still effective in controlling the food safety hazards. When viewed collectively a number of related minor non -compliances may represent a major non compliance. Major non A major non-compliance is a non-compliance that is likely to

compliance compromise public health (including food safety), animal health and welfare, or may lead to the production and handling of unsafe or unsuitable food if no remedial action is taken. When viewed collectively a number of related major non-compliances

may represent critical non-compliance.

Critical non

compliance A critical non-compliance is non-compliance where the contravention poses an imminent and serious risk to public health (including food safety), animal health or welfare.

11.Audit outcomes - The current compliance descriptions of active, broad, weak

and poor are used to provide outcomes of audits, but, to make audit outcomes more transparent, alternative outcomes have been considered. Using objective evidence, it is proposed that a grading system is introduced wh ich will consider the number and type of non -compliances identified during an audit (so the compliance scores for each question and overall section of the audit), and reflect the extent and effectiveness of compliance, with four compliance ratings - good, generally satisfactory, improvement necessary or urgent improvement necessary. The proposed grading system and audit outcomes are outlined in the table below, and we have taken into account a comparison to the Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises under Local Authority control: 5

Audit Outcome proposal

Compliance rating Description Comparison to Food Comparison to

Hygiene Rating

Food Hygiene

Scheme (England,

Information

Wales and Northern

Scheme

Ireland)

(Scotland)

Good No issues of significance

for public health, animal health or animal welfare during the entire audit period.

Generally

Satisfactory

No issues of significance

for public health, animal health or animal welfare identified on the day of the audit. Any non compliances identified during the audit period corrected promptly.

Improvement

necessary

Major non-compliances

identified at audit and/or non compliances during the audit period not always responded to and corrected promptly.

Urgent

Improvement

necessary

Multiple major non

compliances or critical non compliance identified during audit visit or interim audit period . Official intervention required to ensure public health safeguards.

12.Audit Frequencies - Frequency of audit is not prescribed in EU regulations. General

obligations with regard to the organisation of official controls under Regulation (EC)

882/2002 are provided in Article 3, and bring out that these controls should be carried

out regularly, on a risk basis, and with appropriate frequency. The official controls may be carried out without prior warning -except in cases such as audit, where prior notification may be necessary.

13.Under the current system, frequencies of audits vary between a minimum of once

every two, three, five, eight or twelve months - depending on overall audit scores. Eight months is typically the ceiling level for slaughterhouses and cutting plants. In working up audit options, the following factors were considered relevant: The need to focus activities on problematic plants, especially with follow-up visits, ensuring an appropriate level of consideration, and having objective evidence available in the event of a need to review approval. Employing effectively focused partial audits to address audit findings.

Reducing regulatory burdens for good performers.

6 Providing an incentive for businesses to do things well, widening the frequency for those that are performing well compared to those that are not. Balancing follow-up audit visits (partial audits) and unannounced inspections to maintain assurances on food business operator performance.

14.There is no routine official presence in standalone cutting plants, and for this reason it

is proposed that twelve months remains the maximum audit frequency. For slaughterhouses with or without cutting plants, and approved game handling establishments where there is routine attendance by officials, there is the possibility of achieving an 18 -month audit frequency where good standards are being achieved. Proposed audit frequencies for slaughterhouse/co-located cutting plants and approved game handling establishments Audit outcome Follow up partial audit Full audit frequency

Good 0 18 months

Generally satisfactory 1 interim visit 12 months

Improvement necessary Within 1 month 3 months

Urgent Improvement

necessary

Within 1 month

2 months

Proposed audit frequencies for standalone cutting plants Audit outcome Follow up partial Minimum number Full audit audit of unannounced frequency inspections during interim audit period

Good 0 1 12 months

Generally

Satisfactory

1 interim visit 1

Improvement

necessary

Within1 month 1

3 months

Urgent Improvement

necessary

Within 1 month 1

2 months

7

Key proposal(s):

Preferred options for a new audit system, in relation to: Risk ratings -It is proposed that intensity of audits is based on risks that are fully and properly assessed during the audit process, replacing the current approach where pre-set factors based on potential hazards influence frequency of audit regardless of how effective control systems are. Use of evidence -Current descriptions of compliance given to each audit question / audit section -active, broad, weak and poor -are considered vague in terms of objectivity of scoring. It is proposed that these are changed to minor, major and critical non-compliances, drawing on approaches used in alternative audit systems, with these underpinned by objective requirements and evidence Audit outcomes - four new compliance ratings are proposed on audit outcomes -good, generally satisfactory, improvement necessary or urgent improvement necessary. Th e proposed grading system is in comparison to Food Hygiene Rating Scheme and Food Hygiene Information Schemes in place for food premises. Frequency of audit -It is proposed that twelve months remains the maximum audit frequency for Stand Alone Cutting Plants. For slaughterhouses with or without cutting plants, and approved game handling establishments where there is routine attendance by FSA officials, there is the possibility of achieving an 18 -month audit frequency where good standards are being achieved.

Consultation Process

15.There has been ongoing communication with stakeholders during development

of the audit proposals and the FSA held a number of ad hoc meetings with key organisations to help inform its discussions. The FSA then held a series of workshops with stakeholders across the UK to gather views and to understand the potential impact of the proposal. These meetings have informed this consultation and the accompanying IA.

16.This consultation seeks your views on the key changes listed in the above box.

A number of key questions are set out in the box below. We would also be interested in your comments about any other aspect of the proposal, which you would like to bring to our attention.

17.This consultation has been issued by the FSA on a UK basis to all identified stakeholders, including those falling within the broad scope of the proposal where Defra and the devolved administrations have lead policy responsibility for the official controls delivered.

8

Questions asked in this consultation:.

Q1: Risk Rating

a) Do you consider the provisions relating to how risk is used to determine the nature and intensity of audit appropriate? If not, please provide information to support your answer

Q2: Use of Evidence

b) The provisions for proposed scoring of individual audit questions and overall section scores are underpinned by objective evidence, do you support the new descriptors? If not, please provide information to support your answer

Q3: Audit Outcomes

a) Do you have any comments on the proposed four tier compliance rating system for FSA approved meat establishments -so businesses will either be given a compliance rating of good, generally satisfactory, improvement necessary or urgent improvement necessary -depending on compliance and standards assessed through the audit? b) Are audit outcomes sufficiently clear and easy to understand? If not, please suggest alternative wording.

Q4:Audit Frequencies

a) Do you support the proposed new audit frequencies, noting that less compliant businesses will be audited more frequently and also have further unannounced inspections; and the ceiling level for cutting plants without routine daily attendance by officials will remain at 12 months, while this is extended to 18 months in premises with a routine presence and achieving good standards?

18.We welcome comments from all stakeholders. Please send your response by email or post using the contact details given. All responses received as part of this consultation will be given careful consideration; they will be summarised and published on the FSA's website within three months of the close of the

consultation

Responses

19.Responses are required by close 16

th

May 2014. Please state, in your

response, whether you are responding as a private individual or on behalf of an organisation/company (including details of any stakeholders your organisation represents). 9 Thank you on behalf of the Food Standards Agency for participating in this public consultation.

Yours,

Name -Kenneth Thoresen

Branch -FSA Operations Group

Division -Operations Assurance Division

Enclosed

Annex A: Standard Consultation Information

Annex B: Impact Assessment

Annex C: List of interested parties

10

Annex A

Queries

1. If you have any queries relating to this consultation please contact the person named

on page 1, who will be able to respond to your questions. Publication of personal data and confidentiality of responses

2. In accordance with the FSA principle of openness we shall keep a copy of the completed consultation and responses, to be made available to the public on receipt of a request to the FSA Consultation Coordinator (020 7276 8140). The FSA will publish a summary of

responses, which may include your full name. Disclosure of any other personal data would be made only upon request for the full consultation responses. If you do not want this information to be released, please complete and return the Publication of Personal Data form, which is on the website at Return of this form does not mean that we will treat your response to the consultation as confidential, just your personal data.

3. In accordance with the provisions of Freedom of Information Act 2000/Environmental Information Regulations 2004, all information contained in your response may be subject to publication or disclosure. If you consider that some of the information provided in your response should not be disclosed, you should indicate the information concerned, request that it is not disclosed and explain what harm you

consider would result from disclosure. The final decision on whether the information should be withheld rests with the FSA. However, we will take into account your views when making this decision.

4. Any automatic confidentiality disclaimer generated by your IT system will not be considered as such a request unless you specifically include a request, with an explanation, in the main text of your response.

Further information

5. A list of interested parties to whom this letter is being sent appears in Annex C.

Please feel free to pass this document to any other interested parties, or send us their full contact details and we will arrange for a copy to be sent to them direct.

6. Please contact us for alternative versions of the consultation documents in Braille,

other languages or audiocassette.

7. Please let us know if you need paper copies of the consultation documents or of

anything specified under 'Other relevant documents'. 8. This consultation has been prepared in accordance with HM Government consultation principles 1F 2

9. An Impact Assessment will normally be published alongside a formal consultation.

Please see the Impact Assessment at Annex B.

10.For details about the consultation process (not about the content of this consultation)

please contact: Food Standards Agency Consultation Co-ordinator, Room 2A, Aviation House, 125 Kingsway, London, WC2B 6NH. Tel: 020

7276 8140.

2 -guidance 11

Comments on the consultation process itself

11.We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process. If you would like to help us improve the quality of future

consultations, please feel free to share your thoughts with us by using the

Consultation Feedback Questionnaire

at

12.If you would like to be included on future Food Standards Agency consultations on other topics, please advise us of those subject areas that you might be specifically

interested in by using the

Consultation Feedback Questionnaire at

http://www.food.gov.uk/multimedia/worddocs/consultfeedback.doc The questionnaire can also be used to update us about your existing contact details. 12

Title:

REVIEW OF AUDIT ARRANGEMENTS IN FSA APPROVED

MEAT ESTABLISHMENTS WITHIN THE UK

IA No: 0048

Lead department or agency:

Food Standards Agency

Other departments or agencies:

Date: 20/02/2014

Stage: Consultation

Source of intervention: Domestic

Type of measure: Other

Contact for enquiries: Kenneth Thoresen

07789877601

Kenneth.Thoresen@foodstandards.gsi.gov.u

k

Summary: Intervention and Options

RPC Opinion: RPC Opinion Status

Cost of Preferred (or more likely) Option

Total Net Present

Value

£1.81

Business Net

Present Value

£0.81

Net cost to business per

year (EANCB on 2009 prices) -£0.08

In scope of One-In,

Two-Out?

Measure qualifies as

No OUT

What is the problem under consideration? Why is government intervention necessary? Food can pose a risk to human health if it is not produced, manufactured and handled hygienically.

Meat Premises are subject to official control audits carried out with prior warning to ensure compliance

with hygiene regulations. The FSA is the central competent authority responsible for these audits. The

current system has been in place, and remained unchanged, since its introduction in 2006. Aquotesdbs_dbs17.pdfusesText_23