Tom Vanoverschelde Grange, March 2011

1. Federal Agency for the Safety of the Food Chain Belgium Attaining the objective of 5-year coverage of activities under 882/2004 Regulation : The Belgian approach Tom Vanoverschelde Grange, March 2011

2. Contents • About the FASFC • Organization of the internal audit • Setting up of the audit universe • Ensuring a coverage of all activities under Regulation882/2004 over a 5 year period

3. The Belgian Food Safety Agency

4. Our goal : optimising Food chain checks Suppliers of agriculture (feed industry, raw materials, pesticides) Agriculture Food and feed industry Wholesale business Import / export / IC trade Retail Hotels, Restaurants, Pubs Transport

5. Core business of the Food Agency

6. Some figures • Central services in Brussels, 11 Provincial Control Units (PCU), 5 internal laboratories, network of external laboratories • Approx. 1300 employees • 800 independent veterinarians (600 FTE) • Annual budget : € 180 million

7. The internal audit of the FASFC* • Operational since July 2007 • Staff function placed under the direct control of the CEO • One service : quality, environment, ombudsman, and prevention. • 3 full time auditors (2  3 in September 2010) • ISO 9001 certified since October 2008, successful ISO 17020 accreditation audit in December 2010 * The organization of the internal audit has been presented at the meeting in Grange on 8/12/08

8. Audits • Mix of compliance, effectiveness and efficiency • All parts of the organization : administrative processes, inspection services, laboratories, quality management • Competence through : • Training of lead auditors • Use of a pool of technical experts who have a broad knowledge and experience regarding the audit scope • Since 2011 : technical experts = field inspectors • Example of audit scope : “organization and conducting of inspections on the production of foodstuff from non-animal origin”

9. Audit universe • Decision 2006/677 EC : “Form part of an audit program that ensures adequate coverage of all relevant areas of activity and all relevant competent authorities within the sectors covered by Regulation (EC) No 882/2004 at an appropriate risk-based frequency over a period not exceeding five years” • To achieve this, and be able to provide proof of it, a listing of all activities under the scope of 882/2004 is required.

10. Audit universe (2) • Different approaches were considered: • Sectors and subsectors in the food chain • Business processes • Organizational entities

11. Option 1 : sectors in the food chain • Advantages : • Aligned with MANCP / national control plan • Aligned with the structure of the inspection services • Establishing a link with legislation is easier • More technical experts available, with less audit preparation required • Disadvantages: • Supporting services are not linked to a particular sector in the food chain • Some key processes are transversal, and auditing them in parts and pieces will cause a lose of oversight for auditors • “grey areas” in the food chain which do not belong to one specific sector

12. Option 2 : Business processes • Advantages : • The relationships and links between organizational entities and activities are documented and audited. • Difficulties and problems between interrelated activities will be found (e.g. Central and decentralized services) • Disadvantages: • Not all business processes are documented or identified • Every inspection, regardless of the sector, follows the same process. One process covers a wide range of different subjects. • Auditing becomes more difficult because more people and levels in the organization are involved. Auditors need a thorough insight in the overall organizational processes and their relationship. • Not all activities are easily transformed in a process.

13. Option 3 : Organizational entities • Advantages : • The universe is easy to document (= organizational chart) • All entities will be audited  all activities will be covered • Individual audit planning is easier, the number of people involved is limited. • Follows the mindset of a bureaucratic organization • Disadvantages : • Relation between risk and audit coverage is out of balance : all control units should then be audited, even if they perform the same activities. • Entities mostly fulfill activities that are part of a process. The end result of the process is not being audited. • Problems between entities will not be easily found and analyzed.

14. The audit universe of the FASFC • Every option has too many disadvantages to be easily usable  Why not combine them into one model? A U D I T U N I V E R S e Sectors  Technical operations Processes  Transversal operations Entities  Operations of support

15. The audit universe • All activities listed in 3 categories : technical, transversal and support activities • Find the balance between too much and not enough detail • A tool which: • provides a view on all activities to audit ; • displays the activities covered and those not covered • helps to make up the audit program for the next year(s)

16. Building the universe • Technical operations : • Primary sector animals, primary sector plant, animal welfare, feed, transformation of food of animal or non-animal origin, distribution sector, import – export – internal EU trade. • Transversal operations : • Risk analysis, control program, sampling process, collaboration with other organizations, crisis management, registration of operators… • Operations of support : • HR, IT, logistics, financial processes, procurement… Not all activities are directly related to 882/2004.

17. The audit universe See hyperlink: Audit universe for presentation FVO March 9 2011.xlsx

18. From audit universe to audit scope Plan • Audit scope : from objective to follow-up • Example : Inspections in butcheries. • Existence and knowledge of control program and other objectives • Overall organization of the control unit (incl. quality management) • Planning the inspections : assignment of inspectors, choice of butchery, preparation. • Carry-out of the inspection : sample of inspections followed by the auditors : communication/behavior towards operator, organization of the inspection, respect and use of procedures/ checklists/forms, interpretation of findings, determine result and follow-up needed. • General follow-up on findings and measures taken. • Supervision, quality control and monitoring of inspections : on individual and team level. Do Check Act

19. Interpretation of « coverage » • Previous meetings of the Network of Audit Representatives gave us these guidelines : • A full coverage of a certain domain is not realistic, audit is always based on sampling  an audit can cover a defined scope even when it’s conducted in one province. • Single audit : if some areas have been audited by other qualified bodies, the same work does not have to be repeated.

20. Coverage in practice (1) • Some scopes or processes form part of an audit assignment, but are not the main focus of the audit. Some examples: • Collaboration with independent veterinarians is part of the scope of every audit in sectors like slaughterhouses, meat industry and import / export. • An audit about hygiene in slaughterhouses also looks at measures taken to ensure animal welfare. • Handling of customer complaints is looked upon in almost all audits in inspection services, but the complaints process as a whole is not reviewed.

21. Coverage in practice (2) • Coverage • Main scope : an audit has been carried out with the activity as main scope • Part of scope : elements of the process or activity have been reviewed, but not all • Decision • If 1 time referred to as main scope  covered. • (multiple) Part of scope  judgment by internal audit • No audits  plan an audit in next audit program

22. Follow-up of audit recommandations • Responsible = line management • On a continuous basis: • Part of quality management system • Quality managers at different levels in the organization • Follow-up audits • All recommendations are reviewed in a future follow-up audit • 1 to 2 years later, depending on risk and priorities

23. Realization of action plans

24. Some possible issues… • When does the 5 year period start ? • After 5 years : full restart or scroll further one year ? • Documented audit universe + full coverage in a 5 year period  still a need for a (quantified) risk analysis ? • Will full coverage lead to less FVO-missions to Belgium ?

25. Contacts FASFC (Federal Agency for the Safety of the Food Chain) CA Botanique – Food Safety Center – 8th floor Boulevard du Jardin Botanique 55 B - 1000 BRUSSELS www.afsca.be Guy Mommens Director Internal audit, Quality & Prevention Tel +32 (0)2 211 82 33 guy.mommens@favv.be

26. Audit : A profession that serves the whole organization Hagar the Horrible Dik Browne Wouldn’t it be better to try the backdoor first ?