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Compliance and Enforcement Strategy

Earned Recognition: Primary Authority and Third Party Assurance Schemes Sharon Egan, Enforcement Strategy and Research, Enforcement and Local Authority Division. Compliance and Enforcement Strategy.

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Compliance and Enforcement Strategy

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  1. Earned Recognition: Primary Authority and Third Party Assurance Schemes Sharon Egan, Enforcement Strategy and Research, Enforcement and Local Authority Division

  2. Compliance and Enforcement Strategy • Developing a strategic approach to support implementation and set enforcement priorities in the revised FSA Strategy 2010-2015 • Aim is consistent approach to compliance and enforcement across foodchain by all regulators • Clearer direction and leadership.

  3. Compliance and Enforcement Strategy • Key Principles • Target interventions on areas where there is higher risk • More emphasis tackling non-compliance • Greater recognition of business’ own means of securing compliance • Increased transparency of standards • Use of wider incentives and penalties that drive compliance • Consistent risk based controls across foodchain

  4. The Government's strategy is to: • remove or simplify existing regulations that unnecessarily impede growth • reduce the overall volume of new regulation by introducing regulation only as a last resort • improve the quality of any remaining new regulation • move to less onerous and less bureaucratic enforcement regimes where inspections are targeted and risk-based • In April 2010, the Prime Minister said: "I want us to be the first government in modern history to leave office having reduced the overall burden of regulation, rather than increasing it."

  5. The Strategy Themes: Overview Changing FBO behaviour Assessing risk • Improved overview and understanding of risks associated with Food Businesses • Improved risk based regulation • Current approach based on monitoring, education and support can be enhanced through better targeting • An understanding of drivers of compliance in businesses and making greater use of these in our interventions and initiatives. Earned Recognition Tackling non-compliance • Use risk based approaches to monitor compliance to deliver efficiencies and free up resources to tackle key risks • Increase FBO perceptions of the likelihood & consequences of detection • Tougher on persistent/high risk non-compliance

  6. Earned Recognition 1 • Use risk based approaches to monitor compliance. • Better efficiency and free up resources to better tackle key risks • Capitalise on assurance schemes • Removes duplication between public sector and industry’s own checks • Modern Regulation- removing regulatory burdens and encouraging self regulation- strategic outcome • Supports FSA strategy outcome- that responsibility for compliance lies with FBOs

  7. Earned Recognition 2 • Key area for delivery of the strategy • Earned Recognition is about reducing the frequency or different interventions in low risk / compliant businesses • Improve the targeting of regulator state resources to higher risk/non-compliant businesses • Better efficiency and free up resources to better tackle key areas and serious or persistent non-compliance • At core of all ER approaches- OCs are always delivered by competent authorities, OCs are non-delegable from CA • Regulator respond to reactive regulation- incidents, complaints, intelligence-led.

  8. Earned Recognition: Primary (/ Home) Authority • Mechanism to deliver improved co-ordination and consistency • Provides for a ‘national’ approach to England and Wales chains • In retail and catering pilot • Aim is to deliver efficiency and effectiveness in regulation of the PAS food business • Evidence- FBO, LAs and FSA and analysis provides rationale for approach to programmed inspection • Regulator respond to reactive regulation- incidents, complaints, intelligence-led.

  9. Earned Recognition: Primary Authority • Inspection plans and Earned Recognition Rationale Document. • Hygiene and Standards • PA check verify central systems • Eg supermarket- full and open access internal data systems- daily, weekly and monthly checks, regular in-house and external audit reports. • Sound evidence basis. • Cross-reference for analysis- FHRS, Helpline, Incidents data (if possible) • Company also provide customer complaints, LA interventions

  10. Earned Recognition: Primary Authority • IP kept up to date and reactive- vehicle for dissemination information • All interventions feedback- inspection and reactive interventions • May include specific topics re FBO (date coding, temperature checks) or address national strategic priorities (eg Campylobacter/Listeria of FDS, E. coli guidance) • IP broadly sets out to test implementation of the central FSMS. • Address training, FSMS description, non-conformances • RAG necessary to verify • ERRD provides basis- FSA review

  11. Earned Recognition in Dairy Hygiene • A baseline 24 months inspection frequency for farms supplying raw milk for pasteurisation • Subject to the caveats, dairy farms with membership of the Red Tractor Assurance Dairy (RTAD) scheme will benefit from an extended official inspection frequency of 10 years • Dairy farms producing raw drinking milk for human consumption will be subject to official inspection at a frequency of 6 months. • Ad hoc inspections will be carried out in response to adverse findings or notifications from official inspection, RTAD audit, third parties or first purchasers of raw milk. • RTAD farms known to supply raw milk to manufacturers of unpasteurised dairy product will not benefit from an extended official inspection frequency. • Those RTAD members subject to formal official action, or suspension from the RTAD scheme, will not benefit from an extended official inspection frequency. • In the first year of the amended controls official inspections will focus on those dairy farms judged as least compliant under the previous official controls regime. • The new arrangements will be reviewed after a period of three years

  12. Earned Recognition in Dairy Hygiene Scope of the Scheme FSA Read only Read only Monthly re-fresh FSA RTADS Portal Dairy Hygiene Database RTADDB FSA e-mail Non-compliances Apply monthly updates DHIS e-mail Non-compliances Read and update Read only DHIS

  13. Earned Recognition: Third Party Assurance Schemes • Approach already established in primary production hygiene • IPPC pilot poultry pig farms one year. • Dairy farm consultation- use ADF scheme membership to inform risk and inspection frequency in medium-low risk only. • Must address regulations, information sharing pre-requisite. • Checks with scheme, CBs and ‘random’ inspections. • SMEs? • Regulator respond to reactive regulation- incidents, complaints, intelligence-led.

  14. Earned Recognition Common Safeguards and Checks • Meet requirements of 882. • Openness and trust- data sharing • A percentage checked annually by unannounced inspection- is the system working as intended? • High level governance • Evidence and intelligence based • UKAS accredited CBs- impartial, competent and accountable • ER can be awarded, it can also be removed- a reactive system if it isn’t protecting consumers

  15. Earned Recognition Consumer views • ‘Who checks the checkers?...’ • ‘Earned Recognition should not be inherited...’. • ‘We don’t need to have stickers up showing what and how they earn ER...’* • ‘SMEs shouldn’t be disadvantaged’ - Broadly content with the outline proposal- checks and balances described were important. - The fact that inspections are paid for or internal to FBO is not a barrier. (* but some wanted to know)

  16. Delivery: Code of Practice Review • Delivered by 2013. • Some changes incorporated ahead of that - RANs extension, competency framework. • RDNA work led by CIEH and TSI, with LBRO facilitating through world class coalition and FSA input. • ‘Core’ modules and ‘petal’ specialties. • Trialled across range of authorities, goes live October. • Future- evaluation and linking to Food authorisation. • Future-proof- allow for incorporation if positive outcomes from pilots such as AGMA/GMPPP.

  17. Next Steps • Joint development of the model, including delivery plans/options. • Ongoing cost/benefit analysis, impact assessments • Aim is for formal consultation to commence, informed by pilot outcomes. • Post-consultation there will be joint development of business /implementation plans for the strategy. • Aim is UK wide policy. Although implementation is a devolved matter, seeking consistency in approach.

  18. Questions for today • Are there other elements we should consider in ER? • Does it fit with your thinking on service delivery? • What are keys risks?

  19. O unicorn among the cedars To whom no magic charm can lead us, White childhood moving like a sigh Through the green wods unharmed in thySophisticated innocence... -- W. H. Auden

  20. Thank YouComments? Please email:ces@foodstandards.gsi.gov.uk

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