dg sanco directorate f - food and veterinary office

Health andConsumers

Health andConsumers 1

DG SANCO DIRECTORATE F - FOOD AND VETERINARY OFFICE

Item 2

Good practice issues (Annual Report and Executive Summaries)

Aidan O’Connor - Unit F1

Tom Fitzpatrick – Unit F1

Network of Experts on MANCPs and Annual Reports meeting,

Grange, 21-22 November 2012

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Contents

• Good practice issues (Annual Report and Executive Summaries)

• Verification of effectiveness

• Issues arising from the meeting on MS with devolved structures

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MS Annual Reports

Commission Reports to the European Parliament and to the Council

• 1st Report COM(2010) 441

• This pointed to large variability between MS reports in both structure and content and the absence of harmonised data on controls

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2nd Report COM(2012)122(Based inter alia on Member State Annual Reports for 2008 and 2009)

• Available at: http://eur-lex.europa.eu/Result.do?T1=V5&T2=2012&T3=122&RechType=RECH_naturel&Submit=Search

• Comparability of data had improved significantly due to

• MS acquiring experience

• Commission dialogue/feedback

• Main areas for ongoing improvement

• Data collection and analysis

• Overall statements of performance

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Overview of 2010 Annual Reports

• Global feedback, supplemented by individual feedback in writing (with opportunity to discuss during GFAs)

• All 27 Annual Reports provided

• 21 MS provided an Executive Summary

• The Executive Summaries

• facilitated a higher level of analysis and self-assessment by MS

• were seen by MS themselves as a useful instrument

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Executive Summaries

• Model for an Executive Summary developed in conjunction with MS for voluntary use with 2010 Annual Reports

• Based on existing guidelines for the Annual Report (Commission Decision 2008/654/EC), in particular chapters 2 (Purpose of the Annual Report), 8 (General Guidance) and 9.5 (Statement on the overall performance)

• Objective: Providing a tool to improve the value and quality of both MS and Commission Annual Reports through

• a high-level and comprehensive statement on overall performance (self-assessment) based on analysis and synthesis of data

• its contribution to continuous improvement

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Overall effectiveness of controls

• Most MS have in place strategic, operational or compliance indicators

• Wide variation in

• Sectors covered

• Degree to which indicators/measures are SMART*

• Scope of the statement on overall effectiveness

*Specific, Measurable, Attainable, Realistic and Time-bound

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Trends on controls

• Continuing trend towards more risk-based control systems, however,

• some reports suggest that MS do not use a risk-assessment model in every sector

• limited information given on trends in controls (priorities and results)

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Trend analysis of non-compliance (1)

• Main identified areas of non-compliance across sectors:

• HACCP• “Prerequisites”/hygiene• Labelling• Microbiological contamination• Structures/equipment

• Issues on HACCP/Hygiene attributed to staff turnover and lack of training at FBOs

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Trend analysis of non-compliance (2)

• A limited number of reports included analysis of overall levels of compliance

• Some examples of good reporting practice: DK, FI, HU, IE, IT, NL, UK

• Root-cause analysis is generally limited

• Some examples of good reporting practice: BG, CZ, IT, IE, PL, SK, NL, SI

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Enforcement trends: actions taken in case of non-compliance

• In most cases data is provided, however

• Not all sectors covered

• Lack of analysis of overall trends/conclusions

• Internal inconsistency in data presentation

• Difficult to determine the effectiveness of enforcement measures

• Some examples of good reporting practice: CZ, DK, IE, FI, IT, NL

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National systems of audits

• All MS carried out audits in the context of Article 4(6) of Regulation 882/2004 during 2010, however

• 1/3 of Reports did not provide an overview of audit programme, results and follow-up

• 3 MS reported that resource constraints in the audit unit(s) had curtailed implementation of audits

• Some examples of good reporting practice: IT, FR, UK, HU

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Resources

• For the most part no significant developments were highlighted during 2010

• Some points highlighted

• Significant organisational change: FR, NL, SI and UK

• Streamlining of laboratory services: BG (Ministry of Agriculture), ES (food safety), and PL (pesticides)

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Actions taken to improve performance of control authorities (1)

• The main actions involve training, workshops, guidelines, amendments to MANCP, updating legislation

Examples of other reported actions

• Development of information systems and efforts to improve data collection to enhance oversight by CCA: DK, FI, IT, SE

• Specific performance indicators: IT

• Better evaluation and critical analysis of control data

• In Italy, a central institute is designated to undertake this task

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Actions taken to improve performance of control authorities (2)

Examples of other reported actions (continued)

• Measures planned to improve capacity of CCA to verify effectiveness of controls (ES)

• Specific coordination/cooperation improvements (EE, PL, PT)

• Development of internet-based tool for diagnosis of harmful organisms (DE)

• Launch of new food hygiene rating scheme for FBOs (UK)

• Actions in view of growth in internet commerce in food sector (NL, DK, DE)

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Actions taken to improve the performance of Food Business Operators

• Main actions involve: guidelines, training, information campaigns, events, brochures

Examples of other reported actions

• Checklist to verify labelling for food supplements was provided to FBOs with resulting decrease in irregularities (PT)

• Centre for animal welfare created to undertake research and disseminate information to stakeholders (DK)

• Scheme for FBOs to obtain “elite status” and charging of fees for follow-up visits (DK) and “Smiley system” (BE)

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MS Annual Reports: Conclusions (1)

• Quality of Annual Reports continues to improve

• Positive trend across MS towards risk-based controls continues

• Meaningful conclusions based on trend and root cause analysis provided in 13 Annual Reports

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Main areas for improvement:

• Consistency, comparability and collation of control data within MS

• Make clear connections between data presentations to show overall context (controls non-compliances enforcement)

• Emphasis on self-assessment and root-cause analysis

• Show how account is taken of national audit findings (Article 4(6))

• Use of SMART in targets/performance indicators in MANCP

• Show impact on future planning

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• The Executive Summaries model has provided a framework for addressing many of the areas for improvement

• Based on the very positive experience with the 2010 exercise, the Commission invites Member States to use the same Executive Summary model with their future Annual Reports

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• Topics for further discussion (point 6 of agenda)

• Self-assessment (Guidelines, point 9.5)

• Root cause analysis (Guidelines, 9.2.2.3)

• Use of indicators (Guidelines 9.1 and 9.5)

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Good practice initiatives (1)

“Systems Audits” - Objectives

• Examine operation of horizontal control system elements

• Identify good practice, as well as difficulties encountered

• To promote/contribute to coherent EU-wide approach to official control systems

=> Increased levels of assurance and confidence

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“Systems Audits” – Approach & Deliverables

• Initial desk-study of available information (MANCP, MS AR, FVO reports)

• Targeted audits in sample of MS

• Reports to MS audited, and overall overview report

• Working groups to discuss results, identify good/best practice, identify need for additional guidance (or improved legal provisions)

• Input into Annual Report cf. Art. 44 of Reg. 882/2004

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Systems Audits: verification of effectiveness

• Two fact finding pilots in 2012:

• France (26–30 November)

• Austria (10–14 December)

• 5 SA in 2013: Belgium (4-8 March)Czech Republic(18-22 March)Denmark (8-12 April)Bulgaria (3-7 June)Ireland (2-6 September)

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Development of Guidance: Verification of effectiveness (preparation for the Systems Audits)

• FVO currently developing guidance on the requirements for systems to verify effectiveness of official controls [Article 8(3)(a) of Regulation 882/2004]

• The draft was developed with input from five Member States (DE, IE, IT, NL, SE)

• Early draft circulated at CVO/HoS meeting in June 2012 for comments

• Further development based on SAs

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Verification of effectiveness (Main elements of the system)

•Verification of effectiveness is the responsibility of the line management of the CA (i.e. it does not require a separate structure)

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•Verification of effectiveness: On-going assessment of specific activities/procedures (including on-the-spot components) with a focus on effectiveness (ideally combined with root cause analysis where evidence of lack of effectiveness is identified)

• Verification of compliance is an essential element of verification of effectiveness

•Audit: Occasional judgement on whole (or possibly part) of the system by independent party. Article 4(6) audits may contribute to Article 8(3) systems for verification of effectiveness but alone, are generally not sufficient for that purpose

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•Documented Procedures in place for the verification of individual official controls

•Arrangements in place for verification of effectiveness of official control system(s)

•Results of the verification process, including on-the-spot components

•Feedback loop to complete the PDCA cycle

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Forum for exchange of practice on implementation of Regulation 882/2004 among MS with devolved

competences

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Forum for exchange of practice among MS with devolved competences (1)

• Dedicated meeting on 12/13 June (6 MS + Switzerland)

• Participants provided overview of co-ordination frameworks

• Mechanisms for adopting documented procedures, and for audit, in particular within devolved regions, also discussed

• Discussions also both on how verification takes place within devolved regions, and on mechanisms for providing assurances from devolved regions to MS

• This theme will be developed further, through the systems audits and the overview report on verification of effectiveness

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Forum for exchange of practice among MS with devolved competences (2)

Next steps

• Differing views last June on whether meetings of this forum should continue

• Propose that future discussions be integrated into the MANCP network, following completion of the overview report on verification of effectiveness

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Questions?

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