earned recognition: primary authority and third party assurance schemes sharon egan, enforcement...
TRANSCRIPT
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 Strategy Themes: Overview
• Improved overview and understanding of risks associated with Food Businesses
• Improved risk based regulation
• Improved overview and understanding of risks associated with Food Businesses
• Improved risk based regulation
Assessing risk
• Use risk based approaches to monitor compliance to deliver efficiencies and free up resources to tackle key risks
• Use risk based approaches to monitor compliance to deliver efficiencies and free up resources to tackle key risks
Earned Recognition
• 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.
• 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.
Changing FBO behaviour
• Increase FBO perceptions of the likelihood & consequences of detection
• Tougher on persistent/high risk non-compliance
• Increase FBO perceptions of the likelihood & consequences of detection
• Tougher on persistent/high risk non-compliance
Tackling non-compliance
5
Earned Recognition 1
6
• 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
Earned Recognition 2
7
• 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.
Earned Recognition: Primary (/ Home) Authority
8
• 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.
Earned Recognition: Primary Authority
9
• 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
Earned Recognition: Primary Authority
10
• 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
Earned Recognition: Third Party Assurance Schemes
11
• 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.
Earned Recognition Common Safeguards and Checks
12
• 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
Earned Recognition Consumer views
13
• ‘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)
Delivery: Code of Practice Review
14
• 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.
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.
15
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?
16
17
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
18
