The integrity of food / feed safety assurance certification Johan den Hartog, managing director of GMP+ International, Rijswijk, The Netherlands
T
he integrity or credibility of a certificate about food or feed safety assurance is increasingly important.The overall aim of cer tification is to offer confidence to all stakeholders in the market that a cer tified company fulfils the requirements of a normative standard of a certification scheme. Third party certification means that a company’s management system its implementation and daily operations are assessed by an impartial and competent party (certification body, auditor) in a consistent way.
Aim of integrity policy
A scheme manager applies an Integrity policy and related program with the aim of ensuring the confidence that the certified companies comply with the principles and requirements of the applicable normative standards in a proper and unimpaired manner. Otherwise a certificate will lose its credibility. From time to time, certified companies in the feed and food chain are involved in feed/food safety emergencies. In some cases, it raises doubts about the credibility and value of a certificate. In my view, an Integrity policy is one of the most challenging responsibilities of a scheme manager. In most cases, several certification bodies and auditors are involved in the assessment and cer tification of companies, participating in a food/feed safety assurance scheme. Besides impartiality and competence, also consistency of assessing practical situations by certifications bodies and auditors is a concern. Therefore, a scheme manager needs to evaluate the effectiveness of an Integrity policy from time to time and improve it regularly. Above, it has to find the
right balance regarding nature and extent of efforts (cost) to obtain optimal results. GMP+ International has 30 accepted cer tification bodies with about 350 qualified auditors in charge with the cer tification against standards of the GMP+ Feed Cer tification scheme. At this moment, it is fully in the process of evaluating and redrafting its Integrity policy. Integrity policy is not a standalone item, but par t and the breechblock of a coherent set of roles and responsibilities of the involved parties. Therefore, I want to emphasise the responsibility of each involved par ty for the credibility of a certificate, before I dive into the Integrity policy as such.
Responsibility of the certified company
Fir st of all, the cer tified company needs to comply with the requirements appropriately. The management’s responsibility is to propagate adherence to compliance and to evaluate the implementation and compliance regularly. Accurate compliance is also crucial otherwise it will fuel a tendency of indolence. An internal audit is a useful tool to assess compliance regularly. Feed safety culture is the responsibility of the management. Is food/feed safety a priority or a company value? If it is a priority, it can be high or low, depending on the (financial) situation. A value is always at the same level of urgency, because it is a driving force for daily operations. That makes the difference.
Responsibility of the certification body
The cer tification body’s (CB) main responsibility is ensuring competent and impar tial
auditors applying the normative standards in a consistent way, and dealing with nonconformity in accordance with the rules of certification set by the scheme manager. It is recognised that the source of revenue for a certification body is its clients paying for certification, and that this is a potential threat of impartiality. To obtain and maintain confidence, it is essential that a certification body’s decisions are based on objective evidence of (non) conformity and that its decisions are not influenced by other interests or other parties (ISO 17021, par. 4.2). Inaccurate assessment by an auditor results in inaccurate operations of an assessed feed company regarding feed/food safety control. The consequence is that it can lead to fur ther stretching of deviant behaviour and non-compliancy.
Responsibility of the scheme manager
Finally, in my view, the scheme manager too has its responsibility. It is about setting normative standards or certification criteria, about setting rules of certification and about the Integrity policy.
Setting normative standards
The requirements for participating companies as well as involved cer tification bodies in the certification scheme should be achievable and relevant. Validation, prior to implementation, is an important tool. Wellbalanced multi-stakeholder s par ticipation is key for setting achievable and relevant requirements.
Setting rules of certification
Defining a coherent set of rules for certification is another
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impor tant role . For GMP+ International, it is about accreditation against EN 45011. Currently, we are transferring to ISO 17201. Fur thermore, skills and competence requirements of auditors and technical reviewers as well as regular examination of auditors should be ensured. A training program is being developed together with Wageningen Academy.
Integrity policy
GMP+ International’s Integrity policy consists of three cornerstones: complaints management, management of the early warning notifications and compliance assessment. Cur rently, the compliance assessments are carried out by means of witness audits, par allel audits and annual c e r t i fi c a t i o n o f fi c e a u d i t s . The complaints as well ear ly war ning notifications supply input for a risk-based approach of the compliance audit program. GMP+ International is continuously evaluating and reviewing its Integrity policy to improve the effectiveness. A pilot is under way with different types of retrospective assessments. These can either be focused on a single auditor, multiple auditors or the cer tification body as a whole. The first results are very promising and GMP+ International is considering adopting these assessments in a structural way, due to its relevant insights. Fraud prevention is becoming more and more impor tant. My experience is that fraud sooner or later comes to light, because errors are made and thereby it will be discovered. Unfor tunately, it can also result in adverse effects on customers. Recently, GMP+ International did not hesitate to take severe measures in a situation where gross negligence by a company was discovered. We are also investigating in the development of instruments for identifying abnormal behaviour patterns that could indicate fraud. Finally, we have to realize that cer tification and Integrity policy cannot prevent fraud.