Integrity of Feed Safety Assurance certification by Johan den Hartog – Managing Director of GMP+ International The integrity or credibility of a food and feed safety assurance certificate is increasingly important. Major interests are at stake including both commercial and human health. The overall aim of certification is to offer confidence to all stakeholders in the market that a certified company fulfills the requirements of a normative standard of a certification scheme. Third party certification ensures that an impartial party, such as a certification body or an auditor, assesses a company’s management system, its implementation, and daily operations in a consistent way. At the end of 2014, GMP+ International renewed its integrity policy for the GMP+ Feed Certification scheme thoroughly, including its enforcement. Lessons taken from recent feed safety emergencies led to this change. Although it has taken some time and effort to implement it fully, the first experiences can now be shared. A scheme manager applies an Integrity Policy with the aim to ensure the confidence that the certified company complies with the principles and requirements of the applicable normative standards of a certification scheme in a proper and unimpaired manner. Otherwise a certificate will lose its credibility. Maintaining the credibility of a certification scheme is in the interest of the scheme manager as well as all participants and related stakeholders. After all, integrity is doing the right thing, even when no one is watching. However, when put into practice this is not always the case and furthermore ‘situational interpretation’ of requirements can sometimes result in risks for downstream actors in the market. 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 certification of companies, participating in a certification scheme. Besides impartiality and competence, the consistency of assessing practical situations by certification bodies and auditors is vital when striving to achieve this. GMP+ International has 30 accepted certification bodies with about 370 qualified auditors in charge, with the certification against standards of the GMP+ Feed Certification scheme. In December 2015, over 14,700 30 | January 2016 - Milling and Grain
companies / locations were certified in over 75 countries. This high level of participation has created an obligation to maintain a high level of credibility. However, an integrity policy should not be viewed as a stand-alone item, but should form the foundation of a coherent set of roles and responsibilities for those concerned. Therefore, the responsibility of each involved party for the credibility of a certificate is stipulated, before diving into the integrity policy as such. First of all, a certified company needs to comply with the requirements appropriately, as it is in the company’s own interest to control risks. It is then the Management’s responsibility to ensure adherence to those requirements and to evaluate the implementation and compliance regularly. Accurate compliance is also crucial; otherwise it will fuel a tendency of avoidance. An internal audit is a useful tool to assess compliance on a regular basis. Feed safety culture is the responsibility of the management. The question of whether feed safety is a priority or a company value. If it is a priority, it can be high or low, depending on the financial situation. A company value is always at the same level of urgency, because it is a driving force for daily operations. That makes the difference. The certification body’s main responsibility is to ensure that their auditors are applying normative standards in a competent, impartial and consistent way; whilst dealing with nonconformity in accordance with the rules of certification set by the scheme manager. It is recognized that the source of revenue for a certification body is its clients paying for certification, and that this is a potential threat for 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). Inaccurate assessment by an auditor results in inaccurate operations of an assessed feed company regarding feed/ food safety control, which can often lead to an increase in deviant behaviour as well as non-compliancy. Therefore, the certification board’s management has a responsibility to monitor and assure that their employees and auditors are operating with the appropriate level of integrity. Finally, a scheme manager is also responsible for the integrity of the certificate. It is about setting normative standards or certification criteria, about setting clear rules of certification and about an effective and reliable integrity policy.