The risk based approach and the checklists for inspection along the dairy value chain

Transcription

1 The risk based approach and the checklists for inspection along the dairy value chain Marco De Nardi, International Lead Expert (Component 1 and 2) (MSP) 1

2 Presentation outline Risk and risk categorization Farm inspection and the «assistance» role of inspectors Tools for inspection 2

3 Presentation outline Risk and risk categorization Farm inspection and the «assistance» role of inspectors Tools for inspection 3

4 Article 3. General obligations with regard to the organization of official controls Member States shall ensure that official controls are carried out regularly, on a risk basis and with appropriate frequency, so as to achieve the objectives of this Regulation taking account of: (a) identified risks associated with animals, feed/food, feed/food businesses. (b) operators' past record as regards compliance with feed or food law or with animal health and animal welfare rules; (c) the reliability of any own checks that have already been carried out; and (d) any information that might indicate non-compliance. 4

5 Risk Risk (Codex Alimentarious Commission CAC): A function of the probability of an adverse (health) effect, consequential to a hazard(s) in food, and the severity (impact) of that effect. RISK = PROBABILITY + IMPACT

6 Risk categorization What? > Classification of food businesses according to risk category (i.e. high, medium, low) Why? > to allow the regulatory agency responsible to food inspection to prioritize inspections of food businesses which pose the greatest potential risk to the population if the safety of food is out of control. 6

7 Food Inspection in Canton «...» (Switzerland) Cantonal Laboratory Results Samples 1000 different Parameters 50 categories of samples 500 Inspections

8 Food Inspection in Canton (Switzerland) Kanton Zürich Kantonales Labor Zürich 8 Risk based inspection based on: Hazard (probability of health effect...) oself control concept / HACCP (1-4) ofood and Labelling (1-4) oprocesses / Operation (1-4) ofacilities / Installation (1-4) omanagement / Reliability (1 4) Extent (Impact) otype of customers (0-1) oimportance of factory (1-3)

9 Standard frequency of inspections (Canton «...») Kanton Zürich Kantonales Labor Zürich 9 Examples in years: Milk products factory 2 (1 inspection in 2 years) Corned beef producer 1 Meat products 2 Egg packing station 4 Fish products 2 Local butcher 2 Cheese producer 2 Transport / Selling only 4 Restaurant 2 small Store 4

10 Risk calculation (Canton «...») Kanton Zürich Kantonales Labor Zürich 10 Hazard and Extent Overall risk level Frequency of inspections 1 = neglectable standard frequency (2 yrs) 2 = small 0.75 frequency (1.5 yrs) 3 = medium 0.5 frequency (1 yrs) 4 = high 0.25 frequency (0.5 yrs)

11 Presentation outline Risk and risk categorization Farm inspection and the «assistance» role of inspectors Tools for inspection 11

12 Key features of risk-based food inspection Focuses on risk factors along the food chain or processes that pose highest risk Minimises costs to food operators by reducing unnecessary inspection and testing costs Promotes preventive rather than reactive approach to food control 12

13 Traditional vs risk based approach It requires a change of philosophy regarding the inspector s traditional regulatory role, which is generally limited to verifying that regulations are complied with,.to a vision of the inspector as a food safety professional actively contributing to improving the system through changes that aims at enhancing the safety of food products. FAO,

14 How interpersonal skills and technical expertise can help the practical implementation of the risk based approach? Key message: «Educate before we regulate» 14

15 Compliance assistance Compliance assistance= encouraging inspectors to assist industry in finding solutions to violations There is growing evidence that interpersonal skills such as communication, patience, empathy, respect, and consideration are integral to conducting regulatory inspections. 15

16 Results The following interpersonal skills emerged as critical in an assistive approach that improved compliance COMMUNICATION: All inspectors emphasized the communication skills that their roles required and the importance of information sharing to achieve compliance. Inspectors explained to clients the rationale behind regulations and provided guidance on how to meet them. 16

17 Results PATIENCE and EMPATHY Inspectors described the importance of establishing a supportive, empathetic dynamic with clients During field observations, nearly all inspectors complimented clients on improvements made since earlier inspections with respect to compliance, as well as business growth. RESPECT and CONSIDERATION Establishment of a give and take dynamic in which clients felt that they were treated fairly They wanted to avoid overloading clients. Instead, they gave clients the opportunity to correct minor violations during the inspection 17

18 Farm inspection (Switzerland) Two phases: 1) Self monitoring 2) Inspection on site (Duration: 45 minutes) Inspection is announced to the farmer approx. 2 days in advance On site inspection conducted with farmer/farm manager Preparation of inspection report on site 18

19 Presentation outline Risk and risk categorization Farm inspection and the «assistance» role of inspectors Tools for inspection 19

20 Tools for inspection Guideline for conducting inspection Checklist for inspection - classic paper checklist - electronic application (for tablet and smart phone) Electronic data management system (Dairy module) - inspection data management > risk categorization - notification to inspectors of anomalies 20

21 MSP - Inspection Checklists Existing guidelines and checklists currently in use for conducting inspection on-farm, at milk collection points and at milk processing level were collected and evaluated: 1) Unified act of checks (Order of Ministry of Agrarian Policy of Ukraine of , No 538). No specific checklists available > inspectors use universal form 2) Internal order 154, (2 checklists for the inspection of dairy producers and processors intending to export their products to EU): List of questions for conducting inspection on cattle s farm for compliance with European legislation List of questions for conducting inspection dairy enterprises for compliance with European legislation 21

22 MSP - Inspection Checklists 3) Order of the State Department of Veterinary Medicine 14, : Schemes of state veterinary-sanitary control and supervision on dairy processors (not checklists) 4) EU Food Safety project Check-list for conducting inspection on food enterprises for compliance with hygiene requirements List of questions for audit on compliance by markets operators legislation requirements regarding permanent procedures based on the principles of Hazard Analysis and Critical Control Points. 22

23 MSP - Inspection Checklists Revision of checklists finalized. Key topics: o Documentation available at farm level o Animal health and welfare o Territory, buildings, farm o Water supply, sewer system o Lighting o General veterinary and sanitary requirements, hygiene o Ventilation, air conditioning and heating o Personal hygiene of staff o Production, production control system Checklists are currently tested at field level by inspectors 23

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25 MSP - Guidance for inspectors «On the application of thе checklists that are necessary for the preparation of planned state supervision (control) of business entities engaged in the production, collection, transportation and processing of milk on the compliance with veterinary legislation» 25

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27 First feedback from Inspectors on revised checklists Tools (checklists and guidelines) tested at field level Tests are continuing within project training framework So far, positive feedback about new approach and tools Most of the questions are clear, some questions need adjustment Section «What to pay attention to (control points) highly appreciated by inspectors 27

28 Thank you! Thank you for your attention 04/03/2016 2