Article: GFSI steps up the focus on fraud in latest ‘Race to the Top’ benchmarking requirements

This article is taken from the IEG Policy platform dated 30/04/20.

The Global Food Safety Initiative (GFSI) steps up measures to counteract food fraud in the latest version of its benchmarking requirements, as part of the organisation's 'Race to the Top', IHS Markit learned in an exclusive interview with GFSI's new Director, Erica Sheward, on the side-lines of this year's annual conference in Seattle.

Sheward spoke to Sara Lewis about the new benchmarking requirements Version 2020 unveiled in Seattle and differences with the existing version. Sheward also looked at the important role that GFSI can play in helping both company compliance and regulatory enforcement of the EU's official controls regulation and the US Food Safety Modernisation Act (FSMA) as well as in other countries across the globe.

Below is the interview between Sarah Lewis (SL), IHS Markit Policy Analyst and Erica Sheward (ES), Director of GFSI.

Question 1

SL: You took over as director of GFSI in October 2019, so you're still relatively new in the job. What are your plans for the organisation?

ES: Well, big plans. Big plans to modernise, to innovate, to move forward. We're coining the innovation that we've got planned as the Race to the Top. We recognise that, although we've achieved a lot over the last 20 years, we need to continue to move forward and continue to face some of the food safety challenges that we've got in our world head-on.

Question 2

SL: What type of things would you like to change?

ES: Well, fundamentally, we've got to work with the grain of the organisation. We are a harmonisation and benchmarking organisation. We set the bar. We're in a very privileged position, because we don't need to worry about any commercial interests. We're just setting the bar as high as we can set it to achieve, obviously, safe food. And on that basis, we need to continue to raise the bar as we see issues emerging that are not currently covered by existing benchmarking arrangements, and then work with our stakeholder community to ensure that they're able to deliver for us on the ground in terms of the certification and delivery of the audits.

Question 3

SL: And GFSI has just unveiled Version 2020 of its Benchmarking Requirements. It represents a major overhaul, which you called a revolution earlier. Why was such a major revision necessary?

ES: Well, I think because the world is changing so quickly, isn't it? I mean -- And it's about emerging issues, things that we need to not just respond to and react to that are in our line of sight now, but also thinking about things that are coming down the track. So we're thinking very much about what inputs we need to help us assess what food safety risks, hazards, emerging risks are going to be coming that we need to be thinking about, and how they would manifest them in themselves in a benchmarking requirement that might be higher than the existing one. I mean, the process is incredibly thorough and very robust. It takes multiple stakeholders to come together to create those requirements, and then obviously has a knock-on effect to the CPOs and the CBs that are operating under our brand.

Question 4

SL: CPOs and CBs?

ES: The CPOs are the certification programme owners, and the CBs are the certification bodies that deliver the audits, recruit and hire the auditors.

Question 5

SL: Who are the certification programme owners?

ES: They are the organisations that have schemes, standards if you like, that they create, that they will ask to be benchmarked against our requirements.

Question 6

SL: Can you explain what are the differences between earlier versions of the Benchmarking Requirements and the Version 2020?

ES: So, the direct comparison between the last version and Version 2020, so 7.2 and now Version 2020, are things like food safety culture as a requirement, and certainly food fraud. There's a big uplift in thinking in terms of food fraud. So those two things are the standout features, I would say.

Question 7

SL: Right, so people need to look at what they're doing with fraud?

ES: Indeed, and assess their food safety culture robustly, yeah.

Question 8

SL: And who will notice the biggest change, the companies being certified, or the certification bodies?

ES: Everybody. I mean, everyone will. I think the difference, fundamentally, is that the sites at the receiving end of the audit and the certification will be less connected, because their interaction with our uplift in benchmarking requirements will come through their audits, their annual audits, with the certification bodies that they choose to work with. When we create the Benchmarking Requirements, the technical group that comes together to do that are a mix of certification programme owners, our own business members and other technical experts that we bring in. They kind of shape the changes; so, they're much more up to speed, if you like, with what's coming, because they're actually creating the changes themselves.

Question 9

SL: Alright. So, will it be a transition period

ES: Oh, absolutely. There's always a transition period. The idea that we would move today at the press of a button from one set of requirements to another, of course, doesn't work that way. So there's a transition period into 2021. The audits that will flow out of the new version will not manifest themselves until 2021 because the CPOs will have to bring us their standards and make sure that they're aligned and that they're meeting our recognition requirements. So that is a process in and of itself.

Question 10

SL: And what further changes do you think could come in a future update? When will that be?

ES: So that is a really good question, and a lot of people are curious to know that. The idea that we would just continually, perennially, move to upgrade the Benchmarking Requirements is not a given. We would not move to raise the bar unless we had an evidence base to tell us that we needed to. So that would be some scientific evidence to say that there's something fundamental to food safety that we would need to include that wasn't currently there. It's a kind of gap analysis, continued gap analysis, looking at things that may or may not be there, and waiting for people to tell us things that they think we've missed. If nothing comes, we won't just make - do another version for another version's sake. That would be ridiculous. So we're thinking about things based on our inputs, our scientific inputs, that we think may feature relatively soon, particularly around climate change and food safety risks linked to climate change. Thinking about what that's going to mean, and what additional level of oversight we would need to consider that people had to adjust to that.

Question 11

SL: What are the requirements that will be brought in around fraud? You talked quite a bit about the culture changes and what that meant this morning, but what about fraud? What do you want to do?

ES: Well, so, you're not asking the technical expert. My technical experts are not me. But essentially, this is about asking businesses to consider fraud at every aspect of their supply chain: ingredients that may be coming into their products if they're a multiple-ingredient product, or indeed a fraudulent single ingredient. It doesn't matter, you know, what the input is. We would be asking them to consider, where their weak spots were, and thinking about how would it be, could it be possible, you know, that they would be using products or inputs into their products that were not what they appeared to be.

Question 12

SL: Are you satisfied with the take-up of GFSI certification? Are there countries or regions where companies are reluctant to sign up, and what more could you do to get more on board?

ES: So again, that's an excellent question. This isn't a numbers game. A lot of people think it is a numbers game. We would rather have less audits, less certificates, but that everyone could trust, that they were confident that the certificates were on the back of a great audit. But obviously, our ambition is that we increase the pool of certified sites, because that's obviously what we're here to do. I think, in terms of businesses' awareness of GFSI-certified programmes and certification and what it can bring for them, there is still a job to do, and that's talking up the benefits. But we do rely very heavily on, you know, on our stakeholders, who engage much more closely, directly, with businesses than we do, routinely, to, you know, to sell those benefits to businesses. Obviously, our board member companies all require GFSI certification as part of their requirements, so if you're servicing any of our board member companies, the demand is already there for a certificate. And that top-down approach has been very helpful, given a number of our board member companies are obviously the world's largest, you know, food and drink brands. So that helps.

Question 13

SL: The EU's new official controls regulation took effect on December 14th, and it introduces a risk-based approach to inspections, where the food, the lesser the risk, the fewer inspections are required. Do you think GFSI has a role to play in helping with compliance and lowering companies' risk profile?

ES: Oh, absolutely. I mean, absolutely. And one of our strategic priorities is around public-private partnerships, and the specific outcome that we are seeking to achieve through that strand of work is around getting to a place where regulators, national regulators, local regulators, will take a GFSI certificate as an indicator of compliance, and that they will use it as a tool to take risk -- decisions that are risk-based in terms of where they allocate their resources, what they regulate, how they regulate, and not just in terms of policy, but certainly in the delivery of regulations and the enforcement.

Question 14

SL: And are you getting a message from regulators that they share this goal?

ES: Well, I mean, at the end of the day, many of them are either, and both, challenged by their resource, you know, constraints. They know that they're going to, that they have to regulate in a risk-based way, and they need to be seeking ways that they can make different intervention choices and not continue to, you know, to do the same things everywhere. In some cases, we already have regulators that accept GFSI certification, and deliver earned recognition through that, so they'll inspect less or inspect differently as a consequence of that, and in other places there is still a journey to be gone on. And I think the challenge for regulators is that if their rule sets are not principles-based, if they're very prescriptive, if they find it difficult to understand where our high-level requirements and their prescriptive rule sets actually come together. And I think we worked very effectively yesterday to take our regulators on a journey in - of understanding, you know, how our world and their world can come together to be complementary. Because my background is regulation, I've always moved very strongly to say that GFSI certification is not a replacement for regulation. That's not what we would ever advocate. Regulators have a very, very, very robust role to play. But we would ask them to consider the value of certification in their risk-based decision making.

Question 15

SL: And which countries have already kind of taken it on board and accepted it?

ES: Canada, to a greater or lesser extent, and certainly Australia and New Zealand have been very much on the front of it. We have a number of developing countries who have recognised the value on the basis of the fact that their own regulatory systems are somewhat underdeveloped, so they recognise the value of having certification as an indicator of not just compliance, but of food safety. That helps them. And I think, you know, we are still challenged in a number of big markets where we would want to continue to work, you know, to move that conversation forward. So yeah, it's an interesting feature of our work, particularly for me, because obviously, that is my background. That's, you know, that's what I've been doing for the past seven or eight years, is, you know, is leading global initiatives around getting regulators to understand the principles of better regulation, and not being wedded to old ways of doing things. You know, inspect, inspect, inspect; that's not the only tool in your box, you know. There are other tools you can use. SL: And what about in the US, and with Food Safety Modernization Act? Has GFSI got a role there? ES: Yeah. I mean, absolutely. Just as it has everywhere where we want to achieve a public-private partnership outcome, which is that regulators will take this certification, and they will use it as an indicator of something. And, you know, we're obviously engaged with regulators all over the world, of which, you know, the American regulators are just one of a number.

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