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Article: GFSI steps up the focus on fraud in latest ‘Race to the Top’ benchmarking requirements
01 May 2020
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.
RT @SPGlobal: June marks the start of Pride Month, where we commemorate and celebrate the LGBTQ+ community in countries across the globe. S…
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