Federal Agency for the Safety of the Food Chain Attaining the objective of 5-year coverage of activities under 882/2004 Regulation : The Belgian approach

Federal Agency for the Safety of the Food Chain

Attaining the objective of 5-year coverage of activities under 882/2004 Regulation : The Belgian approach

Tom Vanoverschelde

Grange, March 2011


Belgium

Federal Agency for the Safety of the Food Chain2

Contents

• About the FASFC

• Organization of the internal audit

• Setting up of the audit universe

• Ensuring a coverage of all activities under Regulation 882/2004 over a 5 year period


The Belgian Food Safety Agency


Our goal : optimising Food chain checks

Suppliers of agriculture

(feed industry, raw materials, pesticides)

Agriculture

Food and feed industry

Wholesale business

Import / export / IC trade

Retail

Hotels, Restaurants, Pubs

Transport


Core business of the Food Agency


Some figures

• Central services in Brussels, 11 Provincial Control

Units (PCU), 5 internal laboratories, network of

external laboratories

• Approx. 1300 employees

• 800 independent veterinarians (600 FTE)

• Annual budget : € 180 million


The internal audit of the FASFC*

• Operational since July 2007

• Staff function placed under the direct control of the CEO

• One service : quality, environment, ombudsman, and prevention.

• 3 full time auditors (2 3 in September 2010)

• ISO 9001 certified since October 2008, successful ISO 17020 accreditation audit in December 2010

* The organization of the internal audit has been presented at the meeting in Grange on 8/12/08


Audits

• Mix of compliance, effectiveness and efficiency

• All parts of the organization : administrative processes, inspection services, laboratories, quality management

• Competence through :– Training of lead auditors

– Use of a pool of technical experts who have a broad knowledge and experience regarding the audit scope

– Since 2011 : technical experts = field inspectors

– Example of audit scope : “organization and conducting of inspections on the production of foodstuff from non-animal origin”


Audit universe• Decision 2006/677 EC :

“Form part of an audit program that ensures adequate coverage of all relevant areas of activity and all relevant

competent authorities within the sectors covered by Regulation (EC) No 882/2004 at an appropriate risk-based

frequency over a period not exceeding five years”

• To achieve this, and be able to provide proof of it, a listing of all activities under the scope of 882/2004 is required.


Audit universe (2)

• Different approaches were considered:

1. Sectors and subsectors in the food chain

2. Business processes

3. Organizational entities


Option 1 : sectors in the food chain

• Advantages : – Aligned with MANCP / national control plan

– Aligned with the structure of the inspection services

– Establishing a link with legislation is easier

– More technical experts available, with less audit preparation required

• Disadvantages: – Supporting services are not linked to a particular sector in the

food chain

– Some key processes are transversal, and auditing them in parts and pieces will cause a lose of oversight for auditors

– “grey areas” in the food chain which do not belong to one specific sector


Option 2 : Business processes• Advantages :

– The relationships and links between organizational entities and activities are documented and audited.

– Difficulties and problems between interrelated activities will be found (e.g. Central and decentralized services)

• Disadvantages: – Not all business processes are documented or identified

– Every inspection, regardless of the sector, follows the same process. One process covers a wide range of different subjects.

– Auditing becomes more difficult because more people and levels in the organization are involved. Auditors need a thorough insight in the overall organizational processes and their relationship.

– Not all activities are easily transformed in a process.


Option 3 : Organizational entities

• Advantages : – The universe is easy to document (= organizational chart)

– All entities will be audited all activities will be covered

– Individual audit planning is easier, the number of people involved is limited.

– Follows the mindset of a bureaucratic organization

• Disadvantages : – Relation between risk and audit coverage is out of balance : all

control units should then be audited, even if they perform the same activities.

– Entities mostly fulfill activities that are part of a process. The end result of the process is not being audited.

– Problems between entities will not be easily found and analyzed.


The audit universe of the FASFC

• Every option has too many disadvantages to be easily usable

Why not combine them into one model?

Sectors Technical operations

Processes Transversal operations

Entities Operations of support


The audit universe

• All activities listed in 3 categories : technical, transversal and support activities

• Find the balance between too much and not enough detail

• A tool which:– provides a view on all activities to audit ;

– displays the activities covered and those not covered

– helps to make up the audit program for the next year(s)


Building the universe

• Technical operations :– Primary sector animals, primary sector plant, animal welfare,

feed, transformation of food of animal or non-animal origin, distribution sector, import – export – internal EU trade.

• Transversal operations : – Risk analysis, control program, sampling process,

collaboration with other organizations, crisis management, registration of operators…

• Operations of support : – HR, IT, logistics, financial processes, procurement…

Not all activities are directly related to 882/2004.

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The audit universe

See hyperlink:

Audit universe for presentation FVO March 9 2011.xlsx

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From audit universe to audit scope• Audit scope : from objective to follow-up

• Example : Inspections in butcheries. – Existence and knowledge of control program and other

objectives

– Overall organization of the control unit (incl. quality management)

– Planning the inspections : assignment of inspectors, choice of butchery, preparation.

– Carry-out of the inspection : sample of inspections followed by the auditors : communication/behavior towards operator, organization of the inspection, respect and use of procedures/ checklists/forms, interpretation of findings, determine result and follow-up needed.

– General follow-up on findings and measures taken.

– Supervision, quality control and monitoring of inspections : on individual and team level.

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Interpretation of « coverage »

• Previous meetings of the Network of Audit Representatives gave us these guidelines :

– A full coverage of a certain domain is not realistic, audit is always based on sampling an audit can cover a defined scope even when it’s conducted in one province.

– Single audit : if some areas have been audited by other qualified bodies, the same work does not have to be repeated.


Coverage in practice (1)

• Some scopes or processes form part of an audit assignment, but are not the main focus of the audit. Some examples: – Collaboration with independent veterinarians is part of

the scope of every audit in sectors like slaughterhouses, meat industry and import / export.

– An audit about hygiene in slaughterhouses also looks at measures taken to ensure animal welfare.

– Handling of customer complaints is looked upon in almost all audits in inspection services, but the complaints process as a whole is not reviewed.


Coverage in practice (2)

• Coverage – Main scope : an audit has been carried out with the

activity as main scope

– Part of scope : elements of the process or activity have been reviewed, but not all

• Decision– If 1 time referred to as main scope covered.

– (multiple) Part of scope judgment by internal audit

– No audits plan an audit in next audit program


Follow-up of audit recommandations

• Responsible = line management

• On a continuous basis:– Part of quality management system

– Quality managers at different levels in the organization

• Follow-up audits – All recommendations are reviewed in a future follow-

up audit

– 1 to 2 years later, depending on risk and priorities


Realization of action plans


Some possible issues…

• When does the 5 year period start ?

• After 5 years : full restart or scroll further one year ?

• Documented audit universe + full coverage in a 5 year period still a need for a (quantified) risk analysis ?

• Will full coverage lead to less FVO-missions to Belgium ?


Contacts

FASFC (Federal Agency for the Safety of the Food Chain) CA Botanique – Food Safety Center – 8th floorBoulevard du Jardin Botanique 55B - 1000 BRUSSELSwww.afsca.be

Guy MommensDirectorInternal audit, Quality & PreventionTel +32 (0)2 211 82 33 [email protected]


Hagar the Horrible Dik Browne

Audit : A profession that serves the whole organization

Wouldn’t it be better to try

the backdoor first ?

Documents

Federal Agency for the Safety of the Food Chain Attaining the objective of 5-year coverage of activities under 882/2004 Regulation : The Belgian approach