The third in a series of four reports on synergies of official controls with food business operators’ internal protocols has been published.

It covers a fact finding mission to Belgium in Sept. 2017. Reports on Germany and the United Kingdom have already been released by the Directorate-General for Health and Food Safety (DG SANTE). The agency’s plan is for the fourth report to cover the Netherlands.

The objective was to gather information on the way and extent to which the Belgian authority takes account of results of own-checks systems, individual firm food safety standards (IFSS) and private sector food safety standards schemes, also known as third-party certification schemes, in organizing official controls in food of animal and non-animal origin.

The Federal Agency for the Safety of the Food Chain (AFSCA) in Belgium considers national guides developed by industry and stakeholders as the benchmark standards, which when implemented by food business operators will provide the highest level of guarantees for food safety.

Belgium’s agency bases the risk assessment for planning of official controls and implementation, on level of compliance of the food safety management systems with the national guides. This means the level of synergies of official controls with those done by the private sector is limited to some sampling or activities for which no approved national guides exist. Comparisons of the national guides with certain private food safety standards have concluded requirements do not match.

It is looking at ways to better integrate certain private food safety standards schemes into the national risk-based control system. Officials say integration would allow for results to be taken into account for lowering inspection frequency or reducing depth or scope of official inspections.

AFSCA says it wants to avoid giving the impression to food business operators that it requires participation in a private scheme or giving a commercial advantage to certain schemes by “recognizing” them. The agency added there is no assurance that they will evolve in the same way as legal requirements and confidentiality issues might hinder access to audit results of food business operators who are private scheme certified.

The mission team visited one primary producer for food of non-animal origin (FNAO), a supermarket chain and two food sites — one for food of animal origin and the other for FNAO, two private certification bodies and one standard owner.

Private schemes
The idea behind private sector food safety standards schemes, which are voluntary, is if food business operators follow the requirements in these standards, they should provide assurance that they produce foods with relatively high and stable levels of quality and safety.

Participating primary producers and other food business operators certified under a third-party assurance scheme are subject to audits and inspections by certification bodies appointed by the entities that own the private standards schemes or the firm setting the individual firm food safety standards.

There are 11 private sector schemes setting private food safety standards along the food chain, five in the primary production sector and six in the transformation sector. Some of these are recognised by the industry-led Global Food Safety Initiative (GFSI).

At the time of the mission, AFSCA recognized one Belgian private sector scheme covering the primary production sector of food of non-animal origin as equivalent to the relevant approved national sector guide. Certification entitles the food business operators to a certificate stating they have a validated own-checks system (SCS – système d’autocontrôle) in place.

Delegating the task to certification bodies for auditing and validating food business operators’ SCSs is the major area of interaction between official controls and those carried out by the private sector.

AFSCA considers the remaining private sector schemes cannot be recognized as fully equivalent to the approved national sector guides. Equivalency must be demonstrated by owners of the private sector schemes.

Retailer input
Individual firm food safety standards put in place by the supermarket chain visited concerned mainly products marketed under the chain’s in-house brand. Private certification bodies are appointed by the retailer to audit and sample suppliers of such products to ensure the retailer’s product specifications are respected.

The retailer performed a few thousand analyses annually on products marketed under its own label. In 2016, they did 2,600 microbiological analyses, 233 chemical tests and 182 DNA tests for species characterization.

It also imposes requirements for suppliers to be authorized to supply their products. Large food business operators must be certified under schemes such as BRC, IFS or FSSC 22000. Medium-sized suppliers certified under Comeos Food for small and medium-sized enterprises, and small artisanal producers need only be registered or approved by AFSCA.

The retailer insisted the validated SCS is insufficient for the suppliers because it is a national system unlike other standards which are internationally recognized. However, combination of SCS and ISO 22000 worked “very well.”

At the time of the mission, there were 34 guides approved by AFSCA for agro-supply, agriculture, processing, retail and transport. There were 14 certifying bodies approved for validation of food business operators’ SCSs.

Reduction in controls and cost
AFSCA gives incentives to food business operators in reduced frequency of official controls and the levy charged, to encourage them to develop and implement validated food safety management systems based on the national guides.

According to data from the end of 2016, there were 22,753 food business operators with a fully validated SCS, entitling them to a reduction of 75 percent of the annual levy payable to AFSCA and reduction of up to 50 percent in the frequency of inspections, depending on their activities.

The levy depends on the sector activity and the size of the operation. The amount saved by food business operators, if they have a fully validated SCS, ranges from a few Euros to more than €10,000 ($11,400).

A cooperation between AFSCA and Belgapom in relation to sectoral sampling for potatoes provides the agency with additional laboratory results for this sector, allowing better risk analysis for planning and better focusing of resources and official sampling efforts.

The UK mission found synergies between third-party certification schemes and official controls have been in place for many years. The Food Standards Agency recognizes membership and certification for certain schemes to reduce the frequency of official controls. The agency is also working on the “Regulating Our Future” program to redesign the way official controls are delivered.

Germany has a high rate of membership to private sector food safety standard schemes, but there are no synergies between these and official controls. Inspectors had reservations on whether controls by the private sector are unbiased and can contribute to synergies with official controls.

“In particular, the fact that there is a financial relationship between FBOs (food business operators) and certification bodies and that audits for schemes are mainly announced, with advance notice can negatively affect the reliability of information and void the effect of other measures which have been put in place aimed at ensuring reliability,” according to the report.