Examination of Witnesses (Questions 226-239)
MS LINDA
CAMPBELL AND
MR PAUL
WRIGHT
22 JUNE 2004
Q226 Chairman: Good afternoon, Ms Campbell
and Mr Wright, welcome to the Committee this afternoon. I hope
we have not disturbed you by bringing you along a little earlier
in the programme than was originally indicated. We are very grateful
indeed that you were here a bit ahead of time so that we can use
the time usefully. We would like to thank you for the evidence
you sent in in writing and look forward to what you have got to
tell us today in your oral evidence. Linda Campbell, I understand
that you are the Chairman of the Product Authentication Inspectorate
and, Mr Wright, you are the Managing Director; is that correct?
Mr Wright: Yes.
Q227 Chairman: I wonder if I could begin
by asking you to tell us a bit about what is involved in certifying
a farm assurance scheme. Take the National Goats' Milk Scheme
as an example; what inspections do you carry out, how regularly,
where do you go, what do you look for?
Ms Campbell: Paul is the goat
man!
Mr Wright: We are the verifiers
for the National Goats' Milk Scheme which was a scheme that was
developed to allow it to attract a red tractor logo marking and
the Goats' Milk Scheme is built around the current national dairy
farm assurance scheme for cows' milk. Because there are certain
differences between goats and cows it was a scheme that was adapted
for goats' milk. There are only a very, very small number of goat
farms that are actually in this scheme, probably as few as 13
or 14, and in order to get the red tractor logo they were advised
to have independent verification and certification of their farms
meeting those standards. In order to comply with the standards
that have been prepared we visit each of the goat farms once a
year with our auditors and confirm and check that they are in
compliance with their own standards. If they are in compliance
then they continue to be certified and if they are not in compliance
then we do what is commonly called "raised non-conformances",
which they have to address before certification can continue.
Each audit will take something in the order, depending on the
scale and size, of two and a half to three and a half hours on
site.
Q228 Chairman: What actually happens?
How many of your staff or the people you are contracting go out
to the particular farms? What do they look for?
Mr Wright: Just one member goes
out and he has the scheme standard and he has the check list,
which might cover a variety of things. I am not totally familiar
with every aspect of the Goats' Milk Scheme but it will actually
examine production, it will examine welfare, it will examine husbandry,
it will examine medical records, it will examine veterinary reports,
and it will seek confirmation that they are adequate in compliance
with the standards. One person will do that. Those reports are
then submitted back to us by the auditor, who is a contracted
auditor to us and who has experience in that particular industry,
and they are then subject to review by other experienced reviewers
and at that point the report is reviewed for accuracy, objectivity,
impartiality and completeness.
Q229 Chairman: What sanctions do you
employ if the recommendations of the review team are not complied
with?
Mr Wright: In the first instance
of the recommendation if they are not in compliance they do not
get certified. They are then asked to put forward their corrective
actions for any non-compliances and immediately on confirmation
that all their all non-compliances are what is called closed off
they will be certified. For continuing certification at the end
of each surveillance visit, if there are seen to be non-compliances,
certification will continue for a period of 30 days during which
time they are asked to address those non-compliances again. Providing
they do address those non-compliances and they satisfy us that
they have been addressed, certification will continue. If not,
it will be withdrawn.
Q230 Chairman: One suggestion is that
there are about 30 or so such farm assurance schemes operating
in the country, maybe more. Can you give us an estimate of the
number of farm assurance schemes currently operating in Britain?
Ms Campbell: It will be quite
difficult to give you a precise number because there are so many
different reasons why there may be a scheme. The 30 probably is
conservative but it might be in the right region and I think the
thing to recognise about the number of different schemes is that
they are covering so many different aspects. There may be schemes
there that are covering quality, there may be other things to
do with safety or animal welfare, or it could even be to do with
regionality of foods. There are just so much different aspects
that might require a scheme. Following on from what Paul said
about the Goats' Milk Scheme, when you are asking what is involved
in a farm assurance scheme I think the key thing to bear in mind
is what is involved depends entirely upon what is in the standard
and so that is actually the nub of the issue, what is actually
in the standard, rather than saying typically a farm assurance
scheme is X or Y. A farm assurance scheme will assure you that
that farm complies with whatever is in the particular standard
against which they are requiring certification.
Q231 Chairman: In the guidance from the
FSA it states, I understand, that all the food assurance schemes
in the UK should be accredited to European Standard EN 45011 by
the UK Accreditation Service. What proportion of these schemes
actually achieves that accreditation at the moment?
Ms Campbell: Again, I would not
be able to answer that. I am not even sure UKAS could answer it
because it would not necessarily know what schemes have not complied.
It is guidance and I think most of the scheme owners would seek
to ensure that their schemes are accredited, but I do not think
that it is necessary that all the schemes do meet that requirement.
Also what tends to happen in terms of accreditation is that some
schemes can predate this requirement so there tends to be a practical
arrangement to enable schemes to come into compliance with it.
Again, a lot will depend on the particular owners of the standards
or schemes as to how definitive they are about the need to meet
that requirement and/or what terms of time they give in order
for schemes to become compliant with it.
Q232 Chairman: Take, for example, the
schemes which you certify, how many of the ones for which you
are responsible in some way meet the European standard?
Ms Campbell: I should think probably
most of them, do they not, Paul?
Mr Wright: Where there is a specific
requirement for EN 45011 accreditation, it is always our policy
to pursue those accreditations. Accreditation can take a year.
It can take 18 months to build a scheme and satisfy UKAS that
this scheme is in compliance. Where there are schemes that do
not require 45011—and I am hesitant to think of any at the
present time—then we would not necessarily go for EN 45011
because it is an expensive cost burden to the smaller schemes.
I will give you an example of that. We certify Whitstable oysters
and it is a requirement under EU regulations that the scheme operates
to EN 45011 accreditation. Whitstable oysters, however, is one
single producer in Whitstable in Kent where to develop a scheme
and to accredit that particular scheme would be so burdensome
to the organisation concerned that what we do is we simply operate
to EN 45011 in that instance. Very rarely is that the case but
it is such a small operation that it is agreed with Defra that
in that instance we simply operate to EN 45011. It does not make
any fundamental difference, it is just less burdensome on the
poor old Whitstable oyster catcher.
Q233 Mr Jack: In evidence to the Committee
from Mr Clive Dibben, an independent consultant, he said that
the majority of these schemes in which you are involved, certifying
simply mirrors the basic legal requirements in their respective
areas of operation so they give some degree of assurance that
people are playing by the rules but they do not, if you like,
go beyond the minimum standard. Do you agree with Mr Dibben's
assessment?
Ms Campbell: I think there will
be a number of schemes that are predominantly based on minimum
requirements and you could perhaps ask yourself the question why
bother with the schemes if they are merely minimum requirements?
I think that is because producers have seen the need to be able
to demonstrate that they are in fact meeting those minimum requirements
and that it is quite important to purchasers, not necessarily
the consumer but in the food chain, to know that they are meeting
those minimum requirements because obviously there is no policing
of every individual producer to be able to demonstrate that, so
this is one means of being able to show that. I think there are,
though, many, many schemes where they do go beyond the minimum
legal requirement when they are responding to what consumer needs
are because again it is often consumers who are asking for things
that go way beyond what is sensible to legislate for, and therefore
there is a need in the voluntary sector to be able to develop
schemes in response to that, so again things that we are seeing
to do with animal welfare or the provenance of products may be
something that will go beyond legislation but they are a particular
producer seeing that they are responding to consumer needs, so
I do think you have a mixture of both.
Q234 Mr Jack: Do you not therefore think
the implication is that if people see some kind of message of
assurance, some kind of scheme, that they think that the product
area is better than the minimum? Do you not think that informing
people (because these schemes are designed to send out some kind
of message) either about the nature of the end product or the
way that it is being produced, that you should be able to differentiate
between those who are simply saying, "I am having a rigorous
assessment and I am meeting the minimum," as opposed
to, in whatever way they do, exceeding the minimum and perhaps
adding something on as well?
Ms Campbell: Very much so. I think
there is a need for consumers to be able to understand what the
various schemes deliver. In many respects many of the schemes
are not necessarily developed in response to consumer needs. They
may be there in response to purchasers' needs further back in
the food chain, not the end consumer, and there is a danger that
we do as a consumer pick up completely mixed messages. We do not
actually know what the various logos mean. It is not easy for
us to be able to tell, as a consumer, whether it is a marketing
claim or whether it is an independently verified scheme. From
the basic level it is quite hard for a consumer to differentiate
between those two things, so I think it is quite important that
there is an ability to be able to demonstrate that something has
been independently verified and that this is not just a marketing
claim.
Q235 Mr Jack: Have you seen any research
to talk about what consumers' perceptions are of the multiplicity
of schemes that are around, in other words what they understand?
It is quite interesting to see sitting in this Committee the number
of people who, for example, have organic schemes, which have a
variety of different requirements for products under that scheme's
certification process to be counted as organic. There are European
legal requirements to set minimum baseline standards but some
schemes are far more rigorous in their application than others.
It is very difficult for somebody who says, "I would like
to try organic for the first time," to know whether they
were getting the most rigorous or just the basic.
Ms Campbell: I think it is extremely
difficult because again government has got the very hard choice
of deciding whether it tries to enforce standards that are beyond
the legal requirement. We have seen recently this week someone,
I cannot precisely remember who it was, who was confirming that
there was a feeling in the UK that sometimes we interpreted the
EU standards beyond that which our European neighbours did, and
certainly in terms of the organic area, I know there was a lot
of debate in terms of whether UK organics should be allowed to
lower their standards, if you like, to comply with the EU requirements,
lower than many of the existing organic schemes that were here
in the UK, and it was an extremely difficult area. I think overall
there was a feel that as a minimum there has to be a level playing
field between the UK and Europe and that we should not penalise
UK organic farmers but, equally, there should be the opportunity,
if consumers are demanding more than that standard, to be able
to promote organic schemes that meet higher standards and to be
able to build beyond that minimum legal requirement. Again, like
all things, the more choice that you have the more difficult it
is to get a message over to the consumer. That does make it much
more complex, but I think on balance the preference would be to
enable that choice and we have to work harder at trying to simplify
the many messages that are there and to hopefully make it a little
bit easier for people to quite quickly establish benchmark baselines
and then those that are interested, and we have to accept that
not all of us are prepared to put that effort into our shopping
necessarily to research what each individual schemes means but
that those of us who are interested and do wish to know more about
what is behind the various schemes we have easier access to that
information.
Q236 Mr Wiggin: I am very curious about
this because a lot of my constituents who are farmers complain
that they pay to join various schemes and they do not get much
for it. Do you not feel that the boot is really on the wrong foot
and it should be us the consumers who are paying for your schemes?
I have no difficulty with what you are doing. Essentially you
are policing to ensure that we the consumers get what we think
we are going to get. Should not the supermarkets be paying for
that?
Ms Campbell: When you say "our"
schemes, we are the independent verifier of other people's schemes.
They are not our schemes and our job is purely to be able to come
in and be able to verify those claims. That is not to say we are
not involved in helping to develop certain schemes because obviously
as part of developing any scheme if you are going to have it assessed
you need to consider certain elements in it as you develop that
scheme otherwise it would be impossible to assess that scheme.
At the end of the day the consumer always pays, do they not?
Q237 Mr Wiggin: No, definitely they do
not pay when it comes to farm assurance, definitely they do not,
because there are different schemes, as you rightly identified,
and some will be better, some will be different, some will be
cheaper, some will be more expensive. Very often, with farm assurance
schemes particularly, ultimately the farmer pays and there is
no actual premium for selling an accredited product and that is
the point, I am trying to get to.
Mr Wright: I think you have to
go back to the history of farm assurance schemes which were originally
membership driven. They were there to respond to the scares of
the early 1990s and BSE in the mid-1990s. If you take the farm
assurance schemes as they are now there is a negative to it nowadays
because if you are not farm assured you often cannot shift your
stock. That is the negative.
Q238 Mr Wiggin: That is why I am putting
it to you that whilst what you are doing is great, the problem
for us with food is this is a very negative type problem we have
got now. People are putting in schemes whereby they cannot sell
otherwise but that is the wrong way round. Surely it should be
the supermarkets saying, "We will only buy from the schemes
we run"? You may well be the verifier of that but that is
not the way it is happening at the moment. The scheme managers
are the ones insisting that farmers cannot sell their crop otherwise.
Mr Wright: If you take food safety
schemes such as the BRC scheme that is where the manufacturers
pay for that assurance, usually at the behest of the retailers
one has to say, but it is a common enough problem that you define
and it is not one that we should have a view on.
Q239 Mr Wiggin: You are in the middle
but the difficulty for us is that we are trying to talk about
food information and it is all the wrong way round. The people
who will actually be serving the consumers are the supermarkets/the
shops but they are not the ones who are taking a great deal of
interest in this. It is the producers who are doing it to promote
their product.
Mr Wright: You have to identify
benefits too and that is probably the trick for scheme owners.
If they are having to sell that to their members, bearing in mind
that most of the traditional schemes have been NFU driven in the
past, quite obviously it is the NFU's members to some extent whom
they are trying to represent. If you are looking at it from that
viewpoint and the way it was marketed in the past—to actually
give benefits and put assurance back into the food chain where
there was a degree of cynicism and scepticism with all the claims
being made particularly from the farm side (and most of the food
scares have emanated from the farm side in latter years)—then
there was a genuine desire in the industry to put more confidence
back into the food chain by having assurance schemes, so there
is some benefit to it. Would we have been so successful in getting
beef back on the menu without farm assurance schemes? It is an
open question.
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