Supplementary memorandum submitted by
Clive Dibben
1. Further to the Committee's oral evidence
hearings of 22 and 29 June 2004, I would like to clarify and add
to some of the points raised in connection with my earlier submission
to the Committee.
2. During the hearing on 22 June, Mr Jack
stated that I had submitted evidence suggesting that assurance
scheme standards were no more than legal compliance. I think it
is important to point out that my memorandum makes clear that
these comments were in connection with what the Policy Commission
on the Future of Farming and Food described as "baseline
schemes", subsequently known as "foundation schemes".
3. There are, as Linda Campbell of PAI pointed
out in her evidence, schemes that exceed legal minima to varying
degrees. For the most part this is not true of the foundation
schemes, which are based primarily on legal compliance and compliance
with Codes of Practice. Most of the Codes of Practice have been
produced and published by Government and its agencies and are
themselves guidance on how best to achieve legal obligations.
4. As my written evidence stated, this is
not solely my conclusion. It was the view of the Policy Commission
on the Future of Farming and Food, the Food Standards Agency and
others who have investigated the schemes.
5. The Committee also raised the issue of
the integrity of the supply chain. Mr Wiggin suggested that purchasers
were inclined to specify assured supplies unless commercial considerations
meant it was more advantageous to buy from non-assured sources.
In fact this tendency applies equally well to foundation assurance
schemes themselves.
6. The assurance "chains" underpinning
the Red Tractor logo are, in places, less complete than the Committee
and others might have been led to believe. For example under the
rules of the Red Tractor scheme (as at March 2004), beef and sheep
destined for the food chain need not have been on an "assured"
farm from birth. Beef cattle need only have been resident on "assured
premises" for 90 days and lambs for 60 days (of a life span
that may last from nine to 30 months for beef and up to a year
for lamb). This residency period may also be "shared"
between farms. It is quite possible therefore that a significant
proportion of the early stages an animal's life may not be covered
by assurance standards at all.
7. It is also the case that whilst animal
feeds from commercial manufacturers must be purchased from businesses
certified by the feed industry's recognised assurance system,
farmers may buy feeding-stuffs from other sources based only on
self-certification that it is free from contamination and fit
for use as animal feed.
8. This is not to suggest that food resulting
from foundation schemes is anything other than that which it has
always been, but it does illustrate the fact that assurance schemes
merely deliver food produced to a particular standard. Unless
you know what the standard is and how it is enforced the mark
is meaningless. This problem is exacerbated because, for those
promoting the marks, it is tempting to overstate their benefits.
9. In this respect, I believe there is considerable
overlap between evidence the Committee has received on the issue
of diet and health and evidence on systems of production. Both
involve highly complex systems and interactions that are seldom
readily or meaningfully translated into a simple, single label.
What would be of greater merit, in my view, is a system that ensures
that if a food product makes a claim (whether about nutrition,
system of production or provenance) that claim is clear, justified
and verifiable. I believe an independent and impartially awarded
mark showing that a label can be trusted to do what is says would
be welcomed by all, especially if supported by a wider campaign
of information about food and its provenance.
10. A further point was raised during the
session about who pays for assurance. Mr Wiggin suggested that
it was always the farmer.
11. For baseline or foundation schemes this
is almost invariably true. In some cases there is a small premium
paid for products from foundation assured sources, but both the
cost of compliance with assurance scheme standards and the cost
of inspection fall on the farmer who has little power to pass
on those extra costs to purchasers.
12. However, given the widespread uptake
of foundation schemes it would, perhaps, be odd for a premium
to be paid for a non-premium attribute. Indeed an economist might
observe that if purchasers and the end consumer are unwilling
to pay a premium for products achieving foundation level assurance,
perhaps they attach no additional value to it.
13. This may be either because they believe
that what foundation assurance delivers is a basic requirement
of the food they buy (ie a standard feature rather than an optional
extra), in which case why would they pay more? Or it may be that
the foundation schemes have failed to communicate what "added
value" their schemes offer to purchasers. In which case consumers
don't understand why they should pay more.
14. It is probable that both are true to
some degree, but given that other types of assurance scheme seem
to be able to attract premium prices (eg Organics, high welfare
systems, EU protected food name products etc) it may be more of
the former than the latter. It is also the case that some purchasers
(eg manufacturers of baby foods) are prepared to pay a premium
to foundation scheme producers willing to comply with additional
obligations as part of their supply contract.
15. Purchasers may, in fact, see foundation
assurance simply as a means of ensuring producers' legal obligations
are adhered to in a climate where doubt has been cast on the ability
of industry and enforcement bodies to deliver that legal base.
Effectively the "assured" status of the farmer then
becomes the key that allows access to major markets.
16. Taken in this context, it is perhaps
more understandable why producers find it difficult to pass the
cost either of inspection or compliance (mostly with legal obligations)
further down the supply chain. An economist might suggest that
this only becomes a realistic proposition where purchasers or
consumers are convinced that a mark delivers additional value
for which they are prepared to pay. This would imply that those
whose involvement in assurance schemes is driven by a desire to
achieve a price premium will need to think both about exceeding
the foundation level and considering consumers' wishes and expectations—which
are diverse.
17. In this context, it should be noted
that the Strategy for Sustainable Farming and Food agreed with
the Policy Commission's suggestion that "all food should
attain" the baseline assurance standard. As such, the strategy
document and the Policy Commission have effectively sought to
peg all food production systems (whether organic, high-welfare,
integrated farming, foods of specified provenance etc) to the
Red Tractor system.
18. Both the Strategy document and the Policy
Commission also stated that the baseline standard and the Red
Tractor mark should be controlled by Assured Food Standards (AFS).
19. As a recent Parliamentary Question confirmed
(Hansard 17 May 2004: Column 655W), AFS is a private company,
running a private scheme(s). It may therefore seem a little strange
that AFS has, effectively, been given dominion (seemingly as part
of Government policy through the strategy document) over other
private companies and charities operating other private schemes.
20. As "gate keeper" to the national
baseline farming standard, if all food is to be covered by the
baseline scheme (the Red Tractor) all those other schemes and
bodies will have to comply with AFS rules and standards, which
may be less demanding or less appropriate in some circumstances.
21. This "one-size-fits-all" approach
is potentially damaging to all as it threatens to erode existing
standards, market differentiation and price premiums for those
who have achieved them. It may also diminish the incentive for
others to move away from the lowest common denominator.
22. I would reiterate that, in my view,
it is of greater importance to show that any food production system
delivers common outcomes, than to pretend all food is produced
to a common system. Quite clearly, it is not.
23. With reference to the Committee's hearing
on 29 June, whilst there is much of Dr Baines' evidence with which
I would concur, I do not share his narrow definition of an assurance
scheme. As stated in my previous evidence, by reference both to
the Food Standards Agency and International Standards Organisation,
it is evident that any certification scheme which involves elements
of farming practice is de facto a farm assurance scheme—hence
the inclusion of Organic schemes within the FSA definition of
assurance. As such, his estimate of the number of schemes focuses
on a handful of mostly large and mainly farmer-controlled schemes.
There are others and, as Linda Campbell noted in her evidence
of 22 June, the number of schemes is likely to keep rising. Indeed,
it is arguable that the focus of the Fischler reforms on quality
products and improving standards rather dictates that, at least
on a European scale, it is desirable that this should be so.
24. Nor should the definition of an assurance
scheme be restricted to whether or not a scheme has EN 45011 accreditation.
The FSA has advised that all schemes should have such accreditation,
but that does not suggest that prior to accreditation it is not
a scheme—the issue is one of credibility through EN 45011
(the accreditation process itself requires that schemes have a
track record before seeking EN 45011).
25. Finally, despite my view that there
is much that can be improved in the assurance sector, whether
within the so-called foundation level schemes or others, I do
not share Dr Baines' view that they are without merit. Even the
foundation schemes provide an additional tier of inspection, at
the cost of farmers, that would not otherwise exist across a large
proportion of farm output in the UK. They also have the potential
to be an invaluable tool in helping to change the culture of an
entire industry in a way that regulation alone never could.
26. Unlike Dr Baines I do not, and would
not, advocate that farmers withdraw from assurance. To do so would
be to withdraw from the one mechanism that could deliver many,
if not all, of the things Dr Baines and others wish to see for
the food and farming industry of the future—including a
hazard/risk based approach to farming practice. It would also
be a withdrawal from the only mechanism that will allow farmers
to recoup the cost of operating to higher standards than required
by law, whether viewed in an international or domestic context.
27. My concern is not that assurance, in
all its diverse forms, should be dismantled, but that the systems
of delivery and labelling are improved in a way that delivers
a better degree of assurance to consumers and allows schemes with
differing objectives, standards and markets to work together more
harmoniously. Unless this happens it is difficult to see how the
full potential of the Fischler reforms and the Strategy for Sustainable
Food and Farming can be realised in the UK.
28. If this is to happen, those who control
assurance at the foundation level should, perhaps, do more listening
before they start communicating. They must ensure that when they
communicate with others they have a verifiable message that others
want to hear. The current situation seems to be predicated on
telling people what you want them to believe, and if they don't,
saying it louder.
29. The NFU's evidence revealing the disparity
between consumers' recognition of the Red Tractor logo and their
understanding of it, is a case in point. Not unlike the caricature
of the English abroad, the assumption seems to be that if the
message is loud enough (or in this case sufficiently ubiquitous)
this will, of itself, lead to understanding. A better approach
might be to ask whether the right things are being said, in the
right way and whether the systems are there to support it.
30. For a policy of "reconnection"
to be effective, there must first be a dialogue in language that
all understand.
July 2004
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