Memorandum submitted by Genesis Quality
Assurance Limited
EXECUTIVE SUMMARY
1. Genesis Quality Assurance Ltd. is a business
dedicated to the provision of information about food production
systems through assurance schemes.
2. Despite being recognised by independent
third parties as operating schemes at least as good as those operated
by industry bodies and being able to do so more efficiently, the
Genesis QA scheme has faced anti-competitive practices from industry
controlled schemes. This has been damaging to the interests of
producers, consumers and the development of the whole-farm approach
to assurance which promises to deliver assurance in a manner which
is better aligned to consumers' expectations.
3. It is proposed that interests outside
of the sphere of assurance and food labelling have driven industry
organisations to act in the way they have and that this has been
detrimental to the assurance sector and the interests of individual
producers and consumers.
4. Despite access to significant public
funding industry bodies have failed to deliver a credible and
workable assurance authority, despite more than seven years of
trying. It is suggests that new and truly independent approach
is now justified.
INTRODUCTION
5. Since its establishment in 1999, Genesis
Quality Assurance Ltd. has been at the forefront of efforts to
deliver better and more cost-effective methods of providing the
food industry and consumers with information about food production
systems. Even before the National Farmers' Union announced its
plans to develop the Little Red Tractor logo, Genesis QA had announced
its intention to develop a logo to appear on all foods that had
been produced according to its own assurance scheme. This is based
on a more comprehensive system than schemes operated by industry
bodies and is more cost-effective without loss of credibility.
Indeed, in some cases the Genesis QA system has achieved UKAS
accreditation to EN 45011 when industry operated systems have
not.
GENESIS QA
6. Genesis QA was the first assurance scheme
in the farming mainstream to develop and implement a whole-farm
approach to assurance. Instead of requiring farms with more than
one enterprise to sign up to, pay for and be inspected by a plethora
of schemes operated by individual sectors of the food and farming
industry, our system is based on a single scheme. It has a primary
module covering "whole-farm issues" such as management
plans for farm waste and risk assessments for health and safety,
animal welfare and environmental protection. This is complemented
by a suite of additional modules containing the specialist criteria
for individual enterprises such as pigs, beef, sheep, dairy production
and combinable crops.
7. We have good reason to believe that our
scheme is at least as robust as those operated by industry bodies
such as the NFU and in some cases more so. For example our module
in the dairy sector has already achieved EN 45011 accreditation
whilst the main industry operated scheme has yet to do so. This
despite the fact that the National Dairy Farm Assurance Scheme
(NADFAS) is a "founder member" of Assured Food Standards,
which since its inception in 2000 proclaimed that all its schemes
would be EN 45011 accredited within a specific timescale the deadline
of which seems to keep slipping. More than this, AFS refuses to
accept schemes from outside the "founding" group as
"equivalent" unless they are already EN 45011 accredited.
It is also the case, that whilst the Genesis QA scheme does not
permit a Certificate of Conformity to be awarded until all non-conformances
have been rectified, the industry controlled schemes allow certification
of farms with non-conformances still to be addressed.
8. With some industry standards being barely
the minimal legal requirement the acceptance of up to 15 non-conformances
could result in a farm which does not achieve the legal minimum
standards achieving certification.
9. Because our scheme is specifically designed
for farms with more than one enterprise, we are able to offer
single inspections and a single point of contact for scheme administration.
This alone represents a saving in time to producers and allows
us to offer inspection and certification at a lower overall cost
than if producers had to go to several individual industry-run
schemes. Our schemes are recognised and valued by processors and
retailers (including some of the nation's best known and respected
names) and yet we have suffered outrageous difficulty in obtaining
recognition from industry bodies like Assured Food Standards and
the NFU's "British Farm Standard" mark, the Little Red
Tractor.
10. We find this hard to understand and
to accept, particularly as we worked closely with Assured British
Meat (ABM)—the industry and Government-funded assurance
initiative—to help it develop a whole farm system (which
was never implemented even after a joint agreement was signed
between ABM and Genesis QA on the 23 December 1999). It is also
the case that since the control of ABM was returned to an industry-controlled
Board of Directors and AFS was established with further public
funds, the industry-owned schemes have tried to mimic the whole-farm
approach we pioneered through a complex and nepotistic series
of cross-licensing and cross-recognition agreements. This has
been a time consuming and costly business for all concerned, and
has yet to produce the same smoothly integrated system Genesis
QA can already offer.
11. It is a strange coincidence that individual
modules of the Genesis QA scheme were not recognised by AFS until
after any cross-license between the AFS competing schemes were
agreed.
12. A further benefit of the Genesis QA
approach is that risk assessment is a fundamental part of its
structure and operation. In conjunction with the assurance inspections
we are able to offer an insurance risk assessment to producers
which is much valued by insurers, who are then able to tailor
insurance premiums to the level of risk posed by an individual
farm. This enables producers, who have undertaken our inspection
and assessment procedures (especially those with a good risk rating)
to benefit from significantly reduced insurance costs. It is not
uncommon for the savings to outweigh the cost of Genesis QA Certification
and inspection charges leaving the farmer with a net financial
gain.
13. We believe that this may have contributed
to the unwillingness of the industry schemes to accept Genesis
QA. Not only do we offer a commercially more competitive system
(which is in direct competition to the industry's own inspection
and certification businesses), but, we may also be perceived as
a threat to the NFU's interests in the insurance market—even
though we have offered to undertake risk assessments on NFU Mutual's
behalf.
14. As a consequence we have a litany of
complaints against industry-controlled schemes and organisations
which have sought to prevent us from trading on equal terms. Despite
seeking amicable resolutions to each of these problems as they
have arisen we have, on almost every occasion, had to resort to
legal proceedings before organisations involved have accepted
our position as being correct. Thus far we have taken action against
three industry organisations and have been successful on all occasions
with yet another case still unresolved.
THE NEED
FOR CHANGE
15. It is our firm belief that the approach
of industry bodies to Genesis QA and others operating in the assurance
market (whether schemes, certification bodies or others) has been
detrimental to the assurance sector, producers and consumers.
It has certainly hampered the ability of the industry to provide
information about food production systems to consumers in the
most cost-effective way, thus adding cost (or at least preventing
cost-savings) to the assurance chain/food supply chain. It has
also ensured that the development of a whole-farm approach to
assurance has been considerably slower than it might otherwise
be.
16. The merit of the whole-farm approach
is now very widely recognised in other spheres of activity, indeed
Defra, in response to the findings of the Curry Commission is
seeking to adopt a whole-farm approach to its own activities in
enforcement and other areas. Whole-farm is a driving principle
behind cross-compliance and we believe that the Genesis QA experience
and approach could be modified to help Government and its agencies
to deliver their obligations in various areas more efficiently.
17. In the context of assurance and the
provision of information to consumers, the main benefit of whole-farm
assurance is that it actually delivers a more sensible assurance
about the nature of the farm and farming system. Under most other
systems, it is only individual enterprises that are inspected.
However, it seems likely that if you tell a consumer that a product
comes from an "assured farm" or an "assured farmer",
they would expect that standards of operation are of the same
standard across the whole farm, regardless of the enterprise.
This is something with which schemes under the Red Tractor logo
have struggled, because, despite being promoted as a single entity,
the "British Farm Standard" is in fact a loose amalgam
of schemes developed for individual sectors of the industry, at
different times, by different groups and each has dealt with the
same issues in different ways.
18. We believe that consumers and taxpayers
have a right to expect more from an assurance system in which
they have a significant financial and moral stake. Assurance schemes
are one of the main mechanisms by which information about food
production systems is provided to consumers. Through the Curry
Commission, the Food Standards Agency and other bodies assurance
has been recognised as being of national importance. Millions
of pounds of taxpayers money has already been devoted to developing
an assurance system that will work better for the public. But
the industry has still failed to deliver a system which works
coherently either in the context of the industry's own schemes
or the way in which its schemes interface with schemes operating
in what the Curry Commission described as higher tiers (ie Organic,
high welfare, regional or local provenance etc.)
CONCLUSION
19. It is Genesis QA's belief that one reason
for the repeated failure of the industry to deliver a workable
"umbrella body" for assurance—something it has
been trying to do since 1997—is that the interests of individual
producers and consumers are weakly promoted and play second fiddle
to the interests of industry bodies and industry controlled schemes.
Each time a "new" umbrella structure has been proposed
the existing schemes have not surprisingly viewed it as a threat
to their own operations. Consequently, whilst they may have been
cajoled into co-operating with each successive initiative, internecine
rivalries remain making it difficult to achieve a solution that
is workable. The history of assurance umbrella bodies has therefore
been characterised by back sliding on commitments and reneging
on agreements made.
20. Had no assurance schemes already been
in existence then a single body controlling, owning and running
food and farm assurance schemes in all sectors in the UK would
have been the logical approach. As it was, when the first attempt
at an umbrella body for assurance was made there were already
numerous schemes (owned by industry bodies, commercial organisations
and charities) in operation. As such the umbrella bodies could
only ever hope to achieve their objectives either through co-operation
with businesses which, as has already been noted, had their own
objectives to pursue, or through behaving in an anti-competitive
way to coerce. It is on issues of competition that Genesis QA
has had most frequent and most successful recourse to law in order
to open up the market to trade and to recover its legal costs.
21. Given that there was and is a multitude
of assurance schemes in operation, it is our belief that an alternative
approach to the umbrella body issue needs to be employed. We would
like to see a totally independent body which is free from the
control and influence of industry organisations and whose job
is simply to say whether or not any given assurance scheme delivers
an outcome which is equivalent to the outcomes of the national
baseline standard. If a scheme makes any further claim—whether
it be welfare, environment, ethics etc—the umbrella body
would also check that such claims are true.
22. We believe this system would be more
useful to consumers and producers as it would allow competition
in schemes, standards (at least above the national baseline),
inspection and certification. Those schemes and standards that
provided something consumers were prepared to buy would thrive
and survive others would not. Similarly, producers would be able
to choose the assurance system that provided their needs in the
most cost-effective way. As previously stated we believe that
Genesis QA has much to offer in that respect if it is permitted
to trade on equal terms with schemes whose standards it has shown
itself able to match or better.
23. Genesis QA has pioneered the use of
information technology with the collection of information whilst
on farm. Extension to the range of information collected could
be agreed (easily) with the various Government and non government
agencies (within the remit of the Data Protection Act) and supplied
to interested parties accordingly.
24. Whilst AFS and other industry bodies
have been provided with in excess of £2 million of public
funds to deliver commitments that they have failed to achieve,
Genesis QA has received none.
25. Genesis QA has always sought to deliver
that which is in the best interests of consumers and farmers.
In pursuit of that objective, we would be delighted to offer any
further information or assistance to the Committee that we can,
whether by further written evidence or by appearing to provide
oral evidence.
26. Genesis QA prefers the "Ronseal"
approach to farm assurance
"It does what it says on the
tin"
19 April 2004
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