Environment, Food and Rural Affairs CommitteeFurther written evidence submitted by Paul Smith

I have submitted evidence previously and emphasise that the approach to inspection by multiple retailers must change. Engaging 3rd party audit companies selected by the auditees and auditees pay has lead to:

(a)Very questionable relationships between meat companies and audit companies, both with auditors and senior management of such audit companies.

(b)Very questionable relationships between senior technical and purchasing management of multiple retailers and meat companies.

(c)Auditing that focuses on paperwork at the expense of traceability and food safety.

I firmly believe the retailers know about the poor standards of auditing. It facilitates the production of products at a ridiculous price as demanded by them knowing the specification they specify it is not possible to produce at that price. Further, the retailers perceive the value in the current approach is that it also provides a “Due Diligence” defence as demanded by legislation in the event things go wrong. It is possible that courts might consider a 3rd party certificated approval following inspection as meeting this requirement where a prosecution lax in challenging the merits of this certification.

I have very frequently gone into certificated meat plants to find numerous non-conformance issues concerning both traceability and food safety despite same holding BRC certification with as little as one minor non-conformance in such certification reports. The gap is massive and I have not yet seen any traceability exercise undertaken that I would consider as evidence of conformance to traceability requirements. My view is the established requirements are either contrived to facilitate abuse or those specifying the requirements, and those undertaking auditing, have no idea how the industry works.

My objective is solely to ensure things are done right and both the farmer and consumer are fairly treated. I have no doubt senior personnel in retail and audit body organisations make strenuous efforts to stop my involvement in meat industry auditing by “advising” suppliers engaging me in inspection or consultancy is not a good idea. My view however is that it is for the CEO’s of these organisations to demonstrate they are independent of such action by taking appropriate action, as publicly stated.

March 2013