Whatever one’s views of Brexit and whether or not you were a “Remainer” or a “Leaver”, it is safe to say that most people – businesses and individuals – outside of the Westminster bubble just want to get on with our withdrawal from the EU. But what are the implications of Brexit on the food industry?
According to the Government, the processed food and drink sector is the largest manufacturing sector in the UK and contributes £28.8 billion to the economy. With other key statistics including:
- Exports were worth £22 billion in 2017 and they continue to grow.
- The sector directly employs 400,000 people throughout the country, a third of whom are EU nationals.
The sector is characterised by just-in-time delivery of products with short shelf lives and is heavily integrated with supply chains spread across the UK and the EU for sourcing raw materials, processing goods and selling them. Many manufacturers have factories in both the UK and the rest of the EU.
Clearly then it is crucial that the sector is able to remain competitive when we leave the European Union and remember, of course, that Brexit is not just a concern for UK food producers but also for any food manufacturer (EU and non-EU) serving the UK market.
Food is not like other sectors. With climate change and population growth threatening food security globally, keeping the UK’s farmers in business matters. Not just for economic reasons but also for more prosaic but equally important reasons like maintaining the landscapes. Therefore it can be argued that what is needed is an imaginative new system of subsidy that gives public money to farmers for public goods, or risk farmers leaving the land.
Let’s take a brief look at three key areas: Supply Chains, Legislation and Freedom of movement.
- The potential impact of a Brexit on supply chains
Supply chains could indeed be affected if tariffs are imposed between the UK and the other EU Member States. Currently, products move freely across the border between the UK and the other EU Member States and no tariffs apply. Following Brexit however, the food and drink sector could face significant EU tariffs and potential supply chain disruptions.
- What about EU food legislation?
Will the UK continue to apply EU food legislation, which has been adopted, harmonized and is directly applicable throughout the EU, or will it now start introducing its own or new rules?
There are something like 4,500 or so EU regulations covering food, farming and environmental standards that fall within the remit of the Department for Environment, Food and Rural Affairs (DEFRA). Whilst it’s true that Brexiters may hate the Brussels bureaucracy that dictates everything down to the size of olive oil cans, it must be recognised that many of these rules are necessary to protect from the sort of food safety scandals and frauds of the past. They are also what make trade deals and borders frictionless. Exports depend on this sort of harmonisation of rules.
- Freedom of Movement
Another critical factor, the ending freedom of movement, will almost certainly require the creation of a new layer of bureaucracy that can deal with the permits and visas for the estimated 500,000 foreign workers that farmers, food processors and food manufacturers say they must have to stay in business.
As the short review above shows this is a very complex, multi layered, multi-national problem and is likely to be so for years to come. However, business usually finds a way through what often look like intractable problems.
Audits are critically important to food companies and should be treated as such. They are the primary tool your customers use to determine if adequate food safety systems are in place at your facility. This article covers some of the strategies and tactics that should be considered to maximise your chances of a successful audit.
We will take a look at the mechanics of an audit – what’s it all about – as well as considering some common sense tips that will help facilitate a smooth audit visit.
In simple terms, an audit is an answer to a series of specific questions and how you meet them. The Plan, Do, Check Act (PDCA) model is an ideal way to begin to approach an audit.
Plan: What are the rules of the game?
Here we need to consider what are the objectives of the audit and what are the parameters. Know your standard inside and out. You need to know it better than the auditor so you can speak with authority when something comes up that you don’t agree with. You need to be an expert.
Do: What is your procedure?
This is the crux of the audit. The auditor has asked about a requirement under the standard, and now you need to show him (evidence) how you do it. This needs to be written down in a controlled policies and procedure document.
Your goal here is to lead the auditor down a straight and clear path. The auditor reviews the document for compliance to the standard and moves on to his next question.
So, the process needs to include:-
- A written document control procedure with clear responsibilities.
- A way that staff can access the documents.
- A listing (register) of all the documents in the system
- A document retention or storage system
Check: What proof do you have that it was done?
We are back to evidence again. For example, you go over a procedure with the auditor and then he will want proof that it was done according to that procedure. So what can you show the auditor to demonstrate that this is how you do things? Remember if a procedure isn’t documented, you have no proof that it was done.
You may at this point bring up other areas where you test your system as well such as internal audits, self assessment etc. Also consider that auditors will judge behaviours against the evidence they see, so “talking a good game” won’t necessarily cut it if your evidence logs are not consistent with what the auditors sees.
Act: What happens if it is not correct?
We all recognise – even auditors – that no system is perfect, and if it is the auditor will be suspicious. Auditors expect to see errors in your system; they expect to see that things didn’t go as planned. The key here is being able to demonstrate what you did about it. This is your corrective action procedure. Just like document control, it operates the same. So, just like document control, you need a procedure that addresses the requirements and proof that it is followed. Your errors are your proof.
Above all any auditor is looking for clarity and easy path to navigate their way through your processes. The PDCA model can help you to do that.
Now we take a look at some tips that can help you in preparing for and executing a successful audit.
As we have discussed earlier, audits are largely based on the ability to provide the auditor with evidence that operations are compliant with a certain standard. The types of thing that will alert the auditor or make him want to dig deeper include a lack of organisation, untrained staff, and misinterpretation of compliance criteria. So in order to minimise this, here are 5 points to consider:
1.Small things matter
Make sure that conditions throughout the plant are tidy and things are labelled and in their rightful place. There should be sufficient space between the wall and stored material for pest control and cleaning activities to take place. Also ideally your internal audit should be conducted at least two months prior.
2. Teamwork is vital to success
At least three weeks before the audit have a staff meeting to prepare. Employees should be familiar with their written job descriptions and the monitoring records they are responsible for. Also staff and management need to have an understanding of:
- The hazards related to the CCP identified in the Hazard Analysis and Critical Control Points, or HACCP, plan.
- Terms such as “corrective action,” and the difference between verification and validation.
- The difference between recall and traceability.
3. Last minute won’t cut it
Preparation is the key to a successful audit outcome and so actions like filling out documentation in front of the auditor, or correcting deviancies while the audit is being conducted just won’t work. It is also important to use assertive language when speaking with the auditors. Cut out terms like “we try” or “sometimes.”
4. Senior Management involvement
We all have been part of audits where management is not available to attend either the opening or closing meeting. It is in the best interest of the company for someone in a senior role to be briefed prior to the meeting, and meet with the auditor. Adopting an accredited standard is a serious commitment. Senior management should speak with the auditor about the standard/audit and explain some of the steps that have been taken to comply with the standard.
5. Don’t be defensive
Auditors are human beings too, and they will not take kindly to being challenged especially on an area where you clearly don’t comply. Remember they are just doing their job, and the main activity of that job is to collect data. So, if you disagree with the findings, take it up through the appeals process. You can challenge the auditor after the report is issued. Stay positive and the audit will go more smoothly.
If you want to know more about how HVDS can help you to comply with relevant standards relating to clean air in the food industry, please contact us at HVDS on 01785 256976 or email firstname.lastname@example.org.
The definition of a local exhaust ventilation (LEV) system is: an engineering control system to reduce exposures to airborne contaminants such as dust, mist, fume, vapour or gas in the workplace. Simply put it is something that sucks an airborne contaminant out of the workplace.
It is vital that the correct LEV is chosen for a particular task and kept correctly maintained. If a process or activity with which the LEV is associated is changed, then the suitability and specification of the LEV system must be re-assessed.
Most systems consist of the following:
- Hood – where the contaminant enters the LEV
- Ducting ‐ to transport the contaminant and air
- Fan – To power the system
- Discharge – To release extracted air to a safe place
- Air cleaner or arrestor – to filter or clean the extracted air (not all systems have this type)
Types of LEV System:
- Total Enclosure – the process is totally enclosed, and the air extracted from the enclosure e.g. glove boxes/blasting cabinets/CNC machines
- Partial Enclosure – the process is not totally enclosed, and the operator can access the process. Air is pulled passed the operator and into the enclosure e.g. spray booths and milling machines
- Capture Hoods – the process is not enclosed by the system; the contaminant is pulled into the system e.g. ventilated bench, down draft table, welding extract, solder tip extraction, low level room extraction for liquid nitrogen areas or solvent stores, integrated extraction on equipment such as saws and sanders
- Receiving Hoods – the process is not enclosed by the system; the process provides the energy to deliver the contaminant to the hood e.g. canopy hoods over furnace or oven.
Advantages/Disadvantages of LEV:
- Properly positioned LEV and/or well-designed units will capture emissions at source and so protect the employee from exposure.
- The general supply/exhaust ventilation air volume can be reduced as it is not relied upon to dilute contaminants.
- If the LEV is incorrectly placed, contaminants can be drawn into either an employees breathing zone or the process itself.
- Emissions drawn into the system must be disposed of safely and without any adverse effect on the environment.
- It is an additional system to operate and maintain; otherwise it could become an exposure and/or fire hazard.
- Employees must be properly trained in the system’s correct use, its effectiveness and maintenance needs.
When using LEV to control exposure, companies must thoroughly assess the hazards to be controlled and be satisfied with the following:
- the system is fit for purpose
- trained employees are used to maintain the system
- the system is regularly maintained
- records are kept demonstrating that the system is both effective and ongoing.
Having a good understanding of what hazards need to be controlled is crucial to ensure that the initial design can achieve adequate control.
Useful tools include the HSE LEV calculator.
The Control of Substances Hazardous to Health (COSHH) Regulations requires local exhaust ventilation systems to be maintained to a standard suitable for their purpose. It is recommended that the system be checked at least every 14 months, or more frequently if the manufacturer recommends it. Also, simple routine checks can be carried out when the system is in use.
If routine maintenance is neglected extract efficiency will deteriorate and mechanical parts could be liable to fail. As a minimum, the manufacturer or supplier’s recommendations should be used as a guide to the maintenance regime.
Plants should draw up maintenance procedures to cover a full range of activities, from simple visual checks for defects to preventative maintenance and remediation. In addition, they must ensure that there are suitable arrangements in place for the disposal of material collected by filters or other air cleaning devices.
Most filters used in local exhaust ventilation systems will, due to their very nature, require particular handling and care, with disposal being via the appropriate hazardous waste disposal route.
With any maintenance plan, suitable records must be maintained by a named responsible person. Any maintenance records should be held in the vicinity of the LEV system or should be made available for inspection by users or other personnel who may wish to inspect or carry out work on the system.