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A
recently published report by the DTI (Department of Trade &
Industry) is set to drastically influence business continuity strategies
in the UK food sector, at a time when food companies are scrambling
to meet the deadline for complying with the revised food safety
regulations.
The report (entitled ‘IT for Traceability
in the Food Sector’) addresses the issue of traceability,
i.e. the ability by food companies to quickly track and trace back
to the origins of a food product in the event of a contamination
incident (or other such event that may lead to a crisis), often
requiring the recall of hundreds or thousand of items at significant
cost. The study was commissioned to a consortium consisting of Lysis
(a business assurance consultancy), Brunel University and CCFRA
Technology (the leading UK food research association). Within the
working framework, this consortium formed an Industry Forum from
20 leading food firms, working as a team to address the traceability
issue.
Vincent Tombros, Lysis’ managing partner
and the study team’s leader explains: “From January
2005, a new regime of traceability and documentation (Article 18
of European Union Regulation 178/2002) comes into force aiming to
put everyone in the EU onto the same footing. The legislation states
that ‘traceability of food, feed, food-producing animals and
any other substance intended to be, or expected to be, incorporated
into the food or feed shall be established at all stages of production,
processing and distribution’. The law says that the information
must be available ‘on demand’ – not tomorrow,
nor even in a couple of hours, but when requested by a local food
inspector”.
The results of the study provide a fascinating
insight on how companies’ risk management and business continuity
policies will be affected as a result of the traceability law. Vincent
adds: “Most larger UK food companies have in place procedures
and systems (such as bar codes and most recently, RFID – radio
frequency identification systems) that assist in meeting the new
requirements. However, significant black holes were identified in
many cases where UK companies use non-UK suppliers, especially those
from outside the EU”.
The risk of non-compliance to the new food
law appears to be much higher than many senior managers feared.
Take for example the case of a large importer of foods from the
Far East. How quickly can that importer track and trace back a contaminated
batch originating from Thailand? Can it be done “on demand”?
How quickly can the Thai supplier then mobilise to address the crisis
and provide the required product origin info? A similar example
identified by the study concerned a UK producer of high quality
pizzas, importing fresh produce (mozzarella cheese, anchovies, etc.)
from cottage industry producers in Southern Europe.
Vincent notes: “We were surprised by
how insufficient business assurance controls were, as implemented
by companies using overseas suppliers. Many of those companies risk
falling foul of the new regulations and this will severely inhibit
their ability to operate within the new legal framework. We are
not talking about a handful of small companies here, but of hundreds
of firms with turnovers of £10m-250m that will have a big
adjustment to make in a short timescale. This being an EU mandate,
it simply cannot be ignored”.
One of the solutions agreed in the report was
the development of so-called Global Minimum Standards for Business
Assurance. In practice, this means that UK food firms should sanction
their suppliers to comply to a new so-called Business Assurance
model, under which each overseas supplier must demonstrate that
it has in place up-to-date plans for risk management, crisis management,
business continuity management, product recall and other related
topics. Of course, first of all the UK food firms need to develop
the generic standard that they then can present to their suppliers
for their buy-in and tailor them as required. Then, the supplier
will need to prove compliance, whereby their chief executive signs-off
an annual Business Assurance letter.
Vincent concludes: “The difficult thing
will be for the UK food firms to not only develop a standard that
is well-structured but also to successfully engage their suppliers
to adopt it. Suppliers will need to see benefits from all the effort
they need to input. Fortunately, best practices in the development
of such standards were identified from leading companies in other
industrial sectors (such as in energy and automotive), which have
had to address similar issues within their global assurance process.
Such practices can now be modified and imported into the food sector.
“However, at the same time, food companies
face the challenge of streamlining their supply chain management
approach, so that they only collaborate with suppliers capable of
meeting the new requirements. On the plus side, food firms that
will introduce such standards can demonstrate to their customers
(retailers, etc.) that they have control of their supply chain’s
traceability and use this fact to their competitive advantage. All
in all, this new food law may turn out to be a blessing in disguise
for those companies quick enough to adapt, firming up business controls
and creating new win-win partnerships all through the supply chain”.
For an advance copy of the DTI report or more
information on food sector business assurance in the new legal framework,
food companies can contact Vincent.Tombros@lysis-consulting.co.uk

•Date:
2nd March 2004 •Region: UK •Type:
Article •Topic: BC
general
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