In the wake of the recent Hepatitis A berry scare and a new country of origin labelling proposal, the Australian National Audits Office (ANAO) has published a report that highlights failings in Australia’s imported foods surveillance system.
A report from the Auditor-General presented to Parliament on 10 June 2015 recommended that important changes be made by Australia’s Department of Agriculture.
The 3 key recommendations are:
2. The development of performance measures and reporting on outcomes.
3. A new approach for monitoring risk profiles and the referral of food for inspection;
Background
Australia’s Imported Food Inspection Scheme (IFIS) is responsible for determining whether imported food products are suitable to enter Australia. The scheme aims to determine whether products meet the food compositional, labelling and safety standards that are also required for domestically produced foods in Australia and New Zealand.
The Department of Agriculture (‘DOA’) categorises imported food products into two categories: ‘risk products’ and ‘surveillance products’. Risk assessments are conducted by Food Standards Australia New Zealand (FSANZ), which advises the Department of Agriculture on which products ought to fall under each category.
All imported ‘risk’ products go through an inspection process; however rates of inspection are reduced over time once a producer can establish a history of compliance. Examples of foods classified as ‘risk’ include cheeses, peanuts and peanut product, tuna, mackerel and bivalve molluscs.
All foods not categories as ‘risk’ are classified as ‘surveillance’ foods. These products are subject to lower inspection rates selected by automated randomisation, but the rate if inspections are increased only if inspections fail.
Importers also have an option to elect to be assessed under a Food Import Compliance Agreement (FICA), which allows the importer itself to take over some elements of compliance through its own food safety assessment systems. These systems are subject to periodic audits and, according to the ANAO report, have experience low levels of take up.
Purpose & goal of the ANAO audit
The ANAO audit was done in order to assess the effectiveness of the current system, and asked the following questions:
-- Has a compliance program that effectively monitors compliance with regulatory requirements been implemented?
-- Are effective arrangements in place to manage non-compliance?
- -- Have arrangements for collected regulatory intelligence and assessing compliance risks been established?
The ANAO has suggested a range of improvements to improve the administration of IFIS and increase food safety of imported food products to Australia and New Zealand.
Key improvement areas include:
-- Better consistency in the management of serious breaches – including better investigation practices and documentation
-- Developing performance measures specific to the IFIS – including identification of emerging trends and changes and measuring the extent to which objectives are met.
-- The establishment of mechanisms to assure products are being categorised as ‘risk’ or ‘surveillance’ correctly
-- Better consistency between regional offices of the DOA. This has been highlighted by the ANAO as a problematic area as some methods used by the offices differ, leading to a risk of inconsistent implementation and decision-making .
Further in-depth recommendations and observations were made over four key areas of the system: compliance intelligence and risk assessment, monitoring compliance, responding to non-compliance, and governance arrangements.
Governance Arrangements
The report notes that administrative arrangements are currently “overall appropriate” however scope for improvement still exists. This includes upgrade to IT systems used to ensure more consistent outcomes, continued effort for consistency in regional locations and establishment of performance measures specific to the IFIS.
Monitoring compliance
The ANAO recommends the introduction of “targeted communication to small-scale importers” to reduce incidence of inadvertent non-compliance. Further, the report highlights a need for greater awareness of the option of FICA for importers, and established data on the operation of risk profiles to ensure products are being assessed under the appropriate risk category.
Compliance intelligence & risk assessment
The ANAO noted that information collected on imported foods is limited and no system exists for shared information on incidents, recalls and breaches. The implementation of a “compliance intelligence strategy” is recommended in the report as a means to enable information sharing between co-regulators, leading to better compliance levels. This further could enable the collation of information to assist FSANZ in determining the risk management categorisation. At present, FSANZ lacks sufficient feedback to be providing proper guidance.
Responding to non-compliance
A better focus on consistency and efficiency is recommended for improvement, including more timely issuing of holding orders for failing foods, consistent workflow monitoring practices, better documentation of preliminary reviews of serious non-compliances and better planning and routine monitoring arrangements.
