Environment, Food and Rural Affairs Committee Written evidence submitted by Paul Smith

I am a retired inspector with 43 years experience in the meat industry. I have a widely-held reputation in the food industry, particularly the meat industry, as an effective auditor. I wish to assist the Committee in its efforts to effect appropriate changes so as to ensure the horsemeat incident and related incidents do not re-occur. To that end, the reason(s) why it happened need to be clearly understood. The following may assist in explaining this.

1.There is a massive failure of multiple retailers themselves to monitor their suppliers through appropriate inspections at appropriate intervals.

2.Instead, they put a Food Supply Standard together entitled “The Global Standard for Food Safety” and farmed out the inspection responsibility to 3rd party inspection bodies that the BRC and UKAS approved.

3.The suppliers (the auditees) can select which “approved inspection body” they use. They also pay for the audit. Yes, they can pick which audit company, the alleged policeman, they wish. In practice, they also pick which auditor by heaping praise on them followed by request for same individual next visit.

4.The inspection is a “graded result” type of exercise with Grade A being the target of all suppliers, To achieve this, only a small number of non-conformances can be identified and none can be major.

5.The consequence of 3. above has been that the senior management in the inspection bodies can readily bend to any suggestion by the supplier that they are “unhappy” with the inspector/inspection outcome, the implied threat being that they will move their business to another audit body.

6.The audit companies are private, profit-driven, companies and compete with each other to secure supplier nomination as the preferred audit company.

7.One such audit company dominates in the meat sector because its origin was the Meat & Livestock Commission which sold the business, then known as EFSIS, to SAI Global. This happened in 2003.

8.The Managing Director then and many years after was Mark Proctor and Operations Director, Carole Payne.

9.Under their stewardship, two specific meat groups was never audited by their Irish-based auditor following initial audits by this inspector at these sites. Both such groups were/are major suppliers of meat to Tesco. Instead, UK-based inspectors went over to undertake this work.

10.The Irish auditor was a highly respected individual in terms of his knowledge and audit skills.

11.It is for Messrs Proctor and Payne to explain why the person they based there was not used.

12.The Irish based inspector retired in 2008. In 2011, he requested to audit for Tesco as an independent auditor as Tesco were seeking such personnel to undertake additional audits of their supplier base. It was a widely held view that Tesco no longer had any confidence in the 3rd party BRC audit process despite this being their representative body standard. If they had confidence in it, why else would they embark on a return to auditing against their own standard.

13.The message that came back verbally and very indirectly was that although he had great admirers, he had upset very influential people in the meat industry.

14.Why Tesco senior personnel did not challenge this is something for them to answer also asking was it senior Tesco personnel who did not want this inspector involved.

15.Curiously, Tesco gave a substantial amount of this supplementary audit business to SAI Global.

16.Significant social relationships were developed by the above-named individuals with senior personnel in meat companies and with senior retailer personnel and that remains to this day.

17.Mark Proctor left SAI Global in 2009 is now working for Exova, a UK company also selling BRC inspections.

18.Carole Payne left SAI Global in 2009 and now works for Tesco in a senior role.

19.It is also noteworthy that a David Fleetwood was, for a time, a Director of EFSIS/SAI Global whilst also being a Director of ABP. Also, the SAI Global auditor of Silvercrest Foods, an ABP company, used work for ABP.

It is the writer’s view that the whole system is a disgrace and in need of total review.

It is reasonable to want to avoid repeat audits of suppliers by each retail multiple. However, it is the BRC, the multiple retailer representative body, who should employ the inspectors and not commercial companies who are profit-driven and that can be selected at will by suppliers depending on their perceived weakness/toughness. The winners under these arrangements are the senior management of audit companies that build successful careers for themselves but at the expense of both the consumer and farmer.

There is much I could add in relation to the damage to the British farmer through poor standards of traceability auditing by these 3rd party companies. Further, to get an indication of the incestuous relationships and inappropriate relationships that exist between the meat industry, multiple retailers and audit bodies, just demand the names of all individuals who have routinely attended the annual 1,000+ people dinner held by the Butchers & Drovers Charitiable Trust and who is a guest of whom. It is a telling read.

I encourage the Committee to insist on a total reform of the inspection approach with ownership of the approach placed firmly where it belongs, with the multiple retailers and its representative body, the BRC—and most certainly not with 3rd party commercial companies, the regulation of which has never worked and cannot work.

February 2013

Prepared 19th February 2013