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Equivalence, accreditations, certification systems, border clearance procedures & agreements. Dr Bill Jolly Chief Assurance Strategy Officer Ministry for Primary Industries. The Challenge:. Some Unique African Border Challenges. And some Novel Solutions. Some Age Old Principles:.
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Equivalence, accreditations, certification systems, border clearance procedures & agreements Dr Bill Jolly Chief Assurance Strategy Officer Ministry for Primary Industries
Some Age Old Principles: • Know what the end should look like before you start. • Start from the perspective of what the end consumer expects. • Then design a system that is resilient and will consistently meet future requirements
What Would a Good Endpoint Look Like? • Governments & consumers have enough confidence in the systems in place to accept “borderless trade” • E.g. Between New Zealand & Australia • Within the European Union • Within the GCC
Possible African Examples: • Borderless trade within trading blocks • Southern African Customs Union • Southern African Development Community • Maximum access and minimal re-inspection to selected other markets • Based on “system comparability” & recognition of equivalence
What builds trust and confidence? • Same or comparable standards • Robust approval systems • Independently audited quality systems • Aligned compliance & enforcement • System demonstrably free from political and commercial interference • Transparency of the system
2. Equivalence and Comparability • Needs some common reference points • “Level of Protection” often too hard to define objectively • Comparability of base standards, objectives, criteria and process easier
2. Equivalence and Comparability • It should not be about replication or looking for specific differences, • It should be about whether the systems are designed to achieve the same population public health outcomes • Trust comes from knowledge, confidence and experience. Starts with countries sharing the same objectives and working together
3. Role of QA Accreditations: • Recognised as meeting an entry level of quality assurance (for common standards) • Helps ensure a degree of consistency • Provides for an auditable platform • Common standard for comparability
4. Type of Accreditations: • Local government assessed / recognised • e.g. Audit bodies / laboratories • Internationally benchmarked / recognised accreditation agencies (e.g. ISO, GFSI) • Foreign government accreditations / recognitions
8. Foreign Government Accreditations • Should be risk-based and outcome focussed • Should focus on the system not just look for differences or inspect for defects • Should be based on an ongoing cooperative relationship • Should take into account other foreign government or private accreditations
9. Certification Systems • System-Based Assurances • Based on documented quality systems • No Certification without Independent Verification • Requires unique “lot” identification and appropriate security and inventory controls • Requires audited controls around product, integrity, authenticity and traceability
10. Role of Official (health) Certificates: • To better manage those risks to human, animal or plant health that can not be managed via normal importer / exporter relationships and due diligence coupled with a level of border verification. • Should on be required if there is a substantial difference in level of protection required (and achieved) by the importing country which necessitates the consignments being produced under substantial additional controls
10. Certificates: • Official Certificates (if justified) should just state that the consignment has conformed with the protocol agreed between the two governments rather than attempting to replicate specific aspects of it.
11. Border Clearance Procedures: WTO/SPS ANNEX C:CONTROL, INSPECTION & APPROVAL PROCEDURES • Members shall ensure, • such procedures are undertaken and completed without undue delay and in no less favourable manner for imported products than for like domestic products; (e) any requirements for control, inspection & approval of individual specimens of a product are limited to what is reasonable & necessary;
12. Role of Border Inspection (food safety) • Ideally should not be necessary • If comparable systems exist between countries • If commercial parties are held accountable for due diligence • Should not try and replicate domestic legislation applied at the processing level
Role of Border Inspection (food safety) • The verify an appropriate level of importer / exporter due diligence • The provide a feedback loop to exporting governments when expectations are not being met • To apply restrictions and sanctions on those parties not cooperating
Border Inspection Procedures: Should • Minimally impede compliant trade • Reward good performers / trusted traders • Be transparent, undertaken in appropriate facilities, with good quality systems • Use accredited laboratories and have a dispute settlement process • Independent sample to reference laboratory
Role of Agreements: • Should deliver a higher level of protection • Should hugely simplify and facilitate trade • Should save resources, allow these to be directed at higher risk areas
Examples of NZ Agreements • CER with Australia (TTMRA) • Sanitary Agreement with EU • Food Safety System recognition Arrangement with US FDA
Key Messages • Independently audited accreditations are a minimum expectation for both government and third party service providers • Comparable / equivalent systems should reduce the need for international audit and border testing. • Credible certification systems require closed secure production and supply systems which assure no chance of product substitution or fraud. • Credible in country food assurance systems can benefit both countries – by allowing scarce resources to be better targeted at higher risk areas and by speeding product clearance
