As the regulator unveils its new strategy to ensure the meat industry remains ship-shape within the legislative framework, Peter Styler and Geoff Ogle were keen to emphasise the need for partnership between the MHS and industry. "We're all in it to produce products that makes the industry successful," says Ogle. "We're not there to catch them out or trip them up."
Elements of the strategy
The new strategy will see plants that are failing to hit all the right notes put into a category entitled "cause for concern". The status of the plants has been assessed from previous audits, says Ogle, with scores allotted against three main issues: hygienic production, environmental hygiene and confidence in food business operators' (FBOs) food safety management systems.
Ogle says the intention is to create a more open and transparent process: "If you're getting a score below a certain level, they will be classed as a cause for concern and letters will be sent informing them of that."
Styler says transparency is key: "We're trying to set things out with clarity, so there can be no arguments. People will know where they stand."
Letters have now gone out to those plants falling into the category and Ogle says the intention is for those plants in the "cause for concern" category to start to work with their official veterinarian (OV) to identify the areas for improvement and begin to work their way towards full approval.
"When they get the letters, the ideal is that they react in a positive way and say, 'What do we need to do to improve?'." Ogle adds that the MHS is keen to work with the FBOs to help them move forward. "If there is no sign of improvement, we move to a more regulatory role and may have to review their approval. But it's still about giving the FBO the opportunity to work with us."
View to improvement
Ogle is also is keen to point out that the new system is not about shutting down poor performing plants. "This isn't about getting plants into a position where they are facing a review of approval then we've failed," he says. "Success is getting them out of being a cause for concern and into being a fully compliant plant."
Styler adds: "The world won't be solved overnight, but what we're doing is putting a stake in the ground. It will be interesting to see the reaction to these letters they might not react positively initially, but hopefully, people will realise we're not doing it to be pedantic and jobs-worthy."
That is the key message the two want to get across. It is no longer all about the big stick. They want industry to work hand-in-hand with the MHS to bring things forward.
Ogle says: "In the past, we've looked at enforcement as the key mechanism to achieve compliance, but our view is that it's just one of the tools. What we want to do is get voluntary compliance, rather than have to use the threat of the stick." Of course the stick is still there, but with the new collaborative approach, the MHS is hoping to wield it less frequently.
Yet it is not all down to the plants themselves; the MHS needs to up its game as well, the two agree. Ogle says that for its staff to simply point out there is a problem is not good enough; they need to give more information and help the operator look at potential solutions. However, FBOs still need to take responsibility, he adds: "We should be giving them options, although we cannot give them the solution, as that would mean the MHS taking too much ownership of the problem."
Simply entering into dialogue with the plants would be an improvement in many cases says Styler, who adds that any move to get business operators and MHS staff around a table to discuss issues is a step forward. That improvement in dialogue could also help the MHS to improve its services, he notes. "We're trying to set up this working-together so that it opens up dialogue at a local level that will help to show whether anything we're doing around the regulation is a bit daft."
However, Ogle says plants need to be in a position to negotiate before making demands on MHS implementation. "We've been to one plant a really poorly performing plant and the business manager has sat there and asked when we are going to give him OV flexibility. They're on the wrong side of approval and they're questioning OV flexibility they've got a million things to get right first."
Quite often, problems in plants can be solved effectively with simple changes in management. Ogle says: "We've seen things like the floor not being clean and, when it's queried, we're told the guy who does it is on holiday. Management needs to set standards and ensure staff deliver. The good FBOs are doing that. A lot of it just comes down to day-to-day management."
Styler agrees and says ensuring your processes are in order is vital: "Sometimes I see it with HACCP they have got it all down on paper, but then it's put on the shelf and left there. We've got to get them to see that the paperwork isn't where it ends."
Being on the frontline of MHS services is certainly not a job for the faint-hearted, and the process of transformation of the service has posed considerable challenges, but both Ogle and Styler are confident that transformation is starting to deliver.
Ogle says: "The evidence is there. MHS staff have fallen by 21% and there has been a cost reduction of £13.4m between 2006-07 and 2008-09. When you take out that level of staffing, you cannot say that's nothing. We have no control over the regulation; what we can do is improve efficiency and that's not a one-sided debate either. Has industry improved its efficiency by 21%?"
Styler says some businesses have invested to help the MHS cut costs: "We've seen examples of FBOs making changes and spending money and that has allowed us to reduce staff and, ultimately, save them money at the same time."
Both accept that the industry has fundamental issues with the legislative framework within which MHS is having to transform. Styler adds: "Would you start from where you are now? A lot of rules are there for a good reason we have to do the best we can to ensure we're applying those in a proportionate manner."
Railing at front-line MHS staff is akin to tilting at windmills, the two point out, adding that co-operation is more likely to yield longer-term, more effective change and help those above when it comes to effecting legislative movement.
Styler says: "The Food Standards Agency board is starting to raise the discussion now about the future of regulation and, over a number of years, people will start to address whether we're inspecting the right bits in the right way. If that happens, we'll deal with it when it comes along."
In the meantime, the MHS will have to continue to do its job, and industry needs to come to terms with that. Ogle says: "The reality is that we're a regulatory body and for our staff not to do their job properly is a dereliction of duty."