The first unannounced inspections of Red Tractor farms have taken place, prompting a number of concerns from producers. Here Red Tractor addresses some of the key questions raised
The first unannounced Red Tractor spot checks took place in February and, while the principle is generally accepted, the new policy has raised a number of concerns. The spot checks are part of a new risk-based approach to farm assurance rolled out in the pig sector last November.
When the changes were discussed by the NPA Producer Group in March, producers highlighted a number of issues. These included a lack of transparency over the risk ratings, a lack of tolerance for chance events, questions over the weighting given to minor non-conformances, inconsistent messages from assessors and perceived bias against large farms.
Pig World asked Red Tractor to address some of the common concerns.
How has Red Tractor decided on the weightings of each standard?
Each standard is weighted according to how critical it is to the performance and reputation of Red Tractor’s members and the scheme as a whole. The process involved all sector chairmen. The team looked at each standard and considered, if it was breached, how much of a reputational risk it would pose and how Red Tractor would be able to defend it.
For example, tending to sick or injured livestock promptly and handling animals in a way that minimises stress would be considered high risk, whereas not having a farm map or a complaints record would be considered lower risk. All standards have to be complied with, but standards have to be weighted for the risk-based approach to work.
Do ‘key’ standards and ‘major’ non- conformances carry more weighting in the risk-based calculation than ‘minor’ non-conformances?
No, they don’t because the risk-based calculation is determined by the nature and number of non-conformances found at routine audits. Existing ‘key’ standards and ‘major’ and ‘minor’ non-conformances retain their existing purpose and function, but play no part in the risk assessment and do not automatically have more weight than minor conformances.
Why is Red Tractor not publishing the methodology and weightings of individual standards?
The methodology is an internal process carried out by Red Tractor. Serious consideration was given as to whether the methodology and standard weightings should be published in the interests of transparency. However, Red Tractor’s Standards Committee agreed that the merits of not publishing outweighed those for transparency for several reasons. The main one was the importance of maintaining the independence of assessors – they do not know how the standards are weighted, and so remain completely impartial.
Is there enough tolerance in the system?
Some standards have a degree of tolerance already built in, such as slot and slat widths, but as part of the normal standards review process, Red Tractor will consider whether tolerance should and could be built into other standards to ensure pragmatism is applied consistently to the standards during the inspection.
Why does the new approach not allow me to close simple non- conformances on the day, or within 28 days, to potentially reduce my risk rating?
The purpose of the risk-based approach is to encourage producers to comply with every standard, every day. Red Tractor’s objective is for farms to not have non-compliances at the time of the audit, not to wait for the audit to raise non-compliances which then need to be corrected.
Has Red Tractor considered assessor inconsistency and is the system biased against large farms?
With the rollout of the risk-based approach, we recognise it is now even more important that inspections are consistent and fair to all members, regardless of the scale of the farming operation. Red Tractor has been asked to consider whether the risk-based approach is unintentionally biased against larger farms We will shortly be commissioning some analysis in this area to ensure that the risk-based approach is applied consistently, regardless of farm size.
Could missing paperwork now be viewed as more significant than the condition of my pigs?
Generally, the higher risk weighted standards are the more practical ones, but paperwork is important and all standards must be complied with. The recording of antibiotic use in the eMB is a vital standard which makes the Red Tractor scheme world-leading and the only way to demonstrate compliance is by presenting eMB records (either physically or on a screenshot). Another important piece of paperwork is up-to-date records of staff deemed competent to carry out husbandry tasks such as tail docking.
Can assessors tell farmers at routine audits whether they are going to be classified as high risk
Assessors do not know how the standards are weighted or how a farm’s risk rating is calculated so are not in a position to be able to advise farmers of their risk rating. The farmer will be informed if they fall into the high risk category once the Red Tractor system has received details of the visit. Neither the assessor nor the farm’s advisers – such as vets – will be consulted to decide the outcome of the risk rating. Receiving an unannounced inspection does not mean it’s a bad farm – it just means certain improvements need to be made to improve overall compliance.
How can you expect me to be there if you turn up unannounced?
We recognise there are some impracticalities around unannounced inspections. Farms due to receive an unannounced audit will be asked to complete a questionnaire and return it to their certification body within 28 days of receipt to ensure the inspector has all the information required to reduce the risk of disruption or no-one being available.
This will include details of pig-free requirements, when routine activities on the farm occur – such as serving, weaning and routine vet visits – and when it is likely to be de-stocked, if applicable. In addition, emergency contact details for at least three people who can be contacted will need to be provided.
Emergency contacts should include individuals who may know the whereabouts of the farm manager/owner and/or are able to accompany the assessor at the audit. Members will need to notify the certification body if anything subsequently changes.
Assessors will wait up to an hour for someone to arrive or get in contact and be able to start the audit. Producers need to be aware that if an unannounced audit cannot be carried out, it is classed as failed and the cost will be charged to the producer.
What form does an unannounced audit take?
Each unannounced inspection will take the form of a focused spot check, so is shorter than a routine announced audit. If non-conformances are identified, they will be reported back to Red Tractor in the normal way and the member will be categorised in the same way as at the routine audit. The focused spot check could include an assessment of any one of the standards, including paperwork standards, so we encourage all producers to have their paperwork up-to-date at all times.
What can I do to avoid being categorised as high risk and receive unannounced inspections?
Farms upholding all the Red Tractor standards every day will notice no change to their Red Tractor inspection regime. The best way to avoid receiving an unannounced audit is to ensure you are compliant with all standards at your next routine inspection. Overall, this risk-based approach will ensure that the reputation of our members who are conforming to all our standards is maintained.
What is the appeals process, so I can dispute my risk score?
Appeals against non-conformances found during routine inspections (if the member does not agree that it was a non- conformance) will still be dealt with by the farm’s chosen certification body. If a producer wishes to appeal against their risk rating, this should be done directly to Red Tractor. The Red Tractor appeals procedure can be found HERE.
How the new Red Tractor inspection regime works
- All standards have been weighted according to risk, so each member’s risk rating can be categorised following inspections;
- Where there are no non-conformances, or a few low-impact ones, there will be no change to the inspection regime;
- Depending on the nature and number of non-conformances, farms falling into the ‘medium risk’ category might be subject to shorter notice inspections, while ‘higher risk’ farms will be subject to an unannounced spot check;
- If no improvement has been made, membership will be suspended. To be reinstated, a suspended member must successfully correct all non- conformances; and
- If there is no improvement after a further unannounced inspection, membership will be withdrawn.