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Audit overload: Ideas for saving time while maintaining high standards

We all want high standards when it comes to fresh produce. It’s something that sets British apples and pears apart from the rest of the world. Audits are an important way to ensure there is independent endorsement of the high standards and ethical practices apple and pear growers follow.

However, there is a serious risk that the top fruit industry is facing audit overload and duplication. The audit burden is doing nothing to maintain standards, but everything to waste time and money.

Here’s an insight into the audit situation for apple and pear growers, together with some ideas for a more efficient, but equally effective, way forward.

 
What audits apply to apple and pear growers?

The exact details of the audits each grower undertakes varies by farmer and the requirements of their supermarket customers, but the following are very typical:

Red Tractor checks every element of work on the farm from planting to harvest and storage. It will also cover pesticide storage and equipment, the tidiness of farm and the quality of accommodation. It requires documentation about water and energy use and even specifies the number of toilets for staff. Typically, the Red Tractor audit preparation takes five days and the audit itself one day. However, the audit will take longer if there are multiple sites or farms. The documentation often runs to hundreds of pages and there is significant overlap with the BRC audit (see below) when it comes to packhouses and cold stores.

LEAF focuses on sustainable farming and has more than 70 control points that growers need to undertake, document and evidence. LEAF covers many of the same areas as the Red Tractor scheme, including soil management, energy efficiency and water management. The audit for LEAF accreditation usually takes around eight hours to prepare and the audit itself is added onto the Red Tractor audit. In terms of evidence, LEAF requires just as much evidence as the Red Tractor audit but with a greater emphasis on the environment, carbon footprints and waste.

The British Retail Consortium (BRC) audit for food safety, as the name suggests, is about food safety. It covers policies, training, identification of potential hazards, completing records and internal audits, as well as traceability, complaint handling and product packaging, inspection and testing. These audits are usually unannounced, so preparation is ongoing. There are also peaks of activity reviewing documentation when BRC standards are changed – which typically happens every four years. During an audit, the BRC team usually spends two or three days on the farm and the related paperwork for the grower runs to 100s of pages.

SMETA (Sedex Members Ethical Trade Audit) is a check on ethical operations. It covers labour standards as well as health and safety. This audit is typically required every three years and it takes one day, with significant preparation required by the grower.

GRASP audits focus on worker health, safety, and welfare. This annual audit covers social practices such as labour rights and worker protection. These audits take around three hours and require dozens of pages of documentation. The main issue concerning GRASP audits is that they are conducted at peak labour usage time. That means having auditors on the farm during the very busy harvest. GRASP audits are an annual alternative to the three-year SMETA requirement.

The ETI (Ethical Trading Initiative) is about providing evidence (it’s not strictly an audit) of a commitment to ethical trade. This is a continuous commitment which is completed using the Sedex Self-Assessment Questionnaire (SAQ). The questionnaire takes more than a day to complete and is getting increasingly onerous for growers, with lots of crossover with other audits.  Most supermarkets want Sedex SAQs undertaken annually or even twice a year. 

There are also Home Office (often unannounced) visits to check policies, HR files and records, as well as staff training in relation to visiting seasonal workers. These visits can take one or several days depending on the number of seasonal staff employed by the business.

Labour provider audits. All farms must use a licensed permit operator agency to fill vacant seasonal worker jobs. They operate a bit like recruitment agencies. These providers also come on to farms to check the conditions of employment and accommodation for seasonal workers. These checks usually take one or a number of days for each labour provider. There are also lots of documents that must be submitted before the audit takes place. These are required under the government seasonal worker visa scheme. Most larger farms use a number of different labour providers which means several audits covering the same things.

Grower audit of labour providers. Just as the labour providers audit the farms, our growers have a responsibility to audit their labour providers to check that workers have been recruited properly, that there are no poor recruitment practices, and that the recruitment process meets the guidelines of the seasonal workers visa scheme.

Customer unannounced audits. Supermarkets don’t just rely on the results of all the above audits, they often conduct their own audits too. These tend to be unannounced. They typically take ten hours and involve three people from the packhouse and farm. Each apple and pear grower might work with three or more supermarkets and each one sends in their own audit team for similar audits.  The audits can be annual or every three years, depending on the supermarket concerned and the previous audit scores for the farm. Much of the content of the supermarket audits is the same as the BRC audit.

Beyond the above, there are also farm specific audits, such as the Soil Association Organics audit for our organic farmers. Packhouses who pack organic products also have an annual inspection, during which all documents that are covered during the BRC audit are inspected again. Marketing desks also conduct grower due diligence to make sure growers have all been audited correctly, all of which is already available on Sedex.

In short, there are a lot of audits, and a lot of duplication in those audits.

One of the reasons there are so many overlapping audits is the slightly different audit requirements set by supermarkets. There is no coordination to ensure that audit requirements are standard across retailers.

Not only is there duplication across audits, most audits are also undertaken every year, asking the same questions – and getting the same answers – again and again. A school that receives a good or outstanding OFSTED inspection will be inspected every 4 years or so, a school that requires improvement will be inspected every 2.5 years. That’s not the situation for top fruit growers. Even if they have been consistently meeting all the audit requirements, there is no flexibility, and they will still be fully audited every year.

 
Here’s what our growers say about the audit burden:

Tom Hulme, director, AC Hulme & Sons:

“We want audits because we want to be able to demonstrate that we are operating at the highest possible standards. The issue is that there is so much duplication. Of the nine audits we are subject to, four cover our packing activities, all nine review our policies and procedures and five cover almost exactly the same elements of worker safety.”

Ross Goatham, managing director, A C Goatham & Son:

“Just five years ago, one person managed all our auditing preparation. Now we have to employ three people full time and we also need part time assistance from upwards of 12 more people from various areas of the business across the course of the year. The total hours spent managing audits now exceeds 7,500 annually. With profit margins so tight, the audit burden is really costing us.”

James Simpson, managing director, Adrian Scripps Ltd

“There is so much audit duplication. If the supermarkets could take more of a joined-up approach and agree one suite of audits that would save a lot of time and money.”

 
The NFU’s view of fresh produce audits:

BAPL is not the only organisation raising the issue of the audit burden, Martin Emmett, chair of the NFU Horticulture and Potatoes Board said, “We need audits to become more consolidated.  Our members are increasingly concerned about the proliferation of assurance schemes required by their customers. Duplication is creating significant cost and resource challenges for growers yet delivers no added value.

“In particular, there needs to be significantly more effort to reduce the burden on growers who have clearly demonstrated that they run operations that meet the high standards required of them.

“Finally, we want to see a willingness from assurance schemes to avoid building in standards which are covered elsewhere in the market.”

 
BAPL recommendations

To help our growers focus on the important job of growing delicious safe fruit and, at the same time, ensure that high standards are maintained, BAPL is recommending that supermarkets agree one suite of audits for all apple and pear growers.

We are also asking assurance schemes to adopt an OFSTED-style approach to audit timing, so that consistent high performers are recognised as requiring a lighter touch.

We want to be audited, but we don’t want to waste time repeating the same audits in slightly different formats. We believe that with some simple coordination and recognition of repeatedly demonstrated high standards we can reduce the red tape audit burden on growers without any compromise on safety and quality.

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BAPL responds to BRC comments on BBC Countryfile

On Sunday 24 September 2023, BBC Countryfile broadcast a segment on the dire state of the British apple industry.

Two British apple growers shared their personal experiences of the challenges they face and how low supermarket returns are causing them to make a loss and remove some orchards.

Andrew Opie, director of food and sustainability at the British Retail Consortium, spoke to Countryfile on behalf of the supermarkets. However, his comments have been criticised by members of British Apples & Pears Limited (BAPL).

“Andrew Opie said that supermarkets were keeping prices low and implied that’s why they couldn’t pay growers a fair return. That’s simply not true.” Said Ali Capper, executive chair of BAPL. “Shoppers are already paying more – 17% more for British apples in UK supermarkets. It appears retailers have increased the prices of apples and pears to cover their increased costs, but not the increased costs of their suppliers. Someone is making a profit, but it’s not growers.”

New data released by BAPL, exposes the dramatic shift in the fortunes of British apple and pear growers. BAPL has analysed the published business results of a number of growers that together represent over 70% of the British apple and pear industry. This analysis shows a dramatic drop in profitability.

Across six major growers the average level of profits has declined by 133%. This means that each of these representative businesses has suffered a very significant reduction in profit with many incurring substantial losses. This was inevitable because while the price of apples to the consumer has increased, input cost inflation to growers ran at around 23% while supermarkets paid growers, on average, only 0.8% more than the previous year.

BAPL growers were also surprised by Opie’s remarks that supermarkets are fully supportive of British fresh produce.

“Talk is cheap.” Said Ali Capper. “For the BRC to claim that retailers are ‘100% invested in our British supply chain’ is disingenuous at best. The numbers do not lie. Apple growers are not receiving a fair return from supermarkets. This is putting the future of British apple growing at risk. It’s a situation that must change and change quickly.

“If retailers really were ‘doing their best to ensure a sustainable future’ as Andrew Opie claims, we would not see farmers pulling out of apple growing and reducing the numbers of new trees they’re planning on planting.”

BAPL was also surprised to hear Andrew Opie ask the government for additional support for the industry. “Shoppers are already paying more for their fresh produce.” Explained Ali Capper. “We don’t want them to have to pay higher taxes to support the industry as well. We want profit-led investment by growers, but that requires a fair return from supermarkets.”

Below: Listen to Ali Capper’s response to Andrew Opie on behalf of British Apples & Pears Limited

Notes: 

Data points above based on 2022 crop. The 2023 crop is currently being picked and supermarkets are still negotiating prices.

Profit data above from an analysis of published company accounts for six large growers comparing financial years ending 2021 with financial years ending 2022.

Sources for other data points from ONS, NFU and BAPL sources available in the following published BAPL paper: BAPL submission to EFRA Committee – Fairness in the Supply Chain


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