HARPS Newsletter – Spring 2021
In addition, we’ve held more interviews with our H-TAG members, to find out why they joined the H-TAG and what they hope to bring to the group. We’ve also caught up with Craig Shadbolt from NSW DPI and Biosecurity to gain insight into the role of the DPI and the interaction with HARPS, and Deon Mahoney, Head of Food Safety at PMA A-NZ, has provided us with an update on the Primary Plant and Processing (PPP) Requirements for Horticulture (Berries, Leafy Vegetables and Melons) by FSANZ.
Ever wondered why the HARPS Standard requires your business to keep retention samples? We’ll be using the HARPS Newsletters to provide answers to the questions we regularly receive via the HARPS Helpline. In this edition, we’ll provide some answers to why retention samples are so important to your business and how you should be retaining them. Well also share an important update about nominating your retail customer during the HARPS audit and the responsibilities of the HARPS auditor to verify this information.
From time to time, One Direction ANZ will receive enquiries, feedback and complaints from industry members relating to inappropriate practices or behaviours. The HARPS Helpline is available to all HARPS participating businesses as a confidential service. If your query relates to your business, your experiences through audit or information that you are aware of that relates to unapproved supply situations, then the HARPS team can investigate and manage these situations in a professional and confidential manner. Please note that the HARPS team (and the Helpline) are not retailers and there is a complaints process available on the HARPS Website.
Feel free to share your thoughts, opinion, or queries with HARPS by clicking here or contacting the HARPS Helpline on 1300 852 219.
Update on HARPS Version 2.0
On 8th October 2021, all businesses that provided feedback as part of the industry consultation of the Draft HARPS Version 2.0 Standard, were contacted to provide an update on the status of the Version 2.0 review.
The HARPS Technical Advisory Group (H-TAG) has been methodically working through the feedback received during the HARPS Version 2.0 public consultation process. Over 60 meetings have been conducted with the H-TAG since the industry consultation process closed in January 2021.
One of the more significant changes the retailers have agreed upon is the removal of the section on Business Culture. The retailers agreed that a robust and well-implemented strategy for food safety culture is critical to the success of the food safety plan, however, these requirements have been well-addressed in the recent updates of the GFSI standards that support HARPS, and therefore this section will be removed from HARPS Version 2.
In addition to this amendment, following the release of updated GFSI standards, multiple changes have been recommended for removal in regard to duplication. Furthermore, the H-TAG has worked to focus on the appropriate placement of responsibilities by business Tier (either Tier 1, Tier 2 or both).
Recommendations have been developed adopting a science-based approach and ensuring elements are pragmatic and efficient (in terms of implementation) for businesses audited to HARPS, whilst still meeting the needs of the HARPS Retailers and their customers.
We envisage finalising the revised Draft Version 2.0 by early 2022 and plan to pilot this draft across different supplier tiers, product categories and geographical locations to ensure the standard is practical and suitable for the scope of businesses being audited to HARPS. The final draft will then be available for review by industry, where feedback can be provided regarding technical aspects within the HARPS Standard, Scheme Rules and Guidance Document.
We will continue to update the HARPS Website FAQ page to provide responses to your questions and feedback. An ‘update date’ has been added to the FAQ page with new FAQs prefaced with ‘[NEW]’ to assist readers to identify and review new FAQs more easily. In addition, we will continue to provide updates via the HARPS Newsletters. If you have not yet subscribed to the Newsletter, we encourage you to do so by clicking on the following link, subscribe to HARPS.
Nominating your Retailer Customers during the HARPS Audit
During the opening meeting of the HARPS audit, your auditor will ask you which retail customers your business supplies to. This is a fairly straight-forward question for Tier 1 businesses that have contractual arrangements in place with their retail customers, however, this is less obvious for Tier 2 suppliers. The HARPS Retailers have identified inaccuracy relating to the nomination of retailers on the HARPS Summary Form. This is the form used by auditors during HARPS audits (see Figure 1 below for an extract of this form).
Figure 1. An Overview of the Audit Proces
Listing retailers that you do not currently supply can lead to confusion and an increased administrative burden between the retailer quality assurance and commercial teams, as suppliers cannot be identified. Please only nominate the retailers that your site is currently supplying.
Market Access
Feedback to HARPS has identified that suppliers are nominating more than the retailers they are currently supplying believing it may open supply opportunities with additional retailers. This is not the case. Whilst obtaining HARPS approval will satisfy the food safety and quality program requirements for all the HARPS Participating Retailers, HARPS approval is not an automatic contract for supply to a nominated retailer. Approval to supply is a commercial agreement between the individual retailer and supplier and nothing to do with your HARPS approval status. If your business is not aware of who the final retail customer is for your produce, simply advise the auditor that this is the case for your business.
Collection of Evidence to demonstrate supply
Auditors are required to look for evidence of supply to a retailer. Examples include:
- Product packed at the time of audit with demonstration of retailer labelling and packaging available on site;
- Evidence of the supplier’s ability to access a retailer database; and/or
- Product specifications for one or more retailers are available.
To enhance accurate data capture we have requested HARPS auditors to review a Purchase Order for each retailer that is current within the previous 12 months of the audit date. If your business intends to supply one or more of the HARPS Retailers, but have no plan in place, nominating the retailer is not permitted.
HARPS Complaints and Whistle-Blower Process
Whistleblowing refers to the act of raising concerns about suspected or actual misconduct within the activities covered by HARPS and is a key element of our governance framework to achieve transparency and accountability. To aid adoption of HARPS and build trust in the scheme more generally, it is important to have a level playing field for all horticultural suppliers to the HARPS Retailers.
From time-to-time, suppliers will contact the HARPS Helpline to advise us of activities that breach the rules for supply to the HARPS Retailers. This is typically related to the sourcing and/or supply of produce to retailers that is not HARPS approved. One Direction ANZ, the managing entity for HARPS, along with all HARPS Retailers, consider these matters to be serious, hence any allegations are investigated and appropriate action taken. Whilst the HARPS Retailers have their own whistle-blower policies, the HARPS Helpline is available to industry as a confidential service. If any claims of this nature are raised, the matter will be investigated and managed ensuring the identity of the claimant remains anonymous. To review the HARPS Complaints Process please click here.
If any grower or supplier still feels uncomfortable approaching either One Direction ANZ or any of the HARPS Retailers, they are encouraged to speak to either their Peak Industry Body or Hort Innovation.
FAQs from the Helpline: Why do I need to Keep Retention Samples?
Retention samples provide evidence of what your business is producing. Retaining samples from your harvest or pack-run allows you as the producer or packer to verify that your product is able to meet attributes that your retail customer is seeking at the end of shelf-life. Not only do retention samples help demonstrate meeting quality requirements, but the sample can also provide evidence to support compliance with chemical, microbiological and physical requirements. This is particularly useful when retailer customers are investigating customer complaints or adverse testing outcomes.
The HARPS Standard requires retention samples to be kept, however, the number of samples and the frequency of collection must be decided by your business. It is important to ensure that the decisions you make around sample collection are representative of your harvest or packing run. Some areas to consider when determining the number of samples to retain and the frequency of collection, include changes in product variety, weather changes that may impact quality and packaging type.
The retention samples you collect should be retained in the same packaging that would be sold to the consumer to ensure the shelf-life is represented, and its important to ensure retained samples are protected against any potential contamination situations including spoilage due to temperature and infestation by pests or other contaminants. Ideally, they should be stored at a temperature that reflects the supply chain conditions (chilled or ambient, or a combination of both) and a rule of thumb is to keep your samples in the same temperature conditions as per the customer specification and keep samples until the end of the products shelf-life.
PPP Requirements for Horticulture (Berries, Leafy Vegetables and Melons)
Deon Mahoney, Head of Food Safety at PMA A-NZ
Following a 2018 request from the Ministerial Forum on Food Regulation, FSANZ (Food Standards Australia New Zealand) commenced an assessment of food safety risk management for selected horticulture sectors. This involved the development of a proposal (P1052) to address the issue, an initial call for submissions, a comprehensive risk assessment, the identification of risk management options and the regulation impact statement.
On 17th November 2021, FSANZ released their second call for submissions on the proposed food safety measures for primary production and processing of melons, berries, and leafy vegetables. FSANZ outlined four options, including, 1. Status quo; 2. Regulation; 3. Combined regulatory and non-regulatory measures; and 4. Non-regulatory measures alone.
The preferred approach is Option 3, which seeks to strengthen food safety management by introducing nationally consistent food safety standards for each sector, and to produce guidance materials to assist businesses implement the standards.
FSANZ now invites comments on all four options including the preferred approach by 9th February 2022 to inform its decision. Full details are available on the FSANZ website.
Update from the NSW DPI Biosecurity and Food Safety
Craig Shadbolt, Principal Food Safety Scientist
What is the role of NSW DPI Biosecurity & Food Safety?
The NSW Department of Primary Industries has a long history of managing plant and animal disease incursions and dealing with invasive pests. The Biosecurity Act 2015 overhauled legislation in NSW, so that everyone has a general biosecurity duty to help manage risks to native flora and fauna along with our farming sector.
The NSW Food Authority sits within the NSW DPI Biosecurity & Food Safety branch and is the only through-chain food safety regulatory agency in Australia. This provides a unique perspective and access to stakeholders and expertise in food safety.
In more recent years, the NSW Food Authority has been firmly integrated within the NSW DPI biosecurity operations framework. This has provided many benefits in being able to develop complementary biosecurity and food safety outcomes across industry sectors.
What is your specific role within NSW DPI?
In my first 15 years with the NSW Food Authority, I managed a food incident team, which was an excellent way to see what can go wrong at various parts of the supply chain! Over that time, it has been fascinating to see the different factors that combine to cause an outbreak, and the advances in technology to track and trace foodborne pathogens to a source. More recently, the impacts of severe weather events (fire, floods, drought) and access to water supplies underscore the challenges we face in growing and providing safe food.
In my current role as Principal Food Safety Scientist, I’m involved in planning and various projects to mitigate food safety risks across different food commodities, and our systems for responding to foodborne disease outbreaks. This includes representing NSW on the planning associated with the current Food Standards Australia New Zealand (FSANZ) proposal for strengthening food safety in horticulture (P1052).
Interaction with HARPS, thoughts on the program?
I’ve had some involvement with the HARPS team and retailers, particularly in providing perspective or information on recent salmonellosis and listeriosis outbreaks from a regulatory standpoint. The HARPS initiative, in my view, is a great way to standardise best practice and provide a focal point for continuous improvement in food safety.
Going forward, especially as the FSANZ proposal P1052 progresses, it would be beneficial for more structured engagement between HARPS and food safety regulators to ensure that any perceived deficiencies (including compliance breaches linked to a future food safety standard) are addressed and link in with industry training programs. This includes addressing food safety culture, which is increasingly recognised as essential for business.
What worries you about the hort industry in Australia?
While Australia has a well-deserved reputation for producing safe and wholesome food, this can also lead to complacency, and a sense that “a food safety issue will never happen to me”. There is a lot of work that needs to go into improving the food safety culture of the horticulture industry to address this. Thankfully this need is recognised by several groups, and I’m optimistic food safety culture can be improved.
Strengthening Traceability and Authentication – Laava Smart Fingerprints©
Traceability and authentication are increasingly important to consumers and suppliers. The ability to track fresh produce through supply chains, from paddock to plate, is often linked to consumers’ desire to verify the claims on the label. That’s why HARPS partnered with innovative Australian technology company Laava to protect the integrity of our certificates.
Laava Smart Fingerprints® are the upgrade from the QR code: they’re completely secure and can’t be hacked. The global horticulture industry has been looking for an anti-counterfeit solution that can be integrated into existing packaging and supply chain systems. Laava’s solution does that and offers a consumer engagement platform helping brands connect with their audience.
Fast becoming the global mark of trust, Laava is helping avocado growers in NZ demonstrate the journey of their produce – from tree to toast. J3 Freshstore can trace each box of avocados that feature a Fingerprint, collecting data at different points along the supply chain. J3’s strong call to action ‘scan to win a year’s supply’ has seen a 10% scan rate.
Reid Fruits has also benefited from featuring Fingerprints on its premium Tasmanian cherries exported into Asia, with counterfeit attempts foiled in China. Returning to Laava for a third season, Reid has added Fingerprints to ‘approved supplier’ certificates. Reid will also enjoy new features in Laava’s analytics platform, such as a hotspot map showing where in the world Fingerprints are being scanned.
To learn more about how Laava is working with HARPS and other partners to strengthen traceability in horticulture, visit Laava.id
Spotlight on H-TAG Members
Marie-Astrid Ottenhof
Belinda Wilson-Chartres
The H-TAG is a group of industry representatives that are integral to the ongoing development of HARPS. The H-TAG is responsible for guiding and contributing towards improving the operational effectiveness of HARPS, including the HARPS Standard (particularly Version 2) and associated technical documents, such as the Interpretive Guidance Document and Scheme Rules.
The H-TAG provides a voice for industry and help develop recommendations to the retailers regarding improvements to HARPS. Throughout the next editions of the HARPS Newsletter, we’ll provide you with the opportunity to get to know who your H-TAG representatives are and why they chose to be a part of this valuable group.
Belinda, you wear multiple hats in your role as a service provider to the Horticultural Industry, can you tell us a little bit about your role at Fresh Business Directions and how your business provides services for HARPS?
HARPS is part of all that we do across our businesses that services the fresh produce and supporting industries. Fresh Business Directions is a food safety, quality assurance and business management consultancy operating with state, national and international clients across the horticulture industry. For the last 17 years we have supported many businesses in food safety and quality assurance program development (including base programs and HARPS) and management. Fresh Business Training is a Registered Training Organisation (RTO) offering nationally accredited, industry specific food safety and quality management training nationally. Since 2016 we have offered horticulture specific HACCP training that meets HARPS and retailer requirements and Food Safety and Quality Management Programs training for Fresh Produce.
Further to this I have audited and conducted Technical Reviews for nearly 20 years for base standards and for the HARPS standard since inception for certification bodies both domestically and internationally.
Astrid, can you take us through your role at Schreurs & Sons, how you interact with your grower network and the role your business plays with HARPS?
Schreurs & Sons is a grower of predominantly celery, leeks and baby leaf. As the head of their Technical Department, I am responsible for ensuring that the company has the systems and processes in place to ensure all products sent out meet legislative and customer requirements. This includes the Food Safety and Quality standards that we are required to comply with, namely Global GAP and HARPS for the farm and the SQF Food Safety Code for Manufacturing in our processing facility. Aside from supplying the domestic market, we also export to Southeast Asia and the Middle East.
Since joining the H-TAG back in 2017, I have always shared with other growers and industry members in my network that I am a member. Therefore, should they wish to provide any feedback in relation to HARPS through myself, they can do so. To date, this has been quite an effective way to receive feedback on HARPS from other growers.
We are a Tier 1 grower and bring a unique perspective to the H-TAG in that we are certified to GLOBALG.A.P. on farm. We transitioned back in 2015 from Freshcare (before they became GFSI benchmarked) in order to meet some of our export customer requirements.
How and why did you make the decision to apply as a H-TAG member?
Astrid: I am very passionate about food safety, not only ensuring that this is achieved at Schreurs & Sons but by the industry as a whole. As past food safety outbreaks in our industry have shown, both within Australia as well as overseas, they impact the entire industry and can severely damage consumer confidence and have potentially detrimental outcomes. Being an H-TAG member allows us to have a voice in guiding the standard, trying to ensure that elements are included that are practical to implement by growers and are evaluated according to their risk. It’s also beneficial to bring direct on-farm experience to the role, as well as previous experience from roles at a company processing produce for different end uses, including ready-to-eat salads.
Belinda: I wanted to be part of the H-TAG to be an advocate for those in the industry I represent and to give back to the industry that has given me so much. I am extremely passionate about the fresh produce industry. Having worked for almost twenty years in the Horticulture industry in positions in operations, food safety and quality and marketing and working as a consultant, trainer, auditor and technical reviewer has provided a detailed insight into all areas of the fresh produce industry.
Across my current business platforms, I interact with many stakeholders in the fresh produce industry. Through our training business I am constantly gaining industry feedback to determine current trends and issues facing the industry to ensure our training materials are current and of value to participants.
In addition to this I have been involved in a variety of advisory groups, committees and boards for Government, Council, Community organisations and not-for-profits. My varied experience over many years in the industry underpinned by tertiary studies in business, quality assurance, food technology and further studies in microbiology and nutrition has put me in a unique position to contribute to the H-TAG representing many different stakeholders in the program.
Can you tell us about your experiences on the H-TAG so far?
Astrid: There is a very diverse group of people on the H-TAG. They represent a broad section of the industry and bring important and relevant experiences from throughout their careers. Each member has made important contributions to the group and provide different perspectives and insights into issues raised. Members are respectful of each other’s opinions, even if they may differ to their own. I think we are all learning a lot from each other, which has been great.
One of the current biggest challenges faced by the H-TAG is the review of the draft Version 2.0 of the HARPS Standard. There has been a lot of feedback received from industry, which has been invaluable, and this is currently under review and changes to the standard proposed, where deemed necessary. As the HARPS Standard is used as a bolt-on to several GFSI benchmarked global standards, which are constantly being updated themselves, reviewing HARPS against all of these also adds a further level of complexity. Whilst we are making good progress with the review of the standard, it is taking time to ensure that all items are reviewed in detail.
Belinda: The H-TAG is a varied group of industry experts that represent the horticultural sector. The members volunteer their time to ensure that the HARPS Standard is focused on ensuring food safety and quality management (in addition to the base standard requirements) in line with retailer requirements, whilst still being practical for the myriad of businesses that manage the program.
The group has been meeting weekly for the majority of this year, which is a huge commitment! In addition to this many group members also participate in subcommittees and spend additional time gathering essential feedback from those they represent.
I think that it is important that everyone involved in the HARPS program understands how much work has gone into this next version. The group has a great dynamic with members really willing to listen to opposing viewpoints. We have always found a way to agree on outcomes to date (after robust debates). It has been great to work with like-minded people that show a real commitment to ensuring the industry standard is representative of the growers, suppliers and stakeholders needs.
Finally, what do you think are some of the broader challenges we face as an industry as far as food safety is concerned?
Astrid: One of the many challenges faced by the industry is that some growers are finding that achieving compliance to all the required standards is becoming quite onerous. This is concerning because it could lead to businesses taking shortcuts, which could potentially have unintended and detrimental consequences. Finding the right balance between implementing essential checks and balances to ensure food safety outcomes are achieved, whilst ensuring they are practical to implement, will remain an on-going challenge.
Another critical challenge is for businesses to ensure that food safety is the responsibility of everyone within the business and not just the department assigned responsibility for food safety. All staff must have the correct food safety mindset and behave accordingly, not just when senior staff members are present, but also in their absence. This is key to ensuring food safety is maintained at all times. This has been recognised by the new version of the GFSI benchmarking requirements, capturing food safety culture as part of the revised GFSI benchmarked standards and it will be interesting to see how this is adopted by industry.
Belinda: Food Safety Culture is a challenge within the industry now and in the future. There are a number of contributing factors that have led to this including transient staff with a high turnover resulting from many issues including the impact from COVID. It is increasingly difficult for businesses to build a strong food safety culture within their business (which requires ongoing training, communication and resourcing).
In addition to this, there are many competing pressures affecting growers including fires, floods, droughts etc., which may affect growers’ ability to meet standard requirements. We all need to continue to work together as an industry to address these challenges.
Final thoughts…
In our Winter Newsletter we provided you with a link to an article by Deon Mahoney, Head of Food Safety at PMA A-NZ. Deon has kindly provided us with another great read. Click here to read Deon’s take on Culture and its ‘Impact on Food Businesses’.
