Alex Kent charts the launch and development of the SALSA (Safe and Local Supplier Assurance) scheme, which helps SMEs to demonstrate, and continuously improve, their food safety compliance.
The domestic food industry has evolved from a number of medium to large producers to a plethora of small operators, quaintly referred to as SMEs. Small businesses are defined as having up to 49 employees, medium businesses as up to 249[1]. There were 17, 375 SMEs in 2016 – some 98.8% of the total number of food manufacturing businesses. Of the £28.2 billion revenue produced by the food industry, around £13.1 billion can be attributed to SMEs and they account for 41.5% of the 400,000-strong work force in the sector. By any measure, they make a very significant contribution to food production.
How then, without jumping through the hoops of the BRC Global Standard for Food Safety or some other GFSi equivalent, do these small producers achieve listing with major retailers?
The SALSA scheme
In 2007, I was involved in the launch of a new scheme by which small producers could demonstrate food safety compliance. The scheme was called Safe and Local Supplier Assurance, or by its acronym SALSA [which has led to endless music hall jokes about Hispanic dancing]. I liked the idea of helping companies to achieve a level of confidence in their processes and procedures. Some ten years on, having completed thirty or so audits a year, I feel sufficiently qualified as a foot soldier to write this review.
SALSA HQ operates from Banbury, but its not for profit status requires a governance involving the main stakeholders [the National Farmers Union, the Food & Drink Federation, The British Hospitality Association and The British Retail Consortium] and is chaired by IFST’s Chief Executive, Jon Poole. Support is via the Technical Advisory Committee which represents the main users of the scheme [retailers, food service companies, sector bodies – such as Cask Marque and the Specialist Cheesemakers Association, IFST and some of the operating staff, including representatives of the auditors]. This body forensically examines, develops and enhances standards and procedures and is currently led by Jane Duddle of Waitrose.
From a pilot scheme in the Highlands and Islands, involving a handful of cheese and pickle makers, SALSA now has 1480 members [as of 09/2017], of which 1238 are approved. An excellent exposition of the development of the scheme has been produced by Richard Bradford Knox [an auditor/ mentor] and Kevin Kane [University of Salford][2].
The SALSA retention rate is remarkably high; currently, some 93% of the suppliers have remained with the scheme since inception. Growth rate, even in Year 11, is forecast at 11%. Where suppliers have not renewed membership, the most likely reason is that the business has closed down [29% respondents], followed by the business electing to become BRC certified [25%][3].
Figure 1 illustrates how the different food manufacturing sectors are represented. Bakery and dairy suppliers are most common, but the additional value available in two specialist sectors, cheese and brewing [the so-called SALSA + standards] is appreciated by cheese makers and brewers alike. SEAFISH has also recognised that it is the standard of choice for many fish processors. In addition, SALSA is given leave to conduct audits on behalf of STS, the audit body for the public sector [in particular, the NHS], and can now perform a dual audit with the Soil Association.
Recognition by the major players, from the large retailers to food service wholesalers and providers, continues to increase. There are 940 registered buyers[3]– a testament to the robustness of the scheme – who, at no cost, have access to the SALSA directory of suppliers. A list of supporters is available on the SALSA website. Even as a large manufacturer with BRC or equivalent, discovering that your small supplier of niche ingredients has SALSA accreditation should be of some comfort to you.
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| Figure 1: Breakdown of audits by sector |
The SALSA retention rate is remarkably high; currently, some 93% of the suppliers have remained with the scheme since inception.’
Auditors and mentors
Auditors and mentors are generally self-employed, but are scrutinised both prior to engagement and annually by IFST, not only for sector skills and experience, but for their maintenance of CPD [minimum of 35 hours] and an audit log. If IFST is satisfied, they are registered on the Register of Professional Auditors and Mentors[4], and The Register of Food Safety Professionals.
There are currently 67 auditor/ mentors, with only four of these electing to act only as mentors[3]. They are geographically well distributed, as SALSA helps contain the costs to the supplier by generally allocating audits to local auditors, who do not claim travelling expenses.
Great care is taken that the auditor/mentor cohort is well calibrated to ensure that they deliver consistent judgements. There are mandatory annual training sessions, quarterly alignment exercises using brief case studies, face to face interviews and witnessed audits. In addition, each auditor/mentor is given an annual report, where his/ her personal alignment with the scheme is highlighted [e.g numbers and types of non-compliances issued in comparison with scheme averages], as well as feedback from suppliers, who are encouraged to rate their experience of the auditor and of the audit process.
The SALSA Standard
The Standard is broken down into four sections:
1. Pre-requisite Controls –covering everything from Training, Personal Hygiene, Pest Control, through to Shelf life determination [14 subsections, 52 clauses].
2. HACCP & Management Systems- Internal review, Traceability, Complaints – apart from HACCP [6 subsections, 17 clauses]
3. Documentation – document control, specifications, procedures [3 subsections, 3 clauses]
4. Premises [7 subsections, 7 clauses]
As part of each of these, there is an overarching statement of intent, which the supplier must also satisfy.
The SALSA + Standards for beer and cheese, and the STS clauses add further requirements, but the suppliers who subscribe to these standards are both aware and generally prepared for them. The Standards are freely available on the publicly accessible pages of the SALSA website.
The audit
On the day of the audit, the auditor will issue two types of non-compliances:
• Not compliant, or partially compliant for action
• Partially compliant for improvement.
The first group requires the supplier to address these noncompliance issues within 28 days by sending evidence of corrective action, agreed with the auditor, to SALSA for review. These can range from lack of data [for example, on equipment calibration] to a poorly defined recall procedure or an incomplete traceability study.
The second group provides the most fertile grounds for discussion and most of these non-compliance issues relate to best practice. The action required to address these issues is more sustained and longer term – for example, reviews of specifications or establishing refresher training. It is this second group that suppliers view as useful, since it is a way of demonstrating continuous improvement.
Unlike the BRC Global Standard, non-compliances are not graded. In a typical audit, five items require action and four require improvement[3].
Ultimately, the auditor has to make the judgement as to whether the supplier can be recommended for approval, with or without the submission of an action plan, subject to review by HQ. The alternative – not recommended for approval - does not represent abject failure or an unproductive audit, as the auditor will continue with a ‘preaudit’, completing a gap analysis for the business. This offers similar advice to a successful audit and means that the business should stand a better chance of success at the subsequent re-arranged audit. The failure rate currently stands at 3.1%[3].
In my experience, the ultimate question is not necessarily gauged by the numbers or nature of non-compliances, but whether I would be happy to consume product manufactured at the site [and consequently underwrite it for all consumers]. Naturally, auditors are cognisant of enforcement activity and would not sign off a business that had not corrected issues raised by previous enforcement body visits.
Unlike the BRC Global Standard, non-compliances are not graded. In a typical audit, five items require action and four require improvement.’
The top ten problem areas
SALSA collates the data relating to non-compliances for all audits (Table 1).
The top ten issues have been remarkably similar throughout the scheme’s history. It is not easy to identify single causes of failure in any given clause as each requirement has embedded in it several elements. For example – the clause covering Glass and Brittle 1.4.4 – which states ‘Where there isa risk to product and/or packaging,a written procedure for dealingwith breakages, along with a list ofrelevant glass and brittle items tobe checked shall be provided’, This expands to the following elements:
1. The company would be expected to have a glass/brittle breakage procedure, [even more so if the company packs into glass], together with a record of any incidents [or blank record if no such incident has occurred].
2. A dedicated glass breakage kit would be expected, with instructions to dispose of the kit after the clean-up.
3. The company would also be expected to have a register of items and a set of recorded checks of the register, completed at a regular frequency, with due regard to the proximity of the glass/brittle to open product zones.
4. In the latter case, it is likely that a daily check on such items would be necessary, for example, on an opening/closing check list.
5. Maintaining and checking the register is also a set of procedures that warrants training.
6. There should be specific instructions for light fitting cleaning and changing. SALSA has not ignored the fact that companies need help and guidance, not only to understand the thrust of the requirement, but to give practical hints on how to achieve best practice and how to demonstrate that the requirements have been met.
These are available as generic guidance notes, and in the form of ‘Tools and Tips’, which are extended guidance notes and, in many cases, offer document and procedure templates. There are 56 guidance notes available, and because Traceability is the Number 1 Problem Area, SALSA has made this particular Tool & Tip freely available to any interested party – not just to paid up suppliers.
As additional support to suppliers, SALSA also offers Level 1 and Level 2 HACCP Training courses, Labelling workshops, mentoring services [either as part of a package, or recommendation of SALSA mentors local to the supplier], and a telephone help line.
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| Table 1 Top ten noncompliances 2016 (Standard issue 4/ Beer issue 1) |
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| Figure 2: SALSA Tools and Tips |
Continuous improvement
Historical SALSA data for each supplier cannot be mined easily to demonstrate that the number of non-compliances or suggestions for improvement have decreased on second and subsequent audits, but there is sufficient anecdotal evidence from auditor/mentors to give strong voice to this sentiment.
Continuous improvement is very much a feature of the scheme and the auditors will find ways in which the supplier can improve on each audit. Equally, as auditors are rotated after three consecutive audits, the alternative auditor may discover new and different findings.
As a supplier progresses with the SALSA scheme, it comes to view the SALSA auditor as a critical friend, rather than a box-ticking official determined to obstruct day to day operations by overloading a small organisation with yet more paperwork and procedures.
Future developments
SALSA will continue to provide a valuable resource to the small manufacturer for the foreseeable future. Work has already started on making the audit process more user friendly [for both parties], by introducing instant on line reporting during the audit. Other Standard + options may be developed, as well as a possible Warehousing and Distribution Standard.
Support services may also include a label checking service in due course, but it is unlikely that SALSA will provide a one-stop shop for all services and products related to food safety.
As the Food Standards Agency looks for novel ways to regulate the industry, there will be opportunities for audit bodies, such as SALSA, to provide the Certified Regulatory Auditors that are needed under the proposed regime[5].
Where enforcement bodies are aware of SALSA, there is a generous element of earned recognition, as enforcers value the scrutiny that is provided by the scheme.
Conclusions
The SALSA scheme is the ‘must have’ credential for small progressive suppliers to take them to the next level. It has given them the confidence to engage with serious players, where they can match their passion and enthusiasm for their products with sound food safety practices.
Although there is a deal of science involved in the products themselves, food safety systems are not rocket science, merely common sense and good practice. Understanding this allows small suppliers and their customers to sleep soundly at night.
Alex Kent (Honorary Fellow IFST) has spent his career in Technical Management, Quality Assurance and New Product Development within the Food Industry, working for blue chips, such as Marks & Spencer, Unilever [Batchelor’s] and Spillers Foods [Homepride]. Recently retired, Alex helps small businesses, primarily through SALSA but also through the Food Club, an organisation designed for networking and self-help. He is a registered
auditor/mentor for SALSA and has conducted more than 170 audits and advised companies in sectors as diverse as fish processing to breweries, from ingredients to shelf stable sauces.
Alex would be happy to supply an electronic copy of the SALSA Tool & Tip upon request.
Email:alex.kent2013@gmail.comWeb:www.salsafood.co.uk, www.thefoodclub.org.uk
References
1. Department of Business, Energy and Industrial Strategy – Business Population Estimates 2016
2. Safe and Local Supplier Approval - a case study of the Third Party Approval Scheme for micro and small food businesses – R. Bradford Knox and K. Kane, International Journal of Management and Applied Research, 2014, I.(i) pp 31-47
3. Data supplied by SALSA Operations – 09/2017
4. IFST website - https://www.ifst.org/professional-recognition-specialist-qualifications/register-professional-food-auditors-and-mentors
5. Food Standards Agency – “Regulating our future” https://www.food.gov.uk/sites/default/files/rof-paper-july2017.pdf
