Low-risk audit trials

Hi, my name is Sam, and I work for the Dairy, Eggs, and Fish (DEF) team at the Department of Agriculture, Fisheries and Forestry. I am here to talk with you about the changes that the department is making to the way that we regulate and audit low-risk dairy, egg and fish export establishments. The good news is that through these changes the department will be able to reduce regulatory burden for low-risk establishments – and that means there will be less red tape for you! When we talk about low-risk establishments we mean storage facilities, fishing vessels, and some live fish establishments (excluding those that store bivalve molluscs). This does NOT include multicommodity establishments that store other commodities such as plant or meat products.

First of all, lets cover how we currently do things – we call it the ‘site audit approach’. Under the ‘site audit approach’ low-risk establishments are audited annually against a defined scope of audit elements under an establishments Approved Arrangement – or AA as well call it.

We have run the numbers and over the last 5 years the data has shown that establishments engaged in activities such as storing chilled and frozen products, catching and minimally preparing fish, and keeping fish alive during export, are less likely to have export compliance issues than other parts of the industry engaged in more complex activities. This is in part due to their operations – their supply chains are short (product in, product out), and the export products are either only stored, or are minimally processed, and will be further processed before being consumed. This means that low-risk establishments do not need to be regulated in the same way that higher-risk establishments are.

Let’s press pause here, because this is probably a good time to remind everyone what the department’s role in this process is. Ultimately, the department is here to oversee the export process, one of the ways we do this is by auditing your establishments to make sure that food products intended for export are safe for human consumption. By doing this we are able to provide assurances to our trading partners that Australian food products are safe, high quality, and ready for export. SO, from here what we need to do is come up with a way that we can still provide those assurances to our trading partners so that you can keep exporting your products, while being less burdensome for you in your everyday work.

With all of this in mind, the department wants to modernise the way we do things by moving from a ‘site audit approach’ to a new and more targeted ‘verification and assurance model’. We are really excited about the new ‘verification and assurance model’ because it will be based on data and risk, and will ultimately ease regulatory burden for your business.

So, what I have been telling you so far is the context, but what I am about to talk about is the trial of the ‘verification and assurance model’, and it is important that you understand this because your establishment might be selected for the trial.

So lets get into the detail - 50% of dairy, egg and fish establishments identified as low-risk will take part in the trial of the ‘verification and assurance model’. The remaining 50% will continue to be audited as per the current state ‘site audit approach’ we talked about earlier – we are doing it this way so that we can compare the results of the trial to ensure that the new approach still meets food safety and importing country requirements.

We are designing the trial in the most fair and equitable way that we can. Establishments receiving audits during the trial period will be charged as per usual, at the quarterly rate prescribed in the department’s Cost Recovery Implementation Statements, while establishments trialling the ‘verification and assurance model’ will be charged for the average audit time based on historical data. This approach to charging will only occur during the trial period. Success of the trial and full implementation of the ‘verification and assurance model’ will see audit fees largely removed for low-risk establishments. Audit fees will only be applied where non-compliance has been identified and needs to be followed up.

The establishments that will take part in the trial will not need to have a traditional site audit. For those participating, the trial will involve:

• Filling out an establishment questionnaire,
• Signing a declaration,
• Submitting photos of your establishment which will be assessed by department through Artificial Intelligence, AND
• You may also be selected to take part in sector level verification to make sure that the new system is working as it should.

If you are selected to take part in the trial, there will be more information provided about these verification activities and exactly what it means for you.

The trial will run for one year from July 2023 to June 2024. It will be considered successful if the department can prove that the ‘verification and assurance model’ can adequately show compliance with food safety requirements, export legislation, and importing country requirements. As I mentioned before this is to provide assurances to our trading partners which means you can keep exporting your products! If the trial is successful, 100% of low-risk establishments will be regulated using the new ‘verification and assurance model’ which means there won’t be any more site audits unless the department has determined that one is required. If there is insufficient evidence to fully support the new ‘verification and assurance model’, the department will consider extending the trial for a further 12 months.

Department staff will be available to guide you through these changes. For more information have a look at the infographic and emails that we have sent out. The department will also be running webinars, creating more informational videos, and speaking with establishments one-on-one if needed. Communication will be ongoing but if you have questions in the meantime, please contact dairyexportreform@aff.gov.au for dairy, seafoodexportsupport@aff.gov.au for seafood, or dairyeggsfish@aff.gov.au for eggs!

Thanks for listening, we are looking forward to working with you throughout the trial period!