HEALTH & CONSUMER PROTECTION DIRECTORATE-GENERAL
Directorate F - Food and Veterinary Office
F7 - Quality, Planning and Development
Grange, 7 July 2010
Short Report of Meeting of National Audit Systems (NAS) Network
Grange, 29-30 JUNE 2010
Participants: Representatives of all MS except BG, CY, IT, and RO. Switzerland also attended. Commission represented by M. Waters, J. Junttila, I. White Directorate F. M. Scannell Director SANCO F attended the closing session. [1]Apologies for non participation received from IT and G. Balkamos Directorate E.
The meeting was organised around three workshop sessions, for each session the participants divided into three workshop groups to discuss their chosen topic. Each group reported back to the plenary session through a rapporteur, following which there was general discussion on the outcome of the workshops. The following four topics, proposed in advance by the participants, were considered during the workshops.
· Development of proposals from previous "risk –based audits workshops" (3 workshops)
· The relationship between national (internal) audits and FVO audits including the added value of audits.(2 workshops)
· Auditor-auditee relationships – how to foster relations that promote the effectiveness of audits including the added value of audits – system and auditee perspectives (1 workshop)
· Follow-up to audits (3 workshops)
A summary of the outcome of the workshops follows and copies of the presentations made by the rapporteurs will be circulated to all participants. The presentations are also available on
K:\Presentations\2010\Audit Network June 2010
1. Workshops on risk-based audits
Each of the three workshops considered how a guide to good practices based on information provided and views expressed at previous network meetings might be presented. The object of the exercise would be to draw up a relatively simple guide, non prescriptive, guide to good practices to assist in planning audit programmes targeted at auditors responsible for auditing official controls as required by Article 4(6) of regulation 882/2004 and managers with overall responsibility for the audit programme.
All groups considered the draft consolidated paper on previous discussions in both the NAS and MANCP meetings to be a good starting or reference point but overall it was regarded as a bit too complicated and theoretical to meet need for more practical guidance. A proposal from Switzerland to produce a two part document, the first part dealing with general principles and theory and the second focusing on the application of a risk based process was well received. Two of the groups favoured including practical examples from Member States experiences in planning their audit systems and the third group were of the opinion that the guide should only include principles. It was also considered that the paper should focus more on horizontal issues rather than product specific risks.
It was agreed to establish a small electronic working group to work with the network secretariat in preparing proposals for consideration by the next meeting.
It was also suggested that the network might consider a similar exercise addressing audit planning/methodology and review critical success factors, such as best sampling processes, types of audit, expertise requirements including use of external experts.
2. Workshops on the relationship between national (internal) audits and FVO audits
Two groups considered this topic which was proposed with a view to identifying possible synergies between the activities of national and FVO audits in verifying the effectiveness of national controls. Both groups acknowledged the difference in the respective responsibilities of both audit functions but considered that in many ways their task was more similar to FVO audits than to routine national official controls. Therefore they were anxious to explore how the work of NAS might be used to greater effect by the FVO in planning their audit programmes and if there were actions the NAS could take to convince the FVO of the integrity of the NAS and the quality of their audits.
Concern was expressed that there is little tangible evidence that the introduction of the NAS is leading to a reduction in the number of FVO audits and with current pressure on resources it was considered that some incentive is needed to ensure that MS continue to support the development of their NAS. It was remarked that frequently FVO and NAS audits concentrate on the same areas of activity around the same time and it was thought that to some extent it might be better or more effective to reduce such duplication thereby freeing up resources to audit other additional areas. For this to happen better coordination between NAS and FVO audit programmes would be required and it was considered that there was potentially scope for improved coordination.
Some references were made to the unintended negative effects of too frequent auditing; auditee fatigue, reduced impact of findings and recommendations, disruption of/distraction from routine management tasks and difficult issues being left to be addressed by audit rather than being resolved by local management.
It was stressed that the NAS auditors are not seeking withdrawal of the FVO audits which are considered important to support the work of the NAS, by validation of their audit findings and it was opined that without the prospect of FVO audits, many NAS audit recommendations would not be acted upon.
A number of suggestions to develop/improve the relationship were made including the following
- Sharing audit programmes so they can be taken into account in planning respective programmes,
– Problem of different time-frames for planning could impede coordination.
– Possibility of early access to FVO mission programme, even at CVO/HOS stage, to help NAS to take account of FVO plans (publication stage too late).
- Reporting on NAS activities
– Is additional reporting on audit activities to that in Annual report on MANCP necessary, would FVO be interested in receiving national annual audit reports where available?
– Network could consider proposing a standard approach (level of detail) to reporting NAS activities in annual report so FVO could consider MS on a broadly comparable basis. If this proposal is accepted it is strongly recommended that it be tried on a voluntary basis and the template fine tuned before any attempt to formally amend guidelines.
- Feedback on NAS from FVO
– Is the evaluation of effectiveness of NAS in general audit sufficient?
– FVO sectoral audits to comment on findings of NAS in that area (if any).
– FVO series of missions specifically on NAS, like fact finding missions before guidelines, to identify best practices.
- Learning from FVO
– Useful for NAS auditors to participate in FVO opening and closing meetings
– Some NAS auditors accompany FVO inspectors to learn by observing, and this assists the NAS understanding of what is required if NAS is involved in follow-up action.
3. Workshops on Auditor-auditee relationships
The workshop concentrated on identifying good practices to foster good auditor-auditee relationships. The main obstacle to good relationships is the auditees suspicion or perception that the purpose of the audit was to find non-compliance rather than to verify compliance. The challenge is to convince the auditee that both auditor and auditee have a common objective of ensuring the effectiveness and suitability of official controls and identifying areas for improvement and development. A discussion of various practices and prerequisites highlighted the importance of the following:
- Clear mandate, formal authority and support from top management; lack of any of these a major obstacle to acceptability and effectiveness of audit.
- Good communication, transparent procedures and processes, ready access to information, guidelines, training, seminars, etc.
- Building confidence between auditor and auditee, auditor approach and competence and training of auditees for being audited. Auditor to provide auditee with advance information on scope, procedures and methodology for audit (like FVO evaluation plans).
- Adding value
– Result of audit helpful to auditee
– Audit report and processes have sufficient quality and system in place to continuously review and evaluate audit product.
– Top management convinced of benefit
4. Workshops on Follow-up to audits
Discussion in the three groups concentrated on sharing information on the varying systems of follow-up. Approaches and the level of involvement of the audit team in the verification of follow-up varied quite considerable. To some extend the level of development of a systematic approach to follow-up depended on the degree of audit system maturity.
- Arrangements for follow-up included desk top evaluation, follow-up as part of a subsequent audit and in some cases specific follow-up audits depending on the seriousness of the deficiencies noted.
- Some concern was expressed if the auditor was too heavily involved in follow-up they may lose objectivity. There was universal agreement that follow-up action is essential if the objectives of the audit process are to be achieved.
- It was agreed that primary responsibility for an action plan to follow-up an audit rested with the management of the audited activity and the extent of auditor involvement in verifying the effectiveness of the action plan and, or, corrective actions varied.
- Arrangements for follow-up should be formalised.
- There should be clear designation of responsibilities for different stages of follow-up activities.
- A system of monitoring to ensure corrective actions are taken and evaluated.
- Audit Committee and independent scrutiny play an important role in ensuring an appropriate management response to recommendations.
Most auditors had some experience of reoccurrence of the same non-compliances or insufficient follow-up action. It was suggested that a workshop on dealing with persistent non-compliance or lack of follow-up action be held at a future meeting. NL offered to contribute to such discussion by making a presentation on work they are doing to identify root causes of non-compliance.
5. Information on BTSF auditor training programme
Participants were advised that requested training on auditing would be included in the 2011-2012 BTSF programmes and that applications should be made through the national contact points. The participants were advised that the process of selecting a contractor to provide the training will not be completed until late autumn it is possible that specific information on the course venues and dates will not be available until early 2011. Full information will be available from national contact points and the website on BTSF in due course, but the chairman undertook to keep the network members informed of developments. The training will be targeted at those involved in the NAS process and the importance of disseminating information received during training to other auditors was stressed if the full potential of the training was to be realised.
6. Presentation by France
The French representative made a short presentation explaining the accreditation of the French control services.
Maura Waters
2
[1] Some FVO inspectors attended for parts of plenary sessions.