After reading the Ecologist and a few other bits of disappointing news items, I reached a new low when I read about the new initiative designed by some of the most lofty free trade flag flyers to "help" the small producer.
One of the most depressing aspects of starting up a small business is the fact that most of the regulations and restrictions favour the large producer. From health and safety to compost making, only the large, already established can afford to meet the requirements. To add insult to injury one soon encounters the army of inspectors from embedded echelons of bureaucracy in both governmental and private but government supported sources. The most iniquitous are those that in the guise of "helping"- be it the consumer or the producer - obtain funding to provide jobs to "assure" often what the law already requires.
In Smallholders Online Newsletter 178 (28 November, 2006) I submitted the following quote from one of the Red Tractor derivitives:
"Operators of the assurance scheme which underpins the Red Tractor standards have called on livestock markets to apply before Christmas to join up or risk facing potentially damaging delays in attaining assured status. The impact on farmers could be severe if delays occur because, from 1 April 2007, any assured livestock sold through a market which has not joined the scheme will lose its assured status, Assured British Meat has warned."
I claimed that it was coercive to sell assurance to the producer and then take it away because their livestock market refused to pay. Now I fear that yet another expensive assurance scheme will assure that only the large and well established small businesses will be able to afford to access small retail outlets.
The perpetrators bill it as a "local food boost." What a joke. Below I comment on some quotes lifted from the SALSA news item.
"The Safe and Local Supplier Approval (SALSA) scheme removes many of the practical barriers preventing small producers from directly supplying local retailers and caterers."
Sky: If there are barriers, they have been constructed artificially and imposed on the producer by government supported organisations that have frightened retailers into agreeing that they should only buy from companies that carry an expensive label that certifies that they have conformed to what the law requires anyway.
"SALSA is a low cost, but highly rigorous, scheme which works with local producers to ensure they have robust food safety procedures in place. Membership of the SALSA scheme allows producers and processors to demonstrate their ability to meet the necessary legislative requirements."
Sky: At £450, SALSA is not low cost. What is "highly rigorous" about a check sheet that simply follows what DEFRA has already made perfectly clear in booklet after booklet that explains the law and the legal requirements? Farmers are in despair over the reams of paperwork, ear tags, passports and a plethora of other checks to see that they obey the law. The scheme "allows" producers to demonstrate that they meet legal requirements. You see, the fundamental flaw here, as in all inspection schemes, (SALSA calls them "audits") is the mistaken inference that an inspection threat or act will make people honest on the next and subsequent days following the inspection. If a person wants to cheat, they will find a way. Just last week the RSPCA "assurance" scheme received stark criticism:
"The footage gathered by workers at the Hillside Animal Sanctuary, in Frettenham, and passed on to the Evening News shows:· A duck being punched and others being treated roughly and violently grabbed round the neck before being thrown onto the back of a vehicle to be taken for slaughter.· Ducks, some of them obviously injured, being kept in cramped conditions, while dead birds lay beside them on the floor.· The floor of an industrial turkey shed littered with injured and dying birds and one dead bird which is being eaten away by flies.· Squalid conditions at a pig farm near Norwich, where two of the animals appear to be lame and left in pain.All of the farms supply food to leading stores and have been sanctioned by the RSPCA farm animal welfare scheme, Freedom Foods, which is designed to make sure firms rearing animals for food are meeting stringent welfare standards.Farms approved by the RSPCA are allowed to put the "Freedom Foods" logo on their products and demand higher prices."
From Smallholders Online Newsletter Number 191 19 March, 2007. www.smallholders.org
A few years ago I was speaking to an organic certification inspector who told me that not a day goes by that someone doesn't telephone head office to report someone cheating. Yet, the inspection system propaganda continues to treat people as dishonest by telling them that they cannot be trusted. Of course, elementary psychology has shown us that people are much more likely to be trustworthy when they are trusted to begin with. This is especially evident in the behaviour of children. Passing an inspection does NOT demonstrate honesty.
"British Retail Consortium, (BRC) Director General Kevin Hawkins said: 'SALSA is about making it easier for stores to supply local people with goods produced by local suppliers. '"
Sky:
"National buyers, traditionally geared up to source food and drink in quantities suitable for national distribution, require an assurance that the locally sourced food which they are buying meets fundamental legal, food safety and due diligence requirements. SALSA has been developed to meet this need."http://www.salsafood.co.uk/pages/about-us/why-is-salsa-needed.php
Who says they "require" assurance? What about our tax money which funds DEFRA who will enter your property without permission and kill your animals if your paperwork is no in order? If that's not policing the regulations, what are you looking for, the Army?And then there is the Food Standards Agency, FSA.
"[ Enforcement:"The Food Standards Agency oversees local authority enforcement activities for food law. It sets and monitors standards and audits local authorities’ activities to ensure enforcement arrangements are proportionate, consistent and transparent. Powers to enable the Agency to monitor and audit local authorities are contained in the Food Standards Act 1999. The Agency also supports local authorities by funding training, providing grants and making other resources available.]"The FSA is huge and has a lethal bite. And then what about each county's Trading Standards. "[Trading Standards OfficerThe workTrading standards officers (TSOs) protect consumers by making sure that goods and services are bought and sold in a safe and fair trading environment. They advise consumers and businesses, check that businesses keep to the law, investigate complaints and prosecute any traders that break consumer laws. TSOs are employed by local authorities, and their duties may include:
*taking samples of food and goods for testing
*checking that traders’ scalevisiting local traders and businesses to carry out routine checks or investigate complaints
*weights and measures are accurate
*making sure that labelling is correct and advertising is not misleading
*advising consumers and traders about the law
*investigating suspected offences – this may include undercover or surveillance work
*preparing evidence and going to court in prosecution cases
*giving talks to schools and community groups
writing reports and keeping records.]
"East Sussex Trading Standards advise businesses about and enforce numerous pieces of food standard legislation, including regulations on food labelling. http://www.eastsussex.gov.uk/business/tradingstandards/foodsafety/default.htm#subtitle2"These people will close you down if you don't uphold the law.How about the Health and Safety Executive?
"[Health and Safety ExecutiveLegislation The aim of this site is to raise awareness of the range of health and safety legislation that applies to workplaces in Great Britain. It has been designed to:
*help users discover specific legislation that applies to their industry
*explain how to trace and obtain Acts and regulations
*provide links to organisations that can offer advice and guidance on legislation ]"
And then there is each county's Health and Safety department. The following is an example from my own district council.
"[Workplace Health Connect is a new service launched in February this year. It provides free, confidential and impartial advice on creating a safer and more healthy workplace for smaller businesses in England and Wales. http://www.torridge.gov.uk/index.cfm?articleid=6736]"
All the above are funded by taxpayer money and in place to assist businesses to protect the consumer. So why this expensive "assurance?" Of course, with my sales hat, I can easily imagine talking a retailer into going along with my contention that they "need" my services. I will promise to save them a couple of telephone calls checking up on a supplier. I might be able to persuade them that my inspection (auditing, sorry) will protect them from cheaters. I can ask them to help my organisation take in more fees and get bigger so it can "help" more producers. Following that, I can warn the retailer that in the future the government might force them to accept only SALSA approved product. And, of course the clincher is that the retailer pays absolutely nothing for this convenience. No, the producer pays. So, many retailers might shrug and figure it costs them nothing, so why not? SALSA provides services for "due diligence requirements"? What can this mean? Well, of many definitions, most having to do with legal issues, I came up with this one:
"Due DiligenceThe process of systematically evaluating information, to identify risks and issues relating to a proposed transaction. http://www.strategis.ic.gc.ca/epic/internet/insof-sdf.nsf/en/so03149e.html"This is what it boils down to: Verify that information is what it is proposed to be. A retailer can do this with a telephone call or check with their local council.The SALSA website claims that the scheme is:
"self funding and founded on not-for-profit principles; it has received start up funding and support from DEFRA, Highland and Islands Enterprise and Scottish Enterprise. Standards pdf (pg 3)"
How can a scheme be self-funding when it has received start-up public money and charges the small producer £450? Founded in not-for-profit principles? Is it a not for profit company? Their website says " non-profit making" Is it a corporation limited by guarantee? I don't think so.My fear is that the powerful backers of SALSA will achieve what the BRC has achieved with large retailers. I can't find out the total cost of the BRC but the following from their website will reveal just how large, powerful and expensive they have become since 1998. If they charge £230 for just a copy of their standards document, just imagine what the total package must be worth. Perhaps they have saturated the large retailer market and see expansion downward as the only way to grow.
"British Retail ConsortiumWhy do we need BRC Certification? Who needs BRC Certification?(a) Most large UK retailers will only consider business with suppliers who have gained certification to the appropriate BRC Global Standard.Most manufacturers are required to show that they are certificated to the BRC Standards and continuously comply with the legal and quality requirements of its retail customers.This is because they have a legal responsibility for the products under the Food safety act of 1990 for their own retailer label. Brand owners also have a legal responsibility for their brand under this act.British Retail Consortiumhttp://www.brc.org.uk/standards/default.asp?mainsection_id=10&subsection_id=35
PLEASE NOTE: If you represent a food, packaging or consumer product manufacturer and have been asked by a retailer that you need BRC in order to be a supplier, your company needs certification against the appropriate a BRC Standard. Full details of the certification process can be found on the BRC Global Standards website: http://www.brcglobalstandards.com. andhttp://www.brc.org.uk/ContactUs04.aspFood and Packaging Standards plus Guidelines (Print Version) Standard and Guideline Pack English £230.00http://www.brc.org.uk/standards/default.asp?mainsection_id=2&subsection_id=2"
Above, I have submitted considerable detail in an attempt to establish that SALSA is:
(1) Completely unnecessary to either the producer or the retailer.
(2) An unecessary burden of cost on the small and local producer.
(3) Completely unhelpful to the small and local business.
I can only hope that small retailers will be fully informed as to the cost and adverse effects this scheme will have on their small suppliers before they turn down product from those who simply cannot afford this expensive and unnecessary scheme.
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