Safe food safe people management system: enhancing compliance with safety legislation in Irish food and drink manufacturing SMEs
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Whilst the growth of many industry sectors has declined following the deepest global financial recession in decades, the food and drink sector, in particular food and drink manufacturing, has continued to grow. The sector is one of the largest and most important manufacturing sectors in Europe and Ireland. Small and Medium-sized Enterprises (SMEs) and craft enterprises account for the majority of enterprises in the sector and are a very important part of the European economy. Their central role has been recognised by the European Commission and the Member States through various policy declarations, including the Small Business Act (2008) and it’s Review in 2011, which promote the ‘think small first’ principle in policy making. In the Irish context the continued growth of the food and drink manufacturing industry and the many small businesses on which it depends has been identified as a the route to economic recovery and advancement (Central Statistics Office, 2012a). Characteristically small businesses differ from their larger counterparts having fewer resources, informal management systems, a higher risk of workplace injury and illness, a higher turnover of staff etc., however, the same regulatory requirements apply. It is generally accepted that there are costs associated with regulation such as compliance, costs. These costs are higher for an SME than for a large enterprise (Enterprise and Industry, 2007). This results in a disproportionate burden of regulation for SMEs, which is amplified in food and drink SMEs due to the additional burden of food safety regulations. This disproportionate burden in turn results in insufficient compliance with safety regulations, in particular with occupational health & safety (OHS) regulations in the food & drink sector. The sector has a plethora of food safety regulations to contend with and according to the results of a survey conducted by the Food Safety Authority of Ireland (FSAI), these are described by the SMEs as challenging, costly and time consuming, thus OHS requirements can be left to the side and food safety prioritised (Food Safety Authority of Ireland, 2011). A lack of safety compliance intensifies the instability of small business and hence the economy by adding a cost in the form of accidents, incidents, claims, lost time, loss of professional reputation etc. Although, compliance is influenced and challenged by many factors such as; the size of the business, business characteristics, the level of enforcement, the supply chain, the perception of risk etc. small business owners cite the costs and the burden of complex regulations as the main barrier to regulatory compliance. The cost associated with non-compliance in the form of incidents, accidents and possible prosecution, non-compliant businesses will not survive. Due to the diversity of industries in the food and drink manufacturing sector, the final product intended for human consumption, the processing equipment used and the number of manual job tasks, the sector presents as a high risk industry and is therefore highly regulated. Unsatisfactory OHS compliance in Irish food and drink manufacturing SMEs has a negative impact on workers and their families, the enterprises themselves, the Irish food and drink manufacturing sector, the Irish economy and in turn the European economy. As the majority of Irish SMEs are micro-sized enterprises financial penalties and/or prosecutions can lead to closure. However, small business owners believe that the work involved to meet with requirements would outweigh the benefits of regulatory compliance (Haslam et al., 2010). Many interventions to assist SME regulatory compliance have been introduced over the past number of years at a national and European level, with The European Commission in line with Member states has introduced a total of 660 initiatives since 2005 aimed at reducing the complexity of and the number of European Directives (European Commission Project Consortium, 2013). Despite these interventions small businesses continue to struggle with compliance and hence for economic survival, with many closing down (Vetter and Köhler, 2014). Based on this, the importance of SMEs, the moral and legal obligation to protect workers, the value of the food and drink manufacturing industry, the unsatisfactory level of OHS compliance and the perception of compliance as a regulatory burden, a requirement for a suitable system to assist small businesses with regulatory compliance exists. This thesis details the design and the development of such a system, in the form of an aligned safety management system for food and drink manufacturing SMEs in Ireland which will enhance compliance with OHS and in turn protect the worker. As a food and drink manufacturing enterprise cannot begin to trade without the implementation and approval of a food safety management system by the food safety authorities. The food & drink SMEs therefore manage food safety using HACCP as a matter of course. The proposed safety system aligns OHS with these existing food safety management systems, and by doing so, it is anticipated that OHS will receive the same standing as food safety within the industry. As SMEs have difficulty in securing the resources required to comply with regulation and/or standards in their current format the safety system considers the special characteristics of small businesses and their needs in its design. It is designed in line with the ‘think small first’ principle from the Small Business Act (SBA) of 2008 (reviewed in 2011), as well as the ISO Guidance ‘Guidance for writing standards taking into account micro, small and medium-sized enterprises (SMEs) needs’ to ensure an intervention fitting with OHS compliance problems. It aligns OHS regulatory requirements with existing food safety management systems in a language understood by the food & drink businesses allowing the SME to comply with both safety requirements using one management system. The system design provides a sustainable solution to the problem of poor OHS compliance by reducing the cost of compliance and the complexity of regulatory requirements, hence reducing the perceived ‘regulatory burden’ for SMEs. It is anticipated that such a system will be effective in enhancing the level of compliance in the SMEs and by doing so it will also enhance worker safety. Enhanced worker safety will result in reduced costs and an enhanced professional business reputation for Irish food and drink manufacture in international market for business. The resultant safety system was tested in industry to validate the effectiveness and suitability for SMEs, and was also validated by expert reviewers including regulatory authorities and end users.
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