NPA calls on Red Tractor to reduce bureaucracy burden in consultation response
5th Mar 2021 / By Alistair Driver
The NPA has called on Red Tractor to ease the burden of bureaucracy on scheme members and to avoid introducing new standards that are not relevant to the pig scheme.
In its response to the major Red Tractor consultation on changes to the pig scheme’s standards, the NPA also urges Red Tractor to refrain from ‘knee jerk standards setting’ and suggests an overarching review of the scheme is overdue.
Paperwork and bureaucracy: The NPA submitted its response today, following wide consultation with members, and in a letter accompanying it, NPA chief executive Zoe Davies says the ‘overwhelming bulk of comments have related to the apparent increase in paperwork, bureaucracy and addition of standards that are not relevant to pig production’.
“For many smaller producers, the cost of being a Red Tractor member is significant enough without the additional requirements that have been included,” the letter states. “We have seen no evidence that this has been considered in the review and would request that impact on smaller producers be investigated.”
Impact assessment: The NPA’s response also calls for further discussion and analysis where significant changes have been suggested or recommended which go over and above legal requirements, including in relation to stocking density, trough shoulder space and nesting material for sows regardless of slurry system.
In some of these cases, the NPA does not believe sufficient evidence has been presented to justify the change, while neither has any financial impact assessment been undertaken.
“Indeed, NPA believes that as part of due diligence, Red Tractor should complete a financial impact assessment of all the proposed changes to identify what the cost to members might be to comply and whether that cost of compliance is even feasible, particularly given the expectation of Red Tractor to meet standards from day one,” Zoe’s letter states.
Outcome-based: The NPA response expresses concern that some of the suggested changes, for example, the need to document weekly alarm tests, appear to contradict the sensible approach taken by Red Tractor of late of looking at outcomes rather than inputs.
“We have always argued that the emphasis on auditing should be on looking at the pigs and the farm and not sat in the office looking through paperwork, so we do not support the addition of anything that adds to this burden,” the letter says.
Duplication: Smaller independent businesses have also expressed ‘significant concern’ over the level of duplication across various schemes and NPA urges Red Tractor to proactively seek data sharing agreements wherever possible, particularly with retailers.
NPA also suggest that in some cases, Red Tractor is picking up more of the responsibility that should in fact be carried out by enforcement bodies, particularly in areas such as Health and Safety and welfare because those bodies lack the resource to be able to properly do it themselves.
Aligning standards: The NPA’s response highlights how in an effort to align standards across the sector, there are now many areas that do not directly apply to many pig producers, especially those who are contract farmers, rent buildings or land or have no other enterprise as part of their businesses.
This is particularly the case for many of the standards relating to fertiliser use and storage and the NPA response calls for certain standards to be removed where they are far better suited within the crop standards.
Knee jerk: Some changes appear to have been proposed as a direct result of animal rights exposés.
“Where there are obvious gaps they should be discussed, but we do not agree with knee jerk standard setting,” Zoe’s letter states. “Any proposed standard alteration should be properly justified, particularly if the change or addition could have an impact on the number or severity of any non-conformances raised.”
Red Tractor review: In conclusion, the NPA suggests that an overarching review of the scope and role of Red Tractor as a whole is well overdue, and fully supports the standards development principles paper that the NFU has recently drafted.
“As far as we are aware, no review has been conducted since Red Tractor was formed and whilst producer members have been involved in the evolution of the standards, there has been no consultation with industry about the agreed overall forward strategy for Red Tractor,” the letter says.