Guiding food safety authorities in inspection strategy design

A systems approach to food safety regulation

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Abstract

The Nederlandse- Voedsel en Warenautoriteit (NVWA) asked the at-first-sight simple question of how to combine risk-based and random methods for inspection. Risk-based and random inspection methods have contrasting incentives. Risk-based inspection increases efficiency and allocates resources efficiently but fails to regulate low and emergent risks. Random inspection tackles unforeseen and emerging risks, ensures representativeness and prevents bias but fails to detect food hazards and non-compliance with food safety laws efficiently. A void in the literature exists on how to address the question of the NVWA. The supposedly simple question thus appeared to be a rather complex one. The research develops guidance for food safety authorities in combining risk-based and random methods through a design science approach combined with a systems view to retrieve a complete understanding while allowing it to narrow down to practical guidance.

The first step to address the literature void is the development of the construct of inspection strategy based on design science cycles fueled by literature and interviews with regulatory authorities. The following definition of the construct is retrieved: an inspection strategy entails selecting and combining methods based on inherent considerations and operationalization on contextual considerations. The construct of inspection strategy is placed between inspection method selection and food safety regulation. The construct serves as a common language and shared understanding for food safety authorities.

The systems view is introduced to understand why inspection strategy design is complex for food safety authorities because of its context. Literature shows there is value in taking a systems view to regulation. In fact, the complex systems view applied to food safety regulation brought forward systems characteristics to consider in inspection strategy design, including adaptive, emergence, unpredictable and goal-seeking. The systems view showed that an inspection strategy is to be designed within the context of food safety regulation that is continuously changing in an unpredictable manner because of emerging food safety risks. Consequently, the complex systems view provided direction on how guidance for food safety authorities designing an inspection strategy within food safety regulation is to be developed.

Following the definition of inspection strategy and the exploration of the system complexities of the food safety regulation context, the requirements for an inspection strategy are identified. The requirements originated from the systems map, interviews and literature. Fourteen requirements are defined with corresponding categories and priorities. Based on the requirements, a visual framework is constructed, providing an overview of the considerations for food safety authorities designing an inspection strategy. The framework, when applied to strategies, exposes potential trade-offs. The framework respects the complexities of the previously uncovered complex system characteristics by providing insight without imposing rigid standards.

Guidance for food safety authorities is developed based on the previous findings. The guidance is twofold. First, a scale of encountered inspection strategies from random to risk-based is evaluated based on the requirements framework, guiding food safety authorities by providing insight into the associated trade-offs and helping them select a strategy. Second, questions are developed to guide food safety authorities before, during and after the design of an inspection strategy. Food safety authorities have to implement the guidance themselves.

Ultimately, the research holds potential for food safety authorities to improve their inspection strategies combining risk-based and random methods when implementing the guidance. Consequently, improving the state of food safety in an accountable, applicable, feasible and adaptive manner. Through validation is confirmed that the guidance is helpful for the NVWA. Furthermore, the research produces academic value by creating a common language in the academic field through the construct of an inspection strategy and by demonstrating the utility of systems thinking for regulation. The recommendation stands to implement the guidance, include participatory methods, validate with various food safety authorities and continue applying systems thinking in food safety regulation for future research.