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| Agenda Item 4.3 | GF 02/6 |
second fao/who global forum of food safety regulators
Bangkok, Thailand, 12-14 October 2004
(Prepared by the Ministry of Agriculture, Food, Fisheries and Rural Affairs
– National School of Veterinary Services, France)
Vocational training is not an objective per se but a tool for policy implementation in a given administrative and juridical framework. The context determines needs, constraints and solutions.
Any focus on the training of personnel in the food safety control services of different countries of the world requires an insight into their operational context and key developments. The organizational structures and areas of competence of these services are also decisive in determining training responses. We need to go beyond national particularities and discern elements of common interest in order to describe the existing situation and, above all, in order to fuel thought to the future.
The international standards of the Codex Alimentarius and OIE1, which have served as the WTO2 framework of reference since 1995, have converging provisions on the quality of official control and inspection services and on the status, competence and training of personnel, especially regarding official certification3. These texts are cited more in terms of objectives to be reached than means to be implemented.
For the purposes of this paper, official food safety control is defined as all the operations conducted by official services set up to verify and guarantee the conformity of food products with established standards in order to prevent risks to public health. It covers food produced and marketed domestically, as well food imported or intended for export (health certification). It covers all phases of production, processing, storage, transport, sale and final consumption. It comprises numerous operations, including inspection, verification of records, sampling, laboratory analysis, control of staff hygiene, audits and the checking of self-policing systems. Laboratories are not themselves covered because of the highly specific nature of issues relating to competence of laboratory staff.
A large number of structures are in some way involved in a field as complex as the control of food safety. For purposes of simplification, this paper will only deal with specialized food safety services, such as veterinary services, although a similar approach can be deduced by analogy for other services.
The tendency in food safety is to have measures covering the whole production and distribution chain: "from farm to fork" or from upstream (animal feed, veterinary drugs and phytosanitary products) to downstream (the consumer). This review only looks at services relating to food itself – from the time of harvest for crops and the moment of slaughter for animals, when food safety services are not organized holistically.
Food safety concerns have intensified throughout the world in the past 15 years. The operational context of control services has undergone and is undergoing profound change in a framework of greater international connectivity. The following elements can impact strongly on training needs or policies:
The competences that need to be developed among control staff are determined by the objectives, mandate and organization of the service concerned.
The way food safety control services are organized varies widely between countries and many different structures are in some manner involved. Different organizational possibilities and the combination of options will determine training needs.
(1) The degree of vertical integration:
or responsibilities are separated between upstream (primary production: animal health, crop protection) and downstream (processing), with the division at the slaughterhouse or harvest level.
Many countries have recently reorganized their administrations to have a single structure controlling the whole food chain.8
(2) The administrative configuration:
(3) Coordination is organized very differently, whether between ministries over the same territory or between different territorial levels. It might be non-existent, informal or institutionalized (cooperation protocols, institutional lead agency…).
(4) The delegation of selected control: control is seen as a prerogative of the central authority and is usually exercised as such by the administration (more rarely, by independent public agencies). Some countries, however, delegate selected control to private structures that are formally recognized by the administration.
(5) The distribution of responsibilities: under the traditional approach, responsibility for product safety is borne by the official services exercising first-level control over the finished product and, perhaps, production conditions. This continues to be the approach in many countries, at least for the domestic market.
At an intermediary level, operators are responsible for the quality of the products they market, with first-level control remaining in the hands of the official services.
Finally, the present trend is towards a division of responsibilities among: (i) operators responsible for the safety of their products and required to employ preventive measures, notably HACCP related; (ii) public authorities exercising second-level control and checking the measures taken by the operators; (iii) even consumers, given the importance of the post-purchase phases (conservation and preparation) for the maintenance of food safety.
All intermediary situations exist in reality and changes on the ground can only be introduced progressively.
(6) The above points to the following areas of frequent vulnerability:
The control services employ different categories of staff. The terminology employed and the corresponding levels of training and responsibility vary enormously among countries.
For purposes of simplicity, there are two broad categories of staff or agent:
Some of the characteristics of status of these agents impact on training policy.
Status and recruitment
Control agents are usually civil servants (or the equivalent with indefinite contracts), in application of the principle of independence of public service from political or economic pressure. However, in some countries supervisory staff are contracted privately, in which case their appointment and retention depends on the political authority. Recruitment in the decentralized States is often at regional or local level for the technical agents (civil servants), and sometimes also for the supervisory staff. Elsewhere, many countries employ part-time freelancers to make up control staff numbers, particularly for slaughterhouse inspection (veterinarians). But these do not represent the backbone of the system, even though there are countries where a majority of agents are employed on a part-time basis, with the attendant risks of conflict of interest.
Mobility and career development
Under certain systems, thematic and/or geographical mobility is possible, encouraged or even mandatory for promotion, especially for supervisory staff. This is facilitated under national recruitment systems and in services with broad responsibilities. It is a factor of motivation, fostering the harmonization of practices and coordination. In contrast, the possibilities of mobility are few or indeed nil in systems that are based on local recruitment and in services that have very narrow remits. Although these foster stability and capitalization of know-how, they nevertheless incur the risk of lethargy, demotivation and indeed collusion. Finally, the extensive random mobility that takes place in certain countries with the occurrence of political change is clearly a destabilizing element for control staff and services.
Prior initial training designates the level required for recruitment. Post-recruitment or occupational initial training is training provided by the employer before taking up duties.
Prior training
All countries require a certificate of higher education for entry at supervisory level (generally BAC9 + 5 or 6). Candidates have thus acquired a good general scientific base at university level. In most cases, this qualification is sufficient for recruitment, although some professional experience in the private sector is sometimes also required.
However, deficiencies are often noted, undermined effective performance in the official services.
For example, veterinarians trained as clinicians and pathologists have a very diverse understanding of food hygiene. Some universities provide advanced education in this area while others barely touch upon the subject. Disparity between countries is sometimes compounded by differences between universities within the same country, or between veterinarians trained abroad in different countries. To overcome this, some countries have made it mandatory that applicants should have attend selected veterinary university courses to be eligible for public service or to qualify for higher posts. Others resort to post-recruitment training.
Post-recruitment training
This training, which is organized and paid for by the employer, is intended to supplement prior scientific training with the specific technical and administrative expertise that is required for public service in the food safety sector.
This form of training is unknown in many countries, where learning occurs on-the-job. Some services run short training sessions, lasting a few days to a few weeks, to present the central administrations and outline the legal dimension. The practice of setting a 6, 12 or 24 month probationary period before job confirmation is frequent, with or without associated short training, and sometimes with tutoring.
There appear to be very few countries that provide long-term post-recruitment training for their civil servants. In France, veterinary officials in the veterinary services have been trained in the specialized post-graduate National School of Veterinary Services (ENSV) since 1973. This training, open to foreigners, lasts one to two years and covers technical aspects (HACCP, environment, epidemiology, quality assurance), administrative matters (law, economics, international politics) and management. It prepares the ground for a range of appointments.
Such training meets the requirements of a new regulation adopted in 2004, governing the recruitment of official veterinarians. These have to pass an examination on a wide range of technical and administrative subjects (the actual training modalities are left for the Member States to decide) and have received 200 hours of tutored practical training.
The differences in approach to supervisory staff also apply to support staff, depending on the administrative culture of each country.
Prior training
This varies considerably: from recruitment with a university diploma (BAC+2), to a high-school diploma (BAC), to no initial qualification. Assigned responsibilities also vary. Some countries have job specifications for public posts which help determine the "appropriate training" for each individual post.
Post-recruitment occupational training
Post-recruitment training is far more common for this category of staff and generally focuses on a specific area of control (e.g. inspection at slaughterhouse). It rarely covers all potential fields of assignment.
The European Union’s new regulation specifies that these agents should receive 600 hours of theoretical training (the programme is given) and 300 hours of practical training before sitting the qualifying examination. The duration of training will be increased to 1400 hours in 2010.
Staff development or intermittent training serves to keep agents abreast of technical or administrative developments or to enable their career advancement.
It does not exist in many countries, especially developing countries. At most, ad hoc training modules are included in bilateral or international cooperation programmes.
When such training is organized, the basic format is generally a session lasting a few days and focusing on a specific occupational theme.
The perception of staff development varies considerably. Some countries include it in a global policy of institutional training, with annual or even multi-annual programming organized by the employer ministry. The training sessions are either organized directly by the administration or commissioned from universities, specialist schools or vocational associations, following tailored specifications. This approach, which is easier to adopt in a centralized State, also exists in a number of decentralized States which view the training of staff in administrative subdivisions as an instrument of guidance and coherence.
This training often occurs in a less coordinated manner, especially when responding to market forces and the logic of supply. The sessions, paid by the employer or the staff themselves, are organized by universities or laboratories. However, they do not always convey the institutional line-of-thinking and might sometimes transmit divergent messages.
In the decentralized States, each administrative subdivision often designs its own actions based on its own policy, without vertical or horizontal harmonization.
Participation in training courses organized by other countries or in training at international level is an intrinsic ingredient of training policy of certain countries, especially in small countries that depend on the availability of training in their neighbouring countries.
Staff development training can be optional and free of charge to the agent, and might even represent a right rather than a duty. On the other hand, it is sometimes mandatory, even if only in principle, for certain courses, with a minimum number of days of training required each year and even a system of points to be accumulated over a given period. It might also be required for access to certain jobs.
The employer generally covers the cost, although some systems require the staff to pay for all or part of the mandatory training.
All the above points have a direct or indirect bearing on training policy: the general context, the organization of the different services, the status, mobility and conditions of recruitment...
Observation: The focus here is on the training of supervisory staff, unless specified otherwise, because their higher responsibilities and mobility make them a more complex group. The situation for other staff can be deduced by analogy.
Limits
The training of food safety controllers occurs in a determined political, economic, social, institutional, financial and juridical context. It cannot make up for inadequacies of infrastructure (slaughterhouses, laboratories), of personnel, of resources (vehicles and fuel, thermometers, computers…) or of funds, nor can it mitigate the constraints of a given political or territorial structure. Any consideration needs to take these limits into account, especially when setting the thematic and organizational priorities and planning the way forward.
Some prerequisites seem however essential, especially a demonstrated political will, a structured juridical framework (including the distribution of responsibilities among services, the powers given the controller, etc.), available and updated documentation and standards, and a clear institutional policy to be conveyed (training transmits, but does not generate, knowledge).
Objectives
The primary objective of training is to enable staff to acquire the knowledge, tools and "soft skills" (self-management skills) needed to carry out their missions in their respective service of assignment.
The impact of training can however also be perceived on another level.
If properly directed, training is a service management tool. It is the prime vector for the transmittal of values and a shared culture and for the capitalization of know-how. It should aim to standardized practices and have these develop uniformly. By fostering mutual understanding and a common perception of inherent implications, training facilitates exchange between the central administration and its territorial services or subdivisions. It helps decompartmentalize the action of individual services. Key features include post-recruitment training, workshops for the exchange of practices, the mixing of staff development audiences (services, ministries…) and of training facilitators (speakers), etc.
Training is also an excellent tool for human resources management. The primary objective is to provide staff with the wherewithal for effective, appropriate and thus worthwhile action. Providing cost-free training or making training mandatory (especially for target courses) are fundamental decisions. Consultation and needs analysis will be arranged to secure staff input. Training can be taken into consideration for promotion, remuneration, mobility….
Training opportunities
In summary terms, two types of knowledge need to be transmitted10:
These two types of knowledge can be acquired through three principal routes (section V): prior initial training, post-recruitment training and staff development training.
Scientific and technical knowledge
In theory, the employer can set the level required for recruitment. For example, the employer can insist that applicants have attended a specific veterinary university course, where such a course exist. There is also leverage on the content of university training in the form of international recognition of its diplomas.
In practice, recruitment is influenced by the university teaching available and by the attraction of government service to young graduates. In most countries, shortcomings noted at recruitment point to a need for supplementary training.
A number of solutions can then be envisaged, depending on the context. The first requisite is that staff should have the scientific background to thoroughly grasp the issue of food safety and sanitary production. Veterinarians can be relatively easily trained in the safety of animal-based foods because of their initial training in animal husbandry, anatomy, pathology, physiology, microbiology…
Post-recruitment training is the most common way of bringing staff up to the required level. Ideally, this should be sufficiently long to permit field training in consolidation of the theoretical instruction. The further training can focus on a specific field or type of food if the position to be filled is known.
Specialized training for public officials
Public officials need to have administrative and soft skills in addition to their technical training. These refer to civil, administrative and penal law, economics, finance, national and international public policy…
A period of training close to recruitment offers a number of advantages in terms of effectiveness and the moulding of professional identity. If sufficiently long, such training provides supplementary tools and indicators, instils a service-wide culture and facilitates subsequent mobility and refresher training. If short, it will target skills of immediate necessity. The limit is of course the cost to the administration, regardless of whether the new recruits are paid or not during their training.
Staff development training
Refresher training has become essential in an environment of constant scientific, technical, regulatory, international and other development.
The traditional concept of staff development is gradually adopting the notion of lifelong learning. Training acquired at the start of professional life will not be sufficient to perform effectively throughout a career because of knowledge and occupational developments. Training is thus conceived, from the very outset, as requiring further input during the course of a professional career.
In practice, this training is often along traditional lines, with short, target-specific sessions and rarely any diploma. When there is a need for, or emphasis on, more substantial staff development training, this will be based not only on new requirements, but also on the previous training of staff so that their basic competence can be brought up to date.
Organization
Training structures
Adult training has special characteristics. Beyond conveying an academic or institutional message, the theory needs to be followed up with practice if there is to a long-term impact on performance. This means taking staff expectations into account as well as employer needs. The training can be entrusted to a specialized body which will be in a better position to accommodate the demands of both parties. The employer will define the benchmark competence (the skills needed) while the training body will translate these into an appropriate instruction programme (the learning needed to acquire the skills).
Formal recognition of acquired competence (diploma) can be envisaged if the training is sufficiently long.
Training facilitators
Whether initial training or staff development, and whether organized by an administration, a university or a public administration school, it is very enriching to have a variety of course facilitators: lecturers in life sciences (veterinarians, technologists, hygienists, toxicologists, nutritionists, biochemists…), in law, economics, management, social sciences; representatives of administrations (the umbrella ministry, but also from the ministry of justice, trade, finance, the interior…); researchers; private operators…
Training trainers within the control service, who will be expected to give regular training, will help to spread the training sessions. The trainers will be selected for their specialist skill and their motivation and will receive instruction in face-to-face training. They will need to use standard materials so that the training message can be coherent (transparencies, slides, trainer manual, course book…).
Workshops on the exchange of practices on a given topic (e.g. crisis management) serve to build upon knowledge gained and enrich experience.
Training on the ground
In most cases, staff are only trained for their new post through actual on-the-job exposure. Such empirical training risks perpetuating bad habits, mistakes, compartmentalization and divergent approaches among services. It is worst in those small services, especially in developing countries, where a single poorly trained and inadequately equipped official is assigned to a remote region; he or she would have benefited from advanced training to deal with the host of tasks and responsibilities that go with the job…
Minimal acculturation can be acquired by spending time in a reference service, especially in the central administration.
Tutoring is another way of training new staff. Tutors should be volunteers and if possible selected from outside the service hierarchy (perhaps from another service) and need to be specially trained.
Where veterinary or other officers are responsible for providing initial or further training to their support staff (after having themselves been trained), it is important that this should be properly structured. The constraints lie in the absence of trainer training and in the inability of trainers to step back into the wider picture.
Materials – remote training
Training materials are clearly essential, whether for self-instruction or for in-person training. Many developments are expected from information and communication technologies (ICTs), although their actual content will have to be carefully designed. Remote training does not usually exempt in-person training. One current problem that developing countries face is the availability and fragility of computer equipment.
Nor should traditional printed materials be neglected, especially for officers used to self-instruction (normative texts, explanatory notes, books).
There will need to be complementarity between traditional techniques and new ICTs.
Sharing of training
Training is relatively costly, whether for a restricted audience or for broader dissemination. Hence the importance of rational decisions, the search for leverage, the dispersal of delivery… Several options have been considered above (trainer training, hierarchical training, tutoring, new ICTs, participation in training organized by other countries…).
The supranational organization of training is another possibility. This might be:
A regional approach to food security training has been considered by the countries of sub-Saharan Africa and donors. This approach, which is mirrors the creation of common regional markets, is sustainable in nature as removed from the influence of national political change. The eventual creation of a regional body of food safety veterinary inspectors in the WAEMU11 is a case in point. The Inter-State School of Veterinary Sciences and Medicine in Dakar (EISMV) already provides initial training for veterinarians of the region.
Observation: The developing countries sometimes have to cope with an alarming lack of resources, while most services exercise first-level control. Even though application of the academic HACCP approach does not correspond to traditional practices, using the rationale of the HACCP to identify priority problems and effective solutions can produce results – provided staff are properly trained and there is an appropriate regulatory framework. This would provide a methodology that applies to two major dimensions of food safety regulation, which are sometimes quite distinct in the developing countries: on the one hand, the economic impact, especially in the framework of international trade; and on the other, public health, especially at local or regional level. Such consideration and any resulting innovative training would no doubt be best handled at the supranational level.
Topic areas
The fields of expertise relating to food safety vary extensively. Training topics will need to be selected through multi-factor analysis, including, for initial post-recruitment training, the economic context, existing legislation (for example, first or second level controls), possible subsequent assignments, starting level, expected professional competence (occupational benchmark) and available training resources. A similar approach applies to staff development training, with the inclusion of possible multi-annual planning.
Targeted expertise will depend on individual situations:
For example, a field inspector will need to be able to draw up a report, whereas a worker at the central administration will only need a basic knowledge or even awareness. Similarly, an international negotiator will need to be well versed in the SPS agreement (i.e. have command) while a field inspector will only have to be aware of its existence.
Selected examples by way of indication:
Technical knowledge (perhaps focused on a specific line or phase of production):
Depending on the situation and country or region:
Administrative knowledge:
Soft skills:
Except in extreme cases, the value of a structure resides primarily in its staff. Investing in human resources and especially in initial training and staff development is the foundation of management of a control service.
Training is a means of achieving the objectives assigned a structure or control system. It is closely linked to the context and especially the financial constraints. Thus, while general guidelines can be traced in absolute terms (for example, lengthy post-recruitment training), these are often illusory as too costly, especially in developing countries. There is no universal answer, only lines of action and solutions tailored to each national or regional situation.
One prominent feature of food security is the global context which, since the rupture from the entry into effect of the WTO agreements, has tended to align approaches (professional accountability, HACCP, second-level controls, etc.) and thus to create common concerns. Shared training needs could encourage exchanges, even the introduction of innovative solutions at supranational level.
The developing and least developed countries are particularly vulnerable in the areas of public health and thus food safety: sanitary and climatic conditions combine with traditions and a lack of resources and qualified personnel. Such characteristics need to be taken into account in the context of globalization of trade. With regard to training, this is where there is even more call to start from concrete requirements on the ground and to respect cultural norms, if there is to be a lasting tangible impact.
Many countries rely on skills gained during initial training for their official controls, but these do not always seem commensurate with the task at hand. Knowledge-based training is easier to organize and therefore more frequently organized, while training in the hard and soft skills is more difficult to design. To be effective, such training needs to adopt a particular format and to be spread over an appropriate period of time. There would appear to be few experiences in this regard.
Reference material and bibliography available from the author
1 World Organization for Animal Health/International Office of Epizootics
2 World Trade Organization
3 Cf. Codex Alimentarius, Guidelines CAC/GL No 26 (&24 et seq., &43, &47, Annex), CAC/GL No 34 (Annex) – OIE: Terrestrial animal health code (Chapter 1.3.3: Evaluation of veterinary services)
4 Agreement on Sanitary and Phytosanitary Measures – Agreement on Technical Barriers to Trade.
5 Hazard Analysis Critical Control Point
6 The control of sales outlets is often the responsibility of a different administration.
7 Crops and fishery and aquaculture products might be the responsibility of a different structure.
8 For example: Austria (2002), Belgium (2003), Bolivia (2000), Canada (1997), Spain, Netherlands…
9 BAC: High-school diploma
10 Without ignoring their importance, management and non-specific personal skills are not addressed.
11 WAEMU: West African Economic and Monetary Union