NVWA errors not solved by automation

The automation project of the NVWA has failed. For many companies, the aim of automation is 'efficiency'. But this is of course only possible if the processes themselves are looked at properly first. Because if they are not correct, automation will certainly not solve the problem.

http://Photo by Ilya Pavlov on Unsplash

In the latest NVWA2020 progress report of 9 October 2019, ICT is listed as a risk factor while ICT was previously a goal. The central theme is now that the NVWA wants to work knowledge-driven and risk-oriented in order to reduce risks and increase compliance. These are fine words, but how does it work in practice?

The ICT project Inspect of the NVWA will be terminated in April 2019 by Carola Schouten, Minister of Agriculture, Nature and Food Quality, following a damning following a damning research report. The minister speaks of a 'too ambitious programme'. The aim was to reorganise the NVWA, which since 2012 has consisted of three merged The aim was to reorganise the NVWA, which since 2012 has consisted of three merged parts, with the help of automation. But the three But each of the three divisions already had their own way of working, automation and culture that cannot be merged so quickly. So if you start automating start automating, you're putting the cart before the horse. And that proved to be the case.

The programme has cost far too much money and therefore it is it is now time for a review. In the review, the objectives of NVWA2020 will be revised to set priorities for the coming years. will be reviewed and the priorities for the coming years will be further determined. The approach is based on small, controlled steps that support NVWA staff in their primary work NVWA staff in their primary work: enforcing laws and regulations. And this is And that is necessary, because there are only more (complex) rules requiring even more enforcement. enforcement is required.

NVWA errors due to complexity of rules

For the enforcement of complex rules, the NVWA Veterinary and Veterinary and animal products department uses 'open standards' for the sake of convenience. standards'. A grey area where enforcers can or cannot intervene and where an entrepreneur does not know where he stands. entrepreneur does not know where he stands. For example, 'What are or 'When is a carcass rejected? Then you get Then you get a culture of too much, enough or insufficient enforcement. It is not for nothing that a It is not for nothing that a director of a slaughterhouse in the north wrote a letter to the It is not for nothing that a director of a slaughterhouse in the north wrote a letter to the Lower House asking: "I want my own NVWA official back, because he was never difficult!

This is a major pain point for the NVWA, because they have to deal with employees who do not want to enforce employees who do not want to enforce the law and who come into action for every little thing. And if these actions follow each other at a company, then it becomes difficult. But open standards also provide room for power games. If, for example, an NVWA employee doesn't like an entrepreneur, or an NVWA employee wants to pursue certain (personal) ideals, they can ideals, they can enforce extra. For he who seeks will always find. And who will stop them? This creates an unnatural balance of power that can upset entrepreneurs can go 'crazy'. Lawsuits follow where a lot of time and money are wasted. Open standards may be easy for management management, but in practice they do not work.

NVWA errors due to 'grey areas' legislation

On 14 December, the new control regulation came into force which focuses on risk-based supervision. And that sounds very good. But in practice it can be very complex. A new rule is slaughterhouses that slaughter more than 1,000 livestock units (LUs) per year will be subject to permanent will be subject to permanent supervision, unless a risk analysis indicates otherwise. Cattle older than 2 years are, for example, 1 LSU and sheep and goats 0.15 LSU. In The Netherlands has some 164 small and medium-sized slaughterhouses. Some are below and some are above some are above 1000 LU. But how will this new rule be implemented? When will permanent supervision be provided and when not? How will the explained? Because with these super high tariffs of the NVWA permanent supervision is permanent supervision is economically unfeasible for SME companies in the Netherlands. Entrepreneurs are groping in the dark and want to know what requirements they must meet to avoid not receive permanent supervision. But they get no answer. This This is determined behind the scenes and on an individual basis. Another open standard that can one can go in any direction.

Possible solution for errors NVWA

Perhaps it is time to discuss the 'open standards' within a knowledge-driven within a knowledge-driven consultation where, in addition to the government, a diversity of stakeholders are stakeholders have seats for a transparent discussion. A good example of this is the Regulier Overleg Warenwet (Commodities Act). Developments and ambiguities in The Ministry of Public Health discusses developments and ambiguities in regulations with the NVWA and a variety of experts. These experts represent various companies and sectors. Grey areas are made clear and transparent here. Reports are available on the internet. to be found on the internet.

At the NVWA Veterinary and Animal Products Section, the consultation with the sector is still taking place behind closed doors with a representative of a few sector organisations. Results are only communicated to results are only communicated to members. Conveniently, of course. But is it competent, democratic and transparent? In any case, it is currently leading to a great deal of ambiguity and dissatisfaction. and dissatisfaction.

Published in Vleesmagazine Industry Special - 6 December 2019

Yvon Bemelman