Compliance

Traceability of grain used for malting is possible from a batch of malt right back to the farmer or merchant that the grain in silo has been bought from. The major reason for record keeping through this supply chain is to ensure that we are effectively managing the risks to assure food safety. Therefore we take great care to set standards for pesticide application and pesticide residues, mycotoxins and heavy metals. These are considered the major potential risk areas for grain. In addition to setting out our requirements we carry out tests at intake to the maltings and other due diligence testing to confirm that our grain is food safe.

How good is our traceability system?

We can trace the barley used in malting back to the malting process, then to the silo. In the silo many deliveries from farmers and merchants are combined together hence traceability of an individual delivery is not possible. However, we require all our grain for malting to be delivered by members of an Assured Scheme. Schemes such as the Assured Combinable Crops Scheme (ACCS) or Scottish Quality Cereals (SQC) are run by an external accredited organization. If a farmer is found to comply with the correct use of grain treatments and storage they will be issued with an ACCS membership number. The farmer is supplied with a certification sticker showing his membership number. This sticker has to be affixed to the delivery paperwork otherwise grain will be rejected at intake. In addition to the assured scheme sticker the farmer or merchant must supply a certificate showing what if anything has been applied to the grain post-harvest – a Post-Harvest Pesticide Application certificate.

We have on a number of occasions proved that we can trace from a batch of malt back through the malting process back to the original intake documentation showing analysis together with confirmation of the farmer’s membership of an assured grain scheme. Traceability is maintained within our system using unique batch reference numbers and product codes. The traceability exercise takes us on average less than 2 hours.

Farmers are only allowed to use chemicals that are approved for use on malting barley. In the UK we take great care to assess the pesticides that are used on malting barley. The organization called the British Beer and Pub Association (BBPA) together with Campden-BRi carry out a survey of all the possible pesticides that can be used and publish a list of those chemicals that have been shown to have no effect on malting and brewing. The approval is based on practical malting and brewing trials and a comprehensive survey of worldwide literature. The literature covers applications of pesticides in different countries, toxicity data if it exists and brewing trials where pesticide has been applied at twice the maximum permitted limit. If there are no toxicity concerns and there is no effect on malting and brewing process and analysis, both conventional and sensory, then the pesticide is included on the BBPA / Campden-BRi list.

The BBPA/Campden-BRi list contains many chemicals that are assigned Maximum Residue Levels (MRL) based on EU law where applicable. However, many of these pesticides are only applied to the leaves of the barley when growing and do not persist onto the grain at harvest. Therefore it is likely that in the future a revised list of pesticides that should be tested at intake will be developed. Only those pesticides that can persist onto the grain need be tested for residues.

A risk based analysis of the pesticides in the malting process indicates that barley at intake should be sampled at specific rates which are determined according to the risk of occurrence and persistence. Sampling rate is determined on the basis of risk for all the participating malting companies in the MAGB with individual companies contributing results based on intake tonnage. Muntons operates according to this testing schedule and submits samples to an accredited laboratory for pesticide residue testing. We also carry out regular mycotoxin and heavy metal analysis, again on the basis of risk of contamination.

All our due diligence results for the past few years show that there are no residues above the MRL for any pesticide tested. Heavy metals are all well below the maximum permissible limits.

For mycotoxins, because the likelihood of occurrence is largely linked to prevailing weather conditions at harvest and is a feature of the agricultural practice for the country; all maltsters in the UK submit samples via the Maltsters Association of Great Britain (MAGB) for collaborative testing. All our results for recent years confirm that levels of mycotoxins in our grain, and for the UK as a whole, are well below the permissible limits.

If you wish to learn more about the testing and due diligence on UK malt please visit the website of the Maltsters Association of Great Britain on: www.ukmalt.com

The occurrence of mycotoxins due to mold growth is controlled in five ways:

1. By drying grain to below 14% before storage
2. By our due diligence testing
3. By visual inspection of the grain at intake
4. By smelling the grain at intake
5. By monitoring temperatures within the storage silos

Visual inspection of the grain at intake allows us to see any grain that has fungal contamination. Smelling the grain too is a very sensitive way to detect mold. At Muntons we also use internal sensory checks for our intake operators to regularly confirm their ability to smell the moldy aroma. Operators are required to inform us if they have a cold so that they use a deputy to smell the grain since this is an important control check.

Drying of grain to 14% prior to storage puts the grain into a safe environment where mold is unlikely to grow. When stored in silo we monitor the temperature. A rise in temperature over 2-3 days may indicate fungal growth or insect contamination. In this case we can either blow cool air through the silo or use phosphine gas to stop further growth. A professional external company puts the phsophine gas into the silo. Phosphine is very effective at controlling infestation and leaves no residue on the grain.

All our raw materials are bought on an agreed specification. The specification is agreed with the farmer or merchant every year via our ‘Terms and Conditions of Purchase’. This document is reviewed annually.

All our suppliers for grain have to be approved as part of our ISO 9001:2000 system. The approved list is reviewed annually just prior to harvest. Approval is based on the supplier’s acceptance of our Terms and Conditions, membership of an approved supply scheme, and their delivery and general performance record over the past year.

Suppliers may be required to submit a pre-delivery sample for evaluation. However, even if a supplier is approved and has submitted an acceptable pre-shipment sample, our acceptance of a load at intake is based on our analysis of that specific load.

Certification by Other Food Safety Assurance Schemes

Muntons Malt takes Food Safety very seriously and we have become certificated to two

important standards that assure Food Safety:

British Retail Consortium Global Standard – Food (BRC)

Assured UK Malt (AUKM)

Both these standards have a comprehensive HACCP system as the backbone of the requirement. Muntons Malt use multi-disciplinary HACCP teams consisting of production, laboratory, technical, engineering, microbiological and management members to fully protect our products and systems.

The BRC standard was developed by large supermarket operators to provide them with the assurances that they needed from suppliers of raw materials for human consumption. It is a very detailed audit of hygiene practices and food safety control measures.

The AUKM standard was developed jointly by maltsters within the UK to document the very significant level of food safety assurance that we have had for many years, and to set standards for sustaining this high level. It is a scheme audited by an external body (Campden and Chorley Wood Food Research Association).

Both BRC and AUKM require that there is excellent traceability throughout our system both backward to the farmer and forward to the consumer.

Appendix: Risk assessment criteria to explain due diligence sampling

Sustainability is the common objective that links all aspects of Muntons business activities. Our objective is to minimize the impact of our business activity on the environment wherever possible. This is achieved by talking with our suppliers to ensure that they likewise take their corporate social responsibility seriously. Muntons has an underlying and long-standing commitment based on the belief that business can be both profitable and responsible. This is achieved by building long-lasting relationships with our employees, across the supply chain and with the local community.

Muntons keeps abreast of legislation through links with professional and trade bodies, official Internet websites and business and case law updates. Compliance with laws on health and safety, environment and other applicable law are given high priority at executive level via review at our board meetings. We share our information through SEDEX.

Click here for Quality and Food Safety policy

Muntons plc is an equal opportunity employer with respect to race, religion, sex, color, physical ability, marital status and age as described in our staff handbook. We do not tolerate sexual harassment or bullying at work.

Muntons plc has a high regard for the health and safety of its employees. A Company director is responsible for Health and Safety implementation within the group, shadowed by a non-executive director. We also have a diploma-qualified Safety Advisor. At each of our sites we have local safety representatives appointed by the unions and representatives of employee safety selected from our workforce. These are organized into committees meeting monthly. Performance is monitored and reported at divisional board meetings each month. We are members of the British Safety Council.

Muntons plc has an ethical purchasing and supply policy. When purchasing on behalf of the Company, employees are always expected to act professionally and selflessly and be fair, ethical and legal. The same standards apply to our vendors. We monitor our suppliers for their CSR initiatives.

Muntons plc values its reputation for ethical behavior and for financial probity and reliability. It is our policy to conduct business in an honest and ethical way, without the use of corrupt practices or acts of bribery to obtain an unfair advantage.

We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our business dealings and relationships. We follow the law of the UK Bribery Act 2010, in all our markets.

Muntons plc takes great care to ensure that employment terms and conditions are fair and equitable. These are also reviewed with our union representatives and legal advisors. Wages are set with reference to market rate for the job. Advancement of employees within the Company is encouraged by giving access to internal and external training as appropriate for the job and for wider personal development within their chosen career. We always advertise vacancies within the Company before looking externally. We are compliant with the Working Time Directive and closely monitor the hours that our employees work. We support many local and national educational initiatives.

Muntons is passionate about environmental protection. We have environmental standards ISO14001 and ISO50001 and have won many sustainability awards. We consistently outperform our Climate Change emissions targets set by government through a comprehensive carbon reduction program drawing on numerous initiatives throughout the supply chain. We strongly champion carbon reduction in the supply chain and are members of the Sustainable Agriculture Initiative and the Centre for Excellence for UK Farming.

We supply into the food and beverage industries and take hygiene very seriously. All our employees are trained in basic food safety and hygiene with specific reference to the production of malt and malted ingredients. Our plants are certificated to British Retail Consortium Global Standard Food at the highest ‘A’ grade and to ISO22000 and the American Institute of Baking and the externally accredited Assured UK Malt standard. We are certificated to provide Kosher and Organic products. For the protection of the food supply chain we only purchase grain from approved suppliers and the Feed Materials Accreditation Scheme (FEMAS) to protect the co-products we sell as animal feed.

In light of the uncertainty surrounding Brexit, we are doing all we can to mitigate any potential risks which may arise.

To that end, we are delighted and proud to announce that our application for MUNTONS PLC to be granted AEO (Authorised Economic Operator) status has been approved by HMRC.  Our certification will be effective from 01/07/2019. The logo shown is the official AEO logo of the European Commission and, as an AEO certified business we are now entitled to use this logo.

AEO is a status which exists across the UK and Europe.  It is designed to introduce security measures with the purpose of securing the international supply chain. It achieves this by preventing smuggling, tampering, false documentation, identity fraud and theft.  The benefits include simplified customs procedures and the possibility of fast tracking shipments in some cases.  Our customers will benefit from the peace of mind associated with such an accreditation.

As a company involved in the international supply chain, we must ensure that all cargo we control is safe and secure at all times.  Having the AEO accreditation will guarantee a secure transit and ensure we are recognised as ‘trusted traders’.  In addition, it is crucial we ensure we are fully compliant with customs rules in order to avoid penalties.

Gaining AEO accreditation will also give Muntons easier access to any facilitation or simplifications that HMRC may introduce in an attempt to prevent delays at Channel ports in the event of a ‘No Deal’ situation.  It is likely that access to such facilitations will only be granted to ‘Trusted Traders’, so achieving AEO has elevated Muntons to trusted trader status with HMRC.

We will continue to closely monitoring all updates from HMRC regarding the possibility of a ‘No Deal’ Brexit and have undertaken additional Customs training to enable us to deal with the re-introduction of Customs declarations on goods moving between the UK and the EU.