Overview of the National Standards Authority of Ireland (NSAI)
Structure of the NSAI staff involved in official controls
The Authority is headed by the CEO, followed by a Director of Certification. Underneath this director is the Head of Marketing and Regulatory Support, then Audit and Inspection Officers.
The National Standards Authority of Ireland (NSAI) is Ireland's standards body. The NSAI facilitates the development and publication of voluntary standards and is also responsible for the provision of an independent certification service in respect of certification to nationally/ internationally recognised standards for processes and services. The certification division of the NSAI is involved in the official control of food.
The NSAI is the competent authority for:
- The recognition and exploitation of natural mineral waters bottled in Ireland
- Official controls on the production, distribution and import of food contact materials
Accreditation to ISO 17021, ISO 22003 applies to relevant services within NSAI certification. Schedules of accreditation are available at Management Systems Certification - INAB.
Areas of official controls as defined by Art 1(2) of Regulation (EU) 2017/625
- Article 1(2) Food & food safety (recognition of natural mineral water)
- Article 1(2) Food contact materials.
Delegation of official controls
The NSAI do not delegate any official control tasks to delegated bodies in accordance with Article 28 of Regulation (EU) 2017/625.
Scope of responsibility of the NSAI for the official control of food
The NSAI is responsible for the determination of compliance with legislative requirements in relation to the recognition and exploitation of natural mineral waters, which involves:
- Formal recognition of waters extracted from the ground as 'natural mineral water'.
- Permitting companies to exploit (bottle and place on the market) the natural mineral water from named bore hole exits/extraction point.
- Continual recognition of the natural mineral water by means of surveillance inspections confirming the water continues to satisfy legal requirements.
- Ongoing renewal of permission to exploit by means of surveillance inspections.
- Permitting companies to exploit from additional bore hole exits/extraction points and confirmation of originating source.
The NSAI also has responsibility for official controls in establishments (other than food establishments) that import, manufacture, distribute or supply (other than by retail) food contact materials, in accordance with food legislation. In addition, the Official Agency will also undertake official controls in food establishments that manufacture food contact materials and supply them to other establishments; the scope of such official controls shall be limited to the manufacture and supply of food contact materials. Additional inspections may be conducted for individual operators and their establishments based upon a specific assessment of the results of official controls and other official activities. The Authority and Official Agency will review the inspection frequency periodically in the light of experience gained and legislative changes.
Further information on the NSAI food control activities will be found in the NSAI service contract.
Official Controls
Risk categorisation and frequency of official controls
Risk categorisation for natural mineral waters official controls is based upon historical performance and the number of recognised sources per business. There is a minimum frequency of 1 well sample per well and a 0.5-day inspection per annum. Risk categorisation for food contact materials official controls is largely based upon interactivity with the raw materials and product i.e., manufacturer, convertor, distributor. There is a minimum frequency of an annual inspection for manufacturers, and biennial inspection for convertors and distributors.
The NSAI has a comprehensive risk register that covers all aspects on NSAI activity, including responsibilities associated with the role as a FSAI delegated competent authority. The risk register is reviewed on a quarterly basis by NSAI senior management and is managed by NSAI Corporate Services. The risk register and associated mitigation plans are not publicly available.
Methods of official control
The NSAI carries out inspection and verification activities in accordance with legislative requirements, the requirements of the service contract between the NSAI and the Food Safety Authority of Ireland (FSAI) and the NSAI annual business plan.
The NSAI carries out inspections for the initial recognition and permission to exploit natural mineral waters, as requested. The NSAI carries out surveillance inspections of all natural, mineral water producers to ensure legal requirements with respect to recognition and exploitation continue to be met. The NSAI takes samples of source water from each company for microbiological and chemical analysis.
The NSAI carries out official controls, via inspections, on businesses which manufacture, distribute or import food contact materials. When directed by the FSAI, the NSAI will collect samples of food contact materials for laboratory analysis.
The NSAI's Strategic Plan 2016 - 2020 is available to download from the NSAI's website.
Recording of official controls
Performance and outcomes of official controls are recorded in inspection reports that are provided to Food Business Operator (FBO) and FSAI. Reports are provided to other groups as required and being cognisant of Freedom of Information (FOI), General Data Protection Regulations (GDPR) and proprietary information.
There were over 80 inspections carried out by the NSAI in 2019 and almost 40 in 2020.
Resources and Facilities
Staffing resources
Staffing resources that the NSAI has agreed to provide for the official control of foodstuffs are included in the service contract between the FSAI and the NSAI. Staffing figures are reported annually in the Multi-Annual National Control Plan (MANCP) report. In 2020 five whole-time equivalent posts were filled in the NSAI in the area of food safety. Training needs are identified through departmental meetings which prompt discussions on experiences during inspections.
There is also a formal annual review of training needs, with ongoing professional development as needed and as opportunities present.
Training plans are implemented through fulfilment of training needs, coaching, mentoring and feedback.
Competency and training records are in place and competency assessment processes are in place with annual review linked to auditor performance. Customer feedback is also used to evaluate training and competency.
Laboratory resources
The NSAI has an arrangement with official laboratories from the Health Service Executive (HSE) to carry out the analysis of samples taken for official control of natural mineral waters.
IT resources
The NSAI has its own information technology service.
Regulation (EU) 2017/625 (General Obligations)
Article 5(1)(a) Effectiveness and appropriateness of official controls
Audits and auditor interaction.
Article 5(1)(b) Consistency in the delivery of official controls
The NSAI employ a small, well trained, highly experienced team to carry out official controls.
Article 5(1)(c) Ensuring staff performing official controls are free from conflicts of interest
Declarations of conflict of interest are submitted annually.
Article 5(1)(d) Access to adequate laboratory capacity
The NSAI utilise laboratory services as directed by the FSAI.
Article 5(1)(e) Access to suitably qualified and experienced staff
Open recruitment, training and ongoing professional development.
Article 5(1)(f) Access to adequate facilities and equipment
The NSAI have well-resourced infrastructure.
Article 5(1)(g) Ensuring staff have adequate legal powers to perform official controls
Staff involved in official controls are warranted as authorised officers by the FSAI.
Relationships, Memoranda of Understanding and Service Level Agreements with other Competent Authorities
The NSAI does not share responsibility for official controls with any other competent authorities in relation to their work in recognition of natural mineral waters or control of food contact materials.
The NSAI does not delegate any official control tasks to delegated bodies or natural persons in accordance with Article 28 of Regulation (EU) 2017/625.
Communication procedures
The SFPA have the following measures in place to ensure effective and efficient communication:
- Within the NSAI
- Regular departmental meetings
- Auditor meetings
- Staff briefings
- Townhall meetings
- With the FSAI
- Scheduled liaison meetings
- Sharing of data through data transmissions and an annual report
- With other competent authorities and the FSAI
- Cross-agency meetings with competent authorities.
Documented Procedures
Availability of documented procedures to SFPA Staff
Documented procedures are available to NSAI staff via a central electronic document depository accessible through secure internet.
Availability of documented procedures to the FSAI & Auditors
The central competent authority (FSAI), other competent authorities, organisations involved in auditing and the European Commission are provided with soft copies of documented procedures upon request.
Reviewing & updating procedures
Documented procedures are owned by the scheme technical managers, who update them as required.
Audit
Internal audit
The NSAI Internal Audit function is responsible for the NSAI's internal audit schedule.
External audit
The FSAI conduct audits of the NSAI as per the service contract.