Minutes of Feedstuffs Sub Committee: 11 March 2008

Last updated:
27 January 2010
Meeting held at Pullar House, Perth

Attending
Marzena Young – Perth and Kinross
Robert Watson – South Lanarkshire
Derek Taylor – Fife
Alison Taylor – Food Standards Agency (FSA)
George Begg – (Angus)
Brian Wilson – Scottish Food Enforcement Liaison Committee (SFELC), Stirling
Wilma Urquart – Aberdeenshire
Kate Connelly – Argyll and Bute, SCOTSS
Alison Bannister – East Renfrewshire
Maureen McLarty – South Ayrshire Council, LACORS

Apologies
Jacqui Catteral – Animal Medicines Inspectorate
Steven Thomson – Mid Lothian
Gary Walker – Public Analyst
Mungo Howat – South Lanarkshire, Animal Health

Matters arising from the previous meeting
Ayrshire, Stirling and Aberdeenshire took part in the mycotoxin survey (4.2). Vitamin A, not all vitamins (5.2) Feed Hygiene Risk Assessment Form distributed (7.4).

Update from Food Standards Agency Scotland (FSAS)
FSA funding for imported feed sampling: Four bids received from Scottish local authorities.
Action: Alison Taylor to raise at Animal Feed Law Enforcement Liaison Group.

Feed Law Enforcement Code of Practice Guidance: Currently out to consultation. Comments requested by 14 March 2008.

Animal feed spend 2006/07: FSAS has requested a breakdown of expenditure by 31 March.

Future animal feed funding: now coming directly from Scottish Government (SG). FSAS understands that £325k agreed for feed law enforcement 2008/09. Awaiting written confirmation.

Enforcement monitoring returns: due 18 March. Period will be 1 January 2007 to 31 December 2007. From 1 April 2008 period will be financial year end.

GM rice (Bt 63): EU Decision requiring Chinese imports of rice to be accompanied by certification will apply from 15 April. Implementing legislation, a Scottish Statutory Instrument (SSI) issued for consultation 10 March 2008. (Comment: public analysts can tell if GM material is present but cannot determine the percentage declaration.)

GM rice (LL601): New Scottish Regulations came into force 7 March 2008 [SSI 87/2008]. Letter to local authority enforcement officers will be issued shortly.

Guar gum: Recent Commission Decision will impose testing and certification requirements on guar gum and guar gum products from India.

HACCP training: FSAS hoping to provide courses in Scotland for trading standards officers (TSOs) during 2008. The courses will be based on the EU course for auditing HACCP systems.

Secondment opportunity: FSAS offering short-term secondment opportunity for TSOs. Not yet been decided exactly what this will involve. Contact Jacqui Angus at FSAS to discuss.

Quality Meat Scotland (QMS) membership list: QMS has agreed that they will provide a list of all members of the scheme. The method of distribution has to be determined. (Comment:SQC (Cereals) is already available.)

Secretarial support for SFELC sub-group meetings: Has become apparent that FSAS support has been inconsistent. Meeting to be held 11 April with Jim Thomson. Brian Wilson to attend. (Comment: Sub-group minutes not always being fed up to SFELC or published on FSA website).

Action: to raise at meeting with Jim on 11 April

Forthcoming consultations: The Marketing and Use of Feeding Stuffs Regulations (‘The Feed Labelling Review’) and the Feeding Stuffs (Scotland) Amendment Regulations 2008 (‘Milk Fever’).

Comment: Some feed officers are not receiving correspondence from FSAS. Alison Taylor explained that the database was deliberately restricted to lead food and lead feed officers to ensure consistency. FSAS relies on LAs to notify changes, which need to be submitted in writing.

Action: Alison Taylor to send copies of Animal Feed Spend 06/07 letter and Enforcement Monitoring Returns letter to Alison Bannister and Derek Taylor.

Update from the Public Analyst (PA)
Of the samples submitted, failures were found mainly in nutritional claims.
The 12% moisture issue regarding Copper analysis has been passed to the EU. UK law used to deal with the same issue however EU legislation apparently does not.

High ‘DON’ content found in cereals – pigs appear to be more susceptible.

It was reported that labs will be incurring additional accreditation costs as they prepare to become official feed enforcement labs by December 2009 and it was important that sampling levels were maintained to support this and to enable them to maintain expertise.

This information is to be conveyed to all regional group members.

Animal Marketing Inspectorate update
Joint visits are to be encouraged where possible.

LACORS update
Formal template for submission of minutes of meetings to be discussed.

Previous minutes of the SFELC sub-group have now been submitted for publication on to the SFELC section of food.gov.uk. Issue to be discussed with Kirsten Black (in Ryan Bruce's absence).

Regional groups
East Group: nothing to report.
West of Scotland: written update submitted.
North group: written update submitted.

Feed labelling project completed, findings are to be reported.

Queries raised:

Arable farm, potato/grain production. Sold to processor as food. Inevitably, some produce will be deemed unfit for human consumption, therefore find its way into the animal feed chain. Under such circumstances, is the farmer required to register/provide the statement of compliance?
The legislation states that feed businesses are required to submit a statement of compliance by 1 January 2008. Do new businesses created after 1 January 2008 need to provide a statement of compliance?

Answer: New businesses are required to register (i.e. we are now outside the ‘transitional’ period).

Does the Feed Hygiene Regulation apply to sporting estates rearing pheasants, partridge, wildfowl, managing deer etc.?
Answer: If they provide feed, yes.

LACORS risk assessment scheme requires to be re-assessed – issue to be taken to next LACORS focus group meeting.

Individual officer queries to be channelled via the regional groups to SFELC group and if necessary, to the FSA.

Note: If the query raised is with reference to the legislation, Alison Taylor stated that clarification should be sought from the FSA.

Animal feedingstuffs conference
Possible dates are 16 or 21 May 2008. To be held at Viewforth, Stirling.

Format and speakers to be arranged.

Animal Health
No update.

Feed Law Enforcement Code of Practice (CoP) – Legal Status
Question raised by Marzena Young regarding the legality of the CoP.

FSA are of the opinion that the CoP did not need to be signed by a Scottish Minister.

Issue to be referred to LACORS focus group.

Local Authority Enforcement Monitoring System (LAEMS)
Group members are unsure of where we are with the LAEMS system issues.
Action: Alison Taylor to ascertain progress.

Informal opinion that the transition to the LAEMS system should be relatively straightforward.

SFELC workshops feedback
Regional groupings; it was considered that it is not necessarily the best person who is sent to represent their local authority.

It may have been beneficial to have a Trading Standards Institute and a SCOTSS representative attending.

Every group member should participate/contribute, i.e. opinion, respond to consultations, and so on.

Any other business
Transitional period for the purposes of feed hygiene legislation has now expired. Any new businesses wishing to comply with the legislation as of 1 January 2008 will need to apply for registration as opposed to submitting a statement of compliance.

Date of next meeting
To be arranged.