Alison Taylor gave the update.
Brian Wilson advised that there were vacancies on the Scottish Food Advisory Committee and the FSA Board. Alison Taylor would check on the situation.
Action: Alison Taylor
Training: HACCP audit training
FSA Scotland is planning a series of Feed HACCP courses in the New Year, to be delivered by Campden and Chorleywood Food Research Association (CCFRA). A 5-day feed HACCP auditing course is planned which will cover the background to HACCP, prerequisite programmes, principles of HACCP, principles of auditing (including an actual audit) and HACCP planning. The course will be specifically tailored to feed and will assume some existing knowledge of HACCP.
They are also exploring with CCFRA the possibility of a less intensive feed HACCP course which will not assume the same degree of HACCP knowledge.
Alison Taylor thanked those who had responded to emails on this subject in June. Interest in the training has been noted.
The FSA procedure for evaluating training providers was queried by Marzena Young. It was suggested that they request feedback forms from current providers or else obtain feedback from attendees by e-mail following future courses. Alison Taylor asked for concerns to be raised directly with her or with Jacqui Angus.
Action: Marzena Young
Consolidated Guidance on EC Feed Hygiene Regulation (183/2005)
FSA Animal Feed guidance has been revised to include more detailed information on a number of areas.
Animal Feed Stakeholder Meeting - 18 July 2008
A new set of feed additive guidelines had been agreed in December 2007 and published in the Official Journal as Commission Regulation 429/2008. These provide detailed advice on what needs to be included in a new application under EC Regulation 1831/2003 on additives for use in animal nutrition. They also contain advice in respect of renewed authorisations under Directive 70/524/EC of 23 November 1970 (concerning additives in feeding stuffs) and 82/471/EEC of 30 June 1982 (concerning certain products used in animal nutrition), and for silage agents.
Additives for use in animal nutrition also need to be reauthorized to be used and sold after November 2010. There could be delays in the assessment system as it is expected that up to 2,000 dossiers may be submitted.
The Commission plans to distribute a letter to interested parties reminding them of the need for re-authorisation applications to be submitted by 2010.
Animal Feed Law Enforcement Liaison Group (AFLELG) (incorporating the National Animal Feed Ports Panel (NAFPP)) update
AFLELG has established Memoranda of Understanding between LACORS and VMD, and is working on a similar agreement between LACORS and the AHI, on feed hygiene enforcement. Discussions have also started on the coordination of imports controls on animal feed and are being taken forward through the NAFPP which held its inaugural meeting in January 2008. NAFPP mainly comprises UK enforcement officers and is a sub-group of AFLELG. Local authorities with ports are encouraged to join.
NAFPP has proposed that feed law enforcement is incorporated into the Agency’s Guidance and Regulatory Advice on Import Legislation (GRAIL), a web based database which can be found at:
Imported Feed Controls – the FSA has done considerable work in connection with the list of 'high-risk' products of non-animal origin (non-POAO) covered by Article 15(5) of EC Regulation 882/2004 (Official Feed and Food Controls). The FSA has been establishing a framework to effect closer alignment of arrangements for non-POAO with those for POAO. FSA has drawn up a list of 'high-risk' products and has launched a public consultation on this.
Advisory Committee on Animal Feed (ACAF) - current issues
ACAF has so far held two meetings in 2008. The next one is scheduled for 24 September and will include:
- a presentation on the codes of practice for salmonella;
- an oral update on negotiations on the proposed EC Regulation on the Marketing and Use of Feed;
- a presentation on the work of the Farm and Animal Welfare Council and its implications for the animal feed sector;
- a discussion of ACAF’s Forward Work Programme, including horizon scanning.
Proposed EU Regulations on the Marketing and Use of Feed
AFU was conducting a six week public consultation inviting stakeholders' comments on a specific set of questions. It has also liaised with government officials across Whitehall on the formulation of UK negotiating lines on the proposal. An update would be given at ACAF on 24 September.
Proposals for Primary Production visits – Food & Feed
A letter has been issued to local authorities providing an update on the proposed primary production regime in Scotland. The proposal is to allow local authorities to inspect farms within the scope of the respective requirements of Annex 1 of Regulation (EC) No. 852/2004 and Regulation (EC) No. 183/2005 within a single regime of integrated food and feed hygiene inspections carried out according to the current regime for primary production food law. This has been agreed in principle with local authorities but will be subject to consultation in the coming weeks. Local authorities have been asked to consider how they will approach primary production enforcement and to provide that information with costs and training requirements in an application to FSA Scotland. This information will be used to plan resources.
As explained in the letter, the proposed regime will act as a pilot for the remainder of the UK. The letter, which was sent on 25 August 2008 and which contains further details, can be accessed at:
Alison Taylor confirmed that the proposals provided for joint enforcement of both food & feed legislation during a single visit rather than at two separate visits.
Parts of the Food Law Code of Practice concerned with qualifications required to carry out food and feed inspections at primary production level have been redrafted. There was some discussion as to whether this only allowed Trading Standards visits or whether joint Trading Standards and Environmental Health visits could be made. The FSA view is that the redrafting of the Code of Practice allows primary production visits to be carried out by Trading Standards, Environmental Health or Animal Health staff.
A summary of the queries and concerns raised are listed below but it was felt that these should also be submitted as part of the consultation process where appropriate:
- Brian Wilson asked whether the draft English Food Law Code of Practice included Trading Standards competencies in relation to serving of notices. The draft Scottish Food Code did not, and he asked whether it would therefore need amending to enable Trading Standards in Scotland to enforce measures. Alison Taylor would respond.
- Marzena Young felt that the proposed regime will lead to the same regulations being enforced by two different bodies, a subject of criticism in the past.
- Derek Taylor was concerned that the proposal incorporates two-tier training and will lead to two-tier enforcement.
- Kate Connelly was concerned that an application had to be made well before the consultation had taken place.
- Marzena Young asked if some information could be obtained on how the data for numbers of visits was compiled. Wilma Urquhart asked whether or not it took account of quality assurance scheme membership. Alison Taylor would respond.
- Morton Houston queried whether or not we should include in our bids an amount for anticipated revisits. Alison Taylor would respond.
- Brian Wilson was concerned that the proposed risk rating scheme resulting in visits every four or fifty years will lead to markedly less feed hygiene visits taking place in Scotland than in England and potentially the rest of the EU. Since the FSA presumably had a good scientific justification for setting the original risk assessment frequencies for feedingstuffs he asked what had changed to justify the proposed reduction. Alison Taylor would respond.
Action: Alison Taylor