Last updated on 5 March 2010
Minutes of Feedstuffs Sub Committee: 12 June 2007
Meeting held at OFT Offices, 23 Walker Street, Edinburgh EH3 7HX.
Alison Bannister (East Renfrew)
Marzena Young (Perth and Kinross)
Robert Watson (South Lanarkshire)
Mungo Howat (South Lanarkshire, Animal Health)
Kate Connelly (Argyll and Bute)
Maureen McLarty (South Ayrshire, LACORS)
Angela Blair (SCOTSS)
Andrew Mackie (APAS)
Alison Middleton (FSA Scotland)
Brian Wilson (SFELC, Stirling)
Welcome, minute-taking duties and apologies
Apologies were received from Stephen Thomson (Mid Lothian) and Jackie Catterall (Animal Medicines Inspectorate).
Matters arising from minutes of previous meeting held on 2 February 2007
Angela Blair advised that the Road Haulage Association (RHA) letter had been sent and that the procedure for hauliers to register is now in place.
Maureen McLarty passed round a sample feed premises visit pro-forma. LACORS will also put this on its website. She will also send it round to group members electronically.
Action: Maureen McLarty
Mungo Howat asked about the Convention of Scottish Local Authorities (COSLA) risk assessment forms, which Animal Health Officers already use. Mungo Howat would send this form to Maureen McLarty.
Action: Mungo Howat
Mungo Howat mentioned working towards a framework agreement with Animal Health and Welfare Group. Brian Wilson thought that there should be additional forms, for example for mills and feed premises, and that the animal health form could be a part of this. Marzena Young thought that more details were needed for businesses that are primary producers. However, the form that had been circulated was fine for Annexe 1. Alison Middleton asked if LACORS had done anything similar; also whether England had equivalent groups. Angela Blair advised that a number of English local authority regions were setting up feedstuffs groups for the first time.
Reference should be made to Animal Feedstuffs Project Board and not Guidance Board.
Maureen McLarty asked about HACCP training, which she felt should be the equivalent of Level 2.
Marzena Young asked about Food Standards Agency (FSA) input to the Risk Assessment Scheme (RAS). They effectively have a negative rating which has not been updated. Angela Blair advised that the Local Better Regulation Office (LBRO) now have responsibility for RAS.
Under 'Cash sales for traceability' the sentence referring to application to non-domestic animals should be removed.
Maureen McLarty did not know whether details of grouping of port authorities had been circulated. Alison Middleton will speak to LACORS.
Action: Alison Middleton
Brian Wilson asked about the survey of Animal Health officers working in Trading Standards. Angela Blair advised that the last total was 59.29 Full Time Employees (FTE). This figure was skewed by some authorities naming a large number staff as FTE. The new obligation for 10 hours CPPD may affect future collation. Brian Wilson thought it might be worth this group organising a national conference. Maureen McLarty thought its remit was too narrow. Kate Connelly was asked to raise this point later. Angela Blair asked if she should try to revisit the statistical return. Kate Connelly suggested raising it as an item at the next Society of Chief Officers of Trading Standards in Scotland (SCOTSS) meeting.
Action: Angela Blair
Selection of a permanent representative to the SFELC
Brian Wilson was appointed as the group representative to the SFELC. Kate Connelly will be his deputy.
Update from the Food Standards Agency
Alison Middleton went through the report.
Code of Practice Level 1 training
Feedback was received on the Code of Practice Level 1 training courses in Glasgow and Dundee suggesting that future training should be more practical. Forty-five officers had been trained. A question was raised as to whether a further training course was needed. Maureen McLarty pointed out that training needs to be for enforcement officers rather than chief officers. Maureen McLarty also asked about the previous 'Introduction to HACCP' and asked Alison Middleton to see if there were any details on this.
Action: Alison Middleton
Alison Middleton will work with Angela Blair on a further Level 1 training course for 2007 and Level 2 training will be organised following this.
Action: Alison Middleton/Angela Blair
Lack of qualifications at Level 2 is now an issue arising during FSA audits. There was a question as to whether there should be a testing element. There does need to be a separate HACCP element in the training along with quality systems. Kate Connelly thought that a compulsory examination may provoke tension and that an informal evaluation might be better.
Animal Feed Funding for 2008/9
There was a possibility of a further £175k on top of the £325k already allocated for feed standards and hygiene. The additional funding was to meet the new statutory requirements for on-farm inspections. Funds will be split on the same basis as the current allocation.
Alison Middleton attended or observed at the following meetings:
Animal Feedstuffs Project Board: Community guidelines are available on good practice. Areas are published in the Official Journals. The consultation exercise on the draft guidelines to good practice closes on 21 June.
Dioxins in PCBs: Alison Middleton noted that advice was very late in the local authority planning cycle and was not properly funded. There had been seven bids from local authorities. Sampling work would begin in the autumn on feedstuffs samples. Marzena Young thought that the first sample was due by the end of July.
An animal health stakeholder meeting was due to be held on 20 July.
Animal Feedstuffs Enforcement Liaison Group (FSA):
- Guidance had been issued on the EC Regulation on requirement for feed businesses to notify competent authorities of non-compliance.
- State Veterinary Service (SVS) gave an update on BSE controls in relation to the feed ban. Progress had been made and recommendations had been addressed.
- A Memorandum of Understanding between AMI and local authorities for inspection of approved premises had to be finalised.
- EC Regulation on feed hygiene requires competent authorities to make lists of premises available. A letter on this had been sent by Tim Franks. The options are (i) publication on websites or (ii) provision of a local authority contact.
- Monitoring data and inspection returns: there had been 26 responses from Scotland. Alison Middleton had written to the outstanding authorities. Results will go into the National Control Plan.
- National Control Plan guidance was gleaned from local authority data. The Veterinary Medicines Directorate asked for guidance on RACIV procedures.
- Imports on maize gluten and brewer’s grain from USA: there was new EC guidance on this. Member states are now required to conduct random testing. There was a possibility that this had now been superseded and revoked.
- Zinc sulphate trace elements from China were causing contamination. Analysis documents from countries of origin must have a heavy metal statement.
- The next meeting was scheduled for 7 September.
Meeting of Scotland Wales and Northern Ireland Animal Feedstuffs Unit:
- Key areas were ingredient listing, labelling and pet food analysis. There were proposals for EU directives to be amalgamated.
- Consultation on Feed (Specified Undesirable Substances) (Scotland) Regulations 2007. Copies are already getting through to local authorities. Alison Middleton will forward this.
Action: Alison Middleton
- Review of Code of Practice on Feed Law enforcement
- An imported feed controls visit by the Food and Agriculture Organisation to Felixstowe deemed it necessary to obtain more information on ports where feedstuffs were controlled. There was a question as to whether the information on ports needed to be updated. Alison Middleton will contact Les Bailey.
Action: Alison Middleton
- FSA/Scottish Executive Environment and Rural Affairs Department (SEERAD) data sharing: this is now about to start with problems apparently resolved. Brian Wilson asked about getting the information on the Food Surveillance System (FSS) database.
The Advisory Committee on Animal Feeds: this was also attended by Tony McAuley on behalf of the Society of Chief Officers of Trading Standards in Scotland (SCOTSS):
- The impact on the animal feeds industry of increased production of biofuels was discussed.
- There was a presentation on aquaculture.
- Food Standards Agency Scotland (FSAS) thanked Midlothian Council and SCOTSS for their help in organising visits.
- Roisin Dillon asked about funding future training event on biosecurity for Trading Standards. Feedback was due from FSAS on this.
- The was no requirement for on-farm HACCP for on-farm mixers.
- Percentage declaration guidance: existing legislation is for compound feed to have 15% tolerance for declaration. A question arose as to whether this stifles competition and generates trade secrets. There would possibly be a change to descending ingredient declaration.
- Melamine in wheat was added to give extra protein. Member states asked to put procedures in place to monitor imports. FSA identified Falkirk as an import point. They are reporting back to them on a weekly basis.
Kate Connelly thanked Alison Middleton for her report and asked in future for this to be provided in advance of the meeting if possible.
Update from Public Analysts
Andrew Mackie reported that analysts were still waiting for information from FSA concerning specific accreditation and tests.
FSA would provide funding for method development of testing. Information was to be collated from across the UK.
The Food Surveillance System (FSS) database was still being used. There was not a great deal of information on samples available on the database. It would be good to start trialling this.
Andrew Mackie asked about vitamins. Brian Wilson advised that they were not on the current FSS database. Maureen McLarty said that this had been brought to the attention of the FSS.
There would be a move to the electronic reporting of results. Brian Wilson noted that Glasgow had been reporting results scientifically and that this had gone to the manager rather than the operational officer. Maureen McLarty said that Glasgow FSS sends all test reports to her and that she acts as the liaison point to receive all test reports back. This worked well for her local authority.
Update from Animal Medicines Inspectorate (AMI)
There was no report from AMI.
Update from the LACORS Feed Focus Group - Maureen McLarty
Maureen McLarty would provide a short report in advance of future meetings as agreed.
Ron Cheesman was to write about an attempt to 'relax' the training requirement as discovered by LACORS.
There would be a consultation on undesirable elements in pesticide and maize in brewers grain.
There was very little coming in connected to the melamine issue.
A list of registered premises is to be kept on a local basis. ENF/A/07/016 contains guidance on how this information is to be kept. It would be kept on the FSA website for England.
LACORS did not have the resources to run a ports panel and would organise something regionally.
All officers would have to undergo Level 1 Code of Practice training.
Paragraphs 1 to 12 on qualifications suggest that if officers have experience there is no need for Level 1 training. This advice was for those who lacked qualifications but would be relaxed. Brian Wilson questioned the need for this. Angela Blair was keen to keep the TSI aware of this as a live issue. Alison Middleton asked her to arrange for a consultation through the FSA.
Action: Angela Blair
A question was raised as to whether farm premises still have to be registered with the local authority if they are registered under any other official scheme. The advice was that a declaration was needed. It was agreed that all premises should at least advise local authorities of their position by means of a declaration and that, if no appropriate return is received, they should be subject to follow-up visits.
Report from regional Quality Systems groups
West group - Alison Bannister reported on updated benchmarking on policies and procedures. A sampling plan had been set up. All will use the FSS net from this sampling year. Renfrewshire was aware of a food and feed sampling premises that was registered for food on the understanding that there was no need for anything other than a declaration and that there was no need for further inspection. Marzena Young thought that Environmental Health might treat this as waste product premises that was not to be inspected by them. Alison Middleton would take the matter back to FSA in London for clarification. Maureen McLarty had also produced guidance which was to be circulated.
Action: Maureen McLarty
East Group - Brian Wilson reported that the next group meeting was scheduled for the end of June in Haddington. Jackie Catterall will do a presentation. He had asked FSS for Trading Standards training under the FSS net. FSA had agreed to provide expenses for this. The training had taken place and had been well received.
North Group - Marzena Young reported that an analyst had been surprised at the request for details of hydraflouronic acid in the control plan.
There had been problems with organic and non-organic compounds in feedstuffs.
The group would be working on a labelling project.
Moray Council, as a token of best practice, has distributed a Code of Practice implementation plan. This would be distributed further.
Action: Marzena Young
A proposal for mutual visits with Quality Meat Scotland had been declined by them.
Quid had made declarations that percentage banding of ingredients can be used.
A change in legislation on copper in feeds was to be made as current declarations are too high.
Animal Health and Welfare - Mungo Howat
A change to the Animal Health and Welfare Act has provided new powers for local authorities who have been slow to sign up to the new measures.
A Memorandum of Understanding with the Scottish Society for the Prevention of Cruelty to Animals (SSPCA) has not been signed by many as yet.
A strategy paper has been drawn up looking at additional funding for Animal Health officers.
Mungo Howat had spoken to Quality Meats. There was not an established Scottish contact to consult on visits to farm assured premises.
Environmental Health Officers may have been given training on pesticide residues for on-farm inspection. There was concern about overlap and the need to reduce burdens and avoid duplication. Alison Middleton was aware of talks between SEERAD and Animal Health in England. There was a recognised need to establish joined-up working procedures. Maureen McLarty would take proposal for this up through LACORS and Alison Middleton would follow this up with FSA nationally.
Action: Maureen McLarty/Alison Middleton
Kate Connelly thanked Mungo Howat and asked to have Animal Health and Welfare as a standing item on the agenda.
FSS database update
Training would take place for local authorities in July.
Any other business
Angela Blair asked for inspection reports advice to be followed from item 2.
Brian Wilson mentioned an Animal Health and Welfare panel conference and asked about the possibility of a feedstuffs annual conference. Kate Connelly suggested that this should be discussed more fully at a later date. Angela Blair to advise SCOTSS.
Action: Angela Blair
Robert Watson asked about the risk assessment for on-farm visits. Alison Middleton had received a response on this.
Alison Middleton thanked the group for their support while she had been in post.
Date and venue for next meeting
This will be decided after the next SFELC meeting.