Last updated on 29 March 2010
Minutes of Feedstuffs Sub Committee: 28 January 2009
Meeting held at Municipal Buildings, Corn Exchange Road, Stirling
Welcome, minute taking duties and apologies
Kate Connelly (SCOTSS, Argyll & Bute)
Maureen McLarty (South Ayrshire, LACORS)
Jacqui Angus (FSA)
Marzena Young (Perth & Kinross)
George Begg (Angus)
Brian Wilson (SFELC, Stirling)
Stephen Thomson (Midlothian)
Alison Bannister (East Renfrew)
Jane White (Glasgow Scientific Services)
Robert Watson (South Lanarkshire)
No apologies had been received.
Minutes of previous meeting
Update from the Food Standards Agency, Training: HACCP audit training: a query was raised as to why Marzena Young had been named for action. This was because the matter in question had been referred back to Marzena Young following Alison Taylor’s request that any concerns be raised directly with her or Jacqui Angus.
Arrangements for SFELC Workshops
Kate Connelly reported that the workshops, originally planned for February, were now scheduled to be held on 2 April. The basic information had been sent out and there were to be three themes: compliance; National Food Policy Scotland and healthy living. The venue would be the Grosvenor Hilton in Glasgow and the draft programme would include one-hour presentations on each of the three topics followed by a one hour-workshop before and after lunch. This would be followed by feedback.
There was a brief discussion on the relevance of the themes and the inclusion of healthy living was questioned. Information had only been sent out to potential delegates at this stage and more details on the workshops would be available following the SFELC meeting on 6 February. It was important to make the most of these workshops. There was also the possibility of working the subject of primary production into one or more of the themes. Jacqui Angus said that the National Food Policy Scotland topic was a Scottish Government promotion, possibly based solely on food. Kate Connelly said that there were new issues on compliance relating to primary production and Brian Wilson asked how this was being handled in England by Trading Standards. Marzena Young said that she could not see how the topic of healthy living could tie in with enforcement. Jane White said that Environmental Health in the West of Scotland might be looking at the issue of healthy living.
There was no other feedback from SFELC.
Update from the Food Standards Agency
Jacqui Angus referred to her previously sent report and to the notes on The Feeding Stuffs (Scotland) Amendment Regulations 2009 which were to come into force on 5 March 2009.
The Feed (Hygiene and Enforcement) (Scotland) Amendment Regulations 2009
These were in draft form and would amend the 2005 Regulations to allow Scottish Government Rural Payments and Inspections Directorate (SGRPID) staff to carry out feed hygiene inspections. A consultation exercise is to take place on 20 February with a three month deadline for responses. The Scottish Government want SGRPID staff to perform cross-compliance inspections on farms. In terms of qualifications, enforcement officer training requirements will be similar to those for Food Hygiene.
The Feeding Stuffs (Scotland) Amendment (No.2) Regulations 2009
These Regulations have been drafted to set maximum permitted levels for a range of coccidostats and histomonostats in feed. They have to be implemented by 1 July and go out to consultation. Kate Connelly asked if we might sample for these substances in future. Jacqui Angus stated that we would be able to do so. Marzena Young stated that currently there was zero tolerance for levels of these substances but that this was not practical. Presumably tolerances would have to be set. Jane White stated that they were not routinely tested for and would respond on this issue. Marzena Young stated that industry were likely to be looking for regulatory limits.
Action: Jane White
Food Law Code Of Practice
Jacqui Angus referred to her report on this subject. The consultation had ended, with 20 responses received, 14 from local authorities (Stirling & Clackmannanshire having submitted a late entry). There was a majority supporting joint risk rating, but little support for the qualifications proposals or the timescale allowed for obtaining qualifications. The consultation responses were still being analysed.
The qualifications issue was being considered and might be taken out of Annex 10 of the CoP altogether, with lead feed/food officers having to ensure that any officer enforcing primary production Food and Feed Law is competent. There would be no lead officer for primary production and responsibility would lie with the individual Food and Feed lead officers. There was a primary production contact for each local authority who might not necessarily be a lead officer. Brian Wilson asked why there was a difference regarding qualifications in Scotland. Jacqui Angus stated that in England and Wales, Trading Standards Officers (TSOs) enforce food legislation, which is not the case in Scotland. George Begg stated that in England and Wales, TSOs enforced food standards, not food safety, which were not the same things.
Brian Wilson stated that Scotland’s Environment and Rural Services (SEARS) did not currently apply to farms, and local authorities were having to reduce visits. He thought that it was surely up to local authorities to decide on the work that they do.
The meeting then discussed the difference between Scotland and England and Wales in relation to TSOs and food enforcement. Brian Wilson explained the current state of play regarding qualifications. Kate Connelly said that they should be arguing the case with their Directors and that this was not a function of the FSA. Marzena Young stated that TSOs were authorised to inspect feed producers for approvals and questioned why there should be a problem with their qualifications to inspect primary producers. Kate Connelly said that the FSA was trying to resolve the conflict in this area by allowing local authorities to appoint staff. Jacqui Angus said that the FSA were trying to maintain a balanced approach to this. Robert Watson stated that he had spoken with his Environmental Health counterparts and that they were quite happy for TSOs to do this job. Maureen McLarty said that South Ayrshire were conducting joint visits to 'test the water'. Stephen Thomson confirmed that Midlothian were also doing this. Maureen McLarty asked whether they could simply obtain the food competence module of the qualification.
Brian Wilson asked why food officers should be given the task of deciding who is competent to conduct primary production food visits on farms. FSA seemed to be giving Environmental Health the lead role in this. It was clarified that the lead food officer should determine who is competent to carry out the enforcement of primary production food hygiene and that the lead feed officer should determine who is competent to carry out enforcement of primary production feed hygiene. Kate Connelly stated that expressions of concern ought to come from their professional body, the Trading Standards Institute (TSI). Alison Bannister asked whether the lead officer grade for primary production was being removed and whether only lead officers for food and feed would remain. Jacqui Angus replied that this was the case. Brian Wilson thought that this was the FSA effectively saying that it is the lead officer for food hygiene that has the authority, and that there was a risk that Environmental Health would declare that TSOs are not competent to enforce any food aspect of sampling or seizing on farm: change was not the responsibility of the FSA and he believed that the 2006 consultation document had been totally ignored.
Brian Wilson questioned whether the Code of Practice consultation was compliant as the questions did not appear on the FSA website. Jacqui Angus confirmed that the questions did appear in the main text of the website.
Marzena Young stated that the qualifications aspect was a significant change and asked whether there would therefore be further consultation on this.
Jacqui Angus would respond.
Action: Jacqui Angus
Jacqui Angus would confirm that the feed audit scheduled for 15 June 2009 for England, Wales and Northern Ireland, would not take place in Scotland.
Action: Jacqui Angus
Animal Feed Law Enforcement Liaison Group Meeting (AFLELG)
The next meeting was to take place at the FSA Scotland offices in Aberdeen on 19 March. The secretariat has agreed to allow two or three members of the SFELC Feeds Sub-Committee to attend. A letter would be going out the following day. Names should be sent to Jacqui Angus.
Jacqui Angus informed the group that Alison Taylor had now left for the Policy Unit and would be replaced by Pauline Wilkinson on 2 March. Kate Connelly thanked Alison on behalf of the group for her work with Trading Standards.
Primary Production Report
Maureen McLarty presented the report.
The Primary Production (PP) Enforcement Working Group had held its first meeting on 19 November 2008 and the minutes were to be sent out.
Primary Production was to be included in the FSA's 5-year audit plan, but will not take place in the first year.
There was to be an amendment to the Feed Hygiene Regulations in regard to SGRPID officers. They were to be allowed to perform cross-compliance inspections and would apparently not deal with feed. Jacqui Angus said that they do deal with feed but that this was not a matter for the FSA.
The Scottish Government Rural Payments and Inspectorate Directorate (SCRIPID) and Trading Standards would liaise more in the future.
There were still questions regarding risk rating and there should be clarification in the CoP.
There was concern over the four-yearly inspection period for high-risk premises and also over the different risk rating schemes operated by Trading Standards and Environmental Health.
It appeared that the lead officers for feed and food would each decide on the qualifications competency for their respective officers.
There was currently only informal liaison between local authorities and SGRPID officers.
Update from Public Analysts
Jane White gave an update. She said that she had only received some Glasgow Laboratory feed results and that these were for Dumfries & Galloway. Of one hundred informal samples there had been the following failures: 7 for protein, 2 for oil, 4 for ash, 4 for fibre and 7 for mycotoxin. There had also been 3 failures out of 5 tests for aflatoxin B1 in wild bird seed. Aflatoxin B1 could therefore be an area on which to concentrate nationally. The Public Analysts were now set up to test for aflatoxins.
Update from LACORS Feed Focus Group
Maureen McLarty referred to the briefing note of a meeting held on 19 January 2009, specifically to page 2, item 4 in which the FSA's general update stated that horses were to fall within the definition of food producing animals. Jacqui Angus asked whether this decision would be officially communicated as it represented a major change of direction. She would seek clarification. Marzena Young would also seek clarification from LACORS. A brief discussion followed regarding the Trading Standards enforcement role and about whether horses were classifiable as pets. It was agreed that this was a difficult area. The question was raised as to who would have the power under the Animal Health Act to inspect for passports.
Page 4, item 12 on bird feed was referred to which dealt with storage and distribution of wild bird feed. LACORS agreed that this activity would be covered by EC Regulations 183/2005 and 178/2002.
Item 13 dealt with FSA advice on veterinary hospitals and stated that these were to be classed as feed business operators and would thus fall within the provisions of the EC Feed Hygiene Regulation 183/2005.
Page 5, item 14 dealt with legionella in potting compost. A query from the West of Scotland Safety Group was considered and it was agreed that this issue was covered by the General Product Safety Regulations.
Item 18 referred to 5-day feed training courses being run by Compton and Claywood. Marzena Young mentioned European courses that appeared to exclude Scotland as they were targeted at the United Kingdom.
Update from Animal Medicines Inspectorate (AMI)
There was no update.
Reports from Regional Quality Systems (QS) Groups
West: Alison Bannister reported on a recent meeting at which LAEMS and SPPOCS were discussed and where the conclusion was reached that there needed to be some clarification in this area, as there were a number of reporting systems by local authorities, such as FLARE and so on. Jacqui Angus stated that links to these systems ought to be automatic. Alison Bannister asked what information should be being put on each. She asked whether SPOCS was only for primary production and whether samples taken on-farm had to be logged on to both FSSNet and SPOC, or only on FSSNet. Jacqui Angus replied that they need only be logged on FSSNet. Alison Bannister suggested that a flow diagram of which systems to use for what would be helpful. Marzena Young said that there were problems of double reporting on both FLARE, and other local authority systems, as well as LAEMS.
Roisin Dillon (TSI Scottish Branch Training Officer) had approached the FSA about biosecurity training but there had been no response so far.
Grains and milk powder were now to be checked for mycotoxins and melamine. Wild bird feed was also to be sampled.
SGRPID/Agriculture Department officers were confused about the organisation of cross-compliance visits. Jacqui Angus could not see why this should be. Alison Bannister gave the example of her turning up to carry out a feed visit to discover that SGRPID had performed a cross-compliance visit the day before.
East Group: Brian Wilson had nothing to report as there had not been a meeting held recently.
North Group: Marzena Young reported that a meeting had been held on 1 October 2008 at which George Begg was elected as the new Chair. The minutes were available. The next meeting was to be held on 4 February in Perth.
This agenda item had already been covered.
Feedstuffs Conference 2009
Kate Connelly and Marzena Young gave an update. Kate Connelly stated that Marzena Young had sent her some proposals for the conference agenda. Marzena Young was organising the conference which was scheduled provisionally for 21 May, and would be held at the Dewar Centre, Perth. Marzena Young’s email to Kate Connelly of 23 January was referred to for provisional details. Preparations were in hand to receive around eighty delegates, and the FSA had agreed to pay for the venue and catering. Marzena Young indicated that she would like to invite the following speakers among others:
- Tim Frank – FSA Feed Unit London to speak on current issues in feed legislation;
- Judith Nelson – Agricultural Industries Confederation (AIC) to speak on National Feed Assurance Schemes;
- Peter Midgley – FSA Scotland to speak on primary production enforcement;
- a representative from SEERAD;
- a representative from the Public Analysts;
- a representative from the Scottish Agricultural College (SAC) to speak on feed and nutrition from a scientific perspective.
There would also be workshops.
Kate Connelly asked whether eighty delegates would be manageable given that last year's conference had been attended by fifty-five delegates. One of the suggestions following the 2008 Conference was that the number of speakers should be reduced. She asked whether there could be a vote by email to help prioritise.
Although there is currently no charge for the event, Brian Wilson suggested considering a two-day conference with a charge of between £30 and £40 per head.
A brief discussion followed on the possibility of alternating the conference agenda between speakers and workshops to maintain the interest of delegates.
Training Update/Current Consultations
There was nothing to report on these items.
Any other business
There was no other business.
Date and venue for next meeting
The next meeting would be held in April 2009 at Glasgow Scientific Services.