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Trading Standards Animal Feed Service Plan 2019-20

1. Service aims and objectives

Ensuring good levels of animal feed safety is an important part of Dorset Council’s trading standards advisory and enforcement responsibilities. 

The service is responsible for the enforcement of animal feed legislation controlling feed quality, safety, hygiene, labelling and traceability throughout the feed chain including importation, manufacturing and primary production (feeding of farmed livestock and growing crops). These controls help ensure both the safety of the feed and food chain. Historically, the majority of our major animal disease outbreaks such as BSE and Foot and Mouth have been linked to animal feed. Likewise, major food incidents such as dioxins in pork are directly linked to feed hygiene controls.

Business plans

This Feed Service Plan is to be read in the context of the Trading Standards Business Plan. It is produced separately to assist elected members, consumers, businesses, staff, other enforcement bodies and external auditors to focus on the key elements of our animal feed responsibilities as well as meeting the specific needs of the Food Standards Agency (FSA) and national legislation.

Ensuring the safety of the food chain by animal feed work contributes to the Dorset Council’s commitment to the safety and health of people in Dorset. Activity to support local feed businesses with advice and guidance, together with the monitoring of feed supplied to farmers also reflects the commitment to a prosperous Dorset economy.

2. Background

Profile of the Dorset Council

Located in the South West with a designated World Heritage Status coast line, Dorset is a rural county with a rich and diverse countryside that is protected by numerous areas of outstanding natural beauty. The county is largely rural with strong tourism and agricultural industries which are vital for the local economy.

Organisation structure: feed hygiene controls

  1. Trading Standards Service Manager: Ivan Hancock
  2. Principal TS Officer - Animal Health Team including Feed: Neil Martin

  3. Lead Feed Officer: Bill Britton STSEO, Jill Thierstein STSEO, Karen Wood STSEO (AHO), Peter Clark TSEO, Ellie Pages SSO

Agricultural analysts:

Mr N Payne, with deputies Ms E Moran, Mr K Wardle, Mr D Arthur, Mrs J Hubbard, Ms L Downie, Ms M Evans (all at Public Analyst Scientific Services Ltd).

3. Demands of Feed Service and service delivery

There are approximately 4000 business in the Dorset Council area that are registered, or require registration, under the Feed Hygiene Regulations. These are predominately agricultural holdings but also include business such as manufacturers that produce animal feed on a large scale for resale and animal feed importation at Portland Port. Over 200,000 tons of feed material per year is imported via Portland from both inside and outside the EU. All consignments destined for Portland Port are monitored and assessed prior to arrival to establish if further checks or samples need to be taken. As this activity is classed as a first point of entry for feed into the EU the National Trading Standards board point of entry procedure is followed.

All feed premises are risk assessed in accordance with the FSA feed score risk rating scheme. Visit intervals vary between annual visits for high risk and/ or low compliance to ten yearly interventions. The risk factoring for each establishment takes into account the size of the business, the feed operations they undertake and the risk they could potentially pose to the feed chain. However, these risks can be mitigated and the risk score for the business reduced through a system of earned recognition. This takes into account previous compliance history and membership of approved assurance schemes.

Planned interventions

Details of the number and type of visits planned for this financial year can be found in the Appendix 1.

The funding is provided by the Foods Standards Agency (FSA) to enable feed visits to be undertaken. The level of funding will not be confirmed until April 2019 at the earliest however we can expect a similar level of funding from 2018-19 as a result of the new Feed Law Code of Practice. The trading standards service is due to undertake 90 inspections and 3 funded inland samples and 5 funded Point of entry samples. We will carry out further feed samples as shown in the Feed Sampling Plan 2019/20 (not public). In total there are 45 inspections at non- primary production and 45 inspections at primary production level (farms). This is the same number of planned inspections from 2018/19 however we will be undertaking less Food Primary production inspections at high risk food producers such as watercress and lettuce growers. In 2018/19 we undertook 18 inspections and for this coming year there are 4 planned inspections. This reduction is due to the small number of high risk food primary production premises within our region. 

Our approach

Whenever possible feed standards are delivered by way of a single comprehensive visit alongside other trading standards service responsibilities in areas such as food, weights and measures, unfair trading and animal health and welfare.

We recognise the value and importance of our advice and will continue to treat visits as an opportunity to support local businesses with legal advice and guidance, as well as checking for compliance.

Every three months we seek businesses views by way of a business satisfaction survey in order to ensure we continue to respond to local needs. Dorset businesses also have the opportunity to contact our service using our dedicated Business Advice or Animal Health lines.

Our document ‘ Dorset Businesses. What you can expect from your local trading standards’ sets down our commitment to providing Dorset businesses with an efficient, courteous and helpful service.

Our Enforcement Policy gives a clear commitment to ensuring compliance through business advice and guidance where possible and appropriate. Prosecution is reserved for cases involving fraud, negligence, public safety risk, or failure to follow advice or warnings.

Alternative enforcement strategies

Feed business operators who demonstrate high standards of feed safety by taking appropriate steps to comply with the law may have these standards recognised when determining the frequency of inspections and therefore qualify for ‘Earned Recognition’.

These cases allow for the use of alternative enforcement strategies (AES). These strategies aim to reduce the burden on previously compliant businesses while focussing enforcement activity and resources on less compliant businesses. Examples of how we can engage with business through alternative enforcement strategies include questionnaires, surveys and project based inspections. Businesses can also earn recognition by being a compliant member of an approved industry assurance scheme such as ‘Red Tractor’ or being an Agricultural Industries Confederation (AIC) member.

Enforcement priorities

At the time of preparing this service plan, the FSA have not set out the National Feed Enforcement Priorities for 2019/20. Therefore we will maintain the National Enforcement Priorities of 2018/19 which our service will have regard to in prioritising and planning our feed service delivery. Once the National Enforcement priorities are known, we will reconsider any new priorities.

The main priorities for our Service for this year will remain:

Priority 1: Effective identification and appropriate registration of food businesses operating at the level of primary production

The FSA requires local authorities to identify and correctly classify the activity of higher risk ‘ready to eat food’ business establishments operating at the level of primary production. For 2018-2019 these were producers of micro leaves, baby leaves, herbs, watercress, lettuce, spinach, strawberries, salad onions, radishes, celery, chicory. We will continue to ensure our database accurately reflects the activity undertaken by Food Business Operators (FBOs) and that these establishments are appropriately registered where required.

Priority 2: Verification of the presence and accuracy of feed labelling which have the potential to compromise human and/or animal health

The presence and accuracy of labelling information is critical in ensuring feed is provided to the correct species, age of animal and in quantities that would not adversely affect human and/or animal health or impact on traceability. The presence of batch codes aids prompt recall and withdrawal of affected products in the event of a feed safety incident. Ongoing labelling checks will occur during our inspections as well as targeted sampling as shown in this year’s sampling plan.

Priority 3: Effective monitoring of consignments of feed originating from outside EU at point of entry

We will continue to monitor all feed imports and will continue to have a risk based approach to checks which include sampling of all feed consignments. With the uncertainty of BREXIT, the service will remain flexible and will ensure adequate resources are available for official controls at point of entry.

Priority 4: Risk based feed sampling

Our Feed sampling plan will be developed with the assistance of the Trading Standards South West regional feed group and will prioritise sampling to protect human and animal health. 

Priority 5: Validation of effective feed safety management systems at Annex II establishments with a focus on businesses supplying former foodstuffs or co-products 

Contamination of feed often occurs through carry-over, inappropriate storage, mixing or preparation of animal rations, inadequately cleaning of equipment or ineffective implementation of HACCP by the FeBO.

We will prioritise food businesses who supply a co-product or surplus food into the feed chain with examination of the feed safety management systems and controls.

Sampling

Additional funding is also available through an FSA grant for sampling animal feeds. This year the funding will help us commit to take 20 samples in relation to feed safety.

In addition to the sampling program, we investigate any complaints about animal feed received. If necessary, formal samples are submitted to the Public Analyst to establish if the complaints are justified.

Feed incidents

Should a feed incident occur in Dorset contact would be made with the FSA immediately. The nature and scale of the incident would be established as soon as possible to ensure that any feed still in circulation is detained. Feed safety incidents will take priority over the routine inspection and sampling activities.

Partnership working

We recognise the value and importance of working in genuine partnerships with others. Nationally we will continue to contribute to the strategic objectives of the FSA.

Regionally we will continue to support the Trading Standards South West (TSSW) and will seek grant funding opportunities that add value to our work.

We also work with other government bodies such as Animal and Plant Health Agency, Veterinary Medicines Directorate and the Environment Agency.

Feed promotion

Our service will maintain content on the Dorset Council website with links to guidance notes for feed businesses and consumers.

We are innovative in our feed promotion work and the service will continue to explore new methods to promote feed hygiene and guidance. Good examples of this have been livestock smallholder events educating and promoting compliance to numerous livestock keepers as well as improving the accuracy of our feed database.

Advice to business

Our service operates a free at point of delivery dedicated business advice line and a separate dedicated animal health line. Businesses can obtain help and advice on feed issues ranging from registering as an animal feed premises to detailed labelling advice for manufacturers. These telephone lines can also be used to report any feed safety issues or feed complaints.

The Business Companion website has guidance notes for businesses.

4. Resources

Staff resources and professional competence

The TS Rural Team has four (3.22 FTE) enforcement officers authorised as competent to undertake feed hygiene activities, of which two are fully qualified to undertake all aspects of feed enforcement, including the taking of formal samples and undertaking inspections at non-primary production. All officers involved in feed inspection work are required to complete a minimum of 10 hours professional development per year and their competency is assessed each year.

A lead feed officer has been appointed who is responsible for overseeing all feed work conducted in Dorset and to ensure that all feed activities carried out are in accordance with the FSA Feed Law Code of Practice (England). Records are retained to demonstrate the competence level of all authorised officers undertaking feed work. 

Funding

The FSA provides funding for certain feed work. This is allocated to regional groups and then disseminated to individual authorities based on the number and type of premises due to be visited. The funding for inland inspections and sampling allocated to Dorset for the financial year 2019-2020 is estimated at £20,000. with additional funding for point of entry controls.

Facilities and equipment

A stock of suitable sampling equipment is maintained to ensure that feed visits can be carried out safely and samples taken legally. All authorised officers are issued with protective equipment including steel toe capped footwear, waterproof washable clothing etc. Sampling equipment includes shovels, sampling spears in varying lengths, widths and a riffle box for dividing incremental samples. Sampling requirements are legally prescribed so that samples can be proven to be genuinely representative of the larger consignments they are taken from. A sampling method has also been developed in order to take samples from very large consignments of feed material from Portland Port.

Complaints and feed incidents

Feed complaints and incidents are monitored and activity assessed using a regular tactical assessment process. During the last few years, the service has seen an increase in feed related complaints which we have had the resources to act accordingly  

5. Quality assessment

All officers are subject to Performance and Development Review twice a year. All aspects of training needs and performance are monitored.

The lead feed officer is responsible for ensuring the quality of feed activities undertaken by the service, ensuring it complies with the Feed Law Code of Practice.

Activity, demand and progress against plans is monitored by the Trading Standards Management Team.

6. Review

Our Service met all the inspection, sampling and point of entry requirements of the 2018 - 2019 Feed Plan, including carrying out 110 feed inspections and taking 23 feed samples.

The service has continued to enhance the accuracy of our database of registered feed businesses. An action plan is in place detailing improvements and progress is being monitored by the management team. Since 1 April 2017 over 700 non-feed registered businesses have been contacted and as a result, their feed hygiene activities correctly registered on our database. This work will continue for this coming year with a target of 300 unregistered businesses to be contacted and correctly registered.

Contact us

Contact Dorset Trading Standards.

Appendix 1 – Details of feed inspections

Planned feed visits 2019-2020

Inland Feed inspections
Inland FeedNo. of visits 

Manufacturers

3

Co-Producers

11

Mobile Mixer

1

Importers

1

Stores

2

Distributors

7

Transporters

2

On-farm mixer

14

Pet food manufacturer

5

Surplus food

13

Totals

59

Food Hygiene inspections
Food Hygiene No. of visits

R13 Livestock Farm, no feed mixing

26

R14 Arable Farm

1

Food Primary Production

3

Totals

30

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