There are approximately 3,600 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 businesses such as manufacturers that produce animal feed on a large scale for resale and animal feed importation at Portland Port. Over 250,000 tons of feed material per year is imported via Portland from all over the world. All consignments destined for Portland Port are monitored and assessed prior to arrival to establish if further checks or samples need to be taken.
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 considers 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 considers previous compliance history and membership of approved assurance schemes.
COVID-19
The FSA no longer recommend remote inspections. Physical inspections or sampling visits have been carried out in accordance with our COVID-19 risk assessment. As the restrictions ease, we will continue to adhere to COVID-19 safe working recommendations but the aim is for all inspections to be physical and not remote.
Planned interventions
The funding is provided by the Food Standards Agency (FSA) to enable feed visits to be undertaken. The Feed delivery budget will be decreased by approx. 5% which may slightly reduce the number of inspections allocated to the service. Details of the number and type of visits predicted for this financial year can be found in the Appendix 1.
The FSA have decided to reduce the point of entry budget, however the expectation will be to continue monitoring all feed consignments with appropriate interventions such as documentary, physical and sampling checks to be carried where required. Funding will be allocated for a specific sampling project on poultry and pig feed that contain lysine or methionine. We will carry out further feed samples as shown in the Feed Sampling Plan 2022-23 (not public). Approximately half the inspections will be at non-primary production and the remaining at primary production level (farms).
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 month we seek businesses views by way of a business satisfaction survey to ensure we continue to respond to local needs. Dorset businesses also can contact the 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 focusing 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
The Food Standards Agency (FSA) have identified National Feed Enforcement Priorities (NEPs). At the time of writing this plan, the FSA have published Draft NEPs for the coming year.
Our service will have consideration to all the FSA priorities and how they impact on our feed delivery is shown below.
Priority 1 - Verification of effective implementation and maintenance of feed safety management systems
With the exemption of livestock farms which do not mix feeds, all registered feed business should have a feed safety management system based on the principles of HACCP (Hazard Analysis and Critical Control Points). HACCP will form an integral part of our feed and food hygiene inspections. Consideration will be given to the type and scale of the feed business in relation to what written procedures we would expect them to maintain.
Priority 2 - Verification of effective implementation and maintenance of feed safety management systems at businesses supplying former foodstuffs or co-products
We have over 80 businesses registered to supply former foodstuffs or co-products into the animal feed chain. These are mainly food retailers and manufacturers. Nationally 660,000 tonnes of former foodstuffs are processed into animal feed annually at a value of £110 million. This activity can greatly reduce the amount of food waste and provides an excellent feed for livestock however the business must have a robust feed safety management system in place to ensure that there can be no contamination with products of animal origin. Feed contaminated with products of animal origin can be a direct cause of many notifiable diseases, such as Foot and Mouth.
Priority 3 - Effective monitoring of feed on farms
a. Examination of former foodstuffs / co-products being used for feed on farms.
b. On-farm record-keeping requirements & documented procedures.
The service will carry out inspections on all types of farms from smallholders, with only a handful of animals, to very large-scale farming enterprises. Part of the inspection is to enquire if feed is former foodstuffs. Where a former foodstuff is found on-farm, it will be traced to ensure that the supplier is registered in accordance with the feed hygiene regulations. The impact of a notifiable disease linked to feeding contaminated feed would have a devastating effect for the agricultural industry both financially and on the emotional wellbeing of farmers.
Record checks are integral on all our farm inspections. Traceability and records such as pesticide use, pest control and medicine use all help to evidence good standards of animal welfare, environmental controls and safe feeding procedures that will help ensure the food we eat is safe.
Priority 4 - Effective monitoring of storage arrangements at feed premises
Feed storage will also be inspected whether this is feed stored on-farm, at distributors, or with specialist bulk storage of feed materials. Possible sources of contamination must be stored away from feed and feed must be clearly separated, identifiable and stored in a clean and pest free environment.
Priority 5 - Verification of the accuracy of feed labelling particulars
The presence and accuracy of labelling information is critical in ensuring feed is provided to the correct species and 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 6 - Effective monitoring of consignments of feed originating from non-EU countries at point of entry
We will continue to monitor all feed imports and will have a risk-based approach to checks which include document checks and sampling. With the UK having left the EU, the service will remain flexible and will ensure adequate resources are available for official controls at point of entry.
Priority 7 - Effective identification, registration and inspection of food businesses producing higher-risk, fresh produce operating at the level of primary production
We have identified food businesses producing high-risk, fresh produce such as watercress, salads, soft fruit, which are all commonly eaten raw. These businesses are risk assessed and have been assigned an inspection interval period.
Sampling
The service will contribute to the FSA’s national feed sampling project. We will also carry out risk-based sampling in specific areas such as pet foods and feed for food producing animals. The service will produce a feed sampling plan.
In addition to the sampling program, we investigate complaints about animal feed. 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 Feed Business Operator and 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 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.
Primary authority
Currently the service has one primary authority agreement with a feed business. A primary authority agreement would enable a business to have an enhanced relationship with our service, benefiting from a single point of contact for all trading regulation and advice. We will continue to promote this scheme.
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.
Guidance notes for businesses.
