CFG
01/06
Letter dated 23 January
2006 from Foodaware to Ms Helen Browning OBE, Chairman England Implementation
Group, Animal Health and Welfare Strategy:
Priorities
Partnership Working
Costs and Benefits
Enforcement
Dear Ms Browning
Consultation on the Implementation of the Animal Health and
Welfare Strategy
Thank you for giving us the opportunity to comment from a consumer
perspective on the priorities and approach that you are considering.
1. Priorities
The first priority should be to reduce the level of zoonoses, concentrating
particularly on those diseases that cause serious infections in animals
and human beings such as Salmonella, Campylobacter, E.coli, BSE and
TSEs. Improving the health status of farms, ensuring that farm health
plans have been prepared and are adequate to protect the health of
animals, workers and the public should be a high priority. Farmers
vary widely in their knowledge and understanding of the human health
implications of disease, and in their ability systematically to ensure
the highest standards of hygiene for meat and poultry from farm to
fork as required by European consumer law.
Commitment within Defra must be matched by commitment from all those
involved in the industry to prevent disease and cross-contamination
through better health planning and good biosecurity. While many involved
in farming and food production set very high standards within their
own organisations, there is a long way to go for some. Raising standards
among those who are already involved in assurance schemes would be
a start, but must be matched by effective enforcement of the law against
those who remain ignorant of the requirements or who deliberately
flout the law.
We would also like to see more emphasis on sustainability, ensuring
security of supply within the UK and supporting local community initiatives
such as allotments and local market development. More extensive use
of risk analysis, to prepare plans to deal with particular outbreaks
of disease, natural and man-made disasters and ensure that supplies
are secure, could also be beneficial.
2. Partnership Working
Gaining the support of sector-based trade associations, veterinary
suppliers, and all those engaged in the farming industry and rural
environment to encourage partnership working is a means both of providing
education, information and training and for sharing best practice.
Defra should, however, retain a clear separation between its different
roles and not allow its supportive advice and education functions
to become confused with enforcement. Staff in the field can become
too close to those with whom they work on a regular basis and this
posed particular difficulties during the foot and mouth epidemic.
3. Costs and Benefits
We recognise the tensions between the cost of investment in improving
animal health and welfare and the prices paid to farmers for their
produce. However, we strongly believe that high standards and best
practice in animal health and welfare can bring about more cost-effective
outcomes for farmers, by reducing disease, loss of sick animals and
poultry, and reduced cost of pharmaceutical inputs. The industry should
take responsibility for the quality of the food it produces and the
health of the animals it raises. A reduction in zoonoses also benefits
taxpayers by improving public health.
Defra should review the relative levels of expenditure on different
priorities on a rolling basis, to ensure that such expenditure is
in proportion to the risks, and that routine expenditure does not
prevent investment in new areas of surveillance when appropriate.
We are particularly concerned that monies must be earmarked for horizon-scanning
for new and emerging problems, but should not detract from the need
to deal with existing problems.
4. Enforcement
There is limited evidence to show whether the ‘burden of regulation
is appropriate’ and plenty of evidence of the extent of disease,
poor farm record-keeping, inadequate biosecurity, illegal trade and
inadequate standards. In our view, there are a number of innovative
ways in which enforcement could be improved by embracing the role
of vets, and the myriad of people who go on to farms as inspectors,
to ensure compliance with farm and food assurance schemes. Part of
their role should be systematically to check for compliance with existing
law, as well as ensure the particular standards of individual schemes
have been met. Farm assurance should be helping to sustain quality
and improve compliance but, at present, there are significantly different
approaches between schemes and different requirements for the frequency,
and content of inspections and the standards that have to be met.
There is considerable scope for more joined up thinking and collaborative
working in this area, linking in with the role of local trading standards
and environmental health departments. You ask about incentives for
good behaviour and sanctions for non-compliance. These are most effectively
dealt with by taking enforcement action in the courts against those
who persistently and seriously flout the law, and by effective risk-based
enforcement for those who are trying but still need to make progress.
The added benefit would then come from lower costs of inspection and
enforcement, and potentially higher returns for those who comply and
do not require such close ongoing scrutiny.
We await the implementation plan with interest and would be grateful
if you could send us a copy when it is available. Foodaware is content
for this response to be made publicly available.
Yours sincerely
Barbara Saunders
pp Susan Knox
Chairperson
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