CFG
03/07 final
Letter from Foodaware
dated 29 January 2007 to Rufina Acheampong, Official Control Regulation
Implementation Team, Food Standards Agency:
Dear Ms Acheampong
Draft FSA EU guidance on legal requirements for annual reports
on Member States' multi-annual control plans
The purpose of the guidance is to promote and assist the consistent
presentation by Member States of their annual reports on the implementation
of their plans and the results of the official controls which they
have carried out. Foodaware considers that the rationale for the reports,
and additional work which this will create for Member States, lies
in the principles of openness and accountability. It is important
that Member States are accountable to European citizens and consumers
for the work they do in enforcing food safety and plant health legislation,
and that the reports are published so that the public can judge how
effective their national arrangements are in the context of the Community
as a whole. Therefore, it is of vital importance for consumers that
the reports are produced in a consistent manner and that the data
is comparable. We therefore welcome the Commission’s guidance
and stress the importance of the data being published promptly so
that its value is not diminished by being out of date.
Given the complexities of official control and enforcement in the
UK, we are pleased to see that the UK report will integrate Defra’s
responsibilities with those of the FSA so that there is a comprehensive
approach. Foodaware supported the inclusion of controls on plant protection
products in the National Control Plan, and we consider that it is
important for there to be a comprehensive report on matters which
affect food safety.
FSA has asked for specific comments on a number of features of the
guidance, namely:
1. Impact on competent authorities
FSA states that where data is required, the rationale for it should
be explicit. We agree with this, and that there should be some flexibility
to take account of the diversity between Member States. However, it
is even more important that the data produced should be accurate,
reliable and comparable otherwise the value of gathering it at a European
level will be lost. There is considerable public concern about the
apparently differing levels of enforcement and control in Member States,
and any myths in that regard can only be properly addressed by the
provision of objective and comparable information. The Commission’s
evaluation of the effectiveness of Member States’ controls will
be crucial in identifying where weaknesses and potential future problems
lie. The information must be supplied on a consistent basis for it
to provide a meaningful assessment.
2. Synthesis and analysis of
data
It seems logical that the preliminary analysis should be done within
the Member States. They should be doing this work on an ongoing basis,
and following up on their results as a means of assessing the value
of the National Plan so that they can make appropriate adjustments
in any case.
3. Feed and food controls
FSA welcomes the fact that the guidance allows Member States to base
their assessments on existing EU legislation, and believes that this
will allow the UK to continue to develop outcome-based measures of
industry compliance with food law. This interpretation should be clarified
so that the UK is not out of line with other Member States in its
reporting of the effectiveness of controls. The key test is whether
the outcomes are sufficient to protect public health and consumer
safety, and whether levels of compliance are improving over time.
Foodaware is content for our views on this consultation to be made
public.
Yours sincerely
Susan Knox
Chairman
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