CFG
27/07 final
Letter dated 14 September
2007 from Foodaware to Rhys Jackson, Delivery Change Programme, Defra:
Dear Mr Jackson
Consultation on Defra’s response to the Eves' Review
of the Animal Health and Welfare delivery landscape
Foodaware supports the Animal Health and Welfare Strategy, and comments
on that and the proposed European Strategy from a consumer perspective
are available on our website. We have also contributed to the debate
on cost and responsibility sharing through participation in the CVO’s
quarterly meetings with consumer representatives and our response
to that consultation. Members are particularly concerned about the
implications of Defra’s policy and industry practice on the
availability, quality and safety of the food supply and impact of
government policies on the quality of life in the UK.
This consultation is structured in two parts: Part 1 Animal Keeper
Interests and part 2 Organisational Issues. It is disappointing that,
after significant efforts to involve consumer interests in discussions
about animal health and welfare, the consumer, and public interest
in having effective arrangements in place to protect public health
and to ensure that public resources (taxpayers money) are used efficiently,
are not specifically acknowledged.
Comments on specific themes
Theme 1: Inspections
and Enforcement
Foodaware has always recognised that one of the main reasons for government
involvement in regulating agriculture and food businesses is to ensure
that public health and the economic interests of consumers are protected.
As the scope of regulation has increased, however, the public have
become increasingly concerned about the complexity of food law enforcement
at national and local level in the UK, variations in the level of
enforcement between different authorities and regulators, and in the
sanctions awarded by different courts and in different parts of the
UK. Given the complexity of the delivery landscape, there are attractions
in the Eves' Review suggestion that, if collaboration cannot be made
to work, the possibility of a national inspectorate should be considered.
There is a need for coherence in the inspection and enforcement regimes
from farm to fork. However, there is already considerable uncertainty
and change underway through restructuring at every level in Defra
and its Agencies and in the reform of the Meat Hygiene service. A
period of stability is necessary to enable the benefits of the changes
to date to be realised and to clarify the priorities for the future.
Only if the current reforms do not work should further institutional
change be considered.
We welcome the recognition that Defra should ensure that the inspection
regime should be risk-based and that there needs to be closer collaboration
between agencies to ensure resources are effectively used. We have
expressed concern about the level of resources available to local
authority enforcement authorities, particularly to respond effectively
with the complex structure of farming and the meat trade from farm
to table and to ensure traceability for animals and meat at each stage
of production and processing. Improving working relationships between
Animal Health and local authorities will be a step in the right direction,
but will not deliver stronger, and more targeted inspection and enforcement
without the resources to provide advice and take action when problems
arise.
Defra must be clearer about the responsibilities and outcomes that
it requires from delivery bodies and the national and regional priorities
to be addressed. Such priorities should be re-evaluated from time
to time to take account of changing needs. We have also expressed
reservations about the lack of guidance on appropriate levels of activity
and the resources necessary within Local Authorities to meet the public’s
expectations. If this can be addressed in part through the Framework
Agreement we would encourage you to do so
Theme 2: Defra
and delivery partners should promote and reinforce understanding of
the duties, powers and responsibilities of all concerned.
Closer working will not deliver higher standards and more effective
inspection and enforcement arrangements without clarity from Defra
about what it is purchasing through its delivery agencies and what
Local Authorities are obliged to do. In the context of cost-cutting
and cost and responsibility sharing, creative solutions will be needed
to sustain and improve the effectiveness of the inspection and enforcement
arrangements and ensure an appropriate balance is achieved between
public resources and industry funding. Defra also needs to ensure
that compliance is appropriately monitored through targeted inspection
in accordance with the risk assessments.
Theme 3: Animal
Health and Welfare policy should be simplified and clarified for delivery
partners and stakeholders.
We support the case for simplification so that those responsible for
implementing requirements throughout the food chain fully understand
their obligations and responsibilities and can keep up to date with
public expectations. We also agree that this must not increase the
risk of disease, and there is an ongoing case for reinforcing simple,
essential messages about good bio-security and effective hygiene controls
throughout the farming, livestock, meat industry and food processing
sectors.
Theme 4: Defra should
tailor its cattle identification information systems for ease of compliance
by livestock keepers.
This continues to be an area of concern to consumers in the light
of BSE and the recognition that there are still many old animals which
are not included in the system. The system must be made comprehensive
and then improved so that it is easy to comply with and tracks all
animals throughout their lives. Work also needs to be progressed in
relation to pigs, sheep and poultry so the public can have confidence
that systems are in place to facilitate traceability and both prevent
disease spread and allow the cause of outbreaks to be fully investigated.
Theme 5: There should
be greater transparency.
Foodaware supports the actions you are taking in this area but would
like to see more information on the criteria which will be used to
underpin a risk-based inspection and enforcement system. Defra should
also improve information flows to consumers and continue with arrangements
for briefing consumer representatives successfully initiated by the
Chief Veterinary Officer but extend it to include work on sustainability,
climate change and fisheries policy and not Animal Health policy and
practice alone.
Yours sincerely
Susan Knox
Chairman
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