Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
|
|
FSA Interested Party Letter, 14 December 2018
 |
FSA Consultation: Meat official control charges – Proposal to remove plan inspection assistant disco:unt A copy of this document is available on this site (click on image). See also the full text of the Interested Parties Letter - the main elements of the letter are provided below. The consultation closes on the 25 January 2019. |
As the Food Business Operator (FBO) of an approved poultry or rabbit slaughterhouse I am writing to you as an interested party in a proposal to remove the element of the current discounting system for meat official control charges specifically relating to Plant Inspection Assistant (PIA) costs. No other changes are proposed to the current discounting system.
The Food Standards Agency is seeking your views on this proposal. Any comments on this proposal must be received by 25 January 2019.
Background
The FSA’s charges for official controls at poultry slaughterhouses, red meat slaughterhouses and game handling establishments are discounted. The current discounting arrangements were introduced from the start of the 2016/17 year following full public consultation and approval by the Government’s regulatory committee process. A supplementary element of the discounting system is specifically for approved poultry or rabbit slaughterhouses operating PIA systems. Under such systems staff employed by or contracted to FBOs undertake certain official controls under the supervision and direction of an Official Veterinarian.
It is in recognition of the PIA costs incurred by FBOs that these costs are included in the FSA charges calculation. This calculation can result in a supplementary discount, over and above the normal discount, being awarded. More information on the PIA discount can be found in the FSA guide to Charges for Official Controls in Meat Premises which is available here: https://www.food.gov.uk/sites/default/files/media/document/charging-guide-2018-19.pdf (see paragraphs 99 to 122).
The supplementary PIA discount was developed by industry stakeholders who were members of the Steering Group on Meat Charging. The PIA discount was intended to act as an incentive for FBOs to switch from Meat Hygiene Inspectors (MHIs) to PIAs. It sought to do this by ensuring that the official controls charges for an FBO making such a switch would be no higher than if they used MHIs and they could be lower.
Proposal
The FSA proposes that with effect from the start of the 2019/20 financial year, 1 April 2019, the provision for a supplementary discount on charges for meat official controls, which is allocated to some poultry and rabbit slaughterhouses operating PIA systems, will be removed. The removal of the PIA discount, and ceasing to require FBOs to provide the FSA with details of their PIA pay rates and hours data, would reduce the overall level of discount to the poultry sector if no further action were taken. The reduction would not be confined to the PIA discount. This is because the available discount funding is split proportionately between the red meat, game and poultry sectors according to the number of hours of OV, MHI and (in the case of poultry) PIA time. In order to mitigate this effect the FSA proposes two alternative options summarised below:
Option A – increase OV and MHI hours in the discount calculations by a factor of an additional 0.7
The PIA hours represent a factor of 0.7 of the OV and MHI hours in the poultry sector. In order to equalise the proportionate split of poultry sector hours, compared to red meat and game, in the overall discount allocation the OV and MHI hours in the poultry sector would need to be increased by a factor of an additional 0.7.
Option B – increase OV and MHI hours in the discount calculation by a fixed number of hours
As an alternative a fixed number of hours, to reflect PIA hours, could be added to the OV and MHI time for the proportionate split of overall discount funding between the red meat, game and poultry sectors. The number of hours proposed is 228k which reflects PIA hours in the 2017/18 discount calculation. For the same period in the poultry sector the OV hours were 197k and the MHI hours were 152k.
Reasons for change
It is proposed that the PIA element of the official controls charges discount is removed for the following main reasons:
a) The process is administratively burdensome for FBOs and the FSA with information required from FBOs on an annual and monthly basis. This data is collated, validated and processed by the FSA for inclusion in the charges calculation.
b) The supplementary discount was developed by meat industry stakeholders as part of the Steering Group on Meat Charging’s work as an incentive for poultry and rabbit slaughterhouses to switch to PIAs. There has been no discernible impact attributable to the discount on decisions by FBOs that they wish to switch to PIAs.
c) The value of the PIA discount in 2017/18 was less than £32,000 across the industry but approximately 70% of this was received by four FBOs. The discount is greatest where the costs of the PIAs are relatively high.
