FSA Consultation, 17 March 2010

ENFORCEMENT - Proposal to reduce the frequency of on-farm official inspection in the dairy sector (England)

A copy of the consultation document is available on this site. See: Proposal to Reduce the Frequency of On-Farm Official Inspection in the Dairy Sector (England)

The overall objective of the proposal is to reduce the burden of official controls on dairy production holdings in England and Wales by recognising, where applicable, the hygiene aspects of the results of audits carried out by Assured Dairy Farms (ADF), while maintaining consumer safety.

Responses are requested by: 9 June 2010

Audience

Who will this consultation be of most interest to?

Dairy farmers, farmers' representatives, milk buyers and processors, enforcement bodies and those involved with the ADF.

What is the subject of this consultation?

A proposal to reduce the frequency of official on-farm hygiene inspections in the dairy sector. The reduction would be introduced for those dairy farms that have been assessed by Animal Health Dairy Hygiene as lower risk and that also have ADF status.

What is the purpose of this consultation?

The overall objective of the proposal is to reduce the burden of official controls on dairy production holdings in England and Wales by recognising, where applicable, the hygiene aspects of the results of audits carried out by Assured Dairy Farms, while maintaining consumer safety.

Consultation details

The Government’s Whole Farm Approach supports Defra's five year strategy 'Putting Sustainable Development into Practice in Farming, Food and Animal Health and Welfare'. It is aimed at:

• reducing regulatory bureaucracy and costs, both for farmers and government
• improving the environmental and health and safety record of farming, by encouraging better farm practices
• streamlining and targeting enforcement activity on the basis of risk
• fostering a new, customer-focused relationship with farmers

As part of the Whole Farm Approach, the On-farm Inspections Project is developing a strategy for integrating on-farm advisory and enforcement visits in order to reduce the burdens on farmers and improve value for public money. It will achieve this through the following:

• Rationalised on-farm inspection visits where possible, including both the regulatory and voluntary sectors, resulting in more efficient working within the department and associated bodies and a reduced burden on farmers.
• Shared inspection data to reduce duplication of inspection effort and to reduce the burden on farmers and to enable regulators to build up a risk profile for individual farm businesses.
• Improved scheduling of necessary visits, including increased cross department/agency co-ordination to reduce the impact of visits on farmers.

A number of options for potential pilot projects were identified, one of which was inspection activity in the dairy sector.

At present in England and Wales, milk production holdings are subject to statutory inspections by Animal Health Dairy Hygiene (AHDH), on behalf of the Food Standards Agency, for compliance with food hygiene legislation [Regulations (EC) 852/2004 and 853./2004 on the hygiene of foodstuffs set out food hygiene requirements with which food businesses (including primary production) must comply and 854/2004 sets out the requirements for the organisation of official controls on products of animal origin] and the majority are also audited for compliance with farm assurance scheme standards by ADF. There is provision in legislation [Regulation (EC) No 882/2004 on official feed and food – Recital 13] for the recognition of such private quality assurance programmes in the risk prioritisation of official controls. The FSA has applied this principle to official controls in those primary sectors where food hygiene requirements had not applied prior to the introduction of new hygiene controls in 2006 and has now assessed whether the approach might be extended to the dairy sector where official controls on milk production premises have been established for many years.

The changes proposed would apply to inspections of primary production of milk on farm. Arrangements for the inspection and approval by local authorities of on-farm milk processing (such as pasteurisation and cheesemaking) would remain unchanged.

Proposals:

Key proposals:

• Dairy farms classified as Category 4 (lowest risk) at their last AHDH inspection and which have ADF status will have their official inspection frequency reduced. For these farms inspection would take place at least once every 10 years, as opposed to once every 19-24 months at present.
• Dairy farms classified as Category 3 at their last AHDH inspection and which have ADF status would in future be subject to official inspection at least once every five years as opposed to once every 13-18 months at present.
• In order that the above changes can be implemented, certain measures will first need be put in place to ensure that there is good co-operation between the FSA, AHDH and ADF.
• Consideration has been given as to whether changes could be made to the inspection frequency for higher risk category farms (Categories 1 and 2). Evidence from the FSA’s analysis did not support a similar approach for AHDH higher risk farms at the present time. However, a further analysis and review of the potential to extend these changes to Category 2 farms will be carried out after the new procedures have been in operation for 12 months.

Consultation Process So Far:

The FSA set up a stakeholder group with industry representatives to take this work forward. It met four times: in March 2007, July 2008, September 2008 and July 2009. The last meeting in July 2009 discussed and agreed the options that would be put to formal public consultation.

We welcome comments from all stakeholders. Please send your response by email or post using the contact details given. All responses received as part of this consultation will be given careful consideration. These will be summarised and published on the Agency’s website in due course.

Questions asked in this consultation:

Stakeholders are asked to comment on the proposals to reduce official inspection frequency on lower risk dairy farms as identified above.

Stakeholders are asked to comment on the costs and benefits (both monetised and non-monetised) identified in the consultation stage impact assessment for Options 1, 2 and 3.

Responses:

Responses are required by close 9 June 2010. Please state, in your response, whether you are responding as a private individual or on behalf of an organisation/company (including details of any stakeholders your organisation represents).