FSA Consultation letter, 24 January 2011

ENFORCEMENT - Proposal to amend the frequency of certain official control inspections for on-farm dairy hygiene (England and Wales)

A copy of the full consultation document is available on this site. See: Dairy Hygiene inspections - Consultation

A proposal to amend the frequency of certain official controls for on-farm dairy hygiene. Responses are requested by: 14 March 2011

Audience

Who will this consultation be of most interest to?

• Dairy farmers, farmers’ representatives, milk buyers, enforcement bodies, those involved with the Assured Dairy Farms Scheme and consumers.

What is the subject of this consultation?

• A proposal to amend the frequency of certain official controls for on-farm dairy hygiene.

What is the purpose of this consultation?

• The overall objective is to have a scheme of official controls in England and Wales that is proportionate to the risks posed by on-farm milk production, taking account of additional controls and assurance within the milk supply chain and maintaining the protection of public health.

Consultation details

This consultation sets out proposals to reduce the burden of official controls on dairy farms in England and Wales by recognising audits carried out by Assured Dairy Farms (ADF) and maintaining consumer protection.

The Agency recognises the need for proportionate regulation that minimises the burden on industry while retaining the necessary level of public health protection. Earlier last year, the Agency carried out a public consultation on limited recognition of assurance for on-farm dairy hygiene provided by the Assured Dairy Farms (ADF) scheme (see link below). Some consultees were concerned that the Agency had not gone as far as it could in recognising assurance on hygienic conditions provided by the ADF routine on-farm audits.

Since the previous consultation, the Agency has carried out a UK-wide review of official controls for dairy hygiene and is prompted by the findings to propose the further measures outlined in this consultation.

Proposals: Key proposals:

• All dairy farms producing raw milk for processing will be subject to a routine official hygiene inspection at a frequency of a minimum of 24 months except where the dairy farm has current membership of the ADF scheme, in which case it will be subject to routine official hygiene inspection at a frequency of 10 years.
• Ad hoc inspections and follow-up visits will be carried out in response to adverse findings of official inspection and ADF audits – these may also be prompted by adverse information received from third parties such as other on-farm inspection bodies and purchasers of raw milk for processing.
• On-farm dairies producing raw drinking milk for human consumption will be inspected at a frequency of 6 months.

The proposed options for official controls:

The options that have been considered are fully detailed in the Impact Assessment at Annex B. In brief, they are:

• Option 1 - the status quo with inspections being carried out under similar, but different regimes in different parts of the UK
• Option 2 - delivery of dairy hygiene controls through local authorities following the model currently used in Scotland
• Option 3 - delivery of dairy hygiene controls through existing delivery partners, implementing a harmonised risk rating system and recognising Assured Farm status in setting inspection frequencies.

Option 3 is the preferred option as it ensures a consistent and proportionate risk-based approach for setting inspection frequencies on dairy farms. It also continues to protect public health while recognising the expertise of current delivery partners and assurance provided by the ADF scheme.

Implementation and review of the arrangements:

Following public consultation, and subject to responses received, we intend to introduce the changes from 1 April 2011.

Once the new system is established, the annual official inspection at 10% of dairy farms with ADF membership, will provide an ongoing assurance stream that ADF audits are carried out with adequate rigour in respect of dairy hygiene.

A full evaluation will be undertaken once the changes have been in place for at least four years to ensure that public health protection is maintained.

Consultation Process:

In advance of this formal public consultation the Agency has held informal pre-consultation discussions with the following stakeholders, which are key to the successful implementation of the proposals:

• Animal Health Dairy Hygiene – regarding the future provision of official controls
• Assured Dairy Farms – regarding the operation of the ADF scheme
• Dairy UK – regarding the proposed official control regime
• Representatives from companies who are purchasers of raw milk – regarding industry controls and reporting of adverse sampling results
• National Milk Laboratories – regarding the collection and testing of milk samples from dairy farms

The Food Standards Agency welcomes 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; they 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 the frequency of official inspection on 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 Monday 14 March 2011. 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).