Foodlaw-Reading
Dr David Jukes, The University of Reading, UK
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CIEH News Item, 24 May 2023
The Chartered Institute of Environmental Health (CIEH) have called on the UK Government to expand the remit of environmental health officers working at the borders as part of its new scheme for conducting import checks at the border.
CIEH have made this call as part of its consultation response to the Cabinet Office who had been seeking views from both industry and regulators with respect to the draft version of its Border Target Operating Model (BTOM) for import controls.
The draft BTOM, which will begin to be implemented from October 2023, proposes a new approach to sanitary and phytosanitary (SPS) controls (applying to imports of live animals, animal products, plants, and plants products) at the border. It sets out how controls will be simplified, digitised and, over time, delivered through the UK’s new Single Trade Window.
Since publishing the draft proposals six weeks ago, the Cabinet Office, Defra and the Food Standards Agency have embarked upon a series of engagement events, several of which attended by the CIEH, have aimed at explaining how the new system would work in practice.
CIEH have raised several concerns as part of our submission to these proposals, such as the unnecessarily hasty timeline for implementation, the risks associated with the proposed Trusted Trader approach and a lack of clarity regarding future charging mechanisms, etc. CIEH have also highlighted the vital role environmental health officers can play in alleviating some of the staffing concerns under the new BTOM regime, which could have a detrimental effect on food safety as well as food supply, if not properly addressed.
Under retained EU regulations, official veterinarians (OVs) are currently responsible for the majority of SPS checks on products of animal origin (POAO) at the point of import, whereas environmental health officers are responsible for the fish and fishery products aspects of POAO.
CIEH believe there is an opportunity to take advantage of flexibility we now have as a non-EU member state while also addressing some of the staffing shortages being faced with at the borders, by bringing environmental health officers back into the full remit of POAO checks at the border, alongside OV colleagues.
To do this, CIEH are calling for the UK Government to make an amendment to retained EU legislation and embark upon a change of policy which would enable sufficiently competent environmental health officers at BCPs to take on more responsibility for SPS checks, or at the very least embark upon a pilot scheme to see how such an approach would work in practice.
Helen Buckingham, Chartered EHP and independent environmental health consultant specialising in imported food, said:
“There are certainly some concerns about the UK Government’s draft Border Target Operating Model, and we wait to see what the next (and final) iteration of it will contain, when published in June. However, this significant change to the regulatory landscape gives us a unique opportunity for the government to use the skills of environmental health officers to ease staffing pressures at the borders.
Many operational environmental health professionals in the field would be competent to take on these additional roles almost immediately, more readily than securing additional OV expertise, which is clearly not out there. It’s not about replacing OVs, but adding to the talent pool, providing additional resource, flexibility, and confidence for safety aspects and for the supply chain. And we’ve done it before. Not so many years ago, before the OVs took over, EHOs were working alongside Meat Hygiene Inspectors in the abattoirs to assess the fitness of meat for human consumption and ensure high standards of animal welfare.
We would urge the government to, at the very least, engage with the CIEH, the Association of Port Health Authorities and their respective members to codesign a pilot scheme which would test how these proposals would work in practice.”
Diana Tumova, Chartered EHP with background in port health and one of the founding members of the CIEH Border Reform Research Group, said:
“A shortage of OVs was first identified prior to the UK’s 2016 decision to leave the EU one of many adverse impacts the change would have on food exports and imports. The change of immigration rules for EU nationals has further exacerbated this issue as most border OVs are non-UK EU nationals.
A further reduction in OVs working in government services could increase the risk of food crime and fraud, making UK an attractive destination for such activities.
A small change in government policy allowing EHPs, many of whom are already competent in conducting this work, or who could be upskilled and redeployed quite readily, to support OVs conduct POAO checks at the border, could have a big impact on addressing this staffing shortage and also provide the country with the cohort of competent professionals readily prepared to deal with serious incidents. BRRG and CIEH are ready to assist the government in implementing a pilot."
