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Feed Service Plan 2021-2022


Introduction and background

There is a central government requirement for local authorities to comply with relevant legislation, codes of practice, guidance on enforcement priorities and a framework document to produce an annual service plan for feed law enforcement.

This plan is supplementary to the Service’s Annual Operational Plan and Strategic Plan. It gives more specific detail on the Service’s aims and objectives for the forthcoming year in complying with the Feed Law Code of Practice and Food Standards Agency Framework Agreement with Local Authorities, which embodies the requirements of the legislation.

The Trading Standards Service covers Devon, Plymouth, Somerset and Torbay. The Service is hosted by Devon County Council but jointly commissioned by Devon, Plymouth, Somerset and Torbay councils, ensuring that the objectives of all authorities are met. Governance of the Service is through a Joint Service Review Panel.

As a joint service we cover one of the largest rural areas of any trading standards service in the country and thus have a large number of business premises that fall into the agriculture functions of the Service. With over 500 feed premises involved in non-primary production including Teignmouth and Plymouth Docks and over 19,000 primary producers, it is key that we target limited resources appropriately. This is done using three work streams:

  • Engagement with the Food Standards Agency (FSA) / National Trading Standards (NTS) nationally funded and co-ordinated risk-based programme of inspections as a member of Trading Standards South West regional group (TSSW).
  • Taking part in nationally co-ordinated and funded sampling projects.
  • Our own in-house reactive feed sampling programme.

We have appointed a Lead Officer for Feed who oversees the implementation and co-ordination of official controls for the Service. The Lead Officer reports to the Feed Champion Team Manager and wider leadership group who have strategic oversight of this area of work. The day-to-day work is carried out by appropriately qualified and/or trained and experienced Trading Standards Officers who undertake these duties for the Service from within five geographical locations. This work is estimated to equal 3.6 full-time equivalent (FTE) staff.

Where appropriate work is carried out in co-ordination and partnership with other enforcement agencies such as the Animal & Plant Health Agency (APHA) and the Veterinary Medicines Directorate (VMD).

Service aims and objectives

Feed work is classified as core operational work of the Service, so while not highlighted as one of the main service priorities using the Intelligence Operating Model, which is based on consumer or business complaints, it does receive full senior management commitment and support as an area of law in which we have a statutory requirement to enforce and as a functional area which is imperative to the businesses of Devon, Plymouth, Somerset and Torbay. The agriculture trade sector and rural business growth is a target area for both county councils.

This year the bulk of the feed work falls into the ‘Farm to Fork’ project area and is split into the following tasks:

  • Rural Business Surveillance – funded by the FSA and includes inspections, sampling, follow-up work, identification and registration of new feed businesses.
  • Sampling – reactively on complaints received and officer initiation.

In addition we continue to raise awareness of feed hygiene registration requirements and develop support packages for businesses as part of our commercialisation initiative. We have broadened the support offered, particularly on farm, and combine the funded inspections with animal health and welfare audits along with business support from the Heart of the South West Growth Hub and partner agencies. This contributes fully to the Service’s impact on corporate priorities and key aims of the joint service, specifically the following:

  • Support business growth.
  • Provide advice and assistance to local businesses.
  • Create a “level playing field” for reputable local businesses and maintain consumer confidence.
  • Focus on the needs of rural businesses.
  • Maintain emergency contingency plans.

The objectives and service targets for feed work are included in the Service’s Operational Plan and Strategic Plan. Inspections and sampling targets for feed can be found in the ‘Supporting the Local Economy’ section of the Operational Plan.

Service delivery

Inspections

A programme of inspection is developed following completion of the FSA/NTS desktop exercise which enables us to identify those premises that require inspection on a risk-based and intelligence-led approach. These premises are identified more specifically using our database.

The table below shows a summary of the total number of inspections by registration category.

Premise type Target
Manufacturer A01-08, A11 and R01-04 12
Co Product Producer R12 21
Mobile Mixer R04 0
Importers 3
Stores R09 3
Distributor A01-08, R01-03 and R05 12
Transporter R08 8
On Farm Mixer R10 & R11 44
Pet Food Manufacturer R06 30
Supplier of Surplus Food R07 26
Livestock Farms R13 130
Arable Farms R14 2
Food at Primary Production 2
Total 292

When carrying out inspections consideration is given to their status in terms of risk score and earned recognition and any Primary Authority Partnership (PA) agreements that may be in place.

We currently have two businesses which have a PA agreement with us which are Feed Registered. There are currently no inspection plans drawn up for these businesses in relation to agriculture.

Sampling

The Service takes part in nationally co-ordinated sampling projects which fall under National Enforcement Priorities. A Service sampling plan is drawn up informed by the regional feed threat assessment, local intelligence, previous sample results, liaison with our Public Analyst and the FSA National Enforcement Priorities. Where possible, samples are taken from premises that are part of the planned inspections programme.

Sample analysis is carried out by the authorities’ appointed Agriculture Analyst Nigel Payne, Public Analyst Scientific Services (PASS).

Business advice, complaints and investigation

As a service there is a requirement to respond to all requests for business advice within five working days. In 2019/20 we received 155 general requests, which included requests for feed hygiene registration and a rise in enquiries about setting up pet food businesses. It is anticipated that a similar level of advice will be requested this financial year.

The Service now has a fee-based system for the provision of advice for businesses and is actively encouraging businesses to take out Primary Authority partnerships or look at joining our Buy With Confidence assured trader scheme.

Complaints received and subsequent investigations will be undertaken in line with our service enforcement policy. Last year we received 39 complaints regarding agriculture matters. Some of these were linked to animal health and welfare issues and investigations have been undertaken. Others have required cross-border working with other local authorities and the FSA as they have involved the use of unauthorised feed additives.

The Service is signed up to receive Rapid Alert System Feed and Food (RASFF) alerts and will respond accordingly in line with current guidance to any feed-related incidences.

There is a UK-based replacement system in place now we have left the EU.

Other

As the largest service in the TSSW region we aim to continue taking a leading role in the activities of the regional Agricultural Group. Membership of this group includes our Lead Officer and Feed Champion Team Leader, who is currently vice chair of the group, and the TSSW representative on the National Agriculture Panel.

We will continue our work in strengthening relations in line with current memorandums of understanding in place nationally with other agencies such as APHA and VMD, and organisations such as Red Tractor and Agriculture Industries Confederation (AIC).

As part of our animal health work with primary producers we will aim to actively raise the profile of the Service within the local farming community by improving links, communication and business support with other enforcement agencies and in turn provide greater clarity of roles and consistency with our working approach. This will partly be achieved by continuing with the work of the Trading Standards Farming Partnership set up by the Service in 2016.

Resources

An annual review is carried out of the resources required to undertake feed controls when producing the Service Plan. The annual desktop modelling exercise, unsatisfactory sample results, and intelligence received from a variety of sources e.g. our officers, other agencies, complaints and trader advice requests received, are all taken into consideration.

This financial year the Service will aim to maintain the competency of 19 members of staff who will carry out the inspection and sampling work above. They will be based mainly within the Business Support and Innovation Team with five members of the Intelligence & Investigations Team retaining their competency.

Officers are based across the six offices currently located in Exeter, Barnstaple, Chelston, Kingsteignton, Plymouth and Torquay. This will enable the Service to complete the inspections required across Devon, Plymouth, Somerset and Torbay, minimising travel times and distance where possible to geographical location by officer. Note that there are no dedicated feed officers within the Service i.e. solely employed to carry out feed work. This area work is part of their overall work which covers the full remit of trading standards functions.

Staff authorised to carry out these duties are required to meet the minimum qualification requirements specified and must maintain their competencies in line with the requirements specified in the Feed Law Code of Practice. They are supported in achieving this through the Service Career Progression Scheme and appraisal system. Training opportunities will be offered in specific areas where there is a need required. It is the intention to hold at least two in-house update days of all feed officers throughout the year.

The inspection programme will be predominately externally funded by the FSA/NTS money received via TSSW at around £90,000. In previous years we have claimed additional funds for follow-up enforcement work to bring businesses into compliance and for sampling at Teignmouth Port. We will look to utilise this again in 2021/22.

An estimated 1.65 FTE (283 officer days) are required for carrying out planned inspections and sampling plan if it were able to be spread out evenly through the year. However, the majority of inspections are done between September and February due to the seasonality of the types of premises we are inspecting. Therefore, in reality, during this period the Service requires around 3.6 FTE.

Quality assessment

Monitoring of individual officer workloads and progress towards allocated feed work will be carried out as part of officers’ monthly one-to-one meetings with their team manager.

Training requirements and targets will be further assessed during annual and six-monthly appraisals.

An annual review of competency including quality monitoring to ensure consistency across the Service is undertaken by the Lead Officer. This will consider accuracy of reporting, entry on to databases, joint visits and it serves to further highlight any training needs for feed officers as a whole. This monitoring will be supported by designated suitably qualified and competent officers and team managers when they carry out appraisals.

Review

The Service provides regular performance reports to the Joint Service Review Panel which includes the progress against feed targets.

Operational targets are reviewed monthly at team manager meetings (TMG).

Inspection and Sampling plans will be reviewed by the Lead Officer on a quarterly basis in line with returns to NTS required for the completion of funded work. Any issues will be brought to the attention of TMG.

Areas for improvement in the Service’s feed delivery are:

  • Continue to improve the quality of data held on the database.
  • Review and update procedures and policies on the agriculture pages on the staff website in line with the recently revised Code of Practice and Practice Guidance.
  • Further improve the use of intelligence resources by officers e.g. IDB.
  • Raise the profile of the service with stakeholders and members.

The above have been addressed during the annual training day in June and October 2020 with all officers carrying out this work fully briefed on how to improve in these areas.



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