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 (JSRP).
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 (farms), 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 Service priorities in this area, which include a reactive feed sampling programme, utilising social media as an educational tool and having an intelligence-led approach to inspections.
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.
Service Structure for Official Feed:
- Trading Standards Leadership Group (0.1 full-time equivalent (FTE)), plus:
- Lead Officer (0.5 FTE)
- Intelligence and Investigations (0.6 FTE)
- Business Support (2.3 FTE)
- TSConnect Team (0.1 FTE)
This work is estimated to equal 3.6 FTE staff. It was estimated that one-fifth of operational officer time is taken up with Feed work on average per annum, taking into account inspections, sampling, training and Continuous Professional and Personal Development. Slight adjustments were made to this for officers where it is known that more or less time is dedicated to feed work e.g. Lead Officer at 0.5FTE.
Where possible, work is carried out in co-ordination and partnership with other agencies such as the Animal & Plant Health Agency (APHA), Rural Payments Agency and the Veterinary Medicines Directorate (VMD). We also work closely with FSA approved assurance schemes with the ‘earnt recognition’ approach.
Service aims and objectives
Feed work generally is classified as core operational work of the Service, so it is not highlighted as one of the main Service priorities using the Intelligence Operating Model, based on consumer or business complaints.
Instead it receives 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 Devon and Somerset 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 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 | 11 |
| Co Product Producer R12 | 16 |
| Mobile Mixer R04 | 1 |
| Importers | 3 |
| Stores R09 | 4 |
| Distributor A01-08, R01-03 and R05 | 18 |
| Transporter R08 | 8 |
| On Farm Mixer R10 & R11 | 57 |
| Pet Food Manufacturer R06 | 28 |
| Supplier of Surplus Food R07 | 20 |
| Livestock Farms R13 | 128 |
| Arable Farms R14 | 2 |
| Food at Primary Production | 3 |
| Total | 299 |
When carrying out inspections consideration is given to their status in terms of risk score and earned recognition and any Primary Authority (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.
In 2022/23 the focus of the national sampling project is on Feed Mills of which there are five in our Service area which will be included.
Other sampling is shaped 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 2021/22 we received 115 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 31 complaints regarding agriculture matters. In addition there were feed non-compliances linked to animal health and welfare issues, which were investigated as part of bigger cases. Others have required cross-border working with other local authorities and the FSA, as they have involved the use of unauthorised feed additives and salmonella detection in raw ingredients.
The Service is signed up to receive ‘Import of products, animals, food and feed system’ (IPAFFS) alerts and will respond accordingly in line with current guidance to any feed-related incidences.
Other
As the largest Service in the TSSW region we aim to continue taking an active role in the activities of the regional Agricultural Group which includes our Lead Officer
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.
As part of our animal health work with primary producers we will be actively aiming to 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 providing 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.
Resources
A review is carried out annually of the resources required to carry out feed work when producing the Service Plan. Taken into consideration are the results of the annual desktop modelling exercise, unsatisfactory sample results, intelligence from our own database systems and officers, and complaints and trader advice requests received.
This financial year the Service will aim to maintain the competency of 16 members of staff who will carry out the inspection and sampling work above. They will be based mainly in the Business Support and Innovation Team with three members of the Intelligence and Investigations Team retaining their competency.
Officers are based across the six offices 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 of 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, 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 an annual in-house training session at the beginning of the year and to have monthly meetings on Microsoft Teams for all feed officers throughout the year.
The inspection programme will be predominately externally funded by the FSA/NTS money received via TSSW at around £100,000.
In previous years we have claimed additional funds for follow-up enforcement work to bring businesses into compliance and for sampling at Teignmouth and Plymouth Ports. We will look to utilise this again in 2022/23.
Quality assessment
Monitoring of individual officer workloads and progress towards allocated feed work will be carried out as part of officers’ regular 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
A six-monthly performance report is provided by the Service to the JSRP which includes the progress against feed targets.
Operational targets are reviewed regularly at working group meetings.
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 TSLG.
Areas for improvement in the Service’s feed delivery are:
- Continue to improve the quality of data held on the database. Cx software may assist with this.
- Review and update procedures and policies on the agriculture pages on our internal Sharepoint site in line with the 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 with emphasis on greater joint working with partner agencies.
The above have been addressed during the annual training day in April 2022 with all officers carrying out this work fully briefed on how to improve in these areas.