Sefton Metropolitan Borough Council

It was evident from audit data that a significant amount of animal feed materials from outside the European Union was imported into the UK through points of entry for which Sefton Metropolitan Borough Council had enforcement responsibility. With the exception of checks on soya products from China undertaken in accordance with legislative requirements, there were no other planned, proportionate and risk-based arrangements in place to deliver official controls on other imported feed.

The authority had developed a trading standards service plan 2010/2011 and a more specific animal feed plan 2010/2011. These contained service delivery information in line with the service planning guidance in the Framework Agreement and references to imported feed. However, the benefits of further developing the service plan to include a comparison of the resources required to deliver the imported feed law enforcement service against resources available to the authority, were discussed.

There was no system in place for the control of the feed service’s documented procedures, which required both full implementation and review. Adequate control measures were also required to ensure that documents could only be amended by designated officers.

The authority’s documented procedure for the authorisation of officers required review and implementation to ensure that all officers carrying out feed law enforcement were authorised appropriately, based on their qualifications, training, experience and competency. Existing authorisations needed to be reviewed and considered by the authority’s legal department to ensure that officers were duly authorised for the duties they were expected to undertake. It was evident from record checks that officers nominated to carry out feed enforcement did not receive an appropriate level of training in accordance with official guidance and the Feed Law Enforcement Code of Practice.

The authority had an electronic database for the recording of feed law enforcement activities that was capable of providing information necessary for official returns. Although the authority had submitted an annual return to the Agency on its feed law enforcement activities, it had not provided any prescribed quarterly returns in relation to its official controls on soya products from China. A procedure for updating, and maintaining the accuracy of the database needed to be developed to ensure that the feed premises register was accurate and kept up-to-date.

In conjunction with the Mersey Port Health Authority, Wirral Borough Council and the City of Liverpool, the authority had agreed an imported animal feed monitoring procedure, which detailed the arrangements for the identification of vessels, feed consignments and the geographical areas of responsibility for imported animal feed enforcement. There were liaison arrangements in place with the port health authority (PHA) to carry out some monitoring of feed consignments entering the port. However, it was clear that this system was not identifying all consignments that could potentially be used for animal feed. Audit checks confirmed that the liaison arrangements had largely lapsed in the latter part of 2010 and the authority acknowledged that minimal official control activity was being undertaken, based on information received from the PHA.

Audit checks confirmed that records of interventions at establishments handling imported feed, contrary to the service’s documented procedure, did not include sufficient detail of any inspection findings, assessments or sufficient information about the nature, size and scale of relevant establishments.

The service had not developed an effective imported feed sampling policy or programme to ensure that appropriate official controls were carried out on feed imported from outside of the EU. Although some sampling had been undertaken in relation to soya products from China, there had been no sampling at feed business operators that used or stored imported animal feed.

The authority had a generic environmental protection department enforcement policy. Feed detention and seizure procedures had been developed, although these needed to be reviewed to include key powers of detention relating to imported feed at the port.

The service had an appropriate documented procedure for the handling of feed safety incidents and Rapid Alert System for Food and Feed (RASFF) notifications, which needed review to reflect current arrangements. There was an emergency out-of-hours contact number for the authority, and audit checks confirmed that the authority had taken appropriate and effective action in response to a recent imported feed incident, even though no formal out-of-hours service arrangements were in place. The benefits of using intelligence gained from such incidents to inform subsequent checks at the port were discussed.

Since April 2009, there appear to have been no effective local liaison arrangements in place to discuss imported feed enforcement and official controls, although it was clear that previously liaison meetings between the relevant authorities had taken place regularly. The benefits for the authority in attending liaison meetings organised by the port operator at the port for all stakeholders were also discussed.

Although the authority had a documented animal feedingstuffs monitoring procedure, it did not appear to have been implemented and auditors noted no evidence of any internal monitoring related to imported feed activities.