Suffolk County Council

It was evident from audit data that a significant amount of animal feed material from outside the EU was imported into the United Kingdom through points of entry for which Suffolk County Council (SCC) had enforcement responsibility.

The authority had developed a food and feed law enforcement service plan 2010/11, and a more specific animal feed guidance document based upon guidance on national priorities for feed authorities issued by the FSA. The plan contained service delivery information in line with the service planning guidance in the Framework Agreement and references to imported feed. However, auditors discussed 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.

In line with general council policy, the service had developed few documented procedures specifically for its feed law enforcement service. Auditors recommended the development of suitable and proportionate documented procedures to provide guidance for officers across all areas of the service, particularly those areas identified as requiring further improvement and development. A suitable system of document control needed to be developed and implemented to ensure that procedures are regularly kept up to date and accurately reflect the work carried out by the team.

The authority had not developed a documented officer authorisation procedure to ensure that all officers carrying out feed law enforcement were appropriately authorised, based on their individual qualifications, training, experience and competency. Existing authorisations needed to be reviewed and considered by the council’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 had received some animal feed 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, which was capable of providing information necessary for official returns. However, audit checks revealed some difficulties in retrieving an accurate estimate of the number of feed importers and feed establishments in the area. 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 port health authority (PHA) and Suffolk Coastal District Council (SCDC), the authority had agreed a formal Memorandum of Understanding (MoU) concerning arrangements for imported animal feed monitoring and delivery of official controls. This document detailed the arrangements for the identification of vessels and potential feed consignments. There were liaison arrangements in place with the PHA to carry out monitoring of high-risk feed consignments entering the port, in accordance with Regulation (EC) No. 669/2009. However, there were no formal arrangements in place for the routine identification of other types of feed and associated products, including those products not subject to additional controls under Regulation (EC) No. 669/2009. Auditors recommended that SCC develop further arrangements with the PHA to ensure that adequate official controls are carried out on all possible feeding stuffs consignments in accordance with Regulation (EC) No. 882/2006.

Auditors made a reality visit to the Port of Felixstowe to assess facilities for sampling and monitoring of imported feed arriving at the port. Auditors were satisfied that the facilities, equipment, infrastructure and PHA procedures met the requirements needed for designated point of entry (DPE) status. In addition, auditors had discussions with an officer authorised by SCC to undertake and supervise sampling on behalf of SCC at the port. The officer was able to demonstrate a detailed and thorough knowledge of imported feed legislation and relevant sampling techniques.

Audit checks confirmed that records of interventions at inland establishments handling imported feed did not always include sufficient detail of any inspection findings or assessments, or sufficient information about the nature, size and scale of relevant establishments. In addition, some records of inspections and findings were not available at the time of the audit.

SCC had carried out some sampling of animal feeding stuffs, aided by an FSA sampling grant. However, auditors recommended that the sampling programme should be reviewed and, if necessary, expanded to take into account the findings from the authority’s review of its feed premises database and any further liaison with the PHA.

The authority had a generic departmental enforcement policy. Under the MoU the PHA had agreed to undertake all necessary enforcement and follow-up actions in liaison with, and on behalf of, SCC. The PHA had developed a range of suitable procedures for the detention of feed consignments and seizure if necessary. Auditors recommended a review of any existing enforcement procedures to also reference all possible enforcement actions on other feeding stuffs and associated products falling outside the remit of Regulation (EC) No. 669/2009.

The service had an appropriate system in place for the handling of feed safety incidents and Rapid Alert System for Food and Feed (RASFF) alerts. There was an emergency out-of-hours contact number for the authority, and audit checks confirmed that the authority had liaised with the appropriate authorities in response to a recent imported feed incident.

The authority had undertaken some ad hoc qualitative monitoring of feed inspections and officer competency. However, auditors recommended that the authority develop and implement a documented flexible and risk-based internal monitoring procedure to review and assess all relevant areas of the feed law enforcement service.