Minutes of Enforcement Liaison Group meeting: 8 November 2001

Thursday 8 November 2001

Venue: Royal Institute of Public Health and Hygiene, 28 Portland Place, London.

Present
Mr D Statham (Chair) FSA
Mr D Hart FSA
M J Barnes FSA
Mr P Boyle FSA
Mr D Walker FSA
Mr B Knock FSA
Ms C Boville FSA
Dr D Reynolds FSA
Ms J Davies FSA Wales
Mr G McCurdy FSA N. Ireland
Mr J Thomson FSA Scotland
Mr D Foot FSA Secretariat
Mr M Davis FSA Secretariat
Mr M Du Val LACOTS
Mr D Boon London Borough of Croydon (LACOTS Food Strategy Group (Chair))
Mr D Walker Shropshire County Council (LACOTS Food Standards Focus Group)
Ms L Corbett Glasgow City Council (LACOTS Food Hygiene Focus Group (Chair))
Mr A Davies Monmouthshire County Council
Mr M Drysdale Belfast City Council
Mr D Neilson COSLA
Ms A Goodwin CIEH
Ms V Saint FDF
Ms S Davies Consumers’ Association
Ms J Longfield Sustain
Mr L Smale Small Business Service

Apologies

Mr M Wight FSA
Mr C Lawson MHS
Mr D Bloomfield Suffolk Coastal District Council
Mr D Pickering TSI
Mr J Dyson BHA
Ms R Kenningham BRC

Agenda Item 1. Apologies

1.1 As listed above.

Agenda Item 2. Minutes of the last meeting (LG35-F)

2.1 The draft minutes of the last meeting had been circulated for comment and a revised version, with amendments in redline strikeout, circulated for members' agreement prior to being placed on the Agency's website.

Matters Arising

Paragraph 2.4 Mr Foot said that the Enforcement Division’s work on electronic communications with LAs, including chairing a working group to look at this issue, had been subsumed within Communications Division’s work on the development of the new Agency website. Mr Du Val said that communications with LAs had always been regarded as an important issue for the LAELG and asked how enforcement views would be fed into this if it was being taken forward by Comms Division. Mr Boyle said he envisaged that the working group which had been set up to look at this issue would be kept informed of developments particularly in relation to communication with LAs. Mr Statham said that communications had been raised as an issue at the recent LAELG away day and suggested that it could be considered as a substantive issue for future discussion by the Group. Ms Corbett asked whether the working group would be considering any problems arising with the electronic monitoring form. Mr Boyle said that any problems raised by LAs in relation to the electronic monitoring form were being dealt with by officials in their day to day contact with LAs. The frequently asked questions guidance which accompanied the electronic monitoring form had been amended to reflect queries received from LAs.

Paragraph 2.10 Mr Foot said that the implications for the Agency arising from the Phillips Report were due to be discussed under Any Other Business.

Paragraph 3.8 Mr Foot said that subsequent to the last meeting a working group had been established to consider the options for hygiene award schemes to increase transparency of standards in food businesses. The issue of food hygiene award schemes was due to be discussed under Agenda Item 6.

Paragraph 4.5 Mr Foot said that a draft consultation paper had been developed on proposals for a register of food business convictions and prohibited persons. The consultation document had been developed in line with the principles agreed at the last LAELG meeting. The consultation paper was currently with senior Agency officials and a meeting to discuss this issue had been scheduled for later this month. Again, this would be discussed further under Agenda Item 6. Mr Davies asked whether it would be possible to circulate the draft consultation paper to the Group. Mr Foot said that the document would be circulated for information subsequent to the internal Agency meeting. Mr Drysdale asked whether consideration had been given in the development of the proposals to the Data Protection Act. Mr Statham said that colleagues in Legal Division had advised that this was not an issue as all the information on the register would already be in the public domain. Mr Davies asked what was proposed in relation to timescales for removal of offences from the register. Mr Hart said that the draft consultation document would specifically seek views on this issue.

Action: Secretariat

Paragraph 5.4 Mr Foot said that, with regard to support for LA prosecutions, the Agency had given financial support to help with complex fraud investigations regarding chicken meat and had explored the possibility of a MOU with the Association of Chief Police Officers. Mr Walker said that support needed to go beyond financial assistance for prosecutions to also consider other enforcement issues. Mr Statham agreed that this needed further discussion and suggested that a working group be established to specifically consider this issue with a view to developing some proposals for consideration at a future LAELG meeting. A number of members, Mr Walker, Mr Davies, Ms Longfield, Ms Goodwin and Ms Saint, all expressed an interest in being involved in the working group. Mr Statham said that the working group might usefully consider the current obstacles to LAs taking prosecutions and how the Agency might most effectively provide support. Ms Saint suggested that the working group also consider central guidance on alternative enforcement approaches. Ms Reynolds agreed and said that it would also be useful to consider how LAs might share examples of good practice when dealing with potential prosecutions. Mr Statham said that officials would take forward establishment of the working group.

Action: Secretariat

Paragraph 5.5 As agreed at the last meeting, an away day was held on 20 September. The outcome of the day was due to be discussed under Agenda Item 3.

Paragraph 8.1 Officials undertook at the last meeting to clarify the position with regard to the additional ¿2.5m per year funding secured for animal feeds enforcement activity. Mr Knock said that for the remainder of the 2001/02 financial year, LAs within Great Britain had been asked to bid for funding to undertake sampling and analysis. For the 2002/03 and 2003/04 financial years, the additional funding would be allocated to LAs in England only via the Revenue Support Grant. He also said that a paper on animal feeds and more specifically mixing in feed on farm enforcement was due to be considered by the Agency Board at their November meeting. Mr Neilson asked whether there would also be additional funding for feedstuffs enforcement in Scotland. Mr Thomson said that FSA Scotland were currently considering a bid for additional funding for Scottish LAs for 2002/2003.

Agenda Item 3. Review of Awayday Report and Summary

3.1 Mr Statham said that he felt the away day had provided a valuable forum for discussion on the role of the Group and the relationship between the various stakeholders represented. He said that a comprehensive report of the day and a summary of the report had been produced and circulated to Group members and invited any comments from the Group. Mr Boon said that unfortunately he had been unable to attend the away day but commented that there was little reference in the report to a partnership approach to enforcement. He asked whether the Group was intended to provide a forum for informing the development of Agency policy or whether it also had a role to influence the policies and decisions of LA representative bodies. Mr Statham said that, as with all stakeholders represented on the Group, the degree of influence that any decisions by the Group had on the policies of the representative bodies would depend on the representatives themselves. The Group had a role in making recommendations but no power to direct representative bodies, or the Agency Board. Mr Boon said that if the Group were to provide a forum for informing the policies of all stakeholders this needed to be reflected in the agenda and discussion papers for meetings. Mr Statham said that the Agency welcomed suggestions for agenda items from all stakeholders. Mr Davies said that he found the away day to be extremely beneficial and suggested that consideration be given to similar events in the future. This was agreed.

Agenda Item 4. Changes to the Group (LG37)

4.1 Mr Statham said that discussion paper LG37, which had been circulated to members, proposed a number of changes to the Group in the light of discussion at the away day.

Name

4.2 Mr Statham said it was suggested that ‘Local Authority’ be removed from the name of the Group to reflect the fact that the Group’s remit covered all enforcement issues rather than simply local authority enforcement and that the Group be renamed the Enforcement Liaison Group. There was some discussion about alternative names including whether it was sufficient to simply remove the words ‘local authority’ and whether the word ‘enforcement’ should be removed. There was a general consensus that the word ‘enforcement’ should be retained as the definition was wide enough to incorporate all the issues which fell within the Group’s remit whilst also giving the Group necessary focus. There was also general agreement that the removal of ‘local authority’ would better reflect the remit and membership of the Group. Mr Statham said that based on the discussion there appeared to be general agreement for the Group to be renamed the ‘Enforcement Liaison Group’.

Action: Secretariat

Terms of Reference

4.3 Mr Boon referred to his earlier comments concerning the Group’s role in influencing local Government policies and suggested that the first bullet point of the terms of reference, which read ‘contribute to the development of Agency strategies…’, be amended to include other stakeholders. Mr Statham said that, as he had commented earlier, it was not the Group’s responsibility to direct other stakeholders in setting their policies. He added that ultimately the Group had been established by the Agency to provide a forum for liaison between the relevant stakeholders with a view to discussing enforcement issues to inform and make recommendations on the development of the Agency’s policies.

4.4 Ms Reynolds suggested that the references to ‘local authority food law enforcement’ in the terms of reference be amended to simply ‘food law enforcement’ to reflect the wider remit of the Group. This was agreed. Ms Longfield suggested that the first paragraph of the terms of reference be amended to read ‘…the Food Standards Agency’s objectives to improve public health and protect consumers’ interests through…’. This was agreed. Ms Longfield also said that the words ‘and to measurably improve public confidence’ could be removed as this was not an aim but more a side effect of improving public health and protecting consumers’ interests. Mr Barnes said that the wording was intended to mirror a key Agency commitment and suggested that it should therefore be retained. This was agreed.

Action: Secretariat

4.5 Ms Saint suggested that the terms of reference include some wording to highlight the Group’s role in ensuring compliance. Mr Barnes suggested that the third sub-point under the first bullet point be amended to read ‘new enforcement mechanisms and other approaches to ensure compliance’. This was agreed. Mr Statham suggested that, in light of earlier discussion, the final bullet point be amended to read ‘consider any other issues relevant to enforcement the way the Agency works with local authority enforcement.’. This was agreed.

Action: Secretariat

4.6 Mr Knock said that, whilst not seeking a specific mention in the terms of reference for enforcement of the law on animal feed, which is a function of local authorities, he believed it should be recognised that this matter could be considered by the Group, especially where there were implications for food law enforcement. This was agreed.

Chairmanship

4.7 Mr Statham said that, as mentioned in the discussion on the terms of reference of the Group, the Group was established by the Agency as a forum for discussion to inform the Agency’s policies on enforcement. This being the case it would not be practical, and indeed officials did not have the remit, to abdicate Chairmanship of the Group. Mr Du Val said he accepted that the Group had been set up to provide a specific forum for the Agency but that he felt the role of Chair was largely to facilitate discussion and did not, therefore, need to be held by the Agency. The Group accepted the Agency view that the Chairmanship should remain with the Agency.

Membership

4.8 Mr Statham said that the paper proposed a streamlined Agency membership restricted to appropriate staff in the Enforcement Divisions, colleagues from Scotland, Wales and Northern Ireland, and the Meat Hygiene Service. Other Agency representatives would continue to receive papers for the meetings but would only attend where an issue directly relevant to their area of responsibility was due to be discussed. Mr Boon said that it would be useful if additional LA representation could be invited to attend meetings if the individual(s) concerned had expertise in a subject due to be discussed. Mr Statham agreed that this would be beneficial and added that additional consumer and industry representation which provided expertise on a specific issue could also be invited to attend.

4.9 Ms Longfield said that she welcomed the suggestion to extend the membership of the Group to include the Association of Public Analysts (APA). Mr Boon said that the Public Health Laboratory Service (PHLS) should also be considered. Mr Statham agreed and undertook to invite both bodies to attend future meetings. Mr Du Val said that, as the Group had a UK remit, there may be a case for extending the membership to include the Royal Environmental Health Institute of Scotland (REHIS). Mr Thomson said that FSA Scotland would be establishing a mirror group to consider Scottish enforcement liaison issues which would link with the ELG via FSA Scotland and COSLA representation. He added that he would not object to REHIS being represented on the ELG but again only as a link to the Scottish mirror Group. Ms Corbett suggested that COSLA and REHIS could consider sending a joint representative to ELG meetings. Ms Longfield said that extension of the membership to Scottish LA groups could have a knock on effect for the consumer and industry bodies and added that there was a danger of the Group becoming too large and unwieldy. Mr Statham agreed and asked that Mr Thomson consider the need for additional representation or whether views could be fed into discussion via the mirror groups.

Action: Mr Thomson / Secretariat

4.10 Mr Boyle and Ms Boville queried the lack of any English District Council representative amongst the local authority membership of the Group, given that District Councils made up well over half of all local authorities. Mr Du Val said that the Group’s local authority representatives were drawn from LACOTS’ network of food liaison groups, the structure of which allowed for the views of District Councils to be taken into account. Mr Davies said that there was a responsibility on Group members to ensure that they kept associated organisations kept up to date with developments arising from the Group’s discussions. Ms Corbett said that she was aware of a number of LACOTS initiatives to raise awareness of the work of the Group. Mr Statham agreed that members had a responsibility to communicate the work of the Group to the wider audience.

Other Issues

4.11 Mr Statham asked whether there were any other issues about the Group that members wished to discuss. He said that the possibility of breaking into smaller discussion groups within the context of the ELG meetings had been suggested. It was agreed that this would be worthwhile. Mr Boon asked that members be given early sight of the draft agenda for meetings to provide an early opportunity to suggest additional items. This was agreed. Ms S Davies said that she had appreciated the opportunity for a full day’s discussion provided by the away day and commented that the full agendas and relatively limited time available for discussion within the regular ELG meetings often did not allow for detailed discussions on issues. Mr Statham agreed and suggested that the number of agenda items at future meetings be minimised to allow for comprehensive discussion of priority issues and also that consideration be given to longer meetings. This was agreed. Mr Hart said he felt that more use could be made of correspondence between members to inform meeting papers; save time at meetings and promote a more informed debate. Ms Corbett suggested that ‘Matters Arising’ be taken at the end of the meeting. Mr Statham suggested that a paper providing updates on Matters Arising be circulated prior to the meetings so that only those issues the Group wish to be discussed needed to be raised at meetings. Both these suggestions were agreed.

Action: Secretariat

Agenda Item 5. The Future Work of the Group

• Issues identified at the away day as potential priorities
• Consideration of other possible issues to be addressed
• Work programme and mechanisms
• Relationship with Board and with Agency objectives

5.1 Mr Statham said that the Group had identified five issues at the away day which the Group should consider as a matter of priority. However, it was acknowledged at the away day that, due to time constraints, these priority issues would need to be reconsidered at this meeting. Those issues identified at the away day were: licensing; HACCP; consistency (need to define terms); recruitment and training of enforcers; and traceability.

5.2 Mr Walker said that he felt the draft Report on LA Food Law Enforcement in the UK raised a number of important issues about LA food law enforcement and suggested that the Group consider the issues raised. Mr McCurdy suggested that the findings of the Agency’s programme of audits could be considered at the same time to identify common issues across the UK. This was agreed. Mr Statham said that issues stemming from the draft Enforcement Report were due to be considered by the Board at one of their Spring 2002 meetings and also that a summary report of audit findings was also due at this time. He therefore suggested that it would be appropriate for the Group to consider these two items together at the next meeting of the Group scheduled for February 2002. This was agreed.

5.3 Mr Neilson said that he felt that recruitment and training of enforcement officers was a fundamental issue which needed to be considered as a priority. Mr Barnes agreed and said that the Group was well placed to look at recruitment as a strategic issue. Ms Corbett queried how the Agency would influence recruitment and also how this would be viewed by the professional bodies and LA representative bodies. Mr Statham agreed that this was a fundamental issue and he hoped that other bodies would value the Group’s input. Mr McCurdy said that the recruitment of enforcement officers in Northern Ireland was not a problem, but that the food law enforcement service was not seen as an attractive area to work in due to the amount of regulation. Mr Barnes agreed that it would be important to consider the different reasons for the decline in recruitment across the UK. He suggested that practical help could be given to colleges in the form of funding for food law enforcement research projects to make courses more attractive to students. Ms Goodwin said that the CIEH had carried out a significant amount of work on recruitment and undertook to provide feedback to the Group to inform discussions. Ms Reynolds said that it might also be worth considering veterinary involvement in food law enforcement and the role of veterinary surgeons.

5.4 Mr Boon said that it was important to recognise that it was not only EHOs and TSOs carrying out LA food law enforcement but that there were a number of other officers also involved. He suggested that the Agency might wish to consider looking at levels of authorisation and qualification requirements. Mr Statham said that the Agency could not be perceived as lowering qualification requirements to achieve a greater level of enforcement and that there was a need to maintain the current standard of enforcement officers. He suggested that the Group’s discussions could draw on the experience of recruitment in other areas of LA activity. Mr Du Val agreed that this would be beneficial and suggested that other Government Departments such as HSE and DTI could be consulted. Ms Saint suggested that industry could be consulted as well, specifically the experience of third party accreditors. It was agreed that the issue of recruitment and training of enforcement officers should be considered at a future meeting. It was also agreed that the other bodies referred to during discussion should be consulted with a view to providing information or attending the meeting to inform the debate.

5.5 Mr Statham said that licensing was also an issue which had been raised by members on a number of occasions and which had appeared in the list of priority issues. Mr Boon said that LACOTS had produced a discussion paper on this issue, which had been circulated to ELG members, which could inform discussions. Mr Statham said that the Consumers’ Association had also developed a paper on the issue of licensing. A paper on the wider implementation of HACCP to be discussed by the Board at their November meeting also considered the issue of licensing as a potential option once HACCP take up had been increased. He suggested that all of these documents could help inform discussion. Ms S Davies said that the Consumers’ Association would like to see licensing used to ensure the effective implementation of HACCP in all food businesses.

5.6 Mr Boon said that he would like the issue of licensing to be discussed separately from any discussion on HACCP. Mr Statham said that licensing would require a change to legislation and was therefore seen as a long term option, whilst wider implementation of HACCP was viewed as a potential stepping stone to facilitate implementation of any licensing initiative. Ms Goodwin said that she was aware of work to assess the success of Butchers’ Licensing and suggested that the outcome of this work could be fed back to the Group to further inform the debate. Mr Barnes said the Agency had also commissioned some research on Butchers’ Licensing which could be fed into discussions. Mr Statham suggested that one of the 2002 meetings be set aside to consider the issue of licensing and HACCP. He also suggested that the various documents referred to and any other sources of information that members were aware of could be circulated to the Group to inform discussions. This was agreed.

5.7 Ms S Davies said that traceability was a major issue especially with regard to recent developments within the EU on labelling of GM foods. Mr Statham agreed that this was a major issue which had an impact upon much of the Agency’s work. He said that a paper on this issue for consideration by the Agency Board, which could help inform discussion, was currently being developed.

5.8 Mr Statham said that the Group had agreed four distinct areas of work which could be considered during the meetings scheduled for 2002. As discussed earlier, due to the timetable for Board consideration, the Enforcement Report and summary of audits would need to be considered at the first meeting in February. Mr Statham said that the Board paper on traceability was also due in Spring and it was agreed that, if future ELG meetings were to be held over a whole day, there would be sufficient time to also consider this issue at the February meeting. It was agreed that the ELG meeting scheduled for May could consider the issue of recruitment and training of enforcement officers, the meeting scheduled for August could consider licensing and HACCP and that the agenda for the final meeting scheduled for November should be left open. It was also agreed that officials would consider combining the May meeting with another ELG away day. Mr Statham said that officials would consult members for relevant documents to support discussion which could then be circulated via the secretariat prior to each of the meetings.

Agenda Item 6. Transparency of standards in food businesses (LG38)

6.1 Mr Statham said that paper LG38 on transparency of standards in food businesses had been circulated to the Group. This issue had also been discussed at previous Group meetings, most recently in May where it had been agreed that two working groups should be established; one group to take forward development of a public consultation on an Agency Register of food business convictions and prohibited persons and the other to discuss options for a national food hygiene award scheme. A proposed public consultation document on a convictions register was currently with senior Agency officials and was due to be discussed on 21 November. The working group on options for a national food hygiene award scheme had yet to meet.

6.2 Ms S Davies said that transparency of standards in food businesses was an important issue which had the potential to contribute to improve standards in businesses and inform consumers. The Consumers’ Association felt that these objectives could be best delivered by a scoring scheme rather than award scheme. Mr Barnes said that the success of any national hygiene award scheme would be influenced by local authorities' ability to cope with the additional burdens involved in effectively implementing such a scheme. The consistent application of an award scheme would also be dependant upon local authorities ability to meet the basic enforcement requirements with regard to inspection frequencies. Mr Statham agreed that a scoring scheme initiative could be beneficial but that without effective enforcement to support it there was a danger of misinformation because of an inability to visit/revisit at the appropriate frequency. Mr Neilson indicated that the introduction of such a scheme would be a considerable resource implication for LAs and this has to be recognised, in financial support terms, by the SFA and central Government. Ms Corbett agreed that there were resource implications for a national scoring/award scheme and also questioned the usefulness of such schemes in the light of the Canadian survey of these initiatives which had been circulated to the Group. This survey raised a number of questions about the evaluation of the usefulness of such schemes. Ms S Davies said that she could provide information on the evaluation of existing initiatives if required. This was welcomed.

Action: Ms S Davies

6.3 Ms J Davies said that FSA Wales would be launching their hygiene award scheme, which was based on the risk assessment in Code of Practice 9, in January 2002. Mr Statham suggested that the Welsh award scheme be used as a pilot to inform debate on the development of a national scheme. He added that the information mentioned by Ms S Davies and any other relevant information members were aware of could also help focus discussions. It was agreed that a meeting of the working group established to consider this issue should be arranged.

6.4 Mr Statham said that the proposed convictions register provided a more immediate vehicle for increased transparency of the standards in food businesses and asked members for their views. Ms S Davies said that she supported the establishment of a convictions register seeing it as an opportunity to improve standards through increased publicity. Mr Statham said he was conscious that with the likely delays in the court process and also the likelihood of businesses taking immediate appropriate action to rectify any infringements identified, the register might quickly become out of date. Ms Saint agreed that often those named might actually have improved significantly or simply changed name to avoid identification. Mr Statham said that, as mentioned earlier, the proposed consultation on the convictions register was due to be discussed at an internal meeting on 21 November. He said that the secretariat would provide feedback on the outcome of this meeting and, if appropriate, circulate the draft consultation document to members for information.

Agenda Item 7. Updates from England, Scotland, Wales and Northern Ireland

Northern Ireland

7.1 Mr McCurdy said that the NI audit programme would commence from January 2002. The first five local authorities had been identified and one audit would be conducted each month. FSA NI were in the process of establishing a number of liaison groups with local authority representatives, the Department of Agriculture and Rural Development and other relevant bodies. FSA NI were also involved in ongoing support for local authorities via a number of initiatives, including a monitoring seminar, a labelling enforcement seminar, two HACCP assessment courses and the shellfish industry forum.

Scotland

7.2 Mr Thomson said that half of the 32 Scottish local authorities had now been part audited, with all authorities due to be part audited by the end of the financial year. Two audit reports had been placed on the Agency’s website. FSA Scotland would be producing a summary report of findings early 2002. Scottish officials were currently involved in establishing mirror groups to the ELG and Framework Agreement Sub Group which would feed into the UK discussions. The Scottish Food Advisory Committee were currently considering links with enforcement.

Wales

7.3 Ms J Davies said that two audits of Welsh local authorities had now been completed but neither of the reports had been finalised. FSA Wales were currently in discussions with Welsh local authorities with a view to organising meetings two or three times a year to discuss priority issues.

England

7.4 Mr Foot said that 25 local authorities in England had been subject to audit since the programme was launched in April 2001. 13 final audit reports had been published and were available on the Agency’s website. A further 15 audits were scheduled before the end of March 2002. All local authorities selected for audit had been advised of the programme. He added that FSA England would be readvertising for auditors shortly and although there is unlikely to be a problem recruiting EHOs there are likely to be difficulties recruiting suitable TSOs.

7.5 Mr Thomson said that is was worth noting that the auditors from all of the Agency’s constituent parts had recently met to discuss consistency of auditors, audit findings and a number of proposed amendments to the Standard where audits had highlighted inconsistencies or deficiencies in the current wording. It was proposed that these meetings would be held on a regular basis. Mr Foot said that the revised Standard would be circulated to the ELG once agreed by the Framework Agreement Sub Group.

Agenda Item 8. Any Other Business

Health and Safety Commission Priority – Slips and Trips

8.1 Mr Statham said that the Agency had recently been approached by the Health and Safety Executive with a request for assistance from local authority enforcement officers in promoting their ‘Slips and Trips’ campaign whilst undertaking their food law enforcement activity.

Enforcement in Ethnic Food Premises

8.2 Mr Statham said that the Agency were currently conducting a review of publications inherited from MAFF and DH with a view to rationalising the number of publications and updating and rebranding those which were considered to still be relevant. The new Agency publications would be produced in a number of different languages. Ms S Davies asked for an update on the Agency's food hygiene campaign. Mr Barnes said that the campaign was now due to commence in January 2002, and that campaign literature was currently under development.

FVO Missions

8.3 Mr Walker (FSA) said that the FVO had conducted a mission from 25 – 29 June to consider the UK's BSE controls. The visit, which had been co-ordinated by DEFRA, comprised a number of site visits to verify the UK's implementation of control measures relating to Specified Risk Material controls, BSE epidemio-surveillance and new feed controls. The draft report had been received and the Chief Veterinary Officer had made a number of comments, mostly relating to factual accuracy. The final report was due shortly.

8.4 Mr Statham said that the FVO had also recently conducted a mission to the UK to look at Border Inspection Posts (BIPs). Eight BIPs had been visited between 15 – 25 October and colleagues in DEFRA who had co-ordinated the mission expected to receive the draft report shortly. He said that LACOTS would be consulted on the UK's response to the draft report where it impacted upon local authority enforcement.

the Phillips Report

8.5 Mr Statham suggested that Agency officials produce a paper on the implications for enforcement of the Phillips Report from both a central and local Government perspective and that this paper be considered by the Group at its next meeting. This was agreed.

Action: Secretariat

Agency Board

8.6 Ms Corbett asked whether it would be possible for a Board member to attend a future ELG meeting. Mr Statham agreed to look into inviting Sir John Krebs or Suzi Leather to attend for part of one of the meetings scheduled during 2002.

Agenda Item 9. Date of Next Meeting

9.1 Proposed dates for meetings during 2002 had been circulated to group members. The dates proposed were 5 February, 14 May, 13 August and 19 November. It was agreed that due to the timing of the Spring Board meetings the 5 February meeting should be moved back. The secretariat now propose that the next meeting of the ELG be held on 19 February 2002.