Chapter 1 Introduction

Sections

1. Background and Functions

2. Relationships with Other Bodies

3. Communication and Guidance

4. Annexes

1. Background and functions

In this section

1.1 Food Standards Agency

1.2 Food Standards Agency operations (meat hygiene)

1.3 Contacts

1.1 Food Standards Agency

1.1.1 Food Standards Agency remit

The Food Standards Agency (FSA) is an independent Government body, established in 2000 to protect public health and consumer interests in relation to food.

The FSA is the national authority responsible for food safety and food hygiene across England, Wales and Northern Ireland.

FSA’s remit includes:

• negotiations on behalf of England, Wales and Northern Ireland by legal experts and policy officials to ensure that assimilated law reflects the interests of consumers
• providing Food Business Operators (FBOs) responsible for placing unsafe food on the market with appropriate advice to withdraw or recall it and working with other enforcement authorities to take appropriate action
• ensuring good food hygiene, through various initiatives delivered in partnership with Local Authorities (LAs)
• ensuring minimum standards of meat hygiene are maintained within approved slaughterhouses and meat establishments throughout Great Britain. In Northern Ireland, this role is carried out by the Department of Agriculture Environment and Rural Affairs (DAERA)

This guidance manual, the Manual for Official Controls (MOC), contains details of the tasks, responsibilities and duties FSA staff and veterinary contractors undertake in approved meat establishments.

This version of the Manual for Official Controls has been updated to take account of new EU Official Control requirements which came into effect on the 14 December 2019. It is important that FSA Authorised Officers, FSA and LA staff implement the legislation as set out in this manual.

Guidance on some aspects of the new Official Control package has not yet been introduced as these require more consideration. The FSA is working on this and as guidance is finalised it will be communicated to staff and included within the MOC. In the meantime, staff must continue to undertake official controls as outlined within the MOC.

The FSA’s website

1.2 Food Standards Agency operations (meat hygiene)

1.2.1 Principal functions

The principal functions of FSA staff working in approved meat establishments are listed in the table below together with the Government department that holds the policy lead.

Principle function table

Function	Policy lead
Provision of meat inspection and health marking	FSA
Enforcement of food safety and hygiene legislation in approved slaughterhouses, cutting plants and game handling establishments, together with co-located plants, processing minced meat, meat preparations, mechanically separated meat and meat products.	FSA
Enforcement of controls over Specified Risk Material (SRM) and other animal by-products (ABP)	FSA, (TSE) Defra and Welsh Government
Enforcement of welfareatslaughter regulations	Defra and Welsh Government
Collection and despatch of samples for statutory veterinary medicines residue testing and testing of suspect cases	Defra, Veterinary Medicines Directorate (VMD)
Collection and despatch of sheep and goat brain stem samples for the testing of Transmissible Spongiform Encephalopathy (TSE)	Defra and Welsh Government
Supervision of Bovine Spongiform Encephalopathy (BSE) testing	Defra and Welsh Government
Collection and despatch of samples for examination and testing for some notifiable diseases	Defra, Animal and Plant Health Agency (APHA)
Provision of export certification when required by the importing authority or by assimilated law	Defra / APHA
Inspection of imported meat in approved premises	FSA
Provision of services to British Cattle Movement Service (BCMS) for the Cattle Tracing System	Defra (Rural Payments Agency)
Provision of other services on a repayment basis to other Service Level Agreement customers	Other customers

1.3 Contacts

FSA teams:

Corporate Support Unit York Transactions Team (Tel: 01904 232177)

Approvals and Registrations Team (email: approvals@food.gov.uk Tel: 01904 232060)

SLA and Contracts Team (email: sla.contracts@food.gov.uk Tel: 01904 232093)

Updated [FSA Helpline (0330 332 7149)]

Data and Performance Team (email:operations.data@food.gov.uk)

MOC Guidance Team (email:MOC@food.gov.uk)

National Food Crime Unit (email:foodcrime@food.gov.uk Tel: 800 028 1180. For non-UK mobiles or calls from overseas use 0207 276 8787.)

Throughput Team (email:Throughput@food.gov.uk Tel: 01904 232209)

Food Incidents Team (email:foodincidents@food.gov.uk Tel: 020 7276 8448)

Imported Food Team (email:Imported.food@food.gov.uk)

Other:

Department for Environment, Food and Rural Affairs

Animal and Plant Health Agency (APHA)

Find a relevant APHA regional office (Tel: 03000 200 301)

Local authorities

Find a relevant LA office

Companies House (email:enquiries@companies-house.gov.uk Tel: 0870 33 33 636)

Food Standards Scotland – Operations (email:operations@fss.scot)

2. Relationships with other bodies

In this section

2.1 Introduction

2.2 Department for Environment, Food and Rural Affairs

2.3 Animal and Plant Health Agency

2.4 Local Authorities

2.5 Meat industry

2.1 Introduction

2.1.1 Stakeholders and customers

The FSA has many stakeholders and customers, primarily consumers and the public, but also including:

• other government departments and agencies
• health ministers in England, Scotland and Wales
• meat industry
• halal, kosher and religious slaughter groups
• staff and their professional / representative organisations
• Local authorities (LAs)
• farming industry
• animal welfare organisations
• competent authorities of other countries
• European Commission (EC)
• DAERA / Veterinary Public Health Unit (VPHU)

2.1.2 Service standards

Our approach to customers and stakeholders, including Food Business Operators (FBOs) and their staff, must be:

• courteous
• professional
• considerate
• patient

FSA officials must always make a clear distinction between statutory requirements and recommendations of best practice. All advice and enforcement action should be proportionate and comply with the Enforcement Policy in Meat Plants.

Reference: For additional information see chapter 7 on ‘Enforcement’.

2.2 Department for Environment, Food and Rural Affairs

2.2.1 Responsibility

Defra are the central competent authority for animal health and animal welfare legislation in England.

2.2.2 Defra executive agencies

FSA Operations carries out work on behalf of the following Defra Executive Agencies:

• Rural Payments Agency (RPA), which incorporates BCMS for cattle identification matters
• VMD for medicinal residues
• APHA for animal welfare, identification and disease control and monitoring

2.2.3 Work on behalf of Defra

The work that FSA undertake on behalf of Defra and its agencies is outlined in this chapter at section 1.2.

2.2.4 Contact information

Defra can be contacted via their website.

2.3 Animal and Plant Health Agency

2.3.1 Background

FSA Operations works closely with APHA on matters relating to animal welfare and disease control.

2.3.2 Contact information

More information on the operational responsibilities and structure of APHA can be found via their website.

2.4 Local Authorities

2.4.1 LA purpose

LAs provide services directly to local communities. These services include trading standards and environmental health.

2.4.2 LA Animal Health Enforcement Officers

County Councils, Unitary Authorities, Metropolitan Borough Councils and London Boroughs are responsible for the enforcement of legislation relating to the health and welfare of farmed animals. The Trading Standards departments within these authorities usually provide this service, but this is dependent on the individual structure of each authority.

LA Animal Health Officers are responsible for the enforcement of legislation related to the health and welfare of animals on farms and during transport. The legislation covers animal identification, animal movements, disease control, animal welfare, animal by-products, bio-security and contingency planning.

LA Food Officers may visit food premises and have right of entry.

2.4.3 LA Food Enforcement Officers

LA Environmental Health Officers are responsible for enforcement of all food safety and hygiene legislation in all registered and approved food establishments, except for slaughterhouses, cutting plants and game handling establishments requiring approval by the FSAand those approved meat processing plants co-located to slaughter, cutting and game handling premises.

LA’s Trading Standards Officers are also responsible for all food standards enforcement, animal health and animal welfare in transport provisions.

Food establishments falling within the remit of the LA range from major national manufacturers to stand-alone cold-stores where the FSA is not present.

LA Food Enforcement Officers are also responsible for the prevention of illegal slaughter outside approved establishments, and for investigating food complaints from consumers.

2.4.4 FSA and LAs

Our officials work closely with LAs. Particularly Animal Health Officers, Trading Standards Officers (TSOs) and Environmental Health Officers (EHOs). LA officers deal specifically with:

• welfare of animals in transit
• confirmation of validity of cattle passports
• processing of animal by-products
• animal identification
• movementand documentation relating toanimals
• bio-security
• beef labelling requirements
• durability marking of food
• complaints from the general public relating to physical, chemical and microbiological contamination of meat
• issues relating to meat hygiene outside approved establishments

2.4.5 Relationships

Effective communication between FSA staff and LA enforcement officers is essential. Communication can:

• identify local risks, consumer complaints and concerns
• promote understanding of individual pressures and priorities
• facilitate successful enforcement activities that make the most effective use of local resource

2.4.6 Means of communication

Local communication channels between FSA officials and the LA officers must be maintained, for example:

• proactive and informal communication when LA enforcement officers are attending slaughterhouses
• maintaining ongoing discussions in relation to referrals or areas of common interest
• inviting FSA staff to LA regional meetings where appropriate, to discuss LA priorities and issues; FSA staff attending LA regional meetings where resource allows, and contribute to discussions
• considering possible joint local training opportunities, and sharing of information

2.4.7 Partnership working

Effective partnership working by the FSA and LAs will help achieve enforcement objectives and will ensure they are resourced effectively.

The FSA should always provide LAs with referral information at the earliest opportunity.

LAs should respond to the referrals at the earliest opportunity or advise when and how they will be able to respond. Where LAs are unable to respond straight away, the LA should offer advice to FSA staff on any immediate action (for example, appropriate evidence gathering) required to ensure future enforcement action is successful.

LAs should proactively advise FSA staff on the outcomes of any non-compliance detected at a slaughterhouse and explain why such an enforcement approach has been taken.

2.4.8 LA food complaints

Periodically LAs receive complaints from consumers and retailers about meat, meat products / meat preparations / MSM produced in approved establishments.

In order that the matter is investigated, the LA should refer the complaint to Corporate Support Unit (CSU) at York.

CSU will assign an appropriate officer at the establishment concerned to investigate. The assigned officer will be provided with a Food Complaint Investigation Report for completion.

Once the investigation is concluded and the form completed by the assigned officer, it must be returned to CSU and any physical evidence handed back to the LA officer who referred the matter (observing all security and continuity of evidence issues).

2.5 Meat industry

2.5.1 Liaison with industry

As well as day-to-day dealings with FBOs, the FSA also liaises with industry representatives through their respective organisations.

3. Communication and guidance

In this section

3.1 Lines of communication

3.2 Manuals and guides

3.3 Daybook

3.4 Official notebooks

3.5 Operations staff personal conduct

3.6 Authorisation documents

3.7 Modern Slavery and Human Trafficking (MSHT)

3.1 Lines of communication

3.1.1 Communication procedure

All staff follow a standard set of procedures when dealing with communications and queries. These procedures allow FSA Operations staff to work efficiently and effectively. There are situations where the lines of communication are different to those detailed here and are outlined in the relevant instructions.

3.1.2 Summary

The table below summarises the point of contact for technical advice, and also provides points of contact where non-technical advice is required.

Note: In Urgent Improvement Necessary establishments, technical matters should be discussed by the Field Veterinary Co-ordinator (FVC) and the contactor’s Technical Manager (TM). The FVL should be involved in these discussions when necessary.

Point of contact summary

Advice required by	Technical Advice given by	Non-Technical Advice given by
Meat Hygiene Inspector (MHI)	OV	Inspection Team Leader (ITL)
cOV	FVC (following their contractors’ procedure via their TM)	Refer to their contractor’s TM
eOV	FVC	ITL
FVC	FVL	Operations Manager (OM) / Head of Operational Delivery (HOD)
ITL	FVC	Area Manager (AM) / OM
AM	FVC	OM / HOD
OM	FVL	HOD

3.1.3 FBOs seeking advice

FBOs should be made aware that they should ask for advice in the first instance from their OV.

3.1.4 Technical advice for OMs / HODs

AMs / OMs / HODs should always seek technical veterinary advice from the FVC / FVL and / or FSA legal when making decisions relating to application or enforcement of official controls.

3.1.5 Internal communication of non-compliance reporting

When reporting an incident regarding any consignment arriving at the premises, which does not comply with the Regulations, the Authorised Officer (AO) must complete an Internal Communication of Non-Compliance Report (ENF 11/22).

Records of AO reports are monitored in York. This analysis allows the premises regularly dispatching non-conforming product to be identified and enables follow-up action to be initiated.

Reference:See chapter 9 on ‘Forms’.

3.1.6 Liaison with other authorities

There will be occasions where it will be necessary for the OV to contact other authorities, such as APHA, LAs, The Environment Agency etc. For ease of reference, the OV should be aware of their local points of contact.

The ‘Farm to Fork’ wall poster, was issued to all FSA facilities in slaughterhouses may be used to record contact details for each Authority.

Reference: See Annex 1 for an example of the poster.

3.2 Manuals and guides

3.2.1 Manual for Official Controls

The MOC provides details of the tasks, responsibilities and duties FSA staff and veterinary contractors undertake in approved meat establishments.

Volume 1 contains detail of the official controls and forms.

Volume 2 contains relevant legislation.

The manual includes guidance for staff on:

• inspection
• verification and audit
• health marking
• decision making and actions to be taken following official controls
• enforcement
• sampling procedures
• monitoring and surveillance programmes

Note:

1. The OV is responsible for ensuring that all members of the team read and understand the instructions and is also responsible for making the FBO aware of any changes to the manual
2. All staff must be aware of and follow the instructions in the manual unless there is good reason to depart from it. Where the guidance in the MOC is departed from the rationale for this should be clearly recorded

3.2.2 User identifies requirement for MOC amendment

Users of the MOC may identify areas of the manual where they feel that an amendment to existing instructions is warranted. In this case, they should email the Guidance Team, providing full details of their suggestion for improvement or amendment.

The Guidance Team will evaluate the suggestion and commission to the relevant Portfolio Group.

3.3 Daybook

3.3.1 Daybook maintenance

An official daybook must be maintained by FSA staff at each approved establishment. The day and date of operation must be entered by the AO on arrival at the premises. All operational staff should contribute to the daybook when necessary. The daybook is the property of the FSA and must remain under official control at all times. The daybook should not be used in place of other operational records or to needlessly duplicate information recorded elsewhere.

After completion of the day’s entries, the AO or Inspection Team Leader (ITL) should enter their signature then rule a line across the page, immediately below the signature. This is to prevent further, non-contemporaneous, entries being made.

3.3.2 Daybook access

All FSA operational staff must have ready access to the daybook. The OV should inform the FBO that they are entitled to read and make entries in the daybook and reasonable access should be provided.

3.3.3 Daybook security

The Daybook is FSA property and needs to remain under the control of the FSA or its SDP at all times. It is a requirement that the AO ensures that the Daybook is appropriately secured in a lockable storage unit where provided and available. In establishments where it has not been possible to provide a lockable storage unit, it may be appropriate to make local arrangements to keep the Daybook as secure as possible in an alternative location with the agreement of the local management team including the FVC. Those establishments should inform CBI to record them on a central record.

Evidence recorded contemporaneously in a Daybook, such as records of conversations with FBOs and accounts given by different AOs, is often essential evidence in a case and scanned copies of such entries are often used as exhibits. The defence is entitled to see the best evidence (the original version) of the Daybook to ensure the version being exhibited correlates to the original and has not been changed or added to. Therefore, it is vital that the security of the Daybook is maintained so any evidence within, is retained in its original form to comply with the Criminal Procedures and Investigations Act 1996 (CPIA). [See MOC Chapter 7, Section 2.5 for further guidance on gathering and preserving evidence in accordance with CPIA].

3.3.4 Other daybook functions

The daybook should be used to:

• record the health mark number(s) issued to or used by operational staff
• record the serial numbers of seals applied
• record the start and end times of regulatory duties
• record the time of the first kill and last carcase inspected each day, togetherwith any relevant comments; inspection teams may choose to record specific times for each species slaughtered at their establishment
• create a daily record of significant incidents, events or actions which occur at the establishment
• record specific actions taken by the FSA
• provide a means of communication between members of the operational team
• record details of non-compliances or offences that may become a source of evidence for legal proceedings
• record details of enforcement action taken by operational staff
• record verbal technical advice given by Veterinary colleagues or management to all AOs or other operational staff

Note: Contemporaneous notes should be recorded in your personal official notebook where access to the daybook is not readily available. These notes need not be transcribed into the daybook although a reference to their existence may be made.

Reference: See topic 3.4 on ‘Official notebooks’ in this section for additional information.

3.3.5 Arrival and departure

For health and safety purposes all members of the FSA team and their visitors must print their name, designation and time of arrival and departure at the establishment. If necessary, extend the vertical lines by ruling down. After all expected staff have arrived, the ITL should rule across the daybook page leaving four blank lines to accommodate other FSA officials who may visit the establishment.

Note: These entries must be signed by the team member or visitor at the time of departure from the premises.

3.3.6 Use and recording of stamps

It is very important that Health Marks (HMs) are controlled to prevent fraudulent use. All stamps used by FSA staff working in approved establishments must be kept in secure storage when not in use and be recorded in the daybook when issued and returned.

3.3.7 Health mark stamp

All members of staff using a HM stamp must record:

• the number of the HM and the time of issue
• the time stamps are returned to storage

3.3.8 Guidance on daybook entries

All entries in the daybook may be disclosed, for example, to the FBO, and must be professional and courteous. The daybook is an open document and it may be used as evidence in court.

Entries in the daybook:

• must not be written in offensive language
• must not be derogatory about any individuals
• must adhere to the facts
• must state professional opinions that the author is prepared to defend in court if necessary
• must not be used to record disagreements within the team
• must not be used to record criticism of any FSA staff or policy

Daybook entries must be:

• indelible (in ink or ballpoint pen, not pencil)
• relevant
• factual
• legible
• concise
• unambiguous
• written in clear English
• contemporaneous
• signed with the person's name (not just initialled)
• dated

3.3.9 Record of incidents

The format to be used to record incidents should include:

• time of the incident
• description of the incident
• action taken, including details of evidence collected and held under official control and advice given
• names of FSA and FBO staff involved

3.3.10 Retention

In accordance with FSA retention policy, all daybooks should be securely retained for a period of 6 years prior to disposal.

Older daybooks should not be sent for disposal without the approval of the OM / HOD.

3.4 Official notebooks

3.4.1 Official notebook use

These are to be used for recording contemporaneous notes where the daybook is not readily available; for example, where an incident occurs in the lairage that requires facts to be recorded immediately or where the OV is making notes at a meeting with the FBO.

The use of the notebook is not to replace the plant daybook for recording of day-to-day activities and is only to be used for recording factual information, which may need to be presented in court at a subsequent prosecution.

3.4.2 Reference to notebook entries

Where information is recorded in an official notebook, this need not be transcribed into the daybook; however, an entry should be made in the daybook referring to the fact that notes have been taken.

3.4.3 Important points

The notebook may be inspected in court and the following guidance must be adhered to maintain validity:

• record name on front cover, designation and date started
• make all entries with ink or ballpoint pen
• include only original entries and do not copy notes from elsewhere
• record the date and time at commencement of an entry, and upon completion
• enter the notes at the time ‘the offence’ is witnessed or as soon as possible afterwards whilst the facts are fresh in the memory

Note: Include names of other FSA staff present at the time

• if makingalterations, strikeapen through the words, and make the correction,initialling in left hand column; notes must not be erased
• do not remove pages from the notebook
• sign and date each entry at the base of each page
• do not use the notebook for any purpose not connected with your official duties

The notebook may have to be produced in court and read by all parties so entries must be relevant, factual, legible, concise and written in plain English.

3.4.4 Security

You are responsible for ensuring the security of your notebook and producing it in court. Further notebooks are available from CSU on return of your completed notebook.

3.4.5 Return of all notebooks

Notebooks remain the property of the FSA and must be returned prior to leaving the FSA or when requesting a further notebook.

3.4.6 Storage of completed notebooks

Completed notebooks which have been returned as above will be stored and may be required for evidence in the future.

3.5 Operations staff personal conduct

3.5.1 Staff conduct

All staff should adopt, maintain and demonstrate best practice in the course of their duties and conduct themselves in a professional way at all times.

The FSA takes incidents of bullying and harassment very seriously. Information, including policies and other resources can be found on the FSA Intranet Bullying and Harassmentpages.Please note:these pages can only be accessed by FSA staff on FSA devices.

3.5.2 Health and safety

All employees will remain aware of their legal obligations and take seriously the responsibility for their own health and safety and that of other persons who may be affected by their acts or omissions. Information, including policies and other resources can be found on the FSA Intranet Health, safety and wellbeing pages.Please note:these pages can only be accessed by FSA staff on FSA devices.

3.5.3 Personal standards

Every person working in a food handling area is to maintain a high degree of personal cleanliness and is to wear suitable, clean and, where necessary, protective clothing.

Reference: Regulation(EC) 852/2004 Annex II Chapter VIII.

3.5.4 Personal hygiene

FSA staff are to:

• wear white, clean protective clothing when handling exposed meat
• wear hairnets (and beard snoods if appropriate) to cover the hair of the head and where necessary the neck
• wear clean waterproof footwear
• wear designated waterproof footwear and lairage coats when working in dirty areas or with livestock
• not wear watches, jewellery (except plain wedding rings), aftershaves and perfumes in production areas

3.5.5 Operational hygiene

When working in an approved establishment, FSA staff must:

• keep personal equipment clean and change protective clothing as necessary
• use the proper hygiene facilities at all times and in such a way that there is no risk of contamination of meat
• wash contaminated aprons in the apron wash facilities
• use a dedicated hygiene facility
• wash hands, or gloves, whenever they become soiled, and always after handling detained or rejected product
• use a rubber glove over a chain mail glove to reduce the risk of cross contamination
• use blue, food safe, waterproof dressings to protect cuts

Note: some FBOs may require that dressings are also metal detectable.

3.5.6 Health status

FSA staff handling food or entering any food handling area in any capacity where there is any likelihood of direct or indirect contamination must not be:

• suffering from a disease likely to be transmitted through food
• a carrier of a disease likely to be transmitted through food
• afflicted, for example, with infected wounds, skin infections, sores or diarrhoea

3.6 Authorisation documents

3.6.1 OA / MHI title

The (EU) 2017/625 official control package uses the title of Official Auxiliaries (OAs) for Meat Hygiene Inspection (MHI) staff.

MHIs can continue to use the title of MHI except when participating in enforcement action, when the title Official Auxiliary must be used. Authorisation certificates will also use the title Official Auxiliary.

3.6.2 Authorisation documents

FSA staff are issued with authorisation documents depending on their designations, together with photo ID cards for some staff.

There is a legal requirement that AOs must produce a " duly authenticated document showing authorisation"when requested to utilise their powers of entry etc.
Authorisation documents are now issued electronically as a pdf document. AOs have options of how they produce such a document if requested and this may be:

• by downloading the pdf document onto their phone and saving it, to be accessed if or when requested,
• by downloading the pdf document and printing it off as a hard copy, to be produced if or when requested

AOs must have access to their authorisations document in hard copy or electronic formwhilst engaged in official duties, and be prepared to produce them on request. AOs must also ensure they possess all relevant authorisations for the type of establishment where they work and activities which they are performing.

When ceasing to work on behalf of the FSA authorisation documents and letters of confirmation must be returned to their line manager.

Any lost or found authorisation documents must be reported to CSU.

3.6.3 Devolved administrations and other government departments

The FSA does not directly authorise officers for functions that are the policy area of Defra or the Welsh Government (except animal welfare). The FSA receives a delegated authority letter that authorises its staff as inspectors / "persons" to act on their behalf. The general authorisation document provided reflects the officer's authority to act on behalf of both the FSA and those other government departments.

3.6.4 Powers of entry

Authorisation documents provide evidence of the legislation under which they may act. This includes the officer’s power to enter approved establishments at all reasonable hours to identify contraventions of the legislation under which they are authorised and for the performance of all statutory duties.

3.6.5 Action without authorisation

All officers acting on behalf of the FSA must never take enforcement action where they have not been appropriately authorised, as such action would not be valid.

If officers are in any doubt as to whether they are appropriately authorised they should seek technical advice as detailed in the topic ‘Lines of Communication’ previously in this section.

3.7 Modern Slavery and Human Trafficking (MSHT)

Issues of MSHT as defined in the Modern Slavery Act 2015 may be encountered during the operation of food businesses. The indications of such offending taking place may be subtle, but present non the less.

Incidents of suspected MSHT may impact on the FBO, by way of criminal investigation; the consumer, by way of untrained / unqualified staff being involved in the production process and importantly the Potential Victim of Trafficking (PVoT).

Concerns and suspicions of MSHT incidents that do not cause food hazards should be reported to NFCU Food Crime inbox immediately, or alternatively:

• your local Police Force,
• Modern Slavery Helpline (tel. 08000 121 700),
• the Gangmasters and Labour Abuse Authority (tel. 0800 432 0804)

MSHT incidents which have a direct cause of food hazards should be reported immediately to the Incidents Team.

In identifying signs of MSHT, consideration should be given to the following factors:

• FBO staff who live on site. This accommodation may be located within the FBO’s premises or externally in temporary accommodation such as caravans, out houses and vehicles, or even just mattresses located in a room
• FBO staff who appear to have been subject to physical violence or show fear when in the presence of management, allowing the management to answer questions directed at staff
• FBO staff who are not in possession of their identity documents as they are held by a third party or are not receiving any wage for their work
• FBO staff who are not allowed to leave the workplace and have little to no contact with the outside world including friends or family
• FBO staff who do not appear to have access to health care, clean clothing or food and water
• FBO staff who appear to be juveniles under the age of 18, working full time and living with persons who are not members of their family
• FBO staff who are dropped off and collected for work always in the same way, especially at unusual times
• FBO staff who are in a situation of dependence, maybe unfamiliar with the local language or show signs of control, which may include psychological control, (for example, through religion, witchcraft, juju)
• FBO staff who have no contract of employment and are unable to negotiate their working conditions, working excessively long hours, with little to no days off, do not have the correct protective clothing, training or professional knowledge to conduct their job
• FBO staff who appear to be distrustful of authorities and act as if instructed by a third party

4.Annexes

Please note: these pages can only be accessed by FSA staff onFSA devices.

Annex 1a: Sample Farm to Fork poster (England)

Annex 1b: Sample Farm to Fork poster (Wales)

Annex 2: Checklist

Annex 3: Glossary of abbreviations