Updated FSA Official Control Compliance Framework for Registered Dairy Establishments in England and Wales: summary of responses

Red Tractor support the benefit or earned recognition for its members, and that inspections will remain less frequent on those members that demonstrate compliance with the assurance scheme standards. However, it would be beneficial for both parties if we could develop a two way reporting process for information and intelligence to help both organisations get oversight of any poor performing producers.

I do not agree with the Agency’s proposed changes in the consultation information document as indicated on page 1 where it states under points 1) & 2). “1) Proposed changes to how final compliance ratings are applied following primary production Official Control (OC) inspections completed by the Food Standards Agency (FSA) at registered dairy establishments in England and Wales”. “2) Subsequent use of a new risk rating framework with additional inspections for higher risk establishments”.

In relation to 1) & 2) as indicated above, whilst I would agree with additional inspections for higher risk establishments such as Raw Cows Drinking milk or high risk milk wholesalers, I do not believe the new compliance ratings framework will ensure better overall consumer protection in relation to public health.

Red Tractor Farm Assurance is, I believe, more about promoting food sales rather than about consumer or animal welfare protections and has been shown previously in news and other reports to have had flaws in terms of assurance on these issues. Also, many farmers etc believe that without using this assurance scheme they would be disadvantaged in selling their produce and therefore join the scheme not because they believe in it in terms of it being a good assurance scheme, but because it allows them access to certain markets. As I have previously said in consultation responses, I believe farmers generally are not given a fair price for their produce from supermarkets etc and this includes wholesale dairy milk farming.

As Red Tractor Assurance is, I believe, a company owned and is funded by British Farming and the Food industry, it is hard to argue they don’t have a vested or conflict of interests and therefore raises the question if they should be providing any assurance schemes.

When they report periodically to the FSA, this information does not appear in the public domain and therefore there is no real way of determining the effectiveness of their assurance.

I believe that the current approach categories to Official Control inspections with Good, Generally Satisfactory, Improvement Necessary or Urgent Improvement Necessary should be kept rather than going to the suggested three categories of low, medium or high risk, which, I believe, may mask the true level of non-compliance.

Also, I note Good, Generally Satisfactory, Improvement Necessary or Urgent Improvement Necessary are currently used in the Meat Hygiene service and some of their inspectors also carry out work in Dairy Operations. I further believe official controls by the FSA should be no longer than a maximum of 2 years frequency of inspection for a wholesale-only milk premises (as so much can change when the maximum is 10 years in any business with regards to consumer safety etc) and no greater than 6 months for Raw Cows Drinking Milk (RCDM) for direct supply to the final consumer. In the long-term, Red Tractor Assurance should be phased out and all inspections should be carried out internally by the FSA’s Dairy Hygiene Inspectors so that we have truly independent inspections. Yes, it would cost more, but in the long term it would be far more beneficial to the general public and the food industry in terms of public health and long term consumer confidence in the food industry.

I would like to congratulate you for the attempt on cost of illness benefit as it is the first attempt I have seen in a Government consultation. The cost benefits in terms of illness are, I would respectively suggest, generally far greater for 2017 than your example, as the evidence below indicates.

The Zoonoses Report UK 2017 in the link below, stated on page 18 under “Feature article 3: Shiga-toxin producing Escherichia coli O157 outbreak associated with consumption of raw dairy milk.

Authors: Lisa Byrne, Gastrointestinal Infections, National Infections Service, Public Health England

An outbreak of Shiga-toxin producing Escherichia coli (STEC) O157 PT 21/28 stx2 occurred in Autumn 2017 in the South of England. Investigations identified 7 confirmed cases, 3 of whom developed Haemolytic Uraemic Syndrome (HUS). All but one case had either consumed raw milk from, or been exposed directly to the environment, of a farm which was a raw milk producer and was also open to the public. During investigations, control measures put in place to prevent further transmission included cessation of sale and recall of raw milk supplied by the farm, and actions to limit public exposure to associated environmental sources such as preventing access to animals on the farm by closing the petting activities. Despite this, a further 3 cases were notified following the recall, 2 of whom had drunk raw milk from the farm after the recall had been put in place. During 2017, a number of other incidents related to RDM also occurred. In Wales, a child infected with STEC who had consumed RDM died, a rare consequence of STEC infection. Meanwhile, there have been 3 separate outbreaks of Campylobacter spp affecting 27 individuals in total, and an incident of Salmonella Dublin, in which 1 human was infected. Therefore, added to the FSA example in the consultation document for the year 2017 only, is 9 cases of Shiga-toxin producing Escherichia coli (STEC) of which three cases of Haemolytic Uraemic Syndrome (HUS) were caused by STEC in England only. HUS 3 x £300,000 based on 2017 costs = £900,000. See * below. STEC 6 x £8400 = 50,400. based on 2018 costs. See ** below. £140,000 but by ** below is £124,000 + £900.000 + 50,400 = £1,074,400 based on 2017/2018 average costs per case.