Chief Executive’s Report to the Board
FSA 24/06/03
General Election
1. On 22 May, the Prime Minister announced that he was calling a General Election for the 4 July 2024. During the pre-election period, civil servants and Board members in government departments and public bodies such as the FSA are expected to observe certain restrictions, for example in relation to public engagements or publications. The General Election guidance for civil servants and public bodies states that “Departmental and NDPB activity should not be seen to compete with the election campaign for public attention.” It also says that “Officials should decline invitations to events where they may be asked to respond on questions about future government policy or on matters of public controversy.” At the FSA, we examined all of our planned publications and announcements to ensure that they comply with the guidance during this period, reminded staff of their obligations as civil servants particularly in relation to impartiality, and any social media activity, and reviewed public engagements for individuals across the organisation.
2. The Chair, in consultation with me, decided that the Board should continue to meet in June but that we should postpone the broadcast of your discussion, and postpone items where the Executive was asking the Board for significant strategic steers or decisions, for example on regulated products reform. This was to uphold the FSA’s principle of transparent decision-making. Instead, we are taking routine items where you are scrutinising FSA work, which do not need decisions, like annual reports from particular areas of the business. We will publish the papers and the recording of the 19 June Board meeting as soon as possible after the election and will answer questions from the public on the material, as usual.
3. With Food Standards Scotland, we postponed the June publication and launch events for the annual report on food standards, ‘Our Food 2023’, and plan to reschedule this for the Autumn.
4. We are working to understand any manifesto implications for the FSA and the wider food system. We are working with other government departments to prepare for the arrival of a new administration on 5 July.
Democratic Scrutiny Committee
5. On 6 June, the FSA appeared in front of the Northern Ireland Assembly’s Windsor Framework Democratic Scrutiny Committee (DSC).
6. Our objective was to share information and analysis regarding new composition and labelling rules in the EU Breakfast Directives and to assist the DSC in determining the necessity of an inquiry into the EU legislation.
Key points addressed by the Members of the Legislative Assembly included:
- Stakeholder engagement: our proactive engagement with various stakeholders was highlighted and positively received.
- Opportunities for artisanal businesses: we discussed potential benefits for artisanal businesses under the new directives.
- Clarity and choice for consumers: we provided insights into how the legislation would support consumers to make more informed choices, and potentially increase the range of products available on the Northern Ireland market.
- Movement of goods within the UK: we assured the Committee of the seamless movement of goods within the UK internal market.
7. Our detailed evidence was well received, supporting the DSC's decision against launching an inquiry.
Incidents
8. On Monday 10, June I updated the Business Committee on some recent incidents in my report to them. Over the last week there have been further developments, particularly on an STEC incident where we have been working in support of the UK Health and Security Agency. I will update the Board verbally on the latest position at our meeting on 19 June.
Borders Target Operating Model (BTOM)
9. The second phase of the BTOM went live at the end of April. This included the commencement of physical checks at the border on imports from the EU and EFTA (European Free Trade Association). Imports from the rest of the world are also now being subject to the new risk-based approach to controls. This uses a model that assesses the risks posed both by the commodity as well as the country of origin, allowing our border controls to be applied proportionately to the risk posed.
10. Border checks on EU goods are being introduced using a phased approach that sees those goods posing the highest risk to public and animal health, such as poultry and pork products, the first to be subject to controls, gradually adding further tranches of commodities. This has been designed to allow time for businesses and competent authorities to adapt, and to avoid a big bang implementation for new IT systems.
11. The introduction of controls has largely proceeded as planned although there was a Defra systems issue in the early part of the rollout that mostly impacted imports of plants and plant products. This was not linked to the introduction of controls and is fully resolved. Queries from businesses since go-live have been below the volume forecast. The FSA has supported Defra in answering queries, mostly in providing clarification of the risk categorisation of certain products. The FSA is carefully monitoring delivery as it rolls out to ensure that the implementation meets our food safety objectives. Delivery remains at an early stage and so we do not yet have sufficient information to come to any conclusions.
12. This is a major milestone in the control of imports from the EU and it means that we are now in a better position to be able to reassure consumers that our imported food meets the UK’s high standards.
Official Veterinarians
13. The Board will recall that in June 2023, the Royal College of Veterinary Surgeons (RCVS) approved an 18-month extension so that the FSA could use their Temporary Registration scheme for Official Veterinarians (TRNOV). We submitted a written update on TRNOV progress to RCVS in June 2024, demonstrating that despite further challenges, we are currently reducing our reliance on the scheme in line with forecasts. Progress has been impacted by the Home Office-led changes to immigration rules that commenced in April. We have successfully worked with Home Office to reduce the immediate effects of the policy but there will be some longer-term effects if we want to ensure a sustainable pipeline of OVs.
14. In response to FSA’s detailed reporting on the challenges faced by the veterinary profession, particularly concerning OVs, as outlined in in Our Food 2022 (our annual report on food standards), the Environment, Food and Rural Affairs Committee held a non-inquiry session on veterinary shortages in March 2024. I was pleased to give evidence to the inquiry highlighting the impacts of shortages. The Committee Chair wrote a letter of recommendations in May.
Regulated Products Register
15. In May we launched the Register of Regulated Product Applications. It lists all received product applications that have passed initial validation checks, providing transparency to the public and applicants to our regulated products service.
16. On 30 April 2024 we published the first safety assessments for CBD (Cannabidiol) as a novel food. This is a major milestone in our efforts to bring the CBD industry into compliance with food law and the assessments can be found here and here. To our knowledge, these are the first safety assessments on CBD for food use produced by a regulator worldwide.
Achieving Business Compliance
17. I’m pleased to advise the Board that we have completed the 12-month trial of enterprise level regulation with five large retailers in England. The independent evaluation report is still being finalised, but early findings indicate that overall, the trial was successful in enabling the FSA to draw conclusions for a future enterprise level regulation, with all success measures met or partially met. We intend to bring the findings and our proposals to the September Board meeting for a decision on next steps.
Local authority engagement
18. The Regulatory Compliance Directorate has completed a series of engagement events with local authorities (LA) including nine in-person sessions across the UK (one each in Wales and Northern Ireland) and a recent online event for those unable to attend in person.
· The events saw over 250 LA officers attending in person and more than 100 joining the virtual session. Presentations covered the FSA's approach to performance management of LAs and future plans for improving competency assessments for LA officers. Feedback from attendees has been overwhelmingly positive, with 92% expressing satisfaction or high satisfaction with the event content. LAs appreciated the FSA's efforts to engage with them and valued the opportunity to provide input.
Grey Market Goods
19. We have written to 49 UK businesses identified as importers of these goods reminding them of their legal responsibilities to ensure this and compliance of the food they supply. These grey market goods primarily intended for sale in other countries like the U.S.A, include products such as soft drinks, confectionery and cereals which often fail to meet UK food law requirements due to undeclared ingredients, excessive additives, or prohibited substances. We have also communicated with LAs, sharing the letter for their information. This initiative was triggered by intelligence that we had been collecting through our recently-created intelligence considerations hub, which coordinates intelligence on food risks across parts of the FSA such as incidents, the National Food Crime Unit and our Regulatory Compliance Directorate.
Antimicrobial Resistance (AMR)
20. AMR remains high on the agenda for the FSA and across government. Chief Scientific Adviser, Professor Robin May attended a global event in London on 16 May hosted by the UK’s Special Envoy on AMR, Dame Sally Davis. Funding of £85 million was announced to combat antimicrobial resistance, demonstrating a significant commitment from the UK to addressing this global threat.
21. This event followed the publication of the UK’s new 2024-2029 National Action Plan (NAP) on confronting AMR, published by the Department of Health and Social Care (DHSC) but written with partners from across government, including the FSA. The FSA’s funded AMR surveillance and research is contributing to this AMR NAP by improving our understanding of AMR through capability to measure, predict and understand how resistant microorganisms spread from animals and agriculture to humans via the food chain (linked to Theme 1, Outcome 7), and enabling decisions to be based on robust surveillance, scientific research and datasets (linked to Theme 3, Outcome 7). An example is a survey gathering data on microbiological contamination including AMR bacteria found in raw dog and cat food on retail sale in the UK. The FSA commissioned this survey to fill a major gap in our knowledge about the risks associated with pet food.
22. Another contribution to the new NAP comes from the cross-government PATH-SAFE programme, led by the FSA. Now funded until March 2025, a key example has been in the area of environmental surveillance, including testing wastewater and air as novel AMR tracking methods. The data from these projects represent a significant step forward in assessing how these methods, which proved effective during the COVID-19 pandemic, could effectively and efficiently compliment, or replace, traditional surveillance methods and targeting of interventions.
Provision of Allergen Information
23. Following the Board’s direction on the provision of written allergen information for non-prepacked foods in December 2023, the team have been working to develop guidance for food businesses. This covers how to provide written allergen information, so we can start making improvements in this important area quickly. In line with the Board’s decisions, we are doing this in such a way that it could be transitioned to a statutory basis should a new government wish to support mandation. The work includes assessing the initial impact different options will have on stakeholder groups such as flexibility in how written information must be provided that will still ensure consumers get the information they need.
24. We have undertaken additional research with stakeholder groups including consumers, academics, trade associations and allergy charities as well as extensive engagement with LAs and industry (approximately 150 representatives) to ensure that the creation of the guidance done collaboratively. We will formally consult on the best practice guidance in the autumn.
Codex Committee on Food labelling (CCFL) – allergen labelling
25. The Electronic Working Group (EWG) set up by CCFL is consulting on proposed revisions to the allergen labelling principles set out in the General Standard for the Labelling of Pre-packaged Food, prior to meeting in October.
26. We submitted a UK response to the EWG’s first consultation in March. The consultation looked at refining precautionary allergen labelling (PAL) guidelines and establishing allergen thresholds for the use of PAL. Allergen thresholds are defined as the maximum amount of an allergenic food that can be tolerated without producing any adverse reaction. We were able to support most of the proposed revisions. We reserved our position on two key questions relating to standardising allergen thresholds internationally, to inform the application of PAL. The first on the amount of food for a single eating occasion and the second on the use of ED05-based reference doses for allergens, i.e., allergen thresholds.
27. The Consultation asked if countries would support the use of ED05 based reference doses. ED05 is the eliciting dose which is predicted to have an adverse reaction in 5% of the allergenic population as identified by the Codex Expert Committee. The Expert Committee recommended ED05-based values because, according to their evidence, the difference in the public health impact of choosing a more stringent reference dose is expected to be negligible in terms of reducing public health risk. It would introduce considerable burdens and limitations for monitoring. There would be potential unintended consequences on the application of PAL or other risk management strategies. Our response was to reserve the UK’s position as there is currently limited data and evidence to conclusively demonstrate that there wouldn’t be a significant impact on public health. As well as this, there are limitations on tests to detect all 14 regulated allergens.
28. Currently in most countries, including the UK, PAL labelling is voluntary and best practice thresholds can be applied. The EWG will begin a second round of consultation shortly.
29. We will be coming back to the Board later in the year with some formal advice on what position the UK should consider to enable the FSA to advise Minsters on this matter.
30. In the UK, Defra has the overall lead on Codex for government, although the FSA leads in the Codex Committees dealing with food safety. International relations are reserved to Westminster so any final positions or recommendations which may be politically sensitive, or have implications for trade/health, need to be agreed by Ministers.
Animal Welfare
31. The Senedd approved The Mandatory Use of Closed-Circuit Television (CCTV) in Slaughterhouses (Wales) Regulations 2024 on 21 May. These regulations mandate the installation of CCTV cameras in all slaughterhouses in Wales specifically in areas where live animals are unloaded, housed, handled, stunned and slaughtered. Slaughterhouse operators must retain recorded footage for a minimum of 90 days and provide access to authorised personnel such as OVs from the FSA for the purposes of monitoring and verifying animal welfare standards. The regulations will be implemented in two phases:
- From 1 June: slaughterhouses must install and operate CCTV systems, retaining footage and related information for inspection.
- From 1 December: enforcement provisions, including offences and powers to seize footage will come into effect.
32. The FSA will collaborate with food businesses during the six-month transition period to ensure compliance with all requirements. This effort includes developing guidance for slaughterhouse operators in conjunction with colleagues in the Welsh government. Currently there are 20 approved slaughterhouses in Wales. Initial assessments have identified that five facilities lack CCTV systems, while an additional 2 do not have adequate coverage in all required areas.
Staff Successes
33. Dr Collin Willson was awarded the OBE in the King’s New Years Honours list for his outstanding services to animal welfare and veterinary public health in the meat industry. Collin qualified as veterinary surgeon in 1973 and has spent the last two decades in government veterinary public health roles. He was accompanied by his family to the investiture at Windsor castle in April.
34. In May, Dr Esther Heller from the Regulatory Compliance Directorate and Mark James from Field Operations attended a garden party at Buckingham Palace. Esther was selected to attend in recognition of her 38-year career of dedicated public service, 24 of which have been with the FSA since its inception in 2000. Esther’s role involves compiling and evaluating data from our local authority returns. Mark is an Official Auxiliary supporting the delivery of official controls in the meat industry. He was nominated by colleagues recognising his 34-year career as a meat inspector working in local authority, the Meat Hygiene Service and at the FSA since its inception.
Engagements
35. Since my last report to the Board in March, I have continued to hold regular engagement with Food Standards Scotland and other government departments.
36. I met Philip Duffy, CEO of the Environment Agency and the Chair of the Science Council, John O’Brien.
37. Director of Operations, Junior Johnson and I met David Lindars, Technical Operations Director at the British Meat Processors Association.
38. I joined Defra and other government departments at a roundtable on food security.
39. In April, I travelled to Brussels where I met Caroline Read, Deputy Ambassador at the UK Mission to the EU. I also met the Belgian Chief Veterinary Officer, Chantelle Rettigner. I joined an industry roundtable on regulated products reform and precision breeding. I met representatives of the Farmers’ Unions across the UK, and representatives from the British Agricultural Bureau in Brussels. Finally, I met the Director General of Food Drink Europe, Dirk Jacobs.
40. I joined Anjali Juneja, Director of UK and International Affairs and Katie Pettifer, Director of Strategy and Regulatory Compliance at a meeting with representatives from Nesta.
41. I met members of the British Retail Consortium, and I attended the regular Defra F4 meeting with representatives from UK Hospitality, the British Retail Consortium, Food and Drink Federation and the National Farmers’ Union. Separately I met Karen Betts, CEO of the Food and Drink Federation.
42. In late April and early May, I met counterparts at Defra and DHSC to discuss the Highly Pathogenic Avian Influenza outbreak in dairy cattle in the U.S.
43. In May, I joined a cross government senior officials food group meeting. I also accompanied the Chair at the Consumer Stakeholder Forum.
44. I met Dr Joyce Boye, Director General of the Food Directorate at Health Canada.
45. I gave a pre-recorded interview to the BBC on LA resourcing and the Food Hygiene Ratings Scheme and recorded a podcast with New Food.
46. I joined colleagues in Northern Ireland at the Balmoral Agricultural Show in May where I met Katrina Godfrey, Permanent Secretary for Department of Agriculture, Environment and Rural Affairs, NI Chief Veterinary Officer Brian, Dooher, and senior representatives from the Ulster Farmers Union. I also joined Food NI CEO, Michele Shirlow for a tour of the food pavilion.
47. At the end of May, I visited Yeo Valley in Bristol. I also joined Field Operations colleagues at the regional engagement and development day.
Hanes diwygio
Published: 26 Mehefin 2024
Diweddarwyd ddiwethaf: 5 Gorffennaf 2024