A less than robust feed control system means consumer safety and animal health is at risk; moreover, such lack of oversight could harm trade and cause irrevocable damage to the reputation of the feed sector in Scotland, warned the FSS.
“Local authorities are receiving funding to enforce animal feed controls across Scotland but are not delivering on this function,” said Ian McWatt, director of operations at the FSS.
To some extent, it is down to budget allocation decisions as to why the amount of raw material sampling and rate of site inspections has been declining, he said. The recent and impending financial pressures on Scottish councils are seen as only set to diminish the service further, added McWatt.
“In some cases, the cost of a single dioxin sample could be 20% of one local authority’s budget, so as resources become stretched checks become more of a challenge for some local authorities,” he told us.
The EU Food and Veterinary Office (FVO) and the Food Standards Agency (FSA) carried out reviews in the past few years of UK feed controls and identified weaknesses in terms of frequency of inspections and training of officers
While England, Wales and Northern Ireland implemented changes following those evaluations, Scotland made no progress at that time due to the fact the FSS was only being set up.
New oversight model
But McWatt said a new system of official feed controls is set to be rolled out in Scotland.
The FSS, working in collaboration with the Society of Chief Officers of Trading Standards in Scotland (SCOTSS), looked at a number of options for a new model.
Both parties originally proposed a regionalized framework, whereby a smaller number of better resourced lead authorities would be led by the FSS as a single national body through a formal relationship, but the model was shelved; the FSS deemed it unworkable due to resourcing challenges.
Then, in January this year, the FSS board backed a new ‘centralised’ model of feed production monitoring, under which the FSS would be the new designated enforcement body, instead of local authorities.
The earliest date for implementation of this centralised model is April 2017.
“Domestic legislation needs to be amended to give effect to this change, and we are hopeful that will be finalized in the next two months. To mitigate risk to the feed and food chain in the interim, it has been determined that the local authorities will retain the competence for delivery of official controls until next April,” explained McWatt.
And as a system of earned recognition was introduced in Scotland in April, similar to the one already in place in England and Wales, McWatt said this will reduce the burden of inspection on the local authorities until transfer of oversight to the FSS.
“Earned recognition involves reduced inspection frequency for compliant members of Agricultural Industries Confederation (AIC) assurance schemes.
“As well as reducing the burden of regulation on these compliant businesses, this approach will allow local authorities to redirect resources to higher-risk feed businesses,” he said.
Funding challenges
However, in order for the new, centralized model of feed controls to be effective and sustainable, funding awarded to local authorities for feed law enforcement, must now be attributed to FSS, stressed McWatt.
“We are calculating what exactly the local authorities receive in terms of funding for feed law official control and negotiating hard with the Scottish government to secure transfer of this funding to the FSS, when it takes over as the competent authority for feed controls,” he said.
But, said McWatt, such funds redistribution is not a given, as it is being met with opposition from the Convention of Scottish Local Authorities (COSLA).
No one from COSLA was available to comment on the pending legislation prior to publication.
In total, 32 local authorities in Scotland are each responsible for carrying out feed law official control and enforcement within their areas.
They receive funding through the ‘block grant’ from the Scottish government; however, this is not ring-fenced, said McWatt.
He said individual authorities make local decisions on distribution of funding according to circumstances, to address statutory obligations and the jointly agreed set of national and local priorities.
In addition to the block grant, local authorities have, since 2002, received a share of funding from the FSA for feed law enforcement, which, in total, comes to £325,000 (US$430,850), said McWatt.
Resistance to centralization of controls
In a position paper published in February this year, SCOTSS said it is completely opposed to any centralisation of the feed control role to FSS.
The organization said such a model “does not reflect the arrangements that have been put in place in other parts of the UK, and adds risk to the already fragile services that our members deliver through Scottish councils.
“SCOTSS still believes that regional delivery of feed official controls by lead authorities is the most appropriate and viable option. This can be achieved within the existing resources, provided to Scottish councils by Food Standards Scotland, so long as steps are taken to ensure that funding reaches and resources delivery.
“We support COSLA and other Scottish councils, and regret the decision that the FSS board have taken.”