Workshop on Feed Safety, Marketing and Use of Feed Sofia, September 2010 ‘Experiences with National Feed Control Programmes’ Tim Franck, Food Standards Agency, United Kingdom

TODAY Something about the UK Food Standards Agency Legislation/Feed sectors/EU framework UK system of feed controls UK enforcement priorities Some issues/objectives/challenges Some conclusions

United Kingdom Food Standards Agency (FSA) Established in April Non-Ministerial Government Department headed by a Chairman and Board. Reports to Parliament through Health Ministers but not directly accountable to Ministers. Main function is to protect public health from risks in connection with consumption of food. Website:

United Kingdom Food Standards Agency (FSA) CORE VALUES Putting the consumer first. Openness and independence. Science and evidence based.

FSA responsibilities in relation to Animal Feed Animal Feed part of Food Standards Agency responsibilities because of importance to food chain. (TSE legislation/medicated feed responsibility of agriculture departments). Central Competent Authority. Negotiates new legislation in Brussels. Implements legislation in UK. Oversight of enforcement authorities.

Legislation which protects the feed chain General Feed Safety Requirements Regulation 178/2002 on the general principles of food/feed law Undesirable Substances/Use of additives Directive 2002/32 on undesirable substances Regulation 1831/2003 on the use of additives in animal nutrition Standards/Labelling/Use Regulation 767/2009 on marketing and use Import Controls Regulation 882/2004 on Official Food and Feed Controls - Articles 14 – 24 Regulation 669/2009 on high-risk feed Feed Hygiene Regulation 183/2005 on feed hygiene

Feed Sectors Affected Includes: Primary producers (both livestock and arable farms) Importers and traders Feed compounders (manufacturers) Transporters Stores Food businesses (surplus food/co-products) Pet food companies

Framework for official controls Regulation 882/2004 on official control of feed and food Includes requirements on: Competent bodies – article 4 Competent staff – article 6 Methods of sampling and analysis – article 11 System of official laboratories – article 12 Contingency plans for dealing with feed emergencies – article 13 Import controls – articles 14 – 24 Charging provisions – article 27 Registration/approval of feed business establishments – article 31 Reference laboratories – articles 32 and 33 Principles of cooperation between member states – articles 34 to 40 Multi annual national control plan – articles 41 to 43

UK SYSTEM OF FEED CONTROLS Central Competent Authorities Medicated Feed and Feed containing coocidiostats/histomonostats – Department of Environment Food and Rural Affairs (DEFRA) TSE requirements – DEFRA All other requirements Food Standards Agency (e.g. marketing and use, undesirable substances, additives, feed hygiene) Delivery of Feed Controls (Enforcement authorities) Medicated/TSE Animal Medicines Inspectorate (central inspectorate) Animal Health (central inspectorate) Marketing and use, undesirable substances, additives, feed hygiene etc Local authorities (208 in total)

Implementation of Official Controls in the UK Implementation of EU requirements into national law to give enforcement powers to competent bodies and penalties Set out our enforcement strategy in the UK Single-integrated national control plan (NCP): NCP chapter 6 – risk based approach to enforcement Feed Law Enforcement Code of Practice for local authorities – includes a risk-rating for feed business establishments at annex 5: Annual Enforcement Priorities for local authorities based on risk – separate sections for imports, primary production and all other feed sectors:

Monitoring/Audit Collection of data on official control activities Provides information for the audit of enforcement authorities Used to report against the National Control Plan on an annual basis Audit of competent bodies Audit Branch of Food Standards Agency audits enforcement authorities against the requirements of 882/2004 and the code of practice on feed law enforcement Currently auditing a selection of authorities responsible for import controls on both feed and food Similar in nature to audits undertaken by the Food and Veterinary Office

National legislation National Regulations provide: Offences and penalties. Powers of entry. Feed business improvement notices. Feed business prohibition notices.

Code of Practice on Feed Law Enforcement To be followed by enforcement authorities Includes provisions on : Qualifications Conflicts of Interest Feed business improvement notices/prohibition procedures/detentions Feed incident procedures Inspections/feed business rating system Records to be kept

Animal Feed Law Enforcement Liaison Group (AFLELG) Set up in 2005 to discuss animal feed law enforcement matters To identify problems, agree co-ordinated approach Comprises representatives of central and local government.

Enforcement Priorities National Enforcement Priorities issued on annual basis Based on: feed incidents notified using the EU Rapid Alert System for Food and Feed (RASFF); sampling data submitted to the Food Standards Agency by local authorities; recent changes to EU legislation; recommendations of the Food and Veterinary Office (FVO) mission to UK in 2009 Acts as guidance under the Single Integrated National Control Plan for UK

Enforcement Priorities – Imports Enforcement Priorities in 2010/11 cover controls at points of entry, including high risk products listed in Annex I of Regulation 882/2004 any other specific controls required by EU measures e.g. guar gum from India Certain mineral feeds and premixtures from outside EU (e.g. dioxins in copper products, heavy metals in dicalcium phosphates)

Enforcement Priorities – Annex II, Regulation of 183/2005 Examination of feed businesses feed safety management systems (including HACCP). Identification and inspection of feed businesses carrying out drying processes. Use by farms of additives/premixtures. Inspection of food businesses supplying food into the feed chain.

Enforcement Priorities – Farms Controls of premises (farms) subject to Annex I and III of Regulation 183/2005 (Feed Hygiene). Systems at farms in place to prevent contamination of feed e.g. by inappropriate storage. Sampling for deoxynivalenol (DON), zearalenone (ZON) and other undesirable substances that might contaminate home grown cereals. So what are the issues …..

There is a lot of legislation and it continues to develop …..

Keeping up with the legislation Marketing and Use: development of a catalogue of feed materials, codes on good labelling practice. Changes to the Undesirable Substances Directive (e.g. maximum permitted levels). Feed Additives Directive: Re -evaluation of feed additives. Feed Hygiene (Controls on Microbiological Criteria). New Medicated Feed Directive.

F Feed Safety Incidents There is a need to respond quickly to feed incidents Many are related to imports Just a few that have occurred recently 2007 –melamine in pet food from US (origin Peoples Republic of China (PRC)) 2008 – Salmonella in wheat protein from UK 2008 –aflatoxins in sunflower seeds from Egypt 2008 – melamine in organic soya expeller from PRC 2008 – dioxins/PCBs in dried recycled food in Ireland PCBs/dioxins in guar gum from India

Other objectives/challenges Wide range of businesses and products (complementary feed, complete feeds, feed materials, additives etc) to enforce. Controls at point of entry. Identification and inspection of all feed businesses according to risk based principles (including farms). Making sure that all feed business operators are aware of their responsibilities.

Implementation of Marketing and Use Regulation in UK Recent major legislation (came into effect on 1 September 2010) Consulted stakeholders (feed industry, enforcement authorities) during negotiations (no surprises policy). Impact Assessment carried out Formal consultation on national implementing regulations Drawing up guidance in response to questions from stakeholders Attendance at industry meetings and seminars to explain new requirements Put material on website Training of enforcement authorities

Conclusions Much legislation to enforce. Feed sector is large –inspection of farms a challenge. Enforcement authorities require necessary powers and resources. Enforcement officers needs a range of expertise (e.g.on HACCP). Important to have risk-based systems in place for inspections.