The Northern Ireland Grain Trade Association is pleased to have the opportunity to comment on the Feed Law Enforcement Guidance Document Review. 

We are happy with the general principle of earned recognition as it gives tangible benefit to businesses which achieve consistently high standards of management controls and feed safety as demonstrated by their compliance with the relevant industry assurance schemes.

 With the possibility of charges for enforcement activity in the future our members will be very conscious that every inspection visit or sample taken could have a cost. Lighter touch regulation will be welcome particularly where existing controls and available information is recognised and the focus is on risks which are not already well covered.   

 Accredited assurance schemes developed by the industry and audited by independent 3rd party bodies are now in place throughout the food chain and have played a vital role in raising standards of safety and risk management. The schemes developed by the Agricultural Industries Confederation (AIC) are in widespread use - in the feed sector these include UFAS, FEMAS, and TASCC which have become the accepted standards for the industry.

 In Northern Ireland the recent launch of the Food Fortress program has been well received by the trade and this now comprises 45 feed businesses covering 99.9% of compound feeds produced in the province. This brings an extra level of surveillance with a strategic sampling program covering the principle risks across the range of feeds every month of the year. We feel that this program should earn an additional level of recognition for its members as it adds a significant bank of test results which are shared with regulators on a regular basis. This information can be used to inform the risk assessments carried out by DARD/FSA and allow them to focus their attention on risks or businesses not covered by the Food Fortress.

The proposed testing frequency for different activities seems reasonable for businesses within an accredited scheme which is subject to annual audit. We would have concerns that there is very little difference in frequency of inspections between these operations and non scheme businesses - ie there is not a sufficient level of credit allowed for scheme membership. Non scheme businesses, not subject to the discipline of an annual audit would present a much higher risk and this is not reflected in the proposed testing regime. 

We would also wish to see a higher level of control around the area of co products and surplus foods entering the food chain. The management of these materials from food producer through to storage on farm should be given a high priority particularly if there is no appropriate quality scheme in place.

The principle of unannounced inspections may also cause some difficulty in that it is important that the appropriate personnel are on hand to meet the inspector and deal with queries and questions which may arise during the visit.

I trust these comments are useful and we look forward to working with FSA on the detail of the proposals.

Robin Irvine