Terina Hurley
Finance Charging
Food Standards Agency
Room 109Foss House, Peasholme Green
York, YO1 7PR
Email:
29th May 2015
Dear Ms Hurley,
Official Controls Charges in Approved Meat Premises: Consultation on a Proposal for a New Discount System
Thank you for inviting the Farmers’ Union of Wales to contribute to the above consultation. Following an internal consultation with its twelve County Branches, the Union submits the following comments for your consideration.
General Comments
The Union agrees that the FSA should work to develop a meat charges discount system that promotes efficiency, supports improved compliance and appropriately supports small and medium enterprises (SMEs).
However, members also believed that the new system should be transparent, simple and easy to administer in order to reduce the costs borne by businesses. The industry must not be forced into bearing the costs of a charging system that is overly bureaucratic, officious and rigid. The FUW would take this opportunity to reiterate that the current supply chain can function to adversely affect primary producers and that such producers can often become responsible for enduring any additional cost increases which have occurred further up the supply chain. Any moves to reduce the costs of Official Controls, such as those involved in administration, would therefore be welcomed.
Given the above, the FSA must become even more efficient in the undertaking of inspections for Official Controls. Unfortunately, no mention of any changes to ground level FSA working practices are highlighted in this document and the Union would welcome further discussions on how such operations could be improved for the financial and practical benefit of businesses and primary producers. The Union believes that, without a thorough examination of working practises, it is likely that full costs savings have yet to be realised and that the industry is therefore paying for a system in which the inspection operator has little incentive to use inspection resources more efficiently.
The FUW believes that efficient working would be of benefit to all relevant business operators, independent of size and handling capabilities. Better working practises and greater flexibility within the current system would aid in improving business viability and sustainability whilst ensuring that superfluous costs are not passed to this sector. An examination of factors such as production notice periods, working rotas, low throughput excess charges, flexibility in contract hours and the better use of Suitably Qualified Persons (SQPs) would determine if such working practises are fit-for-purpose and would identify where possible change could occur without adversely affecting food safety.
Several members commented on the costs and types of personnel utilised in Official Controls inspections and noted that, in some cases, a small abattoir killing on 1 day might have to employ an OVS an FSA Meat Inspector and a Technician. Members stated that, where possible, staff should be multi –functional and utilised for all parts of production in order to reduce costs. Moreover, the use of SQPs would be a more cost-effective way of ensuring standards are adhered to at lower cost.
Excessive costs risk adversely penalising smaller and medium sized enterprises. Such plants play a key role in terms of the industry as a whole, and supply a range of crucial markets and services, including
a.Local domestic and niche markets, through butchers, delicatessens and other outlets
b.Ethnic markets, which have become an essential part of the supply chain, and are largely serviced by medium sized abattoirs
c.Businesses such as hotels and restaurants whose success depends upon being able to source produce from local small and medium plants
d.The market for meat from older cattle, which, since the over thirty month ban came to an end, has played a central role in terms of the economics of the market as a whole
e.The provision of local services to primary and organic producers which would not otherwise be available
f.The delivery of local and regional brands, including to local authorities
However, such premises can be geographically widespread and maintaining the viability and sustainability of these businesses is therefore essential.
The FUW is concerned that the new system will place an additional burden on abattoirs due to the costs associated with meeting new administrative requirements, such as new software. Given this potentially large financial burden, the Union would reiterate that the new charging system must strive to reduce the amount of bureaucracy associated with its activities.
I trust that due consideration will be given to the preceding information.
Yours sincerely
Dr Hazel Wright
FUW Senior Policy Officer
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