Feed and Primary Production Food Service Plan 2023/2024
1 Introduction
This plan sets out how North Lincolnshire Council, through its Trading Standards Service, will develop its food*/feed service to ensure that all feed standards are complied with.
*Any reference to Food in this plan relates specifically to Food produced at a Primary Production Facility (e.g. Farm/ Grower).
The plan aims to ensure that there is a level playing field for all food*/feed business operators. It details how the Trading Standards Service will meet its responsibilities under the Agriculture Act 1970 (plus subordinate legislation) and Retained European legislation. This involves a combination of measures from taking samples to enforcing food*/ feed standards law and investigating complaints.
The structure of the plan follows the requirements contained within the Framework Agreement on Local Authority Food/Feed Law Enforcement and the Codes of Practice published by the Food Standards Agency (FSA).
2 Aims and objectives
For 2023/24 the Trading Standards Service will adopt as its key service aims:
- Operating a comprehensive compliance regime by means of a mix of inspection, testing and other interventions as appropriate, to ensure the legality of food*/feed produced or marketed within or imported into North Lincolnshire
- Offering chargeable assured advice to local businesses to enable them to market products that comply with feed compositional and feed labelling requirements
- Carrying out food*/ feed standards ‘Home Authority’ enquiries referred by other agencies
- Investigating complaints/ infringements of legislation and taking appropriate action
- The plan will endeavour to implement the related guidance issued by the Feed Delivery Office.
2.1 Links to Corporate Objectives & Plans
The council’s vision for North Lincolnshire is for it to be the Best Place to Live, Work, Visit and Invest. This vision is underpinned by four key outcomes that ensure people are:
SAFE – WELL – PROSPEROUS – CONNECTED
- The inspecting of food*/feed premises to ensure compliance. This will increase consumer protection by safeguarding them from substandard and unsafe food*/feed entering the food chain, ensuring they stay safe and well
- Support food*/feed business by providing chargeable assured advice reducing the cost of non- compliance, which in turn helps them
succeed and prosper - Regulation of food*/ feed businesses will contribute towards a ‘level regulatory playing field’, allo Profile of North Lincolnshire.
3. Profile of North Lincolnshire
North Lincolnshire is largely a rural area with a population of approximately 173,000 residents. Scunthorpe is the largest town in North Lincolnshire and the administrative centre for the area. The three other major population centres are Barton upon Humber, Epworth and Brigg. North Lincolnshire is served by main road links, the M180 and A18.
There are 3 major ports, 7 smaller wharves, 3 major feed manufacturers, a number of pet food manufacturers, feed storage facilities, feed hauliers and many food*/feed producing farms in the area.
All the ports within North Lincolnshire are designated De-minimus ports at present and therefore require quarterly inspections (as agreed by FSA/ NTS) to ensure no changes have occurred relating to feed traffic passing through them. Documentary, identity and physical checks would be carried out if deemed necessary.
Since the end of the Brexit transitional period all goods arriving at Humber Sea Terminal, North Killingholme are now classed as direct Third Country goods. The current monitoring and surveillance is to distinguish how many direct EU products are arriving compared to the number of transhipped products.
There are currently 4 feed manufacturers which are inspected routinely for feed related matters plus a number of Pet Food Manufacturers. In total there is currently 1 approved feed business within North Lincolnshire and 558 registered feed businesses.
The Primary Production of food within North Lincolnshire at present consists of approximately 462 Primary Production businesses, mainly farms growing cereals, livestock farms and root crops and a small number of businesses (horticulturists) growing products for direct entry into the food chain without further processing (e.g. Strawberries, salad crops and herbs). Many of these companies produce a range of products ultimately used by major supermarkets, brewers, bakers and other national food operators.
There is also a considerable amount of Food waste/Co- products (by-products of the food industry) that is also diverted into the animal feed chain. These materials are regarded as animal feed for the purposes of enforcing the legislation.
3.1 Organisational Structure
The Trading Standards Service is part of the Economy & Environment Service within North Lincolnshire Council.
Primary Production of food, and feed enforcement within North Lincolnshire Council’s Trading Standards Service is led by a Trading Standards Enforcement Officer (Feed and Animal Health), who reports to the Trading Standards Team Leader, assisted by a part time Animal Health Officer (with basic feed experience).
In addition, qualified Trading Standards Officers within the Trading Standards team are able to assist with food* work should the need arise.
Under normal circumstances the Feed & Animal Health Lead Officer and part time Animal Health Officers, handle all demand coming into the service regarding Primary Production food and feed law, supported by a basic administrative team. The Head of Service for Trading Standards and Licensing oversees the Trading Standards team.
North Lincolnshire Trading Standards has appointed a Public/Agricultural Analyst at Eurofins for the analysis and testing of food*/feeding stuffs. If deemed necessary, there is provision for the service to utilise other scientific services and appoint other Public Analysts.
3.2 Scope of Primary Production Food and Feed Service
As well as providing comprehensive paid for advice in response to business enquiries, the food*/feed officers carry out programmed inspections of food/feed premises and re-visits where necessary to check compliance with legal requirements.
Where breaches of legal requirements are identified, the necessary informal or formal action is taken in accordance with the council’s Enforcement Policy. For food*Feed safety related issues, ‘improvement notices’ may be issued.
Failure to comply with the improvement notice can lead to criminal sanctions.
Officers will also investigate any complaints received about food/feed standards. Complaints coming into the service are initially dealt with via the Citizens Advice Consumer Helpline and will be referred or notified as appropriate.
Where appropriate, sampling, both formal and informal is carried out on Food*/Feed produced in North Lincolnshire, according to the sampling plan drawn up & agreed with the FSA & NTS. Sampling of both food & feed will take place using an
intelligence, risk-based approach or by responding to complaints.
Where necessary, the service will participate in coordinated sampling surveys/programs organised by the Yorkshire and Humber Trading Standards Group (YAHTSG) or the Food Standards Agency (FSA), as agreed with the appointed Public Analyst.
The service also acts as ‘Home Authority’ for a number of food*/feed businesses. In addition to providing these businesses with advice, the service will deal with enquiries from other Trading Standards Authorities relating to these businesses.
3.3 Service Delivery Contact Points
The Service delivery contacts are as follows:
Postal:
North Lincolnshire Council Trading Standards Service
PO Box 42
Church Square House
Scunthorpe
North Lincolnshire
DN15 6NL
Telephone: 01724 297664
Fax: 01724 297895
Email: trading.standards@northlincs.gov.uk Website: www.northlincs.gov.uk/tradingstandards
24hr emergency contact is available via the Council’s Emergency Control Centre (01724 276444).
3.4 Demands on the Primary Production
Food/Feed Service
Current Primary Production food premises in North Lincolnshire.
= increase from previous year
= decrease from previous year
= same as last year| Code (s) | Premises profile | Number of Primary Production Food premises |
|---|---|---|
| 2 | Farm (assured) | 308 |
| 1 | Farm -non-assured) | 137 |
| 0 | Other horticulture | 16 |
| Total | 461 |
3.5 Access to Expertise
The Service has continuous dialogue and a good working relationship with the Public/Agricultural Analysts (currently Eurofins) on all matters concerned with food*/feed sampling and analysis. Officers are encouraged to contact the Public Analysts where appropriate, to discuss sampling matters.
| Code (s) | Premises profile | Number of Primary Production Food premises |
|---|---|---|
| A&B | Manufactures R04 & R06 | 7 |
| E&F | Stores 09 | 9 |
| G | Distributor R05 | 21 |
| I | Importer | 0 |
| J | Surplus food supplier R07 | 20 |
| LMNO | Transporter R08 | 27 |
| PQ | Co-producer R12 | 11 |
| S | Livestock farm R13 | 212 |
| T | Arable farm R14 | 276 |
**Some premises may have multiple registrations – all registrations shown
3.6 Enforcement Policy & Service Standards
There is an umbrella policy for all enforcement work carried out by all Services within North Lincolnshire. Operating within this general enforcement framework are documented policies for the food*/ feed service i.e., Inspection, Complaint Handling, Sampling, Enforcement of Legislation and dealing with matters of non-compliance. Notice will be given to all A, B and unrated premises prior to an inspection unless it would defeat the object to do so. The service also follows the Code of Conduct of the Crown Prosecution Service, which recognises that prosecution is only one of a suite of remedies that can be used and that others may be considered more appropriate in cases of non-compliance.
In compliance with the Regulators Code a set of Service Standards are maintained and published, which outline what consumers and businesses can expect from the Council.
3.7 Complaints about North Lincolnshire Council or its Officers
North Lincolnshire Council has an established complaints procedure. In the first instance, complaints will be directed to the Service area, to deal with informally. Should this not resolve the issue the complaint will be dealt with via the council’s complaints and comments policy.
4 Service Delivery
Feed standards inspections are programmed in accordance with the Feed Code of Practice (April 2018), in accordance with the Official Feed & Food Control Regulations 2009 and the agreed NTS/FSA programme.
4.1 Premises Risk Profile
Feed premises are now assessed under the FSA risk assessment system and should receive a programmed inspection at the following intervals:
Feed Safety
- A risk premises every 12 months
- B risk premises every 24 months
- C risk premises every 5 years.
| Premises risk rating | Total number of premises | Number of tagged premises due for inspection |
|---|---|---|
| A Risk premises | 0 | 0 |
| B Risk premises | 3 | 0* |
| C Risk premises | 5 | 0* |
| D Risk premises | 15 | 0* |
| E Risk premises | 484 | 0* |
| 2% | 24 | 0* |
| Unrated premises | 12 | 0* |
| Total | 543 | 0* |
*Due to not having a Lead Feed Officer in post, no specific inspections were planned other than those required by funded FSA work
| Premises accreditation | Total number of premises |
|---|---|
| Not farm assured | 137 |
| Farm assured | 308 |
| Unrated | 16 |
| Total | 461 |
4.2 Targeted Inspection Activity
Programmed inspections will be carried out in accordance with a risk-based approach, further outlined below. 
In addition, premises may be targeted as a result of complaints received, local and national food* audits, food alerts and advice from the FSA. Our inspections follow the procedure as laid down in the Feed Law Code of Practice guidance, updated April 2018.
Interventions (contact with our food* and feed businesses) planned for 2023/24 include a range of enforcement actions, including inspections. Re-visits will be carried out to ensure compliance for any required actions from these visits. Self- certification may be accepted for minor issues.
The focus of future food*/feed law enforcement will be determined by intelligence gathered as a result of interventions and advice that officers have given to food*/feed businesses. Analysis of complaints and enquiries will also be taken into account. The interpretation of the above intelligence enables the development of pre-programmed inspections, interventions and targeted food*/feed projects. This ensures that resources can be directed to where they are needed most; taking into account the Council’s ongoing desire to make efficiency savings wherever possible.
Under the FSA risk assessment scheme all A and B risk Premises (Feed) should be inspected throughout the year. The introduction of Earned Recognition (for farm assured premises), however, means that not all premises will require inspection each year. Earned recognition means a nationally recognised Audit Body (that has received approval from the FSA) audits these premises. The B risk premises will be selected based on local areas of concern or priority areas.
Lower risk businesses will not be visited without a valid reason for doing so (complaints, requests for advice or FSA grant funded work). Unrated businesses will be visited for risk assessment purposes.
Businesses may also be dealt with by means of ‘alternative enforcement action’ (e.g. self- assessment questionnaires) as opposed to conventional ‘inspections’. However, those businesses will be able to request advice and assistance from the authorised officers involved in food*/ feed enforcement, as required.
In order to reduce the regulatory burden on business, where possible, inspections will either be combined with DEFRA, RPA or Animal Medicines Inspectorate inspections. In the case of non-complex feed premises (i.e. livestock farms not mixing animal feeds); these inspections may be partially carried out by an Animal Health Officer (suitably trained). Any issues arising will be reported back to the Lead Feed Officer.
Food hygiene inspections will be made at Primary Producers (arable farms, fish farms, market gardens etc.). The numbers of interventions made will be agreed with FSA/NTS as part of the 2022/23 Grant Funded work.
The number of premises closing down and the number of new businesses opening up will contribute to the actual number of inspections undertaken. In addition to pre-programmed inspections, additional inspections are undertaken of new premises opening during the year and temporary or mobile traders at various events and markets held in the administrative area; such events include Farmers Markets and County Shows.
Premises risk ratings may change throughout the year as a result of inspection activity.
4.3 Food*/Feed Complaints
Food*/feed complaints are received into the service by letter, email or calls via the Citizens Advice Consumer Helpline.
Where the complaint refers to contamination, adulteration, composition and labelling, the complaint is fully investigated. Such an investigation will be conducted with a view to tackling the root cause of the problem, to avoid it happening again. Advice may be sought from the YAHTSG regional feed group/NTS/FSA if necessary, for a consensus of opinion, to ensure consistency. Where appropriate, enforcement action is taken, regard will be had, to the council’s Enforcement Policy, Statutory Codes of Practice and National Guidance.
For complaints relating to imported food, officers will refer these to the Hull and Goole Port Health Authority (HGPH). Should HGPH have any concerns regarding feed imports, a reciprocal arrangement is in place.
Where the complaint is regarding foreign bodies or food safety, officers will refer the complaint to the Food and Safety team (Environmental Health Service).
If necessary, the expertise of the new Food Standards Agency Food/Feed Fraud Advisory Unit will be used to assist in food*/ feed fraud investigations which are being carried out on a national basis.
Where food*/feed related complaints are received, enforcement will be structured to tackle the root cause and will be designed to ensure any interventions have the desired impact.
4.4 Primary / Home Authority Scheme
This Service operates in accordance with the Home Authority Principle, acting as a point of contact for businesses within North Lincolnshire that trade both within and outside of the boundaries of the administrative area. We do not currently act as a ‘Primary Authority’ for any North Lincolnshire Food* or Feed Business.
4.5 Advice to Business
The Service provides a chargeable business advice service, which supports businesses to help them comply with the law and to encourage the use of best practice.
This will be achieved through a range of activities including:
- Running courses or seminars, if there is a demand for this type of activity.
- Written advice provided to a particular sector, for example if there is a significant change in legislation affecting that business sector.
- Advice given during the course of inspections.
- Provision of advice via Leaflets and the Services Web Site/Facebook Page.
- Responding to specific enquiries received from food and feed businesses.
- Support of national and local campaigns, such as nationally coordinated surveys.
4.6 Sampling
Sampling will be carried out on an intelligence led basis, taking into account information gathered from complaints, enquiries, nationally emerging issues and National Priorities. Any sampling carried out will take account of the following principles:
a) To maximise the effectiveness of our sampling activities, we will join with coordinated sampling programmes, where appropriate. We will focus on areas where we have evidence to suggest that there are problems affecting businesses and consumers in North Lincolnshire.
b) To this end, we will not take samples where it cannot be justified that there is a need to do so. This principle will also apply to any complaints received.
c) We will consider how our sampling can be more effective and the results maximised. We will work with our Public Analysts to discuss development of new sampling methods where there is a specific need.
d) Sampling will focus on locally produced and packed products, as well as imported products. This will reflect both regional and national priorities. In particular, any priorities deemed as such by the Food Standards Agency.
-
- Animal feeds including Imported feeds (in particular those direct from 3rd countries outside the EU). This may change following BREXIT.
- Local food (waste/Co-products) and feed manufacturers
- Local on farm mixers of animal feeds (where Additives and pre-mixtures are used)
- Emerging issues identified through the use of intelligence
These priorities are designed with the aim of protecting both the consumer and the majority of legitimate businesses who aim to comply with law.
As well as carrying out our own sampling projects, the service also participates in YAHTSG co- ordinated sampling programmes. In addition, we will contribute to the FSA imported feed sampling programme, where possible.
Samples are taken in accordance with legal requirements, (EC) 152/2009 as amended by (EC) 691/2013, the Feed Law Code of Practice and any guidelines issued by the FSA, NTSB or ACTSO. Food samples are taken in accordance with Food Safety Act 1990, code of practice 7; Sampling for Analysis & Examination (Revised November 1990) & the Food Safety (Sampling & Qualifications) (England) Regulations 2013.
In 2023/24, the number of feed samples (taken inland) we will submit to our Agricultural Analyst will be limited to intelligence led or complaint driven samples.. Imported feed samples (3rd Country Imports) may also be taken from irregular shipments where deemed necessary (funding may be available from the FSA).
Food*/feed samples will, in normal circumstances, be submitted to the Public or Agricultural Analyst for analysis and comment.
4.7 Food*/Feed Alerts
Food*/feed warnings are issued by the Food Standards Agency to all food*feed authorities in the country when a national feed safety issue has arisen with a specific food*/feed product. The majority of food*/feed alert warnings are issued for information only, a few requiring immediate action. However, some alert warnings may require more immediate action. Large scale incidents may impact on the demands of the service. Food*/feed hazard warnings are responded to by appropriate officers of the service. All warnings and the subsequent action taken are recorded on the ‘Civica’ database.
The Service has access to the FSA Risk Likelihood Dashboard that details current risks in food and animal feed imports into the UK and monitors the European Rapid Alert System for Food and Feed (RASFF) to ensure any issues likely to impact on local businesses or national feed safety are dealt with. Feed Notifications are also received via email from the FSA.
4.8 Control & Investigation of Outbreaks & Food Related Infectious Disease
Feed Poisoning Notifications will be investigated and appropriate action taken. Food poisoning notifications do not usually fall within the remit of the Trading.
If, however, the Service became aware of any incident of food poisoning or infectious disease, the facts would be reported to the Food and Safety Team (Environmental Health).
4.9 Food*/Feed Liaison
The Service ensures that the enforcement action taken within North Lincolnshire is consistent with that of its neighbouring authorities and liaises with a wide range of organisations to varying degrees in carrying out its food*/feed law enforcement function.
Partners include: 10 other Trading Standards Departments in the Yorkshire and Humberside region which together make up the Yorkshire and Humber Regional enforcement group (YAHTSG).
4.10 Primary Production Food/Feed Promotion
Food Hygiene Primary Production/feed safety-standards promotional work may form part of an annual programme of activities aimed at raising the awareness of food*/feed and other issues within the scope of the Service. This may include newsletters to update businesses on new legislation, and other relevant initiatives and campaigns, attendance at local events, reference material and other information on the Council’s website/Facebook page.
Press releases may be used to highlight food*/feed issues and other information with an immediate public interest.
5 Resources
Provided below are details of the resources that are allocated to the delivery of the Food*/Feed Plan. The establishment resource for the team 0.8 full time officers.
5.1 Staffing Allocations
A list of officers currently authorised to undertake food*/feed law enforcement across the department is maintained, together with a record of training and continuing professional development hours awarded. Currently this stands at one authorised food*/feed officer and one part time Animal Health officer (partially authorised for feed).
- Head of Service – Trading Standards & Licensing 0.05
- Trading Standards Team Leader 0.05
- Feed & Animal Health Officer 0.5
- Animal Health Officer 0.2
5.2 Financial Allocation
The estimated cost of this service which is to be met out of the 2023/24 Trading Standards budget allocation is broken down as follows.
- Staff costs £33,718
- Travel £1,800
- Equipment/Analytical £1,500
- Training £500
- Income -£16,000
- Total Cost £21,518
5.3 Staff Development Plan
It is a requirement for food*/feed enforcement officers to receive structured on-going training of at least 10 hours for feed, per year as continuing professional development and to ensure effective and consistent feed law enforcement.
The Service uses a range of external training organisations including the Trading Standards Institute, training co-ordinated by YAHTSG, the FSA, and internally provided courses. A full range of training will be used including:
- Formal courses leading to qualifications
- Specialist external training courses and events
- Regular updates through team meetings, seminars and training days
- In-house training
- Peer review
All staff participate in the council’s annual appraisal scheme. Staff training needs are identified as part of the process and contribute to the training programme. It is recognised that officers undertaking the inspection of specialist or complex high risk activities require additional experience and skills.
6 Quality Assessment
We aim to continually improve the level of service provided. Procedures are reviewed, where necessary, to incorporate identified improvements.
6.1 Peer Auditing
A list of officers currently authorised to undertake food*/ feed law enforcement across the department is maintained, together with a record of training and continuing professional development hours awarded.
Appendix A – Review of Primary Production Food and Feed Service Plan 2022/23
1. Review against the Service Plan
The review compared the year’s performance against targets set out in the plan 2022/23. The service achieved the following:
Interventions achieved may differ from target inspections planned as premises risk may have changed at time of inspection.
Whilst a comprehensive inspection plan was not put in place due to the service not being able to fill the vacant Lead Feed Officer post. However, with the assistance of North East Lincolnshire Councils’ Feed Officer our committed feed inspections were almost fully completed.
There have been no Food Standards Agency audits of the authority during the year.
In terms of sampling, there were no feed samples taken.
The service dealt with 4 enquiries regarding importations of organic feed materials from China that were contaminated and liaised with the importer to re-allocate them as non-organic.
During the year, 5 service requests for assistance were received in relation to feed. This is a large decrease on the 42 service requests received the previous year. This is attributed to not having a Lead Feed Officer who had a role as a National Representative for Feed matters and dealt with feed queries as part of this role.
| Premises Risk Rating | Total Number of Premises | Interventions Achieved |
|---|---|---|
| A Risk Premises | 0 | 0 |
| B Risk Premises | 4 | 1 |
| C Risk Premises | 6 | 2 |
| D Risk Premises | 15 | 3 |
| E Risk Premises | 95 | 15 |
| 2 % | 27 | 0 |
| Unrated Premises | 19 | 0 |
| Total | 166 | 21 |
| Premises Risk Rating | Total Number of Premises | Interventions Achieved |
|---|---|---|
| Not farm assured | 137 | 1 |
| Farm assured Premises | 310 | 1 |
| Unrated | 16 | 2 |
| Total | 463 |
2. Identification of any variation from the Service Plan
Once again, the FSA offered additional funded work to be carried out at inland Feed Business Operators, but due to the absence of the Feed Officer, no additional work was completed.
3. Areas of Improvement
With the push from Government to decrease the number of routine inspections, there is a push towards more intelligence led enforcement. Intelligence in this area has improved locally over the last year. However, national intelligence around feed is still an area for improvement. As intelligence around feed improves, the next step is to use this intelligence to better target resources and provide the best possible outcomes.
There is now a small, dedicated sampling budget, which has not previously been available. Whilst sampling will still be based around complaints and intelligence. This new sampling budget will allow for a limited routine sampling plan to be developed.
The loss of a dedicated Lead Feed Officer, has meant that the Team Leader from Trading Standards has taken on this role, albeit in a limited capacity. With inspection commitments being reduced. Whilst vacant posts remain the assistance of North East Lincolnshire will be require to meet our FSA requirements.
