Scottish Food Enforcement Committee

Craig Brown chaired the meeting. SFMTA was represented by Douglas Scott. Only other industry representative was from NFU Scotland.

Programme of work to set up the New Food Body for Scotland was presented by Sandy McDougall (FSA) and Fiona Comrie (Scot Gov). The driver for this was the decision of Uk Government to remove responsibility for nutrition and health from FSA in England and Wales. Function of NFB will be comprehensive and Scottish Government has stated that it must have the capability to develop diet and nutrition programmes.

Primary legislation is required to set up Food Standards Scotland. This is determining the timescale of the progress. Programme team of 8 people has been appointed. There are various arms to the transition. Corporate and Support Services is a major project but it includes creating a new meat charging regime for Scotland. (126 responses to the consultation on NFB were received.)

Fiona expanded on the Working with Others project. This covered for example SEPA, diet and health but the emphasis at this meeting was on the relationship with local authorities. Structures and opportunities for improvements considered. All functions with be reviewed and there is no guarantee that all current responsibilities will remain within local authorities' jurisdiction. Transfer of work is not a done deal, “everything is up for grabs”. Approval of establishments is one of the areas under considerable discussion.

The working group will be as transparent as they can be and are willing to attend meetings where their work would be of interest. Its recommendations go back through the Project Manager, Project Board and Programme Board to Ministers.

Scudamore 2 report made recommendations to the working of this committee. These will be considered at the December meeting of SFELC.

Resources Working Group Update was given by Colin Wallace
The pre consultation ideas included:-
Revision of the Food Law Code of Practice, Enforcement policy, COSLA no longer operates the previous Lacors system. Revitalisation of Liaison Groups was needed with publication amongst them of sampling results. Review of sampling guidance to include no inspects blue risk and joint food standards and trading standards. Aspects of testing and methodology including accreditation will be revised.

Approved Establishments Working Group
Proposed guidance was introduced by Billy Hamilton
One of the main concerns in the FSA Audit was the criticism of Approved Premises inspections. Agreed it can be done better. Considered a specialist team. Inspections are currently
Deals with the General Principles for VerifyingFood Safety Management Systems within Establishments approved under EC Regulation 853/2004.
Pennington 1 and 2 that revealed inspection failings are the key drivers.
Principle of inspection assesses legal compliance but really needs to be assessment of food safety of the business. Looks at the Food Safety Management Systems and deploys gap analysis to review systems:- Official Control v Business v Implementation. Aim is to now introduce quality standards for official controls and a process template.

ButcherSafe system – background was given by Billy Hamilton before more detail was presented. CookSafe then Retail Safe and translations and electronic resources. Butchers Safe will allow a food safety management system that will butchers to implement HACCP in a user friendly way. Subsequent to views expressed by SFMTA members fed back through SFMTA to the FSA group the contentious text surrounding shelf life will be removed. Printing should be possible within this calendar year after SFMTA and the working group on behalf of SFELC sign off the contents.

Better Regulation Update was given by Lorna Murray
A Scottish Code of Practice on Better Regulation of Food and Feed law similar to the Westminster version is being developed.
At UK level – on 25 July replacement of Code on protocols on delivery of service.
FSA UK has agreed to reduce unnecessary reg burdens on SMEs. Actions to come before the end of March. Earned recognition approach is being supported, operator appeals process in place. Now there is a policy of one reg in two out. Landscape is different south of the border.

Food standards & Food sampling paper – Paul Bradley
Recommendations
SFELC should continue to press FSA to introduce effective food standards enforcement tools
FSA should continue to gather, collate and disseminate intelligence on emerging issues and trends in the food trade.
SFELC should rename the existing Research Working Group (RWG) as the Sampling and Surveillance Working Group (SSWG)
FSSC and RWG (SSWG) should consider the outcomes of the FSA's research on meat species “carry over” and progress any areas of work identified.
FSSC and RWG (SSWG) should organise a survey on meat species identification, taking the opportunity to develop sampling and testing regimes for meat species identification as well as guidance on interpretation and sample follow up.

Expert Advisory Group to review the lessons to be learned from the horsemeat incident
Professor Jim Scudamore led an Expert Advisory Group to carry out a review of the lessons to be learned from the horsemeat incident. Based on these lessons a series of recommendations for the improvement of food and feed safety and standards in Scotland were made. While most of these recommendations were aimed at FSA, Scottish Government and the New Food Body the Group's work will have a direct impact on the enforcement community.
A number of the recommendations in this paper addressed issues raised by the Group.
SFELC, FLGs and LAs should engage actively with FSA, Scottish Government and the New Food Body to achieve the objectives of the Expert Advisory Group's report
Food sampling in Scotland is now half of what it was in 2002. (Down from in excess of 25,000.)

SFMTA requested that accidental carry over as opposed to deliberate passing off should be considered in interpretation of results of sampling. Peter Midgley FSA suggested that SMEs had the potential to experience the greatest problems in this area. A suggestion that adopting measures deployed by feed manufacturers could be used to reduce species carry over in meat products, was not deemed helpful given the scale of operation in SMEs.

Sampling of animal feedstuff in Holland had revealed high levels of lead in deer bones, originating in Lanarkshire that had not been caused by gunshot. Sampling of venison for metal content does not appear to be undertaken but should be extended to get better value out of testing of venison burgers.

Date of next meeting: 6 December 2013 in Edinburgh, venue TBC.

Meeting closed at 1:00pm