Feed Manual of Official Controls

The Feed Manual is a guide for Authorised Officer conducting Official Controls of feed law and Agents in Scotland.

2. General Arrangements

2.1 Introduction

FSS is the competent authority for the delivery of official controls and enforcement of feed at all stages in the feed chain. 

2.2 Roles and Responsibilities - overview

The following table lays out roles and responsibilities of the FSS central coordination function (Feed Delivery Branch (FDB)) and the delivery by third parties (referred hereafter as “Agent”)

TaskFSS (FDB)Delivery Agent (third parties)
  1. Administration and management
  • Development and delivery of administrative systems for the feed delivery service including development of guidance, monitoring and audit systems.
  • Service planning including annual report against service plan.
  • Develop management reports including monitoring of the Feed Management Information System (FMIS), the Scottish Food Sampling Database (SFSD) and outcomes of meetings with FSS/3rd party feed officers.
  • Audit – cooperation during audit.
  • Provide management information to FSS as required.
  • Participate in review of performance against the Delegated Service Level Agreement (DSLA) for each Agent – quarterly.
  • Handle service complaints from FSS.
  • Submit invoices.
2. Official Control PlanningDevelopment of inspection and sampling plan (this is to be provided 8 weeks prior to the start of the year, provide plan). Plan to have a fixed list with a small amount of flexibility (e.g. primary production))Agree Official Control plan 4 weeks prior to the start of year 
3. Horizon Planning
  • Process intelligence, horizon scanning to inform risk analysis and prioritisation for intervention planning.
  • Feed into the horizon scanning process from FMIS and any other means (identify trends for horizon scanning every quarter)
  • Authorised Officers to gather official control information through FMIS
  • Report suspicion of feed crime to FDB
4. Official control delivery
  • Interrogation and reports (FMIS).
  • Interrogation and reports (SFSD).  
  • Save FeBO inspection reports and analysis certificates to the FMIS and eRDM.
  • Decision making – enforcement action.
  • Engagement with Agriculture Analysts to coordinate analysis activity. Develop an annual sampling plan and provide quarterly updates
  • Deliver a programme of risk-based animal feed interventions, as agreed with FSS, and having full regard to and compliance with FSS guidance and advice, working with businesses to achieve compliance, using informal enforcement action.
  • Refer matters for possible formal enforcement action to FDB
5. Enforcement 
  • Carry out formal enforcement action, with input from the officer responsible for the official control, as necessary.
  • Referral to Court and preparation of reports to the Procurator Fiscal, with input from the officer responsible for the official control
  • Handle appeals for enforcement action.
  • Arrangements for seizure, detention and destruction.
  • Save FeBO enforcement notices and post-enforcement records to eRDM
  • Carry out formal enforcement action only in exceptional circumstances and on agreement with FSS (see chapter 7)
  • Input as necessary e.g. witness statement and assist draft construction of formal enforcement notices
6. Registration 
  • Administer Feed business registration.
  • Update premises lists.
  • Advise 3rd party and FeBO’s
Pass on information regarding unregistered businesses to FDB. Refer businesses to the FSS Online Registration Platform
7. ApprovalsManage the approval of establishments - 
determination and paperwork
  • Pass on information regarding unapproved businesses to FDB. Refer businesses to FSS Online Registration Platform
  • In exceptional circumstances and with written agreement from FSS, carry out pre-approval work and approval inspection 
8. Incidents and Feed Complaints
  • All incidents/ feed complaints are referred to FSS (FDB and Scottish Food Crime and Incident Unit (SFCIU)).
  • Investigation of incidents and feed complaints and discussion with FeBO’s as necessary.
  • Referral to FSS officers for investigations and feed complaints and discussion with FeBO’s at establishment if necessary.
  • Referral procedure to other parts of FSS or OGD.
  • Referral of intelligence to FSS
  • In exceptional circumstances and with written agreement from FSS, carry out investigations and feed complaints with FeBO’s 
9. Imports
  • Strategic management of imports.
  • Point of entry registered with FSS 
  • Inspection on FSS’ s behalf (either as per the official control plan or ad hoc)
  • Inland imports checks (as part of routine inspection)
10. EquipmentFor FSS delivery, FSS equipment ordering, maintenance and calibrationEnsure equipment is available, maintained and calibrated
11. Advice
  • Develop and provide officers with up-to-date technical advice, policy developments and any other guidance which will enable officers to carry their duties effectively.
  • Arrange regular meetings (every quarter), ad hoc online meetings, as necessary, including liaison with other bodies involved in feed e.g. Scottish Government Rural Payments & Inspections Directorate (SGRPID), VMD, industry.
  • Feed manual – update every 3 months, or as necessary.
  • Any other action required by FSS to deliver an improvement in compliance with relevant feed/food law.
  • Where appropriate, promote the feed delivery service and the importance of safe animal feed.
  • Read and understand new advice/guidance
  • Attend FSS/other agency meetings in accordance with Schedule of meetings
12. TrainingProvide training to Authorised Officers based on feedback from regular meetings with FSS officers/ Agents.
  • Enable attendance at FSS courses, maintain minimum 10 hours CPD for each feed officer per year to support evidence of competence.
  • Authorisation of officers.
  • Provide sufficient and appropriately qualified, competent, experienced staff and resources for implementing the feed delivery service within the agreed area of delivery (in accordance with the DSLA and the feed manual).

 

2.3 Schedule of Meetings and Reviews

WhenSubjectHow
Quarter 1 July
  • Review performance against DSLA for each Agent e.g. are inspections being carried out according to plan and other conditions of the DSLA.
  • Include any outcomes of review of inspection and sampling plan.
Remotely (1 to 1)
Quarter 1 July
  • Liaison meetings with other bodies involved in feed e.g. SGRPID, VMD, industry
  • To include technical meetings
  • Where practical to do so, arrange training at the same location in the preceding or subsequent days
Meeting at agreed location or remotely
Quarter 2 October
  • Review performance against DSLA for each Agent e.g. are inspections being carried out according to plan and other conditions of the DSLA.
  • Include any outcomes of review of inspection and sampling plan
  • Agent to discuss officer development needs with FSS
Remotely (1 to 1)

Quarter 3

January

  • Review performance against DSLA for each Agent e.g. are inspections being carried out according to plan and other conditions of the DSLA.
  • Include any outcomes of review of inspection and sampling plan
Remotely (1 to 1)

Quarter 3

January

  • Liaison meetings with other bodies involved in feed e.g. SGRPID, VMD, industry
  • To include technical meetings
  • Discuss full review of DSLA to ensure still fit for purpose
  • Where practical to do so, arrange training at the same location in the preceding or subsequent days
Meeting at agreed location or remotely 
Quarter 4 April
  • Review performance against DSLA for each Agent e.g. are inspections being carried out according to plan and other conditions of the DSLA.
  • Include any outcomes of review of inspection and sampling plan
  • Agent to discuss officer development needs with FSS
Remotely (1 to 1)

2.4 General Requirements

Authorised feed officers must have regard to this manual when discharging their duties and any appropriate guidance issued by, or supported by, the FSS FDB. If the Authorised Officers consider that public and animal health, food or feed safety is likely to be compromised by complying with this manual, they should discuss the matter with the FDB at the earliest opportunity and before any decision is taken. Authorised Officers should fulfil enforcement duties in accordance with the FSS Feed Enforcement Policy. 

The FDB will periodically issue communication to Authorised Officers, and to the management of those Agents, on new and/or revised policies and procedures, information on feed safety matters and other issues connected with the effective delivery of official controls and enforcement of feed law.

Agents musthave arrangements to ensure that the information is shared with the Authorised Officers and determine what action is appropriate and or necessary on receipt of such communications.

The DSLA lays out the area of scope for feed law functions.

The Agent must ensure that there are enough competent/qualified officers to undertake official controls at the full range of feed businesses within the area of scope agreed in the DSLA. This may involve employing temporary staff or contractors, who are also required to meet the qualification and competency requirements for the specific functions the officer is required to undertake.  

The FDB and the Agent will review the performance against the DSLA to ensure that the specified requirements are met.

2.5 Interventions with Feed Businesses

The core function of Authorised Officers is the delivery of official control and other interventions at Feed Business Establishments (FeBEs). Official controls are activities performed by the competent authorities or by the delegated bodies to verify compliance with regulations and that goods meet the requirements laid down. Official controls include inspections and sampling for analysis. Interventions include official controls and other activities such as education, advice and coaching, information and intelligence gathering. 

In Scotland, the official controls carried out by agents shall be inspections and sampling, unless otherwise agreed by FSS.

2.6 Liaison between Competent Authorities

The FDB shall facilitate liaison between and engage in discussion with the Authorised Officers (of Agents and FSS), Agricultural Analyst(s), VMD and APHA. The purpose of the liaison is to help maintain effective and efficient delivery of official controls, registration and approval, co-operation and consistency of enforcement. It shall provide an opportunity to share intelligence and avoid duplication of enforcement by different competent authorities and discuss legal interpretation and consistency. Meetings shall take place on a quarterly basis.

2.7 Equipment

Apart from FSS supplied mobile devices, the Agent shall be responsible for providing equipment listed in Annex 2 to enable them to carry out interventions at Feed Business Establishments (FeBEs), in accordance with this manual.

Authorised Officers shall ensure that equipment is in good working order and, where necessary, calibrated. 

It is the responsibility of the Agent to determine what personal protective equipment is required having regard to their own health and safety polices, risk assessments and procedures. The Agent shall also determine the requirements for cleansing and disinfection for the prevention of spread of animal diseases in accordance with their own policies and procedures. 

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