Feed Manual of Official Controls

This Chapter:

• outlines the qualification and competency requirements for officers who are eligible to be authorised to carry out official controls to verify compliance with feed law
• does not apply to those who have only indirect managerial responsibility for the delivery of feed official controls and feed law enforcement or to those employed in a support role such as administrative and legal staff.

FSS delegation of feed law functions to Agents, as laid out in the DSLA, enables the Agent to authorise its own officers.

In addition, FSS requires that officers are authorised across Scotland in the event of their participation in a major incident where required by FSS.

Authorisation must only be given where there is evidence of the required qualifications and/or competency to undertake the intended specific official control duties. Agents are required to provide the FDB with a copy of this evidence. 

Where in accordance with the DSLA, FSS approves an Agent to carry out additional activity to inspections and sampling e.g. enforcement activity, the Authorised Officer must meet the relevant requirements for qualifications and competencies contained within this chapter.

Authorisations shall be tailored to the role of an individual officer. An officer’s authorisation may be extended as the officer gains the necessary competency and qualifications where these are required, and on submission of evidence to the relevant authorities lead feed officer. Paragraph 3.7 provides examples of how evidence can be demonstrated. 

Written authorisations for feed official controls as issued by the Agent to their Officers will be reviewed on a 6 monthly basis and should be presented to the FSS as part of the review of Officer CPD and training records in accordance with Section 3.8 of the Feed Manual.

Where official controls of food and feed hygiene primary production are to be carried out at the same time, they may be carried out by an officer competent in accordance with this Chapter.

Officers are required to have both the required qualifications and competency for the authorisation granted and activities they undertake as set out in this Chapter.

There are no specific qualification requirements for level 1 officers (farm inspections), qualifications may provide evidence of competency in a particular area.

A range of qualifications are recognised for Level 2 (inspections at premises other than farms): 

Currently available qualifications

(a) CTSI Professional Competency Framework (CPCF)

Trading Standards Practitioner Diploma (TSPD) which must include Unit 4 Feed within Stage 2.

(b) CTSI Professional Competency in Feed

Previously available qualifications

(a) Trading Standards Qualification Framework (TSQF)

(i) Diploma (DCATS) or Higher Diploma (HDCATS) in Consumer Affairs and Trading Standards – must include the Feed Module

(ii) Certificate of Competence - Feed

(iii) Module Certificate in Consumer Affairs and Trading Standards - Feed

(b) Older Qualifications

(i) Diploma in Trading Standards (DTS) or its antecedents 

(ii) Diploma in Consumer Affairs (DCA) which includes the Food and Agriculture Paper, or its antecedents 

(iii) Diploma in Consumer Affairs (DCA) Certificate of Competence in relation to Food and Agriculture, or its antecedents

3.6.1 Qualification Equivalence

Existing or prospective officers may have other qualifications, additional training and experience that together indicate their competence to undertake specific official control or enforcement activities but who do not hold any of the qualifications listed above. Equivalent qualifications should be considered. FSS has developed qualification equivalence criteria, and this is provided in Annex 3.2. Please note that training may still be required to meet the competencies provided in Competency Framework (Annex 3.1). Agents must make enquiries with the FDB if there are any doubts about a prospective officer’s qualifications.

In addition, Authorised Officers must be able to demonstrate, having undertaken appropriate qualification/training and supervised experience for competence in:

• The inspection of hazard analysis and critical control points (HACCP) based safety management systems; and
• Basic components of quality control systems and auditing techniques to ensure effectiveness and operations of the simple systems.

Competency in this manual is a combination of technical and professional skills, knowledge and experience, and may include qualifications, that enable an officer to be appropriately authorised to deliver official controls.

The Competency Framework (Annex 3.1) provides competency requirements for different activities. 

Competency 1  - Undertaking official controls, excluding sampling for analysis of feed, and enforcement action at Feed Business Establishments which solely undertake one of the on-farm activities R10, R11, R13 and R14 or, a combination of these activities.

Competency 2 - Undertaking official controls, excluding sampling for analysis of feed, at FeBEs which undertake one of the activities A1-A11, R1-R9, or R12

Competency 3  - Undertaking official controls, excluding sampling for analysis of feed, at points of entry

Competency 4 - Undertaking sampling for analysis of feed

Competency 5 - Using enforcement powers and carrying out reactive investigations.

Note: Anyone undertaking enforcement action must meet Competency 5. In addition, 

• for enforcement of establishments that are farms, they must meet competency 1
• for enforcement of establishments that are not farms or points of entry, they must meet competency 2 (as well as qualification requirements)
• for enforcement of establishments that are points of entry, they must meet competency 3
• for enforcement related to sampling, at any type of feed establishment, they must meet competency 4 

Column 4 of the Competency Framework (Annex 3.1) provides examples of what competence might look like. There is no requirement to demonstrate competence with all these examples.

Authorising authorities must satisfy themselves that an officer can provide demonstrable evidence that the officer meets the competency (knowledge and skills) requirements relevant to the role the officer is required to undertake and for the scope of their authorisation.

The following are ways in which an officer would be able to demonstrate they meet the competency requirements provided in the Competency Framework:

• qualifications – both academic & professional
• post qualification courses that lead to an additional relevant qualification
• successful completion of training courses, including short courses and e-learning, e.g. on matters related to official controls, HACCP
• employment history detailing functions undertaken, responsibility exercised, and experience gained
• official controls carried out under supervision by an appropriately Authorised Officer
• assessed practical training that requires application of academic and professional knowledge
• completion of a specific piece of work, e.g. drafting of notices, production of witness statements, gathering evidence, building elements of a prosecution file, carrying out sampling in the prescribed manner etc.

Officers are required to maintain a record of evidence containing details of qualifications, training, and details of specific feed law experience which helps to demonstrate that they have met the relevant competencies laid down in this manual. 

If an officer does not have the necessary competencies, there should be consideration about how the development needs can be addressed if the scope of the authorisation is intended to be extended. Until such gaps have been filled, the officer’s authorisation to deliver official controls should be appropriately restricted.

CPD can involve any relevant learning activity, whether formal and structured or informal and self-directed, todevelop the personal qualities and practical experience to undertake their feed law role.

Training needs and development requirements must be assessed formally for each officer on, at least, a six-monthly basis. This information shall be used to inform an officer’s personal development plan and their CPD priorities. This information shall be shared with the FDB every six months to allow ongoing development of the FSS feed training plan.

FSS is responsible for providing appropriate training each year to Authorised Officers and, where identified in the officer training plan or otherwise required to meet regulatory standards, officers must make themselves available to attend this training. If the officer has already met the relevant competencies that the training is intended to provide, there is no need for the officer to attend the training. In addition, Agents shall ensure that any other essential training not specifically feed related, necessary for officers to adequately fulfil their duties, e.g. Information Technology, data protection, Health and Safety, is provided. 

To maintain competence, officers are also required to keep up to date with relevant information and technical developments to enable them to carry out their duties competently and to enable consistent interpretation and application of feed law.  Updated information shall be provided to Authorised Officers and Agents when available and as required by FSS, and may include:

• relevant legislation
• FSS guidance
• guidance documents from other countries (e.g. advice for export requirements)
• UK Guides to Good Practice where appropriate
• guidance and relevant correspondence issued by, jointly with, or on behalf the FSS or FSA
• relevant industry codes of practice; and
• appropriate technical literature.

Agents must ensure that Authorised Officers are provided with the up-to-date information necessary for them to carry out their duties effectively.

Officers must ensure that they receive a minimum of 10 hours CPD per year, relevant to feed and to their level of authorisation and the type and frequency with which they undertake official controls.   

Chapter I, Annex II of  Regulation (EU) 2017/625 outlines the subject matters for the training of staff performing official controls. Examples may include but are not limited to: 

• different control techniques, such as auditing, sampling and inspection
• control procedures
• feed and food law, where relevant to feed controls
• different stages of production, processing and distribution and the possible risks associated with feed law
• assessment of non-compliance
• hazards in animal, feed and food production, where relevant to feed controls
• the evaluation of the application of HACCP procedures
• management systems such as quality assurance programmes that feed businesses operate and their assessment insofar as these are relevant for feed law requirements
• official certification systems
• contingency arrangements for emergencies, including communication between the UK and third countries
• legal proceedings and the implication of official controls
• examination of written, documentary material and other records, including those related to inter-laboratory comparative testing, accreditation and risk assessment, which may be relevant to the assessment of compliance with feed or food law; this may include financial and commercial aspect
• control procedures and requirements for entry into Scotland of goods arriving from third countries and
• any other area necessary to ensure that official controls are carried out in accordance with  Regulation (EU) 2017/625.

FSS shall deliver a programme of annual training for Authorised Officers. In addition, there are several ways in which officers can undertake and attain CPD. Please see below a non- exhaustive list of ways to achieve CPD around animal feed. These include:

• relevant training courses including distance learning or e-learning activities
• coaching from other experienced Authorised Officers
• review of case studies and literature
• conferences or meetings which involve an element of new knowledge and learning
• reading to understand the legal, regulatory framework for professional work
• maintaining or developing specialist skills
• shadowing of an Authorised Officer who meets the competency requirements
• attending training courses / conferences not linked to official controls but supporting professional development
• taking part in a third country audit or fact-finding mission
• shadowing experienced (internal or external) colleagues to develop knowledge of a feed establishment e.g. manufacturer of additives etc.
• participation in scenario-based case studies (e.g. notice drafting, risk-rating, etc.)
• writing relevant articles for peer-reviewed journals / papers
• writing guidance on feed law or other legislative requirements
• making presentations to colleagues or businesses on legislative requirements, particularly new changes to legislation and
• discussions with colleagues and / or FeBO’s on legal requirements / enforcement action which involve an element of learning. 

Individual officers shall maintain a record of their CPD, which should include the following information as a minimum: 

• dates of activity
• type of activity
• hours spent on activity and
• copy of certification or countersignature from a manager or colleague that the stated activity took place. 

Most CPD is likely to be evidenced by the established practice of certification from a training provider. 

If shadowing, experience or participation in scenario-based case studies includes reflective practice that should be documented by the officer and countersigned by the manager. 

A Competency and Qualification Review Record for officers is provided at Annex 3.3 as an example of a record for the officer’s personal development plan and CPD priorities. 

Professional bodies such as the CTSI operate their own Continuing Personal and Professional Development (CPPD) requirements for their respective membership, which includes providing CPPD evidence as part of membership or Chartered Status. Records maintained for professional bodies may be used to demonstrate feed CPD requirements. 

Every 6 months, officers shall undergo a review of completed CPD to identify and assess benefits or otherwise and identify further development needs to inform an officer’s personal development plan and their CPD priorities. Future development needs shall be collated and shared with the FDB at the quarterly review meetings. This information will be used to develop the annual FSS training plan. 

Newly appointed officers must be assessed to ensure that the officer meets the necessary qualification and competency requirements, for their proposed authorisation. This includes newly qualified officers, officers moving to a new authority and officers returning to feed law enforcement after an absence of one year.

The officer and their manager should work together to identify any gaps in knowledge and consider how this can be addressed (see Chapter 3.7 for examples). A structured training and development programme should be produced to assist the officer to build up experience and develop the necessary competencies. 

Ongoing assessment of developing competence allows the authorising authorities to monitor progress and determine suitability for authorisation. 

A newly qualified level 2 officer would need to gain sufficient experience and be able to demonstrate understanding and competency before they are authorised to inspect complex processes (e.g. approved premises). It is the authorising authorities’ responsibility (using an experienced and competent officer) to determine when this is appropriate on a case-by-case basis.