A tall order for port health

The nation's ports are have been on the front pages recently, but not for the reasons we expected.

Already bracing themselves for post-Brexit transition changes, they were suddenly dealing with queues of people and goods stranded in the UK while our European neighbours shut their borders to us in an effort to stop the spread of a new coronavirus strain.

To say they've got their work cut out for them is an understatement as we found out at the beginning of December, when EHN had a glimpse into their world. Here is an extract from that feature. Read the whole thing in the December 2020-January 2021 print issue of the magazine or here (login required).

The Brexit transition period officially ends at 11pm on 31 December, a date that port health authorities (PHAs) are awaiting with increasing trepidation. It signals the UK’s exit from a reciprocal agreement with the EU in which food and agricultural products do not have to undergo port health controls.

In a three-stage process, the UK will begin to impose documentary, identity and physical inspections on produce from the EU, carried out by fully qualified environmental health practitioners and veterinary officers. Thousands of extra checks will be conducted by staff who haven’t yet been recruited, within facilities that haven’t yet been built.

For a workforce that is already understaffed, under-resourced and battling to cope with the COVID-19 pandemic, this is the stuff of nightmares. Nightmares that are gleefully being played out in media forecasts featuring endless queues of lorries jamming the ports with cargoes of rotting food.

The National Audit Office has predicted “significant disruption at the border” from 1 January 2021, and flagged up particular challenges across the border between Northern Ireland and the Republic (more on that in future issues of EHN and EHN Extra).

“Our main concern at the moment is that we are getting very near to the end of the transition period and there are still far too many unknowns,” says the Association of Port Health Authorities executive officer Gary Gould.

“For instance, there are discussions with DEFRA and the Marine Maritime Organisation about whether there needs to be a customs hold on fish and fish products that don’t have the correct certification. This would mean if you have a consignment of fish, it wouldn’t be allowed to leave the port until cleared by port health. That would be a big problem if you haven’t got the facilities to store it.”

The government has pledged to invest £705m to fund the infrastructure, jobs and technology needed to make the new GB-EU border work. But it remains unclear how, when and where the new money is to be spent. Meanwhile, as the deadline draws nearer, many PHAs are struggling to be ready in time.

“DEFRA is talking about contingency plans and that may involve an easing of restrictions. But, once again, we don’t really know what that means,” says Gould. Under the government’s current schedule, the new checks will be introduced in three stages with three key dates:

• From 1 January, PHAs will be required to carry out catch certification checks to combat illegal, unregulated and unreported fishing. A new notification system, IPAFFS (Import of Products, Animals, Food and Feed System), will be in force, having replaced the European TRACES system on 7 December.
• From 1 April, all products of animal origin and high-risk foods of non-animal origin must have the correct health certification and be pre-notified by IPAFFS.
• From 1 July, full checks will be carried out on all EU products subject to sanitary and phytosanitary controls.
While there are some UK ports, such as Felixstowe, that currently receive imported food from outside the EU and therefore already have the experience and facilities to carry out health checks, most smaller ports will have to build up their service from scratch.

According to the chief port health officer of Hull & Goole PHA, Laurence Dettman, this could prove especially challenging. “Some of the larger ports are already heavily involved in imported food work through their border control posts so they have experience going back many years of dealing with imported products of animal origin,” he says. “But a lot of the smaller ports don’t have that traditional expertise. So they’ll be starting from zero, without the resource or the established practice.

“These port operators don’t have any inspection facilities or border control posts. So they are going to have to build these enormous multi-million pound structures to be in place by
1 July next year. And of course we are already struggling with resources, staffing, training, that sort of thing.

“And all of this has got to be done in the middle of a pandemic on a very tight, some would say impossible, timescale.”

John Ambrose, port health officer at London PHA, believes that the new checks will require most major ports to increase their staff numbers by 80 to 100%. “You’ve got to ask where these new staff are going to come from,” he says. “And even if you can get them, it’ll take six to 12 months to get them up to speed.”

Training staff under current circumstances is particularly difficult, he points out. “I can’t have anyone shadowing me at the moment because it’s not COVID safe. So we are trying to come up with new ideas using remote training. But food inspection is about using all your senses – you need to feel it, smell it, even taste it sometimes. You can’t do that over a Zoom call.”

According to Suffolk PHA port health officer Martin Walker, who is based at Felixstowe, even the larger ports are struggling to be ready on time. “The catch certification is a significant amount of work in itself,” he says. “Then there’s the new IT system which hasn’t even been used in anger yet. I had some training on it about a year ago so I’ll definitely need a refresher. It’ll be a massive amount of work to get everybody trained.”

Just to complete a triple whammy of challenges facing PHAs, alongside Brexit and COVID, there are also proposals from the Food Standards Agency to revise its code of practice and competency framework for food inspectors. While this could potentially alleviate recruitment problems, by making it easier to employ staff with relevant experience, there are concerns that it could result in a watering down of professional standards.

“I do have some professional concerns about how this will affect the profession going forward,” says Walker. “I think we need to look very hard at the competency assessments for imported food. I have seen in my time in port health that the imported food side is a hugely specialised area and we’ve seen officers who’ve come in from inland authorities trying to get to grips with the changes in legislation and approach. It can take them one or two years before they feel really confident and competent.

“We need a robust approach to competency otherwise we might end up with a tick-box approach to enforcement and I don’t think that would serve anybody well.”

This is an extract from the cover feature of the December 2020-January 2021 issue of EHN (login required)