Government must prioritise effective and robust SPS regime as it publishes new model for import controls

06 April 2023, Ross Matthewman

The Chartered Institute of Environmental Health (CIEH) has welcomed the long overdue draft publication of the Border Target Operating Model (TOM) and calls upon the UK Government to prioritise the need for an effective SPS regime by listening to Environmental Health Practitioners (EHPs) on the front line during this critical next phase.

The Cabinet Office, who published the TOM yesterday, will now begin a further six-week period of engagement with key stakeholders, listening to their views before the final TOM is published in June. CIEH has urged the Cabinet Office, as well as DEFRA and the Food Standards Agency (FSA) who are major parts of the regulatory landscape, to embark upon meaningful engagement with CIEH and its members given the crucial role EHPs play in ensuring the safety and security of the UK’s food supply chain at the ports and inland.

Concerns had grown that the longer the UK operated with no checks on EU imports, with little plan for the intended capability of a future all-encompassing regime, the greater the risk posed by food safety and animal health incidents.

These concerns have been highlighted in recent developments such as the FSA's ongoing investigation into a rogue meat supplier supplying British supermarkets and food manufacturers with mislabelled mixed meat produce, the illegal import of food products as well as mislabelled food stuffs making its way into our supply chain.

Following a Cabinet Office all-stakeholder engagement call on 5 April to present some of the high-level aspects of the new TOM, the implementation dates, and rationale behind the proposals, CIEH were disappointed that the focus from officials was heavily weighted on the need to reduce regulatory burdens on business compared to securing an effective and proportionate regime for SPS checks.

EHPs play a vital role in maintaining the safety and security of the UK’s food supply chain, within local authority environmental health and port health teams at ports and inland.

Crucially within the private sector, too. EHPs are at the front line in preventing risks to public and animal health and supporting legitimate businesses to sustain a level playing field. Our experts are working closely with DEFRA and the FSA and thus are integral in maintaining the high standards we enjoy in the UK.

CIEH is also continuing to argue that EHPs can play an even more crucial role in the implementation of this new TOM for import controls. Under currently retained EU regulations, checks on particular products of animal origin can only be carried out by an Official Veterinarian. CIEH suggests that any post-EU regulatory regime should enable EHPs with the required competencies to support their veterinary colleagues by undertaking much more of this work.

Ross Matthewman, Head of Policy and Campaigns at CIEH, said:

"We welcome the draft publication of the TOM by the Cabinet Office, which is long overdue.

CIEH and our members had been growing increasingly concerned that the longer the government dithered and delayed in publishing the TOM, the greater the vulnerability of the UK’s food supply chain to food safety incidents and animal health risks, as illustrated by several concerning incidents recently.

Our members play a vital role in maintaining high food standards in this country and by taking on some new responsibilities, could play an even bigger role in ensuring the smooth delivery of this new regulatory regime whilst easing the pressure on potential veterinary shortages.”

Helen Buckingham, Chartered EHP and regulatory policy expert, said:

"While the publication of the long overdue TOM is to be welcomed, early signs as to the Government's priorities and the apparent lack of engagement with those who will be delivering the new regime, are somewhat concerning.

Government officials have had much to say about regulatory burdens not being too onerous on businesses in the new regime, but there’s much less being said about the planned effectiveness and capability of it when it comes to SPS checks.

The vast majority of engagement has been with the border industry and businesses so far. Yesterday’s government press release promises further engagement ‘with industry.’ It feels to me that input from regulatory experts on the front line who will deliver this new regime is scarcer and this worries me.

To focus so heavily on reducing burdens for business and keeping traffic moving, as opposed to talking more about having a better regime of checks that are fit for purpose, is another imbalance in what I’ve read so far. Sensible checks not only keep us safe, they also support good businesses from being undercut by unscrupulous competitors.

CIEH will work with key partners operating in this space, such as the Association of Port Health Authorities, the Local Government Association, and the Chartered Trading Standards Institute, to ensure that our collective, knowledgeable voice is heard at this final design stage and into the implementation of the new regime.”

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