Richard North, 26/01/2021  

A long-running problem spilled over into the pages of The Times yesterday when Shane Brennan, chief Executive of the Cold Chain Federation, wrote an article complaining that the UK food industry "faces a massive wall at the EU border", and needs help to scale it.

Brennan is concerned about businesses meeting "new" requirements for exports which, he says, is not about getting one form or one process right, but dozens. Buyers, sellers and the cold chain must synchronise actions precisely, and it relies on overburdened and at present inexperienced third parties such as official vets and customs agents.

Of those "inexperienced third parties", he offers one example - the "official veterinarians" who must officially certify the export of all meat and dairy goods. In Australia (and pretty much every country in the world), says Brennan, these vets are government employees.

In the UK, however, he points out that we rely on a largely part-time group of private, domestic and farm vets, who are coping with at least ten times more demand than they were a month ago. The responsibility and risks, he says, fall on these individuals, and errors can cost them their licence and livelihood. It's a big barrier to trade, and there is no evidence we are even considering whether our system now needs to change.

To be fair to Brennen, this is by no means the first time he has raised this issue. In early December, he fronted a letter to the Environment Secretary signed by his own and 26 other trade associations. There including the Food and Drink Federation, the NFU, the Road Haulage Association, the Food and Drink Exporters Association and the National Pig Association.

This letter warned that trade volume to the EU in foods of animal origin could drop by 75 percent if more official veterinarians were not hired before the end of the Brexit transition period. After that period, it was expected that they would have to deal with a ten-fold jump in demand for export health certificates, required before goods could be despatched to an EU destination.

At the time, Brennan claimed that the food and logistics industries had been raising this issue with Government for the previous four years. Then, with less than a month to go before the end of the transition period, he and his co-signatories were asking the Secretary of State "to use this crucial window of opportunity before the changes come into force on 1 January to increase certification resource and simplify the export process".

Their letter suggested three actions the Government should take, calling for all currently active official veterinarians "to play a direct role in supporting the export certification process for products of animal origin".

Secondly, it wanted the Animal and Plant Health Agency to use its authority to significantly simplify the guidance on how official veterinarians at the last point of departure before export can rely on existing controls as the basis for having confidence to certify the products for export.

Finally, the letter called for a revision on the rules on what inspection and verification must be done by an official veterinarian, and what could be done by an appropriately trained and supervised certification support officer.

With such a short time left, however, it was unlikely that much could or would be done. However, in late September, then with just over two months to go, agriculture minister George Eustice had claimed that UK had doubled the number of official veterinarians to 1,200 since February 2019, and had added more than 100 "support officers". How many would be available for certification work was not specified.

At this point, we saw an intervention by Jason Aldiss, former managing director of Eville & Jones, the largest government contractor currently providing health certificates on UK food exports. He said that Defra had failed to grasp the scale of the challenge, claiming that the government "doesn't really understand the limitations in the vet community and hasn't reached out to them in a meaningful way".

And just to stress the importance of the point, Dominic Goudie, head of international trade at the Food and Drink Federation, said the availability of vets was a "critically important" issue for UK exporters.

So it comes to pass that, months later as the crisis builds, we have Brennan taking to The Times to air his complaints. But, as always, this blog was on the case way back, and with a key piece published in October 2018.

There I also quoted Jason Aldiss, who was warning of a veterinary recruitment and retention crisis in the UK – a problem that was getting worse. Currently (then more than two years ago), 45 percent of UK government vet posts had been filled by vets from other EU member states and 95 percent of OVs were non-UK EU vets. Since then, the situation has deteriorated, with many of the problematical issues rehearsed in a Select Committee Report published on 17 December last year.

From this emerges two points – that UK-trained vets find working in abattoirs "unattractive", leaving the UK overly reliant on migrant vets, mostly from EU Member States. In practice, many of them are recently qualified, with limited experience and poor English language skills. Often, they use OVS appointments as a way of accessing the UK system in order then to find more agreeable clinical work in animal practices. Deep down, they all want to be James Herriot clones.

Despite the shortage of vets, nothing has been done to stem the developing crisis, while many of the EU-trained vets have gone home. As much to the point, no one seems to be questioning why the UK is continuing to adopt this "clunky" vet-based system that was only introduced because we joined the EEC. It has never functioned efficiently, despite its enormous expense. If there were to be any immediate benefits from Brexit, dumping this system was one of them.

The full system actually came to us in its current form with the advent of the Single Market and the implementation of Directive 91/497/EC. In 1997, I was instrumental in pushing a challenge to the system as far as the ECJ. Given the limited grounds on which we could make the case, the challenge failed – as we feared it would – but we now have the opportunity to start again.

In anticipation of the possibility of change, in October 2019 the Chartered Institute of Environmental Health came up with a neat solution to the OV problem, suggesting that the UK sought to include in the definition of "Official Veterinarian" set out in the EU's "official controls", both Official Veterinary Surgeons (the UK designation for OVs) and Environmental Health Practitioners.

This would have immediately released a body of about 10,000 environmental health officers, who would be potentially made available for export work, solving the vet shortage crisis at a stroke. There would also be the added benefit of reintegrating the controls into the mainstream UK food safety system.

Needless to say, Johnson's negotiating team failed to inject this into the TCA, leaving the crisis unchecked. Meanwhile, in a clumsy attempt to ease the pressure, the Royal College of Veterinary Surgeons has introduced the new role of Certification Support Officers.

With a mere "six hours of accredited online distance learning" – less than a basic food hygiene certificate taken by catering staff - plus "a period of supervision" under a qualified vet, these CSOs would do the dirty work, leaving their professional masters to sign the certificates and collect their generous fees. Only about a 100 of these veterinary servants have joined up.

It was this master-servant arrangement which, in the very first of the EEC's hygiene directives to hit the ground in the UK - Directive 71/118/EEC - imposed an unprepared and largely unqualified veterinary profession on the food safety system in this country.

One effect was to turn more appropriately qualified and more experienced EHOs into "qualified assistants", who could only be grudgingly entrusted "certain tasks", while "acting under the responsibility and supervision of the official veterinarian". Most EHOs, seeing the writing on the wall, walked away from meat inspection. The result was a fragmented and degraded food control system.

Since then, neither the veterinary profession nor the government seem to have learned anything. And having bequeathed a dysfunctional system which is incapable of any remedy without root and branch reform, they are incapable of providing the service that the UK food industry so desperately needs.

The tragedy of it all is that, while Brennan claims that the food and logistics industries had been raising the veterinary issue with Government for the past four years, the rot goes back nearly fifty. Without understanding where the real problems lie, all the likes of Brennan can do is argue for more of the same – the extension of a system which never worked properly in the first place.

But, for all that, this is down to the government and, if it cannot even sort out the British end of the export system, it seems unlikely that we can expect anything other than continuing tales of woe.

Also published on Turbulent Times.

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