Conclusions
36. The Government's Action Plan has been generally
welcomed. The Association of Port Health Authorities thought that
"the Government has done an awful lot in the last year to
improve on the situation as it existed".[104]
However, organisations that have welcomed the general thrust of
the Plan have criticisms of specific aspects of it.
37. We too broadly welcome the Action Plan as an
important first step but, in addition to the comments we have
already made, we would reiterate our concern about the overall
co-ordination of the Government's approach to the issue of illegal
meat imports. We are concerned about the long delay between
the problem being acknowledged by Government - action was being
considered in March 2001 - and substantive action being taken
a year later. Indeed, it seems that without the prompting
of and bringing together of interested parties by the National
Farmers' Union, the forum on illegal meats which agreed the Action
Plan may never have come together.
38. However, since the Action Plan was published
we have generally been impressed with the speed with which the
Government and stakeholders have acted to address the various
elements of the Plan. We hope that the publication of the risk
assessment in September will provide another stimulus to take
the Plan further forward with urgency.
39. Our main recommendations are:
(a) We agree that risk will never be eliminated,
and that proportionate steps need to be taken (paragraph 9).
(b) The degree of uncertainty about the
scale of the problem at the border, particularly if greater certainty
can be achieved through the risk assessment about other points
on the 'pathway', such as preventing a disease spreading to animals,
may mean that changes to policy focus on, for example, the farm
gate rather than the port of entry. Nevertheless, we recommend
that the Government continue to retain and upgrade the information
it gathers about illegal meat imports to enable it to keep the
results of its risk assessment under review (paragraph 12).
(c) We therefore recommend that full details
of the risk assessment, including assumptions made and information
that would improve the assumptions, are published with the risk
assessment so that it is clear to all stakeholders why particular
actions are pursued. Whatever measures are agreed they must not
be seen as an alternative to effective bio-security at home (paragraph
13).
(d) We believe that the Food Standards
Agency should re-examine its decision not to undertake a risk
assessment on the human health implications of illegal meat imports
in parallel with the current study (paragraph 14).
(e) We recommend that the costs considered
when assessing new policies to deal with illegal meat imports
do not just include those faced by Government, but also those
faced by the whole food chain. To put any measures into context
there were more than 60 million passenger movements through Heathrow
alone last year. This demonstrates the scale of the tasks involved
and the risk/benefit relationship (paragraph 15).
(f) The United Kingdom Government must
enter into international discussions aimed at ensuring effective
monitoring of the export trade in order to bear down on any illegality.
To assist such discussions it must demonstrate that its own house
is in order, by making sure that inspections of exports from the
United Kingdom are effective. We are moreover pleased that port
health authority officers already have some form of system for
advising each other of developments but are concerned that it
is not centrally co-ordinated - we hope that the establishment
of the Department for Environment, Food and Rural Affairs's Illegal
Animal Products Seizures (ILAPS) database will assist this process
(paragraph 16).
(g) Granting the power to stop people
to port health authority officers is not entirely straightforward.
Nevertheless, we recognise the strength of the case made for such
new powers. We therefore welcome the fact that the powers available
to port health authority officers will be reviewed, and we recommend
that the Government report the outcome of that review to Parliament
within a year (paragraph 17).
(h) We are concerned that no guidance
was issued with the new powers. At the very least draft guidance
should have been prepared, to help officers understand the new
powers available to them, on the understanding that detailed guidance
would be based on that draft guidance and experience of how the
new powers worked. We hope that the new guidance published in
August will address our concerns, and that it will be regularly
reviewed and updated to take account of the experience of using
the new powers (paragraph 18).
(i) We ask that the Department for Environment,
Food and Rural Affairs explain that delay [in putting in place
new Regulations] (paragraph 19).
(j) We recommend that the Government assess
the costs and benefits of this proposal against the findings of
the risk assessment (paragraph 20).
(k) The current allowances for personal
imports of food, particularly meat and fish, are very confusing.
We therefore firmly support the Government in their objective
of securing a ban on the personal import of meat products. However,
if the European Union does not bring forward better and more effective
measures to deal with this potential abuse the United Kingdom
should give notice that it will introduce unilateral action (paragraph
23).
(l) We believe that it is in the airports',
the airlines' and the Government's interest to have passengers
flowing freely at airports and believe that the greater availability
of information and consequent lesser need for checks of passengers
would facilitate this (paragraph 24).
(m) We believe that the provision of information
in-flight is essential, and we recommend that the Government urgently
seek to persuade airlines to distribute written leaflets, and
show videos as appropriate, setting out the restrictions on personal
imports of meat and other foods. If airlines will not do so voluntarily
we recommend that the Government take steps to obtain legal powers
to compel them to do so (paragraph 25).
(n) Although we welcome the trial use
of dogs to detect illegal meat imports it would be helpful if
the Government were to publish the objectives of the pilot scheme
and the criteria against which its success will be judged (paragraph
27).
(o) We accept that there are limitations
and problems with the proposals to use x-ray equipment and provide
amnesty bins, but we agree with Lord Whitty that both could be
valuable in raising public awareness. We therefore recommend that
both be carefully piloted and assessed for their efficacy in terms
of addressing the problem of illegal meat imports and of raising
public awareness of the problem (paragraph 28).
(p) We agree. In the longer-term there
is a case for greater integration of agencies and management,
and we recommend that Government bring forward a model of a single
agency. In the medium term agencies should commit themselves to
improving the way they work together. In the short term it would
be helpful if the terms of the review of the roles of the agencies
involved in dealing with food imports was published (paragraph
30).
(q) We are concerned that despite well-placed,
intelligence-based suspicion, operations to check flights are
often only mounted when a team can be put together through the
efforts of one official from the port health authority. There
is clearly a need for much higher level co-ordination of such
activity, since it appears that the Department for Environment,
Food and Rural Affairs is not currently fulfilling its 'overarching
role' in this area. Operations against particular flights would
also benefit from agreed commitments, from all the agencies involved,
to the amount of time they are able to devote to operations against
illegal meat imports. We acknowledge that there may be times when
HM Customs and Excise officers, in particular, would be diverted
to more critical work but feel that the higher-level co-ordination
we propose would be better able to take account of such problems.
Moreover, although we acknowledge that other agencies, including
the Food Standards Agency, feel that they should become responsible
for these matters, we are inclined to believe that the Department
for Environment, Food and Rural Affairs should be the lead body
in dealing with illegal imports of meat and other foods (paragraph
31).
(r) We accept that resources currently
allocated to dealing with the problem of illegal meat imports
are not adequate, and are not secure at port level. We recommend
that, once the risk assessment and the review of the roles of
the agencies involved in dealing with illegal food imports have
been completed, the Government provide adequate funds to meet
their recommendations, and consider how they can be secured to
the functions required (paragraph 35).
(s) We are concerned about the long delay
between the problem being acknowledged by Government - action
was being considered in March 2001 - and substantive action being
taken a year later (paragraph 37).
(t) Since the Action Plan was published
we have generally been impressed with the speed with which the
Government and stakeholders have acted to address the various
elements of the Plan. We hope that the publication of the risk
assessment in September will provide another stimulus to take
the Plan further forward with urgency (paragraph 38).
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