APPENDIX 3
Memorandum submitted by the British Ports Association (F5)
1. The British Ports Association comprises 86 port authority members, including the overwhelming majority of significant UK passenger ports. We welcome this opportunity to comment on the Action Plan and its implications for sea ports.
2. We believe that its most important aspect is risk assessment, the results of which are not yet available. Information on the exact nature of the risks and the source of illegal imports is vital. Already there have been misunderstandings about the nature of traffic through UK sea ports. Whereas airports are clearly dealing with inter-continental (ie third countries from where the main threat originates) as well as intra-EU traffic on short-haul routes, UK passenger ports handle traffic which originates almost entirely within the EU and so the threat is substantially different. Ports were asked recently to take part in the poster campaign identifying risks from illegal food imports for cross channel traffic. The ports concerned declined to be involved as the campaign was not relevant; its actual effect would have been to confuse passengers bringing food bought through the usual channels into the country.
3. There are elements of the Action Plan which we support, for example, increased co-operation between agencies coupled with effective intelligence and targeting. We also very much agree that publicity (notwithstanding the points made above) should be used to increase greater awareness of the risks and the penalties.
4. On the question of co-operation between agencies, this is a point of high significance. One of our aims across a whole range of border controls has been to significantly increase agency co-operation, preferably through the setting up of a Single Border Agency which can carry out controls by sharing facilities and personnel. Sharing has been achieved only to a very limited extent; but the fact that, for example, Customs, the Immigration Service and Special Branch require different facilities at ports creates in our view a poor use of resources and a significant hindrance to port efficiency and passenger and traffic flows. Where sharing arrangements are not introduced, any proposals should ensure that there is no duplication of existing legislation, such as that already enforced by Port Health Authorities. Whatever measures are eventually taken will need to bear this in mind; they should be in sympathy with the efficiency objectives of the port concerned.
5. On the theme of sharing resources, we note the possible use of X-ray equipment to scan containers and personal baggage. X-ray machines are currently used by Customs at ports and require significant space to accommodate them, causing disruption and delay to queuing and processing vehicles. We are currently in negotiation with the Immigration Service who have suggested that they may even wish to deploy their own X-ray equipment, putting further pressure on port space and efficiency. The scope to introduce more equipment of this type simply does not exist.
6. Ports are convenient places to locate controls and, in our view, suffer disproportionately as a result. We would hope that not all detection activity is concentrated at ports. [Single Market principles require intra-EU trade processes to mirror domestic ones and as such control should take place at the origin and destination of the goods, rather than en route.] Therefore, we believe that if there is to be a new regime at the UK border this should be complemented by a similarly rigorous detection regime inland. The evidence so far suggests that the amount of illegally imported foods is very small scale; at the same time we appreciate that the consequences for both animal and human health of such small amounts of illegal imports could be significant. We are also very aware of the pressure from the UK food and farming sector and others who are understandably concerned about the disease threat. Nevertheless, we urge the Committee to recommend that action taken is practical and proportionate and carried out in full consultation with those who have to accommodate the inspection services.
7. If a UK regime is to work it will need to be complemented by a tightening of controls at external EU borders. We regard this as a key factor. Any action by the UK would be severely undermined if it was not carried out in co-operation with other EU member states.
8. In summary, we urge the Committee to use its influence to ensure that:
— Clear distinctions between the traffic handled by airports and seaports is appreciated and taken into account.
— Publicity campaigns are relevant to the type of traffic at which they are directed.
— Controls at ports are carried out with due regard for port efficiency.
— There is no duplication of existing legislation or powers.
— Opportunities for increased co-operation between agencies are explored.
— Action is taken at external EU borders.
17 May 2002
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