Memorandum submitted by British Air Transport Association in conjunction with British Airways Plc and Virgin Atlantic Airways Ltd (F13)
1.1 The British Air Transport Association ("BATA"), British Airways ("BA") and Virgin Atlantic Airways ("Virgin") welcome the Committee's invitation to submit comments to its inquiry into Illegal Meat Imports. We have a common interest and concern with illegal meat imports and UK aviation and this memorandum represents the shared views and opinions of all three organisations. We acknowledge that this is unusual and hope the Committee will recognise our united approach.
1.2 BATA represents most UK-registered airlines including scheduled, charter and cargo carriers. Members produce 95 per cent of UK civil aviation output and all long-haul services.
1.3 BA is the UK's largest airline, carrying more than 36 million passengers worldwide in 2000-01 to 266 destinations in 99 countries. It contributes some £2 billion annually to the UK balance of payments.
1.4 Virgin is the UK's second largest long-haul carrier, it has one of the youngest and most environmentally-friendly fleets in the world and is the launch customer for the Airbus A340-600 which uses Rolls Royce engines and UK-manufactured wings. For the year 2000-01 the Virgin Travel Group had a turnover of some £1.4 billion.
1.5 The attack on the World Trade Centre in New York on 11 September 2001 led to a severe downturn in the airline business. UK airlines, particularly those flying long-haul and trans-Atlantic routes, have been badly affected. BA and Virgin have both implemented radical cost-cutting measures, including job losses, capacity reductions and wage freezes to combat the downturn in their business.
1.6 Following the attack, airlines and passengers have been subject to increased security measures, resulting in increased costs and extended airport departure procedures.
2.1 BATA, BA and Virgin attended the summit arranged by the Department of the Environment, Food and Rural Affairs (DEFRA) on 21 March 2002. It was agreed by all at the summit meeting that a risk assessment study should be the first point of action. This was reflected in the action plan issued by the department on 28 March 2002.
2.2 BA and Virgin were contacted by the Veterinary Laboratory Agency ("VLA") and willingly agreed to assist with the collation of information for the risk assessment study.
The initial discussions with the VLA highlighted the regions of the world believed most likely to be responsible for illegal meat imports. Both airlines undertook to liaise with their respective teams in West Africa and the Far East for the purposes of information gathering.
2.3 This process identified a previous problem in early 2000 with flights from Lagos which BA shared with another carrier whereby illegal meat was discovered in passenger baggage. Stringent screening of all checked and hand baggage was introduced and an education programme begun by means of posters in the check-in area. Local evidence shows this has significantly reduced the scale of the problem.
2.4 The airline faced hostility from passengers and the local national authorities. Although the checks were in compliance with the then Ministry of Agriculture, Food and Fisheries directives, they were perceived as airline bureaucracy and discriminatory.
2.5 Today, BA and Virgin passengers' bags are subject to hand searches by the local customs authorities, and all hold baggage and carry-on baggage at check-in at Lagos is subject to 100 per cent x-ray screening. To the best of our knowledge, the problem has largely been resolved as a result of these targeted measures instituted by UK carriers.
2.6 BATA members have no evidence of illegal meat imports from other airports in West Africa nor from the Far East.
3. DEFRA ACTION PLAN
3.1 BATA, BA and Virgin believe the action plan addresses the issues raised at the 21 March meeting.
3.2 A full risk assessment is now underway and UK airlines are grateful to DEFRA for the opportunity to contribute to it. The assessment must include all transport sectors ie road haulage, container and passenger shipping, international rail services and aviation, if an accurate and meaningful result is to be achieved.
3.3 We fully endorse the aim of more co-operation to achieve effective inter-agency enforcement. At present, responsibility for HM Customs, Immigration, overseas consular and embassy representation, port health and Environment, Food and Rural Affairs officials is split among a similar number of central and local Government departments with no effective co-ordination of resources, targets or policies. We recognise that difficulties and problems could arise however we believe it is vital the various agencies work together if illegal imports of meat and plants are to be reduced.
3.4 We believe strengthened intelligence to counter smuggling is necessary and will result from enhanced inter-agency co-operation.
3.5 Increased powers to search for illicit produce are also required if any benefit is to be gained from the increase in resources achieved by closer inter-agency co-operation.
3.6 BATA, BA and Virgin welcome UK liaison with Europe to reform rules on personal imports. Confusion will continue to arise as long as variations in allowance limits and regulations exist between the UK and Europe. For example, airline passengers arriving from non-EU countries via EU transit airports enjoy enhanced allowances into the EU countries and thus into the UK with the elimination of border import controls.
3.7 We believe the provision of information and education of both air and sea passengers is necessary if there is to be a major reduction in the volume of illegal imports. We do not consider the official information currently available to travellers to be clear and unambiguous, in particular the different limits between EU and non-EU services to the UK, by sea and by air.
3.8 We would support an evaluation of the use of detector dogs and the use of x-ray machines to scan containers, as used in other countries.
4. POLICIES AND PRACTICES
4.1 We believe it should be a function of Government to ensure the necessary checks are made to stop illegal imports by individual citizens or organisations through all ports of entry to the UK.
4.2 Current UK regulations and penalties have proved to be ineffective deterrents against the smuggling of illegal drugs and excess duty and tax free goods into the UK. We do not believe similar regulations and restrictions on the import of illegal meats would be effective. New and effective methods must be introduced if the practices of smuggling illegal goods are to be eliminated.
4.3 Warning posters and signs at airports in Australasia and North America are understood to be effective in reducing the amount of illegal meat and plant imports into those areas. "Amnesty bins" are provided for arriving passengers to dispose of suspect produce without penalty.
4.4 Individual customs declarations are required for many countries which require travellers to provide details of goods and monies with which they intend to enter the particular country. The penalties for incorrect declarations are highlighted on these forms.
4.5 Sniffer dogs are an integral part of the anti-smuggling activities in many overseas countries. We cannot comment on the effectiveness of the dogs in tracing food stuffs in baggage but anecdotal evidence suggests they have a deterrent value.
5.1 BATA, BA and Virgin commend the Secretary of State for Environment, Food and Rural Affairs for the expediency shown in formulating an action plan following the summit meeting of 21 March. The Department also instigated a risk assessment study at short notice.
5.2 The scheduled, charter and cargo airlines of the UK are conscientious companies who comply with Government regulations world-wide. Following the events of September 2001 they have acted quickly and responsibly to fulfil their obligations under new and emergency requirements and legislation. In the case of illegal meat imports, where a specific problem has been identified, targeted action has been taken swiftly and efficiently to contain or eradicate it.
5.3 As an industry with much experience of Government legislation we caution against instant and quick-fix solutions. We do not believe "blanket" action is justified, necessary or possible to address the problem of illegal imports. It would be costly and detrimental to the successful UK aviation industry if airlines were required to search for meat products.
5.4 We do not believe the issue is restricted to the straightforward smuggling of illegal meat and plant products in passenger baggage. UK airlines have already instituted a series of measures to deal with the problem where it is known to exist but it was apparent from the concerns raised at the 21 March meeting that the volume of illegal meat imported into the UK exceeds that carried by airline passengers.
5.5 We urge the Committee and DEFRA to ensure the issue is tackled on a wide scale to ensure the eradication of the practice of smuggling. We acknowledge that airlines and their passengers are a visible and easily identifiable part of this complex trade. However, it is wrong to consider that they are the sole source of illegal imports and we believe the problem must be tackled holistically rather than by addressing this sector in isolation.
5.6 BATA, BA and Virgin expect the DEFRA action plan will reduce the illegal meat import trade if and when all points of the action plan are successfully implemented. We look forward to future consultation.
23 May 2002