Improving flock records
13. On a farm visit, inspectors are required to verify
that proper flock records are kept. The C&AG's report noted
that, while accompanying the Department's inspectors on 26 farm
visits, his staff found a high proportion of cases where flock
records were either poor or non-existent. We asked why, seven
years after the European Court of Auditors reported that flock
records were in a lamentable state, there appeared to have been
little improvement. We were told that the Department had been
acting under a misunderstanding that, if an inspection was unannounced
and carried out during the retention period, flock records were
not that important.[14]
14. It is difficult to see how such a straightforward
requirement could be open to misinterpretation, especially as
the EU had told the Department in 1994 that its records were not
up to scratch. We are left with the impression that this is one
more example of tardiness on the part of the Department in its
administration of the Scheme. It is utterly pointless to instruct
farmers to maintain proper flock records and threaten to penalise
them for non-compliance, but then fail to check and enforce the
requirement. It is clear that the Department needs to get a grip
on flock records and demonstrate to farmers that any failure to
comply with the regulations will no longer be tolerated. Ignoring
EU requirements is not an option.
15. The Department's view of flock records was that
they do not give a high level of assurance as to the existence
of sheep and that a headcount is therefore a better check. However,
a headcount only provides a snapshot, with no assurance as to
the position throughout the rest of the retention period or, indeed,
the date when the claim for premium was submitted. We regard flock
records as an important control, with benefits over and above
sheep annual premium—for example, they are a key source
of information during disease outbreaks, as was demonstrated during
Foot and Mouth in 2001. Because of these wider benefits, checks
on flock records should not be confined solely to the retention
period, but should take place throughout the year.[15]
16. Where a farmer is unable to produce his flock
records at inspection, the Department gives him a further 10 days
in which to submit them for checking. We pointed out that this
provides an unscrupulous farmer with the opportunity to falsify
his records and obtain bogus back-up documentation. The Department
responded that there was little more it can do in these circumstances.
It seems to us that the Department's system of checking flock
records is rendered completely useless by allowing a delay of
up to 10 days to complete the check.[16]
17. The Department did tell us that it was taking
legal advice to establish what is reasonable in terms of giving
people time to produce records. If necessary, the legislation
would be amended to enforce this. We find it hard to envisage
many circumstances where the flock records would, legitimately,
not be available at inspection. If the situation did arise, it
should be very much the exception. In our view, the Department
should make clear that it is up to farmers to ensure that their
flock records are held on the farm and are available at all times
for inspection. Failure to comply should result in some form of
sanction.[17]
Improving flock markings
18. Flock markings is another control measure where
the Department appears to have paid scant regard to the findings
of the EU auditors in 1994. The C&AG's staff noted, while
accompanying the Department's inspectors on the 26 farm visits,
that sheep had not been properly marked in 50% of the cases examined.
The Department told the Audit Office that it did not regard flock
markings as a key control because they were not unique and simply
provided supplementary information. We recognise that the system
of flock marking is not foolproof, but it can provide added assurance
at inspection, as a counter to the fraudulent 'borrowing' of sheep.
As with flock records, the Department needs to send a clear message
to farmers that flock marking is obligatory and failure to comply
with the regulations will no longer be tolerated.[18]
Introducing sheep tagging
19. The Department intends to introduce the individual
tagging of sheep. This follows the recognition, in the wake of
Foot and Mouth, that it needs to be aware of all animal movements.
We welcome the Department's decision, although the timetable for
implementation appears to be open-ended. The Department explained
that there has been a delay while it waits for the EU to come
up with proposals on how tagging should be handled throughout
the Community. While we recognise that there could be some advantage
in waiting for EU guidance, we are concerned that the resulting
delay means that it may be some time before a system of tagging
is fully developed and operational.[19]
13 C&AG's Report, paras 2.16-2.20 and Appendix
2 Back
14
Qq 43-51; C&AG's Report, paras 2.21-2.24 Back
15
Q 77; C&AG's Report, para 2.24 Back
16
Qq 117-125 Back
17
Qq 125-126 Back
18
C&AG's Report, paras 2.23, 2.29 Back
19
Q 78; C&AG's Report, para 2.30 Back
