The Council of the Royal College of Veterinary Surgeons (RCVS) has agreed to an urgent request from the Animal and Plant Health Agency (APHA) to prepare supplementary guidance on certification for veterinary surgeons in face of the ‘extraordinary’ circumstances that might be seen if the UK leaves the EU without a deal.
The supplementary guidance would relate specifically to the veterinary export health certification of groupage consignments, ie those which contain multiple low-risk food product types in a single consignment, for export to, or transit through, the EU.
Currently, Export Health Certificates (EHC) are not required for such consignments; however, in the event of a no-deal EU Exit, the UK would assume third-country status and be required to develop a scheme to enable the substantial volume of these product export/transit arrangements to continue.
Such low-risk products would include products of animal origin for human consumption, eg composite products like pizzas and quiches, meat products and processed milk, along with processed pet food; they would not include products like fresh meat, raw milk, raw pet food or live animals.
APHA’s proposed scheme is intended to facilitate the provision of relevant consignment information to the Official Veterinarian (OV) responsible for issuing the EHC in a manner that meets their professional obligations whilst also accommodating the scale and complexity of the supply chains involved.
The College’s supplementary guidance would recognise that it would be neither practical nor possible for the certifying OV at the point of export to have personal knowledge of all relevant products contained within a groupage consignment. Instead, the scheme would involve the OV relying on a ‘support attestation’ containing:
a.a ‘supplier declaration’ made by a representative of the supplying company who has ‘authority and responsibility’ to do so, such authorisation coming in writing from the managing director or equivalent; and,
b.a declaration by a registered veterinary surgeon (or Certification Support Officer acting under the direction of an OV) carrying out relevant checks in relation to the supplier.
The supplementary guidance would further acknowledge that for such a scheme to be workable, veterinary surgeons would need to place reliance on exporters and suppliers of goods providing batch specific information valid for 30 days (with additional assurance provided by vets carrying out periodic checks of the supplier’s premises and records ).
However, the system would be limited to use only in stable supply chains, with APHA’s implementation of a Trusted Supplier Scheme (TSS) intended to provide confidence in the accuracy of support attestations. Any exporters found to be non-compliant could be immediately removed from the TSS, potentially permanently.
The College’s supplementary guidance would then advise OVs to ensure they read, understood and strictly followed APHA’s new guidance on export health certificates, and would offer the reassurance that, providing they act with integrity and adhere to the guidance, no personal liability would attach to them in the event that the information contained with a supplier declaration is incorrect or incomplete.
RCVS President Niall Connell stated: “In discussions at its October meeting, in which we were pleased to have invited the British Veterinary Association to participate, RCVS Council had some concerns around this departure from our usual guidance and therefore sought a number of clarifications and changes to APHA’s original scheme.
“Whilst acknowledging the steps taken by APHA to address these concerns, Council then put in place a number of caveats to preparing its supplementary guidance, including that it would be time-limited, subject to review, and only applicable in the extraordinary circumstances of a no-deal Brexit.
“It also accepted assurances from APHA that these certification changes would not compromise public health, or animal health and welfare, but would be urgently necessary under no deal in order to be able to maintain the UK’s existing food export arrangements."
The caveats to Council’s agreement with APHA to prepare this supplementary guidance are as follows:
· It would only applied in the event that the UK were to leave the EU without a deal;
· It would be a temporary, time-limited measure, as a result of these exceptional circumstances;
· RCVS Council would review this guidance within 12 months of its implementation; and
· The scope of the guidance would be strictly limited to the process for issuing Direct Export or Transit Export Health Certificates for groupage consignments containing low risk products being exported to, and transiting through, the EU.
Apart from the specific situation that would be set out in the supplementary guidance, the rest of the RCVS guidance on veterinary certification would continue to apply.
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