Regulatory Impact Assessment (RIA) for the Agency's guidance on managing manures for food safety
Friday 19 October 2007
The Foods Standards Agency Scotland (FSAS) seeks views on the Partial Regulatory Impact Assessment (RIA) produced for the Agency's guidance document: Managing Manures for Food Safety.
All comments and views should be sent to:
Contaminants, Hygiene, Additives & Shellfish Branch
6th Floor, St Magnus House
25 Guild Street
Aberdeen AB11 6NJ
Tel: 01224 285170
Fax: 01224 285168
Responses are requested by: 11 January 2007
The RIA is a tool that enables Government to weigh evidence on the positive and negative effects of proposed interventions. The guidance, which is voluntary, is attached in the accompanying document. The guidance itself was the subject of a formal consultation in 2002.
Fresh produce can be associated with a wide range of pathogens, and there are occasions where fresh produce has been identified as the source of an outbreak of food poisoning. The Food Standards Agency has a programme of work that aims to contribute to the identification, understanding and control of the microbiological hazards and risks associated with fresh produce. This work supports the Agency’s strategic aim to reduce the number of cases of food poisoning.
Large amounts of organic waste, mainly animal manure and sewage sludge, are recycled to land in the UK, offering a route of disposal that utilises its fertiliser value and maintains soil quality and fertility. These wastes can contain pathogenic micro organisms and there are concerns that these pathogens can be transferred from the waste to food crops and subsequently cause food poisoning. Direct deposition from grazing animals to land is also a concern. In 1999 the FSA initiated a programme of research to provide evidence and information to help assess the relative risk to the consumer from this practice. The Agency developed guidance, with a stakeholder steering group, on managing farm manures to reduce the microbiological hazards and risks associated with fresh produce based on the results from this research. The voluntary guidance aims to provide growers with practical guidance on reducing the risks of foodborne illness resulting from microbiological contamination of ready to eat crops.
The guidance was agreed some time ago and the Agency would now like to complete the publication process. An RIA must therefore be completed to assess the impact and benefits of the guidance to determine whether publishing the text is the most appropriate option for the Agency. A partial RIA has been produced by ADAS for the Food Standards Agency on a GB basis. We consider that the information given is as relevant in Scotland as it is to England and Wales, while recognising that the enforcement arrangements in Scotland are different from those noted in para 11.
The two options are:
- Option 1: To do nothing. The Agency’s guidance will not be published but will be used to provide advice on the food safety aspects of the application manures to agricultural land
- Option 2: To publish the guidance
The partial RIA indicates the Agency should adopt option 2 and publish the guidance.
I would like to invite you to submit your comments on the partial RIA. Your comments will help the Agency produce a full (final) RIA on the guidance. Views on the following questions are particularly welcomed (supporting information or data should be included where available):
- Are the conclusions of the partial RIA valid and do you agree that the Agency should publish the guidance?
- The partial RIA does not indicate the guidance is impractical or disproportionate. Is this the case for all producers?
- The four case studies are intended to provide a reality check on the expert judgements used in the cost benefit analysis. Are the associated costs realistic?
- Are there alternative examples of specific production practices where costs associated with implementation would be significantly greater?
- Are the generic assumptions used in the cost benefit calculation accurate, in particular assumptions made about current practices, markets and likely implementation of the guidance?
- Should any additional factors be taken into account, particularly in relation to organic production?
This consultation has been prepared in accordance with the HM Government Code of Practice on Consultation, which states that a consultation must follow better regulation best practice, including carrying out an Impact Assessment (Regulatory Impact Assessment in Scotland). The assessment is included in the consultation documents.
We are interested in what you thought of this consultation and would therefore welcome your general feedback on both the consultation package and overall consultation process. If you would like to assist us to improve the quality of future consultations, please feel free to share your thoughts with us by using the consultation feedback questionnaire.
Publication of personal data and confidentiality of responses
In accordance with the FSA principle of openness our Information Centre at Aviation House will hold a copy of the completed consultation. The FSA will publish a summary of responses, which may include personal data, such as your full name. Disclosure of any other personal data would be made only upon request for the full consultation responses. If you do not want this information to be released, please complete and return the Publication of Personal Data Form. Return of this form does not mean that we will treat your response to the consultation as confidential, just your personal data.
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Publication of response summary
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If, after three months, the summary is still not showing, please contact the person who was responsible for the original consultation. Alternatively, you can contact the FSA Consultation Co-ordinator by email: firstname.lastname@example.org