Suffocating under a blanket of paperwork
22 01 2008I’ve spent a large part of the past two days working my way through paperwork, trying to find out what paperwork I’ll have to keep and submit to meet various pieces of new regulations, and trying to find out what further regulations are in the pipeline.
It’s an impossible task.
No matter how well intentioned the aims, no matter what the perceived problem is and no matter how many existing laws there are, Government at all levels steadfastly believes the answer lies in more prescription and more paperwork.
One of the more time consuming pieces of agricultural legislation that’s just come into force in the UK are the feed hygiene regulations.
It’s a response to various animal feed scandals in Europe, including dioxin from used engine oil and human growth hormone MPA both being found in animal feeds.
The response was not to ensure better enforcement of existing regulations, but to draft new, more prescriptive rules with an accompanying paper trail.
The result is the feed hygiene regulations.
I’m not going to detail what the regulations entail, except to say that it means I not only have to keep the receipts for all the feed I buy and mix, but also the labels from the packaging so I have details of the exact make-up of the feed.
I also have to keep a detailed log of what I buy, when I buy, from whom I buy, when the best before date is, when I started using the feed, when I finished using it, what recipes and proportions I used in mixing feed, and how often I feed the mix. I’m also supposed to keep 500g samples of feed.
It’s probably not too onerous for a large commercial operation buying truckloads of feedstock, with barcode data entry systems, computer controlled mixing and dispensing, lab analysis of feeds, and staff whose job is to handle paperwork.
But when you buy feed monthly, in sacks, add your own vegetables, use different recipes for dry sows, in-pig sows, lactating sows, boars, various ages of weaners, for different combinations of poultry, and do it all on your own, it’s yet another burden to be shouldered and yet another loss of productive time.
To make matters worse, it’s not the only new piece of legislation to come into effect.
A much less known piece of regulation, certainly among smallholders and crofters if forum and blog discussion is anything to go by, is the food chain information rules.
These require slaughterhouses to ensure pigs they accept for slaughter are healthy and properly identified, and are accompanied by the required information from “producers” (we’re not farmers, smallholders or crofters).
Some information only has to be provided to the slaughterhouse once — the holding’s status, animal health status, reports of veterinary inspections, name and address of vet — but other information has to be provided each time pigs are sent to slaughter.
This includes the dates medicines were used and the withdrawal periods, diseases that might affect the safety of the meat, and the results of samples taken to diagnose disease.
What’s particularly daft about this legislation is that it overlaps with the two pig assurance schemes (which are whole food chain schemes and cover feed and drugs) and with information provided on the animal movement licence that already has to be completed.
No one seems to have had the thought that what’s really needed is one simple, easy to complete form, accessible via the internet and cross-checked against the actual animals at the slaughterhouse that covers an animal right through the food chain.
Give each animal a unique identifier, then trace it electronically as it passes from farm to farm (which already have unique identifiers), to market, to slaughter, to processor/butcher, to point of sale and with all movements logged as well.
If a farm is part of an assured scheme, that would be automatically included as part of of the information attached to the farm’s identifier.
If the animal is reared to organic standards, that would be matched against all the producers and processors who handle it. Similarly with pedigree pork and free range pork.
Instead of requiring producers to maintain animal medicines books, incorporate that into the system as well.
When the vet visits or a farmer, sorry producer, administers medication themselves, a few clicks of a mouse would enable an animal or batch of animals to be noted as having been treated with ABC on X date and ready for slaughter only from Y date.
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There should also be an opt out to allow smallholders and crofters who keep very small numbers of animals for their family’s consumption off the system, except for information about who they are, where they are and what breeds they keep.
In return for the lighter hand of regulation, they would have to accept not being able to sell their meat for human consumption or being able to put live animals back into the system.
In other words, you could keep a couple of pigs, sheep, goats, even a steer but you’d have to eat them yourself and not put them back into the system. You’d not be able to breed from them either unless all the offspring were staying with you to be eaten.
If the British Pig Association, a charity, can set up an easily understood and accessible system to register, transfer and trace pedigree livestock with a few clicks of a mouse, then surely the various Governments could come up with something a little more comprehensive for whole-chain livestock traceability?
Hmm, pigs might fly.
Anyway, back to paperwork.
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On top of the feed hygiene regulations and food chain information rules, I’m now supposed to get a certificate stating that I’m competent to transport livestock over distances greater than 65km and up to eight hours away.
There are more than a few problems with this, particularly in Scotland or anywhere else where it can be a long distance between population centres, markets, abattoirs and the like.
If you live in much of England and large parts of mainland Europe, then it’s not a problem for most producers as their holdings are within 65km of markets, abattoirs and other producers.
If you live in the Highlands, or even where we do in Aberdeenshire, it can be quite a trek to the nearest abattoir, market or even to a breeder with the same breeds as yourself, particularly for pedigree stock.
I take sheep to Elgin to be slaughtered and will need a certificate of competency to transport sheep as Elgin is 65.7km away by the shortest route.
The nearest breeders of pedigree Berkshires are in the Scottish Borders and Dumfries and Galloway, so I need a certificate of competency to transport pigs.
If I want to buy Scots Grey pullets from Kintaline Poultry in Argyll, then I need a certificate of competency to transport poultry.
And there’s the next problem.
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I’m required to have a certificate of competency for each species that I transport as a separate one is required for transporting cattle, sheep, goats, pigs, horses and poultry.
This is a huge problem for small, mixed farms, crofts and smallholdings as we can have four or more species.
Each certificate involves a separate one-hour assessment, each has a £17 administration fee to be paid to the Government, and each as its own fee to be paid to the independent assessor. Oh, and you have to pay for the training as well.
It’s not so much a problem for most of the big commercial producers as they mainly used hauliers for longer distances and the hauliers will ensure their staff have the requisite certificates while passing a small proportion of the cost to each of the large producers that use their services.
But it gets worse. There are only two assessors in Scotland, one near Dundee and one near Edinburgh.
We’re a single-car household, with two young children and livestock to be fed and watered, but I somehow have to find two hours for the drive to the nearest centre, spend another three to four hours doing the assessments and the paperwork (remember, I need three certificates), and then drive another two hour back.
I also have to get the Other Half to work, arrange child care for the children and hope there are no hold-ups that keep me away even longer.
It would be even worse if we were further to the west and/or north, or out on the Islands.
To make matters even more complex, I’ve already had to get authorisation to transport animals over those distances and have held this for a year.
But authorisation is seen as something completely separate to competency.
Couldn’t the Government have combined these into one certificate and arranged for a number of assessment centres around the country?
Or have traveling assessment centres that visit population centres several times a year?
Or given people unique identifiers so they could their theoretical assessments on line? If universities can do this, then surely the Government could?
Sorry, pigs might fly again.
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All of this is on top of a swathe of other regulations that I struggle to keep abreast of.
In fact, I’m certain that I’m probably breaching some regulations because I simply haven’t heard about them or been able to find out what they area.
And there lies another part of the problem.
Governments increasingly rely on industry bodies, industry newspapers and magazines, stakeholder groups and specialist consultants to tell producers about new regulations and their associated paperwork.
It might work most of the time for the large commercial producers with their lobby groups, consultants, industry body memberships and a budget that includes subscriptions to umpteen newspapers, magazines and news letters, but it doesn’t work for the smaller producers.
In the case of the food chain information rules, the first I heard of it was when a Gloucester Old Spot breeder mentioned it at the beginning of the month (which was when it came into effect), while a British Lop breeder mentioned it on the River Cottage forum.
Both had heard about through their club newsletters. I found out more about the rules last week from the Berkshire Pig Breeders Club newsletter.
Quite a few of us then tried to find out more, checking with SEERAD (Scotland), Defra (England), Trading Standards (local government), Animal Welfare (local government) and with abattoirs (many of which didn’t know exactly what the new rules entailed).
Eventually, we found the new rules come under the Food Standards Agency, which gives us another set of bureaucrats to work with but at least they have put the guidelines on their website.
Just don’t look for the Scottish version as the links always bring you back to England and Wales.
That brings up the next problem. Defra, which covers England and Wales, has a reasonably good website where, with patience, you can usually discover much of the information you need.
If you’re in Scotland, however, then you have the dreadful SEERAD website, which is not only difficult to search but often lacks the information you need.
As an example, don’t bother looking for information on pig identification and traceability on Scotland.
For the past four years, SEERAD’s website has read “Pigs (This information will be added shortly)”.
There are scores, even hundreds, more examples I could give but I’m that if you’ve reached this point then you’re as sick of paperwork as I am!
Suffice to say that the most likely thing to cause us to stop keeping livestock is the regulatory and paperwork burden.
Well or course you have nothing better to do, do you?!?!
We have similar annoyances at my work with the differences between English Building Control and Scottish Building Standards. The most irritating is that in England we can use a consultant who isn’t attached to a Council, but in Scotland we’re dealing with a different person each time in each local authority, who interprets the Regulations their own way.
By the way, I noticed you added me to your side bar. That’s very kind, thank you.
“Suffice to say that the most likely thing to cause us to stop keeping livestock is the regulatory and paperwork burden.”
IMO that is the idea, the powers that be don’t want people to produce small scale and be self sufficient - they want us to be beholden to large producers and the best way to put people off is by making it as difficult as possible to have a few back yard chickens or pigs.
Big business cocks it up because they are so big and impersonal and things get overlooked, but as always its the little man that pays the price.
MLA, as you know, I like nothing better than sitting around, making my bum bigger!
Sarah, I know all about different local government interpretations of regulations in Scotland. Each council has its own version of the animal movement licence for pigs and wants that one used. They also want herd books completed in their preferred format. The problem comes when animals cross local government boundaries. I’ve had to rewrite forms a couple of times to satisfy different people - even though the information on the form is exactly the same. I try to list the blogs and websites of regular visitors in my blogroll, plus ones I find interesting. However, with about 1,000 unique visitors to this blog now, it’s difficult to stay on top of the blogroll and make reciprocal visits/comments. I try, though.
WGA, it’s not just speculation on your part. The Berkshire Pig Breeders Club states in its last newsletter that the Government sees smallholders as “the” threat to British biosecurity. Given that all the major disease outbreaks have been down to illegal activity, cock-ups by Government bodies, and stuff-ups by big business, it’s more than a little odd that smallholders are the “the enemy”. I’ve also heard bureaucrats here and in England expressing the desire to get rid of the small, “inefficient” producers in favour of a few big monolithic producers.
It’s not just the small producers the government wants rid of:
Defra vision of a farm-less Britain? - Telegraph.
Incidentally, have you read ‘Bring me my bow’ by John Seymour? He was ranting against just this sort of pointless bureaucracy thirty years ago.
alf
Alf, thanks for that link. The article certainly chimes with our experience.
I haven’t read “Bring Me My Bow” - I’m an ex-pat Aussie so I hadn’t read many of the British farming/smallholding/self sufficiency books until recently and I’m still playing catch up.
It’s an interesting choice of title, though. Was Seymour referring to Blake’s New Jerusalem by any chance?
WGA, you have taken the words right out of my mouth! I am not someone who subscribes to conspiracy theories, but I truly believe that the plan is to stop anyone from looking after themselves in anyway whatsoever. If you can take care of yourself, you can’t be controlled. I wonder if it will be veg growing next?
Vegetable growing is next. Check the seed laws - they’re designed to force out the heirloom, land race and traditional varieties in favour of the varieties developed by the big seed companies and for which they can charge a fortune.
The EEC Common catalogue has been around a long time - in fact it came into force in the 1970’s just at the time Seymour was writing ‘Bring me my bow’. It is widely flouted on the Continent and the smaller UK suppliers are waking up to the fact that this is just another pointless rule that does not merit attention - see for example the reference to it at the top of Thomas Etty Esq’s catalogue.
Incidentally, Prince Charles spoke about this issue on Gardener’s Question Time last spring:
I’ve been ridiculed, says Charles - BBC
Talking of pointless rules, it’s still illegal to eat mince pies on Christmas day (thanks, Cromwell!):
You can still kill a Scotsman in York, but don’t eat a mince pie at Christmas - The Guardian
The best way to counter these sorts of pointless rules is simply to ignore them since they rely on our active co-operation - which is a major theme of Seymour’s. He doesn’t, as I recall, explain the title of his book but having read it I’m certain your guess is right. The book is sadly now out of print - I bought my copy recently via Abe Books.
alf
I thought I might dig a deep hole in my garden, lay down in it and die. Anyone want to join me?
If you had said to my Dad 30 years ago that keeping any livestock or growing what you want would become illegal, he would have laughed himself silly. I grew up in London. We had rabbits, chickens and racing pigeons on the menu. The only reason we didn’t have a pig was because the garden was shared. My family was very large by todays standards, 7 children. If we had not had these supplements to our diet I don’t know how we would have coped.
My parents lived through the hardship of the war, when it suited governments to encourage every body to look after themselves. Now if we don’t do as we are told, there are punitive punishments. And we wonder why we live in a country were the general population could not find its own bum with both hands, let alone take care of themselves and their families.
Sorry, rant over.
Wow.
Here we have many similar laws, but very little enforcement, unless you are very unlucky. Or live next to a politician.
Since much of the Animal/plant health inspection service transfered to “Homeland Security” (I hate that name!) after 9/11, they have been seriously over-stretched.
Good for small farmers; not good for protection of food supply from imported pests & diseases.