London Food Co-ordinating Groups Approvals Sub Group Minutes of

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					London Food Co-ordinating Group's Approvals Sub Group Minutes of Meeting on 6th December 2007 City of London offices, Walbrook Wharf, EC4 Present Nigel Whiteley Mark Stanbury Carole Milligan Hope Robinson Mina Mistry Yinka Fagbohunka James Smith Brian Griffiths Melvyn Hawkins Stephanie Needham Andy Bourlet Mel Bedi Linda Wheeler Keith Fowler Carol Stewart-Williams Ahmet Altan Matthew Collins Henry Katsande Sandra Edmeade-Walters Pip Broad Peter Reddell Lindsay Hewitt Apologies Sarah Page Rob Bartlett Simon Thomas Pippa Barnes Jenny Winslet 1 - Introductions NW welcomed all to the inaugural meeting of the London Food Co-ordinating Group's Approvals Sub Group. This group is the replacement of the North East London Approvals Food Liaison Sub Group, which has been meeting monthly for the last six years. Each officer introduced themselves and gave brief details of the number and type of approved establishments in their borough. Most boroughs had between one and ten establishments which were approved or requiring approval. The notable exceptions were Brent and Ealing, which had 30 and 50 such establishments respectively, and Tower Hamlets, which will shortly have another 40 such establishments within Billingsgate Fish Market. SEW (the Joint Secretary of the London Food Study Group) gave details of their next meeting, which will be held on Monday 10th December.

NW MS CM HR MM YF JS BG MH SN AB MB LW KF CSW AA MC HK SEW PBr PR LH

Hackney Barnet Islington Barking and Dagenham Brent Camden City of London Croydon Ealing Hammersmith and Fulham Havering Hillingdon Kensington and Chelsea Kingston Lambeth Lewisham Newham Redbridge Tower Hamlets Waltham Forest Wandsworth Brentwood

Chair Minute writer

SP RB ST PBa JW

Camden Enfield Haringey Merton Sutton

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2 - Approval of establishments supplying market stalls NW gave a short presentation by summarising the contentious question of whether establishments which supply market stalls are subject to approval. He did this to show the sort of work that the former Approvals Group had been involved in over the last three years. He wrote on behalf of the group to Colin Clifford of the FSA Enforcement Division, querying whether establishments which supply food of animal origin (FoAO) to other ‘establishments’ (which include stalls in separate locations) are subject to approval under Regulation 853/2004, (unless any of the exemptions applied). Colin Clifford confirmed that a market stall is an 'establishment', and also that the first establishment may be subject to approval even if it were supplying another establishment in the same ownership. However the LACORS Food Hygiene Focus Group pointed to a Remark in the EC Guidance Document on Regulation 852/2004, (in paragraph 3.5, Remark 1), made in the context of ‘Processing of primary products at the farm’, (not in the context of approvals under Regulation 853/2004). The Remark gives the scenario of cheese manufactured at a farm and sold at a local market to final consumers, and implies that the supplier is exempt from approval. This view has been incorporated into the LACORS 'Guidance on Approval' (in paragraph 2.2.3). This issue could affect large numbers of farms, homes, and other establishments which supply market stalls within the same ownership in farmers markets and street markets. Our former Approvals Group had responded to Catherine Bowles of the FSA, recommending that the FSA lobbies the European Commission for a change in their Regulations, or in their Guidance Documents, to clarify this issue. However we heard nothing from the FSA or the EC. But only last week David Lock of LACORS sent NW a copy of a letter from Sylvie Sadowski of the FSA Meat Hygiene and Veterinary Division which she had written to him on the subject 'Proposed policy on the supply of food of animal origin by the producer at markets'. In it the FSA agrees with the LACORS view, with certain provisos. Some discussion followed about farm establishments supplying stalls all around the country, some of which were large businesses providing high risk foods of animal origin, (CM). However the FSA is proposing a policy of exempting these farms. On the other hand some low risk businesses, such as those filleting fresh fish continue to be subject to approval, (e.g. many suppliers at Billingsgate Market, SEW said).

3 - Draft Aims, Scope, Objectives, Organisation and Arrangements 3.1 - Introduction NW introduced this item by explaining the informal nature of the previous Approvals Group, one of the advantages of which was an environment which was conducive to ask questions. Due to the size of this new London-wide group, comprising 33 food authorities, officers must define the Aims and Objectives of the group carefully, and keep the discussions within the Scope of the group. NW went through the draft Aims and Objectives item by item. 3.2 - Scope NW explained the scope proposed by reference to the ‘relevant law’ for approving establishments. Regulation EC 854/2004. article 4, lists what the competent authority shall include in their official
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controls: Regulations 852/2004, 853/2004, and 1774/2002 on animal by-products. This article also includes audits of residues, contaminants and prohibited substances. It does not include food standard issues such as labelling (with the exception of health marking and identification marking), or other compositional matters. 3.3 - Objectives NW explained the rationale behind the suggested objectives. These were generally agreed within the group, but there was a lot of discussion on the following matters. 3.3.1 - Assisting in inspections with officers elsewhere in London As regards the objective of giving advice and assisting in inspections, BG referred to the FSA Practice Guidance, (1.2.2), which encourages identifying a pool of officers within their liaison group with experience and qualifications in inspecting approved establishments and high risk activities. BG envisaged this working by assisting with queries by email rather than officers committing themselves to joint visits. NW asked for volunteers to nominate themselves at the next meeting to give other officers advice which should include helping new officers and those without sufficient experience. 3.3.2 - Publishing documents With respect to publishing documents on relevant websites, AB told the group that Peter Scott (Vice Chair of the LFCG) is of the opinion that the expectations of the LFCG are high, and our sub-group should operate on a more formal basis than the previous Approvals Group had done. Documents produced by the group should be posted on the LACORS website. However, NW explained that it had been extraordinarily difficult to get our first completed document posted onto the website, namely the ‘Flow diagram to determine if Approval is required’. (The reason for this was that the LACORS Food Hygiene Focus Group considered that it 'represents a decision making process which is too rigidly framed in relation to farmers markets ...' However the issue of establishments supplying farmers markets is contentious. See item 2 of these minutes). David Lock had written to NW recently inviting him to put the minutes of the Approvals Group on the Liaison Groups part of the LACORS website. Action - NW to put the minutes of the former Approvals Group on the LACORS website. NW told the group that the use of the CIEH London Region website had been agreed by the LFCG, (http://www.london.ciehnet.org/). The issue of maintenance of the site was discussed and NW said that Tay Potier (the CIEH London Regional Policy Officer) should be approached to maintain it. NW asked if there was anyone with an interest in or experience of websites in addition to ST, but there was none. Agreed - SEW to arrange with Tay Potier how to put our documents onto the CIEH London Region web-site. Some discussion ensued in respect of the status of documents posted on the website. Some including SN favoured the final version only and felt that this would meet the expectations of the LFCG (being of high quality). Others in the group including PR felt that the time delay in completing the work, that even the drafts would be useful to them. Agreed - Both the completed documents and the drafts which were reasonably acceptable should be posted onto the CIEH London Region website, but clearly separated from each other. 3.3.3 - Training There are not many training courses on approvals (other than ABC Food Safety and ABC Courses). SEW suggested that in-house training may be the way forward. It was suggested that ABC Food
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Safety be approached to provide courses, with on-site training if possible. 3.3.4 - Presentations NW suggested short presentations at the start of each meeting, with an aim to bring officers up to speed with areas already discussed and researched by the former Approvals Group. There was a general consensus that this was a good idea. CMI expressed concern about the commitment to deliver a presentation and suggested that this be kept informal to minimise the amount of work required by the presenter. AB suggested that other specialists outside the group could be invited to speak at the meetings e.g. Allan Johnson, HPA. 3.4 - Frequency of meetings The former Approvals Group met every month, and wanted to continue doing so. Expectations of the LFCG were discussed. AB thought that the bulk of the work could be undertaken by working groups, outside the main meeting which would mean that main meetings could be held less frequently. NW thought that this may be contrary to those wanting to come to the group to discuss particular queries which they had. BG suggested a bi-monthly meeting, in between the LFCG meetings. It was agreed that the matter would be considered at the next meeting, (after hearing whether ALEHM are prepared to fund the post of minute-writer). 3.5 - Officers attending meetings Whilst each borough may be represented by one officer, attendance is open to individual officers if there is a particular issue they wish to discuss, NW said. NW pointed out that some officers prefer to receive our e-mails, rather than to attend our meetings, which is quite acceptable. LL in Milton Keynes is one notable example. 3.6 - Posts within the Group 3.6.1 - Introduction NW said that he was only permitted to continue leading the Approvals Group in work time for one more week. He introduced the roles of the Co-ordinator and of other post-holders, so that others could consider whether they might be able to help with the work of the group, and volunteer to fill the posts. He explained a diagram he had drafted (and sent to all in the group) showing how the information flows within the Approvals Group, to give an idea of the how the group operates. 3.6.2 - Co-ordinators MS has volunteered to act as Joint Co-ordinator of the group, along with NW for the time being, to manage and co-ordinate it. NW will hand over this role gradually. Agreed. 3.6.3 - Minute-writer ALEHM has been approached to decide whether it is possible to have a paid minute taker as in the other five London Food Liaison and Co-ordinating Groups. A response is awaited from Keith Hill (the Co-ordinator of ALEHM). As a temporary measure, CM volunteered to act as minute taker. Agreed.

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3.6.4 - Information officers ST has volunteered to maintain the reference library of information produced by the group, jointly with NW for the time being. NW will hand over this role gradually. Agreed. 3.6.5 - Working Group leaders NW proposed some working groups which already exist informally, and gave some examples: - Guidance on How to choose a consultant in HACCP. CM briefly described how she had drafted this. - Guidance on simplified HACCP documents for small food manufacturers and producers. NW and BGr.

4 - Need for additional FSA guidance on Approvals of establishments NW told the group that the FSA were inviting views on issues relating to approval of small establishments, and on the need for additional guidance on the requirements for approval and the scope of exemptions. He was strongly in favour of this, and saw this as being the golden opportunity to send to the FSA some of the guidance the former Approvals Group had already written for small establishments. Action - NW to send a response to the FSA by 10 December.

5 - Next Meeting Thursday, 10th January 2008, 09.30 hrs, at Walbrook Wharf.

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Description: London Food Co-ordinating Groups Approvals Sub Group Minutes of