ANNEX 1 Principles
Principle 1
Preserving public safety and maintaining confidence both nationally and internationally in UK food production
- Government funded research alongside industry funded control measures is required to reduce the levels of zoonotic infections.
- Must be driven by good science.
- Replace the word 'public' with 'food'.
- Separate this principle out to provide greater clarity.
Principle 2
Preserving the principles of the AHWS - especially that prevention is better than cure
- Funding for research into rapid diagnostic techniques for both endemic conditions and exotic infections is essential.
- There is a great distinction in respect of this principle between endemic and exotic diseases. For the latter responsibility in terms of prevention must lie with the authorities.
- Agreed. Possibly give this principle primacy over others.
- Strongly welcome the importance given to prevention as opposed to cure.
Principle 3
Maintaining and improving capability to deliver policies
- Both the public and industry would benefit from improved methods of diagnosis and control. The necessary skills and laboratories are essential.
- Concern whether the SVS can deliver AHW objectives.
- SVS should have a contingency fund available to them to meet the immediate cost of seizure of livestock animals.
Principle 4
Sharing responsibilities so that achievement of animal health and welfare outcomes is effective and efficient
- An appropriate balance of responsibilities between Government and industry currently exists in Scotland and feel an integral part of the decision making process.
Principle 5
Sharing costs only where the activity provides a clear benefit or service to industry, taking account of affordability, and of the impact on competitiveness
- Require continued funding for creating and providing certain surveillance tests.
- Need to establish current level of cost sharing before a fair platform can be established from which further cost sharing might take place.
- Nothing to indicate that any extra costs incurred by farmers from cost sharing will be reduced through better returns from the marketplace. There must be clear benefits from the regulatory process which reduce costs.
- Supported but it would not be just to expect industry to carry the cost of benefits that are in the wider public interests. Especially important that any cost sharing takes full account of affordability and of the impact on competitiveness.
- Need to know the types of 'service' for which it is intended to charge before can decide if cost sharing is appropriate.
Principle 6
Focus cost sharing where it is most likely to reduce disease risk
- Add to this principle 'Focus cost sharing where it is likely to reduce risk and as a consequence deliver financial benefit back to the farming business'. Must be able to show on each and every issue that the financial benefit arising outweighs the costs involved.
Principle 7
Responsibilities should be shared at least where costs are shared
- This should not exclude consideration of wider responsibility sharing.
Principle 8
Accountability for both industry and Government
- Endemic disease is not spread evenly throughout the country so there may be resistance to a levy collected from all of the industry.
- Body must have similar powers to the FSA if industry are to have sufficient responsibility to give the levels of accountability required to deliver to individual farmers.
- Accountability must entail transparency.
- The industry element of responsibility sharing must be representative of the entire industry and not be limited to specific sectoral interests.
Principle 9
The regulatory burden should be reduced and measures simplified wherever possible
Removal of some regulations may need to be supported by another form of simplified testing e.g. low cost, rapid, minimally invasive, pre-clinical tests.
- Too soft in its wording. There must be deep rooted reductions in the most difficult regulatory areas which must focus on proportionate regulatory outcomes and risk management principles not processes.
- Concept of proposals enabling regulatory intervention levels - perhaps based on risk assessment - to be recognised is a goal to be quickly achieved. More specific detail required on this principle.
- Discussions on cutting regulatory burden must not be restricted to the filed of AHW issues.
- Agree entirely. Could include more specifically the five principles of better regulation (proportionate, accountable, consistent, transparent and targeted).
Principle 10
Consistency with EC and international developments
- It is essential that the domestic approach to responsibility and cost sharing proposals - both at a UK and Scottish level - is consistent with Community plans, avoids gold-plating, recognises the existing contribution and involvement of producers and provides a platform to move forward.
Additional principles suggested
- There should be a new principle related to enforcement. All MSs should have enhanced obligation to comply with Community law in the animal health sector. A high proportion of FVO inspections should be carried out without prior notice and their reports should contain more detail.
- Additional principle is suggested to reflect the need to charge for enforcement / local authority services in exceptional circumstances where actions give rise to situations where legislative breaches have wide ranging consequences.
- Assessment of affordability should take into account the full regulatory burden faced by producers and not just those resulting from the AHW sphere. In this regard, a separate principle requiring responsibility and cost sharing to be both appropriate and affordable should be included.