The Chartered Institute of Environmental Health (CIEH) has recommended that the UK Government expand the remit of environmental health officers as part of its new import check scheme at the border. As the draft proposals for the Border Target Operating Model (BTOM) for import controls will begin implementation from October 2023, the Cabinet Office sought opinions from both industry and regulators, and CIEH made this call in their response to the consultation.
The draft BTOM proposes a new approach to sanitary and phytosanitary (SPS) controls for imports of live animals, animal products, plants, and plant products at the border. The document outlines how controls will be simplified, digitized, and delivered through the UK’s new Single Trade Window over time. Cabinet Office, Defra, and the Food Standards Agency have taken part in a series of engagement events to explain how the new system will function in practice, with the CIEH expressing concerns about the implementation timeline, risks associated with the proposed Trusted Trader approach, and a lack of clarity regarding future charging mechanisms.
CIEH raised concerns in their submission to these proposals, highlighting that it is crucial to address staffing shortages that could have a detrimental effect on food safety and supply under the new BTOM regime. The institute believes that environmental health officers can play a vital role in this, and there is an opportunity now to take advantage of the flexibility the UK has as a non-EU member state by bringing them back into the full remit of POAO checks at the border with OV colleagues.
CIEH is calling on the UK Government to amend retained EU legislation and change policy to enable sufficiently competent environmental health officers at BCPs to take on more responsibility for SPS checks. At the very least, the institute suggests the government should embark upon a pilot scheme to see how such an approach would work in practice.
One of the founding members of the CIEH Border Reform Research Group, Diana Tumova, emphasizes that a change in government policy that allows EHPs, who are already competent in conducting this work or who can be upskilled and redeployed quite readily, to support OVs conduct POAO checks at the border, could significantly address this staffing shortage and provide skilled professionals to deal with serious incidents.
In conclusion, the BTOM provides an opportunity for the Government to use the skills of Environmental Health Officers to alleviate staffing pressures at the borders. The CIEH suggests that testing these proposals in a pilot scheme will help determine how effectively the suggested changes will work in practice.
