-By Fauzeb Kaskar, Principal Consultant, Environmental Health-
This Blog’s aim is to explain what impact Brexit has had on Port Health and Importing/ Exporting goods. I’ve tried to cover the main points, without making it too mind-boggling, trust me there’s a lot to cover, so forgive me in advance!
What is Port Health and Imported Food Control?
Port Health teams are formed by Local Authorities that would typically have an Airport or Seaport within their district and are responsible for completing Documentary Checks, Identity Checks Physical Inspection/ Examination, and Sampling of Food Imports brought into Great Britain, the Channel Islands, and the Isle of Man via Border Inspection Points (BCP) being the ‘First Point of Entry’.
The teams will typically check Aircraft and Ships for sanitation and infectious disease concerns, along with all the common Environmental Health checks to ensure the ‘Safety of the Food’ items, confirming wholesomeness and deem the foods ‘Fit for Human Consumption’ before releasing the checked goods into the internal market via logistics companies/hauliers.
These checks will ensure that all items are safe for Human and Animal consumption, safeguarding is met, and all compliance with UK / EU legislation is adhered to as well as International legislations such as CITES (Convention on International Trade in Endangered Species of Wild Fauna and Flora).
Port Health Authorities (PHA’s) are formed by Local Authorities to deal with the checking and inspecting of ‘High- Risk’ Food Imports brought into Great Britain, the Channel Islands, and the Isle of Man through various channels including Airports and Ports. They charge a fee for this statutory work (which varies depending on the consignment to be imported) and issue documentation in the form of a ‘Validated’ Common Health Entry Documents (CHED’s) confirming the necessary checks have been undertaken, and the products are safe for entry into the UK Market.
What impact has Brexit had on Imports / Exports to and from Great Britain, the Channel Islands and the Isle of Man?
There are new requirements that businesses involved with importing and exporting food products now need to fulfill to continue operating legally. A few examples of these include:
- Exports from Great Britain, Channel Islands and Isle of Man into the EU or a Third Country now require the exporter to have an EORI number (Economic Operator Identification Number). Exports to Northern Ireland will now also require an ‘XI’ EORI number. Both EORI numbers are unique numbers that identifies a trader / business with Customs officers
- Registration and use of the new Import of Products, Animals, Food and Feed system (IPAFF’s)
- Customs Declarations will need to be made out by businesses
- Health Certificates issued by the Competent Health Authority (normally APHA in the UK) may be required. Prior registration with APHA will be necessary before businesses can start exporting goods and this process can take several weeks to complete fully before goods can enter the EU / Third Countries
- Satisfactory Laboratory Sampling Results may be required for certain goods bound for export
- An Import License and Traceability compliance records / certificates may be required along with specific test result reports i.e. Histamine Levels in Swordfish / Tuna or Aflatoxin test results for some high-risk nut products to give some examples
These added requirements, due to the UK leaving the EU have led to some Councils needing to increase their focus and levels of expertise onto Port Health (some for the very first time having created new BCP from scratch. For example, Ashford BC in Kent whilst others having to grow their existing teams to deal with this added workload.
How will this impact us moving forward?
This will impact all members of the chain, from the shops bringing in goods, UK businesses that operate within Europe / Rest of the World, and Local Authorities / Port Health Authorities.
Requirements such as EORI numbers or APHA registrations, would mean potential delays and loss of produce, including financial losses associated with these losses if the new strict guidelines are not met. Businesses need to prepare themselves well if they are to continue to carry out this part of their services or face the risk of having to cease operating in these fields.
Councils will have to place much greater emphasis on this area of work and ensure that this once niche area of expertise within Environmental Health departments is advanced upon to make sure the service needs are met. Officers will have to be trained to grasp a full understanding of what is required; this can be time intensive which may burden other services and businesses due to the added service pressures.
This will be especially challenging for Councils needing to bring on board fully qualified and competent Environmental Health Officers in this field with the already challenging market and a small pool of candidates. I, fortunately, work with a number of talented Environmental Health Officer’s that have previously covered Port Health & Imported Food Control, along with a number of Officers with a keen interest in the subject area with good baseline knowledge that would take to these positions with ease. This has helped massively when supplying Councils needing to form new teams and increase the size of their existing ones.
Environmental Health has already been greatly impacted by the effects of COVID. This is due to EHO’s taking on a large proportion of the COVID response work. Environmental Health has always been a service area pulled from pillar to post to keep up with service demands and requests due to their high levels of qualifications/competencies and their ability to adapt and solve problems quickly. The switchover has occurred at a difficult time with Councils having seen reductions in Full-Time Environmental Health Officers over recent years due to retirements and a shortage of trained young professionals entering the profession.
What does an Environmental Health Officer think?
For this Blog, I really wanted to get the opinion of an expert in the industry, and after reaching out, Christopher Davis– Principal Environmental Health Practitioner/ Imported Food Control Officer who is currently working at the London Borough of Hillingdon & Heathrow Airport BCP said when asked –
“Even though Environmental Health Officers are trained at University to become just that; an Environmental Health Officer covering the full-service areas of Food Safety, Health & Safety, Environmental Protection, Public Health, and Housing; in reality the vast majority of EHO’s select a preference fairly early on in their careers within the profession and gravitate towards one of those disciplines for their entire careers. Therefore, trying to encourage a well-grounded, ‘comfortable’ employee into a brand-new Port Health function is somewhat challenging”.
He went on to say that “the training provided at Universities for Port Health functions is somewhat limited. Being a highly specialist service area with focussed, less generic work duties makes working in Port Health less appealing to some officers. The job soon becomes tedious to those highly skilled officers who do choose to transition to Port Health roles, which in turn leads to problems in staff retention for some Port Health Authorities, not to mention the lost time invented in training any new staff to enable their full authorisations in the job”.
“The requirement to inevitably have to work shift patterns at most Ports which never sleep or close their doors, disincentives those Environmental Health Officers wanting a good ‘work-life’ balance or with young families. The Brexit situation and the ever-changing rules and regulations along with the sometimes-frenetic workloads associated with busy and dynamic Ports, makes working in and recruiting to Port Health Authority very challenging indeed with the need only ever-increasing moving into the future”.
Brexit has created challenges for Local Authorities who have the responsibility for receiving goods coming into and out of the country. Along with the new and changed legislation, is the difficulty of staffing and securing the right talent with the right specialist knowledge to undertake this work.
Perhaps now that emphasis has increased in this once small specialist area, we will see more graduates showing an increased interest in this area with more work available, and a clear direction of where their career will lead to. Port Health and Imported Food Control is no longer a small area to be forgotten.
Principal Consultant, Environmental Health
Zeb joined Oyster in 2017 after a 1.5 year stint with Hays. Zeb has previous experience recruiting for a number of desks including Social Housing, M&E, and most recently Environmental Health. With over 2 years of solid experience specialising within Public Sector Environmental Health across London and the South Coast, Zeb has steadily built excellent client relationships and reputation within the Sector.