COVID- Diary – Liam Petrie

Liam Petrie, Environmental Health Officer at Glasgow City Council who has recently qualified describes the diversity of the role of the Environmental Health Officer during the pandemic.

“What can I say? the past twelve months have been a whirlwind, from passing my professional exams last October to now, but where do I start?

I started with Glasgow City Council in the January of this year after working for Aberdeenshire Council for four years, where I completed my professional training and qualified as an Environmental Health Officer. My role lies within the Business Regulation team where I cover the West side of the City. During the initial three months in Glasgow I was able to expand my knowledge in both food and health and safety by inspecting a wide range of businesses within the City and responding to some weird and wonderful complaints.

In March, when Covid-19 arrived in Scotland everything seemed to change in a flash; routine food inspections were suspended and the “lockdown” restrictions meant that home working was now the default. Once things started to settle and we had a better idea of what was happening in the world, management asked for volunteers to help out with various Covid-19 related initiatives. Being the keen bean that I am, I was happy to volunteer and get back out there to help out as much as I could. It was also a valuable opportunity for personal development.

Due to the increasing numbers of Covid-19 cases, and associated deaths, within NHS Greater Glasgow and Clyde (NHS GG&C) area there was the potential for mortuary facilities in the region to reach capacity. Under Part 6, Regulation 87 of The Public Health Scotland Act 2008 Local Authorities have a responsibility to provide, or ensure the provision, for its area premises and facilities for the reception and temporary storage of the bodies of persons who die in the authority’s area. As a result, NHS GG&C and the Local Authorities in the area had to initiate a programme of collaborative working to develop emergency procedures in the event that additional facilities were required. The result was the creation of a temporary mortuary facility that could be used in the event that the number of fatalities continued to rise.

Environmental Health staff were tasked to carry out site visits to monitor Health and Safety and Covid-19 procedures that were in place within the facility. We were trained to ensure the structures were being maintained and to identify that caskets were being placed on the racking correctly. Fortunately, the facility was not needed and lay empty during my monitoring visits. It was an eye-opening experience and really made me realise the impact that Covid was having. It also made me realise how important and diverse the work of an Environmental Health Officer is.

In May, I was given the opportunity to volunteer as a contact tracer (CT) for NHS Test and Protect. Before the system went live there were several virtual training events. These were designed to help us utilise the NHS systems (CMS) and to allow access to the personal data required to carry out tracing calls and to follow GDPR.
During the training, I had to learn new skills and adapt to the workings of the NHS systems and get used to working with a script and Standard Operating Procedures (SOPs). But, the biggest challenge at the beginning was the actual phone calls to positive cases. I was very much used to calling complainants who had food poisoning allegations or confirmed food poisoning, but calling someone to discuss their whereabouts, who they had been in contact with and then to sometimes listen to the fear in their voices as this was all still ‘new’ and they had no true understanding of what was going to happen, or they didn’t want to get friends/family into trouble! That had to of been one of my biggest challenges so far.

Myself and five colleagues were trained up to be ‘Expert Mentors’, with responsibility to provide advice and guidance to other non-EHO contact tracers. Our job was to assist the contact tracers on calls. The non-EHO CTs were individuals from all different backgrounds, some of whom had never done anything like this before. My main function was logging into calls and listening to what the contact tracer was saying/doing, ensuring they covered all the specific pin point areas required( for example, any recent foreign travel), and to assist with any concerns the patient or the CT may have during the tracing interview. I had to ensure the CTs would remain calm if they were faced with any difficult calls, to which there were very few. As an EHO, I am very good at keeping people calm in difficult situations, and that has definitely helped me in my role as CT.

When Test and Protect was originally launched we were taking around five calls a day as it was pretty quiet, little did I know it would soon change! A s the restrictions eased and businesses re-opened across the city my role rapidly changed and I became a contact tracer and an expert mentor all in one. This involved contacting individuals who have tested positive for Covid-19 and completing a questionnaire to find out where they had been during their infectious period and identify any close contacts they may have generated. This gave me the opportunity to develop my investigative and communication skills. Often individuals refused to co-operate and provide their details as they were concerned that friends and family would get into trouble if they had been breaching the rules.

In these more challenging situations I had to use my communication skills to explain clearly the reason why this information was important in the fight against Covid-19. Once I had conveyed/explained this to the index case they felt more comfortable providing the information. My Environmental Health student training and work experience really helped with this as I have occasionally found myself in a situation of conflict whilst carrying out inspections and I have been able to use the same skills and techniques when carrying out contact tracing.

When I am not working for Test and Protect I am often tasked with following up with businesses where a known positive case has visited, to try and identify contacts in a hospitality or workplace environment. During these visits I have to carry out a dynamic assessment of the control measures that are in place and determine whether additional contacts will have occurred within the premises. Initially some businesses were reluctant to co-operate, however, by engaging with the business I was often able to turn the situation around and influence change. My knowledge of the contact tracing process really helped here as I was able to explain the implications from a different perspective.

Along with the hospitality assessments, I have recently been involved in close contact services assessments. These include hairdressers and barbers, and if needed, tattoo studios. As close contact services are high risk due to the requirement for close proximity to an individual we started an initiative to assess Covid-19 controls in these businesses. Prior to carrying out any dynamic assessments I studied the retail sector guidance to check what can and cannot be carried out while in a certain level of the tier system. Luckily, at this time Glasgow was in Level 3 and hairdressers and barbers were allowed to operate, but with additional mitigations in place.

During the assessments I looked at cleaning and disinfection, Test and Protect procedures, isolation procedure for symptomatic staff, any high risk procedures e.g. upper lip or nasal waxing and their overall knowledge of covid-19 guidance and compliance. Throughout any assessment I make reference to the 4 E approach where non-compliance is observed. The four E’s are; Engage, Explain, Encourage and Enforce. For example, if breaches have been identified, then I engage with the owner by the quickest possible means, to explain the non-compliance and encourage them to ensure compliance to prevent any form of enforcement being carried out. If after 3 of the 4 E approaches have been carried out and they still will not comply, a further visit would be carried out with two officers and potentially a police officer to ensure compliance, and that may be in the form of a Prohibition Notice under Regulation 22 the Health and Safety at Work etc. Act 1974 or a Notice of Direction under Regulation 3(1) of The Health Protection (Coronavirus, Restrictions) (Directions by Local Authorities) (Scotland) Regulations 2020. These notices would be used to either close the premise until compliance was achieved or to give direction on a specific area i.e. to prevent any high risk zone waxing being carried out. Overall, throughout the different roles, assessments, patrols, complaints and phone calls I have carried out, I can quite clearly see how diverse the role of an EHO is.

And finally, I don’t think I’m alone when I say that 2020 has not been the year I expected it to be, but I wouldn’t change it. Working as an Environmental Health Officer during a pandemic has given me the opportunity to develop my skills, experience and knowledge in a rapidly changing situation which will undoubtedly make me a better Environmental Health Officer. “

Increase to carrier bag charge

The minimum price of a single use carrier bag is set to increase from 5p to 10p.

The Scottish Parliament will be asked to approve the increase from the 1st April 2021. The carrier bag charge was first introduced in Scotland in October 2014.

Prior to the charge, 800 million single use carrier bags were issued annually in Scotland.

By 2015 this fell by 80% with the Marine Conservation Society noting in 2016 that the number of plastic carrier bags being found on Scotland’s beaches dropped by 40% two years in a row with a further drop of 42% recorded between 2018 and 2019.

In a public consultation in 2019, an overwhelming number of respondents (80%) agreed that that there should be an increase in the plastic bag charge and that charging for single use carrier bags has had a positive impact on the environment.

Additional measures to reduce single use plastic consumption include the banning of the sale of plastic stemmed cotton buds, with further steps to ban a number of single use items recently being consulted on.

Due to the ongoing COVID-19 national lockdown, the Scottish Government is also planning to bring forward an exemption for retailers from charging for single use carrier bags for certain deliveries and collections, as was done in Spring 2020.

In 2019 Scottish Retail Consortium reported that around £2.5 million had been raised for good causes from the sale of single-use carrier bags.

Environment and Climate Change Secretary Roseanna Cunningham said: 

“Thanks to the people of Scotland, the introduction of the charge has been successful in reducing the amount of single-use carrier bags in circulation. It has also made us think about the small steps we can all take to help the environment. 

“While the 5p bag charge was suitable when it was first introduced, it is important that pricing is updated to ensure that the charge continues to be a factor in making people think twice about using a single-use carrier bag.

“The Scottish Government is committed to building back a greener society so by further reducing our reliance on single use items, we are taking positive steps to limit our impact on the climate and the environment.”

Chief Executive of Keep Scotland Beautiful Barry Fisher said:

“Fewer single use carrier bags is great news for our environment. Since 2014 the single use carrier bag charge has significantly helped reduce the number of bags being given out by retailers – saving thousands of tonnes of single use plastic realising a significant net carbon saving and reducing the chances of these items becoming littered.

"However, there is still an opportunity to challenge individual behaviours and improve consumer awareness which the doubling of the charge will help do.

“We’ve been fortunate to develop positive partnerships with a range of well-known high street retailers, and a number of small individual store owners, who understand their responsibilities in helping to tackle Scotland’s environmental issues.

"The donations of their customer’s bag charge money have supported us to combat climate change, tackle litter and waste, and protect and enhance the places we care about.”

Takeaways- no indoor entry guidance published

The Scottish Government's Coronavirus (COVID-19): tourism and hospitality sector guidance has been updated with guidance for takeaways who can only operate on a no-indoor entry basis. 

From Saturday 16 January 2021 in Level 4 lockdown areas, businesses primarily concerned with the service of food and drink takeaways can only offer the service on a no-indoor entry basis. This means that customers are not permitted to enter the inside of a premises to collect their purchase and that goods will need to be dispensed in a manner that meets this requirement.

This measure is necessary to reduce the risk associated with people gathering in enclosed spaces (indoors) where the virus may spread more easily from person to person.

The measure applies to those businesses in the hospitality and food and drink sector that are primarily operating a food and drink takeaway service. That means where food and drink takeaway forms the main part of the business and is not incidental to the wider business operation.

Practical examples include the use of a service hatch, a non-internal counter such as a table across the threshold, or passed through a door. 

Brownfield Land Scotland 2021

Environment Analyst's Brownfield Intelligence Network conference Brownfield Land Scotland is returning and will be taking place virtually on 2-3 February 2021. This event will once again bring you practical solutions specific to the management of brownfield and contaminated land in Scotland in a series of 15 presentationsQ&A discussionsvirtual networking and interactive roundtable sessions.

If you are involved in the development of brownfield and contaminated land in Scotland this event is one not to miss.

Key topics to be discussed include:

  • Optimising the role of brownfield in meeting Scotland’s housing targets within changing planning and green frameworks 
  • Working towards a circular economy approach to reusing soil and waste materials
  • Spotlight on innovative remediation solutions
  • Ensuring environmental protection & governance in Scotland post-brexit
  • Improving the quality of site data & optimising its use in developing conceptual site models
  • Exploring the benefits of abandoned coal mines in delivering sustainable urban developments
  • Updated good practice guidance on mine gas risk assessment

Confirmed speakers include: Shona Glenn (Scottish Land Commission); Craig McLaren (Royal Town Planning Institute); Deryck Irving (Green Action Trust); Steve Wilson (The Environmental Protection Group Ltd); Paul Nathanail (GHD); Prof Colin T. Reid (University of Dundee); Dr Tom Henman (RSK); Will Fardon (i2 Analytical); Jeremy Crooks (The Coal Authority); Jon Aumonier (The Coal Authority); Kate Bassett (Groundsure).

Book your place here.

Food Standards Scotland has updated its COVID-19 Guidance for Food Business Operators and their Employees

Food Standards Scotland have updated its guidance for food business operators (FBOs) and their employees on 19 January to reflect the change of takeaway advice, reflecting the no-indoor entry restrictions in line with Scottish Government guidelines. There is also an updated risk assessment tool and checklist. 

Scottish Government publishes updated statutory guidance on the Control of Dogs (Scotland) Act 2010

The Scottish Government has published updated statutory guidance on the Control of Dogs (Scotland) Act 2010 ("2010 Act").

The 2010 Act came into force on 26 February 2011, and statutory guidance was issued ahead of implementation of the legislation.

The key purpose of the 2010 Act is to promote more responsible ownership of dogs and ensure that dogs which are out of control are brought and kept under control in Scotland. As we look ahead to the 10 year anniversary of the 2010 Act coming into force, the focus of the legislation continues to be on the “deed not the breed” approach in tackling irresponsible dog ownership.

The Scottish Government considers that as local authorities have had nearly a decade of experience of use in their 2010 Act powers, it is an appropriate time to issue updated guidance that reflects lived experience and practical use of the legislation.  This guidance document therefore includes examples of best practice of local authorities use of their powers.

The updated guidance has been prepared with the assistance of the Scottish Government led dog control and dangerous dogs working group.  Whose members include Police Scotland, REHIS, Society of Chief Environmental Officers, National Dog Warden Association and COSLA.

International Federation of Environmental Health’s December Newsletter

Please see here for the International Federation of Environmental Health’s December Newsletter

COVID- Diary – Evonne Bauer

Evonne Bauer, Executive Officer of Place and Community Planning, East Dunbartonshire Council is a Chartered EHO and currently Junior Vice-President of the Institute. Evonne’s contribution discusses the different aspects of local authorities’ response to this pandemic and how EHOs have been recognised as key players in the pandemic response. 

1. Describe your work role with relevance to the pandemic? 

I am Executive Officer of Place and Community Planning, at East Dunbartonshire Council, and manage a strategic portfolio covering a range of council services. My remit includes Community Protection, where the Environmental Health, Trading Standards, Licensing Enforcement and Community Safety teams lie.   A further responsibility is Community Planning which has also been a key area involved in the local authority response to the public health crisis.   

As a positive, and during the COVID pandemic, there has been excellent examples of joint working across a wide range of council teams and with our Community Planning Partners. Partner include the Health & Social Care Partnership (HSCP), Greater Glasgow & Clyde NHS Board Public Health Protection Unit, Police Scotland, Scottish Fire and Rescue and importantly the Third Sector Interface, communities and volunteer groups. 

2. What have you and your teams been doing since the pandemic started

The ‘Shielding’ work stream was the initial local authority response to the pandemic and I led in this work stream for East Dunbartonshire Council, which involved putting into place systems and processes locally, as required by Scottish Government. 

Local authorities proactively contacted and offered support to all our shielding individuals (residents identified by Health Board/ GPs as being the most clinically vulnerable groups in terms of their existing health conditions and status). Those shielding were to remain at home with the aim of minimising their risk of exposure to the virus. Government support was provided in terms of a national assistance phone line, routed to our local call handlers, and the offer included the provision of priority supermarket delivery slots and food boxes for those unable to access shops or receive support from family or friends. 

Importantly, our teams complimented this support with locally developed processes and arrangements and these support streams were further extended to identify ‘vulnerable’ members of our communities, through housing tenants, social work referrals etc. A local food distribution centre was established in a leisure centre offering delivery of food boxes to those identified ‘vulnerable’ but out with shielding categories, and also those not able to pay due to the impact of poverty or unemployment through COVID. Our local authority employees also provided regular social isolation support calls to socially isolated individuals. Across East Dunbartonshire, all support service were effective and very well received. 

Joint working with the third sector interface and local organisations like Citizens Advice Bureau, supported the many council teams involved in this response by providing telephone helplines, shopping assistance and prescription delivery services. 

As well as being part of the aforementioned activities, the Environmental Health and Trading Standards teams, worked alongside our business premises following lockdown, and during the transition to the Strategic Framework. This role is ongoing and includes providing advice and support, as well as enforcing compliance with the appropriate Regulations, and all requirements of the designated levels in hospitality, non-essential retail and close contact services etc. The most significant issues being COVID risk assessments of business operations, physical distancing, cleaning and hygiene including infection control measures.  

EHOs are also working with NHS Board Public Health partners on contact tracing work for cases and contacts. Post return of schools in mid-August, then case liaison with education colleagues on a daily basis involving contract tracing in all schools and early years establishments. Problem Assessment Groups and Incident Management Teams have also been implemented for clusters and outbreak control, as and when required. 

Currently across all local authorities then ‘Test and Protect Support’ work streams are ongoing, whereby those self-isolating locally are pro-actively contacted to ascertain any support needs. There is also assessment of financial needs including Scottish Welfare Fund and crisis grants, as appropriate, and the assessment for the Social Isolation Support grant of £500 for those unable to work and receive income because they or their child’s need to self-isolate. The criteria broadly extends only to those on benefits and universal credit. Similar to East Dunbartonshire, other local authorities have been administrating vouchers or cash payments to those families on the lowest incomes and who would normally receive free school meals/ clothing allowance while children are absent from education self-isolating due to having had close contact with a positive COVID case.

3. Highlight some current challenges? 

Following lockdown, the local authorities produced recovery plans to allow resumption of services within the limits of COVID restrictions and guidance and aligned with risk assessments ensuring employee health and safety. This has involved the gradual re-introduction of services and remits, together with the continuation of the COVID response and support services.  These issues in parallel has a significant impact on resources, and particularly when services have to operate in new and innovative ways, for example, one person per vehicle, limited and controlled access to offices/ depots, and working remotely/ from home, with reliance on less face-to- face and use of online virtual meetings to progress business.

The financial burden impacts of COVID response on all local authorities is a continuing major challenge and one that will feature heavily going forward. This is despite there being access to various grant funding to cover specific services and activities. 

In relation to Environmental Health, Food Standards Scotland have advised during the pandemic period that ministers have provided flexibilities against the Food Law Code of Practice in recognition of the continued efforts of EHOs involved in the response. However, realistically this flexibility is likely to come to end early 2021.   Further, additional duties continue around The Health Protection (Coronavirus)(Restrictions and Requirements)(Local Levels)(Scotland) Regulations 2020, as amended, and as statutory and other service functions are reintroduced, nationally this is causing significant resource pressures on local authority teams. 

Fortunately, local authorities have been provided with Scottish Government temporary grant funding until 31 March 2022, to increase Environmental Health officer resources, and in East Dunbartonshire we are recruiting Public Health COVID Compliance Technical Officers to support the EHO role in compliance checks across local businesses. 

As a challenge it would be remiss not to highlight the national impact of EU Exit from 1 January 2021, and a number of requirements that will be different particularly with regard to importing and exporting. The UK requiring its own food safety legislation and equivalency to EU legislation, and the evidence and supervision required on all food stuffs leaving for Europe as well as checks on imports coming from Europe. The work ahead with Food Standards Scotland on Border Control Posts and Export Health Certificates. The roles for Environmental Health, and for our professional colleagues in Trading Standards, cannot be underestimated. 

4. The immediate future in this pandemic period? 

In the immediate future local authorities will be supporting the Heath Board and our Health and Social Care (HSCP) partners in the roll out of the vaccination programme for COVID.  In particular, the local arrangements and infrastructure organisation around vaccine delivery in the community setting.  

The likely introduction of mass asymptomatic testing centres in local community areas will also be supported by local authority colleagues, through Public Health and Local Resilience Partnerships. Going forward, Environmental Health will be part of this team response and will continue with key public health roles in health protection such as business compliance, contact tracing and infection control.

To finish on a few positives while remaining in the depth of this pandemic. I believe the long-standing professional working relationships with Health Board’s Public Health and the CPHMs on all matters of health protection and outbreak control planning has been key to a successful local response.  

Additionally, the work of the national professional COVID Expert Working Group of EHOs and TSOs to deliver consistent and effective responses and interpretation to the legislation. 

Environmental Health Officers have both locally and nationally increased professional profile as a result of this public health crisis, and their well-developed health protection skills and knowledge are recognised as the key players at a local level and frontline in our communities responding to this pandemic to protect public health.

Revised approach to shelf-life safety guidance for chilled fresh beef, lamb and pork following UK-wide consultation

Shelf-life guidance for vacuum and modified atmosphere packed (VP/MAP) chilled fresh beef, lamb and pork with respect to non-proteolytic Clostridium botulinum has been updated across the UK.

The updated guidance now explains that the 10 day shelf- life rule no longer applies to VP/MAP chilled fresh beef, lamb and pork and that if a food business chooses to apply guidance for these foods then a 13 day maximum shelf-life may be applied.

The update follows last month’s public consultation seeking views on various options to change the previous 10-day maximum shelf-life best practice guidance for these products concluded. 

The decision was taken after an extensive programme of stakeholder engagement and evidence gathering will mean food business operators (FBOs) can set safe and appropriately validated shelf-lives for these specific products in line with their existing food safety management systems, in the same way they already do for other types of food.

Moving away from a ‘one size fits all’ system, the new approach will benefit both consumers and industry, continuing to ensure high food safety standards and reducing unnecessary food waste.

The decision has been taken based on a combination of evidence that includes expert microbiological advice, epidemiological information on the occurrence of botulism, and international data over many years on meat products.  Implemented correctly, these new guidelines will have no negative impact on food safety.

Food Standards Scotland (FSS) Head of Food Safety and Standards Policy, Garry Mournian, said:

“The UK has a robust legal framework and the food industry is responsible for ensuring food placed on the market is safe.  Food businesses will be able to follow existing industry guidance to ensure that an appropriate shelf-life is applied to these products, while support will be provided to smaller businesses who may not have this capability by setting a modified 13-day limit.

“We are confident that food businesses throughout the UK will continue to put standards and safety at the heart of everything they do, so consumers can be confident their interests come first.”

Industry representatives on a Joint Food Standards Scotland/Food Standards Agency Industry working group, who have discussed the guidance over the past six months as part of the review process, welcomed the decision.

Martin Morgan, Executive Manager for the Scottish Association of Meat Wholesalers said “This outcome will be welcomed by all our members.  The clear commitment from FSS and FSA to review these controls based on the very latest scientific evidence and expert advice is commendable and an approach we strongly endorse.”

David Lindars, co-chair of the working group and Technical Operations Director of the British Meat Processors Association, said:

“I welcome this decision, which represents modern evidence-based regulation, and has been reached thanks to excellent joined up working between industry and regulator.

“We are confident that this is a proportionate outcome that will benefit consumers and food businesses and help reduce food waste, whilst not compromising food safety.”

The review of the best practice guidance, which aims to reduce the risk of foodborne botulism, found no evidence of outbreaks related to these products globally, and included a report by an Advisory Committee on the Microbiological Safety of Food (ACMSF) subgroup.

“While larger businesses may seek to implement and validate their own shelf-lives for VP/MAP chilled fresh beef, lamb and pork using industry guidance and their own evidence, FSS recognises that small and medium sized food businesses may not have the suitable resources or expertise”.

Therefore, they will be able to use the new ACMSF recommendation for their VP/MAP chilled fresh beef, lamb and pork, should they wish to do so. This means that they can apply a shelf-life of a maximum of 13-days period for these products without further activity to demonstrate the safety in relation to C. botulinum.

This review applies only to VP/MAP chilled fresh beef, lamb and pork without added ingredients or further processing beyond cutting, packing, chilling, freezing and quick-freezing. It does not apply to any beef, lamb or pork that is subject to further processing such as mincing, cooking or mixing with any other ingredients such as herbs, spices or curing salts.

Glasgow City Council Health and Safety Prosecution

by Calum Melrose, Environmental Health Officer, Glasgow City Council.

Alfa Wholesale Limited at 111 Lancefield Street, Glasgow G3 8HZ who operate as a wholesaler of food and groceries to the catering and retailing sector were successfully prosecuted on 26th November 2020 after an employee fell more than 5 metres through a plasterboard ceiling.

The warehouseman who had been employed for less than three weeks had been involved in retrieving stock from an elevated mezzanine area. Whilst working in this area he stepped onto an adjacent unguarded plasterboard ceiling which he fell through landing on the concrete flooring below. The employee spent seven weeks in hospital after suffering bleeding to the brain and life changing injuries.

The incident occurred on 5th November 2017. Glasgow City Council (Environmental Health) as the Enforcing Authority investigated the circumstances which led to the accident. A report was submitted to the Procurator Fiscal recommending that the company responsible, Alfa Wholesale Limited, be prosecuted for breaches of the Health and Safety at Work etc. Act 1974, Management of Health and Safety at Work Regulations 1999 and the Work at Height Regulations 2005.

Alfa Wholesale Limited pled guilty at Glasgow Sheriff Court to breaching Section 2 of the Health and Safety at Work etc. Act 1974 in that they did not ensure, so far as is reasonably practicable, the health safety and welfare at work of their employee. The Sheriff imposed a fine of £120 000 reduced from £150 000 for an early plea.

The accident was entirely foreseeable. Employees regularly accessed the elevated area to retrieve stock which was stored adjacent to an unguarded fragile ceiling. Although risk assessments had been carried out, they did not identify the risk of falling through the plasterboard.

This was an entirely avoidable accident which has resulted in life- long consequences for the employee.

EU Exit- end of transition period

The UK has left the EU, and the transition period ends on 31 December 2020 which means we will also leave the Single Market and Customs Union. 

From 1 January 2021 a number of requirements will be different from an environmental health perspective mainly food safety.

Below is some information and helpful additional sources of information to help prepare for the end of the EU transition period. 

Transition of EU legislation into UK/Scottish law from 1 January 2021

Food Standards Scotland (FSS) are working with Scottish Ministers and others across the UK, to ensure that whatever happens, there will continue to be effective food and feed laws in place across Scotland. The essential elements of all the current EU law will be kept and the necessary changes will be made to reflect the fact that the UK will no longer be part of the EU.

·       Read more about food and feed law after the end of the transition period.

Importing and Exporting

From 1 January 2021 the process for importing and exporting goods to and from the EU will change.  The UK Government website has guidance which outlines action businesses may need to take:

·       Exporting live animals or animal products

·       Exporting groups of POAO to the EU

·       Guide to importing and exporting goods to the EU

Scottish Government’s EU exit food and drink sector update also has further information to help businesses prepare for the end of the transition period.

You can register to view webinars for exporters of animals and products of animal origin to the EU. Previous webinars are available on YouTube:

·       Export Health Certificates

·       Exporting Products of Animal Origin from Great Britain to the EU

·       Exporting Fish and Fishery Products for Human Consumption from Great Britain to the EU

FSS have been working to make sure we have access to new systems such as the UK’s Imports, Products, Animals, Food, and Feed System (IPAFFS) which replaces the EU TRACES system. In addition, FSS are advising Scottish Ministers on new and existing Border Control Posts (BCP’s).

Export Health Certificates 

From 1 January 2021 businesses will be an EHC to export live animals and animal products to the EU and to move live animals and animal products to Northern Ireland.

EHC’s will be required for all export consignments from Scotland to the EU which contain either Products of Animal Origin (POAO) or Composite Products.

An EHC is an official document confirming consignment information, and attesting that the consignment complies with EU health standards and regulations so that your product(s) can be successfully exported from Scotland to the EU. Without this businesses cannot trade with the EU.

Businesses can apply for EHCs for export from Scotland to the EU using the online service.

Defra has published guidance on Export Health Certification for POAO away from the premises of origin.

Health and ID marks

There will be changes to health and ID mark requirements for POAO produced in the UK and placed on the market in Great Britain and Northern Ireland or exported outside of the UK.  

·       Read FSS guidance about the changes to health and ID marks, including sizing and dimensions.

Registration and Inspection of Fishing Vessels

Legal action is required by fishing vessels owners in Scotland ahead of EU Exit to register their fishing vessels as food businesses, and be inspected by the relevant local authority to enable catch to be exported.

If vessel owners fail to meet this legal requirement by 31 December 2020, their catch will not be permitted for export to the EU from 1 January 2021.

Owners of fishing vessels who intend to export their catch, either directly or indirectly, to any EU Member State after 31 December 2020, must contact their Local Authority (LA) Environmental Health Department to register as a food business with them, and make arrangements to have your vessel/s inspected by LA officers. This letter to all fishing vessel owners in Scotland explains further.

·       Local Authority contact details

Read more about the requirements.

Scottish Government’s EU Exit seafood sector guidance page has more information on preparations for the end of the transition period.

Further advice

Please see the following links for further information. 

PrepareforBrexit.Scot – Brexit planning for businesses in Scotland- this tool helps businesses identify what they can do to prepare their company for business following the end of EU transition period.

MyGov.Scot – Information and guidance to help prepare for EU exit.

Use by or best before? New tool to support food businesses

European Food Safety Authority has developed a tool to help food business operators decide when to apply the ‘use by’ or ‘best before’ date to their products.

The use by date on food is about safety – foods can be eaten until this date but not after. The best before date, sometimes shown as BBE (best before end), is about quality and not safety. The food will be safe to eat after this date but may not be at its best.

The European Commission estimates that up to 10% of the 88 million tonnes of food waste generated annually in the EU is linked to date marking on food products.

Kostas Koutsoumanis, chair of EFSA’s Panel on Biological Hazards, said: “Clear and correct information on packaging and a better understanding and use of date marking on food by all actors can help reduce food waste in the EU, while continuing to ensure food safety. This scientific opinion represents a step forward in this direction.”

The tool is structured as a decision tree with a series of questions to be answered by the food business operators to help them decide whether a ‘use by’ or ‘best before’ date is required. Questions range from whether date marking requirements for a food category are already regulated by legislation, whether a product undergoes any treatment to eliminate hazards, whether it is handled again before packaging, its characteristics and storage conditions.

Experts also reviewed the factors that need to be considered by food business operators to set a shelf-life date – the period of time during which a food will remain safe and/or of a suitable quality for consumption while the packaging is intact and it is stored as instructed.

EFSA’s Panel on Biological Hazards will publish another opinion on this topic in 2021. It will focus on the information given to consumers on storage conditions, time limits for consumption after opening and thawing practices.