DAFM - Animal By-Product Controls (ABPs)

Overview of Animal By-Product Controls (ABPs)

Within DAFM, ABP controls are coordinated by VMAAT Division, Veterinary Public Health Division (VPHD), Dairy Controls and Certification Division (DCCD) and Milk and Meat Hygiene/Animal By-Products Administrative Division. A cross-agency body of the departments and agencies involved in the official controls of ABP was set up in 2007. This generally meets four times per year.

"ABP" - Animal By-products "DAFM" - Department of Agriculture, Food and the Marine
"DCCD" - Dairy Controls and Certification Division
"RVO" - Regional Veterinary Office
"VMAAT" - Veterinary Medicines, Anti-Microbial Resistance (AMR), Animal By-Products (ABP) and Transmissible Spongiform Encephalopathies (TSEs)
"VPH" - Veterinary Public Health
"VPH Ops" - Veterinary Public Health Operations

Areas of official controls as defined by Art 1(2) of Regulation (EU) 2017/625

• Article 1(2)(e) prevention and minimisation of risks to human and animal health arising from animal by-products and derived products.

Delegation of official controls

In the context of Article 28 of Regulation (EU) 2017/625, official control tasks in relation to this area are not delegated. 

DAFM shares responsibility with the Local Authority Veterinary Service (LAVS), Food Safety Authority of Ireland (FSAI), Health Service Executive (HSE) and Sea Fisheries Protection Authority (SFPA). However, DAFM are the Competent Authority (CA) with main responsibility and guide and organise controls with the other agencies involved. Within DAFM, ABP controls are coordinated by VMAAT Division, VPH Division, DCCD and Milk and Meat Hygiene/ABP Administrative Division. A cross-agency body of the departments and agencies involved in the official controls of ABP was set up in 2007. This generally meets four times per year with email and phone contacts being maintained as necessary outside of those meetings.

Official controls of ABP are carried out by the following departments or agencies:

Scope of responsibility for the official control of food

DAFM is the CA responsible for the development of policy and legislation and for the implementation of the ABP Regulations.

FSAI is the CA with overall responsibility for the enforcement of official controls regarding the removal of SRM in food establishments. This is achieved through the Service Contract mechanism with DAFM in large capacity premises, LAs for low-throughput slaughterhouses and cutting plants.

Private veterinary practitioners (PVP), working as temporary veterinary inspectors (Vis) in slaughterhouses, carry out activities such as ante- and post-mortem inspections and supervise the taking of samples by the operator for TSE testing purposes, where they perform tasks under contract to DAFM or LA.

Official Controls

Risk categorisation and frequency of official controls

VMAAT division

Following a risk assessment and risk management step, select operators centrally each year for inspection and the frequency of such inspections given the plant type and activities etc. These inspections are centrally uploaded onto an electronic platform that the RVO Senior Veterinary Inspector (SVI) has access to and are also sent to each RVO as a spreadsheet. VMAAT provides guidelines to field staff regarding the selection of premises for official control activity. Premises can also be selected locally by the RVO SVI for inspection based on risk or real time information etc. Where possible, controls are carried out without prior warning. However, this may not always be possible, particularly if the business operator’s presence is required at the inspection.

A level of risk assessment is applied to the selection of premises for official control activity. The factors taken into account include the following:

• The nature of the business operator’s activity

• The volume of activity and type of products involved

• The interval since commencement of activity

• Results of previous inspections (if any)

• Compliance record of the operator

• Legislative considerations requiring specific levels of control

• Other local knowledge

• Fraudulent activity or knowingly misrepresenting information

Dairy controls and Certification Division (DCCD)

DCCD ABP official controls are carried out on a risk basis and at an appropriate frequency. Each establishment is risk assessed on an annual basis. The outcome of this risk assessment determines the frequency of the planned audits and inspections and the frequency of sampling required. Annual sampling plans are prepared for microbiological sampling of ABP materials.

The rational for determining official control frequency is based on a scoring system that takes the following risks into account:

• Throughput/handling of ABP material

• Level of compliance with previous ABP official controls

• Reliability of food business operator’s (FBO) own ABP controls

Methods of official control

The on-going monitoring of ABP plants is carried out by VIs and technical staff in the RVO. The monitoring arrangements, including the number of inspections to be carried out at different types of plants, are set out at the beginning of each year by VMAAT Division. Each RVO SVI is provided with a list of the inspections to be carried out in his/her area.

Non-compliances in RVO-supervised plants are dealt with by a procedure, which is laid down in a document called the “Enforcement Protocol” which is available on DAFM’s intranet.

Inspections in plants supervised by VPH Ops staff are carried out in accordance with formal documented procedures. Non-compliances in VPH Ops-supervised plants are dealt with in accordance with the principles set out in Veterinary Procedure Notice.

Methods of official controls used:

• Examination of operator controls and results obtained

• Inspection of equipment, means of transport, premises

• Inspection of goods

• Inspection of cleaning and maintenance products and processes

• Controls on the hygiene conditions in the operators’ premises

• Assessment of procedures on good manufacturing practices, good hygiene practices, good farming practices and or HACCP

• Examination of documents, traceability records and other records which may be relevant to the assessment of compliance

• Interviews with operators and with their staff

• Verification of measurements taken by the operator and other test results

• Audits of operators

• Other applicable activities required to identify cases of non-compliance

The on-going monitoring of approved dairy processing plants is carried out by the Dairy Inspectorate. Official control procedures, relating to health rules concerning animal by-products not intended for human consumption are outlined in SOP No 25 of the Dairy Controls and Certification Division's procedures.

Methods of official controls used by DCCD:

• Inspection and audit controls on general processing and hygiene standards at establishments and storage plants
• Identification, collection and transport of ABP material
• Inspection of records / documentation and commercial documents
• Review of processing methods
• Inspections and audits of Food Safety Management Systems (FSMS) including HACCP and prerequisite programmes.
• Official sampling programmes to verify compliance with relevant regulations.
• Downstream controls on traceability, use and disposal of animal by-product.
• Downstream controls on the transportation of ABP.

Recording of official controls

Inspections are carried out in accordance with a formal inspection procedure involving a standardised inspection form. An electronic database is maintained centrally which lists the inspections to be carried out and their completion status.

Dairy Controls and Certification Division:

Audits and inspections are carried out using a checklist. A paper record is retained to demonstrate the performance and outcome of inspections and audits. A copy of the report is issued to the Animal By-Products Division. Test reports issued by DAFM Food Microbiology laboratory and provided to the FBO and a copy is retained on file by the local inspector.

Resources and Facilities

Staffing resources

Each RVO is assigned many different and varied tasks and so the estimation of staffing resources dedicated to ABP controls is difficult. Around 700 ABP inspections are carried out annually at ABP approved and registered operators. Many more ABP controls are carried out annually by VPH Ops and DCCD Division at plants approved under the Food Hygiene Package.

Each division assess their training needs at the start of each calendar year. Training needs are decided by (i) assessing the gap that exists in a division between the skills that exist and those that are required to fulfil their business needs during the year (ii) Team requests (iii) Individual staff member requests or training needs identified through their annual “Performance Management and Development System” return.

A Learning Needs Analysis (LNA) form is submitted by each division to the learning and development unit as an official record, stating the training required, which team members require it and the timeframe in which the division requires it to be delivered.

Not all needs may be identified when the LNA is completed initially at the start of the year, but the LNA is a dynamic request and can be added to at any time. 

Specifically, for ABPs, VMAAT provide training based on results of OCs and especially feedback from verification inspections and staff in the field. VMAAT also provide training to a Regional Approval Team of inspectors who assist local RVOs in approving very complex types of ABP plants.

Laboratory resources

The NRL for microbiology samples is located at DAFM laboratories, Backweston. VMAAT division have a contract in place with DAFM laboratories to test official control samples from the full range of ABP plants annually. VMAAT meet at least annually with the NRL to discuss the contract. Part of that contract is that the labs must inform the sampling officer and VMAAT Division immediately in the event of a positive sample being identified and all results, positive and negative, are sent to a dedicated email address where they are maintained on a database by Milk and meat Hygiene Division colleagues. The NRL approve private laboratories, see link attached above, which are obliged under their approval to notify the NRL of any positive samples identified.

DCCD have a service level agreement with the Food Microbiology laboratory in Backweston to carry out testing of ABP material sampled by DCCD staff.

IT resources

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Other resources

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Office facilities

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Regulation (EU) 2017/625 (General Obligations)

Article 5(1)(a) Effectiveness and appropriateness of official controls

Staff within each division perform checks to ensure that the official control system operates effectively. These checks may include:

• Review (both ongoing and end-of-year) of progress of the official control system. This can be obtained either directly from computer databases or, from data provided by the relevant DAFM managers. Feedback from inspectors regarding the outcome of official control activity is also taken into account
• On the spot visits by staff from DAFM to business operator premises
• Supervisory inspections by DAFM staff
• Follow-up of stakeholder feedback where relevant
• Outcome of re-performance inspections by integrated controls division
• Results of audits
• Monitoring by area management teams
• Laboratory feedback on sample numbers, quality and turnaround times
• Review of procedures and associated documents

Article 5(1)(b) Consistency in the delivery of official controls

Consistency in enforcement is achieved through training, documented procedures, and regular liaison within DAFM divisions.

VMAAT HQ VIs carry out a % of verification inspections each year, accompanying the local VI while they carry out the Official Control, and generate a verification report for each inspection verified. Targets for the frequency of verification inspections are laid down at the beginning of the year in VMAAT’s business plan. At the end of the year a summary report is prepared for each plant type outlining areas that require follow up the following year such as training, documentary updates etc.

DCCD carry out accompanied / joint on the spot official controls. The supervising officer accompanies each officer carrying out official controls including sampling.

Supervisory controls consisting of desk-based documentary checks are carried out by the regional inspector to verify that the controls, documentation and follow up actions have been completed in accordance with the SOP’s. The outcome of these controls is documented.

Article 5(1)(c) Ensuring staff performing official controls are free from conflicts of interest

Staff holding designated positions are required to complete conflict of interest forms each year so that such conflict can be managed appropriately where it arises.

Article 5(1)(d) Access to adequate laboratory capacity

VMAAT

As part of the VMAAT contract with the NRL, VMAAT provide sample number estimates for the next year based on previous year’s numbers, new plant approvals etc to allow the NRL budget resources to fulfil the requirements.

DCCD

A sampling plan is formulated annually and accounts for the food microbiology laboratory testing capacity.

Article 5(1)(e) Access to suitably qualified and experienced staff

DAFM undertakes ongoing Workforce Planning & Succession Planning to provide clarity regarding processes for managing our staff resources while facilitating continued organisational growth and positive performance across the Department. Recruitment of suitable staff is undertaken through a mix of competitions run by the Department and by the Public Appointments Service. A great deal of work goes into compiling accurate job specifications and job descriptions to use in recruiting for the wide range of specialist positions within the organisation. All competitions feature appropriately experienced interviewers.

Once in the organisation, new recruits are trained, supervised, and subjected to probationary processes. Ongoing training and development help to ensure that staff can progress through the organisation contributing at higher levels throughout their career and being a pool to draw from for future business needs.

Effective workforce planning and succession planning assists to ensure that the maintenance of a highly skilled, resilient, and adaptable workforce equipped to deal with challenges in an ever-evolving work environment.  Knowledge transfer is also key to planning for the future of the organisation and ensuring that the services we provide to internal and external customers continue to be delivered to the highest standards. Equally, encouraging the pursuit of learning and development opportunities amongst staff is central to the maintenance of quality standards, morale, and motivation.

Article 5(1)(f) Access to adequate facilities and equipment

DAFM staff are provided with the necessary consumables, equipment, PPE and workspace to safely and effectively carry out their duties.

Meat and Milk Hygiene Division provide sampling equipment, calibrated temperature probes and other specialised equipment such as breathing apparatuses to RVO and DCCD staff as requested. RVO staff also have access to other general field duty equipment in their RVOs and each RVO facility is equipped to accommodate the various duties of field inspectors.

The Information Systems Division of the DAFM is responsible for the maintenance and security of databases used by the Animal Health and Welfare Divisions. These databases include: the food business operator register, the inspection database, the imports database and the sampling results database. This division is also responsible for the provision of laptops, desktops and other IT equipment such as printers and scanners across all divisions in DAFM.

Article 5(1)(g) Ensuring staff have adequate legal powers to perform official controls

Each veterinary inspector and DCCD staff that perform ABP OCs in DAFM is an authorised officer under the ABP Regulation, S.I 187 of 2014 and has the powers of an authorised officer laid down in that Regulation.

Article 5(1)(h) Ensuring food business operators cooperate with staff performing official controls

Operators are legally obliged to assist an authorised officer in his/her duties as requested and the authorised officer has powers as laid down in S.I 187 of 2014 if the operator does not cooperate sufficiently.

Relationships, Memoranda of Understanding and Service Level Agreements with other Competent Authorities

None

Communication procedures

Internal reporting and communication channels

Veterinary reporting arrangements are outlined in Figure 3 below. The Agriculture Field Inspection & Test (AFIT) system is used increasingly for the scheduling, performance and reporting of official controls. Hard copy documents are used in areas where the AFIT system has not yet been introduced. Electronically captured data are readily available to management while data captured in hard copy format are reported to line management manually.

DAFM liaises with other divisions in DAFM as necessary. Management structures are in place to allow for collaboration between divisions centrally and at local level and a register is maintained of responsibilities to allow communication flows.

Where it is a requirement, specific (sector) reports are submitted to European Commission annually. DAFM contributes to the compilation of the MANCP annual report which summarises the control activity of the previous calendar year. The relevant data are forwarded to the FSAI for inclusion in the final report.

External communication channels

Formal:

• The Food Safety Liaison Unit (FLSU) provides for a formal communication system between DAFM and the FSAI
• DAFM divisions participate in relevant EU Commission working groups and committees as needed.

A cross-agency body of the departments and agencies involved in the official controls of ABPs was set up in 2007. These agencies include different DAFM divisions involved in ABPs, local authorities, the HSE and the Department of the Environment. It is attended by the FSAI in an observer capacity. The cross-agency group generally meets four times a year.

Informal:

DAFM maintains close working relationships with all relevant stakeholders and actors in the official control system.

Documented Procedures

Availability of documented procedures to DAFM Staff

All official control activity is described in a standard operating procedure (SOP) or procedures manual which is prepared by the division with responsibility for the particular activity. Such procedures are regularly updated. Where necessary, relevant inspection forms are also prepared by the division and provided to field staff. Relevant notices and SOPs are available to staff on the DAFM intranet (Ezone) or on edocs. Standards documents or checklists for each ABP activity type is also available on the DAFM intranet or edocs for field inspectors to use a guide during inspections. These are shared with other agencies through the Cross Agency meetings as requested/required.

Availability of documented procedures to the FSAI & Auditors

Updated documents are also shared with other agencies through the Cross Agency meetings described above as required.

Documented procedures for official controls are supplied on request to organisations involved in auditing, usually as a result of pre-audit questionnaire process.

Reviewing & updating procedure

VMAAT and DCCD review and update procedures following updated/new legislation being published and as required following feedback from operators, inspection staff, verification HQ inspectors and using any other relevant information received. Documentation is also reviewed as part of VMAAT’s and DCCD annual business plan.

Audit

Internal audit

The Veterinary Internal Audit Unit (VIAU) performs audits in the One Health, One Welfare business line that comes under the responsibility of the Chief Veterinary Officer (CVO). The legal basis of the VIAU is Article 6 of Regulation (EU) 2017/625 and the VIAU follows the details laid out in Commission Notice on a guidance document on the implementation of the provisions for the conduct of audits under Article 6 of Regulation (EU) 2017/625 of the European Parliament and of the Council (2021/C 66/02).  The VIAU’s primary role is auditing official controls and other official activities that fall within the scope of Regulation (EU) 2017/625. Oversight of VIAU activities is provided by the Audit Monitoring Group (AMG). The AMG is appointed by DAFM in accordance with the requirement of Article 6 of Regulation (EU) 2017/625 that audits shall be subject to independent scrutiny.

The VIAU produces a five-year audit programme which covers One Health, One Welfare areas in Regulation (EU) 2017/625. An annual programme is also produced annually. Audits are planned and prioritised using a risk-based methodology and taking results and plans for external audits into consideration.

External audit

DAFM is subject to external audits of official controls by DG Santé in accordance with Article 116 of Regulation (EU) 2017/625.

Contingency Planning and Mutual Assistance

Contingency plans are in place in the event of a serious outbreak of a Class A disease where extra Cat 1 processing capacity is required allowing non diseased ABPs to be exported to other member States, particularly Northern Ireland if required.

Ireland has agreed plans to mutually share staff with other countries in the case of animal health emergencies (USA, Canada, NZ, UK, Australia).

DAFM may communicate directly with a MS in relation to a List B disease, e.g., Bovine TB. Contingency plans are also in place in respect of BSE in cattle and scrapie in sheep. Divisions within DAFM have contributed to a business continuity plan outlining how critical activities may be carried out following the occurrence of unforeseen obstacles. As a minimum, in the case of an emergency in an area involving animal health or animal welfare, the Management Advisory Committee (MAC) of DAFM would coordinate the response. Contact points in the context of Regulation 1/2005 EC are used to communicate with other Member States.

Problems regarding consignments of animals or animal products are addressed with the relevant member state as the need arises.

DAFM supports the concept of mutual assistance and is ready to provide such assistance as the need arises in line with the criteria contained in Directive 89/608 EC. Feed and food safety alerts are communicated to DAFM through the FSAI (RASFF). Animal health and welfare alerts are communicated through the CVO.

For further information on any matter raised on this page, or to suggest a correction, contact mancp@fsai.ie