The role of an official veterinarian (OV) is a vital one: protecting animal and public health. OVs face daily difficulties in going about their work, plus there are further future challenges in the pipeline which may make the role even more challenging.
What is the current role of an OV?
OVs play a key role in protecting animal and public health by acting as the “eyes and ears” of the UK government. They are trained to carry out vital functions, such as:
- Testing for notifiable diseases (tuberculosis, brucellosis, etc)
- Abattoir supervision
- Export certification of live animals and animal products, including germinal products
- Import control
However, this article will focus on the role of an OV involved in the export of products of animal origin (POAO) and the challenges they face.
Much of the work since Brexit is in exports to the EU; however, there are still large volumes of goods going to Northern Ireland and the rest of the world
POAO encompasses a wide range of goods, from fresh meat, processed meats, dairy, eggs and fishery products to pet foods, laboratory products, gelatin and collagen. It also incorporates the more obscure POAOs, such as hunting trophies and even firefighting foam!
Much of the work since Brexit is in exports to the EU; however, there are still large volumes of goods going to Northern Ireland and the rest of the world, which also require certification.
What challenges do OVs face?
Any OV working daily at the coalface of export work would invariably come up with a similar list of regular niggles, especially those of incorrect paperwork, delays and inconsistency.
Paperwork
Each export health certificate (EHC) can be up to six pages long and an authorised translation into the official language of the country of entry is also needed for many EU countries. Currently, the vast majority of EHCs must be physically printed and manually annotated, signed and stamped – in a different colour to that of the printing.
Many EHCs contain complex clauses about the origin, processing and safety of the goods being certified. The OV will, therefore, need satisfactory evidence for each component of the final product, for example to show that chicken has not come from areas affected by highly pathogenic avian influenza (HPAI), that pork has been tested for Trichinella, that yoghurt has been made with pasteurised milk or that eggs have not come from an area affected by Newcastle disease or have had a certain heat treatment for a specified length of time.
A typical supermarket vehicle carrying a wide variety of mixed goods from different countries of origin can need dozens of printed EHCs to travel with it, and that is without all the other documentation
It only takes one of these documents to be missing or have incorrect information, and that product, or even the entire shipment, may not be able to be certified. This is a particular challenge for new or inexperienced exporters, who may struggle with the complexity of the documents needed.
It is also worth bearing in mind that a typical supermarket vehicle carrying a wide variety of mixed goods from different countries of origin can need dozens of printed EHCs to travel with it, and that is without all the other documentation such as catch certificates, customs and VAT paperwork, etc.
Delays
OVs are often required to witness the loading and applying of an “official seal” to a vehicle, which takes a lot of coordination with the loading warehouse, the haulier and the OV. An accident on a main road, adverse weather or staff shortages can all cause this to rapidly fall apart and need a last-minute rearrangement. Given many warehouses are chilled or even frozen environments, waiting around can be an unpleasant experience and for short-shelf-life products, these delays can be costly for the exporter.
Inconsistency
Since Brexit, the border control posts (BCPs) carrying out the entry checks to the EU have shown marked inconsistency as to what they will or will not accept for an export. This is the case even within the same EU country – on occasion, even between different staff at the same BCP – for products they have let through numerous times before with identical documentation. This can be due to something as trivial as how many millimetres a stamp is away from a deletion or whether the stamp and the signature need to be in a different colour to each other as well as to the printing.
Potential upcoming changes
Several forthcoming potential changes to the world of product exports are in the pipeline, many of which carry some uncertainty about timelines, implementation and whether they will be beneficial or detrimental.
There are more changes imminent in the field of product imports and exports, such as the Windsor framework, target operating model and e-certification
These upcoming changes involve (Gov.uk, 2023a,b):
- The Windsor Framework
- The target operating model
- E-certification
However, one thing OVs have learned is to expect the unexpected and never assume everything will run smoothly!
The Windsor Framework
The UK and EU have recently announced new rules – known as the Windsor Framework– for the movement of goods, including POAO, from Great Britain to Northern Ireland. This framework is due to be phased in starting October 2023. At its simplest, this means a “green lane” for qualifying goods remaining in NI and a “red lane” where goods destined for the EU can pass through. Those in the “red lane” will be subject to full EU controls and certification.
The flip side is that “green lane” goods will require labelling “Not for EU”, which will be a major cost for GB manufacturers and a challenge for those who do not know where the goods might end up at the time of production.
Questions regularly crop up that do not neatly fit within the scope of the framework, so although at first glance it may reduce OV workload, it is not yet clear if this will indeed be the case.
Target operating model
The UK government recently released its target operating model, or “TOM”, with the aim of creating a smooth, frictionless border. The model is based on the risk of commodity type and country of origin. The intention is to reduce the level of veterinary checks on lower-risk goods (eg those that are shelf stable, industrially processed and not containing meat). The introduction is due to be phased in from October 2023 and will impact both EU and “rest of the world” exporters as the EHC layouts and the process will change.
Given the UK currently has an effective, “open” phytosanitary border with the EU, these changes must be welcomed. However, they need to be robust enough to prevent substandard shipments from entering the UK while also keeping out diseases such as African swine fever, which is already seen in various EU countries.
The availability of veterinary-signed documents from the country of origin confirming the health status of the shipment will really help OVs who are required to certify these goods for re-export, which has been a challenge post-Brexit.
There may also be a requirement for additional BCPs to be built and staffed. But this will require suitably experienced and qualified staff to run them at a time when the veterinary sector is already facing challenges in recruitment.
Electronic certification
Electronic certification, or “e-certs”, is also in the pipeline. DEFRA is working on an export process wherein the entire process will take place online and directly link into the EU’s TRACES system to complete the import paperwork. Small-scale testing has shown e-certs to be a quick and efficient way of certifying. However, the software still lacks the ability to upload large tables of data, and it is not clear how quickly this system will be rolled out to the EU and beyond.
Commercial systems are also available for EHCs for pets and POAOs that allow the vet to complete the deletions and annotations online before printing and signing the final version.
How is the role evolving?
The role of the export OV has evolved from a ‘niche’, often part-time role to an essential position, ensuring the availability of the ‘just in time’ food chain
Since Brexit, the role of the export OV has evolved from a “niche”, often part-time role to an essential position, ensuring the availability of the “just in time” food chain. Therein, OVs are required to rapidly absorb new and complicated rules while remaining calm and having to make decisions rapidly and under pressure. This trend looks set to continue.
