Deadline for mixers
What must you do to comply
with feed mixing legislation
that becomes law in 10 days
time? John Burns reports
ONLY 10 days remain before the deadline for producers to register premises as mixers of livestock feeds. Registration is done through county council trading standards departments and the deadline is Aug 31.
One county which has been particularly active in helping and encouraging farmers to register is Devon. A spokesman points out that registration costs nothing, but fines for failing to register can be high. "Continuing to mix feedstuffs when not registered can render farmers liable to a fine of up to £5000. The new controls are an important step in ensuring integrity of the food chain from plough to plate."
To clear up confusion about exactly who should register, and what the subsequent inspection will involve, Devon trading standards officer Ern Garner visited Castle Hill Barton Farm, Filleigh, run by Michael and Alan Sexon.
The Sexons have registered, but have not been inspected. Mr Garner says trading standards staff are currently concentrating on registrations and farm inspections do not have to be completed until April 2001.
As to which farms should register, the operative word is mixing, he says. But does sprinkling minerals or rolled barley on top of silage in a feeder constitute mixing? "MAFF says that does not constitute mixing. But it is advising those farmers to register anyway to make sure."
But mixing complete diets for the dairy and beef herds at Castle Hill Barton Farm meant it was clear to the Sexons that they had to register.
The EU directive behind the requirement to register aims to ensure transparency and traceability of all farm feeds, and that mixing is done correctly with ingredients free from contamination, explains Mr Garner.
This means that during a farm inspection he looks for written statements with trading names, addresses of the mixer premises and the farms served by them, who is responsible for producing mixes, who is in charge of quality control and actual feeding, and details of any advisers on ration formulation.
If the personnel involved have formal qualifications that could be noted, but theres no requirement for them – practical experience counts. Records of feed ingredients coming onto premises, including source, batch numbers, and delivery dates, should also be available. The form of records kept depends on the size and complexity of enterprises, he explains.
Mr Garner looked at the general condition of food storage buildings and hoppers, checking for sources of contamination, including vermin and birds. "We try to take a practical approach on everything. Our general principle is to make a risk assessment, and not to enforce legislation more rigorously than risks warrant," he says.
The Sexons have a purpose-built feeds store, with smooth walls and compartments for different ingredients. Minerals are clearly labelled and stored tidily on pallets in separate heaps to avoid mistakes, and to make sure the oldest batches are used first.
A bucket and scales are used to weigh out the correct amount. Some minerals are custom-made for them and details of formulation and manufacturers batch number are recorded. Their feed ingredients storage and recording is simplified by buying protein straights ready-mixed.
Their mixer wagon is fitted with weighing equipment to ensure correct proportions of all ingredients. Mr Garner examined the wagon for signs that everything was in working order and there was no stale food in the corners – which could contaminate the next batch – or bits of the machine broken off inside.
On farms with mill-and-mix equipment he will look at the same points, he says.
Mr Garner also points out that there is a requirement to take representative samples of mixed feeds and store them in case of later problems. But he is hesitant about how often they should be taken or how long they should be kept for, because national guidelines on this topic are expected soon.
Although both the Sexons are fully familiar with everything on the farm, Alan deals with records and feed orders. As members of Tescos producer club he already keeps comprehensive records which meet part of the new laws requirements. "But I just wish all the recording could be plain and simple and use the same documents without so much duplication. For instance, if we sell a bullock we have four different records to fill in."
Apart from that, Michael says that most of what is required is good farming practice. Mixing the wrong ingredients or wrong proportions would mean milk yield would go down or there might be a sick bullock and it is in the producers own interest to get it right. He reckons the principle behind the new laws is that there is someone to blame if something goes wrong.
Alan is keen to know whether mixer premises will be given registration numbers, and Mr Garner says that will happen. He has been told that supermarket livestock buyers are already asking farmers for mixer registration numbers.
But what rights of access do trading standards officers have? Mr Garner says that they can inspect at any reasonable time, and do not normally make appointments.
He also points out that where producers are mixing zootechnic products such as antibiotics, coccidiostats or growth promoters, they must be separately inspected and approved by the Royal Pharmaceutical Society of Great Britain. A fee is charged. Those premises must also be registered with trading standards, but will not be inspected by them.
"Incidentally, although copper is used a as growth promoter for pigs it is now dealt with by trading standards, not the RPSGB" adds Mr Garner. *
• Register by Aug 31.
• Enforced by trading standards.
• Farm inspection by 2001.