What to expect from cross-compliance regulatory requirements in 2007

Calf penning rules under cross-compliance  have already caused wide-ranging discussion in the industry, but further requirements outlined in the 2007 Supplement to the Cross Compliance Handbook are well worth taking note of.

The first and potentially biggest issue which could affect livestock producers is the animal health and welfare rules in Statutory Management Requirement (SMR) 18, explains Momenta cross-compliance consultant Simon Draper.

The rules apply to all farmed animals excluding reptiles and fish, but could include horses which are used for farming activities. While all the rules are common sense and have been in operation since 2000, should there be a breach there is now potential for it to be a failure under cross-compliance.

Welfare inspections will be undertaken on behalf of the RPA by the State Veterinary Service, with 1% of livestock units due for inspection each year. Of these, 70% will be farms classified as high-risk units, 20% will be random inspections, while the remaining 10% will be targeted inspections aimed at problem farms or those where complaints have been made.


“Farmers will receive 24 to 48 hours’ notice of visits, and inspections will be targeted at a similar number of non-SFP claiming units. However, for SFP claimants inspections will not be linked to other cross-compliance checks, so some farms could be inspected for animal welfare alone,” says Mr Draper.

Animals may be assessed for their condition and in a herd there are always likely to be a few poor animals. But when a large proportion is in a poor condition, this will invite further inspections on other items of cross-compliance related to welfare such as diet and access to water, staff qualifications and quality of housing.

Animals should be inspected at least once a day on intensive systems and as frequently as required on extensive systems. Record keeping and, in particular, recording animal mortality are important. It is all too easy not to record a death of a piglet or lamb, but this recording helps animal husbandry in spotting early signs of any problems arising. It also shows animals are regularly monitored and cared for.

As well as records, some other failure points to look out for would be to ensure that sharp objects which could cause injury to animals are avoided. “While minor problems such as rusty or broken gate rails or penning are unlikley to cause a breach in themselves, should an animal be injured by such a problem it could be seen as a breach,” explains Mr Draper.


With many livestock units reliant on contractors for spray applications, many have historically paid little heed to the need for spray application records. “Historically, the Green Code has applied, but now all spray records are governed by an SMR. Inspectors will, therefore, ask to see spray records according to crops grown. Where appropriate it may be necessary to have an agronomist’s report to justify product use.”

Sprayers will also need to be in good working order and where appropriate have been inspected and certified as safe to use. “Additionally, for farmers using contractors they will need to ensure they have a copy of their contractors’ spray qualifications on file. All these requirements apply no matter how little product is applied, even where it is applied as a spot spray by knapsack sprayer. And rat poison is classed as a spray, too, so records need to be kept for this as well.”

For mixed dairy and arable farmer Paul Baker, the cross-compliance rules in the 2007 Supplement should create little problem, as he believes they all serve to back up existing legislative requiements. “We currently meet or exceed all the requirements under our dairy assurance scheme, so shouldn’t have any problems, although the calf penning issue will be one we have to tackle at some point.

“Thankfully, with a significant arable enterprise on the farm, we are well aware of the spray record requirements. But for many farmers there will be a cost-benefit issue on this and it may be better to use contractors for spray work, rather than risk falling foul of record keeping and sprayer safety requirements.”

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