We received the following email from Euro-toques Ireland yesterday and we urge all who are involved in the small-scale, artisan production, marketing and selling of food in Ireland, to read and act on it. It’s quite lengthy, but very relevant. We can complain amongst ourselves about the nightmare of compliance, but here Euro-toques are helping us get our problems into the right place and to get action:
Euro-toques is working on a very important project to defend small Irish food producers/farmers and further the cause of traditional/artisan/local/small-scale/real – whatever you want to call it – food production in this country. We need you to help us help you.
This is relevant to you if you are a small-scale food producer or farmer, abattoir, butcher, market trader, food seller etc and relates to any difficulties encountered in terms of food safety enforcement relating to premises, production methods/tools/materials, product, on-farm/on-site sales, farmers markets, retailing, packaging, labeling etc.
As some of you may be aware at our annual Food Awards last year, we proposed the establishment of an expert ‘Safety Net’ group for small producers in trouble in relation to Food Safety/Hygiene rules and enforcement. We are working in earnest to set this up and we hope to provide emergency support for producers as well as advocacy to advance recognition of safe traditional and artisan food production practices. This concerns not only secondary artisan products, but also importantly small-scale primary agricultural production.
Of course we, like all of you, recognise the importance of food safety. But we also recognise that practices that have been carried out in food production for generations are safe, and that hygiene requirements must be proportionate to the risk. Our main aim is, on behalf of producers, to identify the least expensive way of complying with legal requirements and to have these methods recognised by the authorities. We also want to work in general on promoting a food safety culture which is better disposed toward ‘non-industrial’ food production and to contribute to educating our food safety authorities and enforcement officers towards a better understanding of artisan/traditional/small-scale production.
In order to do this, we must build an overall picture of what is currently happening in Ireland, the problems being encountered, the solutions being offered etc. We must be in a position to highlight, factually, where food safety regulation has been applied in a way that is not necessary or proportionate to the food risks in question.
Some of your own experiences, or the experiences of other producers you know, will be invaluable to us in building this picture and in identifying legal arguments against some of the things that are happening in Ireland.
We have, of course, a huge body of anecdotal evidence about incidents which have occurred with the authorities; producers who have gone out of business or almost due to the imposition of immense and unrealistic compliance costs, produce and materials destroyed or confiscated, conflicting advice given etc etc. However, we need concrete facts and real cases so that we can tackle these issues properly with the authorities and hopefully work with them to find solutions.
In order to properly compile this research, we need to record the full details of the producer and the incidents for our own file. However, we will guarantee that all facts and cases will be used in an ANONYMOUS way and your details will be kept confidential, unless we obtain your prior agreement to use them.
If you have a case/incident which you believe is relevant, please let us know about it as soon as possible. Or forward this email to any producer you know of who has run into difficulty.
In informing us of the case, please follow the guidelines below insofar as you can and provide as much factual information as possible.
We would also welcome any feedback in terms of positive experiences or ways in which you managed to reach a satisfactory compromise with the authorities, which we may be able to take lessons from in the future.
You can email your responses to me in confidence at email@example.com
We would ask that you send these to us as quickly as possible, as we need to gather this information urgently before our next meeting of the group and subsequent meeting with the FSAI. We have a legal expert on board who will work on relating your cases back to the relevant legislation and showing where EU law allows for flexibility in such cases etc.
PLEASE TAKE THE TIME TO SIT DOWN AND RESPOND TO THIS EMAIL IMMEDIATELY if you can.
We hope to get a comprehensive and timely response from producers to assist us on this very important project.
(on behalf of the Food Producer ‘Safety Net’ council members Myrtle Allen, Darina Allen, Evan Doyle, and Ruth Hegarty, in addition to our technical and legal experts).
GUIDELINES FOR YOUR RESPONSES:
Please follow these guidelines as much as you can and provide as many facts as possible. You do not need to send us any documentation, but you may if you feel it is particularly relevant. Otherwise, please just quote the name/reference for any legislation referred to in correspondence from the enforcement authority/officer.
We need to know the following detail:
1. Details of Producer What was the scale (output size) and nature of the business in question; i.e what was the product, where were inputs sourced from, what production processes were used, to whom (and how) is product sold.
2. The Problem – Please give an overview of the problem which was encountered (was it hygiene related, labelling, marketing standards, animal health, micro criteria testing etc)
3. Legal Issues – What legislation was used by regulators (DAFF officials, EHOs etc) to ground a complaint/warning/specific order/shut-down. This is important as it can assist us in identifying particular pieces of legislation which we hope to critique further.
4. Costs – what costs did the problem lead to, this can include the financial costs to the business in question (new equipment, buildings, transport etc), but also potentially costs to the actual quality of the product, the local nature of its production etc.
5. Suggested Alternative – how do you think the regulatory objective which the regulator was insisting upon can be met in a suitable and satisfactory way. How is the nature of the risk ‘over-inflated’ by the regulator given the particular circumstances at hand.
6. Interaction with Regulators – how was the interaction with the regulators in question, i.e. were they constructive, unhelpful, aggressive etc. How would you assess their understanding of food safety, food production and their attitude toward risk management.
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