ACTIVITY

Shared goals and objectives brought together experienced officers working in port health, industry, CIEH, FSA and other key stakeholders.

Awareness and collaborative work

Engagement and consultations- responses:

Informal discussions about OV and EH capacity , The topic was discussed on 8th July 2021 at CIEH Port Health Coffee and Catch up - at first exploring the option of using EH for imported foods checks, freeing up OV capacity for the export certification
Informal CIEH meetings June/July 2021May-July 2022
Informal talks about OV capacity issues, Some key concept and ideas for solution introduced to CIEH
informal discussions/meet ups Aug-Sep 2021
Capacity of qualified and competent officers, both OV and EH, was the subject of further discussion . Webinar audience indicated in a poll that they would support a campaign. A task and finish group was subsequently established, which would later become BRRG.
CIEH Port Health Coffee and Catch Up 16/09/2021
Initial meetings explored the legislative framework relating to imported food, strengths and weaknesses of the current system of official controls, opportunities and threats. Key stakeholders were identified and communication channels established.
Group formedSeptember 2021
The group has beeen named BRRG- the Brexit Regulatory Research Group. - later renamed to its current name of Border Reform and Research Group. The title outlined the key initiatives to outline our key goals and interests
BRRG- Group namedOctober 2021
Defra - NI-GB supply chain- during the weekly meeting focused on OV staffing, current situation, statistics and predicted impact on the industry. BRRG presented proposed scope of solution- gaining interest of additional stakeholders groups.
DEFRA NI-GB PresentationNov 2021
The need for a reliable set of conclusive data instigated the need to acquire reliable set of information right from thesource. Association of Port health Authorities agreed to collaborate and BRRG could approach their members to conduct the survey.
BCP preparedness surveyFeb 2022
It become clear, that BRRG doesnt clearly represent the full scope of group interest, as Brexit doesnt really include the Northern Ireland participation. Group therefore become Border Reform & Research Group- the name which currently define the group and its objectives.
BRRG Name changeApril 2022
The results of the survey were presented at Association of Port Health Authorities meeting, CIEH Port Health Coffee and Catch up and slides containing thhe results of quantitative analysis accompanied by valuable commentariees were presented to attending audiences with the ooption to review and download.
BCP preparedness survey outcomes presented March - May 2022
BRRG welcome more members to represent broader scope of expertise and stakeholders insights
BRRG expansion April 2022
BCP preparedness survey Formal report reviewed by CIEH. Admitedly- in reflection of Jacob Rees -Mogg announcement- some aspects will loose on relevance- when core area increase its significance
BCP Survey formal report May-July 2022
BRRG submitted their REUL and BTOM response. 2023 was not as rich on represenation as 2022, mainly owing to anticipated BTOM. Detailed responses on BTOM and REUL helped BRRG to collate ground base of documents which will help future narrow topic targeted responses.
Consultations and responsesREUL, BTOM
In June 2023, the FSA discussed the enduring OV capacity deficit. If not addressed, labor costs may rise and cause problems for staffing of i.e.import SPS checks and other statutory controls. The BRRG is preparing to submit the question for the September FSA Board meeting.
Work in progress FSA Board meeting - Question
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The smarter Regulation to Grow the Economy paper didn’t strike mainstream media, unlike the REUL. Interestingly, detailed reading uncovers concerning intentions and consequences, if recklessly implemented. 

Despite all the reassurances given to the general public about the retention of core principles in environmental, safety, human rights, workers’ rights, etc, more focused reading unveils that actually a very different picture is being painted behind the scenes with very little publicity. 

In effect, the paper justifies deregulation and relaxation of rules- watering down the precautionary principles in favor of prosperity and operation. 

The REUL call for evidence attracted 98 written evidence papers and many other responses. Clearly- quiet publication of the said paper is in principle in many instances removing reassurances given to the general public throughout the REUL process, where objections and substantiated written evidence were at large dismissed or (in effect) ignored. 

BRRG is preparing the response to this paper. Many of the rationales to oppose and submit inquiries about this proposal are on similar grounds to what we submitted as a part of REUL written evidence submissions. 

BRRG took the opportunity to submit our response. The focus of the content aimed to highlight and evidence the risks associated with removing EU legislation. 

BRRG documented and highlighted in relevant detail the issues related to lack of expertise, appreciation for complexities and interlinked hazards, and lack of mapping of remits, interventions, and unintended consequences.  

Anyone following closely the REUL saga could be drawn to relevant UK Parliament pages 

TOM BRRG RESPONSE  Government encouraged stakeholders to share their views and concerns related to the published BTOM (The Border Target Operating Model). Initially, the document was due to be published in the autumn of 2022 then after several significant delays- the draft was released in April 2023. The document attracted an unprecedented level of response. Unfortunately- the individual responses were not published in the public domain. It would be interesting to gain knowledge, of which departments (at what level of technical expertise) do have full visibility of the individual responses and which departments (at what level of executive powers) are provided with secondary & processed information.

The engagement period and the period available to collate the response were hindered by the delayed publication of the risk categories classification- which was the vital document for the business’s position and operational arrangement due to adoption if importing to the UK. 

The BTOM final version was announced to be published in June 2023- which is now clear to be July 2023 in a best-case scenario, The very short period between the publication of the BTOM, response collation, and application of the updated version inevitably leads to the question of how the responses were processed and the level of reflection -while progressing towards the final version of the document. 

The World Trade Organisation -extended response time  -The level of intended reflection could be also subject to further questions. Despite the stakeholder’s feedback challenging extremely short response time given to stakeholders, exacerbated by the unjustifiable delay of risk categories publication, the release of the WTO paper announcing the extension to response time was also not published and the deadline led to a lapse with only little to no publication. 

February 2023  (27/2/2023), the government released the Windsor Framework– regulating the movement of goods between GB and NI. BRG didn’t submit any official response to this policy paper, even though it become increasingly clear, that the level of operability is yet to be questioned due to lack of technical guidance and definition at a technical level. The implementation of additional labeling requirements is already identified as a demand affecting decisions about access to the market, consumer pricing, and food security as such. 

Recent FSA board meeting discussed BTOM and OV capacity at length, the Youtube can be watched here 

June FSA board meeting covered extensive discussion about persisting shortage of OVs. BRRG approached the FSA asking  about how is the workforce gap managed in relation to risk arising from lack of imported food  controls at the border. 

Achievements:

CIEH achieved support and interest from FSA and other key stakeholders. Conceptual views and goals were well received for their rational long-term benefits and logical foundations.

Collaborative work and presented facts gained industry interest. Proposed solutions would ease the pressure, cost, and timing imposed on the industry in the current form of mismanaged administrative burden

CIEH did welcome the open and proactive collaboration of Association of port health authorities on the BCP  survey and further work of BRRG.  

Further participation in consultation, cabinet reviews and communications to highlight the urgency  of managing the structure of imported food controls resourcing in sustainable futureproof way

Public presence and several featured press releases (not directly by BRRG) indirectly signposted the urgency and importance of focus on seeking the solutions. 

South East and Kent MPs interested in matters. Further open letters sent  to engage and promote awareness about urgency of situation

BCP preparedness survey quantitative sections recorded rather united views on burning issues and proposed solutions across the board with some variations. Qualitative entries delivered some excellent proposals- coming from experience, skill, knowledge, and priceless insights. 

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