Memorandum submitted by the Corporation
of London (as London Port Health Authority) (F10)
1. The Corporation of London is the Port
Health Authority (PHA) for the port of London, which encompasses
the tidal Thames, the lower Medway, the former upper river London
Docks, and all the wharves and quays on the river. In particular,
it has jurisdiction over the major ports of Tilbury, Thamesport
(Isle of Grain) and Sheerness as well as London City Airport.
2. Consequently, it has responsibility for
the inspection of imported foods and monitoring of products of
animal origin (POAO) imported from third countries outside the
European Community. Tilbury, Thamesport and Sheerness are all
European Commission (EC) approved Border Inspection Posts (BIPs)
for the importation of POAO.
3. Tilbury is the largest BIP in the UK
in terms of meat and meat products, whilst Thamesport handles
foodstuffs from a wide range of countries, notably the far east.
London City Airport is not a BIP, and the difficulties that this
creates will be addressed later in this submission.
4. There are two routes through which meat
can be smuggled in via the port of London: i) via the major sea
ports and ii) via London City Airport. There is currently no evidence
to suggest that the smaller wharves and ports are being used for
the illegal importation of POAO.
5. Since the Foot and Mouth crisis, there
have been several seizures of smuggled POAO at the sea ports,
notably one of 3,500kg of Chinese hams detected at Thamesport
in a consignment of mixed foodstuffs. Illegal imports are usually
part of a large consignment of mixed foodstuffs.
6. At London City Airport there are regular
seizures from passenger baggageup to 150 a year. These
range from a few kilograms to 50kg of all types of POAO including
bush meat, smoked meat and fish products. These usually originate
in West Africa, and are carried by passengers who have transited
via another European Airport. The luggage is not monitored at
airports en-route, so the only check is carried out at the final
7. Offices at the sea ports are staffed
seven days a week and manifests for all imports from third countries
are received well in advance of each vessel's arrival. This enables
controls to be exercised, such as the Veterinary Checks regime,
and detention and inspection of imported foodstuffs. Where mixed
consignments are received, or where details of the goods are insufficient,
enquiries are made and importers provide packing lists and copy
invoices which show the types of commodity contained in them.
Further checks and inspections are made as appropriate, and local
intelligence used to determine which consignments are to be subject
to a full out-turn, ie all the contents of the shipping container
removed for inspection.
8. At London City Airport, there is not
a full time presence by Port Health officials, and illegal imports
are usually detected by HM Customs or Airport Staff, who notify
the PHA. A procedure is in place, but heavy reliance is placed
on the other organisations to notify Port Health of any suspicious
packages. However, Port Health Inspectors have worked in conjunction
with HM Customs to target certain flights when necessary.
9. At the seaports, although details of
all consignments are obtained, there are considerable resource
implications to out-turn a container both for the Port and the
PHA. Whilst costs for checking legal consignments of POAO can
be recovered from the importer, it is extremely difficult to do
so for smuggled consignments. In addition, no charges can be levied
for checks on consignments of foodstuffs that do not contain POAO.
It follows that the PHA has to pay for any spot-checks and monitoring
of goods for smuggled items.
10. Whilst manifests for vessels carrying
cargo loaded in the EU are also checked for foodstuffs, little
action can be taken for consignments that have EU status. The
UK is reliant on other member states carrying out an equivalent
level of checks to detect smuggled goods, including POAO, prior
to them being allowed free movement across borders.
11. At London City Airport (and indeed at
any other ports that are not BIPs) there is inadequate cover to
check for smuggled POAO. Although HM Customs are co-operative,
they have their own priorities. Again, the London Port Health
Authority does not have the resources to provide full time cover
and cannot recover any costs.
12. The Corporation supports the Government
Action Plan, but considers that further measures could be adopted
to improve controls. These are as follows:
Prior notification of all foodstuffs
to PHAs. It is a requirement that all POAO are notified in advance
to the Authorities, but this is not the case for other foods.
As illegal POAO are frequently smuggled with other foods, it would
greatly assist in their identification if all consignments of
foodstuffs were notified in advance.
Sufficient funding for PHAs. As PHAs
cannot recover costs in their attempts to detect smuggled POAO,
they need to have sufficient resources to tackle the problem effectively.
Currently, much of their funding is provided by local ratepayers.
A total ban on personal imports of
POAO. Very few travellers abide by the legal limits for personal
imports. If there were a total ban, there could be no dispute
over any attempt to smuggle items, and there could be no misunderstanding
over the allowance.
Further work in conjunction with
other Member States to ensure that illegal imports of POAO are
detected at the first point of entry into the Community.
Legislation to include the current
provision contained in Section 20(7) of the Products of Animal
Origin (Imports and Exports) Regulations 1996 which requires the
operator of any place of import to notify the Authorities of any
POAO that has not been imported via a BIP. This would assist smaller
sea ports and airports such as London City, and ensure that operators
of enhanced remote transit sheds notify the Authorities of any
POAO found with other foodstuffs.
Powers should also be given to Port
Health Officers to examine all consignments of imported goods,
even those that do not contain foodstuffs, as this would enable
spot checks to be carried out for smuggled POAO should there be
any intelligence to suggest that it is present.
13. A meeting was convened on 24 April by
the Association of Port Health Authorities for representatives
to consider how additional resources could be deployed to assist
Port Health Authorities in detecting illegal POAO and subsequently
taking enforcement action. It was agreed that the following suggestions
should be put to DEFRA:
DEFRA should control the funding
which should be targeted at problem areas.
Teams of six qualified officers should
be based at the major sea and airports throughout the country
and should be able to be diverted to other areas if necessary.
The teams should concentrate on the
searching of food and other consignments as well as passenger
Government should enhance publicity
on this issue.
Guidance and/or a code of practice
should be issued to the teams to ensure a consistent approach.
The Corporation supports this initiative which
would allow resources to be deployed where they are required most.