March 2002
NOTHING TO DECLARE
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Volume 110/03, March 2002, pages 76-79

Concern over widespread and illegal imports of meat in to the UK and the risk to public health has emphasised the need for tighter controls. Nick Warburton focuses on Britain's largest port, Heathrow, and the challenges facing port health officers

In a shrinking world in which goods and people can travel from A to B with increasing frequency and speed, the potential for diseases such as foot and mouth and classical swine fever to be spread has greatly increased. With risks to public health posed by innocent travellers unwittingly breaking the law or by smugglers satisfying the UK's black market for exotic specialities, port health officers have focused attention on inconsistencies in current legislation.

Picture the scene: A luggage check on a coach arriving at Dover from Eastern Europe on a Friday morning results in the discovery of meat that exceeds the 1kg allowed by law. The following day, a passenger arriving at Heathrow from West Africa passes through customs with nothing to declare. Inside his suitcase is antelope meat that is being smuggled in to the UK, destined for one of London's ethnic markets where specialities such as monkey, ant eater and elephant meats are sold under the counter. Across the airport at one of the 98 remote transit sheds, located across five local authorities, port health officials from Hillingdon LBC searching through a consignment of vegetables from the Far East discover a consignment of illegally imported pork...

The scale and range of illegal animal imports passing through the UK's border inspection posts (BIPs), varies considerably nation-wide. At seaports like Felixstowe and River Tees, for instance, port health authorities have intercepted varying quantities of illegal goods, such as dried fishery products, milk products and meat products. While these infringements are a matter of concern, the volume and frequency of imports (which may have illegal consignments concealed in them) is far outstripped at the airports, which receive large quantities of perishable goods on passenger flights arriving each hour.

The scale of illegally imported animal products entering the UK is almost impossible to calculate, as no central records are kept to show how many products have been confiscated. The Department of Transport, Local Government and the Regions (DTLR) claims that in excess of 1,750kg of illegal meat was confiscated from individuals during the financial year of 2000 - 2001, but that is likely to be the "tip of the iceberg". According to a Food Standards Agency report, over 12 tonnes of undeclared products of animal origin were found at Heathrow alone, just in the transit sheds subject to Hillingdon LBC searches. As David Tyson, British Veterinary Association vice-president says, the problem is European-wide, meaning that the UK and other member states are dependent on how stringent the border checks are in every member state. Pressure to control imports will undoubtedly mount as Europe's borders shift eastwards and once Terminal Five becomes fully operational. As Mr Tyson notes, "the shorter the chain, the easier it is to check it".

Illegal meat imports find their way into the country through various channels. Individuals travelling from third countries, for instance, are permitted under an EC directive (the importation of third country animal products) to bring in up to 1kg of cooked meat in a hermetically sealed container. Many port health officers would like to see all personal imports banned on the basis that it sends out entirely the wrong message to those passengers intent on bringing in animal products. A recent National Farmer's Union survey revealed that more than half of the population in Britain was unaware about what can and can't be legally brought into the country after trips abroad.

A black market trade has also emerged, which has seen frozen and dried bush meat, smuggled through UK airports in suitcases, primarily from West African countries. The trade is widespread and targeted at airports because it is the quickest means of importing it. The problem is not unique to airports, as busy ports such as Dover have also intercepted undeclared meat, but the scale is considerably smaller. As port health officers have no powers to stop and search passengers (this lies with customs officials), much of the meat is finding its way to ethnic markets around the country.

Hillingdon LBC, the local authority responsible for Heathrow airport, works closely with customs officials to raise awareness of "risk carriers" - those travelling on airlines from countries where bush meat and other suspect meat originate. Most Association of Port Health Authority (APHA) members would like port health officers to be given greater powers to search passengers' baggage, but in Heathrow's case, such a development would require careful planning. As Shabeg Nagra, divisional environmental health officer at Hillingdon, explains, "Forty to 50 million people pass through the airport a year, so who would you target?" Mr Nagra's colleague, head of consumer protection, Kathy Sparks adds, "No one has really looked at the practicalities of how it will be resourced". Mr Nagra would like to see changes in primary legislation. "Rather than target the suitcases after they have come off the carousel, it would be better to target the airlines and do it in the baggage check or before the baggage from that flight goes on to the belts". A system of x-rays that can detect both animal and non-animal products could be employed to locate illegal imports. Such a system has been used successfully in New Zealand (BBC News webpage, 2 May 2001), but thanks to the scale of imports in the UK, a similar policy here would require a substantial investment package from Central Government.

Additionally, port health officers have no legal power to prosecute passengers should they find them. As Doug Bloomfield, assistant director of environmental services for Suffolk coastal district council responsible for Felixstowe explains, authorities rarely prosecute because it is difficult to prove intent. The usual defence is that the meat is unsolicited. Hillingdon LBC has targeted most of its resources at a far larger problem involving the smuggling of illegal meat concealed in variety of forms, for example, hidden among vegetable consignments or as whole consignments described as non-animal product.

The trade flourishes thanks to a loophole in current legislation, which allows non-animal products to enter the UK, by-passing veterinary checks. At present the importing of third country animal products is harmonised throughout the EC. In the UK, it is controlled by the Products of Animal Origin (Import and Export) Regulations 1996, requiring importers to give prior notification of the contents of their imports. Each consignment must be accompanied by appropriate documentation. The consignment has to go through border inspection posts and will only be given customs clearance once port health officers have issued a certification showing that all veterinary checks have been completed.

The same stringent measures do not apply to imports of non-animal products and considering the sheer volume of all imports entering busy ports such as Heathrow (BAA estimate it exceeds a million tonnes a year), the difficulty in locating illegal meat being smuggled in becomes clear. In the UK, the EC directive on non-animal products is exercised under the Imported Food Regulations 1997 which does allow some basic food safety requirements such as powers of inspection, sampling, detention and seizure but checks are rarely made unless a particular threat to health has been established. The pattern is similar at the UK's seaports.

Stuart Milner, chief port health officer at Tees Port Health Authority, says his authority has witnessed a variety of concealment methods, from storing illegal products at the rear of containers, to the importing of meat in vegetable stock cube boxes. He explains that although these products can be refused entry, if the products meet food safety requirements and are not unwholesome the importer, under the products of animal origin regulations, is allowed to re-export the product to the country of origin. In some cases, the consignment could, following its arrival in the exporting country, enter the UK again. Mr Milner points out that under the regulations there does not appear to be a mechanism for prosecuting importers.

At Heathrow, where the volume and frequency of imports passing through the port dwarfs that at Tees Port, Hillingdon LBC has neither the resources nor the powers to provide the same level of checks. The council's policy "targets the transit sheds where we know there are risk airlines coming in," says Mr Nagra, and this is primarily from East and West Africa and the Far East. Even so, the council has only the personal resources to check one out of every four flights each day. Hillingdon LBC is notified of about 400 consignments of non-animal product, but this is after the shipments have arrived and left the airport for the transit sheds in Hillingdon's locality. Two officers are sent out each day to the authority's 20 transit sheds to identify consignments. If the officers suspect illegal animal products in the containers, they take the consignments back to the border inspection post for a closer inspection. If illegal imports are found, they are destroyed at a cost to the council.

Hillingdon LBC is powerless to inspect the sheds in the other local authority areas but is involved in regular meetings with Slough, Spelthorne, Hounslow and Surrey councils on improving checks across the airport. Mr Nagra says that if central government provided the resources, Hillingdon LBC could arrange with the other councils to monitor the transit sheds outside its jurisdiction. As Heathrow continues to expand, such a development will become increasingly important.

Proposals put forward by the FSA last October (EHN, 26 October 2001) to increase the powers of port health officers have been welcomed by the APHA but funding remains a sticking point. One of the key issues for the APHA is for all non-animal products to be pre-notified. Such a move would allow port health authorities to recover their food inspection costs, as it would result in importers paying for the inspection of food plant origin. It would also allow port health offices to target products that posed a serious health risk. Such a move however, would require EC legislation, which according to the FSA's director of enforcement and food standards, David Statham, could take until 2003 to come about.

A more immediate development, proposed by the FSA, could be a common electronic information system for port health authorities. Sandra Westacott, principal port health officer at Southampton Port Health Authority welcomes the proposal but cautions: "it would need to be a centrally-funded and rationalised database where all information is available not only to port health authorities but also to businesses and the public".

In the meantime, the FSA has recently established a special unit, headed up by Sarah Appleby, and including a secondment from the APHA and a veterinary expert from Defra with a responsibility of putting into action the most relevant proposals. The special unit is due to report back to the FSA board in May on its progress. Fears of human and animal disease and bio-terrorism make controlling illegal imports vital. Arguably a higher media profile for port health officers will result in authorities gaining the resources and legal changes that are needed to stop illegal smuggling.