Call to Pick Up the Pace on Red Tape Review

Progress on Pack essential given EU simplification agenda

Scottish Government must pick up the pace on its efforts to strip bureaucracy and red tape out of Scottish farming.

Months after well-known farming figure Brian Pack published his review into red tape, commissioned by Scottish Government, no progress has been made and there are already examples of Scottish Government departments back-sliding on some of the reports’ 61 recommendations.

At the time of its launch, NFUS stressed the importance of the Pack document to Scottish farmers and crofters, given its potential to rationalise red tape and inspection levels.

Yesterday’s statement by Cabinet Secretary Richard Lochhead that an announcement on the Pack recommendations will come in the New Year suggests that the report hasn’t yet been consigned to the shelf, as feared.  However, the Union will be looking for a much higher level of urgency and priority around the report than has been seen since its launch last August.

In the void, policy decisions are already being taken that work against some of the recommendations made by Brian Pack.  On January 1 2015, the Scottish Government plans to introduce a more aggressive penalty matrix to drive the prompt reporting of cattle movements to fit with Scotland’s three day reporting window. The changes have been rushed through in response to the criticism of EU auditors.  The more aggressive approach to be taken by Scottish officials fails to recognise that European standards allow a seven day window for reporting. This clear case of gold-plating goes against specific recommendations in the Pack report which called for a seven-day reporting period for cattle movements to be considered.

Other Pack recommendations included the creation of an independent advisory board to ensure that the plethora of regulatory bodies in Scotland are consistent and co-ordinated when it comes to rules, regulations and inspections.  The Union was particularly keen to see this watchdog developed with an appropriate degree of urgency and it hopes that its formation will form part of any New Year announcement from Scottish Government.

In a statement to NFU Scotland, Mr Pack said he understood the Union’s frustration but he remained hopeful of progress.

Speaking at the Union’s Christmas Press Briefing, President Nigel Miller said:
“There is clear potential in Brian Pack’s ‘Doing Better’ initiative to strip out red tape but for five long months, this report has been side-lined to gather dust.

“It contained 61 separate recommendations – each of which could make a difference – but it now appears that producers will have to wait until the New Year before we hear which of these Scottish Government is going to progress.  The top priority was the establishment of an overarching Advisory Board.  Given that no progress has been made on this one headline issue, Scottish Government has still to clear the first hurdle.

“Worse still, proposals emerging of the intention to rigidly enforce the number of days in which a Scottish farmer must report cattle movements is gold plating.  Scotland says three days while Europe allows seven.  

“We fully accept the importance of traceability but unless the national herd faces a heightened disease risk situation, the seven day notification period is appropriate and could be subject to enforcement. In periods of high disease risk, reporting periods could still be tightened to three days and gain the support of producers.  Data suggests that, even with some delays, more than 90 percent of the cattle movements recorded in Scotland would fit within the EU standard.

“To rigidly enforce a three day reporting requirement is a step backwards and a worrying sign of an escalating penalty culture within Scottish Government rather than a commitment to improve communication and collaboration through smarter, risk-based traceability systems.

“Progress on Pack is essential because work in Scotland to address the burden of legislation and regulation must dovetail with the simplification agenda being driven by our new Agricultural Commissioner, Phil Hogan.  We welcome the fact that some of Brian’s work is already being channelled into Brussels.  Commissioner Hogan’s commitment to addressing the legislative burden was refreshing and Scotland cannot be left behind.

“I am in total agreement with Brian’s summation that it is only the implementation of the recommendations that will improve the lot of farmers, land managers and regulators not simply the production of the report.

“Given Richard Lochhead’s statement yesterday, I hope the time for dithering is over and that the Cabinet Secretary will instruct his officials to give this report the degree of importance that it merits. It is in the interests of all that the actions and structures mapped out by Brian Pack must be brought into reality.”

The ‘Doing Better’ report author, Brian Pack added:

“I fully understand NFU Scotland’s frustration at the lack of progress in adopting the Doing Better recommendations, which have the potential to reduce bureaucracy for farmers, land managers and regulators. With the enormously increased workload for officials stemming from the implementation of the reformed CAP coming to an end, I am very hopeful that progress to implement my recommendations will follow.”

“The early establishment of an Advisory Board including independent members, which the Cabinet Secretary Richard Lochhead was very supportive of, would greatly ease the process and should be a pre-requisite to regulatory change.”   

Notes to Editors

  • The following recommendations were included in Brian Pack’s ‘Doing Better’ report on red tape:
    • We recommend that a consultation is launched to investigate changing the maximum number of days for farmers' (not Critical Control Points) notifying movements to BCMS from 3 to 7 days - 7 being the maximum permitted in the EU Directive. Consideration should be given to the ability to revert to 3 days in the case of disease outbreak. We believe that the representative trade bodies and the Scottish Government should work to ensure there is voluntary compliance by marts and abattoirs for recording movements within 3 days. If this approach fails methods for enforcing compliance should be investigated.
    • We recommend that the deadline for up-dating the on-farm-register for movements of cattle on or off the business is extended to be in line with that afforded to notifying movements to BCMS - currently 3 days with a recommendation to hold a consultation to move to 7 days - with the proviso that an up-dated register can be provided on demand in an infectious disease situation.


Contact Bob Carruth on 0131 472 4006 or Ruth McClean on 0131 472 4108

Date Published:

News Article No.: 191/14

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