Cross Compliance: Guide to Cross Compliance in England 2015 (GCCE 2015 v1)

Inspections


To check that claimants are following cross compliance properly, we visit a certain percentage of holdings each year.

Each scheme year, there will be cross compliance inspections on:

  • 1% of claimants who claim Basic Payment Scheme (BPS)
  • 1% of claimants who have a rural development agreement.

Claimants won’t always receive advance warning of these visits and it could happen more than once in a year. If we do give advance warning, it’s likely to be less than 48 hours before the inspection.

Claimants must co-operate with the inspector, giving help and equipment to allow checks to be made safely. Claimants who refuse to allow an inspector on their land, or who don’t co-operate, could lose all of their payment(s).

When an inspector arrives they will tell the claimant what’s involved and what they need to do.

At the end of the inspection, the inspector will explain to the claimant what they’ve found. If they find anything wrong, RPA will send more information to the claimant to explain how it affects their claim(s). This will be in writing and will be sent within 3 months of the date of the inspection.

Who makes inspections?

Depending on which GAECs and SMRs apply to their holding(s), claimants may be inspected by one or more Competent Control Authority inspector(s) from:

They will use any necessary information from the Environment Agency, the Forestry Commission, Natural England, and Veterinary Medicines Directorate.

There is more information below about what each organisation will look for when they inspect a holding.

More information can also be found in the ‘Verifiable Standards’ on the ‘cross compliance: inspections’ page on www.gov.uk.

Rural Payments Agency (RPA)

Inspecting land and facilities

The inspector will make a full physical inspection of the land – taking measurements where appropriate.

Food and/or feed producers, and – as in the majority of cases – claimants who give feed to food-producing animals, will be asked to show the inspector all storage areas for food, biocides and plant protection products (where these apply).

This is to make sure that:

  • the claimant has taken adequate measures to prevent food and feed contamination
  • the claimant is following food and feed hygiene rules.

The inspector will also, where necessary, check that the claimant is following the correct processes; for example, withdrawing food and feed that has not met safety rules from the market.

Inspecting users of plant protection products (PPPs)

The inspector will check that:

  • any plant protection products (PPPs) are authorised
  • there is a permit for any parallel-traded products
  • all PPPs are used in accordance with the conditions on the label.

Storage facilities will also be inspected, to make sure that the claimant is complying with the storage requirements on the product label.

Where necessary, the inspector will also make sure that enough ‘buffer zones’ are in place on the holding to protect watercourses.

Inspecting livestock keepers

The inspector will ask to see all livestock housing areas, and the claimant will need to provide suitable labour and safe handling facilities. The inspection will include checks to make sure that:

  • cattle on the farm match the animals recorded on the Cattle Tracing System and that they are properly tagged and registered
  • sheep and goats are identified in line with the rules – and that the number of animals matches the annual inventory return
  • pigs are marked in line with the rules:
    • pig marking equipment is being maintained correctly
    • the number of animals matches the stocktake
  • the restricted feed rules have been met
  • the claimant is adhering to any movement restrictions or other notices
  • the claimant is aware of the requirement to tell Defra of suspected disease outbreaks.

To find out what livestock records an inspector will ask to see, read the ‘Checking records’ section below.

Inspecting dairy claimants

The inspector will make additional hygiene checks of livestock, dairy facilities and routines, and milk storage and records.

Inspecting egg producers

The inspector will make additional checks to make sure that eggs are kept hygienically.

Inspecting groundwater

The inspector will check that:

  • any hazardous substances (for example, pesticides or sheep dip) and non-hazardous pollutants are stored and used in line with codes of good practice
  • the claimant is not knowingly permitting a ‘groundwater activity’ involving hazardous substances and/or non-hazardous pollutants unless they have obtained and/or are meeting the conditions of a permit from the Environment Agency
  • the claimant is meeting the terms of any permit issued to them in the permitted application area.

Inspecting for nitrates rules

If the holding is in a Nitrate Vulnerable Zone, the inspector will check:

  • silage and slurry storage structures
  • field silage sites
  • field activities
  • any temporary field storage of solid manure.

If the holding is not in a Nitrate Vulnerable Zone, the inspector will check field activities for compliance with the no spread zones.

Inspecting water abstraction licences

The inspector will check for a water abstraction licence (where applicable) and that the claimant is meeting its conditions.

This usually involves:

  • reading the water meter
  • checking the meter calibration certificate
  • seeing where the water is taken from and where it’s used.

If a claimant needs to abstract water during the inspection and their licence has a Locally Prescribed Flow condition, the inspector will need to check the structure and may take a flow reading.

Checking records

The inspector will need to examine farm records (in digital and/or paper format), for a number of the GAECs and SMRs.

For farms in a Nitrate Vulnerable Zone, the inspector will want to see records which must include:

  • the size of the farm
  • projected livestock numbers, and nitrogen production and loading calculations
  • actual livestock numbers, and manure production and slurry storage calculations
  • organic manure-spreading risk map
  • locations of temporary field manure storage sites, and dates used
  • nitrogen spreading four-stage plan
  • field records of when and where nitrogen fertiliser is spread, and if necessary the maximum nitrogen (N max) calculation
  • records of imports/exports of livestock manures
  • documents covering new, substantially enlarged, or substantially reconstructed silos, slurry stores and field silage sites.

For animal records, the inspector will check:

  • that movement records, both on and off the holding, for cattle, pigs, sheep and goats, are up to date and that movement documents are correctly filled in and kept
  • that the annual inventory for sheep and goats and/or pigs is filled in and can be reconciled
  • that the herd register and/or flock register is filled in correctly and is up to date
  • that there are systems for tracing animal products and/or feed – for example, receipts and/ or invoices for inputs onto the farm, and products when they leave the farm
  • veterinary medicinal records.

Other records the inspector may need to examine include:

  • plant protection and biocidal products’ records of usage
  • Local Environment Risk Assessment for Pesticides (LERAP) records
  • water abstraction records
  • permits for any on-farm discharge of hazardous substances or non-hazardous pollutants and the records of materials applied to the permitted area (material, quantity and dates applied)
  • map for no spread zones.

Other documents

The inspector may also need to see other documents. For land, this may include:

  • a burning licence
  • a Certificate of Competence for using plant protection products
  • a felling licence
  • a special nature conservation order or management notice
  • English Heritage consent to carry out an operation on a scheduled monument
  • local authority permission to remove a hedgerow
  • local authority written consent regarding trees subject to a Tree Preservation Order (TPO)
  • local authority written consent to permanently or temporarily divert a visible public right of way
  • management prescriptions
  • Natural England consent or licence for operations on a Site of Special Scientific Interest (SSSI)
  • Natural England or Forestry Commission screening notice and/or remediation notice and/or consent about any Environmental Impact Assessment (EIA)
  • copies of any analyses of the nitrogen content of livestock manure, if used
  • any written advice from a FACTS-qualified adviser.

For animals, this may include:

  • Animal Movement Licensing System (AMLS) documents
  • auction slips, invoices, Central Point Recording Centre (CPRC) lists and fallen stock receipts
  • a letter of authorisation from Animal and Plant Health Agency to use restricted proteins and/or feed products containing restricted proteins
  • records of analysis and/or samples carried out on any livestock or feed
  • records of analysis and/or samples carried out for producing milk
  • records of routine and pre-movement tuberculosis (TB) tests.

Animal and Plant Health Agency (APHA)

The inspector will expect to:

  • see all animals in their normal rearing environment
  • see that any back-up system is working if animals’ health and well-being depends upon artificial ventilation; and how the alarm system works if the ventilation system fails
  • be able to examine specific animals on request
  • take as evidence, where required, any samples, carcases, photographs and/or other evidence to support both compliance and non-compliance.

Also, the inspector will:

  • inspect veterinary medicine and mortality records
  • check any other records that may support compliance with the rules
  • ask whether there has been a known or suspected outbreak of a notifiable disease (as listed under the disease control requirements) on your premises during the year.

For calves, the inspector will need to take:

  • pen and/or stall measurements
  • blood samples, if any of the calves appear anaemic on first inspection.

For pigs, the inspector will need to measure:

  • light intensity in pens from a sample of age groups present
  • pens and/or stalls from a sample of age groups present, for all fattening pigs and boars
  • pens, stalls, slat widths and/or slat openings.

Animal and Plant Health Agency also carry out inspection of restricted substances on behalf of the Veterinary Medicines Directorate . In these cases, the inspector will:

  • inspect a sample of animals for signs of the use of banned substances, such as growth promoters
  • select one or more suitable animals and carry out sampling of blood and/or urine; or send samples of animal feed or bulk milk for laboratory analysis
  • inspect medicines stores and medicines records, including invoices about the purchase of medicines.
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