The inspection process

Under European legislation, annual cross compliance inspections must take place of:

at least 1% of farmers submitting applications to the Single Payment Scheme and other direct payments; and
at least 1% of farmers that entered into new commitments under relevant rural development schemes from 1 January 2007.

Two organisations, known as Competent Control Authorities (CCAs), are responsible for inspecting the different cross compliance areas. CCA responsibilities are as follows:

CCA	Area of Responsibility
Rural Payments Agency	SMRs 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12 GAECs 1, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18
Animal Health and Veterinary Laboratories Agency	SMRs 13, 14, 15, 16, 17, 18

Each CCA will select and carry out inspections on the farm businesses that need to meet the rules for which it has responsibility.

Inspections are selected by risk assessment which includes a random element. Cross compliance inspections are likely to be unannounced which means you may not be given any notice of a visit. If you are notified, it is likely to be less than 48 hours before the inspection.

A cross compliance inspection may be carried out by one or more inspectors and you may be inspected more than once during the year. This could be because the relevant CCA was unable to check all the rules for which it has responsibility at a single inspection or because your business has been selected for inspection by more than one CCA. The CCAs will try to co-ordinate inspections wherever possible and they will also make sure that inspections cause minimum disruption.

You must cooperate with the inspectors and provide facilities and labour to allow the necessary checks to be made safely. If you refuse to allow an inspection, obstruct an inspector, or fail to give reasonable help, you may lose all of your payments.

At the start of the inspection, the inspector will need to take time to explain what is involved. The inspector will provide a clear explanation of why they are there and explain how they will carry out the inspection. They will tell you what is needed from you and will give you an idea of how long the inspection will take. Before leaving your farm, the inspector will explain what they found during the inspection. The inspector may take as evidence, where required, photographs and/or other evidence to support both compliance and non-compliance.

The inspector will fill in a full written report detailing the results of the inspection. This is sent to RPA in its role as paying agency. RPA will assess all of the inspection findings and may carry out validation on them. RPA will then decide if your payments are to be reduced and how much they will be reduced by. You will normally only be told in writing of the cross compliance inspection results if you have not met the rules. RPA will not be able to confirm any payment reduction until it has assessed the results of all of the inspections that have taken place on your holding in the calendar year.

Inspections by the RPA Inspectorate

Physical inspection of land and facilities

There will be a full physical inspection of your land, where the inspector will cover all of your agricultural land parcels, taking measurements where appropriate to check that you are meeting the cross compliance rules including an assessment of your Soil Protection Review (SPR) 2010.

If you are a food producer or a feed producer, or you give feed to food producing animals (this will be the majority of you), the inspector will ask to see all storage areas for food, biocides and plant protection products, where these apply to your business. This is to make sure that you have taken adequate measures to prevent contaminating food and feed and to make sure that food and feed hygiene rules are being met. The inspector will also, where necessary, check that correct processes are followed, such as withdrawing food and feed from the market where the food or feed safety rules have not been met.

Physical inspection for users of plant protection products (PPPs)

The inspector will check that any plant protection products (PPPs) used are authorised products, or in the case of parallel traded products have a permit, and that they are used in accordance with the conditions on the label and that their use is recorded properly.

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

Physical inspection for livestock keepers

The inspector will ask to see all your livestock housing areas and you 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, with births, movements and deaths correctly reported and recorded; they are properly tagged and registered; passports are signed and in order;
sheep and goats are identified in line with the rules; and that when counted the number of animals matches your annual inventory return;
pigs are marked in line with rules; marking equipment is being maintained correctly; a headcount can be reconciled with the annual stocktake total;
you have met the restricted feed rules;
you are adhering to any movement restrictions or other notices; and
you are aware of the requirement to tell Defra of suspected disease outbreaks.

Physical inspection for dairy farmers

Additional hygiene checks will be done to examine the livestock, dairy facilities and routines, milk storage and records.

Physical inspection for egg producers

There are extra checks to make sure that eggs are kept hygienically.

Physical inspection for groundwater rules

The inspector will carry out the following:

checks to make sure that if you store and use hazardous substances (for example, pesticides or sheep dip) and non hazardous pollutants, you do so in line with codes of good practice;
checks to make sure that you do not knowingly permit a ‘groundwater activity’ involving hazardous substances and/or non hazardous pollutants unless you have obtained and/or are meeting the conditions of a permit from the Environment Agency; and
a physical inspection of the permitted application area to make sure that you are meeting the terms of any authorisation issued to you.

Physical inspection for sewage sludge rules

The inspector may wish to look at land that has been spread with sludge.

Physical inspection for nitrates rules

If your farm is in a Nitrate Vulnerable Zone the inspector will be inspecting:

storage structures;
field activities; and
your field solid manure storage.

If your farm is not in a Nitrate Vulnerable Zone, the inspector will check field activities to check compliance with the No spread zones (GAEC 19).

Physical Inspection for water abstraction licences

An inspector will visit your site and check that you have a licence, if you need one for your activities. Where you have an existing licence, they will check that you are meeting the conditions in your abstraction licence. To do this, they will usually need to read your water meter, check your meter calibration certificate, review your own records, see where you take the water from and where you use it.

Record checks

The inspector will need to examine your records for a number of the cross compliance standards, whether electronic and/or paper copies.

For all inspections you must produce your SPR 2010 to show that:

you have filled it in;
you have identified soil issues on your land and filled in the Soil Risk Record accordingly;
you have filled in the Farm Soil Plan confirming what soil protection measures you will be carrying out;
you have implemented the measures which you identified;
you have filled in the annual review, if it applies;
you have followed specific guidance or written direction, if these have been issued; and
you have filled in the access to waterlogged land table, if it applies.

If your farm is in a Nitrate Vulnerable Zone, the inspector will want to see your records which must include:

the size of your 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 field manure storage sites and dates used;
nitrogen spreading plan; and
field records recording when and where nitrogen fertiliser is spread, and if necessary your nitrogen max calculation.

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;
the annual inventory for sheep and goats and/or pigs is filled in and can be reconciled;
the herd register and/or flock register is filled in correctly and up to date;
systems for tracing animal products and/or feed production, for example, receipts and/or invoices of inputs on to your farm and products when they leave the farm; and
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;
systems for tracing food production, for example, receipts and/or invoices of inputs on to your farm and products when they leave the farm;
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);
sewage sludge records; and
map for GAEC 19 No spread zones.

Checks of other documents

The inspector may also need to see other documents, to check that you are meeting the cross compliance rules.

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);

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 Health and Veterinary Laboratories 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.

Inspections by Animal Health and Veterinary Laboratories Agency for animal welfare and disease control purposes

The inspector will expect to:

see all animals in their normal rearing environment;
see that your back-up system is working if your animals’ health and well-being depends upon artificial ventilation and for you to show the operation of your alarm system if the ventilation system fails;
be able to examine specific animals on request; and
take as evidence, where required, any samples, carcasses, 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; and
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.

If you keep calves, the inspector will also need to take:

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

If you keep pigs, the inspector will also 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, where required, for accommodation brought into use or reuse since 1 January 2003. Please note this will be a requirement for all accommodation from January 2013.

Inspections by Animal Health and Veterinary Laboratories Agency for the Veterinary Medicines Directorate concerning restricted substances

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, urine or animal feed or bulk milk for laboratory analysis;
inspect your medicines store and medicines records, including invoices about the purchase of medicines.

* RPA use information provided by the Veterinary Medicines Directorate and Chemicals Regulation Directorate to undertake checks on part of SMR 11. VMD also undertake checks of SMR 10.
** Natural England may carry out checks under GAEC 5 and GAEC 9.

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Page published: 30 December 2011