The odour of garlic wafts from the shipping container after veterinary inspectors break the seal, open doors and unlock air trapped six weeks during the voyage from Thailand.
“The seal is a vital part of the inspection. If the seal was opened by the agent or the driver, that consignment would be rejected,” says Feargal Ó Cuinneagáin, one of the Department of Agriculture’s veterinary inspectors at Dublin Port’s border inspection post or BIP.
Inside the refrigerated container, or “reefer” as the inspectors call them, are 24,000kg of frozen cooked chicken, shipped to Dublin by an English-registered food company and processed by an Irish customs agent.
Food of animal origin arriving from outside the European Union, from "third countries", must be checked to minimise risk to public or animal health or anything that could hurt the economy.
There are the highly regulated sanitary and phytosanitary checks, or SPS for short – an acronym that has become known to a far wider audience thanks to Brexit. These border inspections, more so than any others, pose the biggest complications to post-Brexit trade between the Republic and the UK given the volume of food that moves at speed, unhindered and unchecked, between the two countries.
As much as 70 per cent of lorry freight driving off ferries from the UK at Irish ports is thought to be food product. Suddenly applying checks after Brexit day on March 29th has the potential to wreak havoc should the UK fail to ratify the withdrawal deal with the EU.
All consignments undergo documentary and identity checks, but some face a third check: a physical inspection. For the highest risk foods, such as poultry, milk, egg and honey, strict EU rules on food safety compel department vets to conduct physical checks on 50 per cent of these consignments.
The amount of food coming from the UK through well-established, delicately managed supermarket supply chains would create a big headache in a hard Brexit for the border inspection post at Dublin Port, Ireland's busiest.
In a no-deal scenario, it is hard to see how British-made fresh chicken or ham sandwiches or chicken curry ready meals will not being delayed, particularly when this border inspection post checks only chilled, frozen or ambient foods.
SPS inspections at Dublin Port are carried out on lift-on, lift-off, or "lo-lo" food containers. These are frozen, chilled or ambient and have spent weeks on the high seas en route to Ireland.
There are no checks carried out on the hundreds of thousands of tonnes of meat-based products arriving in the back of roll-on, roll-off, or “ro-ro” lorries from the UK because they come from within the EU.
This means changing and upscaling an entire system of intricate checks at the port. It means more checks, staff and buildings.
“That is certainly a challenge,” says Ronan Halpin, a superintending veterinary inspector at the department, of the fate of the British supermarket chicken sandwich post-Brexit. “The same rules will apply to the UK as currently apply to existing third countries.”
They call the overall process being “BIP-ed”. Brendan Gorman, one of the veterinary inspectors, carefully opens the container in case boxes have fallen. He takes the temperature inside; it’s minus 18 degrees.
The Thai chicken is packed in jumbo boxes which makes it easier to remove from a lorry. Over the piercing reverse beeps of a forklift, Ó Cuinneagáin reads out his checks and cross-checks of documents accompanying the container.
Each load comes with three pieces of documentation: a health certificate for meat products, a bill of lading for ocean transport and a document known as a “common veterinary entry documentation” or CVED. There can be others.
“We have to cross-reference everything so that it’s the same, here, here and here,” says Ó Cuinneagáin, pointing to the three separate forms.
There are two types of identity check: a seal check to ensure it is intact and that information corresponds to the health certificate. This kind of check can be done away from the BIP, which is based in a cold storage facility near the Dublin Port Tunnel entrance, away from the port’s ferry terminals.
A more intensive check requires breaking the seal, opening the container and checking that the stamps and health marks on the boxes inside identifying the country of origin match those on the documents.
Codes on the health cert and CVED are checked and double-checked on the EU’s Trade Control and Expert System (Traces), the go-to online reference database. It carries everything from the heat temperature the chicken is cooked at to a code identifying the slaughter hall and processing plant in Thailand.
“If this establishment was delisted, it wouldn’t be on Traces so it would be an illegal import then,” says Ó Cuinneagáin.
The EU arm that audits health and food will have to examine UK plants for food standards and processes
After Brexit British abattoirs and food processing plants from where animal products are dispatched must be listed as an EU-approved establishment by the EU. This means “DG Sante” staff in Co Meath – the EU arm that audits health and food – will have to examine UK plants for food standards and processes.
“They might be taking a lot of short trips to the UK,” says Paul Rafter, one of the veterinary inspectors BIP-ing the Thai chicken.
Getting the documents correct is crucial. In 2017, the department rejected non-EU animal food imports in 67 per cent of cases because the documents did not comply. The department as part of its Brexit preparedness campaign is pushing this message to businesses importing food from the UK. The BIP must be notified of consignments at least 24 hours in advance.
“We are really trying to drum home that documentation is a really important piece: ‘don’t fall at the first hurdle, get your documentation right, get it to us in time and we can process it in the most expedient way possible’,” says Sunita Jeawon, veterinary inspector at the National Disease Control Centre.
Physical check
The BIP team take four boxes of chicken out of different parts of the container.
“If there is something dodgy with a consignment, you are going to have all the good stuff to the front. That’s why we take off multiples boxes,” says Ó Cuinneagáin.
They check to ensure there is no defrosting or wetness on the boxes or no fetid smells that would raise suspicions. The best before date (2020 for this chicken), health marker, lot numbers and batch numbers are all checked.
The frozen chicken, cooked in a tikka sauce, comes in 10kg bags which are weighed and checked.
In about 0.4 per cent of containers, products are sampled by sending them off to a lab to be tested for contaminants
The BIP opens about four containers a day for physical checks. Food from Brazil, China and India undergo more frequent and more intensive checks because of the risks associated with food from those countries.
In about 0.4 per cent of containers, products are sampled by sending them off to a lab to be tested for contaminants, the level of antibiotics and the like. About 200 samples a year are tested at this BIP. If it is a random sampling, the product is released; if it is risk based, the food is held at the port until tested.
To cope with future “third country” trade with the UK, the Government has applied to make Rosslare the country’s fourth BIP along with Dublin Port, Dublin Airport and Shannon Airport.
At Dublin Port, stalling of the EU-UK withdrawal deal at Westminster has forced the State to lease a 13,000sq ft warehouse on a five-acre site closer to the ferry terminals for SPS checks in a no-deal Brexit. The Government has signed off on €4 million to be spent hiring veterinary inspectors. The department is deploying 230 staff, including new recruits and temporary contractors, to cope with that crash-out scenario.
“It is very difficult to second-guess how trade will evolve because a border is being constructed between the UK and the rest of the EU and produce of all sorts will be subjected to border controls,” says Halpin.
The time, cost and transport of products from additional checks and health certificates that these products will inevitably require will affect “flows and volumes,” he adds.
It is not the same risk as a chicken coming from Brazil
A hard Brexit would be “a very difficult challenge”, says Halpin, while a soft Brexit and a “standstill” transition period to December 31st, 2020, would be easier to prepare for.
He takes some comfort from the fact that the UK has committed to apply the sweep of EU laws at least in the short term.
“It is not the same risk as a chicken coming from Brazil,” he says.
But with just 25 days until Brexit is due to happen, veterinary inspectors are unsure of even what a soft Brexit would mean for checks on British food imports.
“We don’t know until the terms of the actual withdrawal come out,” says Rafter, standing in the BIP’s chilled inspections room.
“We don’t know what the terms of a soft Brexit are going to be. That’s going to determine the volume of stuff that is going to come at us after March 29th. We just don’t know at the moment.”
