Pilot details

This section contains further detail for the AOS pilot, on the following areas:

The Memorandum of Understanding (MoU)

An MoU is a written document which outlines the respective obligations of the parties in relation to a joint project. It is not a legally binding agreement but sets out the shared understanding of the parties in relation to the project, including the conditions and roles and responsibilities of each party.

Prior to the pilot launch in June, participating businesses and the government will be required to sign the AOS pilot Memorandum of Understanding (MoU), demonstrating their commitment to fulfilling the roles and responsibilities for the duration of the pilot. More information about the MoU will be shared with successful applicants prior to the pilot launch.

Roles and responsibilities during the pilot

External roles

Businesses will need to put forward two employees to act as Authorised Persons (AP) and conduct the day-to-day inspections, with one senior employee chosen to take the role of a Person Responsible (PR).

APs will need to be able to understand SPS certificates/commercial paperwork, while PRs will need to be senior enough to act and take decisions on behalf of the business.

It will not be acceptable for a single employee to take both roles. The AP must be allowed to carry out their examinations without undue pressure on or influence over their findings.

Key responsibilities are as follows:

Person responsible:

Acting as the central point of contact with the Competent Authority, with overall accountability for the organisation’s authorised operator status.
Ensuring access to the Control Point
Retaining all records within the expected timeframe and making them available
Guaranteeing availability of staff for audit checks
Planning for succession and continuity in PR and AP roles in the case of unexpected departures

Authorised person(s):

Performing examinations solely for goods for which they have been signed off as competent.
Committing to and completing relevant training.
Keeping accurate inspection records, in line with Competent Authority SOPs.
Cooperating with and addressing audit findings.

Internal roles

Defra:

Will provide policy and comms direction and governance for the programme. Governance responsibilities will include decision making regarding withdrawal and suspension from the pilot.
Will provide legal oversight of the programme.
Will also lead the collection and analysis of evidence that will be used to support a robust post-pilot evaluation. The results of this will determine whether AOS can progress to rollout in 2025.

APHA and/or Scottish Government:

Will lead in delivering the training and auditing during the pilot.
Will coordinate ongoing inspections at Control Points.
Will be the point of contact for PRs during the pilot. Correspondence during the pilot is to be handled through the AOS inbox (AOSImports@apha.gov.uk) and Scottish BCP inbox (BCPScotland@gov.scot). This includes general queries.

Conflict of Interest during the AOS pilot

Delegating physical and ID checks to commercial operators will put the interests of the business and the requirement to act impartially in competition with one another. However, there is a broad expectation that businesses understand and agree with the need to prioritise GB biosecurity above all other interests given the risks that an outbreak poses.

Nevertheless, to ensure that any conflict of interest is managed responsibly, businesses will be provided with the following documents which they will be need to comply with during the pilot:

A Code of Ethics: This will set out 8 ethical principles that all employees in the business will be expected to comply with for the duration of the Pilot.
A Conflict of Interest Internal Business Protocol: APs and PRs will sign to commit to managing conflict of interest during the pilot and will set the measures they will take to do so.

More information will be provided during the training and following selection process.

Control Point (CP) designated premises and associated customs authorisation

AO’s premises need to be designated as a CP and be customs authorised. Businesses that are not yet a designated CP who submit an EOI will only be favourably considered if they are in the later stages of being approved i.e., a final site visit undertaken or imminently planned, with enough time to enable the designation process to be completed ahead of the pilot start date.

There is flexibility in the Official Controls Regulation legislation to allow CPs to be adapted or built to the requirements of individual businesses. Infrastructure costs for designation will vary significantly depending on the volumes of consignments, the existing facilities and what standard of facility the business requires.

There are numerous designated CPs currently in GB. The full list can be found here.

Further information on CPs can be found on the Plant Health Portal.

Check out this CP leaflet which gives a step-by-step guide and more information on the requirements for obtaining CP designation.

Click here for a case study of JZ Flowers’ experience of obtaining CP designation.

Training during the AOS pilot

The AOS training programme has been designed to align strictly with, and not go beyond the requirements of International Standards for Phytosanitary Measures (ISPM) 45. Under ISPM 45 the training requirements should be equivalent to those required for the National Plant Protection Organisation (NPPO) if it were to undertake the same phytosanitary actions.

The AOS training will be delivered in two phases:

Phase One consists of six webinars and ten modules to be undertaken over a three-week period.
The AP will be assessed via a 20 multiple-choice questionnaire at the end of Phase One. An AP will have three attempts to pass the Phase One assessment. If the AP fails all three attempts at this assessment they will be withdrawn from the training programme.
An AP must pass the Phase One assessment to be eligible to move to Phase Two. APs will be required to achieve an 80% pass mark.
Phase Two will involve completion of the AOS Training Record in five weeks and to be signed off as competent in relevant section/s of the AOS Training Record. For Phase Two, the AOS Imports team and/or Scottish Government will assess the competence of the AP before signing them off as competent in the relevant commodity.

The total qualification time (TQT) for an AP is 120 hours. This is an average of 3 hours for 40 days over 8 weeks based on a standard working week (Mon – Fri). The TQT covers self-learning and guided learning. As a result, the competent authority (APHA/SG) will have delivered as part of the guided learning:

6 hours of webinars virtually in Phase One
13 hours of face-to-face training via a two-day workshop in Phase Two
5 hours of 1-2-1 support to the AP through an assigned mentor or local plant health inspector in Phase Two.

The completion of the AOS training package will enable commercial operators to be recognised as competent to perform identification and physical import checks of produce including cut flowers and foliage, plants for planting and used agricultural/forestry machinery in England, Scotland, and Wales only during the pilot.

Auditing during the pilot

The Competent Authority will implement a two-tier audit regime for businesses partaking in the pilot: 

Tier 1 audits will focus on APs to ensure they are following the relevant Standard Operating Procedures and records are being kept appropriately. As a minimum, Tier 1 audits will be undertaken monthly where plants are being inspected and every two months for sites handling only produce. The PR is responsible for ensuring an AP is available to facilitate the audit. Where a non-conformity is identified, the AP and/or PR must take steps to rectify and provide the required evidence within stipulated timescales.  
Tier 2 audits will be undertaken less frequently than Tier 1 and will have a broader scope. Tier 2 audits for plant importing businesses will take place twice over the period of the pilot, and once for plant produce importing businesses. These audits will assess whether processes are being followed in accordance with SOPs by PR(s), inspection logs are being completed correctly and training records of all APs associated to the AO are maintained. Some elements may be undertaken remotely, and PRs will be expected to provide documents in advance upon request from the auditor. Tier 2 audits will also incorporate an audit of Control Point facilities to ensure minimum requirements are being maintained. Where non-conformity is identified, the PR must take steps to rectify and provide the required evidence within stipulated timescales.

Unannounced audits may be undertaken by the Competent Authority with no prior notice made to the AO. Tier 1 and Tier 2 audits will be scheduled in advance.  

Pilot participants should also be aware that the frequency and scheduling of audits is under the full control of the Competent Authority.  

Managing non-conformity and withdrawal from the pilot

It is expected that non-conformity will be identified at Tier 1, Tier 2, and unannounced audits. Depending on the circumstances of the non-conformity, it will either be managed by those responsible for the tier of audit being undertaken by detailing corrective action and a timescale to rectify in the audit outcome or by following an escalation process. The AP and PR will be responsible for ensuring that remedial action is taken to address any non-conformities.

Businesses should be aware of the risk of withdrawal from the AOS pilot if there is evidence of critical non-conformity. If the Competent Authority detects a critical non-conformity, it will be referred to a withdrawal review panel who will consider the case and decide whether the business can remain on the pilot.

Businesses will be able to withdraw from the pilot. However, it is expected that businesses should only apply for the EOI if they are confident they can commit fully to the pilot, and that the decision to withdraw is due to exceptional or unforeseen circumstances. Businesses that do withdraw from the pilot will be asked to set out the reasons why they have decided to do so in an exit interview.

Fees and charges

Participants will not be subject to AOS fees during the pilot.  However, if the pilot is successful, there will be a cost to gaining AOS if it is decided to roll out the authorisation. It will operate at cost recovery to cover training, auditing and authorisation costs. Indicatively, we believe this will range between £6,800 and £9,800 per annum. The pilot will be used to gather data that will assist with calculating the costs for AOS.

The statutory plant health fees for documentary, identity, and physical import inspections, will continue to apply for the participants of AOS during the pilot.  These fees will be charged as they are currently.

Competent Authorities are looking into a fee structure based on cost recovery for the services being provided. This is standard Government approach that means government neither profits at the expense of consumers nor makes a loss for taxpayers to subsidise. Costs will be calculated on an accruals basis, including overheads, depreciation, and the cost of capital.

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