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MARTYN’S LAW: STANDARD TIER CONSULTATION

This government consultation is seeking views on the requirements imposed on Standard Tier premises under the Terrorism (Protection of Premises) Bill.

It is intended for organisations, businesses, local and public authorities, and individuals who own or operate publicly accessible premises or events that the Terrorism (Protection of Premises) Bill will potentially affect.

It seeks views from those responsible for smaller premises which would fall within the Standard Tier.

The Bill will impose requirements in relation to certain premises and events to increase their preparedness for, and protection from, a terrorist attack by requiring them to take proportionate steps, depending on the size and nature of the activities that take place at the premises.

The proposed requirements would apply to those responsible for qualifying public premises and qualifying public events. They might be individuals but, in most cases, would be a business or other organisation.

One of the conditions for premises would be that they be wholly or mainly used for a listed purpose, such as the provision of entertainment and leisure facilities to the public.

The proposals set out different requirements for:

  • Standard tier premises, which would have a capacity of 100-799 individuals.
  • Enhanced tier premises and qualifying public events, both of which have a capacity of 800 individuals or more.

It is stressed that this consultation is focused on the requirements proposed in relation to standard duty premises, which are referred to as the “Standard Tier”.

According to the document, in total it is estimated that 278,880 premises fall into the Standard Tier. These are mostly:

  • Retail and hospitality (65% of premises).
  • Places of worship (16%).
  • Schools (11%).

In terms of the operation of these premises:

  • 153,590 are operated by micro businesses/organisations (55.1%).
  • 37,450 are operated by small businesses/organisations (13.4%).
  • 28,600 are operated by medium businesses (10.3%).
  • 59,240 are operated by large businesses/organisations (21.2%).

The Standard Tier incorporates premises which have a variety of purposes, ranging from shops, community facilities or village halls to cinemas, nightclubs or theatres which may have capacity for up to 799 individuals. It is noted that those who operate these premises will have differing skills, experiences and knowledge as to how best to respond to emergencies. The Standard Tier procedures have been developed to recognise a diversity of premises and their occupants, delivering meaningful outcomes across this broad range of premises where lives could be saved in the event of an attack.

Revised approach

During pre-legislative scrutiny conducted by the Home Affairs Select Committee (HASC), some concerns were raised as to the burden associated with the Standard Tier, with particular focus on voluntary and community-run premises within scope of the published draft Bill.

Since publication of the draft Bill in May 2023, the Government has revised its approach to the Standard Tier. The revised obligations are designed to be low-to-no financial cost and low burden to put in place, whilst continuing to deliver meaningful outcomes that could save lives. The government is committed to ensuring that those responsible for complying with Standard Tier requirements premises are not over-burdened. It is felt that the proposed changes to the Standard Tier mean that the duty can apply to premises in a proportionate way, without incurring significant additional cost or time. Specific feedback is sought in this consultation to ensure the proposed requirements strike the right balance.

The purpose of this consultation is to test government’s proposals for the Standard Tier. Views of organisations and the general public are invited as to whether the revised approach:

  • Sets out the government’s requirements for the Standard Tier in a clear, understandable way.
  • Is better suited to the wide variety of organisations within the Standard Tier, to ensure that any burden is appropriate.

Summary of revised Standard Tier requirements

In summary, those responsible for Standard Tier premises must:

  •  Notify the Regulator that they are, or have become, responsible for premises within scope of the Bill (and so subject to the relevant requirements). This remains broadly in line with previous requirements.
  • Have in place procedural measures that could be expected to reduce, so far as reasonably practicable, the risk of physical harm to individuals at the premises in the event of an attack. These relate only to the procedures to be followed by people working at the premises in the event of an attack occurring or being suspected as about to occur. Details on the procedures required are set out at paragraph 22. As the procedural measures are about procedures for responding to an attack or suspected attack, it is not expected or required that physical alterations be undertaken or additional equipment purchased for Standard Tier premises.
  • In contrast to the published draft Bill, there is no requirement to complete a specified form (the ‘Standard Terrorism Evaluation’) for Standard Tier premises or ensure thatpeople working at the premises are given any specific training. However, as part of putting in place the procedural measures, workers will need to be sufficiently instructed or trained to carry them out effectively.

The consultation closes on 18 March 2024.

Martyn’s Law: standard tier consultation – GOV.UK (www.gov.uk)

DEFRA QUESTIONNAIRE: FOOD WASTE REPORTING BARRIERS, ENABLERS & CONSUMER IMPACT

Defra consulted on improved food waste reporting by large businesses in England and published a Government Response in July 2023. In November 2023, Defra announced that the new Secretary of State had decided to retake the decision, re-considering all options including mandatory measures for large businesses.

Defra is seeking additional evidence on the barriers and enablers of food waste reporting by businesses, including a further understanding of whether the potential financial costs or savings associated with measuring and reporting would impact consumers.

Defra have engaged WRAP to gather this feedback from large businesses in the industry via this questionnaire: https://forms.office.com/e/YM46mNR8Yt.

WRAP would be grateful if you could complete this for your business by Friday, 1st March (or share with a colleague if they are better placed to do so).

Your responses will be kept confidential to WRAP and Defra (and can be submitted anonymously if you prefer). The questionnaire should take no more than 10 minutes to complete (although it may take you more time to gather the required information).

At this point, WRAP are only seeking views from large businesses in England and/or Wales due to the scope of options under consideration.

Please also share this with suppliers or customers, where relevant, to contribute their views. If you have any questions, please don’t hesitate to get in touch via foodwasteroadmap@wrap.org.uk.

REMINDER: HAVE YOUR SAY ON ‘NOT FOR EU’ LABELLING REQUIREMENTS IN GB BY 15TH MARCH

As reported in last week’s newsletter, we would strongly urge members to participate in the consultation recently launched by Defra on proposals to implement ‘not for EU’ labelling on goods across GB.

The rationale for this proposal is stated as being ‘to maintain continuity of supply to Northern Ireland’ in an effort to secure ‘Northern Irelands integral place in the United Kingdom’.

In practice it will mean that, to place goods for sale on the GB market, they must be labelled as ‘not for EU’. However, due to Unfettered Market Access rules this labelling requirement will not apply to qualifying goods moving from Northern Ireland to Great Britain.

There are 28 questions in total which seek views on the implementation of the policy in the following areas:

  • Your or your business’ trade within the UK Internal Market – in particular with NI
  • How you would expect to see this policy enforced
  • How you’re already preparing, or will prepare, to introduce these requirements
  • Any challenges you might face in introducing these requirements, and how you see this being managed
  • Expected impacts (including costs and benefits)
  • Where you think targeted exemptions may help to ensure these requirements are implemented effectively, for example exemptions for types of product or types of business

Whilst many questions provide multiple choice answers there are others which really are worth spending some time on, and those are the ones where you are asked to provide explanations to substantiate your answers or data as to the impact of such proposals, for example Q8, 12b, 13, 14 and 15 onwards. Whist the BFFF have represented members views in previous months, this is now your chance to evidence what we have been saying and ensure your thoughts and concerns are heard loud and clear.

Defra would prefer to receive responses through their Citizen Space platform here, although you will see at the bottom of the page, that pdf’s of the consultation have been provided should you prefer to answer via email. We have also transferred the consultation over to word format should you find it easier to work with. This can be accessed here.

Email responses should be sent to markingofretailgoods.consultation@defra.gov.uk

This consultation will close on 15 March 2024.

FROM PLAIN BOXES TO PRIME BRANDING: SMURFIT KAPPA’S INSULATED PACKAGING REVOLUTIONISES SUPPLY CHAIN FOR BOROUGH BROTH

Borough Broth is a London-based, award-winning producer of organic, slow-cooked, and impeccably seasoned bone broths. The business champions sustainability, crafting their broths from ingredients sourced exclusively from Soil Association Organic farms across the UK. Their commitment to British organic suppliers reflects a profound dedication to high animal welfare standards, wildlife preservation, and combating climate change. This dedication to sustainability isn’t just a choice; it’s their essence, creating flavours that nourish while respecting the planet.

Borough Broth turned to Smurfit Kappa as they were experiencing a series of packaging challenges. Despite supplying premium bone broths to renowned brands such as Waitrose, Holland & Barrett, and Ocado, their products were initially packaged in nondescript boxes lacking distinctive branding. The use of sheep’s wool insulation in their boxes to maintain the broths’ temperature raised concerns about the packaging’s environmental impact. Additionally, issues with efficiency arose as their existing packaging occupied excessive warehouse space and, didn’t align with the brand’s commitment to delivering high-quality products in the most sustainable way possible.

The talented team at Smurfit Kappa Beacon was able to provide Borough Broth with a sustainable thermal packaging solution that not only eliminated the need for wool insulation but also offered valuable branding opportunities. Moreover, this innovative packaging solution freed up precious space in the Borough Broth warehouse, helping to streamline operations and reinforce their dedication to the environment.

Beyond better packaging

Borough Broth’s previous packaging, characterised by plain boxes containing wool insulation, presented several challenges. Firstly, the lack of distinctive branding on their packaging failed to represent the stand-out brand and showcase the premium quality of the products inside. The use of wool insulation, while effective, wasn’t the most sustainable choice when compared to corrugated cardboard alternatives that could still hold products at the desired temperatures during transit. The previous packaging also occupied a significant amount of warehouse space and proved to be less efficient for both packing and shipping due to the use of the wool insulation and the number of components used to package their products.

Clever thinking and creative solutions

Our packaging experts identified the pressing need to keep Borough Broth’s precious products at the correct temperature throughout transit. With Smurfit Kappa Beacon’s innovative insulated packaging solution, the customer was able to distribute their products regionally and nationally via DPD, ensuring quality preservation by maintaining temperatures between 5-8°C upon delivery.

There was also the need to optimise precious warehouse space for the customer. The Beacon design team played a pivotal role in crafting an economical variant of insulated packaging. This creative solution employed thinner materials and fewer components, all while upholding exceptional thermal performance throughout the supply chain, resulting in significant space and cost savings.

What adds a remarkable dimension to this case is the transition from a single standard cardboard food box to two custom solutions – 0216 style and 0711 style – each offering four distinctive prints. Moving away from plain cases to printed cases, has enabled Borough Broth to notably amplify their brand awareness.

Wider impact of packaging

The adoption of corrugated thermal packaging allowed Borough Broth to remove the need for wool insulation which enabled ease of construction, helped to reduce costs, and ensured the end user could dispose of the packaging easily through kerbside recycling. Borough Broth’s progress was nothing short of remarkable, with a yearly growth rate of over 100%, marked by new listings, media attention, and surging order numbers. Additionally, this transition effectively addressed customer concerns regarding recyclability, especially in terms of replacing sheep’s wool insulation in the packaging.

Borough Broth didn’t just find satisfaction; they were thrilled with the invaluable support they received from Smurfit Kappa Beacon throughout this journey. This partnership stands as a testament to the transformative potential of innovative packaging solutions in enhancing a brand’s identity, driving sales, and contributing to sustainability objectives.

“We’re absolutely delighted, the support of Smurfit Kappa has been immeasurable on this journey” – Rick Stratman, General Manager at Borough Broth.

Marc Holland, Business Development Manager at Smurfit Kappa Beacon reflects “Tapping into creative ideas from our talented Design Team, shaping these and coming up with new ones is key to product development and manufacturing innovations that will provide our customers with choice, quality, and value. This creative thinking is crucial for our future success.”

A game-changing solution

The ground-breaking thermal packaging solution marked a pivotal moment for Borough Broth, reshaping their trajectory. In tackling initial packaging hurdles and presenting a more effective, eco-friendly, and branded alternative, Smurfit Kappa not only contributed to Borough Broth’s growth but also elevated customer satisfaction.

Borough Broth’s experience serves as a powerful illustration of the significance of innovative packaging within the food industry and the profound impact that a strategic partnership can have in achieving outstanding results within a competitive market.

If you’re in search of insulated packaging solutions that can revolutionise your business, get in touch today.

TREND CATCHER SPRING/SUMMER 2024

Trend Catcher is our bi-annual report, tracking the prominence of insights & trends, allowing us to stay ahead of the curve, and catch the waves of future growth. 

https://issuu.com/dawnfarms/docs/dawn_farms_trend_catcher_spring_summer_2024?fr=sOWFlNTYyOTcwNjI

INDUSTRY LAUNCHES TRAILBLAZING TRANSPORT REFRIDGERATION APPRENTICESHIP

On Tuesday, January 16th, Marshall Fleet Solutions hosted an industrywide event marking the launch of the UK’s
first dedicated apprenticeship for the transport refrigeration industry.

Approved for delivery following a two-and-a-half year process spearheaded by Marshall Fleet Solutions and
several partners within an initial “trailblazer” group, the Mobile Transport Refrigeration Technician apprenticeship has been designed from the ground up to develop all the knowledge, skills and behaviours required in order to install, service and repair transport refrigeration units.

The course can be delivered across the UK on an industry-wide basis, enabling transport refrigeration companies
and fleet operators of all sizes to work with training providers to develop their own teams of fully qualified in-house engineers and technicians.

Taught and assessed in partnership with accredited training providers, the course will typically take 36 months,
with an end point assessment (EPA) period of four months.

Speaking at today’s event, Marshall Fleet Solutions Managing Director Mark Howell remarked, “This new apprenticeship is a much-needed replacement for an outdated, complicated setup that contained gaps and often lacked relevance.

“With this new programme, we have finally achieved proper recognition of the crucial work being done by the
talented people who are ultimately ensuring an uninterrupted supply of food and medicine in the UK.

“I’m grateful to our partners within the industry and education sector for their support in developing this
comprehensive apprenticeship standard, and to the government for acknowledging the specific need for such
an apprenticeship.”

Members of the apprenticeship trailblazer group include Morrisons, Petit Forestier, Nagel-Langdon, Turners of
Soham, Coolmax, Michael Ward Refrigeration, Peter Staines Refrigeration, TIP Group, and Tesco. Reflecting the widespread support for the apprenticeship, the launch event was attended by transport refrigeration service providers, fleet operators and training providers.

Also in attendance were representatives from City of Liverpool College, who proved instrumental in developing
course content alongside Marshall Fleet Solutions and its trailblazer partners.

“We are proud to have partnered with industry to develop this pioneering and much-needed new qualification,” said Lynton Perry, Refrigeration, Air Conditioning and Heat Pump Sector Lead at City of Liverpool College.

“The apprenticeship has a broad appeal extending well beyond school leavers, and including adult learners considering a career change, as well as anyone seeking a flexible working package that fits in with their needs.” For its own intake, Marshall Fleet Solutions and City of Liverpool College aim to pilot the apprenticeship with up
to 10 apprentices starting in 2024.

More information on the Mobile Transport Refrigeration Technician apprenticeship can be found on the Institute
for Apprenticeships & Technical Education’s website

Member Benefits

Exclusive Partnership deals on key products and services:

  • BFFF energy deals and rates
  • Vypr member deals and introduction
  • Defib Plus deals
  • Company Shop – membership
  • Mentor – MHE training health check

Exclusive access to networking opportunities and events:

  • Meet the Buyer events (retail & foodservice)
  • Annual Business Conference with networking dinner
  • Specialist H&S and Technical Conferences
  • Special interest groups (packaging, frozen food temperatures)
  • Annual Lunch
  • Awards Night
Upcoming Events More Events
Sponsorship Packages

We offer a range of sponsorship opportunities to BFFF members across our events throughout the year, with flexible packages that can be tailored to suit your business objectives.

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