CFG
01/08 final
Letter dated 3 January
2007 from Foodaware to Mr David Gray, Food Hygiene Implementation
and Regions Division, Food Standards Agency
Dear Mr Gray
FSA consultation on the Draft Food Hygiene (England) (Amendment)
Regulations 2008
Foodaware members discussed this draft proposal at the Group meeting
on 6 December 2007. This consultation refers to England Regulations
2008 although the text says that Scotland, Wales and Northern Ireland
will make similar legislation. Members consider that, with considerable
trade in live animals and meat between the various parts of the
United Kingdom, it is essential for the same food safety rules to
apply.
1. Time limits for production
of minced meat after slaughter
FSA is seeking support for a proposal to disapply time limits set
out in the EU hygiene legislation for the production of minced meat
after slaughter. FSA considers these to be prescriptive, not based
on risk and contrary to the English tradition of ageing meat before
mincing. FSA states that the time limits have been carried over
from the former Directive 94/65 which lays down requirements for
minced meat production and marketing and was intended to take account
of the consumer preference to eat raw and lightly cooked minced
meat products in other Member States.
While Foodaware members acknowledge that this change in the application
of Community Regulations in the UK could provide more choice for
consumers, they questioned the need for this change and did not
consider that the consultation had demonstrated sufficient reasons
to justify it. Members noted that not all supermarkets hang beef
and were concerned that different groups of consumers in the UK
may choose to cook minced beef and beef products for differing lengths
of time depending on personal preference. Consumer habits in this
area vary and may have changed in recent years. As a result of the
proposed change in time limits, there may be an increase in risk
to consumers if the micro-biological quality of the meat on sale
falls. If the change in regulations takes place, FSA would need
to consider providing information on the cooking implications so
that consumers are aware of the change.
2. Exemption from requirement for low
throughput slaughterhouses to have facilities for detained meat
Although Foodaware has expressed concern about the loss of rural
abattoirs and the importance of being able to source food locally,
members wholly oppose this proposal which they consider is unacceptable
for the handling and supply of meat in the 21st century. They are
strongly of the view that all slaughterhouses should have refrigerated
facilities on site and oppose the introduction of national measures
to exempt small slaughterhouses from the requirement.
3. Exemption of low throughput slaughterhouses
from the requirement to have facilities for cleansing and disinfection
of vehicles
Foodaware is content with this proposal.
4. Special Health Mark for animals
subject to emergency slaughter
This is a sensible proposal to distinguish animals which have been
subject to emergency slaughter but whose meat is suitable for inclusion
in the food chain. It is important that the mark should also describe
what it means so that there is no possibility of confusion and the
meat cannot be exported.
We look forward to receiving feedback on the outcome of the consultation
in due course, and are content for our views to be made public.
Yours sincerely
Susan Knox
Chairman
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