CFG
06/05
Letter from Foodaware
dated 21 March 2005 to Michelle Bayliss, Primary Production Division,
Food Standards Agency:
Dear Ms Bayliss
FSA Consultation on the Future of Butcher Shop Licensing in England
Foodaware members would like to add their concerns to those of other
consumer and enforcement organisations, and have commented in detail
below. A number of our members strongly supported the introduction
of licensing following the Pennington Enquiry and consider that it
would be premature for this protection to be dropped without considerably
more justification than that which was presented in the consultation
document.
Specific Comments
Foodaware has strongly supported the application of HACCP principles
across the food chain from production and processing, to the point
of sale. We have also supported the European Commission’s hygiene
reforms and acknowledge the effort the Food Standards Agency has put
into encouraging HACCP training for small businesses. To that extent
we understand the FSA desire to treat all food businesses the same
by replacing the scheme for licensing butcher’s premises in
England with the new hygiene regulations.
The consultation document includes two proposed
options:
- to replace the existing regime with a new regime based on the
hygiene regulations, thereby removing the requirement for licensing
but retaining the obligation on butchers to register with the
local authority, or
- to continue the existing regime at an estimated cost of £130
million which the document suggests may not pass the better regulation
tests.
We regret that these seem to be based more on administrative and
cost considerations than on an assessment of risk and the public
health implications of change.
While we would not support the retention of expensive and unnecessary
legislation, the consultation does not assess the effectiveness
of the current regime, and does not consider whether there has been
any change in the public health risk from E. Coli and other pathogens
carried in or on meat. This is particularly regrettable given that
Option 1 would remove the requirement for butchers to undertake
mandatory food handler training and replace it with HACCP based
obligations. There are many small butcher’s shops in England,
and although they do not tend to cook meat on the premises as happens
in Scotland, most sell cooked meats alongside raw meat, and so the
public health risk is considerably higher than that from other food
premises. Supermarkets are generally able to segregate the staff
selling cooked and uncooked meat (although not fish) and so have
additional controls on site.
The Consultation document says that independent evaluations of butchers
licensing commissioned by the FSA show that licensing has been successful
in raising hygiene standards. However, without the discipline of
licensing these may slip and the emergency sanctions which allow
local authorities to close premises which pose a risk to human health
are not intended to deal with poor practice or lack of understanding
of hygiene and risk.
The volumes of meat sold by independent butchers may be small by
comparison with sales from large retailers. Any decision to remove
licensing should, however, be based on evidence that the present
regime has successfully raised standards of hygiene and training
in butchers’ shops and that licensing is no longer necessary.
Cost-cutting should not be the main driver for the cost of food
poisoning to individuals and on health budgets remains high.
We would strongly urge the FSA to ensure that the mandatory hygiene
training is retained even if Option 1 is recommended to government.
We have understood from enforcement authorities that registration
of food premises is a poor alternative to licensing, imposing administrative
burdens on Local Authorities but not giving them the power to require
food suppliers to meet certain standards before they trade and making
it more difficult to close unsatisfactory businesses down. The introduction
of Option 1 will also make enforcement potentially more costly if
the regulations are appropriately enforced on all meat traders and
butchers for the local authority will be expected to ensure compliance
but the license fee income will no longer be available.
Foodaware is content for this response to be made publicly available.
Yours sincerely
Foodaware
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